mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00006125.json

{
  "document_metadata": {
    "page_number": "59 of 93",
    "document_number": "410-1",
    "date": "11/04/21",
    "document_type": "court document",
    "has_handwriting": true,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 410-1 Filed 11/04/21 Page 59 of 93\nCounts One, Three, and Five Two: Conspiracy to Violate Federal Law - Fourth Element\nThe fourth, and final, element which the Government must prove beyond a reasonable doubt is that the overt act was committed for the purpose of carrying out the unlawful agreement.\nIn order for the Government to satisfy this element, it must prove, beyond a reasonable doubt, that at least one overt act was knowingly and willfully done, by at least one conspirator, in furtherance of some object or purpose of the conspiracy, as charged in the Indictment. In this regard, you should bear in mind that the overt act, standing alone, may be an innocent, lawful act. Frequently, 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.\nCommented [CE82]: The fourth element is consistent with Sand and the Court's recent instructions on this issue. See Sand, Instr 19-8; United States v. Pizcarro, 17 Cr 151 (AJN)\nCommented [RA(83R82]: GOVERNMENT RESPONSE:\nThe Court has also combined this element with the third element. See United States v. Lebedev, 15 Cr 769 (AJN)\nThe Government defers to the Court's preference\nDOJ-OGR-00006125",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 410-1 Filed 11/04/21 Page 59 of 93",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Counts One, Three, and Five Two: Conspiracy to Violate Federal Law - Fourth Element",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The fourth, and final, element which the Government must prove beyond a reasonable doubt is that the overt act was committed for the purpose of carrying out the unlawful agreement.\nIn order for the Government to satisfy this element, it must prove, beyond a reasonable doubt, that at least one overt act was knowingly and willfully done, by at least one conspirator, in furtherance of some object or purpose of the conspiracy, as charged in the Indictment. In this regard, you should bear in mind that the overt act, standing alone, may be an innocent, lawful act. Frequently, 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.",
      "position": "middle"
    },
    {
      "type": "handwritten",
      "content": "Commented [CE82]: The fourth element is consistent with Sand and the Court's recent instructions on this issue. See Sand, Instr 19-8; United States v. Pizcarro, 17 Cr 151 (AJN)\nCommented [RA(83R82]: GOVERNMENT RESPONSE:\nThe Court has also combined this element with the third element. See United States v. Lebedev, 15 Cr 769 (AJN)\nThe Government defers to the Court's preference",
      "position": "margin"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006125",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [],
    "organizations": [
      "Government",
      "Court"
    ],
    "locations": [],
    "dates": [
      "11/04/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "410-1",
      "17 Cr 151",
      "15 Cr 769",
      "DOJ-OGR-00006125"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a conspiracy case. The text includes legal language and references to specific court cases and instructions. There are handwritten comments in the margin."
}