{
  "document_metadata": {
    "page_number": "76",
    "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 76 of 93 Formal / Informal Immunity of Government Witnesses [If applicable] You have heard the testimony of an accomplice witness, [witness name], who was a co-conspirator of Jeffrey Epstein, but who was not charged as a defendant in this case. [Witness name] have testified under a grant of immunity from this Court. What this means is that the testimony of the witness may not be used against him or her in any criminal case, except a prosecution for perjury, giving a false statement, or otherwise failing to comply with the immunity order of this court. Because of the interest an accomplice may have in testifying, testimony should be scrutinized with great care and viewed with particular caution when you decide how much of that testimony to believe. Such testimony should be scrutinized by you with great care and you should act upon it with caution. You should consider whether [witness name] has a motive to testify falsely. You should examine [her testimony] closely to determine whether or not it is colored in such a way as to place guilt upon the defendant, Ms. Maxwell, in order to further the witness's own interests. If you believe the testimony to be true and determine to accept it, you may give it such weight, if any, as you believe it deserves. Adapted from Sand, et al., Modern Federal Jury Instructions, Instr. 7-8; and the charge of the Hon. Loran G. Schofield in United States v. Calk, 19 Cr. 366 (LGS). Commented [CE93]: The defense submits that these edits are appropriate given [Employee-1]'s status as an unindicted co-conspirator. See Sand, Instr. 7-5, 7-1, 7-8 Commented [RA94R93]: GOVERNMENT RESPONSE: (1)The defense's proposed changes include language typically used when the witness is testifying pursuant to an agreement with the Government. Employee-1 has no such agreement and is merely testifying under a grant of immunity (2) The defense will likely argue that Employee-1 is not a co-conspirator of the defendant's. The defense should not be permitted to argue that Employee-1 was not a co-conspirator and that her testimony should be taken with particular caution because she was a co-conspirator DOJ-OGR-00006142",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 410-1 Filed 11/04/21 Page 76 of 93",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Formal / Informal Immunity of Government Witnesses",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "[If applicable] You have heard the testimony of an accomplice witness, [witness name], who was a co-conspirator of Jeffrey Epstein, but who was not charged as a defendant in this case. [Witness name] have testified under a grant of immunity from this Court. What this means is that the testimony of the witness may not be used against him or her in any criminal case, except a prosecution for perjury, giving a false statement, or otherwise failing to comply with the immunity order of this court.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Because of the interest an accomplice may have in testifying, testimony should be scrutinized with great care and viewed with particular caution when you decide how much of that testimony to believe. Such testimony should be scrutinized by you with great care and you should act upon it with caution. You should consider whether [witness name] has a motive to testify falsely. You should examine [her testimony] closely to determine whether or not it is colored in such a way as to place guilt upon the defendant, Ms. Maxwell, in order to further the witness's own interests. If you believe the testimony to be true and determine to accept it, you may give it such weight, if any, as you believe it deserves.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Adapted from Sand, et al., Modern Federal Jury Instructions, Instr. 7-8; and the charge of the Hon. Loran G. Schofield in United States v. Calk, 19 Cr. 366 (LGS).",
      "position": "bottom"
    },
    {
      "type": "handwritten",
      "content": "Commented [CE93]: The defense submits that these edits are appropriate given [Employee-1]'s status as an unindicted co-conspirator. See Sand, Instr. 7-5, 7-1, 7-8",
      "position": "margin"
    },
    {
      "type": "handwritten",
      "content": "Commented [RA94R93]: GOVERNMENT RESPONSE: (1)The defense's proposed changes include language typically used when the witness is testifying pursuant to an agreement with the Government. Employee-1 has no such agreement and is merely testifying under a grant of immunity (2) The defense will likely argue that Employee-1 is not a co-conspirator of the defendant's. The defense should not be permitted to argue that Employee-1 was not a co-conspirator and that her testimony should be taken with particular caution because she was a co-conspirator",
      "position": "margin"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006142",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jeffrey Epstein",
      "Ms. Maxwell",
      "Loran G. Schofield",
      "Employee-1"
    ],
    "organizations": [
      "Government"
    ],
    "locations": [],
    "dates": [
      "11/04/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "410-1",
      "19 Cr. 366 (LGS)",
      "DOJ-OGR-00006142"
    ]
  },
  "additional_notes": "The document appears to be a court document related to the case United States v. Calk, 19 Cr. 366 (LGS). It contains instructions for the jury regarding the testimony of an accomplice witness. The document has been edited with comments from both the defense and the government."
}