{
  "document_metadata": {
    "page_number": "60",
    "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 60 of 93\n\nCounts One, Three, and Five - Liability for Acts and Declarations of Co-Conspirators\nWhen people enter into a conspiracy to accomplish an unlawful end, they become agents or partners of one another in carrying out the conspiracy.\nIn determining the factual issues before you, you may consider against Ms. Maxwell any acts or statements made by any of the people that you find, under the standards I have already described, to have been her co-conspirators, even though such acts or statements were not made in her presence, or were made without her knowledge.\nYou will recall that I have admitted into evidence against the defendant the acts and statements of others because these acts and statements were committed or made by persons who the Government charges were also confederates or co-conspirators of the defendant.\nThe reason for allowing this evidence to be received against the defendant has to do in part with the nature of the crime of conspiracy. A conspiracy is often referred to as a partnership in crime as in other types of partnerships, when people enter into a conspiracy to accomplish an unlawful end, each and every member becomes an agent for the other conspirators in carrying out the conspiracy.\nTherefore, the reasonably foreseeable acts, statements, and omissions of any member of the conspiracy, committed in furtherance of the common purpose of the conspiracy, are deemed under the law to be the acts of all of the members, and all of the members are responsible for such acts, statements, or omissions.\nIf you find, beyond a reasonable doubt, that a defendant was a member of the conspiracy charged in the Indictment, then any acts done or statements made in furtherance of the conspiracy by a person also found by you to have been a member of the same conspiracy may be considered against that defendant. This is so even if such acts were committed or such\n60\nDOJ-OGR-00006126",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 410-1 Filed 11/04/21 Page 60 of 93",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Counts One, Three, and Five - Liability for Acts and Declarations of Co-Conspirators",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "When people enter into a conspiracy to accomplish an unlawful end, they become agents or partners of one another in carrying out the conspiracy.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "In determining the factual issues before you, you may consider against Ms. Maxwell any acts or statements made by any of the people that you find, under the standards I have already described, to have been her co-conspirators, even though such acts or statements were not made in her presence, or were made without her knowledge.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "You will recall that I have admitted into evidence against the defendant the acts and statements of others because these acts and statements were committed or made by persons who the Government charges were also confederates or co-conspirators of the defendant.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The reason for allowing this evidence to be received against the defendant has to do in part with the nature of the crime of conspiracy. A conspiracy is often referred to as a partnership in crime as in other types of partnerships, when people enter into a conspiracy to accomplish an unlawful end, each and every member becomes an agent for the other conspirators in carrying out the conspiracy.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Therefore, the reasonably foreseeable acts, statements, and omissions of any member of the conspiracy, committed in furtherance of the common purpose of the conspiracy, are deemed under the law to be the acts of all of the members, and all of the members are responsible for such acts, statements, or omissions.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "If you find, beyond a reasonable doubt, that a defendant was a member of the conspiracy charged in the Indictment, then any acts done or statements made in furtherance of the conspiracy by a person also found by you to have been a member of the same conspiracy may be considered against that defendant. This is so even if such acts were committed or such",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "60",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006126",
      "position": "footer"
    },
    {
      "type": "handwritten",
      "content": "Commented [CE84]: The defense proposes this more streamlined and more balanced instruction on liability for acts and declarations of co-conspirators, which is consistent with the Court's prior instructions on this issue. See United States v. Pizarro, 17 Cr 151 (AJN)",
      "position": "margin"
    },
    {
      "type": "handwritten",
      "content": "Commented [RA(85R84]: See response on page 47",
      "position": "margin"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "11/04/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "410-1",
      "17 Cr 151 (AJN)",
      "DOJ-OGR-00006126"
    ]
  },
  "additional_notes": "The document appears to be a court filing with annotations and comments in the margins. The text is mostly printed, with some handwritten comments. The document is related to a court case involving Ms. Maxwell."
}