mirror-epstein-docs/results/IMAGES005/DOJ-OGR-00014355.json

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  "full_text": "Case 1:20-cr-00330-PAE Document 765 Filed 08/10/22 Page 51 of 95 2789 LCI1MAX1\n\n1 MR. EVERDELL: Oh, yeah. Agreed, your Honor.\n2 MR. ROHRBACH: Yes.\n3 THE COURT: What do you have, Mr. Everdell?\n4 MR. EVERDELL: So this is where it gets a little complicated, your Honor. I mean, I know that in lines 11 through 22 we're listing -- and in the next page as well, we're listing out the overt acts in the indictment. We're listing them verbatim, but they're talking about ages, under the age of 18, under the age of 18, and we've already talked about how the ages are sort of different depending on the statutes. That's one issue. Right. So we might want to replace the -- instead of the ages -- and I know -- it's less of an issue because I think we've agreed that the indictment is not going back to the jurors, so they're not going to be reading the language, but maybe instead of \"under the age of 18,\" \"when Jane was under the relevant age of consent in the relevant jurisdiction,\" or something to that effect.\n18 MR. ROHRBACH: Your Honor, if I may. I understand the concern the defense is raising. I think for Counts One and Three, since the relevant age of consent I think everyone agrees is 17, the government would be fine with saying \"under the age of 17,\" and we'd have to say \"the indictment alleges\" or something like that, because it would no longer be following the text of the indictment.\n24 THE COURT: Yes. I mean, we could do \"alleges\" or\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
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      "content": "1 MR. EVERDELL: Oh, yeah. Agreed, your Honor.\n2 MR. ROHRBACH: Yes.\n3 THE COURT: What do you have, Mr. Everdell?\n4 MR. EVERDELL: So this is where it gets a little complicated, your Honor. I mean, I know that in lines 11 through 22 we're listing -- and in the next page as well, we're listing out the overt acts in the indictment. We're listing them verbatim, but they're talking about ages, under the age of 18, under the age of 18, and we've already talked about how the ages are sort of different depending on the statutes. That's one issue. Right. So we might want to replace the -- instead of the ages -- and I know -- it's less of an issue because I think we've agreed that the indictment is not going back to the jurors, so they're not going to be reading the language, but maybe instead of \"under the age of 18,\" \"when Jane was under the relevant age of consent in the relevant jurisdiction,\" or something to that effect.\n18 MR. ROHRBACH: Your Honor, if I may. I understand the concern the defense is raising. I think for Counts One and Three, since the relevant age of consent I think everyone agrees is 17, the government would be fine with saying \"under the age of 17,\" and we'd have to say \"the indictment alleges\" or something like that, because it would no longer be following the text of the indictment.\n24 THE COURT: Yes. I mean, we could do \"alleges\" or",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
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