{
  "document_metadata": {
    "page_number": "41",
    "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 41 of 93\n\nCounts Two, Four, and Six: Aiding and Abetting\n\nIn connection with the crimes charged in Counts Two, Four, and Six, the defendant is also charged with aiding and abetting the commission of those crimes. Aiding and abetting liability is its own theory of criminal liability. In effect, it is a theory of liability that permits a defendant to be convicted of a specified crime if the defendant, while not herself committing the crime, assisted another person or persons in committing the crime. As to Counts Two, Four, and Six, therefore, the defendant can be convicted either if she committed the crime herself, or if another person committed the crime and the defendant aided and abetted that person to commit that crime.\n\nUnder the federal aiding and abetting statute, whoever \"aids, abets, counsels, commands, induces, or procures\" the commission of an offense is punishable as a principal. You should give those words their ordinary meaning. A person aids or abets a crime if she knowingly does some act for the purpose of aiding or encouraging the commission of that crime, with the intention of causing the crime charged to be committed. To \"induce\" means to lead or move by persuasion or influence as to some action or state of mind. To \"procure\" means to bring about by unscrupulous or indirect means. To \"cause\" means to bring something about, to effect something.\n\nIn other words, it is not necessary for the Government to show that Ms. Maxwell the defendant herself physically committed the crime charged in order for you to find her guilty. This is because a person who aids, abets, counsels, commands, induces, or procures the commission of a crime is just as guilty of that offense as if she committed it herself.\n\nAccordingly, you may find Ms. Maxwell the defendant guilty of the offenses charged in Counts Two, Four, and Six if you find beyond a reasonable doubt that the Government has proven that another person actually committed the offense with which Ms. Maxwell the defendant is\n\nCommented [CE55]: This language is unnecessary and redundant Moreover, it is not included in the Court's most recent instructions on this issue. See United States v. Berry, 20 CR 84 (AJN); United States v. Pizarro, 17 Cr 151 (AJN)\n\nCommented [RA(56R55]: GOVERNMENT RESPONSE: The Court has given this instruction previously See United States v. Lobadeiv, 15 Cr 769 (AJN); United States v. Jones, 16 Cr 553 (AJN) It is clarifying for the jury before the Court gives a more fulsome description of accomplice liability\n\nCommented [CE57]: The additional language is consistent with the Court's earlier instructions on this issue. See United States v. Berry, 20 CR 84 (AJN); United States v. Pizarro, 17 Cr 151 (AJN)\n\nCommented [RA(58R57]: GOVERNMENT RESPONSE: Because the instructions do not elsewhere define terms that carry their ordinary meaning (e g the verbs in the Mann Act and sex trafficking counts), there is no reason to do so here\n\nDOJ-OGR-00006107",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 410-1 Filed 11/04/21 Page 41 of 93",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Counts Two, Four, and Six: Aiding and Abetting",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "In connection with the crimes charged in Counts Two, Four, and Six, the defendant is also charged with aiding and abetting the commission of those crimes. Aiding and abetting liability is its own theory of criminal liability. In effect, it is a theory of liability that permits a defendant to be convicted of a specified crime if the defendant, while not herself committing the crime, assisted another person or persons in committing the crime. As to Counts Two, Four, and Six, therefore, the defendant can be convicted either if she committed the crime herself, or if another person committed the crime and the defendant aided and abetted that person to commit that crime.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Under the federal aiding and abetting statute, whoever \"aids, abets, counsels, commands, induces, or procures\" the commission of an offense is punishable as a principal. You should give those words their ordinary meaning. A person aids or abets a crime if she knowingly does some act for the purpose of aiding or encouraging the commission of that crime, with the intention of causing the crime charged to be committed. To \"induce\" means to lead or move by persuasion or influence as to some action or state of mind. To \"procure\" means to bring about by unscrupulous or indirect means. To \"cause\" means to bring something about, to effect something.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "In other words, it is not necessary for the Government to show that Ms. Maxwell the defendant herself physically committed the crime charged in order for you to find her guilty. This is because a person who aids, abets, counsels, commands, induces, or procures the commission of a crime is just as guilty of that offense as if she committed it herself.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Accordingly, you may find Ms. Maxwell the defendant guilty of the offenses charged in Counts Two, Four, and Six if you find beyond a reasonable doubt that the Government has proven that another person actually committed the offense with which Ms. Maxwell the defendant is",
      "position": "middle"
    },
    {
      "type": "handwritten",
      "content": "Commented [CE55]: This language is unnecessary and redundant Moreover, it is not included in the Court's most recent instructions on this issue. See United States v. Berry, 20 CR 84 (AJN); United States v. Pizarro, 17 Cr 151 (AJN)",
      "position": "margin"
    },
    {
      "type": "handwritten",
      "content": "Commented [RA(56R55]: GOVERNMENT RESPONSE: The Court has given this instruction previously See United States v. Lobadeiv, 15 Cr 769 (AJN); United States v. Jones, 16 Cr 553 (AJN) It is clarifying for the jury before the Court gives a more fulsome description of accomplice liability",
      "position": "margin"
    },
    {
      "type": "handwritten",
      "content": "Commented [CE57]: The additional language is consistent with the Court's earlier instructions on this issue. See United States v. Berry, 20 CR 84 (AJN); United States v. Pizarro, 17 Cr 151 (AJN)",
      "position": "margin"
    },
    {
      "type": "handwritten",
      "content": "Commented [RA(58R57]: GOVERNMENT RESPONSE: Because the instructions do not elsewhere define terms that carry their ordinary meaning (e g the verbs in the Mann Act and sex trafficking counts), there is no reason to do so here",
      "position": "margin"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006107",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell"
    ],
    "organizations": [
      "Government"
    ],
    "locations": [],
    "dates": [
      "11/04/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "410-1",
      "20 CR 84 (AJN)",
      "17 Cr 151 (AJN)",
      "15 Cr 769 (AJN)",
      "16 Cr 553 (AJN)"
    ]
  },
  "additional_notes": "The document appears to be a court document related to the case of Ms. Maxwell. It includes instructions for the jury regarding aiding and abetting liability. The document has several comments and annotations in the margins, indicating that it has been reviewed and edited by multiple parties."
}