{
  "document_metadata": {
    "page_number": "12",
    "document_number": "100",
    "date": "12/18/20",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 100 Filed 12/18/20 Page 12 of 36\ndendant faces up to 35 years of incarceration, and may very well spend the remainder of her natural life in prison. The seriousness of the offenses make such a steep penalty a real possibility upon conviction, thereby giving the defendant an overwhelming incentive to flee if given the chance.\n\nIn light of that strong incentive to flee, all three of the victims listed in the Indictment have asked the Government to convey to the Court that they continue to seek the defendant's detention. Additionally, pursuant to the Crime Victims' Rights Act, one of the victims has provided a written statement urging the Court to deny bail, which is attached as Exhibit A hereto. That unanimous view of the victims reflects three related reasons that this factor weighs so heavily in favor of detention. First, the victims sincerely fear that if the defendant is released, she will be able to evade justice. Second, the pain that the victims still feel to this day as a result of the defendant's conduct supports the conclusion that this offense is especially serious and may result in a lengthy sentence. Third, as discussed further below, the victims' attention to this case and willingness to convey their views reflects their commitment to take the stand and testify at the defendant's trial, demonstrating the strength of the Government's case.\n\nIn short, this factor offers no reason to reverse the prior detention order.\n\nB. The Strength of the Evidence\n\nFurther incentivizing the defendant to flee, the Government's evidence remains strong. As the Court recognized when analyzing this factor at the July 14, 2020 hearing, the central evidence in the Government's case will come from the detailed testimony of three different victims, who will each independently describe how the defendant groomed and enticed them to engage in sexual activity with Jeffrey Epstein. (Tr. 82). The Indictment itself contains a description of the accounts these victims have provided law enforcement, which corroborate each other in meaningful part.\n9\nDOJ-OGR-00002173",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 100 Filed 12/18/20 Page 12 of 36",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "defendant faces up to 35 years of incarceration, and may very well spend the remainder of her natural life in prison. The seriousness of the offenses make such a steep penalty a real possibility upon conviction, thereby giving the defendant an overwhelming incentive to flee if given the chance.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "In light of that strong incentive to flee, all three of the victims listed in the Indictment have asked the Government to convey to the Court that they continue to seek the defendant's detention. Additionally, pursuant to the Crime Victims' Rights Act, one of the victims has provided a written statement urging the Court to deny bail, which is attached as Exhibit A hereto. That unanimous view of the victims reflects three related reasons that this factor weighs so heavily in favor of detention. First, the victims sincerely fear that if the defendant is released, she will be able to evade justice. Second, the pain that the victims still feel to this day as a result of the defendant's conduct supports the conclusion that this offense is especially serious and may result in a lengthy sentence. Third, as discussed further below, the victims' attention to this case and willingness to convey their views reflects their commitment to take the stand and testify at the defendant's trial, demonstrating the strength of the Government's case.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "In short, this factor offers no reason to reverse the prior detention order.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "B. The Strength of the Evidence",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Further incentivizing the defendant to flee, the Government's evidence remains strong. As the Court recognized when analyzing this factor at the July 14, 2020 hearing, the central evidence in the Government's case will come from the detailed testimony of three different victims, who will each independently describe how the defendant groomed and enticed them to engage in sexual activity with Jeffrey Epstein. (Tr. 82). The Indictment itself contains a description of the accounts these victims have provided law enforcement, which corroborate each other in meaningful part.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "9",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002173",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jeffrey Epstein"
    ],
    "organizations": [
      "Government",
      "Court"
    ],
    "locations": [],
    "dates": [
      "12/18/20",
      "July 14, 2020"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 100",
      "Tr. 82",
      "DOJ-OGR-00002173"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is printed and there are no visible stamps or handwritten notes. The document is page 12 of 36."
}