Whether repeatedly arguing in closing that the defendant 'needed the jury to believe' certain things impermissibly shifted the burden of proof and eviscerated the presumption of innocence

QUESTIONS PRESENTED Whether repeatedly arguing in closing that the defendant ‘needed the jury to believe’ certain things impermissibly shifted the burden of proof and eviscerated the presumption of innocence. Whether answering “Yes” to the jury question “If we believe she aided and abetted in the kidnapping, does that automatically make her guilty of Count Two (kidnapping)?” undercut the reasonable doubt standard and the government’s burden of proof. -2 List of All Proceedings 1. United States District Court, 8.D.N.Y., Docket No. 20-cr-388-4; judgment entered 5/3/2022. 2. United States Court of Appeals for the Second Circuit, Docket No. 221044-cr; judgment entered 2/7/2024. -3