In this filing, the government submits its proposed jury instructions, also known as “requests to charge,” ahead of Sean Combs’ upcoming trial. These instructions lay out how the jury should interpret the law as it applies to the charges in the Third Superseding Indictment, including conspiracy, racketeering (RICO), drug trafficking, sex trafficking, and related offenses. The government requests standard instructions on presumption of innocence, burden of proof, credibility of witnesses (including cooperating witnesses and law enforcement), and the meaning of reasonable doubt. Critically, it also asks the court to include specific legal definitions tied to each alleged crime—for example, the elements of a RICO enterprise and the requirements for proving participation in a drug distribution conspiracy.

Furthermore, the government includes instructions regarding the consideration of co-conspirator statements, evidence of prior bad acts, and accomplice testimony, reflecting the sensitive and complex nature of the allegations against Combs. The proposed charges emphasize that the jury must evaluate the case based solely on the evidence presented, without speculation or bias, and that guilt must be proven beyond a reasonable doubt. These instructions, if accepted by the judge, will guide the jury through the legal standards necessary to determine whether Combs is guilty on any or all of the multiple felony counts he faces. The submission underscores the government's intent to secure clear, legally sound guidance for the jury in what is expected to be a high-profile and multifaceted trial.


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source:

gov.uscourts.nysd.628425.275.0.pdf