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691 KB
Extraction Summary
4
People
2
Organizations
0
Locations
3
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal document
File Size:
691 KB
Summary
This legal document, filed on April 29, 2022, details a dispute during a trial over how to respond to a note from a deliberating jury. The Defendant proposed several responses, which the Court deemed legally erroneous, including a simple 'no' and later a request to direct the jury to specific lines of an instruction. The core issue revolves around the Defendant's argument concerning the purpose of a return flight in relation to illegal activity and the Court's discretion in guiding the jury.
People (4)
| Name | Role | Context |
|---|---|---|
| Parker |
Mentioned in the case citation 'United States v. Parker, 903 F.2d 91, 101 (2d Cir. 1990)'.
|
|
| Defendant | Defendant |
The subject of the document, who proposed responses to a jury note that were deemed erroneous by the Court.
|
| counsel | Legal Counsel |
Mentioned as having discussed the jury's note with the Court and the Defendant.
|
| trial judge | Judge |
Quoted from the 'United States v. Parker' case regarding their discretion in responding to jury communications.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Court | government agency |
The judicial body presiding over the case, which received a note from the jury and disagreed with the Defendant's pro...
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| United States Court of Appeals for the Second Circuit | government agency |
Referenced by the citation '(2d Cir. 1990)' in the case 'United States v. Parker'.
|
Timeline (3 events)
A jury was deliberating and sent a note to the court with a question.
Court
jury
A hypothetical return flight is discussed in the context of whether it could aid and abet a trip for the purpose of illegal sexual activity.
Relationships (2)
The document details a disagreement between the Defendant and the Court on how to properly respond to a jury's note, with the text stating the Defendant's proposed responses were 'erroneous'.
Key Quotes (4)
"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
— United States v. Parker case
(A quote from a 1990 court case cited to support the trial court's discretion in handling jury questions.)
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Quote #1
"no"Source
— Defendant
(The Defendant's first proposed answer to the jury's question.)
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Quote #2
"not for the purpose of illegal sexual activity."Source
— Defendant
(The Defendant's argument for why the answer to the jury's question should be 'no', relating to the purpose of a return flight.)
DOJ-OGR-00010397.jpg
Quote #3
"significant or motivating purpose."Source
— Instruction No. 21
(A phrase from a jury instruction that the Defendant requested the Court to direct the jury's attention to.)
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,079 characters)
Case 1:20-cr-00330-PAE 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.
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.
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.
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.
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.
31
DOJ-OGR-00010397
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