EFTA00074500

Use of Electronic Communications 
Some of the evidence in this case has consisted of electronic communications seized from 
computers or electronic accounts. There is nothing illegal about the Government's use of such 
electronic communications in this case and you may consider them along with all the other 
evidence in the case. Whether you approve or disapprove of the seizure of these communications 
may not enter your deliberations. 
You may, therefore, regardless of any personal opinions, consider this evidence along 
with all the other evidence in the case in determining whether the Government has proven the 
defendant's guilt beyond a reasonable doubt. However, as with the other evidence, it is for you to 
determine what weight, if any, to give such evidence. 
Adapted from the charge of the Hon. Alison J. Nathan in United States 
v. Lebedev, 15 Cr. 769 (MN). 
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Persons Not on Trial 
You may not draw any inference, favorable or unfavorable, towards the Government or 
the defendant on trial from the fact that any person in addition to the defendant is not on trial 
here. You also may not speculate as to the reasons why other persons are not on trial. Those 
matters are wholly outside your concern and have no bearing on your function as jurors. 
Adapted from the charge of the Hon. Alison J. Nathan in United States 
v. Jones, 16 Cr. 553 (MN) and in United States v. Pizarro, 17 Cr. 151 
(AJN); the charge of the Hon. Kimba M. Wood in United States v. 
Almonte, 16 Cr. 670 (KMW); the charge of the Hon. Denise L. Cote 
in United States v. Purcell, 18 Cr. 081 (DLC); and the charge of the 
Hon. P. Kevin Castel in United States v. William Walters, 16 Cr. 338 
(PKC). 
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Preparation of Witnesses 
You have heard evidence during the trial that witnesses have discussed the facts of the 
case and their testimony with the Government lawyers, the defense lawyers, or their own lawyers 
before the witnesses appeared in court. 
Although you may consider that fact when you are evaluating a witness's credibility, I 
should tell you that there is nothing either unusual or improper about a witness meeting with 
lawyers before testifying so that the witness can be aware of the subjects he or she will be 
questioned about, focus on those subjects, and have the opportunity to review relevant exhibits 
before being questioned about them. Such consultation helps conserve your time and the Court's 
time. In fact, it would be unusual for a lawyer to call a witness without such consultation. 
Again, the weight you give to the fact or the nature of the witness's preparation for his or 
her testimony and what inferences you draw from such preparation are matters completely within 
your discretion. 
Adopted from the charge of the Hon. Alison J. Nathan in United States 
v. Jones, 16 Cr. 553 (AJN) and in United States v. Pizarro, 17 Cr. 151 
(AJN); the charge of the Hon. Kimba M. Wood in United States v. 
Almonte, 16 Cr. 670 (KMW); and the charge of the Hon. P. Kevin 
Castel in United States v. William Walters, 16 Cr. 338 (PKC). 
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EFTA00074582

Redaction Of Evidentiary Items 
[If Applicable] 
We have, among the exhibits received in evidence, some documents that are redacted. 
"Redacted" means that part of the document has been taken out. Material may be redacted for any 
number of reasons, including that it is not relevant to the issues you must decide in this case, among 
other reasons. You are to concern yourself only with the part of the item that has been admitted 
into evidence, and you should not consider any possible reason for the redactions. 
Adapted from the charge of the Hon. Alison J. Nathan in United 
States v. Jones, 16 Cr. 553 (AJN); and the charge of the Hon. Richard 
J. Sullivan, Jury Charge, United States v. Adony Nina, et al., 13 Cr. 
322 (S.D.N.Y. 2013). 
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Charts and Summaries — Admitted as Evidence 
[If Applicable] 
Now, some of the exhibits that were admitted into evidence were in the form of charts 
and summaries. For these charts and summaries that were admitted into evidence, you should 
consider them as you would any other evidence, which includes assessing the accuracy of the 
information contained in those charts or summaries. 
Adapted from Sand, et al., Modern Federal Jury Instructions, Instr. 
5-12; and the charge of the Hon. Alison J. Nathan in United States v. 
Jones, 16 Cr. 553 (MN). See also Fed. R. Evid. 1006. 
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EFTA00074584

Stipulations 
[If Applicable] 
In this case you have heard evidence in the form of stipulations. 
A stipulation of testimony is an agreement among the parties that, if called, a witness 
would have given certain testimony. You must accept as true the fact that the witness would 
have given the testimony. However, it is for you to determine the effect or weight to give 
that testimony. 
You also heard evidence in the form of stipulations that contain facts that were agreed to 
be true. In such cases, you must accept those facts as true. 
Adapted from the charge of the Hon. Alison J. Nathan in United States 
v. Jones, 16 Cr. 553 (AJN) and in United States v. Pizarro, 17 Cr. 151 
(MN); the charge of the Hon. P. Kevin Castel in United States v. 
William Walters, 16 Cr. 338 (PKC); and from Sand, et al., Modern 
Federal Jury Instructions, Innis. 5-6 & 5-7. 
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EFTA00074585

Punishment Not to be Considered by the Jury 
Under your oath as jurors, you cannot allow a consideration of possible punishment that 
may be imposed upon a defendant, if convicted, to influence you in any way or in any sense to 
enter into your deliberations. The duty of imposing sentence is mine and mine alone. Your 
function is to weigh the evidence in the case and to determine whether the defendant is or is not 
guilty upon the basis of evidence and the law. 
Therefore, I instruct you not to consider punishment or possible punishment in any way 
in your deliberations in this case. 
Adapted from the charge of the Hon. Alison J. Nathan in United 
States v. Pizarro, 17 Cr. 151 (MN); from the charge of the Hon. Denise 
L. Cote in United States v. Purcell, 18 Cr. 081 (DLC); and charge 
of the Hon. P. Kevin Castel in United States v. William Walters, 16 
Cr. 338 (PKC). 
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EFTA00074586

Right to Hear Testimony; Election of Foreperson; Communications with the Court; Juror 
Note-Taking 
You are about to go into the jury room and begin your deliberations. The documentary 
evidence will be sent back with you. If you want any of the testimony read to you, that can be 
arranged. But please remember that it is not always easy to locate what you might want, so be as 
specific as you possibly can in requesting portions of the testimony that you might want. 
Your first task as a jury will be to choose your foreperson. The foreperson has no greater 
voice or authority than any other juror, but is the person who will communicate with the Court 
through written note when questions arise and to indicate when you have reached your verdict. 
Your requests for testimony—in fact, any communications with the Court— should be 
made to me in writing, signed by your foreperson, and given to one of the Marshals. I will 
respond to any questions or requests you have as promptly as possible, either in writing or by 
having you return to the courtroom so I can speak with you in person. In any communication, 
please do not tell me or anyone else how the jury stands on the issue of the jury's verdict until 
after a unanimous verdict is reached. 
For those of you who took notes during the course of the trial, you should not show your 
notes to or discuss your notes with any other juror during your deliberations. Any notes you have 
taken are to assist you and you alone. The fact that a particular juror has taken notes entitles that 
juror's views to no greater weight than those of any other juror. 
Finally, your notes are not to substitute for your recollection of the evidence in this case. 
If you have any doubt as to any testimony, you may request that the official trial transcript that 
has been made of these proceedings be read or otherwise provided to you. 
Adapted from the charge of the Hon. Alison J. Nathan in United 
States v. Lebedev, 15 Cr. 769 (AJN), in United States v. Jones, 16 Cr. 
553 (AJN), and in United States v. Pizarro, 17 Cr. 151 (MN). 
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CONCLUDING REMARKS 
Members of the jury, that about concludes my instructions to you. The most important 
part of this case, members of the jury, is the part that you as jurors are now about to play as you 
deliberate on the issues of fact. It is for you, and you alone, to weigh the evidence in this case 
and determine whether the Government has proved beyond a reasonable doubt each of the 
essential elements of the crime with which each Defendant is charged. If the Government has 
succeeded, your verdict should be guilty as to that Defendant and that charge; if it has failed, 
your verdict should be not guilty as to that Defendant and that charge. 
You must base your verdict solely on the evidence or lack of evidence and these 
instructions as to the law, and you are obliged under your oath as jurors to follow the law as I 
have instructed you, whether you agree or disagree with the particular law in question. 
Under your oath as jurors, you are not to be swayed by sympathy. You should be guided 
solely be the evidence presented during the trial and the law as I gave it to you, without regard 
to the consequences of your decision. You have been chosen to try the issues of fact and reach a 
verdict on the basis of the evidence or lack of evidence. If you let sympathy interfere with your 
clear thinking, there is a risk that you will not arrive at a just verdict. 
As you deliberate, please listen to the opinions of your fellow jurors, and ask for an 
opportunity to express your own views. Every juror should be heard. No one juror should hold 
center stage in the jury room and no one juror should control or monopolize the deliberations. 
If, after listening to your fellow jurors and if, after stating your own view, you become 
convinced that your view is wrong, do not hesitate because of stubbornness or pride to change 
your view. On the other hand, do not surrender your honest convictions and beliefs solely 
because of the opinions of your fellow jurors or because you are outnumbered. Your final vote 
must reflect your conscientious belief as to how the issues should be decided. 
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Thus, the verdict must represent the considered judgment of each juror. In order to 
return a verdict, it is necessary that each juror agree to it. Your verdict must be unanimous. 
If at any time you are divided, do not report how the vote stands, and if you have 
reached a verdict, do not report what it is until you are asked in open court. 
A verdict form has been prepared for your convenience. After you have reached your 
decision, your foreperson will fill in the form. At that point the foreperson should advise the 
marshal outside your door that you are ready to return to the courtroom. 
Finally, I say this not because I think it is necessary, but because it is the custom in this 
courthouse to say this: You should treat each other with courtesy and respect during your 
deliberations. 
In conclusion, ladies and gentlemen, I am sure that if you listen to the views of your 
fellow jurors, and if you apply your own common sense, you will deliberate fairly. 
Dated: New York, New York 
October 
2021 
Respectfully submitted, 
DAMIAN WILLIAMS 
[Defense signature block] 
United States Attorney 
By: 
Assistant United States Attorneys 
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