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686 KB
Extraction Summary
5
People
4
Organizations
1
Locations
2
Events
1
Relationships
4
Quotes
Document Information
Type:
Legal document
File Size:
686 KB
Summary
This legal document, part of a court filing from December 2021, presents an argument from Ms. Maxwell's defense to Judge Alison J. Nathan. The defense contends that a supplemental jury instruction given by the court was incorrect and prejudicial, citing multiple Second Circuit precedents to argue that confusing or misleading instructions at a critical stage of deliberation can be grounds for reversal. The filing asserts that this error applies to multiple counts and requests a curative instruction.
People (5)
| Name | Role | Context |
|---|---|---|
| Alison J. Nathan | The Honorable |
The document is addressed to 'The Honorable Alison J. Nathan'.
|
| Ms. Maxwell | Defendant |
Mentioned as the individual to whom the Court's response was prejudicial. The footnote discusses the conditions for h...
|
| Kopstein |
Party in a cited legal case, 'United States v. Kopstein'.
|
|
| Lefkowitz |
Party in a cited legal case, 'United States v. Lefkowitz'.
|
|
| Hudson |
Party in a cited legal case, 'Hudson v. New York City'.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| The Court | judiciary |
Referred to as the entity that must give jury instructions and whose response to a jury note is being challenged.
|
| Second Circuit | government agency |
Cited as the source of legal precedent regarding jury instructions.
|
| Nat'l R.R. Passenger Corp. | company |
A party in a cited legal case, 'Nat’l R.R. Passenger Corp. v. One 25,900 Square Foot More or Less Parcel of Land'.
|
| New York City | government agency |
A party in a cited legal case, 'Hudson v. New York City'.
|
Timeline (2 events)
The jury interrupted its deliberations to seek further explanation of the law, which the document describes as a 'critical moment in a criminal trial'.
jury
Court
The Court provided a response to a jury note, which the defense argues was a substantively incorrect and prejudicial supplemental jury instruction.
Court
jury
Locations (1)
| Location | Context |
|---|---|
|
Mentioned in the footnote as the state where sexual activity must have been intended to occur for a conviction on cer...
|
Relationships (1)
The document is a legal filing from Ms. Maxwell's defense team addressed to Judge Nathan, who is presiding over her case.
Key Quotes (4)
"A jury’s interruption of its deliberations ‘to seek further explanation of the law’ is a ‘critical moment in a criminal trial’; and [the Second Circuit] therefore ascribe[s] ‘crucial importance’ to a ‘completely accurate statement by the judge’ at that moment."Source
— Second Circuit (via United States v. Kopstein)
(Used to emphasize the significance of the jury's question and the need for a perfectly accurate response from the judge.)
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Quote #1
"Instructions are erroneous if they mislead the jury as to the correct legal standard or do not adequately inform the jury of the law."Source
— Second Circuit (via Hudson v. New York City)
(Cited to define what constitutes an erroneous jury instruction.)
DOJ-OGR-00008794.jpg
Quote #2
"Reversal is “required where, based on a review of the record as a whole, the error was prejudicial or the charge was highly confusing.”"Source
— Second Circuit (via Kopstein)
(Quoted to establish the legal standard for when an erroneous instruction requires the verdict to be reversed.)
DOJ-OGR-00008794.jpg
Quote #3
"A charge that appears likely to have left the jury ‘highly confused’ may, on that ground alone, be reversed."Source
— Second Circuit (via Nat’l R.R. Passenger Corp. v. One 25,900 Square Foot More or Less Parcel of Land)
(Used to argue that confusion caused by the jury instruction is sufficient grounds for reversal.)
DOJ-OGR-00008794.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (2,120 characters)
Case 1:20-cr-00330-PAE Document 566 Filed 12/28/21 Page 5 of 7
The Honorable Alison J. Nathan
December 27, 2021
Page 5
December 27, 2021
Page 5
a curative instruction. Moreover, because the same issues arise with respect to the substantive
enticement offense charged in Count Two, the Court must give the same instruction as to Count
Two as well.¹
enticement offense charged in Count Two, the Court must give the same instruction as to Count
Two as well.¹
Supplemental Jury Instruction
Second, we believe that the Court’s response to the jury note was substantively incorrect
and prejudicial to Ms. Maxwell. “A jury’s interruption of its deliberations ‘to seek further
explanation of the law’ is a ‘critical moment in a criminal trial’; and [the Second Circuit] therefore
ascribe[s] ‘crucial importance’ to a ‘completely accurate statement by the judge’ at that moment.”
United States v. Kopstein, 759 F.3d 168, 172 (2d Cir. 2014) (quoting United States v. Lefkowitz,
284 F.2d 310, 314 (2d Cir. 1960)). “Instructions are erroneous if they mislead the jury as to the
correct legal standard or do not adequately inform the jury of the law.” Hudson v. New York City,
271 F.3d 62, 67 (2d Cir. 2001). Reversal is “required where, based on a review of the record as a
whole, the error was prejudicial or the charge was highly confusing.” Kopstein, 759 F.3d at 172;
see also id. (“A charge that appears likely to have left the jury ‘highly confused’ may, on that
ground alone, be reversed.” (quoting Nat’l R.R. Passenger Corp. v. One 25,900 Square Foot More
or Less Parcel of Land, 766 F.2d 685, 688 (2d Cir. 1985) (“A charge that appears likely to have
left the jury ‘highly confused’ may, on that ground alone, be reversed.”))). “Even if an initial
and prejudicial to Ms. Maxwell. “A jury’s interruption of its deliberations ‘to seek further
explanation of the law’ is a ‘critical moment in a criminal trial’; and [the Second Circuit] therefore
ascribe[s] ‘crucial importance’ to a ‘completely accurate statement by the judge’ at that moment.”
United States v. Kopstein, 759 F.3d 168, 172 (2d Cir. 2014) (quoting United States v. Lefkowitz,
284 F.2d 310, 314 (2d Cir. 1960)). “Instructions are erroneous if they mislead the jury as to the
correct legal standard or do not adequately inform the jury of the law.” Hudson v. New York City,
271 F.3d 62, 67 (2d Cir. 2001). Reversal is “required where, based on a review of the record as a
whole, the error was prejudicial or the charge was highly confusing.” Kopstein, 759 F.3d at 172;
see also id. (“A charge that appears likely to have left the jury ‘highly confused’ may, on that
ground alone, be reversed.” (quoting Nat’l R.R. Passenger Corp. v. One 25,900 Square Foot More
or Less Parcel of Land, 766 F.2d 685, 688 (2d Cir. 1985) (“A charge that appears likely to have
left the jury ‘highly confused’ may, on that ground alone, be reversed.”))). “Even if an initial
¹ The defense notes that the object of the conspiracies charged in Counts One and Three is a violation of the same
New York statute. While we do not contest that alleged sexual activity that occurred in other states can be evidence of
those conspiracies, the jury cannot convict Ms. Maxwell on those counts without finding that she acted with the intent
that someone under the age of 17 would engage in sexual activity within the state of New York that violated New
York law.
New York statute. While we do not contest that alleged sexual activity that occurred in other states can be evidence of
those conspiracies, the jury cannot convict Ms. Maxwell on those counts without finding that she acted with the intent
that someone under the age of 17 would engage in sexual activity within the state of New York that violated New
York law.
2068538.1
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