In the case United States v. Combs, Inc., 24-cr-542 (AS), the defense submitted a letter to Judge Subramanian further supporting their requested edits to the Court’s proposed jury charge. The defense elaborated on certain issues that were referenced in comment bubbles within their proposed edits, which are aimed at modifying the jury instructions to better align with their legal arguments. These proposed edits highlight key areas where the defense believes the current jury charge may mislead or improperly influence the jury’s decision-making process.

Additionally, the defense also addressed objections to the government’s redline edits, which likely included the prosecution's own proposed modifications to the jury instructions. The letter emphasized specific points of contention where the defense felt the prosecution’s edits were either incomplete or insufficient in ensuring that the jury received a fair and accurate legal framework for deliberation. The correspondence from the defense represents a critical step in refining the instructions that the jury will follow when ultimately deciding the outcome of the case.



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source:

gov.uscourts.nysd.628425.421.0.pdf