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This document is page 6 of a legal letter addressed to Judge Alison J. Nathan, dated December 27, 2021, filed during the Ghislaine Maxwell trial. The defense argues that a jury note indicates confusion regarding Counts Two and Four, specifically concerning jurisdiction and New York law. The text argues that the jury should not be permitted to convict Maxwell based on conduct that occurred in New Mexico (specifically aiding in a return flight from New Mexico) as it does not constitute a violation of New York law.
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This legal document argues that there is a substantial likelihood that Ms. Maxwell was improperly convicted on Mann Act counts. The defense contends the conviction may have been based on testimony about conduct in New Mexico, which does not violate New York law, thereby constituting a 'constructive amendment' of the indictment that broadened the charges beyond what was originally presented by the government.
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This document is a memorandum dated September 17, 2019, from Hugh J. Hurwitz (Assistant Director, Reentry Services Division, BOP) to J. Ray Ormond (Regional Director, Northeast Region). It formally discusses the 'Psychological Reconstruction' report following Jeffrey Epstein's suicide on August 10, 2019, at MCC New York. The memo instructs the recipient to review the attached report and provide a written response within 60 days outlining corrective actions and implementation plans to improve the national suicide prevention program.
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This legal document, dated December 27, 2021, is a filing to Judge Alison J. Nathan arguing that the jury in Ms. Maxwell's trial is confused. The author contends that the court's response to a jury note improperly allows them to consider conduct that occurred in New Mexico as a basis for conviction on counts requiring a violation of New York law. The filing cites legal precedent to argue that New York lacks jurisdiction over conduct occurring entirely out-of-state and that this issue could warrant vacating a potential conviction.
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