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10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 precluding the term "victim" is both unnecessary and impractical. United States v. Dupigny, 18 CR 528, transcript of October 17, 2019, Docket No. 198 at 50. It is appropriate for the government to use the terms as representative of its l
of evidence and the court's instructions "taken as a whole clarify the government's burden of proving all elements of the crime." United States v. Washburn, 444 F.3d, 1007, 1113 (8th Cir. 2006); see also, Server v. Mizell, 902 F.2d 611, 615, (7th Cir. 1990); United States v. Granbois, 119 F.App'x 35,
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 precluding the term "victim" is both unnecessary and impractical. United States v. Dupigny, 18 CR 528, transcript of October 17, 2019, Docket No. 198 at 50. It is appropriate for the government to use the terms as representative of its l
Page: EFTA00023369 →of evidence and the court's instructions "taken as a whole clarify the government's burden of proving all elements of the crime." United States v. Washburn, 444 F.3d, 1007, 1113 (8th Cir. 2006); see also, Server v. Mizell, 902 F.2d 611, 615, (7th Cir. 1990); United States v. Granbois, 119 F.App'x 35,
Page: EFTA00023369 →10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 precluding the term "victim" is both unnecessary and impractical. United States v. Dupigny, 18 CR 528, transcript of October 17, 2019, Docket No. 198 at 50. It is appropriate for the government to use the terms as representative of its l
of evidence and the court's instructions "taken as a whole clarify the government's burden of proving all elements of the crime." United States v. Washburn, 444 F.3d, 1007, 1113 (8th Cir. 2006); see also, Server v. Mizell, 902 F.2d 611, 615, (7th Cir. 1990); United States v. Granbois, 119 F.App'x 35,
ncluding the psychological relationship between pimps and the women prostituted by them"); Notice and Oct. 17, 2019 Tr. at 27:1-12, United States v. Dupigny, No. 18 Cr. 528 (JMF) (S.D.N.Y.), Dkt. Nos. 180-1, 198 (permitting expert testimony on "the psychological relationship between a pimp and the woman
he "jury will not be unduly prejudiced against [the defendant] if the government refers to certain witnesses as victims"); (citing United States v. Washburn, 444 F.3d 1007, 1013 (8th Cir. 2006) ("[A] number of courts have determined that the use of the term "victim" in jury instructions is not prejudicia
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 precluding the term "victim" is both unnecessary and impractical. United States v. Dupigny, 18 CR 528, transcript of October 17, 2019, Docket No. 198 at 50. It is appropriate for the government to use the terms as representative of its l
of evidence and the court's instructions "taken as a whole clarify the government's burden of proving all elements of the crime." United States v. Washburn, 444 F.3d, 1007, 1113 (8th Cir. 2006); see also, Server v. Mizell, 902 F.2d 611, 615, (7th Cir. 1990); United States v. Granbois, 119 F.App'x 35,
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