DOJ-OGR-00010398.jpg
725 KB
Extraction Summary
6
People
4
Organizations
3
Locations
2
Events
1
Relationships
5
Quotes
Document Information
Type:
Legal document
File Size:
725 KB
Summary
This legal document, part of a court filing, defends the court's decision to reject the defendant's proposed jury instructions. The court argues the requested instructions were unresponsive, redundant, and legally inaccurate, particularly the claim that sexual activity outside New York could not form the basis for the charges. The document asserts that the existing jury charge correctly focused the inquiry on the violation of New York Penal Law Section 130.55, specifically concerning the overt act of transporting the victim, Jane, from Florida to New York for the purpose of sexual abuse.
People (6)
| Name | Role | Context |
|---|---|---|
| Arroyo | Party in a lawsuit |
Mentioned in the legal citation "Arroyo v. Jones, 685 F.2d 35, 39 (2d Cir. 1982)".
|
| Jones | Party in a lawsuit |
Mentioned in the legal citation "Arroyo v. Jones, 685 F.2d 35, 39 (2d Cir. 1982)".
|
| Kopstein | Party in a lawsuit |
Mentioned in the legal citation "United States v. Kopstein, 759 F.3d 168, 172 (2d Cir. 2014)".
|
| Lefkowitz | Party in a lawsuit |
Mentioned in the legal citation "United States v. Lefkowitz, 284 F.2d 310, 314 (2d Cir. 1960)".
|
| Maxwell | Defendant |
Mentioned in "Maxwell Reply at 9 n.4.". The context implies Maxwell is the Defendant in the current case.
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| Jane | Victim |
Mentioned as the person who traveled from Florida to New York for the purpose of being sexually abused and who the De...
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| The Second Circuit | government agency |
Referenced as a court that has cautioned on supplemental jury instructions and as the circuit for several cited cases.
|
| United States | government agency |
Mentioned as a party in the legal citations "United States v. Kopstein" and "United States v. Lefkowitz".
|
| Government | government agency |
Mentioned in the footnote as the prosecuting party that must prove its case beyond a reasonable doubt.
|
| Court | government agency |
Referenced as the body that provided the jury charge and that the Defendant argues should have provided a different i...
|
Timeline (2 events)
Locations (3)
| Location | Context |
|---|---|
|
Mentioned as the origin of Jane's travel.
|
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Mentioned as the destination of Jane's travel and the location where the alleged sexual activity was intended to occu...
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The specific location where Jane was allegedly to be sexually abused.
|
Relationships (1)
The document describes the Defendant's alleged actions of transporting Jane from Florida to New York for the purpose of sexually abusing her, which forms the basis of criminal charges (Counts Two and Four).
Key Quotes (5)
"enjoy special prominence in the minds of jurors"Source
— The Second Circuit (citing Arroyo v. Jones)
(A caution from the Second Circuit regarding supplemental jury instructions.)
DOJ-OGR-00010398.jpg
Quote #1
"crucial importance"Source
— The Second Circuit (citing United States v. Kopstein)
(Describing the need for complete accuracy in jury instructions.)
DOJ-OGR-00010398.jpg
Quote #2
"a criminal offense under New York law"Source
— Court (in Jury Charge)
(Part of the jury charge specifying the nature of the inquiry.)
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Quote #3
"from Florida to New York for purposes of sexually abusing her at the New York Residence, in violation of New York Penal Law, Section 130.55"Source
— Court (in Jury Charge)
(The specific overt act described in the jury instructions.)
DOJ-OGR-00010398.jpg
Quote #4
"sexual activity in any state other than New York cannot form the basis"Source
— Defendant (in proposed instruction)
(A legally inaccurate statement from the defendant's rejected proposal for jury instructions.)
DOJ-OGR-00010398.jpg
Quote #5
Full Extracted Text
Complete text extracted from the document (2,323 characters)
Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 32 of 45
No. 566.7 The Second Circuit has cautioned that supplemental instructions “enjoy special prominence in the minds of jurors,” Arroyo v. Jones, 685 F.2d 35, 39 (2d Cir. 1982), and that complete accuracy is of “crucial importance,” 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)). Portions of the requested instruction were unresponsive, portions were redundant, and portions were legally inaccurate. The first paragraph, which pertained to Count Two, was unresponsive to the jury’s note that asked only about Count Four. The second paragraph was unnecessary because it was redundant. The Defendant now raises for the first time, in a footnote, that the Court should have sua sponte provided the jury this paragraph alone. Maxwell Reply at 9 n.4. But the charge as a whole already made clear that a violation of New York Penal Law Section 130.55 was the key inquiry. See Jury Charge at 20, 23, 26, (specifying “a criminal offense under New York law”), 24 (Count Two instructions on New York Penal Law Section 130.55), 28 (Count Four referring back to these instructions), 49–50 (specifying the overt act of Jane traveling “from Florida to New York for purposes of sexually abusing her at the New York Residence, in violation of New York Penal Law, Section 130.55”). Finally, the proposal also inaccurately stated that “sexual activity in any state other than New York cannot form the basis” of
7 The requested instruction read:
As to the third element of Count Two, you must determine whether the Government has proven beyond a reasonable doubt that the Defendant acted with the intent that Jane would engage in sexual activity within the state of New York in violation of New York Penal Law 130.55.
As to the second element of Count Four, you must determine whether the Government has proven beyond a reasonable doubt that the Defendant transported Jane with the intent that Jane would engage in sexual activity within the state of New York in violation of New York Penal Law 130.55.
An intent that Jane engage in sexual activity in any state other than New York cannot form the basis of these two elements of Counts Two and Four.
Dkt. No. 566 at 7.
32
DOJ-OGR-00010398
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