{
  "document_metadata": {
    "page_number": "20",
    "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 20 of 93\n\nCount Two: Enticement to Engage in Illegal Sexual Activity - First Element\n\nThe first element of Count Two which the government must prove beyond a reasonable doubt is that the defendant Ms. Maxwell knowingly persuaded or induced or enticed or coerced an individual [Jane Doe-1 pseudonym] to travel in interstate or foreign commerce; namely from Florida to New York, as alleged in the Indictment. The terms \"persuaded,\" \"induced,\" and \"enticed,\" and \"coerced\" have their ordinary, everyday meanings.\n\nThe term \"interstate commerce\" simply means movement from one state to another. The term \"State\" includes a State of the United States and the District of Columbia.\n\n\"Knowingly\" Defined\n\nThe defendant Ms. Maxwell must have acted knowingly. An act is done knowingly when it is done voluntarily and intentionally and not because of accident, mistake, or some other innocent reason.\n\nNow, knowledge is a matter of inference from the proven facts. Science has not yet devised a manner of looking into a person's mind and knowing what that person is thinking.\n\nWhether the defendant Ms. Maxwell acted knowingly may be proven by the defendant's Ms. Maxwell's conduct and by all of the facts and circumstances surrounding the case.\n\nAdapted from Sand et al., Modern Federal Jury Instructions, Instr. 64-7; the charge of the Hon. Alison J. Nathan in United States v. Pizzaro, 17 Cr. 151 (AJN) and in United States v. Le, 15 Cr. 38 (AJN); the charge of the Hon. Denise L. Cote in United States v. Purcell, 18 Cr. 081 (DLC); the charge of the Hon. Kimba M. Wood in United States v. Almonte, 16 Cr. 670 (KMW); and the charge of the Hon. Sidney H. Stein in United States v. Waqar, 18 Cr. 342 (SHS). See United States v. Waqar, 997 F.3d 481, 484-85 (2d Cir. 2021) (stating that the \"statutory verbs\" in § 2422(b) \"attempt, persuade, induce, entice, [and] coerce, though not defined in the statute, are words of common usage that have plain and ordinary meanings\" (citation omitted)).\n\n20\n\nDOJ-OGR-00006086",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 410-1 Filed 11/04/21 Page 20 of 93",
      "position": "header"
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    {
      "type": "printed",
      "content": "Count Two: Enticement to Engage in Illegal Sexual Activity - First Element\n\nThe first element of Count Two which the government must prove beyond a reasonable doubt is that the defendant Ms. Maxwell knowingly persuaded or induced or enticed or coerced an individual [Jane Doe-1 pseudonym] to travel in interstate or foreign commerce; namely from Florida to New York, as alleged in the Indictment. The terms \"persuaded,\" \"induced,\" and \"enticed,\" and \"coerced\" have their ordinary, everyday meanings.\n\nThe term \"interstate commerce\" simply means movement from one state to another. The term \"State\" includes a State of the United States and the District of Columbia.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "\"Knowingly\" Defined\n\nThe defendant Ms. Maxwell must have acted knowingly. An act is done knowingly when it is done voluntarily and intentionally and not because of accident, mistake, or some other innocent reason.\n\nNow, knowledge is a matter of inference from the proven facts. Science has not yet devised a manner of looking into a person's mind and knowing what that person is thinking.\n\nWhether the defendant Ms. Maxwell acted knowingly may be proven by the defendant's Ms. Maxwell's conduct and by all of the facts and circumstances surrounding the case.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Adapted from Sand et al., Modern Federal Jury Instructions, Instr. 64-7; the charge of the Hon. Alison J. Nathan in United States v. Pizzaro, 17 Cr. 151 (AJN) and in United States v. Le, 15 Cr. 38 (AJN); the charge of the Hon. Denise L. Cote in United States v. Purcell, 18 Cr. 081 (DLC); the charge of the Hon. Kimba M. Wood in United States v. Almonte, 16 Cr. 670 (KMW); and the charge of the Hon. Sidney H. Stein in United States v. Waqar, 18 Cr. 342 (SHS). See United States v. Waqar, 997 F.3d 481, 484-85 (2d Cir. 2021) (stating that the \"statutory verbs\" in § 2422(b) \"attempt, persuade, induce, entice, [and] coerce, though not defined in the statute, are words of common usage that have plain and ordinary meanings\" (citation omitted)).",
      "position": "middle"
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    {
      "type": "printed",
      "content": "20",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006086",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell",
      "Jane Doe-1",
      "Alison J. Nathan",
      "Denise L. Cote",
      "Kimba M. Wood",
      "Sidney H. Stein"
    ],
    "organizations": [],
    "locations": [
      "Florida",
      "New York",
      "United States",
      "District of Columbia"
    ],
    "dates": [
      "11/04/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "410-1",
      "17 Cr. 151 (AJN)",
      "15 Cr. 38 (AJN)",
      "18 Cr. 081 (DLC)",
      "16 Cr. 670 (KMW)",
      "18 Cr. 342 (SHS)",
      "997 F.3d 481"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of United States v. Ghislaine Maxwell. The text is printed and there are no visible stamps or handwritten notes. The document is page 20 of 93."
}