{
  "document_metadata": {
    "page_number": "13",
    "document_number": "18",
    "date": "07/10/20",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 13 of 26\ndocuments and other evidence from approximately twenty-five years ago and meaningfully assist in the preparation of her defense. These restrictions are additional \"compelling reasons\" justifying her release. See id.8\nII. The Government Has Not Carried Its Burden Under 18 U.S.C. § 3142.\nThe grave concerns raised by the current COVID-19 crisis notwithstanding, Ms. Maxwell must be released because she has met her limited burden of production showing that she does not pose a flight risk, and the government has entirely failed to demonstrate that no release condition or combination of conditions exist that will reasonably assure Ms. Maxwell's presence in court.\nA. Applicable Law\nAs the Supreme Court has recognized, \"[i]n our society liberty is the norm, and detention prior to trial or without trial is the carefully limited exception.\" United States v. Salerno, 481 U.S. 739, 755 (1987). Pretrial detention is appropriate only where \"no condition or combination of conditions will reasonably assure the appearance of the [defendant].\" United States v. Sabhnani, 493 F.3d 63, 75 (2d Cir. 2007) (quoting 18 U.S.C. § 3142(e)). The Bail Reform Act provides that a court \"shall order the pretrial release\" of the defendant (18 U.S.C. § 3142(b)) (emphasis added), but may impose bail conditions if \"such release will not reasonably assure the appearance\" of the defendant in court. 18 U.S.C. § 3142(c). Where conditions are necessary, such release shall be \"subject to the least restrictive . . . set of conditions that [the court] determines will reasonably assure the appearance of the person as required.\" 18 U.S.C. § 3142(c)(1)(B) (emphasis added). Consequently, \"[u]nder this statutory scheme, 'it is only a limited group of offenders who should be denied bail pending trial.'\" Sabhnani, 493 F.3d at 75 (citation and internal quotation marks omitted).\n8 See also Letter of Sean Hecker to Hon. Margo K. Brodie (July 8, 2020), Federal Defenders of New York, Inc. v. Federal Bureau of Prisons, et al., No. 19 Civ. 660 (E.D.N.Y.) (Doc. No. 78) (detailing absence of in-person visitation, highly limited VTC and telephone call capacity, and issues pertaining to legal mail and legal documents).",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 13 of 26",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "documents and other evidence from approximately twenty-five years ago and meaningfully assist in the preparation of her defense. These restrictions are additional \"compelling reasons\" justifying her release. See id.8",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "II. The Government Has Not Carried Its Burden Under 18 U.S.C. § 3142.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The grave concerns raised by the current COVID-19 crisis notwithstanding, Ms. Maxwell must be released because she has met her limited burden of production showing that she does not pose a flight risk, and the government has entirely failed to demonstrate that no release condition or combination of conditions exist that will reasonably assure Ms. Maxwell's presence in court.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "A. Applicable Law",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "As the Supreme Court has recognized, \"[i]n our society liberty is the norm, and detention prior to trial or without trial is the carefully limited exception.\" United States v. Salerno, 481 U.S. 739, 755 (1987). Pretrial detention is appropriate only where \"no condition or combination of conditions will reasonably assure the appearance of the [defendant].\" United States v. Sabhnani, 493 F.3d 63, 75 (2d Cir. 2007) (quoting 18 U.S.C. § 3142(e)). The Bail Reform Act provides that a court \"shall order the pretrial release\" of the defendant (18 U.S.C. § 3142(b)) (emphasis added), but may impose bail conditions if \"such release will not reasonably assure the appearance\" of the defendant in court. 18 U.S.C. § 3142(c). Where conditions are necessary, such release shall be \"subject to the least restrictive . . . set of conditions that [the court] determines will reasonably assure the appearance of the person as required.\" 18 U.S.C. § 3142(c)(1)(B) (emphasis added). Consequently, \"[u]nder this statutory scheme, 'it is only a limited group of offenders who should be denied bail pending trial.'\" Sabhnani, 493 F.3d at 75 (citation and internal quotation marks omitted).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "8 See also Letter of Sean Hecker to Hon. Margo K. Brodie (July 8, 2020), Federal Defenders of New York, Inc. v. Federal Bureau of Prisons, et al., No. 19 Civ. 660 (E.D.N.Y.) (Doc. No. 78) (detailing absence of in-person visitation, highly limited VTC and telephone call capacity, and issues pertaining to legal mail and legal documents).",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "9",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001593",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell",
      "Sean Hecker",
      "Margo K. Brodie"
    ],
    "organizations": [
      "Federal Defenders of New York, Inc.",
      "Federal Bureau of Prisons",
      "Supreme Court"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "07/10/20",
      "July 8, 2020"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 18",
      "No. 19 Civ. 660 (E.D.N.Y.)",
      "Doc. No. 78",
      "18 U.S.C. § 3142",
      "481 U.S. 739",
      "493 F.3d 63"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell, discussing the government's burden under 18 U.S.C. § 3142 and the applicable law regarding pretrial detention. The text is printed and there are no visible stamps or handwritten notes."
}