{
  "document_metadata": {
    "page_number": "15",
    "document_number": "40-1",
    "date": "04/12/2021",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 21-770, Document 40-1, 04/12/2021, 3075763, Page15 of 25\n\nARGUMENT\n\nThe District Court Properly Denied Maxwell's Motions for Bail and Temporary Release\n\n27. Judge Nathan did not clearly err when she determined that Maxwell is a risk of flight and that no conditions would reasonably assure her appearance in court. Nor did Judge Nathan abuse her discretion or clearly err by denying Maxwell's request for temporary release.\n\nA. Applicable Law\n\n28. In seeking pretrial detention, the Government bears the burden of showing, by a preponderance of the evidence, that the defendant poses a risk of flight, and that no condition or combination of conditions would reasonably assure her presence in court. See 18 U.S.C. § 3142(f); United States v. Sabhnani, 493 F.3d 63, 75 (2d Cir. 2007).\n\n29. Where the defendant is charged with certain offenses, including offenses involving a minor victim under 18 U.S.C. §§ 2422 or 2423, a statutory presumption arises \"that no condition or combination of conditions will reasonably assure the appearance of the person as required . . .\" 18 U.S.C. § 3142(e)(3)(E). In such a case, the defendant \"bears a limited burden of production-not a burden of persuasion-to rebut that presumption by coming forward with evidence that he does not pose a ... risk of flight.\" United States v. Mercedes, 254 F.3d 433, 436 (2d Cir. 2002).\n\n15\n\nDOJ-OGR-00001332",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 21-770, Document 40-1, 04/12/2021, 3075763, Page15 of 25",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "ARGUMENT",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The District Court Properly Denied Maxwell's Motions for Bail and Temporary Release",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "27. Judge Nathan did not clearly err when she determined that Maxwell is a risk of flight and that no conditions would reasonably assure her appearance in court. Nor did Judge Nathan abuse her discretion or clearly err by denying Maxwell's request for temporary release.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "A. Applicable Law",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "28. In seeking pretrial detention, the Government bears the burden of showing, by a preponderance of the evidence, that the defendant poses a risk of flight, and that no condition or combination of conditions would reasonably assure her presence in court. See 18 U.S.C. § 3142(f); United States v. Sabhnani, 493 F.3d 63, 75 (2d Cir. 2007).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "29. Where the defendant is charged with certain offenses, including offenses involving a minor victim under 18 U.S.C. §§ 2422 or 2423, a statutory presumption arises \"that no condition or combination of conditions will reasonably assure the appearance of the person as required . . .\" 18 U.S.C. § 3142(e)(3)(E). In such a case, the defendant \"bears a limited burden of production-not a burden of persuasion-to rebut that presumption by coming forward with evidence that he does not pose a ... risk of flight.\" United States v. Mercedes, 254 F.3d 433, 436 (2d Cir. 2002).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "15",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001332",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Maxwell",
      "Judge Nathan"
    ],
    "organizations": [
      "Government",
      "District Court"
    ],
    "locations": [],
    "dates": [
      "04/12/2021"
    ],
    "reference_numbers": [
      "Case 21-770",
      "Document 40-1",
      "3075763",
      "18 U.S.C. § 3142(f)",
      "18 U.S.C. §§ 2422",
      "18 U.S.C. § 3142(e)(3)(E)",
      "493 F.3d 63",
      "254 F.3d 433",
      "DOJ-OGR-00001332"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Maxwell, discussing the denial of bail and temporary release. The text is well-formatted and printed, with no visible handwriting or stamps."
}