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739 KB
Extraction Summary
3
People
3
Organizations
4
Locations
2
Events
2
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
739 KB
Summary
This legal document is a portion of a court filing, likely a response or motion, dated April 29, 2022. It defends the Court's decisions regarding jury instructions against objections from the Defendant (Maxwell). The Court rejected the Defendant's requests to limit the charges to specific travel routes (e.g., from Florida to New York) and to instruct the jury on the age of consent laws in New Mexico, the United Kingdom, and Florida, arguing these requests were unnecessary, inaccurate, and would confuse the jury.
People (3)
| Name | Role | Context |
|---|---|---|
| Maxwell | Defendant |
Referenced in "Maxwell Br. at 15," indicating a brief filed by the Defendant.
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| Little | Party in a cited case |
Mentioned in the case citation "United States v. Little, 828 F. App’x 34, 37–38 (2d Cir. 2020)."
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| The Defendant | Defendant |
Mentioned throughout the document as the party making objections and requests to the court regarding jury instructions.
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Organizations (3)
| Name | Type | Context |
|---|---|---|
| The Court | government agency |
Mentioned throughout as the judicial body making decisions on jury instructions and rejecting the Defendant's requests.
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| The Government | government agency |
Mentioned as the prosecuting party in the case, which had not charged the Defendant with certain theories of guilt.
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| 2d Cir. | government agency |
Referenced in a case citation, referring to the United States Court of Appeals for the Second Circuit.
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Timeline (2 events)
2021-11-23
Final Pretrial Conference where jury instructions were discussed.
Charging Conference where travel requirements were discussed.
Locations (4)
| Location | Context |
|---|---|
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Mentioned as the location of the predicate state law at issue and a destination of travel.
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Mentioned as a point of origin for travel in the Defendant's rejected request for jury instruction.
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Mentioned as another potential point of origin for travel and a location whose age of consent law the Defendant wante...
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Mentioned as a location whose age of consent law the Defendant requested be included in jury instructions.
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Relationships (2)
The document details the Defendant's legal arguments and requests being rejected by the Court, showing their adversarial roles within a legal proceeding.
The document describes the Government as the prosecuting party that had not charged the Defendant with certain theories of guilt, placing them in an adversarial relationship in a criminal case.
Key Quotes (3)
"stripped of any mention of ‘travel to New York.’"Source
— The Defendant
(The Defendant's objection to the jury charge, as cited from 'Maxwell Br. at 15'.)
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Quote #1
"Florida to New York"Source
— The Defendant
(Part of the Defendant's rejected request to limit the charge to requiring travel from this specific route.)
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Quote #2
"‘to wit’ clauses do not modify essential elements of the offense"Source
— United States v. Little, 828 F. App’x 34, 37–38 (2d Cir. 2020) (summary order)
(A legal principle cited to support the Court's decision not to limit the charge based on a 'to wit' clause in the Indictment.)
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Quote #3
Full Extracted Text
Complete text extracted from the document (2,216 characters)
Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 33 of 45
convictions on Counts Two and Four, erroneously implying that such evidence was irrelevant. Dkt. No. 566 at 7 (emphasis added). Thus, in light of the note’s ambiguity and the Defendant’s failure to propose an accurate response in either the first attempt or the second attempt a day later, the Court’s decision to refer the jury back to the legally sound charge was not error and plainly did not result in a constructive amendment to the Indictment.
The Defendant does not expressly contend that the instructions were legally erroneous— nor could she. As explained above, the charge made clear that the only predicate state law at issue was New York’s. Instead, the Defendant objects that the charge was “stripped of any mention of ‘travel to New York.’” Maxwell Br. at 15. But the Court rejected the Defendant’s specific requests that were unnecessary, inaccurate, or would have confused the jury. For example, the Court rejected the Defendant’s request to limit the charge to requiring travel from “Florida to New York,” as alleged in the “to wit” clause of the Indictment, because travel from New Mexico to New York, for example, would also have been sufficient. See Trial Tr. at 2758–61 (Charging Conference); see also United States v. Little, 828 F. App’x 34, 37–38 (2d Cir. 2020) (summary order) (noting that generally, “‘to wit’ clauses do not modify essential elements of the offense”). The Court also denied the Defendant’s request to instruct the jury on law governing the age of consent in New Mexico, the United Kingdom, and Florida. First, the Defendant’s proposal oversimplified New Mexico’s age of consent law. The Court could not accurately instruct the jury on New Mexico’s law without potentially introducing a theory of guilt that the Government had not charged, or resolving a factual question on the use of force for the jury. Trial Tr. at 1712–13; Nov. 23, 2021, Final Pretrial Conference Tr. at 31–38. And second, instructing on state law that the Defendant was not alleged to have violated ran a serious risk of confusing the jury as to the role of that law. Indeed, it was the Defendant’s proposal that
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DOJ-OGR-00010399
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