In multi-complainant child sexual assault trials, a Markuleski direction must not preclude the jury from using doubts about one complainant's evidence when assessing counts that are supported by the evidence of both complainants. A direction that tells the jury a doubt about 'complainant A' cannot affect their assessment of counts involving 'complainant B' is erroneous where complainant A's evidence supports those counts. Trial judges and counsel must carefully consider the interaction between standard Markuleski directions and counts supported by cross-complainant evidence.
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