{
  "document_metadata": {
    "page_number": "4",
    "document_number": "213",
    "date": "04/16/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 213 Filed 04/16/21 Page 4 of 8\nyears ago that may be applicable to dozens of people in multiple places including a foreign country.\nUnited States v. Vickers, No. 13-CR-128-A, 2014 WL 1838255, at *1 (W.D.N.Y. May 8, 2014), also does not help the government. This case concerned a one count indictment in 2013. It is patently clear from the opinion by the district court that the statements from the alleged victim detailing the allegation had been provided to the defendant and the court which noted that the lengthy recitation of facts in the opinion \"are taken from the allegations set forth in the Affidavit of Federal Bureau of Investigation Special Agent Jennifer Jayne Amo submitted in support of the May 16, 2013 Criminal Complaint (Dkt.# 1), the Indictment (Dkt.# 8), and the government's response to the instant motions (Dkt.# 20).\" 2014 WL 1838255, at *3 n.1. The dates and times of the alleged conduct would have been fairly easy to identify given the detail provided in discovery. Here, Ms. Maxwell has not been provided with any relevant statements by the government or its witnesses.\nThe government's attempt to hide behind the general proposition that children cannot be expected to remember dates also fails. Resp. at 155. The alleged victims here are not children, they are adults. Moreover, a review of the case relied on by the government, United States v. Young, No. 08-CR-285 (KMK), 2008 WL 4178190, at *2 (S.D.N.Y. Sept. 4, 2008), demonstrates the proper way to charge these types of allegations (which is not as the government did here):\nCount One alleges that Defendant sexually abused Victim One, aged fourteen at the time, during the daytime on a Saturday in or about the Fall of 2006; Count Two alleges that Defendant sexually abused Victim One, aged fifteen at the time, during the daytime on a Saturday in or about September 2007; and Count Three alleges that Defendant sexually abused Victim Two, aged sixteen at the time, on an evening in or about the Summer of 2006. Stated differently, the three counts each specify a particular time of day (daytime or evening), and feature variances in date ranges stretching from roughly four days in Count Two to thirteen days in Count One to four months in Count Three.\n3\nDOJ-OCR-00003836",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 213 Filed 04/16/21 Page 4 of 8",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "years ago that may be applicable to dozens of people in multiple places including a foreign country.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "United States v. Vickers, No. 13-CR-128-A, 2014 WL 1838255, at *1 (W.D.N.Y. May 8, 2014), also does not help the government. This case concerned a one count indictment in 2013. It is patently clear from the opinion by the district court that the statements from the alleged victim detailing the allegation had been provided to the defendant and the court which noted that the lengthy recitation of facts in the opinion \"are taken from the allegations set forth in the Affidavit of Federal Bureau of Investigation Special Agent Jennifer Jayne Amo submitted in support of the May 16, 2013 Criminal Complaint (Dkt.# 1), the Indictment (Dkt.# 8), and the government's response to the instant motions (Dkt.# 20).\" 2014 WL 1838255, at *3 n.1. The dates and times of the alleged conduct would have been fairly easy to identify given the detail provided in discovery. Here, Ms. Maxwell has not been provided with any relevant statements by the government or its witnesses.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The government's attempt to hide behind the general proposition that children cannot be expected to remember dates also fails. Resp. at 155. The alleged victims here are not children, they are adults. Moreover, a review of the case relied on by the government, United States v. Young, No. 08-CR-285 (KMK), 2008 WL 4178190, at *2 (S.D.N.Y. Sept. 4, 2008), demonstrates the proper way to charge these types of allegations (which is not as the government did here):",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Count One alleges that Defendant sexually abused Victim One, aged fourteen at the time, during the daytime on a Saturday in or about the Fall of 2006; Count Two alleges that Defendant sexually abused Victim One, aged fifteen at the time, during the daytime on a Saturday in or about September 2007; and Count Three alleges that Defendant sexually abused Victim Two, aged sixteen at the time, on an evening in or about the Summer of 2006. Stated differently, the three counts each specify a particular time of day (daytime or evening), and feature variances in date ranges stretching from roughly four days in Count Two to thirteen days in Count One to four months in Count Three.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "3",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OCR-00003836",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jennifer Jayne Amo",
      "Ms. Maxwell",
      "Victim One",
      "Victim Two",
      "Defendant"
    ],
    "organizations": [
      "Federal Bureau of Investigation"
    ],
    "locations": [
      "W.D.N.Y.",
      "S.D.N.Y."
    ],
    "dates": [
      "May 8, 2014",
      "May 16, 2013",
      "Sept. 4, 2008",
      "Fall of 2006",
      "September 2007",
      "Summer of 2006",
      "04/16/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 213",
      "13-CR-128-A",
      "08-CR-285 (KMK)",
      "Dkt.# 1",
      "Dkt.# 8",
      "Dkt.# 20",
      "2014 WL 1838255",
      "2008 WL 4178190",
      "DOJ-OCR-00003836"
    ]
  },
  "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 4 of 8."
}