{
  "document_metadata": {
    "page_number": "12 of 14",
    "document_number": "388",
    "date": "10/29/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 388 Filed 10/29/21 Page 12 of 14\nand requested a ride away from the murder scene shortly after the crime took place did not support an inference of guilt).\nThe government therefore cannot establish, with any degree of confidence, sufficient facts to satisfy even the first of the Sadawi inferences. Al-Sadawi, 432 F.3d at 424 (probative value of flight evidence as proof of consciousness of guilt \"depends upon the degree of confidence with which four inferences can be drawn: (1) from the defendant's behavior to flight...\"). Allowing the government to present this evidence to the jury as evidence of \"flight\" would invite the jury to infer consciousness of guilt based on nothing more than unfounded speculation. That is patently improper and must be precluded. Id. (citing Sanchez, 790 F.2d at 252 (flight evidence \"must ... provide the jury with more than an opportunity for mere conjecture and speculation.\" (internal quotation marks and citation omitted))).\nFurthermore, admitting evidence of flight would be misleading to the jury and unfairly prejudicial to Ms. Maxwell. It would also require the defense to call witnesses to counter the government's evidence and lead to a distracting mini trial on the issue of flight. The prejudice, confusion, and delay caused by admitting this evidence would substantially outweigh any limited probative value it may have. It must therefore be excluded under Rule 403. See Fed. R. Evid. 403; see also Green, 2017 WL 4803957, at *4-*5 (precluding flight evidence pursuant to Al-Sadawi and Rule 403).\n9\nDOJ-OGR-00005699",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 388 Filed 10/29/21 Page 12 of 14",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "and requested a ride away from the murder scene shortly after the crime took place did not support an inference of guilt).\nThe government therefore cannot establish, with any degree of confidence, sufficient facts to satisfy even the first of the Sadawi inferences. Al-Sadawi, 432 F.3d at 424 (probative value of flight evidence as proof of consciousness of guilt \"depends upon the degree of confidence with which four inferences can be drawn: (1) from the defendant's behavior to flight...\"). Allowing the government to present this evidence to the jury as evidence of \"flight\" would invite the jury to infer consciousness of guilt based on nothing more than unfounded speculation. That is patently improper and must be precluded. Id. (citing Sanchez, 790 F.2d at 252 (flight evidence \"must ... provide the jury with more than an opportunity for mere conjecture and speculation.\" (internal quotation marks and citation omitted))).",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Furthermore, admitting evidence of flight would be misleading to the jury and unfairly prejudicial to Ms. Maxwell. It would also require the defense to call witnesses to counter the government's evidence and lead to a distracting mini trial on the issue of flight. The prejudice, confusion, and delay caused by admitting this evidence would substantially outweigh any limited probative value it may have. It must therefore be excluded under Rule 403. See Fed. R. Evid. 403; see also Green, 2017 WL 4803957, at *4-*5 (precluding flight evidence pursuant to Al-Sadawi and Rule 403).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "9",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005699",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Maxwell"
    ],
    "organizations": [
      "DOJ"
    ],
    "locations": [],
    "dates": [
      "10/29/21",
      "2017"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 388",
      "DOJ-OGR-00005699"
    ]
  },
  "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 likely a page from a larger filing, as indicated by the page number '12 of 14'."
}