{
  "document_metadata": {
    "page_number": "46",
    "document_number": "93",
    "date": "12/10/20",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 46 of 91\nk7e2MaxC kjc\n\n1 So we understand why the court has to follow this\n2 process, but we submit that these presentations just are not\n3 relevant to the determination before the court today. And,\n4 again, we don't have spin. The big fact that the government,\n5 Ms. Moe tried to put before you through the victim is that\n6 supposedly someone had called in a civil action threatening the\n7 two-year-old child. Notice how carefully that was phrased,\n8 your Honor. It wasn't tied to Ms. Maxwell. It's more spin,\n9 spin, spin.\n10 So we are here to consider bail. We should consider\n11 the statute. We should consider your Honor's guidance under\n12 the statute. So let me just put that to one side. I determine\n13 that that really disposes of the issue of what weight to give.\n14 In turning to the statute, your Honor, turning to the\n15 factors, I don't want to spend a lot of time on the standard,\n16 because I know your Honor is very familiar with it, but I do\n17 want to point out that, in an opening brief and reply brief and\n18 now an oral presentation, the government has not once\n19 represented the standard to your Honor nor the burden that it\n20 has. And that is the statute, under 3142(c), says that \"even\n21 the case where there is not to be release ROR\" -- which this is\n22 not that case -- \"the court shall order pretrial release\n23 subject to the least restrictive condition or combination of\n24 conditions.\" That as you now read, of course, in light of\n25 3142(e), (f), and (g), the provisions on detention, that the\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00001923",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 46 of 91",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "1 So we understand why the court has to follow this\n2 process, but we submit that these presentations just are not\n3 relevant to the determination before the court today. And,\n4 again, we don't have spin. The big fact that the government,\n5 Ms. Moe tried to put before you through the victim is that\n6 supposedly someone had called in a civil action threatening the\n7 two-year-old child. Notice how carefully that was phrased,\n8 your Honor. It wasn't tied to Ms. Maxwell. It's more spin,\n9 spin, spin.\n10 So we are here to consider bail. We should consider\n11 the statute. We should consider your Honor's guidance under\n12 the statute. So let me just put that to one side. I determine\n13 that that really disposes of the issue of what weight to give.\n14 In turning to the statute, your Honor, turning to the\n15 factors, I don't want to spend a lot of time on the standard,\n16 because I know your Honor is very familiar with it, but I do\n17 want to point out that, in an opening brief and reply brief and\n18 now an oral presentation, the government has not once\n19 represented the standard to your Honor nor the burden that it\n20 has. And that is the statute, under 3142(c), says that \"even\n21 the case where there is not to be release ROR\" -- which this is\n22 not that case -- \"the court shall order pretrial release\n23 subject to the least restrictive condition or combination of\n24 conditions.\" That as you now read, of course, in light of\n25 3142(e), (f), and (g), the provisions on detention, that the",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001923",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Moe",
      "Ms. Maxwell"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "12/10/20"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 93",
      "3142(c)",
      "3142(e)",
      "3142(f)",
      "3142(g)",
      "DOJ-OGR-00001923"
    ]
  },
  "additional_notes": "The document appears to be a court transcript, with a formal tone and legal language. The content is a discussion of bail and pretrial release conditions."
}