Request for additional jury instructions regarding Counts Two and Four based on a jury note.
This document is a legal letter dated December 27, 2021, from defense attorney Christian R. Everdell to Judge Alison J. Nathan during the trial of United States v. Ghislaine Maxwell. The defense requests additional jury instructions to clarify 'apparent errors' in the jury's understanding of Count Four, specifically regarding whether aiding in a return flight (rather than the flight to the location of sexual activity, such as New Mexico) constitutes guilt. The letter references a specific jury note (Court Exhibit #15) and cites the indictment regarding transportation from Florida to New York for sexual acts with Jeffrey Epstein.
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