evidence: "Judge Merchan just told the jury that they do not need unanimity to convict," Roberts wrote. "4 could agree on one crime, 4 on a different one, and the other 4 on another. He said he would treat 4-4-4 as a unanimous verdict." In fact, all 12 jurors had to agree to find Trump guilty to convict him of the felonies with which he was charged: 34 counts of falsifying business records. The judge in the case, Juan M. Merchan, repeatedly made this clear, saying in his instructions to the jury: "Each count you consider, whether guilty or not guilty, must be unanimous." [...] Merchan then said that while the jury would have to "conclude unanimously" that Trump had violated Section 17-152 to find Trump guilty, they did not have to be unanimous about the "unlawful means" that were used.