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Extraction Summary
3
People
2
Organizations
2
Locations
2
Events
1
Relationships
4
Quotes
Document Information
Type:
Court filing (legal brief/opinion - case 1:20-cr-00330-pae)
File Size:
735 KB
Summary
This document page is from a court filing (Case 1:20-cr-00330-PAE) dated April 29, 2022, concerning the trial of Ghislaine Maxwell. It discusses a dispute over the interpretation of a jury note regarding 'Count Four,' specifically whether the jury was considering conduct in New Mexico versus New York state law. The text details arguments about a missing comma in the note and the Court's instruction that New York law was the governing statute, even if New Mexico events were relevant to intent.
People (3)
| Name | Role | Context |
|---|---|---|
| The Defendant | Defendant |
Refers to Ghislaine Maxwell (based on case number context). The document discusses her legal team's arguments regardi...
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| The Court | Judicial Authority |
The judge/court managing the trial, specifically regarding instructions given to the jury.
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| The Jury | Fact Finder |
The jurors deliberating on the case, specifically asking questions via notes about Count Four.
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Organizations (2)
| Name | Type | Context |
|---|---|---|
| Government |
The prosecution (DOJ), accused by the defendant of 'muddying the inquiry'.
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| 2d Cir. |
Second Circuit Court of Appeals, referenced in case citation.
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Timeline (2 events)
Trial
Locations (2)
| Location | Context |
|---|---|
|
Location of testimony, potential sexual abuse, and origin of a flight.
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Location of applicable state law and destination of travel.
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Relationships (1)
Defendant accuses Government of 'muddying the inquiry'; legal arguments in briefs.
Key Quotes (4)
"significant or motivating purpose"Source
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Quote #1
"The note was clear on one point—the jury was asking about the second element of Count Four."Source
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Quote #2
"the only state law at issue was New York’s, even if sexual abuse in New Mexico was relevant evidence of intent."Source
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Quote #3
"muddying the inquiry"Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,283 characters)
Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 30 of 45
to the second element. Or it could have been asking if it was permissible to consider the New
Mexico testimony in its assessment of Count Four. Indeed, the Defendant proffered a different
interpretation when the Court first read the note at trial. Initially, the Defendant argued that the
jury was asking if the Defendant could be found guilty solely for aiding and abetting a flight
home from New Mexico, which she said raised the issue of whether sexual activity could be the
“significant or motivating purpose” for the travel. Trial Tr. at 3128–30. It was only after a
protracted discussion, spanning ten pages of transcript, that the Defendant eventually suggested
that the jury was considering convicting the Defendant on Count Four solely on conduct in New
Mexico without any travel to New York. On this score, the Defendant argued at trial and argues
now that the absence of a comma between “New Mexico” and “where/if” revealed the jury’s
thinking. Maxwell Reply at 6 n.2. 6 But hinging the note’s meaning on an absent comma does
not indicate a meaning “clear on [its] face.” Maxwell Reply at 9. With or without the comma,
the note was ambiguous as to the destination of the hypothetical return flight, the testimony
being referenced, and the legal question being asked.
Mexico testimony in its assessment of Count Four. Indeed, the Defendant proffered a different
interpretation when the Court first read the note at trial. Initially, the Defendant argued that the
jury was asking if the Defendant could be found guilty solely for aiding and abetting a flight
home from New Mexico, which she said raised the issue of whether sexual activity could be the
“significant or motivating purpose” for the travel. Trial Tr. at 3128–30. It was only after a
protracted discussion, spanning ten pages of transcript, that the Defendant eventually suggested
that the jury was considering convicting the Defendant on Count Four solely on conduct in New
Mexico without any travel to New York. On this score, the Defendant argued at trial and argues
now that the absence of a comma between “New Mexico” and “where/if” revealed the jury’s
thinking. Maxwell Reply at 6 n.2. 6 But hinging the note’s meaning on an absent comma does
not indicate a meaning “clear on [its] face.” Maxwell Reply at 9. With or without the comma,
the note was ambiguous as to the destination of the hypothetical return flight, the testimony
being referenced, and the legal question being asked.
The note was clear on one point—the jury was asking about the second element of Count
Four. Accordingly, the Court sent the jury back to the charge, which accurately instructed that
Count Four had to be predicated on finding a violation of New York law. This response ensured
that the jury focused on the correct instruction and, in turn, reminded the jury that the only state
law at issue was New York’s, even if sexual abuse in New Mexico was relevant evidence of
intent. See United States v. Rommy, 506 F.3d 108, 126 (2d Cir. 2007) (“[A] trial court
Four. Accordingly, the Court sent the jury back to the charge, which accurately instructed that
Count Four had to be predicated on finding a violation of New York law. This response ensured
that the jury focused on the correct instruction and, in turn, reminded the jury that the only state
law at issue was New York’s, even if sexual abuse in New Mexico was relevant evidence of
intent. See United States v. Rommy, 506 F.3d 108, 126 (2d Cir. 2007) (“[A] trial court
6 The Defendant also accuses the Government of muddying the inquiry by inserting a comma in this supposedly
crucial spot. Maxwell Reply at 5, 6 n.2. It is apparent from the Government’s brief that it relied on the trial
transcript for its transcription of the jury note, which included a comma between these words. See Gov. Br. at 13
(quoting Trial Tr. at 3126).
crucial spot. Maxwell Reply at 5, 6 n.2. It is apparent from the Government’s brief that it relied on the trial
transcript for its transcription of the jury note, which included a comma between these words. See Gov. Br. at 13
(quoting Trial Tr. at 3126).
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