This document argues that without further instruction, the jury might convict Ms. Maxwell based on a constructive amendment or prejudicial variance from the indictment, which would violate her constitutional rights. It cites legal precedents to support this claim.
This legal document, dated December 27, 2021, is a filing addressed to Judge Alison J. Nathan regarding the trial of Ms. Maxwell. The filing argues that without specific jury instructions, there is a risk of the jury convicting Ms. Maxwell based on a 'constructive amendment' to the indictment, which would be a per se violation of her constitutional rights. The argument is supported by citing several legal precedents from the Second Circuit and the Southern District of New York.
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