{
  "document_metadata": {
    "page_number": "10",
    "document_number": "11-1",
    "date": "07/12/19",
    "document_type": "court document",
    "has_handwriting": true,
    "has_stamps": false
  },
  "full_text": "Case 1:19-cr-00490-RMB Document 11-1 Filed 07/12/19 Page 10 of 10\n\nHonorable Henry Pitman\nUnited States Magistrate Judge\nJuly 8, 2019\nPage 10\n\nCONCLUSION\n\nAs set forth above, in this case, the risk of flight in this case is extraordinarily real. The defendant is extremely wealthy, has extensive foreign contacts, and is charged with serious offenses that carry a potential statutory sentence of up to 45 years' imprisonment—even a fraction of which could result in the defendant, who is 66 years old, spending the rest of his life in jail. In sum, the defendant's transient lifestyle, his lack of family or community ties, his extensive international travel and ties outside the country, and his vast wealth, including his access to and ownership of private planes, all provide the defendant with the motive and means to become a successful fugitive. Further, the nature of the offenses he is alleged to have perpetrated—the abuse of dozens of underage, vulnerable girls—along with his demonstrated willingness to harass, intimidate and otherwise tamper with victims and other potential witnesses against him, render his dangerousness readily apparent.\n\nAccordingly, the Government respectfully submits that the defendant cannot and will not be able to meet his burden of overcoming the strong presumption in favor of detention, that there are no conditions of bail that would assure the defendant's presence in court proceedings in this case or protect the safety of the community, and that any application for bail should be denied.\n\nVery truly yours,\n\nGEOFFREY S. BERMAN\nUnited States Attorney\nBy: _______________________\nAlex Rossmiller / Alison Moe / Maurene Comey\nAssistant United States Attorney\nSouthern District of New York\nTel: (212) 637-2415 / 2225 / 2324\n\nCc: Martin Weinberg, Esq., and Reid Weingarten, Esq., counsel for defendant\nHon. Richard M. Berman, United States District Judge",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:19-cr-00490-RMB Document 11-1 Filed 07/12/19 Page 10 of 10",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Honorable Henry Pitman\nUnited States Magistrate Judge\nJuly 8, 2019\nPage 10",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "CONCLUSION",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "As set forth above, in this case, the risk of flight in this case is extraordinarily real. The defendant is extremely wealthy, has extensive foreign contacts, and is charged with serious offenses that carry a potential statutory sentence of up to 45 years' imprisonment—even a fraction of which could result in the defendant, who is 66 years old, spending the rest of his life in jail. In sum, the defendant's transient lifestyle, his lack of family or community ties, his extensive international travel and ties outside the country, and his vast wealth, including his access to and ownership of private planes, all provide the defendant with the motive and means to become a successful fugitive. Further, the nature of the offenses he is alleged to have perpetrated—the abuse of dozens of underage, vulnerable girls—along with his demonstrated willingness to harass, intimidate and otherwise tamper with victims and other potential witnesses against him, render his dangerousness readily apparent.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Accordingly, the Government respectfully submits that the defendant cannot and will not be able to meet his burden of overcoming the strong presumption in favor of detention, that there are no conditions of bail that would assure the defendant's presence in court proceedings in this case or protect the safety of the community, and that any application for bail should be denied.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Very truly yours,",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "GEOFFREY S. BERMAN\nUnited States Attorney",
      "position": "middle"
    },
    {
      "type": "handwritten",
      "content": "_______________________",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Alex Rossmiller / Alison Moe / Maurene Comey\nAssistant United States Attorney\nSouthern District of New York\nTel: (212) 637-2415 / 2225 / 2324",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Cc: Martin Weinberg, Esq., and Reid Weingarten, Esq., counsel for defendant\nHon. Richard M. Berman, United States District Judge",
      "position": "bottom"
    }
  ],
  "entities": {
    "people": [
      "Henry Pitman",
      "Geoffrey S. Berman",
      "Alex Rossmiller",
      "Alison Moe",
      "Maurene Comey",
      "Martin Weinberg",
      "Reid Weingarten",
      "Richard M. Berman"
    ],
    "organizations": [
      "United States Magistrate Judge",
      "United States Attorney",
      "Southern District of New York"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "July 8, 2019",
      "07/12/19"
    ],
    "reference_numbers": [
      "1:19-cr-00490-RMB",
      "11-1"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is mostly printed, with a single handwritten signature line. There are no visible stamps or redactions."
}