In this filing titled “Defendant Sean Combs’s Additional Requests to Charge,” Combs’s legal team submitted supplemental proposed jury instructions for Judge Subramanian to consider as the case approaches deliberations. The defense emphasized that these additional instructions were necessary to ensure the jury fully understood the legal standards governing the charges, particularly with respect to the government’s burden of proof, the definitions of key terms under RICO and sex trafficking statutes, and the presumption of innocence afforded to the defendant. They argued that without these clarifying instructions, the jury risked being misled by the government’s broad and potentially prejudicial narrative framing.


Furthermore, the defense stressed that the proposed instructions were rooted in well-established case law and were essential to safeguarding Combs’s constitutional rights during deliberations. The filing highlighted concerns that certain elements of the government’s case—such as its reliance on character evidence and speculative inferences—could improperly sway the jury unless properly neutralized by clear guidance from the Court. The defense urged Judge Subramanian to adopt these additional charges in full to preserve the fairness and integrity of the proceedings.


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source:

gov.uscourts.nysd.628425.388.0.pdf