{
  "document_metadata": {
    "page_number": "31",
    "document_number": "657",
    "date": "04/29/22",
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  "full_text": "Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 31 of 45\n\nresponding to a note from a deliberating jury is only required to answer the particular inquiries posed.\"); see also United States v. Parker, 903 F.2d 91, 101 (2d Cir. 1990) (“The trial judge is in the best position to sense whether the jury is able to proceed properly with its deliberations, and [s]he has considerable discretion in determining how to respond to communications indicating that the jury is experiencing confusion.”). The jury was free to send a clarifying or further note following the Court’s instruction.\n\nBy contrast, the Defendant failed to propose a legally accurate response for the jury. Her proposed responses to the note on the day it was received and the following morning were erroneous. At the time the Court received the note and discussed it with counsel, the Defendant first proposed that the answer to the note’s question was simply “no” because, she argued, a return flight is for the purpose of returning home, “not for the purpose of illegal sexual activity.” Trial Tr. at 3128–30. But the Court could not respond “no” to an ambiguous question. Id. at 3138. Moreover, the Defendant eventually conceded the principle that assistance with a return flight home could aid and abet a trip that was for the purpose of illegal sexual activity. See id. at 3136. Alternatively, the Defendant requested that if the Court were to refer the jury to the charge, that it direct the jury to lines 14 to 17 of Instruction No. 21, which instructed on “significant or motivating purpose.” Id. at 3131. But it was unclear that those particular lines addressed the jury’s question, and the Court’s decision to refer the jury to the entirety of Instruction No. 21 encompassed those lines.\n\nThe following day, although the jury had not sought further clarification, the Defendant took another pass at proposing an additional response to the note. She requested a three-paragraph supplemental instruction that referenced elements of Counts Two and Four. See Dkt.\n\n31\nDOJ-OGR-00010397",
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      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 31 of 45",
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    {
      "type": "printed",
      "content": "responding to a note from a deliberating jury is only required to answer the particular inquiries posed.\"); see also United States v. Parker, 903 F.2d 91, 101 (2d Cir. 1990) (“The trial judge is in the best position to sense whether the jury is able to proceed properly with its deliberations, and [s]he has considerable discretion in determining how to respond to communications indicating that the jury is experiencing confusion.”). The jury was free to send a clarifying or further note following the Court’s instruction.",
      "position": "body"
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    {
      "type": "printed",
      "content": "By contrast, the Defendant failed to propose a legally accurate response for the jury. Her proposed responses to the note on the day it was received and the following morning were erroneous. At the time the Court received the note and discussed it with counsel, the Defendant first proposed that the answer to the note’s question was simply “no” because, she argued, a return flight is for the purpose of returning home, “not for the purpose of illegal sexual activity.” Trial Tr. at 3128–30. But the Court could not respond “no” to an ambiguous question. Id. at 3138. Moreover, the Defendant eventually conceded the principle that assistance with a return flight home could aid and abet a trip that was for the purpose of illegal sexual activity. See id. at 3136. Alternatively, the Defendant requested that if the Court were to refer the jury to the charge, that it direct the jury to lines 14 to 17 of Instruction No. 21, which instructed on “significant or motivating purpose.” Id. at 3131. But it was unclear that those particular lines addressed the jury’s question, and the Court’s decision to refer the jury to the entirety of Instruction No. 21 encompassed those lines.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The following day, although the jury had not sought further clarification, the Defendant took another pass at proposing an additional response to the note. She requested a three-paragraph supplemental instruction that referenced elements of Counts Two and Four. See Dkt.",
      "position": "body"
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    {
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      "content": "31",
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      "content": "DOJ-OGR-00010397",
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  "entities": {
    "people": [],
    "organizations": [
      "United States"
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    "locations": [],
    "dates": [
      "04/29/22"
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    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "657",
      "903 F.2d 91",
      "3128–30",
      "3138",
      "3136",
      "3131",
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      "Two",
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      "DOJ-OGR-00010397"
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  "additional_notes": "The document appears to be a court transcript or legal document. The text is printed and there are no visible stamps or handwritten notes. The document is well-formatted and easy to read."
}