Post-Summation Instructions

Introduction

Members of the jury, I will now instruct you on the law. I will
first review the general principles of law that apply to this caseand all criminal cases.
You have heard me explain some of those principles at the
beginning of the trial. I am sure you can appreciate the benefitsof repeating those instructions at this stage of the proceedings.
Next, I will define the crimes charged in this case, explain

the law that applies to those definitions, and spell out theelements of each charged crime.
Finally, I will outline the process ofjury deliberations.

These instructions will take at least an hour, and you will
not receive copies of them. You may however, request that I
read them back to you in whole or in part as many times as you
wish, and I will be happy to do so.

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Role of Court and Jury
During these instructions, I will not summarize theevidence. If necessary, I may refer to portions of the evidence
to explain the law that relates to it. My reference to evidence,or my decision not to refer to evidence, expresses no opinion

about the truthfulness, accuracy, or importance of any particularevidence.

In fact, nothing I have said in the course of this trial

was meant to suggest that I have an opinion about this case. If
you have formed an impression that I do have an opinion, youmust put it out of your mind and disregard it.
The level of my voice or intonation may vary during these

instructions. If I do that, it is done to help you understand.

It is

not done to communicate any opinion about the law or the factsof the case or of whether the defendant is guilty or not guilty.

It is not my responsibility to judge the evidence here. It isyours. You are the judges ofthe facts, and you are responsiblefor deciding whether the defendant is guilty or not guilty.

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Reminder: Fairness

Remember, you have promised to be a fairjuror. Afairjuror
is a person who will keep their promise to be fair and impartial
and who will not permit the verdict to be influenced by a bias or
prejudice in favor of or against a person who appeared in thistrial on account of that person's race, color, national origin,ancestry, gender, gender identity or expression , religion,
religious practice , age, disability or sexual orientation, andfurther, a fair juror must be mindful of any stereotypes orattitudes about people or about groups of people that the juror
may have, and must not allow those stereotypes or attitudes toaffect their verdict.

As I have explained , we all develop and hold unconscious

views on many subjects. Some of those unconscious views may
come from stereotypes and attitudes about people or groups ofpeople that may impact on a person's thinking and decisionmaking without that person even knowing it. As a juror, you are
asked to make a very important decision about another memberof the community. I know you would not want to make thatdecision based on such stereotypes or attitudes, that is, on what
we call implicit biases, and it would be wrong for you to do so. A
fair juror must guard against the impact of such stereotypes orattitudes . You can do this by asking yourself during yourdeliberations whether your views and conclusions would be
different if the defendant, witnesses or others that you haveheard about or seen in court were of a different race, color,

national origin , ancestry, gender, gender identity or expression,
religious practice, age or sexual orientation, or if they did nothave a disability. If the answer is yes, then , in keeping with yourpromise to be fair, reconsider your views and conclusions alongwith the other jurors, and make sure your verdict is based on theevidence and not on stereotypes or attitudes. Justice requires no
less.

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Limiting Instruction Regarding the Defendant
Jurors, you will recall that during jury selection you agreed
that you would set aside any personal opinions or bias you might
have in favor of or against the Defendant, and that you would
decide this case fairly on the evidence and the law. Again, I
direct you to decide this case on the evidence and the law as it
relates to the Defendant here on trial. You must set aside any
personal opinions or bias you might have in favor of or against

the Defendant, and you must not allow any such opinions to
influence your verdict.

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Sentence: Not Consider

Remember also, in your deliberations, you may notconsider or speculate about matters relating to sentence or
If there is a verdict of guilty, it will be mypunishment.

responsibility to impose an appropriate sentence.

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Evidence

When you judge the facts, you are to consider only theevidence .
The evidence in the case includes:

the testimony ofthe witnesses,

the exhibits that were received in evidence, and thestipulations agreed to by the parties. Remember, a stipulation

is information the parties have agreed to present to the jury as
evidence, without calling a witness to testify.
Testimony which was stricken from the record or to which
an objection was sustained must be disregarded by you.
Exhibits that were received in evidence are available, upon
your request, for your inspection and consideration .
Exhibits that were just seen during the trial, or marked for
identification but not received in evidence, are not evidence, andare thus not available for your inspection and consideration.

But testimony based on those exhibits that were notreceived in evidence may be considered by you. It is just thatthe exhibit itself is not available for your inspection andconsideration.

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Evidentiary Inferences
In evaluating the evidence, you may consider any fact thatis proven and any inference which may be drawn from such fact.
To draw an inference means to infer, find, conclude that afact exists or does not exist based upon proof of some other fact
or facts.

For example, suppose you go to bed one night when it is
not raining and when you wake up in the morning, you look out
your window; you do not see rain , but you see that the street andsidewalk are wet, and that people are wearing raincoats andcarrying umbrellas. Under those circumstances , it may bereasonable to infer, that is conclude, that it rained during thenight.

In other words, the fact of it having rained while you wereasleep is an inference that might be drawn from the proven factsof the presence of the water on the street and sidewalk, andpeople in raincoats and carrying umbrellas.
An inference must only be drawn from a proven fact orfacts

and then only if the inference flows naturally, reasonably, andlogically from the proven fact or facts, not if it is speculative.
Therefore, in deciding whether to draw an inference, you must
look at and consider all the facts in the light of reason , common
sense, and experience.

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REDACTIONS

As you know, certain exhibits were admitted into evidencewith some portions blacked out or redacted. Those redactions

were made to remove personal identifying information and toensure that only relevant admissible evidence was put beforeyou. You may not speculate as to what material was redacted
or why, and you may not draw any inference , favorable orunfavorable against either party, from the fact that certain
material has been redacted.

Page 8Limiting Instructions
You may recall that I instructed you several times during the trialthat certain exhibits were being accepted into evidence for alimited purpose only and that you were not to consider that
evidence for any other purpose. Under the law we refer to thatas a limiting instruction . I will now remind you of some of thelimiting instructions you were given during the trial.
AMI - You will recall that you heard testimony that while David
Pecker was an executive at AMI, AMI entered into a non-prosecution agreement with federal prosecutors, as well as aconciliation agreement with the Federal Election Commission(FEC). I remind you that evidence was permitted to assist you ,the jury, in assessing David Pecker's credibility and to help
provide context for some of the surrounding events. You may
consider that testimony for those purposes only.

Neither the

non-prosecution agreement, nor the conciliation agreement isevidence of the Defendant's guilt, and you may not consider

them in determining whether the Defendant is guilty or not guilty
ofthe charged crimes.
Michael Cohen - You also heard testimony that the Federal

Election Commission ("FEC") conducted an investigation intothe
payment to Stormy Daniels and of responses submitted byMichael Cohen and his attorney to the investigation. That
evidence was permitted to assist you, the jury, in assessing
Michael Cohen's credibility and to help provide context for someof the surrounding events. You may consider that evidence forthose purposes only. Likewise, you will recall that you heard
testimony that Michael Cohen pleaded guilty to violating theFederal Election Campaign Act, otherwise known as FECA. I
remind you that evidence was permitted to assist you, the jury,
in assessing Mr. Cohen's credibility as a witness and to help
provide context for some of the events that followed . You may
Page 9consider that testimony for those purposes only. Neither the factof the FEC investigation, Mr. Cohen and his attorney's responses
or the fact that Mr. Cohen pleaded guilty, constitutes evidence of
the Defendant's guilt and you may not consider them indetermining whether the Defendant is guilty or not guilty of thecharged crimes .
Wall Street Journal News articles-

You will recall that certain

Wall Street Journal news articles were accepted into evidence

during the trial.

I remind you now that the articles were

accepted and may be considered by you for the limited purposeof demonstrating that the articles were published on or about acertain date and to provide context for the other evidence.

The

exhibits may not be considered by you as evidence that any of
the assertions in the articles is true.

Other hearsay evidence not accepted for its truth – There wereother exhibits which contained hearsay and were not accepted
for the truth of the matter asserted but for another purpose. For
example, there were several National Enquirer headlines and an-

invoice from InvestorAdvisory Services (People's 161 ). Those
were accepted for the limited purpose of demonstrating that thearticles were published and the document created.
There were also some text messages that were accepted with asimilar limitation. For example, People's Exhibit 171.A withrespect to Gina Rodriguez's texts only and 257 with respect toChris Cuomo's texts only. Those text messages were accepted
for the limited purpose of providing context for the responses by
Dylan Howard and Michael Cohen.
The exhibits which were accepted into evidence with a limiting
instruction are 152, 153.A, 153.B, 153.C, 161 , 171.A, 180, 181
and 257.

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If you have any additional questions or need clarification as towhich exhibits were accepted into evidence with limitations, justsend me a note with your question and I will be happy to clarify.

Presumption of Innocence
We now turn to the fundamental principles of our law that
apply in all criminal trials-the presumption of innocence, theburden of proof, and the requirement of proof beyond areasonable doubt.

Throughout these proceedings, the defendant is presumed

to be innocent. As a result, you must find the defendant not
guilty, unless, on the evidence presented at this trial, you
conclude that the People have proven the defendant guilty
beyond a reasonable doubt.

In determining whether the People have satisfied theirburden of proving the defendant's guilt beyond a reasonable
doubt, you may consider all the evidence presented , whether by

the People or by the defendant. In doing so, however, remember
that, even though the defendant introduced evidence, the burdenof proof remains on the People.

Defendant Did Not Testify
The fact that the defendant did not testify is not a factor
from which any inference unfavorable to the defendant may be
drawn.

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Burden of Proof

The defendant is not required to prove that he is not guilty.
In fact, the defendant is not required to prove or disproveanything . To the contrary, the People have the burden ofproving the defendant guilty beyond a reasonable doubt. Thatmeans, before you can find the defendant guilty of a crime, thePeople must prove beyond a reasonable doubt every element of
the crime including that the defendant is the person who
committed that crime. The burden of proof never shifts from thePeople to the defendant. If the People fail to satisfy their burdenof proof, you must find the defendant not guilty and if the People
satisfy their burden of proof, you must find the defendant guilty.

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Reasonable Doubt

What does our law mean when it requires proof of guilt"beyond a reasonable doubt"?
The law uses the term , "proof beyond a reasonable doubt,"
to tell you how convincing the evidence of guilt must be to permit

a verdict of guilty. The law recognizes that, in dealing with humanaffairs, there are very few things in this world that we know withabsolute certainty.

Therefore, the law does not require thePeople to prove a defendant guilty beyond all possible doubt. On
the other hand, it is not sufficient to prove that the defendant isprobably guilty. In a criminal case, the proof of guilt must be
stronger than that. It must be beyond a reasonable doubt.
A reasonable doubt is an honest doubt of the defendant's

guilt for which a reason exists based upon the nature and qualityof the evidence. It is an actual doubt, not an imaginary doubt. It

is a doubt that a reasonable person , acting in a matter of thisimportance, would be likely to entertain because of the evidence
that was presented or because of the lack of convincing
evidence .

Proof of guilt beyond a reasonable doubt is proof thatleaves you so firmly convincedof the defendant's guilt that you

have no reasonable doubt of the existence of any element ofthe

crime or of the defendant's identity as the person who committed
the crime .

In determining whether the People have proven the
defendant's guilt beyond a reasonable doubt, you should be
guided solely by a full and fair evaluation of the evidence . After
carefully evaluating the evidence, each of you must decide
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whether that evidence convinces you beyond a reasonable doubtof the defendant's guilt.
Whatever your verdict may be , it must not rest uponbaseless speculation . Nor may it be influenced in any way bybias , prejudice , sympathy, or by a desire to bring an end to yourdeliberations or to avoid an unpleasant duty.
If you are not convinced beyond a reasonable doubt thatthe defendant is guilty of a charged crime, you must find thedefendant not guilty of that crime and if you are convinced
beyond a reasonable doubt that the defendant is guilty of acharged crime, you must find the defendant guilty of that crime.

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Credibility of Witnesses
Introduction

As judges ofthe facts, you alone determine the truthfulness
and accuracy of the testimony of each witness .
You must decide whether a witness told the truth and was

accurate, or instead, testified falsely or was mistaken. You
must also decide what importance to give to the testimony you
accept as truthful and accurate. It is the quality of the testimonythat is controlling, not the number of witnesses who testify.

Accept in Whole or in Part (Falsus in Uno)
If you find that any witness has intentionally testified falsely
as to any material fact, you may disregard that witness's entire
testimony. Or, you may disregard so much of it as you find was
untruthful, and accept so much of it as you find to have beentruthful and accurate.

Credibility factors

There is no particular formula for evaluating thetruthfulness and accuracy of another person's statements or

testimony. You bring to this process all of your varied
experiences . In life, you frequently decide the truthfulness andaccuracy of statements made to you by other people. The same
factors used to make those decisions , should be used in thiscase when evaluating the testimony.

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In General

Some of the factors that you may wish to consider in

evaluating the testimony of a witness are as follows :Did the witness have an opportunity to see or hear the
events about which he or she testified?

Did the witness have the ability to recall those eventsaccurately?

Was the testimony of the witness plausible and likely to betrue, or was it implausible and not likely to be true?
Was the testimony of the witness consistent or inconsistent
with other testimony or evidence in the case?

Did the manner in which the witness testified reflect upon
the truthfulness of that witness's testimony?

To what extent, if any, did the witness's background,training, education, or experience affect the believability of thatwitness's testimony?
Did the witness have a conscious bias, hostility or someother attitude that affected the truthfulness of the witness's

testimony?
Did the witness show an "unconscious bias," that is, a biasthat the witness may have even unknowingly acquired fromstereotypes and attitudes about people or groups of people, andif so, did that unconscious bias impact that witness's ability to betruthful and accurate .

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Motive

You may consider whether a witness had, or did not have,a motive to lie.

If a witness had a motive to lie, you may consider whether
and to what extent, if any, that motive affected the truthfulness ofthat witness's testimony.
If a witness did not have a motive to lie, you may consider
that as well in evaluating the witness's truthfulness.

Benefit

You may consider whether a witness hopes for or expects

to receive a benefit for testifying.

If so, you may consider

whether and to what extent it affected the truthfulness of thewitness's testimony.
Interest/Lack of Interest

You may consider whether a witness has any interest in
the outcome of the case, or instead, whether the witness has nosuch interest.

You are not required to reject the testimony of an interested
witness, or to accept the testimony of a witness who has nointerest in the outcome of the case .
You may, however, consider whether an interest in theoutcome, or the lack of such interest, affected the truthfulness of
the witness's testimony.
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Previous Criminal Conduct

You may consider whether a witness has been convictedof a crime or has engaged in criminal conduct, and if so, whether
and to what extent it affects your evaluation of the truthfulness ofthat witness's testimony.

You are not required to reject the testimony of a witness.
who has been convicted of a crime or has engaged in criminal
conduct, or to accept the testimony of a witness who has not.
You may, however, consider whether a witness's criminal
conviction or conduct has affected the truthfulness of thewitness's testimony.

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Inconsistent Statements

You may consider whether a witness made statements at
this trial that are inconsistent with each other.

You may also consider whether a witness made previous
statements that are inconsistent with his or her testimony at trial .
You may consider whether a witness testified to a fact here

at trial that the witness omitted to state, at a prior time, when it

would have been reasonable and logical for the witness to havestated the fact. In determining whether it would have beenreasonable and logical for the witness to have stated the omitted

fact, you may consider whether the witness' attention was called
to the matter and whether the witness was specifically asked
about it.

If a witness has made such inconsistent statements oromissions, you may consider whether and to what extent theyaffect the truthfulness or accuracy of that witness's testimony
here at this trial.

The contents of a prior inconsistent statement are not proofof what happened .
You may use evidence of a priorinconsistent statement only to evaluate the truthfulness or
accuracy ofthe witness's testimony here at trial.

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Consistency

You may consider whether a witness's testimony isconsistent with the testimony of other witnesses or with otherevidence in the case .

If there were inconsistencies by or among witnesses, you
may consider whether they were significant inconsistencies
related to important facts, or instead were the kind of minor

inconsistencies that one might expect from multiple witnesses tothe same event.

Witness Pre-trial Preparation
You have heard testimony about the prosecution anddefense counsel_speaking to a witness about the case before thewitness testified at this trial. The law permits the prosecution
and defense counsel to speak to a witness about the case before

the witness testifies, and permits a prosecutor and defense
counsel to review with the witness the questions that will or may
be asked at trial, including the questions that may be asked oncross-examination.

You have also heard testimony that a witness read orreviewed certain materials pertaining to this case before thewitness testified at trial. The law permits a witness to do so.
Speaking to a witness about his or her testimony andpermitting the witness to review materials pertaining to the casebefore the witness testifies is a normal part of preparing for trial.

It is not improper as long as it is not suggested that the witness
depart from the truth .

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Identification

The People have the burden of proving beyond areasonable doubt, not only that a charged crime was committed,

but that the defendant is the person who committed that crime.

Thus, even if you are convinced beyond a reasonable
doubt that a charged crime was committed by someone , you
cannot convict the defendant of that crime unless you are also
convinced beyond a reasonable doubt that he is the person who
committed that crime.

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Accomplice as a Matter of Law
Under our law, Michael Cohen is an accomplice because
there is evidence that he participated in a crime based upon

conduct involved in the allegations here against the defendant.
Our law is especially concerned about the testimony of an
accomplice who implicates another in the commission ofa crime,
particularly when the accomplice has received , expects or hopes
for a benefit in return for his testimony .

Therefore, our law provides that a defendant may not be
convicted of any crime upon the testimony of an accompliceunless it is supported by corroborative evidence tending toconnect the defendant with the commission of that crime .

In other words, even if you find the testimony of Michael
Cohen to be believable, you may not convictthe defendant solely
upon that testimony unless you also find that it was corroborated
by other evidence tending to connect the defendant with thecommission of the crime .

The corroborative evidence need not, by itself, prove thata crime was committed or that the defendant is guilty.

What thelaw requires is that there be evidence that tends to connect thedefendant with the commission of the crime charged in such a
way as may reasonably satisfy you that the accomplice is telling
the truth about the defendant's participation in that crime.
In

determining whether there

is

the

necessarycorroboration, you may consider whether there is material,
believable evidence, apart from the testimony of Michael Cohen,
which itself tends to connect the defendant with the commission
ofthe crime.
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You may also consider whether there is material,

believable evidence, apart from the testimony of Michael Cohen,
which, while it does not itself tend to connect the defendant withthe commission of the crime charged , it nonetheless so
harmonizes with the narrative of the accomplice as to satisfy youthat the accomplice is telling the truth about the defendant's
participation in the crime and thereby tends to connect thedefendant to the commission of the crime.

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The Charged Crimes
I will now instruct you on the law applicable to the charged
offenses.

That offense is Falsifying Business Records in the First
DegreePage 24-

34 Counts.

Accessorial Liability

Our law recognizes that two or more individuals can act
jointly to commit a crime, and that in certain circumstances, eachcan be held criminally liable for the acts of the others. In thatsituation, those persons can be said to be "acting in concert" witheach other.

Our law defines the circumstances under which one person
may be criminally liable for the conduct of another. That definitionis as follows :When one person engages in conduct whichconstitutes an offense, another is criminally liable for suchconduct when, acting with the state of mind required forthe
commission of that offense, he or she solicits, requests,commands, importunes , or intentionally aids such person
to engage in such conduct.

Under that definition , mere presence at the scene of acrime, even with knowledge that the crime is taking place, ormere association with a perpetrator of a crime, does not by itself
make a defendant criminally liable for that crime.

In order for the defendant to be held criminally liable for the
conduct of another which constitutes an offense, you must findbeyond a reasonable doubt:(1) That he solicited, requested, commanded, importuned,

or intentionally aided that person to engage in that conduct, and(2) That he did so with the state of mind required for thecommission of the offense.
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If it is proven beyond a reasonable doubt that the defendantis criminally liable for the conduct of another, the extent or degreeof the defendant's participation in the crime does not matter. A

defendant proven beyond a reasonable doubt to be criminallyliable for the conduct of another in the commission of a crime is

as guilty of the crime as if the defendant, personally, hadcommitted every act constituting the crime.
The People have the burden of proving beyond areasonable doubt that the defendant acted with the state of mind

required for the commission of the crime, and either personally,
or by acting in concert with another person , committed each of
the remaining elements of the crime.
Yourverdict, on each count you consider, whether guilty or
not guilty, must be unanimous. In order to find the defendant
guilty, however, you need not be unanimous on whether the
defendant committed the crime personally, or by acting in concert
with another, or both.

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The Charged Crimes

I will now instruct you on the law applicable to the charged
offense.

That offense is FALSIFYING BUSINESS RECORDS

IN THE FIRST DEGREE – 34 COUNTS.
-

FALSIFYING BUSINESS RECORDS
IN THE FIRST DEGREE

Penal Law § 175.10

Under our law, a person is guilty of falsifying business.
records in the first degree when , with intent to defraud that
includes an intent to commit another crime or to aid or conceal

the commission thereof, that person:
makes or causes a false entry in the business records ofan enterprise.
The following terms used in that definition have a special
meaning:

ENTERPRISE means any entity of one or more persons,corporate or otherwise, public or private, engaged in business,
commercial,professional,
governmental activity.

industrial,social,political

or

BUSINESS RECORD means any writing or article,
including computer data or a computer program , kept ormaintained by an enterprise for the purpose of evidencing or
reflecting its condition or activity.

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INTENT means conscious objective or purpose . Thus, aperson acts with intent to defraud when his or her conscious
objective or purpose is to do so. Intent does not requirepremeditation. In other words, intent does not require advanceplanning . Nor is it necessary that the intent be in a person's mind
for any particular period of time. The intent can be formed , andneed only exist, at the very moment the person engages inprohibited conduct or acts to cause the prohibited result, and not
at any earlier time.
The question naturally arises as to how to determine

whether a defendant had the intent required for the commissionof a crime.

To make that determination in this case, you must decide
if the required intent can be inferred beyond a reasonable doubt
from the proven facts.

In doing so, you may consider the person's conduct and allof the circumstances surrounding that conduct, including, but notlimited to, the following:
what, if anything , did the person do or say;what result, if any, followed the person's conduct; andwas that result the natural , necessary and probableconsequence of that conduct .
Therefore, in this case, from the facts you find to have been
proven, decide whether you can infer beyond a reasonable doubtthat the defendant had the intent required for the commission ofthis crime .

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INTENT TO DEFRAUDAs I previously explained, a person acts with intent to
defraud when his or her conscious objective or purpose is to do
SO .

In order to prove an intent to defraud, the People need notprove that the defendant acted with the intent to defraud any
particular person or entity. A general intent to defraud any personor entity suffices .
Intent to defraud is also not constricted to an intent todeprive another of property or money and can extend beyond
economic concerns .

INTENT TO COMMIT OR CONCEAL ANOTHER CRIME

For the crime of Falsifying Business Records in the First
Degree, the intent to defraud must include an intent to commit
another crime or to aid or conceal the commission thereof.

Under our law, although the People must prove an intent
to commit another crime or to aid or conceal the commission

thereof, they need not prove that the other crime was in factcommitted , aided, or concealed .

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NEW YORK ELECTION LAW § 17-152 PREDICATEThe People allege that the other crime the defendant
intended to commit, aid, or conceal is a violation of New YorkElection Law section 17-152.

Section 17-152 of the New York Election Law provides thatany two or more persons who conspire to promote or preventthe
election of any person to a public office by unlawful means andwhich conspiracy is acted upon by one or more of the parties
thereto, shall be guilty of conspiracy to promote or prevent anelection .

Under our law, a person is guilty of such a conspiracy
when, with intent that conduct be performed that would promoteor prevent the election of a person to public office by unlawfulmeans, he or she agrees with one or more persons to engage inor cause the performance of such conduct.

Knowledge of a conspiracy does not by itself make thedefendant a coconspirator. The defendant must intend that
conduct be performed that would promote or prevent the electionof a person to public office by unlawful means. Intent means

conscious objective or purpose. Thus, a person acts with theintent that conduct be performed that would promote or preventthe election of a person to public office by unlawful means when
his or her conscious objective or purpose is that such conduct be
performed.

Evidence that defendant was present when others agreed
to engage in the performance of a crime does not by itself showthat he personally agreed to engage in the conspiracy.

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"By Unlawful Means"

Although you must conclude unanimously that thedefendant conspired to promote or prevent the election of any
person to a public office by unlawful means, you need not be
unanimous as to what those unlawful means were.

In determining whether the defendant conspired topromote or prevent the election of any person to a public officeby unlawful means, you may consider the following: (1) violationsof the Federal Election Campaign Act otherwise known as FECA;(2) the falsification of other business records; or (3) violation of
tax laws.

THE FEDERAL ELECTION CAMPAIGN ACT

The first of the People's theories of “unlawful means" which

I will now define for you is the Federal Election Campaign Act.

Under the Federal Election Campaign Act, it is unlawful for
an individual to willfully make a contribution to any candidate withrespect to any election for federal office, including the office ofPresident of the United States , which exceeds a certain limit. In
2015 and 2016, that limit was $2,700. It is also unlawful under

the Federal Election Campaign Act for any corporation to willfully
make a contribution of any amount to a candidate or candidate's
campaign in connection with any federal election, or for any
person to cause such a corporate contribution. For purposes ofthese prohibitions, an expenditure made in cooperation,
consultation, or concert with , or at the request or suggestion of,a candidate or his agents shall be considered to be a contribution
to such candidate.

Page 31The terms CONTRIBUTION and EXPENDITURE include

anything of value, including any purchase, payment, loan, or
advance, made by any person for the purpose of influencing any
election for federal office .

Under federal law, a third party's payment of a candidate's
expenses is deemed to be a contribution to the candidate unlessthe payment would have been made irrespective of thecandidacy.

If the payment would have been made even in the absenceof the candidacy, the payment should not be treated as acontribution .

FECA's definitions of "contribution" and "expenditure" donot include any cost incurred in covering or carrying a news story,
commentary, or editorial by a magazine, periodical publication,or similar press entity, so long as such activity is a normal,

legitimate press function . This is called the press exemption.
For example, the term legitimate press function includes
solicitation letters seeking new subscribers to a publication.

FALSIFICATION OF OTHER BUSINESS RECORDS

The second of the People's theories of "unlawful means"
which I will define for you now is the falsification of other businessrecords.

Under New York law, a person is guilty of Falsifying.
Business Records in the Second Degree when with intent to
defraud, he or she makes or causes a false entry in the businessrecords of an enterprise.

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I previously defined for you the terms enterprise, businessrecords, and intent to defraud .

For purposes of determining whether Falsifying Business
Records in the Second Degree was an unlawful means used bya conspiracy to promote or prevent an election here, you may

consider: (i) the bank records associated with Michael Cohen's
account formation paperwork for Resolution Consultants LLC
and Essential Consultants LLC accounts; (ii) the bank records
associated with Michael Cohen's wire to Keith Davidson ; (iii ) the
invoice from Investor Advisory Services Inc. to Resolution

Consultants LLC; and (iv) the 1099-MISC forms that the Trump
Organization issued to Michael Cohen.

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VIOLATION OF TAX LAWS

The People's third theory of “ unlawful means" which I willdefine for you now is a Violation of Tax Laws.
Under New YorkState and New YorkCity law, it is unlawful
to knowingly supply or submit materially false or fraudulent
information in connection with any tax return.
Likewise, under federal law, it is unlawful for a person towillfully make any tax return , statement, or other document thatis fraudulent or false as to any material matter , or that the person
does not believe to be true and correct as to every material
matter.

Under these federal , state, and local laws, such conduct isunlawful even if it does not result in underpayment of taxes.

COUNT-SPECIFIC

In order for you to find the defendant guilty of the crime of
Falsifying Business Records in the First Degree under Count 1of the Indictment, the People are required to prove, from all of
the evidence in the case, beyond a reasonable doubt, each of
the following two elements:
1. That on or about February 14, 2017, in the county of
New Yorkand elsewhere , the defendant , personally, orby acting in concert with another person or persons,made or caused a false entry in the business records ofan enterprise, specifically, an invoice from Michael
Cohen dated February 14 , 2017, marked as a record of
the Donald J. Trump Revocable Trust, and kept ormaintained by the Trump Organization; andPage 34

2. That the defendant did so with intent to defraud that
included an intent to commit another crime or to aid orconceal the commission thereof.

If you find the People have proven beyond a reasonable
doubt each of those two elements, you must find the defendant
guilty of this crime.
If you find the People have not proven beyond areasonable doubt either one or both of those two elements, youmust find the defendants not guilty of this crime.
You have now heard me define the law for Count One.

There are thirty-three remaining counts in the indictment. Eachfor Falsifying Business Records in the First Degree and eachoccurring in New York County. The only difference is that eachcount pertains to a different business record and possibly a
different date. The underlying law applies in the same way toeach of the remaining counts so I will only repeat it in full one
more time before I read Count 34. Of course , you can ask me torepeat the law in its entirety as many times as you wish and I will
be happy to do so.

The second count pertains to an entry in the Detail General
Ledger for the Donald J. Trump Revocable Trust, dated
February 14, 2017, bearing voucher number 842457, andkept or maintained by the Trump Organization .
The third count pertains to an entry in the Detail General
Ledger for the Donald J. Trump Revocable Trust, dated

February 14 , 2017, bearing voucher number 842460, andkept or maintained by the Trump Organization .
The fourth count pertains to a Donald J. Trump Revocable
Trust Account check and check stub dated February 14,
2017, bearing check number 000138, and kept ormaintained by the Trump Organization.
Page | 35

The fifth count pertains to an invoice from Michael Cohen
dated March 16, 2017 , marked as a record of the Donald

J. Trump Revocable Trust, and kept or maintained by the
Trump Organization.
The sixth count pertains to an entry in the Detail General
Ledger for the Donald J. Trump Revocable Trust, dated

March 17, 2017 , bearing voucher number 846907, andkept or maintained by the Trump Organization.

The seventh count pertains to a Donald J. Trump
Revocable Trust Account check and check stub dated

March 17 , 2017, bearing check number 000147 , and kept

or maintained by the Trump Organization.

The eighth count pertains to an invoice from Michael
Cohen dated April 13 , 2017, marked as a record of Donald

J. Trump, and kept or maintained by the Trump.
Organization .

The ninth count pertains to an entry in the Detail General
Ledger for Donald J. Trump, dated June 19, 2017, bearing
voucher number 858770, and kept or maintained by the
Trump Organization .
The tenth count pertains to a Donald J. Trump accountcheck and check stub dated June 19, 2017, bearing checknumber 002740, and kept or maintained by the Trump.
Organization .
The eleventh count pertains to an invoice from Michael
Cohen dated May 22, 2017, marked as a record of Donald

J. Trump, and kept or maintained by the Trump
Organization .

Page 36

The twelfth count pertains to an entry in the Detail General

Ledger for Donald J. Trump , dated May 22, 2017, bearing
voucher number 855331 , and kept or maintained by the
Trump Organization .
The thirteenth count pertains to a Donald J. Trump accountcheck and check stub dated May 23, 2017, bearing checknumber 002700, and kept or maintained by the Trump
Organization.
The fourteenth count pertains to an invoice from Michael
Cohen dated June 16, 2017, marked as a record of Donald

J. Trump, and kept or maintained by the Trump
Organization.

The fifteenth count pertains to an entry in the Detail
General Ledger for Donald J. Trump, dated June 19, 2017,

bearing voucher number 858772, and kept or maintainedby the Trump Organization.
The sixteenth count pertains to a Donald J. Trump accountcheck and check stub dated June 19, 2017, bearing checknumber 002741 , and kept or maintained by the Trump.
Organization.
The seventeenth count pertains to an invoice from Michael

Cohen dated July 11 , 2017, marked as a record of Donald
J. Trump, and kept or maintained
Organization.

by the Trump.

The eighteenth count pertains to an entry in the Detail

General Ledger for Donald J. Trump, dated July 11 , 2017,
bearing voucher number 861096, and kept or maintainedby the Trump Organization .

Page 37

The nineteenth count pertains to a Donald J. Trumpaccount check and check stub dated July 11 , 2017, bearing
check number 002781 , and kept or maintained by the
Trump Organization.

The twentieth count pertains to an invoice from Michael
Cohen dated August 1 , 2017, marked as a record of
Donald J. Trump, and kept or maintained by the Trump
Organization.

The twenty-first count pertains to an entry in the Detail
General Ledger for Donald J. Trump, dated August 1,
2017, bearing voucher number 863641 , and kept ormaintained by the Trump Organization .

The twenty-second count pertains to a Donald J. Trumpaccount check and check stub dated August 1 , 2017,

bearing check number 002821 , and kept or maintained by
the Trump Organization .

The twenty-third count pertains to an invoice from Michael
Cohen dated September 11 , 2017, marked as a record of
Donald J. Trump, and kept or maintained by the Trump.
Organization.

The twenty-fourth count pertains to an entry in the Detail
General Ledger for Donald J. Trump, dated September 11 ,2017, bearing voucher number 868174, and kept ormaintained by the Trump Organization .
The twenty-fifth count pertains to a Donald J. Trump.
account check and check stub dated September 12, 2017,

bearing check number 002908, and kept or maintained by
the Trump Organization .

Page 38

The twenty- sixth count pertains to an invoice from Michael
Cohen dated October 18, 2017, marked as a record of

Donald J. Trump, and kept or maintained by the Trump.
Organization.

The twenty-seventh count pertains to an entry in the Detail

General Ledger for Donald J. Trump, dated October 18,
2017, bearing voucher number 872654 , and kept ormaintained by the Trump Organization .
The twenty-eighth count pertains to a Donald J. Trump.
account check and check stub dated October 18 , 2017,

bearing check number 002944, and kept or maintained by
the Trump Organization .

The twenty-ninth count pertains to an invoice from Michael
Cohen dated November 20, 2017, marked as a record of

Donald J. Trump, and kept or maintained by the Trump.
Organization .
The thirtieth count pertains to an entry in the Detail General
Ledger for Donald J. Trump, dated November 20, 2017,

bearing voucher number 876511 , and kept or maintainedby the Trump Organization.

The thirty-first count pertains to a Donald J. Trump accountcheck and check stub dated November 21 , 2017 , bearing
check number 002980, and kept or maintained by the
Trump Organization .
The thirty-second count pertains to an invoice from Michael
Cohen dated December 1 , 2017, marked as a record of

Donald J. Trump, and kept or maintained by the Trump
Organization .

Page 39

The thirty-third count pertains to an entry in the Detail

General Ledger for Donald J. Trump, dated December 1 ,2017, bearing voucher number 877785, and kept ormaintained by the Trump Organization .

The Thirty Fourth Count is also Falsifying Business
Records in the First Degree but as it pertains to a checkand check stub dated December 5, 2017. I will now

repeat for you the law pertaining to the crime of Falsifying
Business Records in the First Degree in its entirety.

FALSIFYING BUSINESS RECORDS
IN THE FIRST DEGREE

Penal Law § 175.10
Under our law , a person is guilty of Falsifying Business
Records in the First Degree when , with intent to defraud that
includes an intent to commit another crime or to aid or conceal
the commission thereof, that person:

makes or causes a false entry in the business records ofan enterprise.

The following terms used in that definition have a special
meaning :ENTERPRISE means any entity of one or more persons,corporate or otherwise, public or private, engaged in business,
commercial, professional, industrial, social, political or

governmental activity.

BUSINESS RECORD means any writing or article ,including computer data or a computer program , kept ormaintained by an enterprise for the purpose of evidencing or
reflecting its condition or activity.

Page 40

INTENT means conscious objective or purpose . Thus, aperson acts with intent to defraud when his or her conscious

objective or purpose is to do so.
Intent does not require premeditation . In other words, intent

does not require advance planning . Nor is it necessary that theintent be in a person's mind for any particular period of time. The
intent can be formed , and need only exist, at the very moment
the person engages in prohibited conduct or acts to cause theprohibited result, and not at any earlier time.

The question naturally arises as to how to determine
whether a defendant had the intent required for the commissionof a crime.

To make that determination in this case, you must decide
if the required intent can be inferred beyond a reasonable doubt
from the proven facts .

In doing so, you may consider the person's conduct and allof the circumstances surrounding that conduct, including, but notlimited to, the following :what, if anything , did the person do or say;what result, if any, followed the person's conduct; andwas that result the natural, necessary and probableconsequence of that conduct.

Therefore, in this case, from the facts you find to have been
proven, decide whether you can infer beyond a reasonable doubtthat the defendant had the intent required for the commission ofthis crime .

Page 41

INTENT TO DEFRAUDAs I previously explained, a person acts with intent to
defraud when his or her conscious objective or purpose is to do
SO .

In order to prove an intent to defraud, the People need notprove that the defendant acted with the intent to defraud any
particular person or entity. A general intent to defraud any personor entity suffices .
Intent to defraud is also not constricted to an intent todeprive another of property or money and can extend beyond
economic concerns .

INTENT TO COMMIT OR CONCEAL ANOTHER CRIME

For the count of Falsifying Business Records in the First
Degree, the intent to defraud must include an intent to commit
another crime or to aid or conceal the commission thereof.

Under our law, although the People must prove an intent
to commit another crime or to aid or conceal the commission

thereof, they need not prove that the other crime was in factcommitted , aided, or concealed .

Page 42NEW YORK ELECTION LAW § 17-152 PREDICATEThe People allege that the other crime the defendant
intended to commit, aid, or conceal is a violation of New YorkElection Law section 17-152.

Section 17-152 of the New York Election Law provides thatany two or more persons who conspire to promote or prevent theelection of any person to a public office by unlawful means andwhich conspiracy is acted upon by one or more of the parties
thereto, shall be guilty of conspiracy to promote or prevent anelection .

Under our law, a person is guilty of such a conspiracy

when, with intent that conduct be performed that would promoteor prevent the election of a person to public office by unlawfulmeans, he or she agrees with one or more persons to engage inor cause the performance of such conduct.

Knowledge of a conspiracy does not by itself make thedefendant a coconspirator. The defendant must intend that
conduct be performed that would promote or prevent the electionof a person to public office by unlawful means. Intent means
conscious objective or purpose. Thus, a person acts with theintent that conduct be performed that would promote or preventthe election of a person to public office by unlawful means when

his or her conscious objective or purpose is that such conduct be
performed.

Evidence that defendant was present when others agreed
to engage in the performance of a crime does not by itself showthat he personally agreed to engage in the conspiracy.

Page 43

"By Unlawful Means"

Although you must conclude unanimously that thedefendant conspired to promote or prevent the election of any

person to a public office by unlawful means, you need not be
unanimous as to what those unlawful means were.

In determining whether the defendant conspired topromote or prevent the election of any person to a public officeby unlawful means, you may consider the following unlawfulmeans: (1) violations of the Federal Election Campaign Act
otherwise known as FECA; (2) the falsification of other businessrecords; or (3) violation of tax laws.

THE FEDERAL ELECTION CAMPAIGN ACT

The first ofthe People's theories of “unlawful means" which
I will now define for you is the Federal Election Campaign Act.
Under the Federal Election Campaign Act, it is unlawful for
an individual to willfully make a contribution to any candidate withrespect to any election for federal office, including the office ofPresident of the United States , which exceeds a certain limit. In
2015 and 2016, that limit was $2,700. It is also unlawful under

the Federal Election Campaign Act for any corporation to willfully
make a contribution of any amount to a candidate or candidate's
campaign in connection with any federal election, or for any

person to cause such a corporate contribution. For purposes ofthese prohibitions, an expenditure made incooperation,

consultation, or concert with , or at the request or suggestion of,a candidate or his agents shall be considered to be a contribution
to such candidate.

Page 44The terms CONTRIBUTION and EXPENDITURE include

anything of value, including any purchase, payment, loan, or
advance, made by any person for the purpose of influencing any
election for federal office .

Under federal law, a third party's payment of a candidate's
expenses is deemed to be a contribution to the candidate unlessthe payment would have been made irrespective of thecandidacy.

If the payment would have been made even in theabsence ofthe candidacy, the payment should not be treated asa contribution.

FECA's definitions of "contribution" and "expenditure" donot include any cost incurred in covering or carrying a news story,
commentary, or editorial by a magazine, periodical publication,or similar press entity, so long as such activity is a normal,
legitimate press function. This is called the press exemption.

For example, the term legitimate press function includes
solicitation letters seeking new subscribers to a publication.

FALSIFICATION OF OTHER BUSINESS RECORDS

The People's second theory of "unlawful means" which I
will define for you is the falsification of other business records.

Under New York law, a person is guilty of Falsifying.
Business Records in the Second Degree when with intent to

defraud , he or she makes or causes a false entry in the businessrecords of an enterprise.

I previously defined for you the terms enterprise, businessrecords, and intent to defraud.
Page 45

For purposes of determining whether Falsifying Business
Records in the Second Degree was an unlawful means used bya conspiracy to promote or prevent an election here, you may
consider: (i) the bank records associated with Michael Cohen's
account formation paperwork for the Resolution Consultants LLC

and Essential Consultants LLC accounts; (ii) the bank records
associated with Michael Cohen's wire to Keith Davidson ; (iii) the
invoice from Investor Advisory Services Inc. to Resolution

Consultants LLC; and (iv) the 1099-MISC forms that the Trump
Organization issued to Michael Cohen.

VIOLATION OF TAX LAWS

The People's third theory of " unlawful means" which I willdefine for you is a Violation of Tax Laws.
Under New YorkState and New YorkCity law, it is unlawful

to knowingly supply or submit materially false or fraudulent
information in connection with any tax return.

Likewise, under federal law, it is unlawful for a person towillfully make any tax return , statement, or other document thatis fraudulent or false as to any material matter, or that the person
does not believe to be true and correct as to every material
matter.

Under these federal, state, and local laws, such conduct isunlawful even if it does not result in underpayment of taxes.

Page 46

In order for you to find the defendant guilty of the crime of
Falsifying Business Records in the First Degree under Count 34,

the People are required to prove, from all of the evidence in thecase, beyond a reasonable doubt, each of the following twoelements :1. That on or about December 5 , 2017, in the county of
New York and elsewhere, the defendant , personally, orby acting in concert with another person or persons,made or caused a false entry in the business records ofan enterprise, specifically, a Donald J. Trump accountcheck and check stub dated December 5, 2017, bearing
check number 003006, and kept or maintained by the
Trump Organization; and2. That the defendant did so with intent to defraud that
included an intent to commit another crime or to aid orconceal the commission thereof.

If you find the People have proven beyond a reasonable

doubt both of those two elements, you must find the defendant
guilty of this crime .
If you find the People have not proven beyond areasonable doubt either one or both of those two elements, youmust find the defendants not guilty of this crime.

Page 47

Motive When Not Element of Crime

Let me now explain motive, and in particular, the difference
between motive and intent.

Intent means conscious objective or purpose. Thus, aperson commits a criminal act with intent when that person's
conscious objective or purpose is to engage in the act which thelaw forbids or to bring about an unlawful result.
Motive, on the other hand , is the reason why a personchooses to engage in criminal conduct.

If intent is an element of a charged crime, that element
must be proved by the People beyond a reasonable doubt.

this case, intent is , as I have explained, an element of the crimeof Falsifying Business Records in the First degree.
Motive, however, is not an element of the crimes charged.

Therefore, the People are not required to prove a motive for thecommission of the charged crimes .
Nevertheless, evidence of a motive, or evidence ofthe lackof a motive, may be considered by the jury.

For example , if you find from the evidence that thedefendant had a motive to commit the crime charged , that is acircumstance you may wish to consider as tending to support afinding of guilt.
On the other hand , if the proof establishes that thedefendant had no motive to commit the crime charged , that is acircumstance you may wish to consider as tending to establishthat the defendant is not guilty of the crime charged.

Page 48

Deliberations

Yourverdict, on each count you consider, whether guilty or

not guilty, must be unanimous; that is, each and everyjuror must
agree to it.

To reach a unanimous verdict you must deliberate with theother jurors. That means you should discuss the evidence andconsult with each other, listen to each other, give each other'sviews careful consideration, and reason together when
considering the evidence. And when you deliberate, you should

do so with a view towards reaching an agreement if that can bedone without surrendering individual judgment .
Each of you must decide the case for yourself, but only

after a fair and impartial consideration of the evidence with theother jurors. You should not surrender an honest view of theevidence simply because you want the trial to end , or because
you are outvoted . At the same time , you should not hesitate toreexamine your views and change your mind if you becomeconvinced that your position was not correct.

Page 49

Jury Note Taking
Some jurors took notes.

Any notes taken are only an aid to your memory and must
not take precedence over your independent recollection.

Those jurors who chose not to take notes must rely on theirown independent recollection and must not be influenced by any
notes that another juror may have taken.
Any notes you took are only for your own personal use inrefreshing your recollection .
A juror's notes are not a substitute for the recordedtranscript of the testimony or for any exhibit received in evidence.
If there is a discrepancy between a juror's recollection and his or
her notes regarding the evidence, you should ask to have therelevant testimony read back or the exhibit produced in the jury
room .

In addition , a juror's notes are not a substitute for thedetailed explanation I have given you of the principles of law thatgovern this case. If there is a discrepancy between a juror's
recollection and his or her notes regarding those principles , you
should ask me to explain those principles again, and I will behappy to do so.

Page 50

Exhibits, Readback & Law Questions

You may see any or all of the exhibits that were received
in evidence. Simply write me a note telling me which exhibit or
exhibits you want to see.
You may also have the testimony of any witness read backto you in whole or in part. Again, if you want a read back, write
me a note telling me what testimony you wish to hear.
If you are interested in hearing only a portion of a witness'testimony, please specify in your note which witness and, with asmuch detail as possible, which part of the testimony you want tohear.

Of course, when testimony is read back, questions to which
an objection was sustained and material otherwise struck fromthe record is not read back.

If you have a question on the law, write me a note
specifying what you want me to review with you.

Page 51

Foreperson's Role
Under our law, the first juror selected is known as theforeperson. During deliberations, the foreperson's opinion andvote are not entitled to any more importance than that of any
other juror.

What we ask the foreperson to do during deliberations is tosign any written note that the jury sends to the court. The
foreperson does not have to write the note or agree with its
contents. The foreperson's signature indicates only that thewriting comes from the jury.
The foreperson may also chair the jury's discussions during
deliberations.

When the jury has reached a verdict, guilty or not guilty, theentire jury will be asked to come into court . The foreperson will
be asked whether the jury has reached a verdict.

If theforeperson says yes, the foreperson will then be asked what theverdict is for each charged count.

After that, the entire jury will be asked whether that is theirverdict and will answer yes or no.

Finally, upon the request ofa party, each juror will be asked
individually whether the announced verdict is the verdict of thatjuror, and upon being asked, each juror will answer yes or no.

Page 52

VerdictSheet

I will give you a form known as a verdict sheet.

The

verdict sheet lists each count submitted for your considerationand the possible verdicts. Please use the form to record yourverdict with an X or a check mark in the appropriate place.

In addition to listing the counts, I have added some
additional language on the verdict sheet in order to distinguishthe counts:

You will notice that I have indicated whether a countpertains to an invoice, a voucher or a check.

For the invoices, I have added the date and for thevouchers and checks I have added the number.

The sole reason for doing this is to help you distinguishbetween the various counts.

It is not a substitute for my full

instructions on the meaning and elements of each charge, and it
should not discourage you from asking me to define a crime
again if a question about it arises .

Page 53

Jury Deliberation Rules

Finally, there are a few remaining rules which you must observe during yourdeliberations.

1. While you are here in the courthouse, deliberating on the case, you will be kept

together in the jury room . You may not leave the jury room during deliberations . Lunch
will of course be provided .
If you have a cell phone or other electronic device, please
give it to a court officer to hold for you while you are engaged in deliberations.
2. You must deliberate about the case only when you are all gathered together
in the jury room . You must not, for example, discuss the case as you go to and fromthe courtroom. It is important that each juror have the opportunity to hear whateveranother juror has to say about the case, and that by law must only be done when you
are all gathered together in the jury room . Thus, if for any reason , all twelve of you are
not gathered together in the jury room, please stop deliberating until you are all present.

3. During your deliberations, you must discuss the case only among yourselves;

you must not discuss the case with anyone else, including a court officer, or permit
anyone other than a fellow juror to discuss the case in your presence.
4.

If you have a question or request, you must communicate with me by writinga note, which you will give to a court officer to give to me. The law requires that you
communicate with me in writing in part to make sure there are no misunderstandings.
5.

We will work every day until about 4:30. However, we can work later if thejury wishes to do so and all the jurors are in agreement. Simply send me a note as earlyin the day as possible and let me know that you wish to stay beyond 4:30 and if so, whattime you would like to work until . Depending on the time you select, we may orderdinner for you .
I should explain that, under our law, I am not permitted to have a conversation
about the facts of the case, or a possible verdict, or the vote of the jury on any count withany one juror, or group of jurors , or even all the jurors. Thus, in any note that you sendme, do not tell me what the vote of the jury is on any count.

If a juror wants to speak to me during deliberations, a meeting here in the
courtroom with the parties will be arranged.

No juror, however, can tell me what

is being said about the facts of the case, or a possible verdict, or what the vote ofany juror or the jury is on any count. And, while I will of course listen to whatevera juror has to say that does not involve those subjects, I may not be able to respondto that juror if the response involves instructions on the law. I may be required toThecall into court the entire jury and respond by speaking to the entire jury.
reason for that is that our law wants to make sure that each and every juror hears,

at exactly the same time, whatever I have to say about the law, and our law wants
to make sure that the jury hears those instructions from me and not from anotherjuror.

That concludes my instructions on the law.