The defense sent a letter requesting the Court to provide an additional jury instruction to prevent conviction on Mann Act counts based on a constructive amendment or prejudicial variance.
This legal document, filed on February 11, 2022, details the defense's request for an additional jury instruction concerning Mann Act counts, arguing against conviction based solely on New Mexico conduct. The Court declined this instruction, and the jury subsequently convicted Ms. Maxwell on Count Four, with charges also in Counts One and Three. The document also cites applicable law regarding constructive amendments, defining them and explaining their impact on a defendant's Grand Jury Clause rights.
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