{
  "document_metadata": {
    "page_number": "14",
    "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 14 of 26\n\nThe government bears a dual burden in seeking pre-trial detention. First, the government must show \"by a preponderance of the evidence that the defendant . . . presents an actual risk of flight.\" Sabhnani, 493 F.3d at 75 (emphasis added). If the government is able to satisfy this burden, it must then \"demonstrate by a preponderance of the evidence that no condition or combination of conditions could be imposed on the defendant that would reasonably assure his presence in court.\" Id.\n\nIn determining whether there are conditions of release that will reasonably assure the appearance of the defendant, the court must consider (1) the nature and circumstances of the offense charged; (2) the weight of the evidence against the person; (3) the history and characteristics of the person; and (4) the nature and seriousness of the danger to any person or the community that would be posed by the person's release. 18 U.S.C. § 3142(g).\n\nIn this case, unlike in the Epstein case, the government does not contend that Ms. Maxwell poses any danger to the community, and therefore the fourth factor does not apply.\n\nThe Bail Reform Act contains a rebuttable presumption, applicable based on certain of the crimes charged here, that no conditions will reasonably assure against flight. See 18 U.S.C. § 3142(e)(3)(E). In cases where this presumption applies, the \"defendant bears a limited burden of production—not a burden of persuasion—to rebut that presumption by coming forward with evidence that [she] does not pose . . . a risk of flight.\" See United States v. English, 629 F.3d 311, 319 (2d Cir. 2011) (quotation omitted). This rebuttable presumption can be readily satisfied, United States v. Conway, No. 4-11-70756 MAG (DMR), 2011 WL 3421321, at *2 (N.D. Cal. Aug. 3, 2011), and \"[a]ny evidence favorable to a defendant that comes within a category listed in § 3142(g) can affect the operation\" of the presumption. United States v. Dominguez, 783 F.2d 702, 707 (7th Cir. 1986); see also United States v. Mattis, No. 20-1713,\n\n10\nDOJ-OGR-00001594",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 14 of 26",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The government bears a dual burden in seeking pre-trial detention. First, the government must show \"by a preponderance of the evidence that the defendant . . . presents an actual risk of flight.\" Sabhnani, 493 F.3d at 75 (emphasis added). If the government is able to satisfy this burden, it must then \"demonstrate by a preponderance of the evidence that no condition or combination of conditions could be imposed on the defendant that would reasonably assure his presence in court.\" Id.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "In determining whether there are conditions of release that will reasonably assure the appearance of the defendant, the court must consider (1) the nature and circumstances of the offense charged; (2) the weight of the evidence against the person; (3) the history and characteristics of the person; and (4) the nature and seriousness of the danger to any person or the community that would be posed by the person's release. 18 U.S.C. § 3142(g).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "In this case, unlike in the Epstein case, the government does not contend that Ms. Maxwell poses any danger to the community, and therefore the fourth factor does not apply.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The Bail Reform Act contains a rebuttable presumption, applicable based on certain of the crimes charged here, that no conditions will reasonably assure against flight. See 18 U.S.C. § 3142(e)(3)(E). In cases where this presumption applies, the \"defendant bears a limited burden of production—not a burden of persuasion—to rebut that presumption by coming forward with evidence that [she] does not pose . . . a risk of flight.\" See United States v. English, 629 F.3d 311, 319 (2d Cir. 2011) (quotation omitted). This rebuttable presumption can be readily satisfied, United States v. Conway, No. 4-11-70756 MAG (DMR), 2011 WL 3421321, at *2 (N.D. Cal. Aug. 3, 2011), and \"[a]ny evidence favorable to a defendant that comes within a category listed in § 3142(g) can affect the operation\" of the presumption. United States v. Dominguez, 783 F.2d 702, 707 (7th Cir. 1986); see also United States v. Mattis, No. 20-1713,",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "10",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001594",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell",
      "Epstein"
    ],
    "organizations": [
      "DOJ"
    ],
    "locations": [
      "N.D. Cal."
    ],
    "dates": [
      "07/10/20",
      "Aug. 3, 2011"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-AJN",
      "Document 18",
      "No. 4-11-70756 MAG (DMR)",
      "No. 20-1713",
      "DOJ-OGR-00001594"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell. The text is printed and there are no visible stamps or handwritten notes. The document is page 14 of 26."
}