{
  "document_metadata": {
    "page_number": "35",
    "document_number": "453",
    "date": "11/12/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 453 Filed 11/12/21 Page 35 of 52\nvictim's age, you must find that the defendant knew that the victim was less than seventeen years old.\") (emphasis added).\nIt is unclear whether the government is now claiming that to admit evidence as proof of the Mann Act conspiracies, it only needs to prove that was under the age of 18 at the time of the alleged abuse and that Ms. Maxwell did not need to know anything about age, or that Ms. Maxwell only needed to know that was under the age of 18. Either one is a misstatement of the law. For \"sexual activity\" to be \"criminal,\" it must be illegal under the laws of the jurisdiction where the sex acts allegedly took place. If those crimes are based on lack of consent due to age, it is only illegal if the alleged victim is under the age of consent in that jurisdiction. And according to the government's own proposed jury instructions, Ms. Maxwell can only be found guilty of the Mann Act conspiracies if she knew (and the other alleged victims) were under the age of consent in the particular jurisdictions where the sex acts allegedly took place. Because was, at all times, over the age of consent in the relevant jurisdictions, her evidence is not within the scope of the charged conspiracies and is therefore not admissible as direct evidence. At the very least, because it is not \"manifestly clear\" that evidence is proof of the charged conspiracies, \"the proper course is to proceed under Rule 404(b).\" United States v. Townsend, No. S1 06 CR. 34 (JFK), 2007 WL 1288597, at *1 (S.D.N.Y. May 1, 2007) (citing United States v. Nektalov, 325 F. Supp. 2d 367, 372 (S.D.N.Y. 2004)).\nevidence should also be excluded under Rule 404(b) and Rule 403.\nAs argued in our initial Motion, evidence that Ms. Maxwell allegedly encouraged an adult to engage in legal sexual activity is not, in any way, evidence of her intent to facilitate Epstein's\n29\nDOJ-OGR-00006915",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 453 Filed 11/12/21 Page 35 of 52",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "victim's age, you must find that the defendant knew that the victim was less than seventeen years old.\") (emphasis added).\nIt is unclear whether the government is now claiming that to admit evidence as proof of the Mann Act conspiracies, it only needs to prove that was under the age of 18 at the time of the alleged abuse and that Ms. Maxwell did not need to know anything about age, or that Ms. Maxwell only needed to know that was under the age of 18. Either one is a misstatement of the law. For \"sexual activity\" to be \"criminal,\" it must be illegal under the laws of the jurisdiction where the sex acts allegedly took place. If those crimes are based on lack of consent due to age, it is only illegal if the alleged victim is under the age of consent in that jurisdiction. And according to the government's own proposed jury instructions, Ms. Maxwell can only be found guilty of the Mann Act conspiracies if she knew (and the other alleged victims) were under the age of consent in the particular jurisdictions where the sex acts allegedly took place. Because was, at all times, over the age of consent in the relevant jurisdictions, her evidence is not within the scope of the charged conspiracies and is therefore not admissible as direct evidence. At the very least, because it is not \"manifestly clear\" that evidence is proof of the charged conspiracies, \"the proper course is to proceed under Rule 404(b).\" United States v. Townsend, No. S1 06 CR. 34 (JFK), 2007 WL 1288597, at *1 (S.D.N.Y. May 1, 2007) (citing United States v. Nektalov, 325 F. Supp. 2d 367, 372 (S.D.N.Y. 2004)).\nevidence should also be excluded under Rule 404(b) and Rule 403.\nAs argued in our initial Motion, evidence that Ms. Maxwell allegedly encouraged an adult to engage in legal sexual activity is not, in any way, evidence of her intent to facilitate Epstein's",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "29",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006915",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell",
      "Epstein"
    ],
    "organizations": [
      "DOJ"
    ],
    "locations": [
      "S.D.N.Y."
    ],
    "dates": [
      "11/12/21",
      "May 1, 2007",
      "2004"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 453",
      "S1 06 CR. 34 (JFK)",
      "DOJ-OGR-00006915"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case against Ms. Maxwell. The text is mostly printed, with some redacted sections. The document includes references to specific court rules and case law."
}