{
  "document_metadata": {
    "page_number": "46",
    "document_number": "670",
    "date": "06/22/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 670 Filed 06/22/22 Page 46 of 55\n\nOffice recognized in its report, a significant sentence “should promote general deterrence against the exploitation and degradation of humans made possible by this offense, as well as untouchable individuals who feel their privilege and affluence entitle them to victimize others without fear of consequence.” (PSR at 67).8\n\nB. The Defendant’s Arguments for a Lenient Sentence Are Unpersuasive\n\nThe defendant spends the majority of her sentencing submission complaining that her conditions of pretrial confinement warrant a downward variance. Not only are the defendant’s claims inaccurate, but the defense overlooks the extraordinary steps that the Court has taken throughout the pendency of this case to oversee the conditions of this defendant’s confinement. Indeed, the Court received regular updates regarding the defendant’s conditions of confinement throughout this case, which were based on regular communications between the Government and Bureau of Prisons (“BOP”) legal counsel. As a result, the Court already has exceptional insight into the defendant’s conditions of pretrial confinement and is well aware of the many privileges the defendant has received while in custody. Although the defendant has clearly disliked her experience at the Metropolitan Detention Center (“MDC”), the conditions she in fact experienced do not rise to a level of extremity that warrant a downward variance, much less the extent of a variance the defendant seeks.\n\n8 The defendant argues that she should not be “sentenced as if she were Harvey Weinstein” who was convicted of forcible rape following a state jury trial. (Dkt. No. 663 at 20). These are different cases, under different sentencing regimes, with different facts. It is pointless to compare a state rape case involving adults to a federal case involving child exploitation. The defendant should be sentenced under the applicable federal Sentencing Guidelines for her extensive crimes against children. Defendants engaged in sexual abuse of minors are regularly sentenced to significant sentences of imprisonment in this District. See, e.g., United States v. Maria Soly Almonte, 16 Cr. 670 (KMW) (defendant sentenced to twenty years’ imprisonment for a non-violent child trafficking scheme, notwithstanding mitigating factors, including defendant’s poverty and personal experience with sexual abuse). The defendant is not an exception.\n\n44\nDOJ-OGR-00010581",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 670 Filed 06/22/22 Page 46 of 55",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Office recognized in its report, a significant sentence “should promote general deterrence against the exploitation and degradation of humans made possible by this offense, as well as untouchable individuals who feel their privilege and affluence entitle them to victimize others without fear of consequence.” (PSR at 67).8",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "B. The Defendant’s Arguments for a Lenient Sentence Are Unpersuasive",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The defendant spends the majority of her sentencing submission complaining that her conditions of pretrial confinement warrant a downward variance. Not only are the defendant’s claims inaccurate, but the defense overlooks the extraordinary steps that the Court has taken throughout the pendency of this case to oversee the conditions of this defendant’s confinement. Indeed, the Court received regular updates regarding the defendant’s conditions of confinement throughout this case, which were based on regular communications between the Government and Bureau of Prisons (“BOP”) legal counsel. As a result, the Court already has exceptional insight into the defendant’s conditions of pretrial confinement and is well aware of the many privileges the defendant has received while in custody. Although the defendant has clearly disliked her experience at the Metropolitan Detention Center (“MDC”), the conditions she in fact experienced do not rise to a level of extremity that warrant a downward variance, much less the extent of a variance the defendant seeks.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "8 The defendant argues that she should not be “sentenced as if she were Harvey Weinstein” who was convicted of forcible rape following a state jury trial. (Dkt. No. 663 at 20). These are different cases, under different sentencing regimes, with different facts. It is pointless to compare a state rape case involving adults to a federal case involving child exploitation. The defendant should be sentenced under the applicable federal Sentencing Guidelines for her extensive crimes against children. Defendants engaged in sexual abuse of minors are regularly sentenced to significant sentences of imprisonment in this District. See, e.g., United States v. Maria Soly Almonte, 16 Cr. 670 (KMW) (defendant sentenced to twenty years’ imprisonment for a non-violent child trafficking scheme, notwithstanding mitigating factors, including defendant’s poverty and personal experience with sexual abuse). The defendant is not an exception.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "44",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00010581",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Harvey Weinstein",
      "Maria Soly Almonte"
    ],
    "organizations": [
      "Bureau of Prisons",
      "Metropolitan Detention Center"
    ],
    "locations": [],
    "dates": [
      "06/22/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 670",
      "Dkt. No. 663",
      "16 Cr. 670 (KMW)"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case involving child exploitation. The text is printed and there are no visible stamps or handwritten notes. The document is well-formatted and legible."
}