June 25 Continued

By T L. Reigns

The Scoop Digital Newspaper: July 2025

Continued

The current version of the conspiracy instruction was labeled “too short” by prosecutors, who cautioned that its brevity might confuse jurors.

“The current definition is only a few sentences long,” the government noted, “and may leave open too many unanswered questions… resulting in a number of jury notes seeking clarification.”

Because conspiracy law is not intuitive for most people, the prosecution proposed additional language explaining what constitutes an unlawful agreement.  

How knowledge or intent is established, and the difference between direct participation and indirect support in a conspiracy.

They also urged Judge Subramanian to clarify that criminal narcotics activity automatically satisfies the interstate commerce requirement under Second Circuit law. 

Since the racketeering statute (RICO) mandates a nexus to interstate commerce, the government argued that jurors might be uncertain unless explicitly told that drug trafficking qualifies.

Venue was another concern raised in the filing. Prosecutors asked the court to instruct that trafficking or other acts tied to the case that occurred within the district—such as planning meetings, communications, or transfers—can be sufficient to establish venue in the Southern District of New York.

The letter also took issue with proposed unanimity instructions. The government strongly objected to requiring jurors to unanimously agree on the precise means or methods by which a crime was committed—arguing this could introduce error or confusion.

Instead, the prosecution suggested a clearer format, which mirrors federal precedent, for charges under Counts 2 and 4 (sex trafficking of Cassie Ventura and Jane). 

They asked that jurors be instructed they must unanimously agree that at least one specific instance of sex trafficking occurred during the time period charged.

However, jurors need not agree on which exact method satisfied the legal elements of trafficking, so long as they all find the elements were proven beyond a reasonable doubt.

The same instruction was requested for Counts 3 and 5 (transportation to engage in prostitution). 

The government emphasized that jurors must agree that at least one qualifying instance occurred—but do not need to unanimously agree on each detail, such as date, location, or the exact travel method used.

This clarification, they said, would reflect existing case law and prevent a hung jury or appeals over instructional ambiguity.

In summation, prosecutors argued that while the court’s preference for simplified instructions was understood and respected, over-simplifying could compromise the integrity of the verdict. 

Given the sensitive nature of the charges, ranging from emotional coercion to economic entrapment, jurors must be equipped with a full understanding of legal standards and how to apply them to evidence.

Legal observers watching the trial closely have noted that the prosecution’s request reflects the broader difficulty of explaining sex trafficking and forced labor statutes to jurors who may have no experience with such cases.

“These cases turn on perception, power dynamics, and patterns,” said a former federal prosecutor.

“If jurors are told to look at everything through a single lens like ‘Was there violence?’ or ‘Was there payment?’—they can miss the bigger picture of coercion.”

Judge Subramanian has not yet issued a final ruling on the government’s full set of proposed additions. 

However, during earlier hearings, he acknowledged the prosecution’s concern about the legal complexity, and hinted that he may include some of the clarifying language where needed.

As the case enters its final phase, the stakes are high, not only for Sean Combs, but for how trafficking law is interpreted in one of the most high-profile federal trials of the year. 

Whether the jury receives a comprehensive legal roadmap or a shortened version could influence both the verdict and the scope of any appeals.

Closing arguments are expected to conclude later this week, with jury instructions and deliberations to follow shortly thereafter.

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The Scoop Digital Newspaper
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