mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00006124.json

{
  "document_metadata": {
    "page_number": "58",
    "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 58 of 93 is sufficient as long as all of you find that at least one overt act was committed by one of the conspirators in furtherance of the conspiracy. You should bear in mind that the overt act, standing alone, may be an innocent, lawful act. However, an apparently innocent act sheds its harmless character if it is a step in carrying out, promoting, aiding, or assisting the conspiratorial scheme. You are therefore instructed that the overt act does not have to be an act which in and of itself is criminal or constitutes an objective of the conspiracy. I instruct you, however, that any overt acts related to Minor Victim-1, who at trial was identified as [Jane Doe-3 pseudonym], are not direct evidence of the conspiracies charged in Counts One and Three of the Indictment and they cannot satisfy the overt act element of these offenses. You are further instructed that the overt act need not have been committed at precisely the time alleged in the Indictment. It is sufficient if you are convinced beyond a reasonable doubt, that it occurred at or about the time and place stated. Adapted from Sand, et al., Modern Federal Jury Instructions, Instrs. 19-7, 19-8; the charge of the Hon. Alison J. Nathan in United States v. Lebedev, 15 Cr. 769 (AJN); the charge of the Hon. Kimba M. Wood in United States v. Almonte, 16 Cr. 670 (KMW); and the charge of the Hon. Denise L. Cote in United States v. Purcell, 18 Cr. 081 (DLC). Commented [CE78]: This language is covered in the proposed fourth element See United States v. Pizarro, 17 Cr 151 (AJN) Commented [RA(79R78]: See below response Commented [CE80]: The defense maintains that the allegations of Jane Doe-3 are not direct evidence of the charged Mann Act conspiracies and should be redacted from the Indictment If they are not, the defense requests this instruction Commented [RA(81R80]: GOVERNMENT RESPONSE: This language is unnecessary because the jury cannot convict on Minor Victim-3 alone due to the statute of limitations instruction  In any event, this language may or may not be accurate depending on the Court's ruling as to Minor Victim-3  Finally, the Government notes that the defendant's proposed language erroneously refers to Minor Victim-1, rather than Minor Victim-3 58 DOJ-OGR-00006124",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 410-1 Filed 11/04/21 Page 58 of 93",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "is sufficient as long as all of you find that at least one overt act was committed by one of the conspirators in furtherance of the conspiracy. You should bear in mind that the overt act, standing alone, may be an innocent, lawful act. However, an apparently innocent act sheds its harmless character if it is a step in carrying out, promoting, aiding, or assisting the conspiratorial scheme. You are therefore instructed that the overt act does not have to be an act which in and of itself is criminal or constitutes an objective of the conspiracy. I instruct you, however, that any overt acts related to Minor Victim-1, who at trial was identified as [Jane Doe-3 pseudonym], are not direct evidence of the conspiracies charged in Counts One and Three of the Indictment and they cannot satisfy the overt act element of these offenses. You are further instructed that the overt act need not have been committed at precisely the time alleged in the Indictment. It is sufficient if you are convinced beyond a reasonable doubt, that it occurred at or about the time and place stated.",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "Adapted from Sand, et al., Modern Federal Jury Instructions, Instrs. 19-7, 19-8; the charge of the Hon. Alison J. Nathan in United States v. Lebedev, 15 Cr. 769 (AJN); the charge of the Hon. Kimba M. Wood in United States v. Almonte, 16 Cr. 670 (KMW); and the charge of the Hon. Denise L. Cote in United States v. Purcell, 18 Cr. 081 (DLC).",
      "position": "footer"
    },
    {
      "type": "handwritten",
      "content": "",
      "position": "none"
    },
    {
      "type": "stamp",
      "content": "",
      "position": "none"
    },
    {
      "type": "other",
      "content": "Commented [CE78]: This language is covered in the proposed fourth element See United States v. Pizarro, 17 Cr 151 (AJN) Commented [RA(79R78]: See below response Commented [CE80]: The defense maintains that the allegations of Jane Doe-3 are not direct evidence of the charged Mann Act conspiracies and should be redacted from the Indictment If they are not, the defense requests this instruction Commented [RA(81R80]: GOVERNMENT RESPONSE: This language is unnecessary because the jury cannot convict on Minor Victim-3 alone due to the statute of limitations instruction  In any event, this language may or may not be accurate depending on the Court's ruling as to Minor Victim-3  Finally, the Government notes that the defendant's proposed language erroneously refers to Minor Victim-1, rather than Minor Victim-3",
      "position": "margin"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Kimba M. Wood",
      "Denise L. Cote",
      "Jane Doe-3",
      "Minor Victim-1",
      "Minor Victim-3"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "11/04/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 410-1",
      "15 Cr. 769",
      "16 Cr. 670",
      "17 Cr 151",
      "18 Cr. 081",
      "DOJ-OGR-00006124"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case, with annotations and comments in the margins. The text is mostly printed, with some annotations and comments that appear to be handwritten or typed in a different font. The document includes references to various court cases and legal instructions."
}