mirror-epstein-docs/results/IMAGES003/DOJ-OGR-00006138.json

{
  "document_metadata": {
    "page_number": "72",
    "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 72 of 93\n\nVenue\n[If requested by defense]\nWith respect to each of the counts in the indictment, you must also consider the issue of venue, namely, whether any act in furtherance of the unlawful activity charged in that count occurred within the Southern District of New York. The Southern District of New York encompasses the following counties: New York County (i.e., Manhattan), Bronx, Westchester, Rockland, Putnam, Dutchess, Orange and Sullivan Counties. Anything that occurs in any of those places occurs in the Southern District of New York.\n\nVenue must be examined separately for each count in the Indictment. Venue on one count does not establish venue on another count, though if applicable, you may rely on the same evidence to establish venue on multiple counts.\n\nCommented [CE88]: This language is unnecessary and unfairly highlights the government's theory of the case. It is also not consistent with the Court's prior instructions on this issue. See United States v. Pizarro, 17 Cr 151 (AJN)\n\nDOJ-OGR-00006138",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 410-1 Filed 11/04/21 Page 72 of 93",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Venue\n[If requested by defense]",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "With respect to each of the counts in the indictment, you must also consider the issue of venue, namely, whether any act in furtherance of the unlawful activity charged in that count occurred within the Southern District of New York. The Southern District of New York encompasses the following counties: New York County (i.e., Manhattan), Bronx, Westchester, Rockland, Putnam, Dutchess, Orange and Sullivan Counties. Anything that occurs in any of those places occurs in the Southern District of New York.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Venue must be examined separately for each count in the Indictment. Venue on one count does not establish venue on another count, though if applicable, you may rely on the same evidence to establish venue on multiple counts.",
      "position": "middle"
    },
    {
      "type": "handwritten",
      "content": "[As to the conspiracy charges, the Government need not prove that any crime was completed in this District or that the defendant Ms. Maxwell or any of her co-conspirators were physically present here. Rather, venue is proper in this District if the defendant Ms. Maxwell or any of her co-conspirators caused any act or event to occur in this District in furtherance of the offense, and it was reasonably foreseeable to the defendant Ms. Maxwell that the act would take place in the Southern District of New York.\n\nAs to the substantive counts, that is, the non-conspiracy counts, the Government again need not prove that any crime was completed in this District or that the defendant Ms. Maxwell was physically present here. Rather, venue is proper in this District provided that any act in furtherance of the essential conduct of the crime took place in the Southern District of New York. Again, Ms. Maxwell, the defendant need not have specifically intended to cause an act or event to happen in this District, or even known that he was causing an act or event to happen here, as long as it was reasonably foreseeable to Ms. Maxwell, the defendant that such act would]",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Commented [CE88]: This language is unnecessary and unfairly highlights the government's theory of the case. It is also not consistent with the Court's prior instructions on this issue. See United States v. Pizarro, 17 Cr 151 (AJN)",
      "position": "margin"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006138",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell"
    ],
    "organizations": [
      "Government",
      "Court"
    ],
    "locations": [
      "Southern District of New York",
      "New York County",
      "Manhattan",
      "Bronx",
      "Westchester",
      "Rockland",
      "Putnam",
      "Dutchess",
      "Orange",
      "Sullivan Counties"
    ],
    "dates": [
      "11/04/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "410-1",
      "17 Cr 151 (AJN)",
      "DOJ-OGR-00006138"
    ]
  },
  "additional_notes": "The document appears to be a court filing with tracked changes and comments. The text has been redacted in some areas, and there are handwritten notes and comments in the margins."
}