📧 Communication

This legal document, page 22 of a court filing from February 25, 2022, presents the prosecution's argument against the defendant's claim of a constructive amendment to their indictment. The prosecution asserts that the S2 Indictment for Mann Act offenses was consistent with the evidence presented and jury instructions, citing the D'Amelio case. A footnote further argues that even if one count was flawed, based on jury notes concerning Annie Farmer's testimony about abuse in New Mexico, it would not invalidate the other conspiracy counts, citing the Pfaff and Milstein cases.