📧 Communication

This legal document is part of a court filing arguing that the government's summation during a trial did not constructively amend the indictment. The prosecution consistently maintained that the defendant and an associate, Epstein, transported underage girls like "Jane" to New York with the intent for them to be sexually abused there. The defense counters that a jury note suggests the conviction was based on intent for activity in New Mexico, not New York, and that the court erred by not providing a supplemental instruction to clarify this point.