DOJ-OGR-00021015.jpg
669 KB
Extraction Summary
6
People
3
Organizations
3
Locations
1
Events
1
Relationships
5
Quotes
Document Information
Type:
Legal document
File Size:
669 KB
Summary
This legal document is a page from a court filing arguing against the defendant's (Maxwell's) appeal regarding jury instructions. The filing asserts that the trial court correctly rejected the defendant's proposed instruction because it was unresponsive, redundant, and legally inaccurate. The core issue revolves around whether sexual activity outside of New York could form the basis for a conviction, with the filing arguing that the existing jury charge sufficiently clarified that the violation had to be under New York Penal Law.
People (6)
| Name | Role | Context |
|---|---|---|
| Arroyo | Party in a lawsuit |
Mentioned in the case citation Arroyo v. Jones, 685 F.2d 35, 39 (2d Cir. 1982).
|
| Jones | Party in a lawsuit |
Mentioned in the case citation Arroyo v. Jones, 685 F.2d 35, 39 (2d Cir. 1982).
|
| Kopstein | Party in a lawsuit |
Mentioned in the case citation United States v. Kopstein, 759 F.3d 168, 172 (2d Cir. 2014).
|
| Lefkowitz | Party in a lawsuit |
Mentioned in the case citation United States v. Lefkowitz, 284 F.2d 310, 314 (2d Cir. 1960).
|
| Maxwell | Defendant |
Mentioned as the Defendant who submitted a reply brief ("Maxwell Reply at 9 n.4").
|
| Jane | Victim |
Mentioned as the person the Defendant allegedly transported from Florida to New York for the purpose of sexual abuse.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| The Second Circuit | Court |
Cited as having cautioned about supplemental jury instructions.
|
| United States | Government |
Party in the cited cases United States v. Kopstein and United States v. Lefkowitz.
|
| Government | Government agency |
Referenced in the requested jury instruction as the entity that must prove its case beyond a reasonable doubt.
|
Locations (3)
| Location | Context |
|---|---|
|
Mentioned as the origin of Jane's travel.
|
|
|
Mentioned as the destination of Jane's travel and the jurisdiction whose laws are at issue.
|
|
|
Mentioned as the specific destination where Jane was to be sexually abused.
|
Relationships (1)
The document describes the Defendant's alleged actions of transporting Jane with the intent to sexually abuse her, which forms the basis of Counts Two and Four.
Key Quotes (5)
"enjoy special prominence in the minds of jurors,"Source
— Arroyo v. Jones
(Describing the effect of supplemental instructions, as cited from a Second Circuit case.)
DOJ-OGR-00021015.jpg
Quote #1
"crucial importance,"Source
— United States v. Kopstein
(Describing the need for complete accuracy in jury instructions.)
DOJ-OGR-00021015.jpg
Quote #2
"a criminal offense under New York law"Source
— Jury Charge
(Quoted from the jury charge to specify the nature of the inquiry.)
DOJ-OGR-00021015.jpg
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
— Jury Charge
(Quoted from the jury charge, specifying the overt act related to the charges.)
DOJ-OGR-00021015.jpg
Quote #4
"sexual activity in any state other than New York cannot form the basis"Source
— Defendant's proposed instruction
(A portion of the defendant's requested jury instruction, which the document claims was inaccurate.)
DOJ-OGR-00021015.jpg
Quote #5
Full Extracted Text
Complete text extracted from the document (2,392 characters)
Case 22-1426, Document 58, 02/28/2023, 3475901, Page189 of 221
A-389
Case 1:20-cr-00330-AJN Document 657 Filed 04/29/22 Page 32 of 45
A-389
Case 1:20-cr-00330-AJN 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-00021015
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