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Case 1:20-cr-00330-PAE Document 367-1 Filed 10/22/21 Page 6of17 e 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. e 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? Commented [A5]: The Government’s proposed language of the charges is reflected in purple colored font. The ILE GAL PRINCIPLES) aa s proposed language is reflected in green color rae , es Commented [A6R5]: DEFENDANT OBJECTION: The 12. The Court will instruct the jury that every person accused of a crime is presumed Defendant objects 00 tie full-scale cecasimilsnion of the charges in this case. There is little distinction between each to be innocent; an indictment, which is only an accusation, is not proof of anything; and a defendant 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 cannot be found guilty unless the jury, having heard all the evidence in the case, unanimously 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. decides that the evidence proves his guilt beyond a reasonable doubt. Will you accept and apply Commented [A7]: GOVERNMENT OBJECTION: The Government objects to the questions in the “Legal Principles” section proposed by the defendant on the grounds a. Is there anyone on this panel who thinks that because Ms. Maxwell is charged with that the questions are overly broad, argumentative, vague, confusing, and redundant. a crime, she is probably guilty of something? Commented [A8R7]: DEFENDANT RESPONSE: The defense incorporates by reference their response to the : F Government objections to the Introduction and her Objection b. Do you agree that the worst thing that can happen under our American system of to the Charges section included by the Government. this rule of law? 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? DOJ-OGR-00005363