mirror-epstein-docs/results/IMAGES005/DOJ-OGR-00014366.json

{
  "document_metadata": {
    "page_number": "62 of 95",
    "document_number": "765",
    "date": "08/10/22",
    "document_type": "court transcript",
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    "has_stamps": false
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  "full_text": "Case 1:20-cr-00330-PAE Document 765 Filed 08/10/22 Page 62 of 95 2800 LCIAMAX2ps\n\nSecond of all, there are particular factual knowledge elements that the defense is contesting. One is her knowledge of the age of the victim. Another is her mens rea with regard to the purposes of travel. And so for those things the jury could reasonably conclude that she had sufficient -- that she was engaging in conscious avoidance as to those particular facts.\n\nSo, for example, to take the knowledge of age issue, the defense has elicited testimony from several witnesses that the defendant could not, was not aware that the various victims were minors. The jury could conclude that she in fact did have that knowledge. The jury could also conclude that she consciously avoided having that knowledge. Those are both reasonable theories available for the jury for which there is an adequate factual predicate in the record, your Honor.\n\nMR. EVERDELL: Your Honor, I think this is inviting the jury, by considering the conscious avoidance charge, to convict on an improper basis that she must have known.\n\nTHE COURT: Could you just respond to the specific argument, because I think you started by saying there's been no contention as to a lack of knowledge with respect to any aspect of the crimes charged. So the specific contention and the reason I had in my head to include it rather than not include it -- which, for reasons you've indicated, is a case-by-case analysis depending on what factual issues are in play. But on\n\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00014366",
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      "content": "Case 1:20-cr-00330-PAE Document 765 Filed 08/10/22 Page 62 of 95 2800 LCIAMAX2ps",
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      "content": "Second of all, there are particular factual knowledge elements that the defense is contesting. One is her knowledge of the age of the victim. Another is her mens rea with regard to the purposes of travel. And so for those things the jury could reasonably conclude that she had sufficient -- that she was engaging in conscious avoidance as to those particular facts.",
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      "content": "So, for example, to take the knowledge of age issue, the defense has elicited testimony from several witnesses that the defendant could not, was not aware that the various victims were minors. The jury could conclude that she in fact did have that knowledge. The jury could also conclude that she consciously avoided having that knowledge. Those are both reasonable theories available for the jury for which there is an adequate factual predicate in the record, your Honor.",
      "position": "middle"
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    {
      "type": "printed",
      "content": "MR. EVERDELL: Your Honor, I think this is inviting the jury, by considering the conscious avoidance charge, to convict on an improper basis that she must have known.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "THE COURT: Could you just respond to the specific argument, because I think you started by saying there's been no contention as to a lack of knowledge with respect to any aspect of the crimes charged. So the specific contention and the reason I had in my head to include it rather than not include it -- which, for reasons you've indicated, is a case-by-case analysis depending on what factual issues are in play. But on",
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    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "content": "DOJ-OGR-00014366",
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      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "dates": [
      "08/10/22"
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      "1:20-cr-00330-PAE",
      "765",
      "DOJ-OGR-00014366"
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  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
}