{
  "document_metadata": {
    "page_number": "10",
    "document_number": "423",
    "date": "11/08/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 423 Filed 11/08/21 Page 10 of 11\nPage 10\ncompromised. (See, e.g., Dkt. 282 at 2 (finding “nothing in the record plausibly establishes that current protocols interfere with Maxwell’s ability to prepare for her trial and communicate with her lawyers”)).\n\nFinally, in a single paragraph, the defendant argues that the Jencks Act and Giglio material she has received “contradict the purported ‘strength’ of the government’s case.” (Def. Mot. 6). But that claim is supported by only the most conclusory of assertions that “there is no independent corroboration” for the victims’ statements and that they “demonstrate contamination and collusion from various sources.” (Id.). The defendant has made such arguments about the strength of the Government’s case before (see, e.g., Dkt. 18 at 19; Dkt. 97 at 30-33; Dkt. 171 at 7-8), and each time the Court has rejected the defendant’s bail application. (See, e.g., Second Order at 9-10 (rejecting the defendant’s claim that the Government overstated the strength of its case at the bail hearing, finding that the defendant “too easily discredits the witness testimony”)). Moreover, since the Court’s third detention order, the Court has also rejected the defendant’s pretrial motions to dismiss the charges (Dkt. 207, 317), the pendency of which the defendant had also claimed undermined the strength of the case (see, e.g., Dkt. 171 at 7-8), and a grand jury returned a superseding indictment charging additional counts based on an additional victim, and the Government intends to prove the existence of two additional victims at trial. Thus, the defendant’s latest ipse dixit about the victims does not in fact “undermine the strength of the government’s case.” (Def. Mot. 6). Quite the contrary, that the defendant is this close to trial and still cannot make a more compelling argument about the strength of the case underscores what has been apparent from the Government’s first proffer: the case is strong.\n\nThe defendant’s motion for reconsideration should be denied.\n\nDOJ-OGR-00006210",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 423 Filed 11/08/21 Page 10 of 11",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Page 10",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "compromised. (See, e.g., Dkt. 282 at 2 (finding “nothing in the record plausibly establishes that current protocols interfere with Maxwell’s ability to prepare for her trial and communicate with her lawyers”)).\n\nFinally, in a single paragraph, the defendant argues that the Jencks Act and Giglio material she has received “contradict the purported ‘strength’ of the government’s case.” (Def. Mot. 6). But that claim is supported by only the most conclusory of assertions that “there is no independent corroboration” for the victims’ statements and that they “demonstrate contamination and collusion from various sources.” (Id.). The defendant has made such arguments about the strength of the Government’s case before (see, e.g., Dkt. 18 at 19; Dkt. 97 at 30-33; Dkt. 171 at 7-8), and each time the Court has rejected the defendant’s bail application. (See, e.g., Second Order at 9-10 (rejecting the defendant’s claim that the Government overstated the strength of its case at the bail hearing, finding that the defendant “too easily discredits the witness testimony”)). Moreover, since the Court’s third detention order, the Court has also rejected the defendant’s pretrial motions to dismiss the charges (Dkt. 207, 317), the pendency of which the defendant had also claimed undermined the strength of the case (see, e.g., Dkt. 171 at 7-8), and a grand jury returned a superseding indictment charging additional counts based on an additional victim, and the Government intends to prove the existence of two additional victims at trial. Thus, the defendant’s latest ipse dixit about the victims does not in fact “undermine the strength of the government’s case.” (Def. Mot. 6). Quite the contrary, that the defendant is this close to trial and still cannot make a more compelling argument about the strength of the case underscores what has been apparent from the Government’s first proffer: the case is strong.\n\nThe defendant’s motion for reconsideration should be denied.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00006210",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Maxwell"
    ],
    "organizations": [
      "Government",
      "Court",
      "Grand Jury"
    ],
    "locations": [],
    "dates": [
      "11/08/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "423",
      "282",
      "18",
      "97",
      "171",
      "207",
      "317",
      "DOJ-OGR-00006210"
    ]
  },
  "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 well-formatted and legible."
}