{
  "document_metadata": {
    "page_number": "21",
    "document_number": "621",
    "date": "02/25/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 621 Filed 02/25/22 Page 21 of 51\n\n\"almost invariable assumption of the law . . . that jurors follow their instructions\"). Accordingly, even if the jury note suggests some confusion, the Court's response did not constructively amend the S2 Indictment. See Jones, 847 F. App'x at 30 (finding no constructive amendment in a sex trafficking case where the indictment did not contain the verb \"advertise\" but the evidence included evidence of advertising and the Court mistakenly used that verb in parts of the instructions, because the advertising evidence \"fell squarely within the charged scheme\" and the Court otherwise correctly instructed the jury); Lebedev, 932 F.3d at 54 (\"The jury instructions described a conspiracy substantially the same as the one charged in the indictment.\")\n\nThird, the defendant's argument is better framed as a challenge to the Court's response to the jury note or a challenge to the jury instructions in the form of a constructive amendment argument. See, e.g., United States v. Muraca, 803 F. Appx' 545, 546 (2d Cir. 2020) (\"[T]he trial court enjoys considerable discretion construing the scope of a jury inquiry and in framing a response tailored to the inquiry,\" and \"If a supplemental charge is legally correct, the district court enjoys broad discretion in determining how, and under what circumstances, that charge will be given.\"). Rather than challenge what she takes to be an error, however, the defendant argues instead that the Court's response to the jury note worked a constructive amendment. In so doing, the defendant must surmount the high bar of showing that, notwithstanding the focus of the trial evidence, the Court's limiting instructions at trial, and the Court's jury instructions taken as a whole, the Court's response to the jury note \"so modif[ied] essential elements of the offense that there is a substantial likelihood that the defendant may have been convicted of an offense other than that charged in the indictment.\" Gross, 2017 WL 4685111, at *20. The original instructions\n\n20\n\nDOJ-OGR-00009583",
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      "content": "Case 1:20-cr-00330-PAE Document 621 Filed 02/25/22 Page 21 of 51",
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    {
      "type": "printed",
      "content": "\"almost invariable assumption of the law . . . that jurors follow their instructions\"). Accordingly, even if the jury note suggests some confusion, the Court's response did not constructively amend the S2 Indictment. See Jones, 847 F. App'x at 30 (finding no constructive amendment in a sex trafficking case where the indictment did not contain the verb \"advertise\" but the evidence included evidence of advertising and the Court mistakenly used that verb in parts of the instructions, because the advertising evidence \"fell squarely within the charged scheme\" and the Court otherwise correctly instructed the jury); Lebedev, 932 F.3d at 54 (\"The jury instructions described a conspiracy substantially the same as the one charged in the indictment.\")",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Third, the defendant's argument is better framed as a challenge to the Court's response to the jury note or a challenge to the jury instructions in the form of a constructive amendment argument. See, e.g., United States v. Muraca, 803 F. Appx' 545, 546 (2d Cir. 2020) (\"[T]he trial court enjoys considerable discretion construing the scope of a jury inquiry and in framing a response tailored to the inquiry,\" and \"If a supplemental charge is legally correct, the district court enjoys broad discretion in determining how, and under what circumstances, that charge will be given.\"). Rather than challenge what she takes to be an error, however, the defendant argues instead that the Court's response to the jury note worked a constructive amendment. In so doing, the defendant must surmount the high bar of showing that, notwithstanding the focus of the trial evidence, the Court's limiting instructions at trial, and the Court's jury instructions taken as a whole, the Court's response to the jury note \"so modif[ied] essential elements of the offense that there is a substantial likelihood that the defendant may have been convicted of an offense other than that charged in the indictment.\" Gross, 2017 WL 4685111, at *20. The original instructions",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "20",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00009583",
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  "entities": {
    "people": [],
    "organizations": [
      "Court"
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    "locations": [],
    "dates": [
      "02/25/22",
      "2020"
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    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "621",
      "DOJ-OGR-00009583"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is mostly printed, with no handwritten content or stamps visible. The document is well-formatted and legible."
}