mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00006114.json

{
  "document_metadata": {
    "page_number": "48",
    "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 48 of 93\n\ncircumstantial evidence. The old adage, \"Actions speak louder than words,\" applies here. Often the only evidence that is available with respect to the existence of a conspiracy is that of disconnected acts and conduct on the part of the alleged individual co-conspirators. When taken altogether and considered as whole, however, these acts and conduct may warrant the inference that a conspiracy existed as conclusively as would direct proof, such as evidence of an express agreement. On this question, you should refer back to my earlier instructions on direct and circumstantial evidence and inferences.\n\n[So, in considering the first element of the crime of conspiracy as charged in Counts One, Three, and Five - whether the conspiracy actually existed - you should consider all the evidence that has been admitted with respect to the acts, conduct, and statements of each alleged coconspirator, and any inferences that may be reasonably drawn from them. It is sufficient to establish the existence of the conspiracy, as I've already said, if, from the proof of all the relevant facts and circumstances, you find beyond a reasonable doubt that the minds of at least two alleged co-conspirators met in an understanding to accomplish, by the means alleged, the object of the conspiracy.]\n\nIn short, as far as the first element of the conspiracy is concerned, the Government must prove beyond a reasonable doubt that at least two alleged conspirators came to a mutual understanding, either spoken or unspoken, to violate the law in the manner charged in Counts One, Three, and Five of the Indictment.\n\n[Liability for Acts and Declarations of Co-Conspirators\nYou will recall that I have admitted into evidence against the defendant the acts and statements of others because these acts and statements were committed or made by persons who the Government charges were also confederates or co-conspirators of the defendant-]\n\nCommented [CE65]: This language seems redundant\nCommented [RA(66R65]: GOVERNMENT RESPONSE: This language was used in United States v. Almonte, 16 Cr 670 (KMW) It is a summary of the preceding three paragraphs, each of which is describes a different aspect of the law of conspiracy\n\nDOJ-OGR-00006114",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 410-1 Filed 11/04/21 Page 48 of 93",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "circumstantial evidence. The old adage, \"Actions speak louder than words,\" applies here. Often the only evidence that is available with respect to the existence of a conspiracy is that of disconnected acts and conduct on the part of the alleged individual co-conspirators. When taken altogether and considered as whole, however, these acts and conduct may warrant the inference that a conspiracy existed as conclusively as would direct proof, such as evidence of an express agreement. On this question, you should refer back to my earlier instructions on direct and circumstantial evidence and inferences.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "[So, in considering the first element of the crime of conspiracy as charged in Counts One, Three, and Five - whether the conspiracy actually existed - you should consider all the evidence that has been admitted with respect to the acts, conduct, and statements of each alleged coconspirator, and any inferences that may be reasonably drawn from them. It is sufficient to establish the existence of the conspiracy, as I've already said, if, from the proof of all the relevant facts and circumstances, you find beyond a reasonable doubt that the minds of at least two alleged co-conspirators met in an understanding to accomplish, by the means alleged, the object of the conspiracy.]",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "In short, as far as the first element of the conspiracy is concerned, the Government must prove beyond a reasonable doubt that at least two alleged conspirators came to a mutual understanding, either spoken or unspoken, to violate the law in the manner charged in Counts One, Three, and Five of the Indictment.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "[Liability for Acts and Declarations of Co-Conspirators You will recall that I have admitted into evidence against the defendant the acts and statements of others because these acts and statements were committed or made by persons who the Government charges were also confederates or co-conspirators of the defendant-]",
      "position": "middle"
    },
    {
      "type": "handwritten",
      "content": "Commented [CE65]: This language seems redundant Commented [RA(66R65]: GOVERNMENT RESPONSE: This language was used in United States v. Almonte, 16 Cr 670 (KMW) It is a summary of the preceding three paragraphs, each of which is describes a different aspect of the law of conspiracy",
      "position": "margin"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006114",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [],
    "organizations": [
      "Government"
    ],
    "locations": [],
    "dates": [
      "11/04/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "410-1",
      "16 Cr 670",
      "DOJ-OGR-00006114"
    ]
  },
  "additional_notes": "The document appears to be a court filing with annotations and comments in the margins. The text is mostly printed, with some handwritten comments. The document is related to a conspiracy case and discusses the elements of conspiracy and the liability for acts and declarations of co-conspirators."
}