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Indictment - United States v. Maurice Fayne related docket

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CourtU.S. District Court for the Northern District of Georgia
Filed2022-06-30

U.S. District Court for the Northern District of Georgia · No. 1:20-cr-00228-MHC-JKL · Doc. 276 · 2022-06-30 · Docket on CourtListener

Summary

The government's supplemental jury instructions in United States of America v. Daniel Eric Jay, No. 1:20-CR-228-MHC-JKL, in the U.S. District Court for the Northern District of Georgia, filed June 30, 2022 as Document 276. The filing submits two proposed instructions: a corrected instruction on bank fraud under 18 U.S.C. § 1344 and the Eleventh Circuit pattern instruction on punishment, which it says was omitted from the original proposed instructions. The bank fraud instruction lists four elements, including that the financial institution was federally insured, and defines scheme to defraud, material fact and intent to defraud. The punishment instruction tells jurors to consider each count separately and never to consider punishment in deciding guilt. The five-page filing is signed by two Assistant United States Attorneys.

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Page 1 of 5 
IN THE UNITED STATES DISTRICT COURT 
FOR THE NORTHERN DISTRICT OF GEORGIA 
ATLANTA DIVISION 
 
UNITED STATES OF AMERICA 
v. 
DANIEL ERIC JAY 
CRIMINAL INDICTMENT 
1:20-CR-228-MHC-JKL 
SECOND SUPERSEDING 
 
Government’s Supplemental Jury Instructions 
The United States of America hereby submits two proposed jury 
instructions. One is a corrected instruction on bank fraud. The other is the 
Eleventh Circuit’s pattern instruction on punishment, which was inadvertently 
omitted from the Government’s original proposed jury instructions. 
Respectfully submitted, 
RYAN K. BUCHANAN 
United States Attorney 
 
/S/ JOHN RUSSELL PHILLIPS 
Assistant United States Attorney 
Georgia Bar Number 576335 
 
/s/ BERNITA B. MALLOY 
Assistant United States Attorney 
Georgia Bar Number 718905 
600 U.S. Courthouse 
75 Ted Turner Drive, SW 
Atlanta, GA 30303 
(404) 581-6000 
 
Case 1:20-cr-00228-MHC-JKL     Document 276     Filed 06/30/22     Page 1 of 5

Page 2 of 5 
O52 
Bank Fraud 
18 U.S.C. § 1344 
It’s a Federal crime to carry out or attempt to carry out a scheme to 
defraud a financial institution, or to get money or property owned or controlled 
by a financial institution by using false pretenses, representations, or promises. 
The Defendant can be found guilty of this crime only if all the following 
facts are proved beyond a reasonable doubt: 
 the Defendant knowingly carried out or attempted to carry out a 
scheme to defraud a financial institution or to get money from a 
financial institution by using false or fraudulent pretenses, 
representations, or promises about a material fact; 
 the false or fraudulent pretenses, representations, or promises were 
material; 
 the Defendant intended to defraud the financial institution or 
someone; and 
 the financial institution was federally insured. 
A “scheme to defraud” includes any plan or course of action intended to 
deceive or cheat someone out of money or property by using false or fraudulent 
pretenses, representations, or promises relating to a material fact. 
A statement or representation is “false” or “fraudulent” if it is about a 
material fact that the speaker knows is untrue or makes with reckless 
indifference as to the truth and makes with intent to defraud. A statement or 
Case 1:20-cr-00228-MHC-JKL     Document 276     Filed 06/30/22     Page 2 of 5

Page 3 of 5 
representation may be “false” or “fraudulent” when it’s a half truth or effectively 
conceals a material fact and is made with the intent to defraud. 
A “material fact” is an important fact that a reasonable person would use 
to decide whether to do or not do something. A fact is “material” if it has the 
capacity or natural tendency to influence a person’s decision. It doesn’t matter 
whether the decision-maker actually relied on the statement or knew or should 
have known that the statement was false. 
To act with “intent to defraud” means to act knowingly and with the 
specific intent to use false or fraudulent pretenses, representations, or promises 
to cause loss or injury.  Proving intent to deceive alone, without the intent to 
cause loss or injury, is not sufficient to prove intent to defraud. 
The Government doesn’t have to prove all the details alleged in the 
indictment about the precise nature and purpose of the scheme. It also doesn’t 
have to prove that the alleged scheme actually succeeded in defrauding anyone. 
What must be proved beyond a reasonable doubt is that the Defendant 
knowingly attempted or carried out a scheme substantially similar to the one 
alleged in the indictment. 
 
 
Case 1:20-cr-00228-MHC-JKL     Document 276     Filed 06/30/22     Page 3 of 5

Page 4 of 5 
B10.2 
Caution: Punishment 
(Single Defendant, Multiple Counts) 
Each count of the indictment charges a separate crime. You must consider 
each crime and the evidence relating to it separately. If you find the Defendant 
guilty or not guilty of one crime, that must not affect your verdict for any other 
crime. 
I caution you that the Defendant is on trial only for the specific crimes 
charged in the indictment. You’re here to determine from the evidence in this 
case whether the Defendant is guilty or not guilty of those specific crimes. 
You must never consider punishment in any way to decide whether the 
Defendant is guilty. If you find the Defendant guilty, the punishment is for the 
Judge alone to decide later. 
 
 
Case 1:20-cr-00228-MHC-JKL     Document 276     Filed 06/30/22     Page 4 of 5

Page 5 of 5 
CERTIFICATE OF SERVICE 
I hereby certify that, on June 30, 2022, I electronically filed the foregoing 
document with the Clerk of Court using the CM/ECF system. 
 
JOHN RUSSELL PHILLIPS 
ASSISTANT UNITED STATES ATTORNEY 
GEORGIA BAR NO. 576335 
 
 
 
600 U.S. Courthouse 
75 Ted Turner Drive, SW 
Atlanta, GA 30303 
(404) 581-6000 
Case 1:20-cr-00228-MHC-JKL     Document 276     Filed 06/30/22     Page 5 of 5

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