{
  "document_metadata": {
    "page_number": "129",
    "document_number": "563",
    "date": "12/18/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 563 Filed 12/18/21 Page 129 of 167\n\n1 Instruction No. 35: Counts One, Three, and Five: Conspiracy to Violate Federal Law –\n2 Second Element: Membership in the Conspiracy\n3 With respect to each of Counts One, Three, and Five, if you conclude that the\n4 Government has proven beyond a reasonable doubt that the relevant conspiracy existed, and that\n5 the conspiracy had the object I just mentioned, then you must next consider the second element:\n6 namely, whether Ms. Maxwell knowingly and willfully participated in the conspiracy knowing\n7 its unlawful purpose and intending to further its unlawful objectives.\n8 In order to satisfy the second element of Counts One, Three, or Five, the Government\n9 must prove beyond a reasonable doubt that Ms. Maxwell knowingly and willfully entered into\n10 the conspiracy charged in the particular count with a criminal intent—that is, with a purpose to\n11 violate the law—and that she agreed to take part in the conspiracy to further promote and\n12 cooperate in its unlawful objective.\n13\n14 \"Willfully\" and \"Knowingly\"\n15 An act is done “knowingly” and “willfully” if it is done deliberately and purposely—that\n16 is, Ms. Maxwell’s actions must have been her conscious objective rather than a product of a\n17 mistake or accident, mere negligence, or some other innocent reason.\n18 To satisfy its burden of proof that Ms. Maxwell willfully and knowingly became a\n19 member of a conspiracy to accomplish an unlawful purpose, the Government must prove beyond\n20 a reasonable doubt that Ms. Maxwell knew that she was a member of an operation or conspiracy\n21 to accomplish that unlawful purpose, and that her action of joining such an operation or\n22 conspiracy was not due to carelessness, negligence, or mistake.\n23 Now, as I have said, knowledge is a matter of inference from the proven facts. Science\n24 has not yet devised a manner of looking into a person’s mind and knowing what that person is\n24 thinking. However, you do have before you the evidence of certain acts and conversations\n\n46\nDOJ-OGR-00008667",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 563 Filed 12/18/21 Page 129 of 167",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "1 Instruction No. 35: Counts One, Three, and Five: Conspiracy to Violate Federal Law –\n2 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\nGovernment has proven beyond a reasonable doubt that the relevant conspiracy existed, and that\nthe conspiracy had the object I just mentioned, then you must next consider the second element:\nnamely, whether Ms. Maxwell knowingly and willfully participated in the conspiracy knowing\nits 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\nmust prove beyond a reasonable doubt that Ms. Maxwell knowingly and willfully entered into\nthe conspiracy charged in the particular count with a criminal intent—that is, with a purpose to\nviolate the law—and that she agreed to take part in the conspiracy to further promote and\ncooperate in its unlawful objective.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "\"Willfully\" and \"Knowingly\"\nAn act is done “knowingly” and “willfully” if it is done deliberately and purposely—that\nis, Ms. Maxwell’s actions must have been her conscious objective rather than a product of a\nmistake 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\nmember of a conspiracy to accomplish an unlawful purpose, the Government must prove beyond\na reasonable doubt that Ms. Maxwell knew that she was a member of an operation or conspiracy\nto accomplish that unlawful purpose, and that her action of joining such an operation or\nconspiracy 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\nhas not yet devised a manner of looking into a person’s mind and knowing what that person is\nthinking. However, you do have before you the evidence of certain acts and conversations",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "46",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00008667",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell"
    ],
    "organizations": [
      "Government"
    ],
    "locations": [],
    "dates": [
      "12/18/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "563",
      "DOJ-OGR-00008667"
    ]
  },
  "additional_notes": "The document appears to be a court transcript or jury instruction related to the case of Ms. Maxwell. The text is printed and there is no handwriting or stamps visible."
}