{
  "document_metadata": {
    "page_number": "18",
    "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 18 of 93 Count Two: Enticement to Engage in an Illegal Sexual Activity - The Statute The relevant statute for Count Two is Title 18, United States Code, Section 2422, which provides that \"[w]hoever knowingly persuades, induces, or entices-or coerces any individual to travel in interstate or foreign commerce, or in any Territory or Possession of the United States, to engage in . . . in any sexual activity for which any person can be charged with a criminal offense,\" is guilty of a federal crime. Commented [CE17]: The defense objects to beginning out of order with the substantive counts and grouping the conspiracy counts later The defense submits that the instructions for the counts should proceed in order, as they are charged in the Indictment, and each count should be separately addressed. Commented [RA(18R17]: GOVERNMENT RESPONSE: The Government submits that it will be clearer for the jury to avoid repetition to explain the substantive crimes, and then incorporate that explanation for the conspiracy offenses Commented [CE19]: The defense objects to the inclusion of the term \"coerces\" if the proof at trial does not include evidence of the use of force of other coercion Commented [RA(20R19]: GOVERNMENT RESPONSE: The term \"coerce\" carries its ordinary meaning. see United States v. Wagar, 997 F 3d 481, 485 (2d Cir 2021) (regarding § 2422(b)), and the ordinary meaning of \"coerce\" need not involve force. See \"Coerce,\" Merriam-Webster Dictionary (defining \"coerce\" as \"to compel to an act or choice\") The Government expects that its proof will include evidence of coercion, and in any event, this verb is in the statutory language DOJ-OGR-00006084",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 410-1 Filed 11/04/21 Page 18 of 93",
      "position": "header"
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    {
      "type": "printed",
      "content": "Count Two: Enticement to Engage in an Illegal Sexual Activity - The Statute",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The relevant statute for Count Two is Title 18, United States Code, Section 2422, which provides that \"[w]hoever knowingly persuades, induces, or entices-or coerces any individual to travel in interstate or foreign commerce, or in any Territory or Possession of the United States, to engage in . . . in any sexual activity for which any person can be charged with a criminal offense,\" is guilty of a federal crime.",
      "position": "middle"
    },
    {
      "type": "handwritten",
      "content": "Commented [CE17]: The defense objects to beginning out of order with the substantive counts and grouping the conspiracy counts later The defense submits that the instructions for the counts should proceed in order, as they are charged in the Indictment, and each count should be separately addressed.",
      "position": "margin"
    },
    {
      "type": "handwritten",
      "content": "Commented [RA(18R17]: GOVERNMENT RESPONSE: The Government submits that it will be clearer for the jury to avoid repetition to explain the substantive crimes, and then incorporate that explanation for the conspiracy offenses",
      "position": "margin"
    },
    {
      "type": "handwritten",
      "content": "Commented [CE19]: The defense objects to the inclusion of the term \"coerces\" if the proof at trial does not include evidence of the use of force of other coercion",
      "position": "margin"
    },
    {
      "type": "handwritten",
      "content": "Commented [RA(20R19]: GOVERNMENT RESPONSE: The term \"coerce\" carries its ordinary meaning. see United States v. Wagar, 997 F 3d 481, 485 (2d Cir 2021) (regarding § 2422(b)), and the ordinary meaning of \"coerce\" need not involve force. See \"Coerce,\" Merriam-Webster Dictionary (defining \"coerce\" as \"to compel to an act or choice\") The Government expects that its proof will include evidence of coercion, and in any event, this verb is in the statutory language",
      "position": "margin"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006084",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [],
    "organizations": [
      "Government",
      "Merriam-Webster Dictionary"
    ],
    "locations": [
      "United States"
    ],
    "dates": [
      "11/04/21",
      "2021"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "410-1",
      "18",
      "2422",
      "997 F 3d 481",
      "485",
      "2d Cir 2021",
      "DOJ-OGR-00006084"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case, with annotations and comments in the margins. The text is mostly printed, with some handwritten comments and annotations."
}