DOJ-OGR-00021014.jpg
618 KB
Extraction Summary
4
People
1
Organizations
0
Locations
3
Events
3
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
618 KB
Summary
This legal document details a dispute between the Defendant and the Court regarding how to respond to a deliberating jury's note. The Defendant's initial proposed responses were deemed erroneous, and she later conceded a point about a return flight's potential connection to illegal sexual activity. The document outlines the Defendant's attempts to influence the jury's understanding through specific instructions and supplemental proposals.
People (4)
| Name | Role | Context |
|---|---|---|
| Defendant | Party in case |
The party whose proposed responses and arguments regarding jury instructions are being discussed.
|
| counsel | Legal representative |
Discussed the jury note with the Court; likely representing the Defendant.
|
| Parker | Defendant (in cited case) |
Defendant in the cited case 'United States v. Parker'.
|
| trial judge | Judge |
General reference to the role of a judge in handling jury communications, cited from *United States v. Parker*.
|
Organizations (1)
| Name | Type | Context |
|---|---|---|
| United States | government agency |
Party in the cited case 'United States v. Parker'.
|
Timeline (3 events)
Jury deliberations in a legal case, during which the jury sent a note to the Court.
jury
A return flight home, discussed in the context of whether it could aid and abet illegal sexual activity.
home
Relationships (3)
The Court discussed the jury note with counsel, and the Defendant then proposed responses, implying counsel represents the Defendant.
The document details disagreements between the Court and the Defendant on how to respond to a jury note and interpret instructions.
Court
→
legal/judicial
→
jury
The Court received a note from the deliberating jury and issued instructions to them.
Key Quotes (3)
"The trial judge is in the best position to sense whether the jury is able to proceed properly with its deliberations, and [s]he has considerable discretion in determining how to respond to communications indicating that the jury is experiencing confusion."Source
DOJ-OGR-00021014.jpg
Quote #1
"not for the purpose of illegal sexual activity."Source
— Defendant
(Defendant's argument regarding the purpose of a return flight.)
DOJ-OGR-00021014.jpg
Quote #2
"significant or motivating purpose."Source
DOJ-OGR-00021014.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (2,133 characters)
Case 22-1426, Document 58, 02/28/2023, 3475901, Page188 of 221
A-388
Case 1:20-cr-00330-AJN Document 657 Filed 04/29/22 Page 31 of 45
A-388
Case 1:20-cr-00330-AJN Document 657 Filed 04/29/22 Page 31 of 45
responding to a note from a deliberating jury is only required to answer the particular inquiries
posed."); see also United States v. Parker, 903 F.2d 91, 101 (2d Cir. 1990) ("The trial judge is in
the best position to sense whether the jury is able to proceed properly with its deliberations, and
[s]he has considerable discretion in determining how to respond to communications indicating
that the jury is experiencing confusion."). The jury was free to send a clarifying or further note
following the Court's instruction.
posed."); see also United States v. Parker, 903 F.2d 91, 101 (2d Cir. 1990) ("The trial judge is in
the best position to sense whether the jury is able to proceed properly with its deliberations, and
[s]he has considerable discretion in determining how to respond to communications indicating
that the jury is experiencing confusion."). The jury was free to send a clarifying or further note
following the Court's instruction.
By contrast, the Defendant failed to propose a legally accurate response for the jury. Her
proposed responses to the note on the day it was received and the following morning were
erroneous. At the time the Court received the note and discussed it with counsel, the Defendant
first proposed that the answer to the note's question was simply “no” because, she argued, a
return flight is for the purpose of returning home, “not for the purpose of illegal sexual activity.”
Trial Tr. at 3128–30. But the Court could not respond “no” to an ambiguous question. Id. at
3138. Moreover, the Defendant eventually conceded the principle that assistance with a return
flight home could aid and abet a trip that was for the purpose of illegal sexual activity. See id. at
3136. Alternatively, the Defendant requested that if the Court were to refer the jury to the
charge, that it direct the jury to lines 14 to 17 of Instruction No. 21, which instructed on
“significant or motivating purpose.” Id. at 3131. But it was unclear that those particular lines
addressed the jury's question, and the Court's decision to refer the jury to the entirety of
Instruction No. 21 encompassed those lines.
proposed responses to the note on the day it was received and the following morning were
erroneous. At the time the Court received the note and discussed it with counsel, the Defendant
first proposed that the answer to the note's question was simply “no” because, she argued, a
return flight is for the purpose of returning home, “not for the purpose of illegal sexual activity.”
Trial Tr. at 3128–30. But the Court could not respond “no” to an ambiguous question. Id. at
3138. Moreover, the Defendant eventually conceded the principle that assistance with a return
flight home could aid and abet a trip that was for the purpose of illegal sexual activity. See id. at
3136. Alternatively, the Defendant requested that if the Court were to refer the jury to the
charge, that it direct the jury to lines 14 to 17 of Instruction No. 21, which instructed on
“significant or motivating purpose.” Id. at 3131. But it was unclear that those particular lines
addressed the jury's question, and the Court's decision to refer the jury to the entirety of
Instruction No. 21 encompassed those lines.
The following day, although the jury had not sought further clarification, the Defendant
took another pass at proposing an additional response to the note. She requested a three-
paragraph supplemental instruction that referenced elements of Counts Two and Four. See Dkt.
took another pass at proposing an additional response to the note. She requested a three-
paragraph supplemental instruction that referenced elements of Counts Two and Four. See Dkt.
31
DOJ-OGR-00021014
DOJ-OGR-00021014
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