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nduct, which will somehow prejudice the defendant. (Def. Mot. 4 at 13). The Court should not assume that the jury will speculate about principles of United Kingdom law and apply them to this case. The Court will properly instruct the jury on the elements of the offenses charged in the Indictment and the evidenc
of minor victims is regularly admitted for similar purposes in cases where charges allege sexual activity with minors. See, e.g., United States v. Vickers, 708 F. App'x 732, 737 (2d Cir. 2017) ("As to the testimony concerning Vickers' grooming' of his victims, we conclude that such evidence was admissi
endant takes issue with the Indictment's reference to these sex acts as "abuse" because, she asserts, Minor Victim-3 was above the age of consent in the United Kingdom at the time they occurred. The description in the Indictment is factually accurate, however, because Minor Victim- 3 will testify to her subjective
used to describe the window of when a violation occurred." (citing United States v. Nersesian, 824 F2d 1294, 1323 (2d Cir. 1987)); United States v. Vickers, No. 13 Cr. 128 (RJA) (HKS), 2014 WL 154 EFTA00100121 1838255, at *1, 4-6 (W.D.N.Y. May 8, 2014) (denying motion to dismiss indictment charging
endant takes issue with the Indictment's reference to these sex acts as "abuse" because, she asserts, Minor Victim-3 was above the age of consent in the United Kingdom at the time they occurred. The description in the Indictment is factually accurate, however, because Minor Victim- 3 will testify to her subjective
sed to describe the window of when a violation occurred." (citing United States v. Nersesian, 824 F.2d 1294, 1323 (2d Cir. 1987)); United States v. Vickers, No. 13 Cr. 128 (RJA) (HKS), 2014 WL 154 EFTA00077786 1838255, at *1, 4-6 (W.D.N.Y. May 8, 2014) (denying motion to dismiss indictment charging
endant takes issue with the Indictment's reference to these sex acts as "abuse" because, she asserts, Minor Victim-3 was above the age of consent in the United Kingdom at the time they occurred. The description in the Indictment is factually accurate, however, because Minor Victim- 3 will testify to her subjective
sed to describe the window of when a violation occurred." (citing United States v. Nersesian, 824 F.2d 1294, 1323 (2d Cir. 1987)); United States v. Vickers, No. 13 Cr. 128 (RJA) (HKS), 2014 WL 154 EFTA00039601 1838255, at *1, 4-6 (W.D.N.Y. May 8, 2014) (denying motion to dismiss indictment charging
motion takes issue with the Indictment's reference to these sex acts as "abuse" because, the assert, Minor Victim-3 was above the age of consent in the United Kingdom at the time they occurred. The description in the Indictment is factually accurate, however, because Minor Victim-3 subjectively experienced these
sed to describe the window of when a violation occurred." (citing United States v. Nersesian, 824 F.2d 1294, 1323 (2d Cir. 1987)); United States v. Vickers, 13 Cr. 128 (MA) (HKS), 2014 WL 1838255, at *1, 4-6 (W.D.N.Y. May 8, 2014) (denying motion to dismiss indictment charging enticement of a minor, in
endant takes issue with the Indictment's reference to these sex acts as "abuse" because, she asserts, Minor Victim-3 was above the age of consent in the United Kingdom at the time they occurred. The description in the Indictment is factually accurate, however, because Minor Victim- 3 will testify to her subjective
sed to describe the window of when a violation occurred." (citing United States v. Nersesian, 824 F.2d 1294, 1323 (2d Cir. 1987)); United States v. Vickers, No. 13 Cr. 128 (RJA) (HKS), 2014 WL 154 EFTA00103179 1838255, at *1, 4-6 (W.D.N.Y. May 8, 2014) (denying motion to dismiss indictment charging
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