United States v. Reis and Hockridge, N.D. Tex. No. 4:24-cr-00287-O, Doc. 222: Jury charge (Hockridge trial) (2025-06-20)
Summary
The court's jury charge, Document 222 in United States of America v. Stephanie Hockridge, a/k/a Stephanie Reis, Case No. 4:24-cr-00287-O (N.D. Tex., Fort Worth Division), filed 06/20/25. It instructs jurors on the presumption of innocence, the government's burden of proof beyond a reasonable doubt, direct and circumstantial evidence, and witness credibility. The charge states that witnesses Flores and Karnezis were convicted of conspiracy to commit wire fraud, and that testimony of alleged accomplices who entered plea agreements must be weighed with greater care and caution. It also covers opinion testimony from David Abshier concerning the PPP Program and when a statement is "material". The charge is signed June 20, 2025.
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“United States v. Reis and Hockridge, N.D. Tex. No. 4:24-cr-00287-O, Doc. 222: Jury charge (Hockridge trial) (2025-06-20).”
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/ Case 4:24-cr-00287-O Document 222 Filed 06/20/25 Pagelof21 PagelD 2508 / IN THE UNITED STATES DISTRICT COURT. FOR THE NORTHERN DISTRICT OF TEXAS,,,0 52588 T COURT vas FORT WORTH DIVISION | FILL UNITED STATES OF AMERICA, § j POMS Plaintiff, § Bienen § V. § Case No. 4:24 CR-00287-O § STEPHANIE HOCKRIDGE, a/k/a § (02) STEPHANIE REIS, § § Defendants. § JURY CHARGE Members of the Jury: In any jury trial there are, in effect, two judges. I am one of the judges; the other is the jury. It is my duty to preside over the trial and to decide what evidence is proper for your consideration. It is also my duty at the end of the trial to explain to you the rules of law that you must follow and apply in arriving at your verdict. First, I will give you some general instructions which apply in every case, for example, instructions about burden of proof and how to judge the believability of witnesses. Then I will give you some specific rules of law about this particular case, and finally I will explain to you the procedures you should follow in your deliberations. You, as jurors, are the judges of the facts. But in determining what actually happened—that is, in reaching your decision as to the facts—it is your sworn duty to follow all of the rules of law as I explain them to you. Case 4:24-cr-00287-O Document 222 Filed 06/20/25 Page2of21 PagelD 2509 You have no right to disregard or give special attention to any one instruction, or to question the wisdom or correctness of any rule I may state to you. You must not substitute or follow your own notion or opinion as to what the law is or ought to be. It is your duty to apply the law as I explain it to you, regardless of the consequences. It is also your duty to base your verdict solely upon the evidence, without prejudice or sympathy. That was the promise you made and the oath you took before being accepted by the parties as jurors, and they have the right to expect nothing less. The indictment or formal charge against a defendant is not evidence of guilt. Indeed, the defendant is presumed by the law to be innocent. The defendant begins with a clean slate. The law does not require a defendant to prove her innocence or produce any evidence at all and no inference whatsoever may be drawn from the election of a defendant not to testify. The government has the burden of proving the defendant guilty beyond a reasonable doubt, and if it fails to do so, you must acquit the defendant. While the government’s burden of proof is a strict or heavy burden, it is not necessary that the defendant’s guilt be proved beyond all possible doubt. It is only required that the government’s proof exclude any “reasonable doubt” concerning the defendant’s guilt. A “reasonable doubt” is a doubt based upon reason and common sense after careful and impartial consideration of all the evidence in the case. Proof beyond a reasonable doubt, therefore, is proof of such a convincing character that you would be willing to rely and act upon it without hesitation in making the most important decisions of your own 2 Case 4:24-cr-00287-O Document 222 Filed 06/20/25 Page3of21 PagelD 2510 affairs. As I told you earlier, it is your duty to determine the facts. To do so, you must consider only the evidence presented during the trial. Evidence is the sworn testimony of the witnesses, including stipulations, and the exhibits. The questions, statements, objections, and arguments made by the lawyers are not evidence. The function of the lawyers is to point out those things that are most significant or most helpful to their side of the case, and in so doing to call your attention to certain facts or inferences that might otherwise escape your notice. In the final analysis, however, it is your own recollection and interpretation of the evidence that controls in the case. What the lawyers say is not binding upon you. During the trial I sustained objections to certain questions and exhibits. You must disregard those questions and exhibits entirely. Do not speculate as to what the witness would have said if permitted to answer the question or as to the contents of an exhibit. Also, certain testimony or other evidence has been ordered removed or redacted from the record and you have been instructed to disregard this evidence. Do not consider any testimony or other evidence which has been removed from your consideration in reaching your decision. Further, do not speculate about what information, if any, has been redacted from exhibits admitted into evidence during trial. Your verdict must be based solely on the legally admissible evidence and testimony. Also, do not assume from anything I may have done or said during the trial that I have any opinion concerning any of the issues in this case. Except for the instructions to 3 Case 4:24-cr-00287-O Document 222 Filed 06/20/25 Page4of21 PagelD 2511 you on the law, you should disregard anything I may have said during the trial in arriving at your own verdict. In considering the evidence, you are permitted to draw such reasonable inferences from the testimony and exhibits as you feel are justified in the light of common experience. In other words, you may make deductions and reach conclusions that reason and common sense lead you to draw from the facts which have been established by the evidence. Do not be concerned about whether evidence is “direct evidence” or “circumstantial evidence.” You should consider and weigh all of the evidence that was presented to you. “Direct evidence” is the testimony of one who asserts actual knowledge of a fact, such as an eyewitness. “Circumstantial evidence” is proof of a chain of events and circumstances indicating that something is or is not a fact. The law makes no distinction between the weights to be given either direct or circumstantial evidence. But the law requires that you, after weighing all of the evidence, whether direct or circumstantial, be convinced of the guilt of the defendant beyond a reasonable doubt before you can find her guilty. I remind you that it is your job to decide whether the government has proved the guilt of the defendant beyond a reasonable doubt. In doing so, you must consider all of the evidence. This does not mean, however, that you must accept all of the evidence as true or accurate. You are the sole judges of the credibility or “believability” of each witness and the weight to be given to the witness’s testimony. An important part of your job will be making 4 Case 4:24-cr-00287-O Document 222 Filed 06/20/25 Page5of21 PagelD 2512 judgments about the testimony of the witnesses who testified in this case. You should decide whether you believe all, some part, or none of what each person had to say, and how important that testimony was. In making that decision I suggest that you ask yourself a few questions: Did the witness impress you as honest? Did the witness have any particular reason not to tell the truth? Did the witness have a personal interest in the outcome of the case or their own case? Did the witness have any relationship with either the government or the defense? Did the witness seem to have a good memory? Did the witness clearly see or hear the things about which he or she testified? Did the witness have the opportunity and ability to understand the questions clearly and answer them directly? Did the witness’s testimony differ from the testimony of other witnesses? These are a few of the considerations that will help you determine the accuracy of what each witness said. Your job is to think about the testimony of each witness you have heard and decide how much you believe of what each witness had to say. In making up your mind and reaching a verdict, do not make any decisions simply because there were more witnesses on one side than on the other. Do not reach a conclusion on a particular point just because there were more witnesses testifying for one side on that point. You will always bear in mind that the law never imposes upon a defendant in a criminal case the burden or duty of calling any witnesses or producing any evidence. The testimony of a witness may be discredited by showing that the witness testified falsely, or by evidence that at some other time the witness said or did something, or failed Case 4:24-cr-00287-O Document 222 Filed 06/20/25 Page6of21 PagelD 2513 to say or do something, which is inconsistent with the testimony the witness gave at this trial. Earlier statements of a witness were not admitted in evidence to prove that the contents of those statements are true. You may not consider the earlier statements to prove that the content of an earlier statement is true; you may only use earlier statements to determine whether you think the earlier statements are consistent or inconsistent with the trial testimony of the witness and therefore whether they affect the credibility of that witness, If you believe that a witness has been discredited in this manner, it is your exclusive right to give the testimony of that witness whatever weight you think it deserves, or no weight at all. You have been told that witnesses Flores and Karnezis were convicted of conspiracy to commit wire fraud. A conviction is a factor you may consider in deciding whether to believe that witness, but it does not necessarily destroy the witness’s credibility. It has been brought to your attention only because you may wish to consider it when you decide whether you believe the witness’s testimony. It is not evidence of anything else. The testimony of an alleged accomplice, and/or the testimony of one who provides evidence against a defendant, for immunity from or reduction in punishment, or for personal advantage or vindication, must always be examined and weighed by the jury with greater care and caution than the testimony of ordinary witnesses. You, the jury, must Case 4:24-cr-00287-O Document 222 Filed 06/20/25 Page7of21 PagelD 2514 decide whether the witness’s testimony has been affected by these circumstances, by the witness’s interest in the outcome of the case, by prejudice against the defendant, or by the benefits that the witness has received or may expect or hope to receive, either financially or as a result of being immunized from prosecution or having their own punishment reduced. You should keep in mind that such testimony is always to be received with caution and weighed with great care. You should not convict any defendant upon the unsupported testimony of such a witness unless you believe that testimony beyond a reasonable doubt. In this case the government called as witnesses multiple alleged accomplices, with whom the government has entered into plea agreements. These agreements provide that the witnesses would each be charged with one count of conspiracy to commit wire fraud and that the government would not bring any additional charges for conduct underlying and relating to that conspiracy. In the case of Eric Karnezis and Jimmy Flores, the agreements included a nonbinding recommendation to the judge to reduce their sentence. Such plea bargaining, as it is called, has been approved as lawful and proper, and is expressly provided for in the rules of this court. An alleged accomplice, including one who has entered into a plea agreement with the government, is not prohibited from testifying. On the contrary, the testimony of such a witness may alone be of sufficient weight to sustain a verdict of guilty. You should keep in mind that such testimony is always to be received with caution and weighed with great Case 4:24-cr-00287-O Document 222 Filed 06/20/25 Page8of21 PagelD 2515 care. You should never convict a defendant upon the unsupported testimony of an alleged accomplice unless you believe that testimony beyond a reasonable doubt. The fact that an accomplice has entered a plea of guilty to a similar offense is not evidence of the guilt of any other person. You should never convict any defendant upon the unsupported testimony of such a witness unless you believe that testimony beyond a reasonable doubt. During the trial you heard the testimony of David Abshier, who expressed opinions concerning the PPP Program. If scientific, technical, or other specialized knowledge might assist the jury in understanding the evidence or in determining a fact in issue, a witness qualified by knowledge, skill, experience, training, or education may testify and state an opinion concerning such matters, Merely because such a witness has expressed an opinion does not mean, however, that you must accept this opinion. You should judge such testimony like any other testimony. You may accept it or reject it and give it as much weight as you think it deserves, considering the witness’s education and experience, the soundness of the reasons given for the opinion, and all other evidence in the case. You will note that the Indictment charges that the offenses were committed “on or about” or “in or about” a specified date. The government does not have to prove that the crime was committed on that exact date, so long as the government proves beyond a reasonable doubt that the defendant committed each crime on a date reasonably near the Case 4:24-cr-00287-O Document 222 Filed 06/20/25 Page9of21 PagelD 2516 date stated in the indictment. You are here to decide whether the government has proved beyond a reasonable doubt that the defendant is guilty of the crimes charged. The defendant is not on trial for any act, conduct, or offense not alleged in the indictment. Neither are you called upon to return a verdict as to the guilt of any other person or persons not on trial as a defendant in this case. Ifa defendant is found guilty, it will be my duty to decide what the punishment will be. You should not be concerned with punishment in any way. It should not enter your consideration or discussion. A separate crime is charged in each count of the indictment. Each count, and the evidence pertaining to it, should be considered separately. If you find the defendant guilty or not guilty as to one of the crimes charged, that should not control your verdict as to any other. As used in these instructions, a representation or statement is “material” if it has a natural tendency to influence, or is capable of influencing, the decision of the person or entity to which it is addressed. The Government can prove materiality in either of two ways. First, a representation or statement is “material” if a reasonable person would attach importance to its existence or nonexistence in determining his choice of action in the transaction in question. Second, a statement could be material, even though only an Case 4:24-cr-00287-O Document 222 Filed 06/20/25 Page10of21 PagelD 2517 unreasonable person would rely on it, if the person who made the statement knew or had reason to know his victim was likely to rely on it. In determining materiality, you should consider that naivety, carelessness, negligence, or stupidity of a victim does not excuse criminal conduct, if any, on the part of the defendant. The word “knowingly,” as that term has been used from time to time in these instructions, means that the act was done voluntarily and intentionally, not because of mistake or accident. You may find that a defendant had knowledge of a fact if you find that the defendant deliberately closed her eyes to what would otherwise have been obvious to her. While knowledge on the part of the defendant cannot be established merely by demonstrating that the defendant was negligent, careless, or foolish, knowledge can be inferred if the defendant deliberately blinded herself to the existence of a fact. One of the issues in this case is whether the Defendant acted in good faith. Good faith is a complete defense to the crime of wire fraud if the defendant did not act with the intent to defraud, which is an element of the charge. The essence of the good faith defense is that one who acts with honest intentions cannot be convicted of a crime requiring fraudulent intent. The phrase ‘good faith’ includes, among other things, an opinion or belief honestly held, even if the opinion is in error or the belief is mistaken. However, even though a defendant held a certain opinion or belief, a defendant does not act in good faith if he or she also knowingly made false or fraudulent representations or promises or otherwise acted 10 Case 4:24-cr-00287-O Document 222 Filed 06/20/25 Page11lof21 PagelD 2518 with the intent to defraud or deceive another. You have heard testimony in this case regarding various rules, regulations, and guidance issued by the Small Business Administration, or “SBA,” under the Paycheck Protection Program, or “PPP,” namely, related to the program’s purpose, loan requirements, and how loan proceeds are disbursed. You have also heard testimony of various tax laws and documents. Ms. Hockridge is charged with conspiracy to commit wire fraud and wire fraud. She is not charged in this case with violating any SBA rules, regulations, or guidance. She is also not charged with violating any tax laws. It is your duty to determine if the government has established her guilt to the crimes charged, not to any other matter. The government has introduced audio recordings that have an accompanying transcript of the oral conversation which can be heard on the audio recordings received in evidence. The transcript also purports to identify the speakers engaged in such conversation. I have admitted the transcript for the limited and secondary purpose of aiding you in following the content of the conversation as you listen to the tape recording, and also to aid you in identifying the speakers. You are specifically instructed that whether the transcript correctly or incorrectly reflects the content of the conversation or the identity of the speakers is entirely for you to determine based upon your own evaluation of the testimony you have heard concerning the 11 Case 4:24-cr-00287-O Document 222 Filed 06/20/25 Page12of21 PagelD 2519 preparation of the transcript, and from your own examination of the transcript in relation to your hearing of the tape recording itself as the primary evidence of its own contents; and, if you should determine that the transcript is in any respect incorrect or unreliable, you should disregard it to that extent. It is what you hear on the tape that is evidence, not the transcripts. During the course of trial, you have heard evidence that law enforcement officers, as part of their investigation, sought and obtained search warrants from judges. You may not infer from the fact that these warrants were court-ordered that the defendant or any of the alleged co-conspirators committed any of the offenses charged. That information was provided to you solely for the purpose of informing you how the government obtained certain evidence introduced in this case. Certain charts and summaries have been shown to you solely as an aid to help explain the facts disclosed by evidence (testimony, books, records, and other documents) in the case. These charts and summaries are not admitted evidence or proof of any facts. You should determine the facts from the evidence that has been admitted. Certain charts and summaries of other records have been received into evidence. They should be considered like any other evidence in the case. You should give them only such weight as you think they deserve. The charts and summaries include inferences or conclusions drawn from the records underlying them. It is up to you to determine if these inferences or conclusions are accurate. 12 Case 4:24-cr-00287-O Document 222 Filed 06/20/25 Page130f21 PagelD 2520 The underlying records are the best evidence of what occurred. Count One of the indictment charges the defendant with conspiracy in violation of Title 18, United States Code, Section 1349. Section 1349 makes it a crime for anyone to conspire with someone else to do something which, if actually carried out, would be a violation of Title 18, United States Code, Section 1343 (Wire Fraud). A “conspiracy” is an agreement between two or more persons to join together to accomplish some unlawful purpose. It is a kind of “partnership in crime” in which each member becomes the agent of every other member. For you to find the defendant guilty of this charge, you must be convinced that the government has proved each of the following beyond a reasonable doubt: First: That the defendant and at least one other person made an agreement to commit the crime of wire fraud; Second: That the defendant knew the unlawful purpose of the agreement; and Third: That the defendant joined in the agreement willfully, that is, with the specific intent to further the unlawful purpose. I will separately instruct you on the elements of wire fraud, which is the object of the conspiracy charged in the indictment. One may become a member of a conspiracy without knowing all the details of the unlawful scheme or the identities of all the other alleged conspirators. If a defendant understands the unlawful nature of a plan or scheme and knowingly and intentionally joins 13 Case 4:24-cr-00287-O Document 222 Filed 06/20/25 Pagei14of21 PagelD 2521 in that plan or scheme on one occasion, that is sufficient to convict her for conspiracy even though the defendant had not participated before and even though the defendant played only a minor part. The government need not prove that the alleged conspirators entered into any formal written or oral agreement, nor that they directly stated between themselves all the details of the scheme. Similarly, the government need not prove that all of the details of the scheme alleged in the indictment were actually agreed upon or carried out. Nor must it prove that all of the persons alleged to have been members of the conspiracy were such, or that the alleged conspirators actually succeeded in accomplishing their unlawful objectives. Mere presence at the scene of an event, even with knowledge that a crime is being committed, or the mere fact that certain persons may have associated with each other, and may have assembled together and discussed common aims and interests, does not necessarily establish proof of the existence of a conspiracy. Merely being married to a person who commits a crime does not support the inference that the spouse conspired to commit a crime. You may, if you choose, consider the marriage as circumstantial evidence of knowledge. Also, a person who has no knowledge of a conspiracy, but who happens to act in a way which advances some purpose of a conspiracy, does not thereby become a conspirator. You must determine whether the conspiracy charged in the indictment existed, and, if it did, whether the defendant was a member of it. If you find that the conspiracy charged did not exist, then you must return a not guilty verdict, even though you find that some 14 Case 4:24-cr-00287-O Document 222 Filed 06/20/25 Page15of21 PagelD 2522 other conspiracy existed. If you find that a defendant was not a member of the conspiracy charged in the indictment, then you must find that defendant not guilty, even though that defendant may have been a member of some other conspiracy. The events presented at trial happened in various places. There is no requirement that the entire conspiracy take place in the Northern District of Texas, but in order for you to return a guilty verdict, the government must prove by a preponderance of the evidence that either the agreement or an overt act took place in this district, even if the defendant never set foot in the district. An overt act is an act performed to affect the object of a conspiracy, although it remains separate and distinct from the conspiracy itself. Though the overt act need not be of criminal nature, it must be done in furtherance of the object of the conspiracy. Unlike the other elements of the offense, this is a fact that the government has to prove only by a preponderance of the evidence. This means the government has to convince you only that it is more likely than not that part of the conspiracy took place in the Northern District of Texas, All other elements of the offense must be proved beyond a reasonable doubt. You are instructed that Amarillo, Bedford, Dallas, and Tarrant County, Texas are located in the Northern District of Texas. Title 18, United States Code, Section 1343, makes it a crime for anyone to use interstate wire communications in carrying out a scheme to defraud. 15 Case 4:24-cr-00287-O Document 222 Filed 06/20/25 Page16of21 PagelD 2523 For you to find the defendant guilty of this crime, you must be convinced that the government has proved each of the following beyond a reasonable doubt: First: That the defendant knowingly devised or intended to devise a scheme to defraud, that is, the defendant and any coconspirator sought to unlawfully enrich themselves by submitting and causing the submission of false and fraudulent applications for forgivable Paycheck Protection Program loans; Second: That the scheme to defraud employed false material representations; Third: That the defendant caused to be transmitted by way of wire communications, in interstate commerce, any writing, sign, or signal for the purpose of executing such scheme; and Fourth: That the defendant acted with a specific intent to defraud. A “scheme to defraud” means any plan, pattern, or course of action intended to deprive another of money or property or bring about some financial gain to the person engaged in the scheme. A “specific intent to defraud” means a conscious, knowing intent to deceive and cheat someone. A representation is “false” if it is known to be untrue or is made with reckless indifference as to its truth or falsity. A representation would also be “false” if it constitutes a half truth, or effectively omits or conceals a material fact, provided it is made with the intent to defraud. 16 Case 4:24-cr-00287-O Document 222 Filed 06/20/25 Page17of21 PagelD 2524 A representation is “material” if it has a natural tendency to influence, or is capable of influencing, the decision of the person or entity to which it is addressed. It is not necessary that the government prove all of the details alleged in the indictment concerning the precise nature and purpose of the scheme. What must be proved beyond a reasonable doubt is that the defendant knowingly devised or intended to devise a scheme to defraud by means of false or fraudulent pretenses, representations, or promises that was substantially the same as the one alleged in the indictment. It is also not necessary that the government prove that the material transmitted by wire communications was itself false or fraudulent, or that the use of the interstate wire communications facilities was intended as the specific or exclusive means of accomplishing the alleged fraud. What must be proved beyond a reasonable doubt is that the use of the interstate wire communications facilities was closely related to the scheme because the defendant either wired something or caused it to be wired in interstate commerce in an attempt to execute or carry out the scheme. The alleged scheme need not actually succeed in defrauding anyone. To “cause” interstate wire communications facilities to be used is to do an act with knowledge that the use of the wire communications facilities will follow in the ordinary course of business or where such use can reasonably be foreseen. Each separate use of the interstate wire communications facilities in furtherance of a scheme to defraud by means of false or fraudulent pretenses, representations, or promises constitutes a separate offense. 17 Case 4:24-cr-00287-O Document 222 Filed 06/20/25 Page18o0f21 PagelD 2525 As to counts two to five, you are instructed that the guilt of a defendant in a criminal case may be established without proof that the defendant personally did every act constituting the offense alleged. The law recognizes that, ordinarily, anything a person can do for himself or herself may also be accomplished by him or her through the direction of another person as his or her agent, or by acting in concert with, or under the direction of another person or persons in a joint effort or enterprise. If another person is acting under the direction of the defendant or if the defendant joins another person and performs acts with the intent to commit a crime, then the law holds the defendant responsible for the acts and conduct of such other persons just as though the defendant had committed the acts or engaged in such conduct. Before any defendant may be held criminally responsible for the acts of others, it is necessary that the accused deliberately associate herself in some way with the crime and participate in it with the intent to bring about the crime. Mere presence at the scene of a crime and knowledge that a crime is being committed are not sufficient to establish that a defendant either directed or aided and abetted the crime unless you find beyond a reasonable doubt that the defendant was a participant and not merely a knowing spectator. In other words, you may not find any defendant guilty unless you find beyond a reasonable doubt that every element of the offense as defined in these instructions was committed by some person or persons, and that the defendant voluntarily participated in its commission with the intent to violate the law. 18 Case 4:24-cr-00287-O Document 222 Filed 06/20/25 Page19o0f21 PagelD 2526 A conspirator is responsible for offenses committed by another conspirator if the conspirator was a member of the conspiracy when the offense was committed and if the offense was committed in furtherance of, and as a foreseeable consequence of, the conspiracy. Therefore, if you have first found the defendant guilty of the conspiracy charged in Count One and if you find beyond a reasonable doubt that during the time the defendant was a member of that conspiracy, another conspirator committed the offenses in Counts Two, Three, Four, or Five, both in furtherance of and as a foreseeable consequence of that conspiracy, then you may find the defendant guilty of Counts Two, Three, Four, or Five, even though the defendant may not have participated in any of the acts which constitute the offense described in Count Two, Three, Four, or Five. In order for you to return a guilty verdict as to Counts Two, Three, Four, or Five, the government must prove by a preponderance of the evidence that a wire transmission in furtherance of the scheme was begun, continued, completed, or was committed in the Northern District of Texas. Unlike the other elements of the offense, this is a fact that the government must prove only by a preponderance of the evidence. This means the government must convince you only that it is more likely than not that the offense charged was begun, continued, completed, or was committed in the Northern District of Texas. All other elements of the offense must be proved beyond a reasonable doubt. You are instructed that Amarillo, Bedford, Dallas, and Tarrant County, Texas are located in the Northern District of Texas. 19 Case 4:24-cr-00287-O Document 222 Filed 06/20/25 Page 20o0f21 PagelD 2527 To reach a verdict, whether it is guilty or not guilty, all of you must agree. Your verdict must be unanimous on each count of the indictment. It is your duty to consult with one another and to deliberate in an effort to reach agreement if you can do so. Each of you must decide the case for yourself, but only after an impartial consideration of the evidence with your fellow jurors. Do not let any bias, sympathy, or prejudice that you may feel toward one side or the other influence your decision in any way. In particular, do not let racial, ethnic, national origin, or other bias influence your decision in any way. During your deliberations, do not hesitate to reexamine your own opinions and change your mind if convinced that you were wrong. But do not give up your honest beliefs as to the weight or effect of the evidence solely because the opinion of your fellow jurors, or for the mere purpose of returning a verdict. Remember at all times, you are judges—judges of the facts. Your duty is to decide whether the government has proved the defendant guilty beyond a reasonable doubt. When you go to the jury room, the first thing that you should do is select one of your number as your foreperson, who will help to guide your deliberations and will speak for you here in the courtroom. A verdict form has been prepared for your convenience. The foreperson will write the unanimous answer of the jury in the space provided for each count of the indictment, either guilty or not guilty. At the conclusion of your deliberations, the foreperson should date and sign the verdict. If you need to communicate with me during your deliberations, the foreperson 20 Case 4:24-cr-00287-O Document 222 Filed 06/20/25 Page21of21 PagelD 2528 should write the message and give it to the court security office. I will either reply in writing or bring you back into the court to answer your message. Bear in mind that you are never to reveal to any person, not even to the court, how the jury stands, numerically or otherwise, on any count of the indictment, until after you have reached a unanimous verdict. Signed this 20th day of June, 2025. Reed O’ Connor é UNITED STATED DISTRICT JUDGE 21
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