{
  "document_metadata": {
    "page_number": "6",
    "document_number": "566",
    "date": "December 27, 2021",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 566 Filed 12/28/21 Page 6 of 7\n\nThe Honorable Alison J. Nathan\nDecember 27, 2021\nPage 6\n\ninstruction is not itself erroneous or highly confusing, a supplemental instruction prompted by a jury question may be so muddled as to warrant vacatur.\" Id. at 172.\n\nThe jury note indicates that the jury is confused about the second element of Count Four, and by extension, the third element of Count Two. Both counts require an intent to violate New York law and cannot be based on any conduct that allegedly occurred in New Mexico (or any other state besides New York). The court's answer to the jury's question permits the jury to convict Ms. Maxwell on Count Four based on alleged conduct occurring in New Mexico—aiding in a return flight from New Mexico. Not only is that conduct not charged in the indictment (see discussion above), it also is not illegal under New York law. Under New York law, an intent to engage in sexual activity in any other state cannot form the basis for a violation of New York law, as charged in Counts Two and Four. See People v. Carvajal, 6 N.Y.3d 305, 312 (2005) (\"CPL 20.20[] has codified the general principle that, for New York to exercise criminal jurisdiction, some alleged conduct or a consequence of that conduct must have occurred in the state.\") If the defendant disputes the evidence of the State's prosecutorial authority at trial, \"the trial court should charge the jury that jurisdiction must be proven beyond a reasonable doubt.\" People v. McLaughlin, 80 N.Y.2d 466, 472 (N.Y. 1992).\n\n2068538.1\nDOJ-OGR-00008795",
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      "content": "Case 1:20-cr-00330-PAE Document 566 Filed 12/28/21 Page 6 of 7",
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    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nDecember 27, 2021\nPage 6",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "instruction is not itself erroneous or highly confusing, a supplemental instruction prompted by a jury question may be so muddled as to warrant vacatur.\" Id. at 172.\n\nThe jury note indicates that the jury is confused about the second element of Count Four, and by extension, the third element of Count Two. Both counts require an intent to violate New York law and cannot be based on any conduct that allegedly occurred in New Mexico (or any other state besides New York). The court's answer to the jury's question permits the jury to convict Ms. Maxwell on Count Four based on alleged conduct occurring in New Mexico—aiding in a return flight from New Mexico. Not only is that conduct not charged in the indictment (see discussion above), it also is not illegal under New York law. Under New York law, an intent to engage in sexual activity in any other state cannot form the basis for a violation of New York law, as charged in Counts Two and Four. See People v. Carvajal, 6 N.Y.3d 305, 312 (2005) (\"CPL 20.20[] has codified the general principle that, for New York to exercise criminal jurisdiction, some alleged conduct or a consequence of that conduct must have occurred in the state.\") If the defendant disputes the evidence of the State's prosecutorial authority at trial, \"the trial court should charge the jury that jurisdiction must be proven beyond a reasonable doubt.\" People v. McLaughlin, 80 N.Y.2d 466, 472 (N.Y. 1992).",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "2068538.1\nDOJ-OGR-00008795",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ms. Maxwell"
    ],
    "organizations": [],
    "locations": [
      "New York",
      "New Mexico"
    ],
    "dates": [
      "December 27, 2021",
      "2005",
      "1992"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 566",
      "2068538.1",
      "DOJ-OGR-00008795"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is printed and there are no visible stamps or handwritten notes. The document is well-formatted and legible."
}