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The jury instructions here not only failed  to require that Brooks take deliberate steps to blind himself to the illegal purpose of his conduct, but additionally  instructed  the  jury  that   he   did   not need  to  “know”  or  even  suspect  that  his  conduct was unlawful. In combination, the jury instructions regarding “deliberate  ignorance”  and  “ignorance  of the law lowered the scienter which the  Government was required to prove to a mere reckless or negligent standard. This Court should grant  certiorari  to  en- sure uniformity of the law in allowing convictions on less than actual knowledge of the criminal nature of one’s conduct throughout the Circuit Courts of  Ap- peals in this  important  and  routinely  encountered area of escalating complex business prosecutions.15

15 See generally, Harvey A. Silverglate, Three Felonies a Day (2011); The Heritage Foundation and the National Association of Criminal Defense Lawyers, Without Intent: How Congress is Eroding the Criminal Intent Requirement in Federal Law (2010).

Respectfully submitted,



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