{
  "document_metadata": {
    "page_number": "4",
    "document_number": "395",
    "date": "10/29/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 395 Filed 10/29/21 Page 4 of 9\n\nGhislaine Maxwell moves in limine to preclude reference to the accusers as \"victims\" or \"minor victims.\" Ms. Maxwell moves for an order precluding all trial participants from referring to the accusers as \"victims\" or \"minor victims.\" Instead, all trial participants, including the Court, should refer to all persons by their individual names.\n\nARGUMENT\n\nUnder the United States Constitution, Ms. Maxwell is presumed innocent unless the government proves all elements of the alleged offenses beyond a reasonable doubt. U.S. Const. amend. V; In re Winship, 397 U.S. 358, 364 (1970). The presumption of innocence has deep historical roots and is a core tenet of criminal law. \"The principle that there is a presumption of innocence in favor of the accused is the undoubted law, axiomatic and elementary, and its enforcement lies at the foundation of the administration of our criminal law.\" Coffin v. United States, 156 U.S. 432, 453 (1895) (looking to Deuteronomy and the law of Athens, Sparta, and Rome for early versions of the presumption of innocence).\n\nIn some criminal cases, the parties agree that an accuser was the victim of a crime. When, for example, a person is stabbed or shot, there is no dispute that the person was a victim of something. E.g., Jackson v. State, 600 A.2d 21, 24 (Del. 1991) (stating, on appeal from a rape conviction, that \"[t]he term 'victim' is used appropriately during trial when there is no doubt that a crime was committed and simply the identity of the perpetrator is in issue.\")\n\nThis is not one of those cases. Rather, Ms. Maxwell denies that she victimized anyone. And there is ample evidence to support her defense. The jury ultimately will have to decide whether the government has proven that these accusers are in fact \"victims\" or \"minor victims.\"\n\nIn advance of the jury's verdict, any reference to the accusers by those terms necessarily conveys the speaker's opinion that a crime in fact occurred and that the accusers are credible. Conveying such a personal belief biases the jury against Ms. Maxwell, implies a belief in the truthfulness of\n\n1\n\nDOJ-OGR-00005769",
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      "content": "Case 1:20-cr-00330-PAE Document 395 Filed 10/29/21 Page 4 of 9",
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    {
      "type": "printed",
      "content": "Ghislaine Maxwell moves in limine to preclude reference to the accusers as \"victims\" or \"minor victims.\" Ms. Maxwell moves for an order precluding all trial participants from referring to the accusers as \"victims\" or \"minor victims.\" Instead, all trial participants, including the Court, should refer to all persons by their individual names.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "ARGUMENT",
      "position": "middle"
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    {
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      "content": "Under the United States Constitution, Ms. Maxwell is presumed innocent unless the government proves all elements of the alleged offenses beyond a reasonable doubt. U.S. Const. amend. V; In re Winship, 397 U.S. 358, 364 (1970). The presumption of innocence has deep historical roots and is a core tenet of criminal law. \"The principle that there is a presumption of innocence in favor of the accused is the undoubted law, axiomatic and elementary, and its enforcement lies at the foundation of the administration of our criminal law.\" Coffin v. United States, 156 U.S. 432, 453 (1895) (looking to Deuteronomy and the law of Athens, Sparta, and Rome for early versions of the presumption of innocence).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "In some criminal cases, the parties agree that an accuser was the victim of a crime. When, for example, a person is stabbed or shot, there is no dispute that the person was a victim of something. E.g., Jackson v. State, 600 A.2d 21, 24 (Del. 1991) (stating, on appeal from a rape conviction, that \"[t]he term 'victim' is used appropriately during trial when there is no doubt that a crime was committed and simply the identity of the perpetrator is in issue.\")",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "This is not one of those cases. Rather, Ms. Maxwell denies that she victimized anyone. And there is ample evidence to support her defense. The jury ultimately will have to decide whether the government has proven that these accusers are in fact \"victims\" or \"minor victims.\"",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "In advance of the jury's verdict, any reference to the accusers by those terms necessarily conveys the speaker's opinion that a crime in fact occurred and that the accusers are credible. Conveying such a personal belief biases the jury against Ms. Maxwell, implies a belief in the truthfulness of",
      "position": "middle"
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      "type": "printed",
      "content": "1",
      "position": "footer"
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    {
      "type": "printed",
      "content": "DOJ-OGR-00005769",
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  ],
  "entities": {
    "people": [
      "Ghislaine Maxwell"
    ],
    "organizations": [],
    "locations": [
      "United States",
      "Athens",
      "Sparta",
      "Rome",
      "Delaware"
    ],
    "dates": [
      "10/29/21",
      "1970",
      "1895",
      "1991"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 395",
      "397 U.S. 358",
      "156 U.S. 432",
      "600 A.2d 21",
      "DOJ-OGR-00005769"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ghislaine Maxwell. The text is printed and there are no visible stamps or handwritten notes. The document is page 4 of 9."
}