📧 Communication

This document is page 12 of a defense filing (Document 647) dated March 11, 2022, in the case against Ghislaine Maxwell. The text argues that the jury instructions were insufficient and led to a 'constructive amendment' of the indictment, potentially allowing the jury to convict Maxwell based on activity in New Mexico rather than the required New York jurisdiction. It highlights a 'Jury Note' demonstrating the jury's confusion regarding Count Four and the application of New York Penal Law Section 130.55.