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622 KB

Extraction Summary

2
People
2
Organizations
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Locations
2
Events
1
Relationships
2
Quotes

Document Information

Type: Legal document
File Size: 622 KB
Summary

This document is page 6 of a court filing from the case against Ghislaine Maxwell, dated October 22, 2021. It appears to be a proposed jury questionnaire, outlining the charges in Counts Five and Six related to sex trafficking of minors with Jeffrey Epstein between 2001 and 2004. The document also includes questions for potential jurors regarding legal principles like the presumption of innocence and reasonable doubt, alongside objections from both the defense and the government concerning the wording and content of these sections.

People (2)

Name Role Context
Ghislaine Maxwell Defendant
Mentioned as the defendant in the case, charged with conspiring with Jeffrey Epstein for sex trafficking of minors (C...
Jeffrey Epstein Co-conspirator
Mentioned as a co-conspirator with Ghislaine Maxwell in Count Five, which charges them with engaging in sex trafficki...

Organizations (2)

Name Type Context
The Court Judicial body
Mentioned as the entity that will instruct the jury on legal principles and is being asked to consider objections fro...
The Government Government agency
The prosecuting party in the case against Ghislaine Maxwell. Their proposed language and objections are noted in the ...

Timeline (2 events)

2001-2004
Count Five charges that Ghislaine Maxwell conspired with Jeffrey Epstein and others to engage in sex trafficking of minors.
2001-2004
Count Six charges that Ghislaine Maxwell engaged in sex trafficking of minors, and aided and abetted the same.

Relationships (1)

Ghislaine Maxwell Co-conspirators Jeffrey Epstein
The document states in Count Five that Ghislaine Maxwell 'conspired with Jeffrey Epstein and others to engage in sex trafficking of minors.'

Key Quotes (2)

"Do you agree that the worst thing that can happen under our American system of criminal justice is for an innocent person to be convicted of a crime she did not commit?"
Source
— Proposed jury question (A question posed to potential jurors to gauge their views on the principles of the justice system.)
DOJ-OGR-00005363.jpg
Quote #1
"Ms. Maxwell’s presumption of innocence never goes away unless and until the government proves each and every element of the charges beyond a reasonable doubt."
Source
— Proposed jury instruction/question (A statement of legal principle presented to potential jurors for their consideration.)
DOJ-OGR-00005363.jpg
Quote #2

Full Extracted Text

Complete text extracted from the document (2,993 characters)

Case 1:20-cr-00330-PAE Document 367-1 Filed 10/22/21 Page 6 of 17
* Count Five charges that, from at least in or about 2001, up to and including in or about 2004, Ghislaine Maxwell conspired with Jeffrey Epstein and others to engage in sex trafficking of minors.
* Count Six charges that, from at least in or about 2001, up to and including in or about 2004, Ghislaine Maxwell engaged in sex trafficking of minors, and aided and abetted the same.
11. Does any juror have any personal knowledge of the charges in the Indictment, as I have described them beyond what you have already noted in your questionnaire?
LEGAL PRINCIPLES
12. The Court will instruct the jury that every person accused of a crime is presumed to be innocent; an indictment, which is only an accusation, is not proof of anything; and a defendant cannot be found guilty unless the jury, having heard all the evidence in the case, unanimously decides that the evidence proves his guilt beyond a reasonable doubt. Will you accept and apply this rule of law?
a. Is there anyone on this panel who thinks that because Ms. Maxwell is charged with a crime, she is probably guilty of something?
b. Do you agree that the worst thing that can happen under our American system of criminal justice is for an innocent person to be convicted of a crime she did not commit?
13. Ms. Maxwell’s presumption of innocence never goes away unless and until the government proves each and every element of the charges beyond a reasonable doubt. This principle applies to each of the charges in this case, just as in any criminal case. Do you have any opinions about the reasonable doubt standard in criminal cases?
14. Does each member of the jury understand that the reasonable doubt standard of proof is the highest standard of evidence provided for under our laws?
Commented [A5]: The Government’s proposed language of the charges is reflected in purple colored font. The defendant’s proposed language is reflected in green color font.
Commented [A6R5]: DEFENDANT OBJECTION: The Defendant objects to the full-scale recapitulation of the charges in this case. There is little distinction between each Count and summarizing each of the six counts places an unfair emphasis on the fact that the Government has chosen to charge largely the same conduct in six different ways. If the Court is inclined to summarize each of the six counts, the defense requests that each be followed with a statement that Ms. Maxwell has denied the charge and is presumed innocent of it.
Commented [A7]: GOVERNMENT OBJECTION: The Government objects to the questions in the “Legal Principles” section proposed by the defendant on the grounds that the questions are overly broad, argumentative, vague, confusing, and redundant.
Commented [A8R7]: DEFENDANT RESPONSE: The defense incorporates by reference their response to the Government objections to the Introduction and her Objection to the Charges section included by the Government.
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DOJ-OGR-00005363

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