{
  "document_metadata": {
    "page_number": "47",
    "document_number": "562",
    "date": "12/17/21",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 562 Filed 12/17/21 Page 47 of 82\n\nInstruction No. 35: Counts One, Three, and Five: Conspiracy to Violate Federal Law – Second Element: Membership in the Conspiracy\n\nWith respect to each of Counts One, Three, and Five, if you conclude that the Government has proven beyond a reasonable doubt that the relevant conspiracy existed, and that the conspiracy had the object I just mentioned, then you must next consider the second element: namely, whether Ms. Maxwell knowingly and willfully participated in the conspiracy knowing its unlawful purpose and intending to further its unlawful objectives.\n\nIn order to satisfy the second element of Counts One, Three, or Five, the Government must prove beyond a reasonable doubt that Ms. Maxwell knowingly and willfully entered into the conspiracy charged in the particular count with a criminal intent—that is, with a purpose to violate the law—and that she agreed to take part in the conspiracy to further promote and cooperate in its unlawful objective.\n\n“Willfully” and “Knowingly”\n\nAn act is done “knowingly” and “willfully” if it is done deliberately and purposely—that is, Ms. Maxwell’s actions must have been her conscious objective rather than a product of a mistake or accident, mere negligence, or some other innocent reason.\n\nTo satisfy its burden of proof that Ms. Maxwell willfully and knowingly became a member of a conspiracy to accomplish an unlawful purpose, the Government must prove beyond a reasonable doubt that Ms. Maxwell knew that she was a member of an operation or conspiracy to accomplish that unlawful purpose, and that her action of joining such an operation or conspiracy was not due to carelessness, negligence, or mistake.\n\nNow, as I have said, 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. However, you do have before you the evidence of certain acts and conversations",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 562 Filed 12/17/21 Page 47 of 82",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Instruction No. 35: Counts One, Three, and Five: Conspiracy to Violate Federal Law – Second Element: Membership in the Conspiracy",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "With respect to each of Counts One, Three, and Five, if you conclude that the Government has proven beyond a reasonable doubt that the relevant conspiracy existed, and that the conspiracy had the object I just mentioned, then you must next consider the second element: namely, whether Ms. Maxwell knowingly and willfully participated in the conspiracy knowing its unlawful purpose and intending to further its unlawful objectives.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "In order to satisfy the second element of Counts One, Three, or Five, the Government must prove beyond a reasonable doubt that Ms. Maxwell knowingly and willfully entered into the conspiracy charged in the particular count with a criminal intent—that is, with a purpose to violate the law—and that she agreed to take part in the conspiracy to further promote and cooperate in its unlawful objective.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "“Willfully” and “Knowingly”",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "An act is done “knowingly” and “willfully” if it is done deliberately and purposely—that is, Ms. Maxwell’s actions must have been her conscious objective rather than a product of a mistake or accident, mere negligence, or some other innocent reason.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "To satisfy its burden of proof that Ms. Maxwell willfully and knowingly became a member of a conspiracy to accomplish an unlawful purpose, the Government must prove beyond a reasonable doubt that Ms. Maxwell knew that she was a member of an operation or conspiracy to accomplish that unlawful purpose, and that her action of joining such an operation or conspiracy was not due to carelessness, negligence, or mistake.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Now, as I have said, 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. However, you do have before you the evidence of certain acts and conversations",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "46",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00008503",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell"
    ],
    "organizations": [
      "Government"
    ],
    "locations": [],
    "dates": [
      "12/17/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "562"
    ]
  },
  "additional_notes": "The document appears to be a court instruction related to a conspiracy case involving Ms. Maxwell. The text is printed and there are no visible stamps or handwritten notes. The document is part of a larger case file, as indicated by the page number and document number."
}