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be N Ww ws Oo OY ~] oO WO Ww a OY 20 21 22 23 24 25 Case 1:20-cr-00330-PAE LCKCmax9 Southern Document 767 Charge counties Rockland, Anything Southern New York County, i.e. that occurs in any of District of New York. the indictment. Venue must be examined separately another. District of New York encompasses the Filed 08/10/22 Page 230 , Manhattan, Bronx, West Putnam, Dutchess, Orange, of 257 3064 following tchester, and Sullivan Coun ties. those places occurs in the Venue on one count does not for each count in t establish venue on establish evidence on multiple counts. reasonable doubt, evidence. than not. proving venue, has satisfied that i! The government need not prove venue beyond a but only by a mer preponderance of A preponderance of Thus, the governmen th vidence means more t, which does bear the burden of more likely than not that some @) the other hand, you Ffense occurred in the Southe furtheranc rn District of New York If applicable, you may rely on the sam vidence to the likely fF you conclude that it is of each charged . lf, on prove th you must venue requirement as to a particular of acquit Ms. Maxwell of other elements of the offens on or about various da not necessary, however, for the government conduct alleged occurred exactly on such da Instruction No. 41: are proven. Time of Offense. The indictment alleges that cer SOUTHERN DISTR CT RE PORTERS, Piss (212) 805- 0300 find that the government has failed to fFense, then that offense even if all the tain conduct occurred tes or during various time periods. It's to prove that any tes or throughout DOJ-OGR-00017251