{
  "document_metadata": {
    "page_number": "15",
    "document_number": "410-1",
    "date": "11/04/21",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 410-1 Filed 11/04/21 Page 15 of 93\n\nCHARGE\n\nSummary of Indictment\n\nThe Indictment contains six counts, or \"charges,\" against the defendant. Each count constitutes a separate offense or crime. You must consider each count of the Indictment separately, and you must return a separate verdict on each count. I am briefly going to summarize each count, and then will give you the law in greater detail.\n\nCount One of the Indictment charges Ghislaine Maxwell, the defendant, with conspiring—that is, agreeing—with others to entice an individual to travel in interstate and foreign commerce to engage in sexual activity for which a person can be charged with a criminal offense- Count One relates to multiple victims and the time period 1994 to 2004.\n\nCount Two of the Indictment charges the defendant Ms. Maxwell with enticing an individual Jane Doe-1 pseudonym to travel in interstate and foreign commerce to engage in sexual activity with Jeffrey Epstein for which a person can be charged with a criminal offense. Count Two relates to Jane Doe-1 pseudonym Minor Victim 1 and the time period 1994 to 1997.\n\nCount Three of the Indictment charges the defendant Ms. Maxwell with conspiring with others to transport a minor in interstate and foreign commerce, with intent that the minor engage in sexual activity for which a person can be charged with a criminal offense. Count Three relates to multiple minor victims and the time period 1994 to 2004.\n\nCount Four of the Indictment charges the defendant Ms. Maxwell with transporting a minor Jane Doe-1 pseudonym in interstate and foreign commerce, with the intent that the minor Jane Doe-1 pseudonym engage in sexual activity with Jeffrey Epstein for which a person can be charged with a criminal offense.\n\n1 The defense has informed the Government that they continue to object to the use of pseudonyms. The parties have agreed to use neutral identifiers here to avoid the need for redactions.\n\nCommented [CE12]: These references will need to be changed once we agree upon an appropriate pseudonym\n\nCommented [CE13]: For a discussion of the reasons for these changes, see proposed edits to Count Two - Elements",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 410-1 Filed 11/04/21 Page 15 of 93",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "CHARGE\n\nSummary of Indictment",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The Indictment contains six counts, or \"charges,\" against the defendant. Each count constitutes a separate offense or crime. You must consider each count of the Indictment separately, and you must return a separate verdict on each count. I am briefly going to summarize each count, and then will give you the law in greater detail.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Count One of the Indictment charges Ghislaine Maxwell, the defendant, with conspiring—that is, agreeing—with others to entice an individual to travel in interstate and foreign commerce to engage in sexual activity for which a person can be charged with a criminal offense- Count One relates to multiple victims and the time period 1994 to 2004.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Count Two of the Indictment charges the defendant Ms. Maxwell with enticing an individual Jane Doe-1 pseudonym to travel in interstate and foreign commerce to engage in sexual activity with Jeffrey Epstein for which a person can be charged with a criminal offense. Count Two relates to Jane Doe-1 pseudonym Minor Victim 1 and the time period 1994 to 1997.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Count Three of the Indictment charges the defendant Ms. Maxwell with conspiring with others to transport a minor in interstate and foreign commerce, with intent that the minor engage in sexual activity for which a person can be charged with a criminal offense. Count Three relates to multiple minor victims and the time period 1994 to 2004.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Count Four of the Indictment charges the defendant Ms. Maxwell with transporting a minor Jane Doe-1 pseudonym in interstate and foreign commerce, with the intent that the minor Jane Doe-1 pseudonym engage in sexual activity with Jeffrey Epstein for which a person can be charged with a criminal offense.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1 The defense has informed the Government that they continue to object to the use of pseudonyms. The parties have agreed to use neutral identifiers here to avoid the need for redactions.",
      "position": "bottom"
    },
    {
      "type": "handwritten",
      "content": "Commented [CE12]: These references will need to be changed once we agree upon an appropriate pseudonym",
      "position": "margin"
    },
    {
      "type": "handwritten",
      "content": "Commented [CE13]: For a discussion of the reasons for these changes, see proposed edits to Count Two - Elements",
      "position": "margin"
    }
  ],
  "entities": {
    "people": [
      "Ghislaine Maxwell",
      "Jeffrey Epstein",
      "Jane Doe-1"
    ],
    "organizations": [
      "Government"
    ],
    "locations": [],
    "dates": [
      "11/04/21",
      "1994",
      "2004",
      "1997"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "410-1"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case against Ghislaine Maxwell. The text includes summaries of the indictment counts and references to pseudonyms used for victims. There are also comments in the margin indicating proposed changes to the text."
}