

In this filing, the government submits its proposed jury instructions, also known as “requests to charge,” ahead of Sean Combs’ upcoming trial. These instructions lay out how the jury should interpret the law as it applies to the charges in the Third Superseding Indictment, including conspiracy, racketeering (RICO), drug trafficking, sex trafficking, and related offenses. The government requests standard instructions on presumption of innocence, burden of proof, credibility of witnesses (includi
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