{
  "document_metadata": {
    "page_number": "56 of 82",
    "document_number": "562",
    "date": "12/17/21",
    "document_type": "court document",
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  "full_text": "Case 1:20-cr-00330-PAE Document 562 Filed 12/17/21 Page 56 of 82\n1 responsibility for her own conduct by \"deliberately closing her eyes,\" or remaining purposefully\n2 ignorant of facts which would confirm to her that she was engaged in unlawful conduct.\n3 With respect to the conspiracy counts, you must also keep in mind that there is an\n4 important difference between knowingly and intentionally participating in a conspiracy, on the\n5 one hand—and which I just explained to you—and knowing the specific objective of the\n6 conspiracy, on the other. You may consider conscious avoidance in deciding whether the\n7 Defendant knew the objective of a conspiracy, that is, whether she reasonably believed that there\n8 was a high probability that a goal of the conspiracy was to commit the crime charged as objects\n9 of the conspiracy and took deliberate and conscious action to avoid confirming that fact but\n10 participated in the conspiracy anyway. But conscious avoidance cannot be used as a substitute\n11 for finding that the Defendant knowingly and intentionally joined the conspiracy in the first\n12 place. It is logically impossible for a defendant to intend and agree to join a conspiracy if she\n13 does not actually know it exists.\n14 In sum, if you find that the Defendant believed there was a high probability that a fact\n15 was so and that the Defendant took deliberate and conscious action to avoid learning the truth of\n16 that fact, you may find that the Defendant acted knowingly with respect to that fact. However, if\n17 you find that the Defendant actually believed the fact was not so, then you may not find that she\n18 acted knowingly with respect to that fact.\n55\nDOJ-OGR-00008512",
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      "content": "Case 1:20-cr-00330-PAE Document 562 Filed 12/17/21 Page 56 of 82",
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    {
      "type": "printed",
      "content": "1 responsibility for her own conduct by \"deliberately closing her eyes,\" or remaining purposefully\n2 ignorant of facts which would confirm to her that she was engaged in unlawful conduct.\n3 With respect to the conspiracy counts, you must also keep in mind that there is an\n4 important difference between knowingly and intentionally participating in a conspiracy, on the\n5 one hand—and which I just explained to you—and knowing the specific objective of the\n6 conspiracy, on the other. You may consider conscious avoidance in deciding whether the\n7 Defendant knew the objective of a conspiracy, that is, whether she reasonably believed that there\n8 was a high probability that a goal of the conspiracy was to commit the crime charged as objects\n9 of the conspiracy and took deliberate and conscious action to avoid confirming that fact but\n10 participated in the conspiracy anyway. But conscious avoidance cannot be used as a substitute\n11 for finding that the Defendant knowingly and intentionally joined the conspiracy in the first\n12 place. It is logically impossible for a defendant to intend and agree to join a conspiracy if she\n13 does not actually know it exists.\n14 In sum, if you find that the Defendant believed there was a high probability that a fact\n15 was so and that the Defendant took deliberate and conscious action to avoid learning the truth of\n16 that fact, you may find that the Defendant acted knowingly with respect to that fact. However, if\n17 you find that the Defendant actually believed the fact was not so, then you may not find that she\n18 acted knowingly with respect to that fact.",
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      "type": "printed",
      "content": "55",
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      "type": "printed",
      "content": "DOJ-OGR-00008512",
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  "entities": {
    "people": [],
    "organizations": [
      "DOJ"
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    "locations": [],
    "dates": [
      "12/17/21"
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    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "562",
      "DOJ-OGR-00008512"
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  "additional_notes": "The document appears to be a court transcript or legal document related to a conspiracy case. The text is printed and there are no visible stamps or handwritten notes. The document is well-formatted and legible."
}