DOJ-OGR-00016950.jpg
579 KB
Extraction Summary
4
People
2
Organizations
1
Locations
2
Events
2
Relationships
3
Quotes
Document Information
Type:
Court transcript
File Size:
579 KB
Summary
This document is page 24 of a court transcript from Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell), filed on August 10, 2022. Defense attorney Mr. Everdell is arguing for specific jury instructions regarding the definition of 'persuasion,' 'inducement,' and 'enticement' based on the precedent *U.S. v. Broxmeyer*. He proposes language stating that these elements are only satisfied if they specifically *caused* the victim, referred to as 'Jane,' to travel in interstate commerce.
People (4)
| Name | Role | Context |
|---|---|---|
| Mr. Everdell | Defense Attorney |
Arguing for specific jury instruction language regarding causation and definitions of inducement.
|
| The Court | Judge |
Presiding over the hearing, reviewing the cited case law (AJN refers to Alison J. Nathan).
|
| Mr. Rohrbach | Prosecutor |
Begins to speak/object at the bottom of the page.
|
| Jane | Victim/Witness (Pseudonym) |
Mentioned in the proposed jury instruction regarding travel in interstate commerce.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Southern District Reporters, P.C. |
Footer information.
|
|
| DOJ |
Indicated in the document stamp code DOJ-OGR-00016950.
|
Timeline (2 events)
Locations (1)
| Location | Context |
|---|---|
|
Implied by 'Southern District Reporters' and the case number format.
|
Relationships (2)
Direct dialogue in transcript.
Everdell proposing legal language narrowing the definition of how Jane was induced to travel.
Key Quotes (3)
"This element is satisfied only if the 'persuasion,' 'inducement,' or 'enticement' caused Jane to travel in interstate commerce as alleged in the indictment."Source
DOJ-OGR-00016950.jpg
Quote #1
"the words 'persuade,' 'induce,' and 'entice' are words of causation and they need to cause an effect"Source
DOJ-OGR-00016950.jpg
Quote #2
"We understand that's been overruled by the Court."Source
DOJ-OGR-00016950.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (1,460 characters)
Case 1:20-cr-00330-AJN Document 765 Filed 08/10/22 Page 24 of 95 2762
LCI1MAX1
LCI1MAX1
1 word "coerced" we would like to remove. We understand that's
2 been overruled by the Court.
3 Okay. But there is some additional language we would
4 propose at the end of line 6, and this is something that I
5 raised I think in a letter submission in -- or not in a
6 letter -- orally at the Rule 29 argument. It's based on U.S.
7 v. Broxmeyer, which, as I argued to the Court at the Rule 29
8 argument, the words "persuade," "induce," and "entice" are
9 words of causation and they need to cause an effect, and so
10 what we would propose after the sentence, "The terms
11 'persuaded,' 'induced,' 'enticed,' and 'coerced' have their
12 ordinary, everyday meanings," we would propose adding the
13 following language: "This element is satisfied only if the
14 'persuasion,' 'inducement,' or 'enticement' caused Jane to
15 travel in interstate commerce as alleged in the indictment."
16 We're basing that on U.S. v. Broxmeyer, interpreting those
17 words from a different but related statute.
18 THE COURT: Give me one moment.
19 MR. EVERDELL: I have a copy of Broxmeyer, your Honor,
20 if you'd like to see it.
21 THE COURT: Sure. I'll take it.
22 MR. EVERDELL: Your Honor, I believe it's on page 125
23 of the opinion.
24 THE COURT: Okay. The relevant language.
25 MR. ROHRBACH: Your Honor, this is not just a
2 been overruled by the Court.
3 Okay. But there is some additional language we would
4 propose at the end of line 6, and this is something that I
5 raised I think in a letter submission in -- or not in a
6 letter -- orally at the Rule 29 argument. It's based on U.S.
7 v. Broxmeyer, which, as I argued to the Court at the Rule 29
8 argument, the words "persuade," "induce," and "entice" are
9 words of causation and they need to cause an effect, and so
10 what we would propose after the sentence, "The terms
11 'persuaded,' 'induced,' 'enticed,' and 'coerced' have their
12 ordinary, everyday meanings," we would propose adding the
13 following language: "This element is satisfied only if the
14 'persuasion,' 'inducement,' or 'enticement' caused Jane to
15 travel in interstate commerce as alleged in the indictment."
16 We're basing that on U.S. v. Broxmeyer, interpreting those
17 words from a different but related statute.
18 THE COURT: Give me one moment.
19 MR. EVERDELL: I have a copy of Broxmeyer, your Honor,
20 if you'd like to see it.
21 THE COURT: Sure. I'll take it.
22 MR. EVERDELL: Your Honor, I believe it's on page 125
23 of the opinion.
24 THE COURT: Okay. The relevant language.
25 MR. ROHRBACH: Your Honor, this is not just a
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
(212) 805-0300
DOJ-OGR-00016950
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