{
  "document_metadata": {
    "page_number": "47",
    "document_number": "93",
    "date": "12/10/20",
    "document_type": "court document",
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    "has_stamps": false
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  "full_text": "Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 47 of 91 47\nk7e2MaxC kjc\n1 law of the statute, by its structure, favors release. The\n2 Supreme Court has and the Second Circuit has advised us that a\n3 very limited number of people should be detained prior to trial\n4 because of the statute's structure, and the government nowhere\n5 mentions that. It basically acts as if all it has to do is\n6 invoke the presumption on the client and then we are done, and\n7 that's just not the legal standing, your Honor.\n8 They also say nothing about the burden, which is\n9 discussed on a case written for the Second Circuit by Judge\n10 Raggi, and also the U.S. v. English case. Without going into a\n11 lot of detail, as the court is aware, the burden of persuasion\n12 is the government's. It never shifts. The presumption can be\n13 rebutted, and we submit it is here, and then it is the burden\n14 of the government to show that the defendant is a risk of\n15 flight and that there are no conditions or combination of\n16 conditions to secure the release, which we submit they haven't\n17 done here.\n18 So let me turn, your Honor, if I may, to the factors\n19 under 3142(g), and before I do that, I also want to address\n20 some of the government's comments about the bail package. We\n21 decided that we should come before your Honor with a package\n22 that was set out subject, of course, to the ruling provided by\n23 the court, subject of course to verification as to suretors by\n24 Pretrial Services and the court. We didn't want to just walk\n25 in and say, Judge, we should be entitled to bail, please set\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00001924",
  "text_blocks": [
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      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 47 of 91 47",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "k7e2MaxC kjc",
      "position": "margin"
    },
    {
      "type": "printed",
      "content": "1 law of the statute, by its structure, favors release. The\n2 Supreme Court has and the Second Circuit has advised us that a\n3 very limited number of people should be detained prior to trial\n4 because of the statute's structure, and the government nowhere\n5 mentions that. It basically acts as if all it has to do is\n6 invoke the presumption on the client and then we are done, and\n7 that's just not the legal standing, your Honor.\n8 They also say nothing about the burden, which is\n9 discussed on a case written for the Second Circuit by Judge\n10 Raggi, and also the U.S. v. English case. Without going into a\n11 lot of detail, as the court is aware, the burden of persuasion\n12 is the government's. It never shifts. The presumption can be\n13 rebutted, and we submit it is here, and then it is the burden\n14 of the government to show that the defendant is a risk of\n15 flight and that there are no conditions or combination of\n16 conditions to secure the release, which we submit they haven't\n17 done here.\n18 So let me turn, your Honor, if I may, to the factors\n19 under 3142(g), and before I do that, I also want to address\n20 some of the government's comments about the bail package. We\n21 decided that we should come before your Honor with a package\n22 that was set out subject, of course, to the ruling provided by\n23 the court, subject of course to verification as to suretors by\n24 Pretrial Services and the court. We didn't want to just walk\n25 in and say, Judge, we should be entitled to bail, please set",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001924",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Raggi"
    ],
    "organizations": [
      "Supreme Court",
      "Second Circuit",
      "Pretrial Services",
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "12/10/20"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "93",
      "DOJ-OGR-00001924"
    ]
  },
  "additional_notes": "The document appears to be a court transcript or legal document. The text is mostly printed, with no visible handwriting or stamps. The content is a legal argument or discussion, referencing specific cases and statutes."
}