{
  "document_metadata": {
    "page_number": "63 of 74",
    "document_number": "36",
    "date": "07/24/19",
    "document_type": "court document",
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  "full_text": "Case 1:19-cr-00490-RMB Document 36 Filed 07/24/19 Page 63 of 74 63\n1 districts were aware of it, which there is no evidence that\n2 they were. The approval of jurisdiction to contemplate federal\n3 charges and a federal NPA, as the defendant tried to wiggle out\n4 of this agreement after it had been signed, is different from\n5 having the NPA apply outside of the Southern District of\n6 Florida which it does not.\n7\n8 What they're describing is a normal appeal process,\n9 and there is an entirely separate process for getting coverage\n10 outside of the relevant district, and what they're describing\nain't it. It didn't happen here.\n11 Your Honor, the defense has kept coming back to this\n12 idea of 1591 being enslavement, of pimping people out, of\n13 people servicing individuals 15 to 20 times a day as they\n14 mentioned in one of its submissions. Quintessential sex\n15 trafficking is sex trafficking that is met by the elements of\n16 the crime which we have here.\n17\n18 The defense said we don't have consent here or putting\n19 the issue of consent aside. Your Honor, it's underage girls.\n20 It's underage girls that are involved in this case, and it's\n21 underage girls who are the victims. To say that consent is\n22 some sort of a separate issue that we should ignore is\n23 offensive, frankly, and it's not supported by the law.\n24\n25 Moving along, with respect to compliance following a\nprior conviction rebutting the presumption, it's easy to figure\nout why that's not the case, your Honor. I'll explain why.\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00000573",
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      "type": "printed",
      "content": "Case 1:19-cr-00490-RMB Document 36 Filed 07/24/19 Page 63 of 74 63",
      "position": "header"
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    {
      "type": "printed",
      "content": "1 districts were aware of it, which there is no evidence that\n2 they were. The approval of jurisdiction to contemplate federal\n3 charges and a federal NPA, as the defendant tried to wiggle out\n4 of this agreement after it had been signed, is different from\n5 having the NPA apply outside of the Southern District of\n6 Florida which it does not.\n7\n8 What they're describing is a normal appeal process,\n9 and there is an entirely separate process for getting coverage\n10 outside of the relevant district, and what they're describing\nain't it. It didn't happen here.\n11 Your Honor, the defense has kept coming back to this\n12 idea of 1591 being enslavement, of pimping people out, of\n13 people servicing individuals 15 to 20 times a day as they\n14 mentioned in one of its submissions. Quintessential sex\n15 trafficking is sex trafficking that is met by the elements of\n16 the crime which we have here.\n17\n18 The defense said we don't have consent here or putting\n19 the issue of consent aside. Your Honor, it's underage girls.\n20 It's underage girls that are involved in this case, and it's\n21 underage girls who are the victims. To say that consent is\n22 some sort of a separate issue that we should ignore is\n23 offensive, frankly, and it's not supported by the law.\n24\n25 Moving along, with respect to compliance following a\nprior conviction rebutting the presumption, it's easy to figure\nout why that's not the case, your Honor. I'll explain why.",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00000573",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [
      "Southern District of Florida"
    ],
    "dates": [
      "07/24/19"
    ],
    "reference_numbers": [
      "1:19-cr-00490-RMB",
      "Document 36",
      "DOJ-OGR-00000573"
    ]
  },
  "additional_notes": "The document appears to be a court transcript or legal document. The text is typed and there are no visible handwritten notes or stamps. The content discusses legal arguments and references specific laws and court procedures."
}