Sand

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Also known as:
Judge Sand

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DOJ-OGR-00017006.jpg

This document is a page from a court transcript (Case 1:20-cr-00330-AJN, United States v. Ghislaine Maxwell) filed on August 10, 2022. It details a legal argument between defense attorney Mr. Everdell and prosecutor Mr. Rohrbach regarding jury instructions concerning 'investigative techniques.' Everdell argues the charge should be removed as the defense did not elicit evidence on the topic, while Rohrbach argues it is a correct statement of law relevant to the case.

Court transcript
2025-11-20

DOJ-OGR-00017003.jpg

This document is a court transcript from August 10, 2022, detailing a legal argument between two attorneys, Mr. Rohrbach and Mr. Everdell, and the judge. The discussion centers on the precise wording of a jury instruction concerning "uncalled witnesses," with Mr. Everdell proposing a modification and Mr. Rohrbach defending the standard instruction used in the district.

Legal document
2025-11-20

DOJ-OGR-00016959.jpg

This document is page 33 of a court transcript from Case 1:20-cr-00330-AJN (USA v. Ghislaine Maxwell), filed on August 10, 2022. The dialogue captures a legal argument between the Judge ('The Court') and defense attorney Mr. Everdell regarding jury instructions for a charge under 18 U.S.C. ยง 2421 (Mann Act). The Judge cites *United States v. An Soon Kim*, arguing that the word 'dominant' is not required in the statutory language for proving the purpose of transportation, while Everdell attempts to distinguish the case.

Court transcript
2025-11-20

DOJ-OGR-00016958.jpg

This document is a court transcript from August 10, 2022, capturing a dialogue between a judge ('THE COURT') and an attorney ('MR. EVERDELL'). Mr. Everdell is advocating for a new proposed jury instruction, arguing that its 'dominant purpose' language is more accurate as it is based on Second Circuit case law from Judge Rakoff, unlike the previous instruction's language which he claims was invented by Judge Sand without basis in circuit law.

Legal document
2025-11-20

DOJ-OGR-00016957.jpg

This document is a page from a court transcript filed on August 10, 2022. It captures a legal debate between two attorneys, Mr. Rohrbach and Mr. Everdell, before a judge regarding the precise wording of jury instructions for a case involving interstate travel for criminal sexual activity. The core of the argument is whether the law requires a 'dominant purpose' or if 'one of the dominant purposes' is sufficient, with both sides citing legal precedents like the Miller case and authorities like Sand to support their positions.

Legal document
2025-11-20

DOJ-OGR-00016956.jpg

This document is a page from a court transcript dated August 10, 2022. An attorney, Mr. Rohrbach, is arguing a point of law to the judge regarding the jury instruction for 'dominant purpose' in a case about crossing state lines for criminal sexual conduct. He cites legal precedents, including the 'Sand' and 'Miller' cases, to support his position that the purpose need only be one of the dominant purposes, not the sole one.

Legal document
2025-11-20
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