{
  "document_metadata": {
    "page_number": "2",
    "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 2 of 26 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 ARGUMENT 5 I. The Conditions Created by the COVID-19 Pandemic Mandate the Release of Ms. Maxwell. 5 II. The Government Has Not Carried Its Burden Under 18 U.S.C. § 3142. 9 A. Applicable Law 9 B. Ms. Maxwell Has Rebutted the Presumption That She Poses a Flight Risk, and the Government Has Not Carried Its Burden That No Combination of Conditions Can Be Imposed To Reasonably Assure Her Presence In Court 11 1. Ms. Maxwell's Personal History and Characteristics Demonstrate That She Is Not a Flight Risk 12 2. The Nature and Circumstances of the Charges and the Weight of the Evidence Militate in Favor of Bail 17 3. The Proposed Bail Package Is More Than Adequate to Secure Ms. Maxwell's Presence 20 CONCLUSION 22 i DOJ-OGR-00001582",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 2 of 26",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "TABLE OF CONTENTS",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Page",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "PRELIMINARY STATEMENT 1 ARGUMENT 5 I. The Conditions Created by the COVID-19 Pandemic Mandate the Release of Ms. Maxwell. 5 II. The Government Has Not Carried Its Burden Under 18 U.S.C. § 3142. 9 A. Applicable Law 9 B. Ms. Maxwell Has Rebutted the Presumption That She Poses a Flight Risk, and the Government Has Not Carried Its Burden That No Combination of Conditions Can Be Imposed To Reasonably Assure Her Presence In Court 11 1. Ms. Maxwell's Personal History and Characteristics Demonstrate That She Is Not a Flight Risk 12 2. The Nature and Circumstances of the Charges and the Weight of the Evidence Militate in Favor of Bail 17 3. The Proposed Bail Package Is More Than Adequate to Secure Ms. Maxwell's Presence 20 CONCLUSION 22",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "i",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001582",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "Ms. Maxwell"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "07/10/20"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 18",
      "DOJ-OGR-00001582"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell, with a table of contents outlining the structure of the document."
}