circuit it is clear that an expert cannot testify on an ultimate issue of law and cannot simply be used as a vehicle to get in the government's closing argument that's exactly what happened in this case at trial the heart of this case was really free will mr taylor at every stage argued that each of the women who worked for him made a choice of their own free will to work as prostitutes and that they need a choice of their own free will to have an contested that he was guilty of the crime of promotion of prostitution there was some evidence of course that was put out of the trial that he was guilty of domestic violence but the core of his defense at trial was that these four women who were new to the indictment at all times were acting of their own free will and they get they did not work as prostitutes because they were forced to drop it or horsed into doing so now the government's witness turn a derby  women to work for them counsel is that only a legal opinion though you are arguing it partly used in your briefing busses legal issue but it sounds much more like the factual description of prostitution and that is a separate crime what she talked about is the let's assume this were a murder case for example and the defendant was contending that he was guilty of nd degree murder and the government puts out an who says hey i was a homicide detective for twenty five years and i can tell you that if anybody ever picks up a gun and shoots somebody they're doing that with deliberation that's the that's a legal  and basically equated the two things even though they're separate terms for from a legal standpoint of him it is simply somebody who makes money off of promoting prostitution that she may be wrong but it doesn't sound to me as a so she is giving us a legal conclusion if the problem comes in a way because the words she is using the ordinary english words also are the words that overlap with  legal standard but she needs these the ordinary words well the difficulty is it in cases in which expert with this is used terms that are not commonly understood if they are using them and defining them that's exactly what's prohibited that is giving an opinion on the ultimate legal issue and in this case yes she was wrong but the problem is that she was she came  with a lot of history of working in this field and she had an impressive resume and she told the jury something that she wasn't qualified to say which was that there was no difference between a pimp and a sex trafficker that was never said anything of the kind and then there was some confusion about that because a defense questioning and as closing argument so that only come how did the problem but the main problem is that this witness took a legal any of these women had not been subjected to force from that coercion and particularly with respect to the victim elsie who was in her that it may have made a perfectly reasonable decision that she wanted heroin and she was willing to prostitute and mr taylor and his helpers get her heroin she could have made that as a perfectly rational freewill decision but had the jury believe that a seizure that might be constitutional is at its inception can become a reasonable if there is too long to delay between the seizure and the search of the items it counsel even if we assume that t on the other phones as well and so what is the marginal relevance or additional evidence that would that came from the fall that in your view could make any difference in the trial well it was mostly relevant to the minor age as and the result is that one of the text messages that was on the phone which the government referred to over and over and over again w text message from mr taylor to his brother carl they did not have carl's bone they only had mr taylor's phone and it said i'm taking a twenty year chance or you grow something and something along those lines which was used as and what she told people and what evidence they her age certainly even they're cooperating with those who was under immunity and said now i know everybody was convinced this girl was thought that that was that was quite damning evidence particularly given how and how much inconsistent testimony h s had given as demonstrated by her own text messages just as money for the grand jury the other thing that was on it was a lot as which was the recent conflicting testimony on that as well edges it does it to the extent that eight was much more independent than the other prostitutes she was she was considered the bottom as in the parlance of prostitution so and earth i just know that are no other question from the expert testimony on kids except for one or two is i think not material to the argument it was clear that she meant that pimps use or sprung horrors in and our sex traffickers and there's no difference however legally there is obviously if you look at washington statutes there are different categories and one of them is a person who promotes prostitution that is published in a much lower rate than being a sex trafficker there's also a federal crime of course of promoting prostitution as long as there's an interstate elena's so they are two different two different of as is and it was improper for an expert witness to equate those because that's a legal question secondly with regard  answer that question the testimony from d k with him admitting things after the fact are very different than what he knew at the time that agents went up to one and she certainly he found out when she was arrested that she was under age he heard all about that because he was at the neighboring hotel so anything he said after that would have been self serving to try to say hey i didn't know she was seventeen or i thought she was seventeen or i got she was seventeen and that's why i didn't want to have anything to do with her or whatever but the the relevant universe of time is at the time that he agreed to send her when she with and have her prostitute the nd thing is th not under age there may have been any other reasons why they used other people's photographs but it doesn't make logical sense that they would have done that because she looks somehow under age when she was only a few months away from it turning eighteen and i only point that out just because there really wasn't that much evidence that taylor knew that she was under age and certainly the evidence from age has was conflicting and she was not a credible witness and of course always maintain that nobody knew that she was under eighteen so the evidence of age was actually not overwhelm me other than that i think the one thing i'd like to correct from my nose br