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696 KB
Extraction Summary
5
People
1
Organizations
2
Locations
3
Events
2
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
696 KB
Summary
This legal document page details the court's reasoning for rejecting the Defendant's proposed jury instructions. The court argues that it correctly instructed the jury on the sole predicate offense under New York Penal Law, avoiding confusion that the Defendant's proposals regarding other jurisdictions' laws and specific witness testimonies (from Kate, Annie, and Jane) would have created. The document concludes that the Defendant's claim of potential jury error, specifically regarding conduct in New Mexico versus New York, is speculative and implausible.
People (5)
| Name | Role | Context |
|---|---|---|
| Kate | Witness |
Mentioned in relation to her testimony, for which the Defendant requested limiting instructions.
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| Annie | Witness |
Mentioned in relation to her testimony, for which the Defendant requested limiting instructions.
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| Jane | Witness |
Mentioned in relation to her testimony about New Mexico and travel to New York.
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| Joyner | Party in a cited case |
Mentioned in the case citation 'United States v. Joyner, 313 F.3d 40, 47 (2d Cir. 2002)'.
|
| Ms. Maxwell | Defendant |
Mentioned in a footnote as the subject of a proposed jury instruction regarding her intent for minors to engage in se...
|
Organizations (1)
| Name | Type | Context |
|---|---|---|
| The Court | government agency |
Mentioned as the body that rejected the Defendant's requests for jury instructions.
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Timeline (3 events)
Locations (2)
| Location | Context |
|---|---|
|
Referenced in relation to New York Penal Law, Jane's travel, and sexual conduct.
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|
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Referenced in relation to Jane's testimony and the location of alleged conduct.
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Relationships (2)
The document describes an adversarial legal relationship where the Defendant made requests for jury instructions that the Court rejected.
Jane is a witness whose testimony about travel and sexual conduct is being used in a case against the Defendant.
Key Quotes (3)
"illegal sexual activity as alleged in the indictment."Source
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Quote #1
"[t]o prove Counts One and Three, the government must establish beyond a reasonable doubt that Ms. Maxwell acted with the intent that the minors would engage in sexual activity for which any person can be charged with a criminal offense."Source
— Defendant's proposed instruction
(Quoted in a footnote from the Defendant's proposed jury instruction.)
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Quote #2
"[i]f the individual was at or above the age of consent in the relevant jurisdiction when the sexual activity occurred, then for the purposes of Counts One and Three, the sexual activity was not illegal."Source
— Defendant's proposed instruction
(Quoted in a footnote from the Defendant's proposed jury instruction regarding ages of consent in different jurisdictions.)
DOJ-OGR-00021017.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (2,578 characters)
Case 22-1426, Document 58, 02/28/2023, 3475901, Page191 of 221
A-391
Case 1:20-cr-00330-AJN Document 657 Filed 04/29/22 Page 34 of 45
A-391
Case 1:20-cr-00330-AJN Document 657 Filed 04/29/22 Page 34 of 45
ran the risk of moving the jury away from consideration of the core of criminality alleged in the
Indictment.⁸
Indictment.⁸
The appropriate approach was to instruct the jury on the one and only predicate state
offense for the Mann Act counts charged in the Indictment: New York Penal Law Section
130.55. For that reason, the Court also rejected the Defendant’s request to repeat in the charge
the limiting instructions as to Kate’s and Annie’s testimony and the Defendant’s request, raised
for the first time at the charging conference and well after completion of her testimony, to
include an unspecified limiting instruction as to Jane’s New Mexico testimony. Trial Tr. at
2773–77. During the witnesses’ testimony, the jury had yet to be instructed on the meaning of
“illegal sexual activity as alleged in the indictment.” But it was unnecessary to repeat the
limiting instructions alongside the charge’s definition of “illegal sexual activity.” Id. at 2774–75.
The jury now had that phrase clearly defined as a violation of New York Penal Law Section
130.55. In sum, the jury instructions charged that the jury could convict the Defendant only on
the predicate state offense of New York law. The jury is presumed to have followed these
instructions. See United States v. Joyner, 313 F.3d 40, 47 (2d Cir. 2002).
offense for the Mann Act counts charged in the Indictment: New York Penal Law Section
130.55. For that reason, the Court also rejected the Defendant’s request to repeat in the charge
the limiting instructions as to Kate’s and Annie’s testimony and the Defendant’s request, raised
for the first time at the charging conference and well after completion of her testimony, to
include an unspecified limiting instruction as to Jane’s New Mexico testimony. Trial Tr. at
2773–77. During the witnesses’ testimony, the jury had yet to be instructed on the meaning of
“illegal sexual activity as alleged in the indictment.” But it was unnecessary to repeat the
limiting instructions alongside the charge’s definition of “illegal sexual activity.” Id. at 2774–75.
The jury now had that phrase clearly defined as a violation of New York Penal Law Section
130.55. In sum, the jury instructions charged that the jury could convict the Defendant only on
the predicate state offense of New York law. The jury is presumed to have followed these
instructions. See United States v. Joyner, 313 F.3d 40, 47 (2d Cir. 2002).
At bottom, the Defendant asks the Court to speculate based on an ambiguous note that
the jury disregarded Jane’s substantial testimony about travel to New York and sexual conduct in
New York and further assumed a violation of New York law could be based on conduct only in
New Mexico. It is hardly plausible, let alone substantially likely, that this was the jury’s
the jury disregarded Jane’s substantial testimony about travel to New York and sexual conduct in
New York and further assumed a violation of New York law could be based on conduct only in
New Mexico. It is hardly plausible, let alone substantially likely, that this was the jury’s
⁸ The Defendant’s proposed instruction on other jurisdictions’ ages of consent first stated that “[t]o prove Counts
One and Three, the government must establish beyond a reasonable doubt that Ms. Maxwell acted with the intent
that the minors would engage in sexual activity for which any person can be charged with a criminal offense.”
Request to Charge at 51. It then instructed on the ages of consent in several jurisdictions and stated that “[i]f the
individual was at or above the age of consent in the relevant jurisdiction when the sexual activity occurred, then for
the purposes of Counts One and Three, the sexual activity was not illegal.” Id. at 52. This proposed instruction
would likely have created the confusion the Defendant raises now.
One and Three, the government must establish beyond a reasonable doubt that Ms. Maxwell acted with the intent
that the minors would engage in sexual activity for which any person can be charged with a criminal offense.”
Request to Charge at 51. It then instructed on the ages of consent in several jurisdictions and stated that “[i]f the
individual was at or above the age of consent in the relevant jurisdiction when the sexual activity occurred, then for
the purposes of Counts One and Three, the sexual activity was not illegal.” Id. at 52. This proposed instruction
would likely have created the confusion the Defendant raises now.
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DOJ-OGR-00021017
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