Federal Court Filing (EFTA00074500)

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA S2 20 Cr. 330 (MN) GHISLAINE MAXWELL, Defendant. [PROPOSED] JOINT REQUESTS TO CHARGE EFTA00074500 TABLE OF CONTENTS INTRODUCTORY INSTRUCTIONS 1 Role of the Court 1 Role of the Jury 2 Sympathy: Oath As Jurors 3 Contact with Others/Social Media 4 Statements of Counsel and Court Not Evidence; Jury's Recollection Controls 5 Improper Considerations 7 All Parties Are Equal Before the Law 8 Presumption of Innocence and Burden of Proof 9 Reasonable Doubt 10 The Indictment 12 CHARGE 13 Summary of Indictment 13 Multiple Counts 15 Count Two: Enticement to Engage in an Illegal Sexual Activity - The Statute 16 Count Two: Enticement to Engage in Illegal Sexual Activity- The Elements 17 Count Two: Enticement to Engage in Illegal Sexual Activity - First Element 18 Count Two: Enticement to Engage in Illegal Sexual Activity - Second Element 19 Count Two: Enticement to Engage i