mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00006123.json

{
  "document_metadata": {
    "page_number": "57",
    "document_number": "410-1",
    "date": "11/04/21",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 410-1 Filed 11/04/21 Page 57 of 93\n\nCounts One, Three, and Five Two: Conspiracy to Violate Federal Law - Third Element\n\nThe third element that the government must prove beyond a reasonable doubt to establish the offense of conspiracy is that at least one overt act charged in the Indictment was knowingly committed by at least one of the conspirators not necessarily Ms. Maxwellthe defendant in furtherance of the conspiracy.\n\nThe 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.\n\nWith respect to the overt acts for Count One, the Indictment reads as follows: [The Court is respectfully requested to read the overt acts listed under Count One of the Indictment].\n\nWith respect to the overt acts for Count Three, the Indictment reads as follows: [The Court is respectfully requested to read the overt acts listed under Count Three of the Indictment].\n\nWith respect to the overt acts for Count Five, the Indictment reads as follows: [The Court is respectfully requested to read the overt acts listed under Count Five of the Indictment].\n\nIn order for the Government to satisfy this element, it is not necessary for the Government to prove that Ms. Maxwellthe defendant committed the overt act. It is sufficient for the Government to show that any of the members of the conspiracy knowingly committed some overt act in furtherance of the conspiracy. Further, the overt act need not be one that is alleged in the Indictment. Rather, it can be any overt act that is substantially similar to those acts alleged in the Indictment, if you are convinced that the act occurred while the conspiracy was still in existence and that it was done in furtherance of the conspiracy as described in the Indictment. In addition, you need not be unanimous as to which overt act you find to have been committed.\n\n57\n\nDOJ-OGR-00006123",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 410-1 Filed 11/04/21 Page 57 of 93",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "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 charged in the Indictment was knowingly committed by at least one of the conspirators not necessarily Ms. Maxwellthe defendant in furtherance of the conspiracy.",
      "position": "middle"
    },
    {
      "type": "handwritten",
      "content": "not necessarily Ms. Maxwellthe defendant",
      "position": "margin"
    },
    {
      "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 as follows: [The Court is respectfully requested to read the overt acts listed under Count One of the Indictment].",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "With respect to the overt acts for Count Three, the Indictment reads as follows: [The Court is respectfully requested to read the overt acts listed under Count Three of the Indictment].",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "With respect to the overt acts for Count Five, the Indictment reads as follows: [The Court is respectfully requested to read the overt acts listed under Count Five of the Indictment].",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "In order for the Government to satisfy this element, it is not necessary for the Government to prove that Ms. Maxwellthe defendant committed the overt act. It is sufficient for the Government to show that any of the members of the conspiracy knowingly committed some overt act in furtherance of the conspiracy. Further, the overt act need not be one that is alleged in the Indictment. Rather, it can be any overt act that is substantially similar to those acts alleged in the Indictment, if you are convinced that the act occurred while the conspiracy was still in existence and that it was done in furtherance of the conspiracy as described in the Indictment. In addition, you need not be unanimous as to which overt act you find to have been committed.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "57",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006123",
      "position": "footer"
    },
    {
      "type": "stamp",
      "content": "Commented [RA(76): See objection on page 45",
      "position": "margin"
    },
    {
      "type": "stamp",
      "content": "Commented [CE77]: The language \"not necessarily Ms Maxwell\" is not necessary because the instruction covers this point later and it is confusing to place it here without explanation The language \"in furtherance of the conspiracy\" is not necessary under the defense's proposal because this concept is covered in the fourth element",
      "position": "margin"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell"
    ],
    "organizations": [
      "Government"
    ],
    "locations": [],
    "dates": [
      "11/04/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "410-1",
      "DOJ-OGR-00006123"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a conspiracy case. The text discusses the third element required to establish the offense of conspiracy and the overt act element. There are comments and objections noted in the margins."
}