{
  "document_metadata": {
    "page_number": "25",
    "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 25 of 51\nneed to repeat those instructions in the context of the full charge, which clarified that \"the violation of law is as charged in New York.\" (Tr. 2774-75, 2777). And the fact that the defense failed to seek or receive a limiting instruction before Jane's testimony did not provide a separate basis for including a limiting instruction in the final charge. (Tr. 2777). The Court, the Government, and the defense were painstaking during trial to ensure that the jury understood that the Mann Act counts required an intent to commit a criminal sexual act in New York. That the defense missed an additional opportunity for a limiting instruction is not a prejudicial variance, much less a constructive amendment.\n\nII. The Court Should Enter Judgment on Counts Three and Five\n\nThe S2 Indictment charged three conspiracies under 18 U.S.C. § 371. Counts One and Three were predicated on two different provisions of the Mann Act, whereas Count Five charged a conspiracy based on the Trafficking Victims Protection Act. As the Court held in an April 16, 2021 Order, the Government was entitled to present these three different counts to the jury. (Dkt. No. 207 at 27). Following the verdict, however, the Government agrees that the Court should enter judgment on only one of the Mann Act conspiracy counts, given the similarities between those counts. Accordingly, of the three conspiracy counts charged in the S2 Indictment, the Government submits that the Court should enter judgment on Count Three, which was predicated on 18 U.S.C. § 2423(a), and Count Five, which was predicated on 18 U.S.C. § 1591.\n\nCounts Three and Five are not multiplicitous, and the Court should enter judgment on both counts. In particular, as discussed in greater detail below, Counts Three and Five arose from different criminal schemes, involving different criminal conduct, different statutory predicates, and a different modus operandi. The defendant ignores these important distinctions, claiming, in 24\n\nDOJ-OGR-00009587",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 621 Filed 02/25/22 Page 25 of 51",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "need to repeat those instructions in the context of the full charge, which clarified that \"the violation of law is as charged in New York.\" (Tr. 2774-75, 2777). And the fact that the defense failed to seek or receive a limiting instruction before Jane's testimony did not provide a separate basis for including a limiting instruction in the final charge. (Tr. 2777). The Court, the Government, and the defense were painstaking during trial to ensure that the jury understood that the Mann Act counts required an intent to commit a criminal sexual act in New York. That the defense missed an additional opportunity for a limiting instruction is not a prejudicial variance, much less a constructive amendment.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "II. The Court Should Enter Judgment on Counts Three and Five",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The S2 Indictment charged three conspiracies under 18 U.S.C. § 371. Counts One and Three were predicated on two different provisions of the Mann Act, whereas Count Five charged a conspiracy based on the Trafficking Victims Protection Act. As the Court held in an April 16, 2021 Order, the Government was entitled to present these three different counts to the jury. (Dkt. No. 207 at 27). Following the verdict, however, the Government agrees that the Court should enter judgment on only one of the Mann Act conspiracy counts, given the similarities between those counts. Accordingly, of the three conspiracy counts charged in the S2 Indictment, the Government submits that the Court should enter judgment on Count Three, which was predicated on 18 U.S.C. § 2423(a), and Count Five, which was predicated on 18 U.S.C. § 1591.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Counts Three and Five are not multiplicitous, and the Court should enter judgment on both counts. In particular, as discussed in greater detail below, Counts Three and Five arose from different criminal schemes, involving different criminal conduct, different statutory predicates, and a different modus operandi. The defendant ignores these important distinctions, claiming, in 24",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00009587",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "Jane"
    ],
    "organizations": [
      "Government"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "02/25/22",
      "April 16, 2021"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "621",
      "Dkt. No. 207",
      "DOJ-OGR-00009587"
    ]
  },
  "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."
}