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640 KB
Extraction Summary
4
People
1
Organizations
1
Locations
3
Events
1
Relationships
4
Quotes
Document Information
Type:
Legal document
File Size:
640 KB
Summary
This legal document details the District Court's handling of a jury note during the trial of Maxwell. The jury questioned whether Maxwell could be found guilty on Count Four if she only aided in the victim Jane's return flight, not the initial flight to New Mexico where the criminal intent was present. The court declined to answer directly, finding the question too difficult to 'parse factually and legally,' and instead referred the jury back to the original instructions for that count.
People (4)
| Name | Role | Context |
|---|---|---|
| Maxwell | Defendant |
Mentioned in the context of her motion for a new trial, a jury note regarding her guilt, and her contentions about ju...
|
| Jane | Victim/Subject of charge |
Mentioned in a jury note regarding her transportation to New Mexico for the purpose of sexual activity.
|
| Juror 50 | Juror |
Mentioned in footnote 34 regarding questioning by the District Court about potential juror misconduct.
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| Ianniello | Defendant in a cited case |
Mentioned in the case citation 'United States v. Ianniello' in footnote 34.
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Organizations (1)
| Name | Type | Context |
|---|---|---|
| District Court | government agency |
The court that handled Maxwell's trial, denied her motion, responded to a jury note, and questioned a juror.
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Timeline (3 events)
The jury was deliberating and sent a note to the court for clarification on Count Four of the Indictment.
District Court
Jury
A hearing on potential juror misconduct involving Juror 50, mentioned in a footnote.
District Court
Locations (1)
| Location | Context |
|---|---|
|
Mentioned in the jury's question as the destination of a flight where the intent was for Jane to engage in sexual act...
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Key Quotes (4)
"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
— Jury
(A note sent by the jury to the District Court during deliberations seeking clarification on a charge.)
DOJ-OGR-00021866.jpg
Quote #1
"parse factually and legally"Source
— District Court
(The District Court's reason for not directly answering the jury's note, stating it was difficult to do so.)
DOJ-OGR-00021866.jpg
Quote #2
"[w]e leave it to the district court’s discretion to decide the extent to which the parties may participate in questioning the witnesses, and whether to hold the hearing in camera."Source
— United States v. Ianniello, 866 F.2d 540, 544 (2d Cir. 1989)
(A legal precedent cited in footnote 34 to support the District Court's handling of questioning a juror.)
DOJ-OGR-00021866.jpg
Quote #3
"Maxwell knowingly transported Jane in interstate commerce with the"Source
— District Court
(Part of the District Court's instruction to the jury on the second element of Count Four, as described in footnote 36.)
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Quote #4
Full Extracted Text
Complete text extracted from the document (1,763 characters)
Case 22-1426 Document 109-1, 10/20/2024, 36684997, Page 19 of 36
enough; the District Court did not abuse its discretion in denying Maxwell’s motion for a new trial.34
4. The District Court’s Response to a Jury Note Did Not Result in a Constructive Amendment of, or Prejudicial Variance from, the Allegations in the Indictment
During jury deliberations, the jury sent the following jury note regarding Count Four of the Indictment:
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?35
The District Court determined that it would not respond to the note directly because it was difficult to “parse factually and legally” and instead referred the jury to the second element of Count Four.36
34 Nor did the District Court err in questioning juror 50 rather than allowing the parties to do so. In conducting a hearing on potential juror misconduct, “[w]e leave it to the district court’s discretion to decide the extent to which the parties may participate in questioning the witnesses, and whether to hold the hearing in camera.” United States v. Ianniello, 866 F.2d 540, 544 (2d Cir. 1989). And while Maxwell contends that the District Court improperly limited questioning about Juror 50’s role in deliberations, she both waived that argument below and fails to show here how any such questioning would not be foreclosed by Federal Rule of Evidence 606(b).
35 A-238.
36 A-207-221. The District Court’s instruction on the second element of Count Four required the jury to find that “Maxwell knowingly transported Jane in interstate commerce with the
19
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