mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00006079.json

{
  "document_metadata": {
    "page_number": "13",
    "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 13 of 93 all of the evidence, you are satisfied beyond a reasonable doubt of the defendant's guilt with respect to a particular charge against her, you should find the defendant guilty of that charge. Adapted from the charge of the Hon. Alison J. Nathan in United States v. Jones, 16 Cr. 533 (AJN) and in United States v. Pizarro, 17 Cr. 151 (AJN). Commented [CE10]: The defense objects to this language It creates an unbalanced charge in which language favorable to the defendant is stated only once. This language is also not found in Sand or in the Court's recent jury instructions on reasonable doubt See Sand, Instr 4-1; United States v. Berry, 20 CR 84 (AJN); United States v. Pizarro, 17 Cr 151 (AJN) Commented [RA11R10]: GOVERNMENT RESPONSE: The Court used a version of this language in United States v. Lebedev, 17 Cr 769 (AJN); United States v. Jones, 16 Cr 553 (AJN); and United States v. Le, 15 Cr 538 (AKN) The full instruction is also used in this district United States v. Purcell, 18 Cr 81 (DLC). And much of this language also appears in Sand See Sand, Instr 4.1 (\"A reasonable doubt is not caprice or whim. It is not speculation or suspicion. It is not an excuse to avoid the performance of an unpleasant duty \") This language is necessary to provide the jury with additional information about what counts as a reasonable doubt It does not create an unbalanced charge in light of the lengthy charge on the presumption of innocence that immediately precedes this charge, but the Government would not oppose including this language in the second paragraph of the charge to eliminate the defense's concern 13 DOJ-OGR-00006079",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 410-1 Filed 11/04/21 Page 13 of 93",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "all of the evidence, you are satisfied beyond a reasonable doubt of the defendant's guilt with respect to a particular charge against her, you should find the defendant guilty of that charge.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Adapted from the charge of the Hon. Alison J. Nathan in United States v. Jones, 16 Cr. 533 (AJN) and in United States v. Pizarro, 17 Cr. 151 (AJN).",
      "position": "middle"
    },
    {
      "type": "handwritten",
      "content": "Commented [CE10]: The defense objects to this language It creates an unbalanced charge in which language favorable to the defendant is stated only once. This language is also not found in Sand or in the Court's recent jury instructions on reasonable doubt See Sand, Instr 4-1; United States v. Berry, 20 CR 84 (AJN); United States v. Pizarro, 17 Cr 151 (AJN)",
      "position": "margin"
    },
    {
      "type": "handwritten",
      "content": "Commented [RA11R10]: GOVERNMENT RESPONSE: The Court used a version of this language in United States v. Lebedev, 17 Cr 769 (AJN); United States v. Jones, 16 Cr 553 (AJN); and United States v. Le, 15 Cr 538 (AKN) The full instruction is also used in this district United States v. Purcell, 18 Cr 81 (DLC). And much of this language also appears in Sand See Sand, Instr 4.1 (\"A reasonable doubt is not caprice or whim. It is not speculation or suspicion. It is not an excuse to avoid the performance of an unpleasant duty \") This language is necessary to provide the jury with additional information about what counts as a reasonable doubt It does not create an unbalanced charge in light of the lengthy charge on the presumption of innocence that immediately precedes this charge, but the Government would not oppose including this language in the second paragraph of the charge to eliminate the defense's concern",
      "position": "margin"
    },
    {
      "type": "printed",
      "content": "13",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006079",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan"
    ],
    "organizations": [
      "United States"
    ],
    "locations": [],
    "dates": [
      "11/04/21"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 410-1",
      "16 Cr. 533",
      "17 Cr. 151",
      "20 CR 84",
      "17 Cr 769",
      "16 Cr 553",
      "15 Cr 538",
      "18 Cr 81"
    ]
  },
  "additional_notes": "The document appears to be a court document with annotations and comments in the margins. The text is mostly printed, with some handwritten comments. The document is related to a court case, specifically United States v. Jones and United States v. Pizarro."
}