{
  "document_metadata": {
    "page_number": "32",
    "document_number": "2017-00330",
    "date": null,
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:17-cr-00330-AJN Document 101 Filed 01/03/18 Page 32 of 36\nUnited States). Further, unlike those cases and the cases cited by the defendant, the crimes charged here involving minor victims trigger a statutory presumption in favor of detention, weighing further in favor of detention. See Mercedes, 254 F.3d at 436.\n\"Each bail package in each case is considered and evaluated on its individual merits by the Court.\" Epstein, 425 F. Supp. 3d at 326. Unlike the cases cited by the defense, the Government seeks detention not solely on the basis that the defendant is of financial means and has foreign citizenship. Rather, detention is warranted because the defendant is a citizen of multiple foreign countries, including one that does not extradite its nationals, with \"substantial international ties,\" \"familial and personal connections abroad,\" and \"substantial financial resources,\" (Tr. 83-84), with a demonstrated sophistication in hiding herself and her assets, who, for the myriad reasons discussed herein and identified at the original hearing—including the seriousness of the offense, the strength of the Government's evidence, and the potential length of sentence—presents a substantial flight risk. (Tr. 82-91). The defendant continues to pose an extreme risk of flight, and the defense has not offered any new information sufficient to justify reversal of the Court's prior finding that no combination of conditions could ensure her appearance.\nD. Conditions of Confinement\nFinally, the Renewed Bail Application reiterates the same argument about the potential harms of detention on the defendant that this Court rejected at the initial bail hearing. (Tr. 42, 68-69). As was the case in July, these complaints do not warrant the defendant's release.\nThe defendant continues to have more time than any other inmate at the MDC to review her discovery and as much, if not more, time to communicate with her attorneys. Specifically, the defendant currently has thirteen hours per day, seven days per week to review electronic discovery. Also during that time, the defendant has access to email with defense counsel, calls with defense",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:17-cr-00330-AJN Document 101 Filed 01/03/18 Page 32 of 36",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "United States). Further, unlike those cases and the cases cited by the defendant, the crimes charged here involving minor victims trigger a statutory presumption in favor of detention, weighing further in favor of detention. See Mercedes, 254 F.3d at 436.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "\"Each bail package in each case is considered and evaluated on its individual merits by the Court.\" Epstein, 425 F. Supp. 3d at 326. Unlike the cases cited by the defense, the Government seeks detention not solely on the basis that the defendant is of financial means and has foreign citizenship. Rather, detention is warranted because the defendant is a citizen of multiple foreign countries, including one that does not extradite its nationals, with \"substantial international ties,\" \"familial and personal connections abroad,\" and \"substantial financial resources,\" (Tr. 83-84), with a demonstrated sophistication in hiding herself and her assets, who, for the myriad reasons discussed herein and identified at the original hearing—including the seriousness of the offense, the strength of the Government's evidence, and the potential length of sentence—presents a substantial flight risk. (Tr. 82-91). The defendant continues to pose an extreme risk of flight, and the defense has not offered any new information sufficient to justify reversal of the Court's prior finding that no combination of conditions could ensure her appearance.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "D. Conditions of Confinement",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Finally, the Renewed Bail Application reiterates the same argument about the potential harms of detention on the defendant that this Court rejected at the initial bail hearing. (Tr. 42, 68-69). As was the case in July, these complaints do not warrant the defendant's release.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The defendant continues to have more time than any other inmate at the MDC to review her discovery and as much, if not more, time to communicate with her attorneys. Specifically, the defendant currently has thirteen hours per day, seven days per week to review electronic discovery. Also during that time, the defendant has access to email with defense counsel, calls with defense",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "29",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001174",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [],
    "organizations": [
      "United States",
      "Government",
      "Court",
      "MDC"
    ],
    "locations": [
      "United States"
    ],
    "dates": [
      "01/03/18",
      "July"
    ],
    "reference_numbers": [
      "1:17-cr-00330-AJN",
      "Document 101",
      "Tr. 83-84",
      "Tr. 82-91",
      "Tr. 42, 68-69",
      "DOJ-OGR-00001174"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is printed and there are no visible stamps or handwritten notes. The document is page 32 of 36."
}