{
  "document_metadata": {
    "page_number": "32",
    "document_number": "32",
    "date": "07/18/19",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 32 of 33\nDefendant and their purported role as independent monitors. (The same problem arises in relation to private 24/7 security guards.) This is especially problematic where, as here, it is alleged that employees of the Defendant may have engaged in unlawful acts with and on behalf of the Defendant. According to the Government, “the defendant worked with others, including employees and associates who facilitated his exploitation of minors, by among other things, contacting victims and scheduling their sexual encounters with the defendant, both in New York and in Florida.” Dkt. 11, Ex. 1 at 2.\n(6) “As a fallback,” the Defense suggests the utilization of and the funding of a private security guard agency to “virtually guarantee” Mr. Epstein’s presence in court and, presumably, also to supervise his behavior. This contingency plan is not a part of Mr. Epstein’s 14 point proposal. Nevertheless, the Court is asked by the defense to “revisit” its legal viewpoint as expressed in an earlier decision concerning 24/7 private home security guards.\nEach bail package in each case is considered and evaluated on its individual merits by the Court. And, in view of the Court’s finding of dangerousness, a new bail proposal likely would be futile. See, e.g., United Ferranti, 66 F.3d at 544 (“No conceivable conditions could ensure the safety of the community.”); Orena, 986 F.2d at 632 (“We do not agree that the bail conditions set by the district court eliminate the danger to the community or are superior to detention for purposes of the Bail Reform Act.”); United States v. Colombo, 777 F.2d 96, 100 (2d Cir. 1985) (“These conditions are clearly inadequate to protect the public from one found for bail purposes to be a danger to the community.”).\n32\nDOJ-OGR-00000503",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 32 of 33",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Defendant and their purported role as independent monitors. (The same problem arises in relation to private 24/7 security guards.) This is especially problematic where, as here, it is alleged that employees of the Defendant may have engaged in unlawful acts with and on behalf of the Defendant. According to the Government, “the defendant worked with others, including employees and associates who facilitated his exploitation of minors, by among other things, contacting victims and scheduling their sexual encounters with the defendant, both in New York and in Florida.” Dkt. 11, Ex. 1 at 2.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "(6) “As a fallback,” the Defense suggests the utilization of and the funding of a private security guard agency to “virtually guarantee” Mr. Epstein’s presence in court and, presumably, also to supervise his behavior. This contingency plan is not a part of Mr. Epstein’s 14 point proposal. Nevertheless, the Court is asked by the defense to “revisit” its legal viewpoint as expressed in an earlier decision concerning 24/7 private home security guards.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Each bail package in each case is considered and evaluated on its individual merits by the Court. And, in view of the Court’s finding of dangerousness, a new bail proposal likely would be futile. See, e.g., United Ferranti, 66 F.3d at 544 (“No conceivable conditions could ensure the safety of the community.”); Orena, 986 F.2d at 632 (“We do not agree that the bail conditions set by the district court eliminate the danger to the community or are superior to detention for purposes of the Bail Reform Act.”); United States v. Colombo, 777 F.2d 96, 100 (2d Cir. 1985) (“These conditions are clearly inadequate to protect the public from one found for bail purposes to be a danger to the community.”).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "32",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00000503",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Epstein"
    ],
    "organizations": [],
    "locations": [
      "New York",
      "Florida"
    ],
    "dates": [
      "07/18/19"
    ],
    "reference_numbers": [
      "1:19-cr-00490-RMB",
      "Document 32",
      "Dkt. 11",
      "Ex. 1",
      "66 F.3d",
      "986 F.2d",
      "777 F.2d 96",
      "DOJ-OGR-00000503"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Jeffrey Epstein. The text discusses the defendant's bail proposal and the court's concerns regarding the defendant's potential danger to the community. The document includes citations to various court cases and legal references."
}