mirror-epstein-docs/results/IMAGES005/DOJ-OGR-00014628.json

{
  "document_metadata": {
    "page_number": "228",
    "document_number": "767",
    "date": "08/10/22",
    "document_type": "Charge",
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    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 767 Filed 08/10/22 Page 228 of 257 3062 LCKCmax9 Charge established by a showing that the defendant was careless, negligent, or foolish. However, one may not willfully and intentionally remain ignorant of a material fact and important to her conduct in order to escape the consequences of criminal law. The law calls this conscious avoidance or willful blindness. An argument by the government of conscious avoidance is not a substitute for proof, it is simply another factor that you, the jury, may consider in deciding what the defendant knew. Thus, if you find beyond a reasonable doubt that the defendant was aware that there was a high probability a crime was being committed but that the defendant deliberately and consciously avoided confirming this fact such as by purposefully closing her eyes to it or intentionally failing to investigate it, then you may treat this deliberate avoidance of positive knowledge as the equivalent of knowledge, unless you find that defendant actually believed that she was not engaged in such unlawful behavior. In other words, a defendant cannot avoid criminal responsibility for her own conduct by deliberately closing her eyes or remaining purposefully ignorant of facts which would confirm to her that she was engaged in unlawful conduct. With respect to the conspiracy counts, you must also keep in mind that there is an important difference between knowingly and intentionally participating in a conspiracy, on SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00014628",
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      "content": "Case 1:20-cr-00330-PAE Document 767 Filed 08/10/22 Page 228 of 257 3062 LCKCmax9 Charge",
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    {
      "type": "printed",
      "content": "established by a showing that the defendant was careless, negligent, or foolish. However, one may not willfully and intentionally remain ignorant of a material fact and important to her conduct in order to escape the consequences of criminal law. The law calls this conscious avoidance or willful blindness.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "An argument by the government of conscious avoidance is not a substitute for proof, it is simply another factor that you, the jury, may consider in deciding what the defendant knew. Thus, if you find beyond a reasonable doubt that the defendant was aware that there was a high probability a crime was being committed but that the defendant deliberately and consciously avoided confirming this fact such as by purposefully closing her eyes to it or intentionally failing to investigate it, then you may treat this deliberate avoidance of positive knowledge as the equivalent of knowledge, unless you find that defendant actually believed that she was not engaged in such unlawful behavior. In other words, a defendant cannot avoid criminal responsibility for her own conduct by deliberately closing her eyes or remaining purposefully ignorant of facts which would confirm to her that she was engaged in unlawful conduct.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "With respect to the conspiracy counts, you must also keep in mind that there is an important difference between knowingly and intentionally participating in a conspiracy, on",
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    },
    {
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "type": "printed",
      "content": "DOJ-OGR-00014628",
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  "entities": {
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    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "locations": [],
    "dates": [
      "08/10/22"
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    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "767",
      "3062",
      "LCKCmax9",
      "DOJ-OGR-00014628",
      "(212) 805-0300"
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  "additional_notes": "The document appears to be a court transcript or legal document. The text is typed and there are no visible redactions or damage."
}