{
  "document_metadata": {
    "page_number": "32 of 45",
    "document_number": "657",
    "date": "04/29/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 32 of 45\n\nNo. 566.7 The Second Circuit has cautioned that supplemental instructions \"enjoy special prominence in the minds of jurors,\" Arroyo v. Jones, 685 F.2d 35, 39 (2d Cir. 1982), and that complete accuracy is of \"crucial importance,\" United States v. Kopstein, 759 F.3d 168, 172 (2d Cir. 2014) (quoting United States v. Lefkowitz, 284 F.2d 310, 314 (2d Cir. 1960)). Portions of the requested instruction were unresponsive, portions were redundant, and portions were legally inaccurate. The first paragraph, which pertained to Count Two, was unresponsive to the jury's note that asked only about Count Four. The second paragraph was unnecessary because it was redundant. The Defendant now raises for the first time, in a footnote, that the Court should have sua sponte provided the jury this paragraph alone. Maxwell Reply at 9 n.4. But the charge as a whole already made clear that a violation of New York Penal Law Section 130.55 was the key inquiry. See Jury Charge at 20, 23, 26, (specifying \"a criminal offense under New York law\"), 24 (Count Two instructions on New York Penal Law Section 130.55), 28 (Count Four referring back to these instructions), 49–50 (specifying the overt act of Jane traveling \"from Florida to New York for purposes of sexually abusing her at the New York Residence, in violation of New York Penal Law, Section 130.55\"). Finally, the proposal also inaccurately stated that \"sexual activity in any state other than New York cannot form the basis\" of\n\n7 The requested instruction read:\n\nAs to the third element of Count Two, you must determine whether the Government has proven beyond a reasonable doubt that the Defendant acted with the intent that Jane would engage in sexual activity within the state of New York in violation of New York Penal Law 130.55.\n\nAs to the second element of Count Four, you must determine whether the Government has proven beyond a reasonable doubt that the Defendant transported Jane with the intent that Jane would engage in sexual activity within the state of New York in violation of New York Penal Law 130.55.\n\nAn intent that Jane engage in sexual activity in any state other than New York cannot form the basis of these two elements of Counts Two and Four.\n\nDkt. No. 566 at 7.\n\n32\n\nDOJ-OGR-00010398",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 657 Filed 04/29/22 Page 32 of 45",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "No. 566.7 The Second Circuit has cautioned that supplemental instructions \"enjoy special prominence in the minds of jurors,\" Arroyo v. Jones, 685 F.2d 35, 39 (2d Cir. 1982), and that complete accuracy is of \"crucial importance,\" United States v. Kopstein, 759 F.3d 168, 172 (2d Cir. 2014) (quoting United States v. Lefkowitz, 284 F.2d 310, 314 (2d Cir. 1960)). Portions of the requested instruction were unresponsive, portions were redundant, and portions were legally inaccurate. The first paragraph, which pertained to Count Two, was unresponsive to the jury's note that asked only about Count Four. The second paragraph was unnecessary because it was redundant. The Defendant now raises for the first time, in a footnote, that the Court should have sua sponte provided the jury this paragraph alone. Maxwell Reply at 9 n.4. But the charge as a whole already made clear that a violation of New York Penal Law Section 130.55 was the key inquiry. See Jury Charge at 20, 23, 26, (specifying \"a criminal offense under New York law\"), 24 (Count Two instructions on New York Penal Law Section 130.55), 28 (Count Four referring back to these instructions), 49–50 (specifying the overt act of Jane traveling \"from Florida to New York for purposes of sexually abusing her at the New York Residence, in violation of New York Penal Law, Section 130.55\"). Finally, the proposal also inaccurately stated that \"sexual activity in any state other than New York cannot form the basis\" of",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "7 The requested instruction read:\n\nAs to the third element of Count Two, you must determine whether the Government has proven beyond a reasonable doubt that the Defendant acted with the intent that Jane would engage in sexual activity within the state of New York in violation of New York Penal Law 130.55.\n\nAs to the second element of Count Four, you must determine whether the Government has proven beyond a reasonable doubt that the Defendant transported Jane with the intent that Jane would engage in sexual activity within the state of New York in violation of New York Penal Law 130.55.\n\nAn intent that Jane engage in sexual activity in any state other than New York cannot form the basis of these two elements of Counts Two and Four.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "Dkt. No. 566 at 7.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "32",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00010398",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jane"
    ],
    "organizations": [
      "Second Circuit",
      "Government"
    ],
    "locations": [
      "New York",
      "Florida"
    ],
    "dates": [
      "04/29/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 657",
      "No. 566",
      "Dkt. No. 566",
      "DOJ-OGR-00010398"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is mostly printed, with no visible handwriting or stamps. The document is well-formatted and legible."
}