📧 Communication

This document is page 4 of a legal submission to Judge Alison J. Nathan (dated Dec 27, 2021) in the case of United States v. Ghislaine Maxwell. The text argues that the jury must be instructed not to convict Maxwell on Count Four based on the victim 'Jane's' travel to New Mexico, as the indictment specifically charged travel to New York. The defense contends that a conviction based on the New Mexico events would constitute a 'constructive amendment' or 'variance' from the indictment, which is reversible error.