DOJ-OGR-00008935.jpg
730 KB
Extraction Summary
4
People
3
Organizations
2
Locations
3
Events
1
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
730 KB
Summary
This legal document from a court case, filed on February 11, 2022, details arguments over jury instructions concerning whether an offense must be a violation of New York law, even if events occurred in New Mexico. It highlights a specific note from the deliberating jury asking for clarification on Count Four, questioning if defendant Ms. Maxwell could be convicted for aiding a victim's (Jane's) return flight if the criminal intent was tied to the initial flight to New Mexico. The court declined to provide clarifying instructions, referring the jury back to the original charge.
People (4)
| Name | Role | Context |
|---|---|---|
| MR. ROHRBACH | Defense Counsel (implied) |
Quoted making arguments to the court regarding jury instructions concerning the Mann Act charges and offenses in New ...
|
| Annie |
Mentioned by Mr. Rohrbach as relating only to conspiracy counts, not the Mann Act charges.
|
|
| Jane | Victim/Witness |
Her testimony and travel to and from New Mexico are central to the legal arguments and the jury's question.
|
| Ms. Maxwell | Defendant |
The defendant in the case. The jury is considering convicting her on Count Four based on her alleged help in planning...
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| The Court | Government agency |
Presiding over the case, agreed with the government on jury instructions, and responded to the Jury Note by referring...
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| The government | Government agency |
The prosecution in the case, which reiterated a point regarding Jane's testimony and whose position the Court agreed ...
|
| The jury | Legal body |
The body deliberating the verdict, which sent a note to the court asking for clarification on Count Four of the Indic...
|
Timeline (3 events)
Jane's return flight from New Mexico, which the jury questioned if Ms. Maxwell's aid in planning was sufficient for a conviction.
from New Mexico
Locations (2)
| Location | Context |
|---|---|
|
Location where sexual contact/abuse with Jane allegedly occurred and the destination/origin of flights discussed in t...
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|
|
The location whose laws (New York offense) are being discussed as the required basis for the relevant illegal sexual ...
|
Relationships (1)
The document discusses the jury's consideration of convicting Ms. Maxwell for aiding in Jane's transportation for the purpose of sexual activity.
Key Quotes (3)
"Annie only relates to the conspiracy counts, at least as to these Mann Act charges, and the jury is going to be instructed here that the relevant illegal sexual activity has to be the violation of the New York offense. So again, there’s no risk that the jury will think that the sexual contact that happened in New Mexico is something that on its own is sufficient to show the illegal sexual activity required by the statute."Source
— MR. ROHRBACH
(Arguing to the court about the scope of jury instructions regarding the location of the alleged crime.)
DOJ-OGR-00008935.jpg
Quote #1
"Your Honor, these instructions do not put before the jury any violation of any New Mexico offense whatsoever above or below the age of consent, so I think there’s no risk that the jury is going to convict the defendant based on their concerns about a violation of a New York offense."Source
— MR. ROHRBACH
(Continuing his argument to the court about jury instructions to prevent conviction based on a New Mexico offense rather than a New York offense.)
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Quote #2
"Under Count Four (4), if the defendant aided in the transportation of Jane’s return flight, but not the flight to New Mexico where/if the intent was for Jane to engage in sexual activity, can she be found guilty under the second element?"Source
— The Jury
(A note sent to the court during deliberations seeking clarification on the requirements for a conviction on the transportation count.)
DOJ-OGR-00008935.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (2,185 characters)
Case 1:20-cr-00330-PAE Document 600 Filed 02/11/22 Page 11 of 37
MR. ROHRBACH: Annie only relates to the conspiracy counts, at least as to
these Mann Act charges, and the jury is going to be instructed here that the
relevant illegal sexual activity has to be the violation of the New York offense. So
again, there’s no risk that the jury will think that the sexual contact that happened
in New Mexico is something that on its own is sufficient to show the illegal
sexual activity required by the statute.
these Mann Act charges, and the jury is going to be instructed here that the
relevant illegal sexual activity has to be the violation of the New York offense. So
again, there’s no risk that the jury will think that the sexual contact that happened
in New Mexico is something that on its own is sufficient to show the illegal
sexual activity required by the statute.
Tr. 2775:2-9. With regard to Jane’s testimony, the government reiterated the same point:
MR. ROHRBACH: Your Honor, these instructions do not put before the jury any
violation of any New Mexico offense whatsoever above or below the age of
consent, so I think there’s no risk that the jury is going to convict the defendant
based on their concerns about a violation of a New York offense.
violation of any New Mexico offense whatsoever above or below the age of
consent, so I think there’s no risk that the jury is going to convict the defendant
based on their concerns about a violation of a New York offense.
Tr. 2776:5-10. The Court agreed with the government and declined to include the requested
instructions. Tr. 2777:12-25.
2. The Jury Note
During their deliberations, the jury sent a note inquiring about the proper basis to convict
under Count Four of the Indictment (the substantive transportation count) (the “Jury Note” or the
“Note”). The Jury Note read as follows:
Under Count Four (4), if the defendant aided in the transportation of Jane’s return
flight, but not the flight to New Mexico where/if the intent was for Jane to engage
in sexual activity, can she be found guilty under the second element?
flight, but not the flight to New Mexico where/if the intent was for Jane to engage
in sexual activity, can she be found guilty under the second element?
Court Exhibit #15 (Dkt. 593 at 23). The defense argued that the Note indicated that the jury was
already contemplating convicting Ms. Maxwell on Count Four based on Jane’s testimony about
sexual abuse in New Mexico, which was not a violation of New York law, and that their question
focused on whether Ms. Maxwell’s help planning Jane’s return flight from New Mexico,
assuming they found she gave any, was sufficient to satisfy the second element of Count Four.
Tr. 3128:6-3140:18. The Court disagreed and did not offer any clarifying instructions, and
simply referred the jury to the charge for the second element of Count Four. Tr. 3140:20-3141:3.
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DOJ-OGR-00008935
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