{
  "document_metadata": {
    "page_number": "52",
    "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 52 of 167\n1 Instruction No. 36: Counts One, Three, and Five Two: Conspiracy to Violate Federal Law - Third Element\n2\n3 The third element that the Government must prove beyond a reasonable doubt to\n4 establish the offense of conspiracy is that at least one overt act was knowingly committed by at\n5 least one of the conspirators.\n6 The overt act element requires the Government to show something more than mere\n7 agreement; some overt step or action must have been taken by at least one of the conspirators in\n8 furtherance of that conspiracy. In other words, the Government must show that the agreement\n9 went beyond the mere talking stage. It must show that at least one of the conspirators actually\n10 did something in furtherance of the conspiracy.\n11 With respect to the overt acts for Count One, the Indictment reads alleges as follows:\n12 (1) Between in or about 1994 and in or about 1997, when Jane was under the age of 1718,\n13 Maxwell participated in multiple group sexual encounters with Epstein and Jane in New York\n14 and Florida; (2) In or about 1996, when Jane was under the age of 178, Jane was enticed to travel\n15 from Florida to New York for purposes of sexually abusing her at the New York Residence, in\n16 violation of New York Penal Law, Section 130.55; (3) In or about 1996, when Annie was under\n17 the age of 18, Maxwell provided Annie with an unsolicited massage in New Mexico, during\n18 which Annie was topless; (4) Between in or about 1994 and in or about 1995, when Kate was\n19 under the age of 18, Maxwell encouraged Kate to provide massages to Epstein in London,\n20 England, knowing that Epstein intended to sexually abuse Kate during those massages; (45)\n21 Between in or about 2001 and in or about 2002, when Carolyn was under the age of 178,\n22 Maxwell and Epstein invited Carolyn to travel from Florida to a place outside of Florida with\n23 Epstein.\n51\nDOJ-OGR-00008590",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 563 Filed 12/18/21 Page 52 of 167",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "1 Instruction No. 36: Counts One, Three, and Five Two: Conspiracy to Violate Federal Law - Third Element",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The third element that the Government must prove beyond a reasonable doubt to establish the offense of conspiracy is that at least one overt act was knowingly committed by at least one of the conspirators.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The overt act element requires the Government to show something more than mere agreement; some overt step or action must have been taken by at least one of the conspirators in furtherance of that conspiracy. In other words, the Government must show that the agreement went beyond the mere talking stage. It must show that at least one of the conspirators actually did something in furtherance of the conspiracy.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "With respect to the overt acts for Count One, the Indictment reads alleges as follows:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "(1) Between in or about 1994 and in or about 1997, when Jane was under the age of 1718, Maxwell participated in multiple group sexual encounters with Epstein and Jane in New York and Florida; (2) In or about 1996, when Jane was under the age of 178, Jane was enticed to travel from Florida to New York for purposes of sexually abusing her at the New York Residence, in violation of New York Penal Law, Section 130.55; (3) In or about 1996, when Annie was under the age of 18, Maxwell provided Annie with an unsolicited massage in New Mexico, during which Annie was topless; (4) Between in or about 1994 and in or about 1995, when Kate was under the age of 18, Maxwell encouraged Kate to provide massages to Epstein in London, England, knowing that Epstein intended to sexually abuse Kate during those massages; (45) Between in or about 2001 and in or about 2002, when Carolyn was under the age of 178, Maxwell and Epstein invited Carolyn to travel from Florida to a place outside of Florida with Epstein.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "51",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00008590",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Maxwell",
      "Epstein",
      "Jane",
      "Annie",
      "Kate",
      "Carolyn"
    ],
    "organizations": [],
    "locations": [
      "New York",
      "Florida",
      "New Mexico",
      "London",
      "England"
    ],
    "dates": [
      "1994",
      "1997",
      "1996",
      "1995",
      "2001",
      "2002"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "563",
      "DOJ-OGR-00008590"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a conspiracy case involving Maxwell and Epstein. The text includes details about the alleged crimes and the legal definitions relevant to the case."
}