{
  "document_metadata": {
    "page_number": "11",
    "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 11 of 14\n157). By contrast, the Second Circuit found that the government's evidence in Al-Sadawi was \"too attenuated\" to establish that the defendant intended to flee to avoid prosecution or apprehension and the government should not have been permitted to argue consciousness of guilt on the basis of that evidence. Id.\nHere, the purported \"flight\" evidence is even more attenuated than in Al-Sadawi. Like Al-Sadawi, Ms. Maxwell knew she was a subject of the government's investigation after the arrest of Jeffery Epstein and could have left the country at any point in the one-year period leading up to her arrest (nine-and-a-half months longer than Al-Sadawi). But she did not.\nUnlike Al-Sadawi, there is no evidence whatsoever that Ms. Maxwell was preparing to flee. Neither Ms. Maxwell nor her spouse had purchased a plane ticket, nor was Ms. Maxwell planning to move locations. On the contrary, Ms. Maxwell had been living in the same residence in New Hampshire for seven months - a location she chose because it was close to her family and close to the prosecutors in New York in case she needed to meet with them. Moreover, when Ms. Maxwell was arrested, the arresting agents found nothing suggesting that she planned to abscond. Finally, unlike Al-Sadawi, Ms. Maxwell proffered independent evidence supporting an alternative explanation for her actions that rebuts any inference that she intended to flee.\nHence, if it was improper for the trial court to allow the introduction of flight evidence in Al-Sadawi, it would be even more improper for the Court to do so here. See id.; see also Sanchez, 790 F.2d at 252-53 (precluding evidence that defendant failed to appear at the initial date and a continuance date scheduled for his own trial); United States v. Green, No. 12-Cr-83S, 2017 WL 4803957, at *4-*5 (W.D.N.Y. Oct. 25, 2017) (precluding evidence that defendant jumped from a third-floor window after being arrested and interviewed by the police); United States v. Glenn, 312 F.3d 58, 67-68 (2d Cir. 2002) (evidence that defendant flagged down a car\n8\nDOJ-OGR-00005698",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 388 Filed 10/29/21 Page 11 of 14",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "157). By contrast, the Second Circuit found that the government's evidence in Al-Sadawi was \"too attenuated\" to establish that the defendant intended to flee to avoid prosecution or apprehension and the government should not have been permitted to argue consciousness of guilt on the basis of that evidence. Id.\nHere, the purported \"flight\" evidence is even more attenuated than in Al-Sadawi. Like Al-Sadawi, Ms. Maxwell knew she was a subject of the government's investigation after the arrest of Jeffery Epstein and could have left the country at any point in the one-year period leading up to her arrest (nine-and-a-half months longer than Al-Sadawi). But she did not.\nUnlike Al-Sadawi, there is no evidence whatsoever that Ms. Maxwell was preparing to flee. Neither Ms. Maxwell nor her spouse had purchased a plane ticket, nor was Ms. Maxwell planning to move locations. On the contrary, Ms. Maxwell had been living in the same residence in New Hampshire for seven months - a location she chose because it was close to her family and close to the prosecutors in New York in case she needed to meet with them. Moreover, when Ms. Maxwell was arrested, the arresting agents found nothing suggesting that she planned to abscond. Finally, unlike Al-Sadawi, Ms. Maxwell proffered independent evidence supporting an alternative explanation for her actions that rebuts any inference that she intended to flee.\nHence, if it was improper for the trial court to allow the introduction of flight evidence in Al-Sadawi, it would be even more improper for the Court to do so here. See id.; see also Sanchez, 790 F.2d at 252-53 (precluding evidence that defendant failed to appear at the initial date and a continuance date scheduled for his own trial); United States v. Green, No. 12-Cr-83S, 2017 WL 4803957, at *4-*5 (W.D.N.Y. Oct. 25, 2017) (precluding evidence that defendant jumped from a third-floor window after being arrested and interviewed by the police); United States v. Glenn, 312 F.3d 58, 67-68 (2d Cir. 2002) (evidence that defendant flagged down a car",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "8",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005698",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell",
      "Jeffery Epstein"
    ],
    "organizations": [
      "Second Circuit"
    ],
    "locations": [
      "New Hampshire",
      "New York"
    ],
    "dates": [
      "10/29/21",
      "Oct. 25, 2017"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 388",
      "12-Cr-83S",
      "790 F.2d",
      "312 F.3d 58",
      "2017 WL 4803957"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell. The text discusses the government's evidence and the defendant's intentions. The document is well-formatted and free of significant damage or redactions."
}