{
  "document_metadata": {
    "page_number": "15",
    "document_number": "22",
    "date": "07/13/20",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 22 Filed 07/13/20 Page 15 of 19\nthan any other inmate at the MDC, and thus she cannot claim any greater need for bail than the\nmany inmates awaiting trial there.3\nThe virus, of course, presents new and complex challenges for protecting inmates' health,\nbut the BOP generally, and the MDC specifically, are prepared to handle the risks presented by\nCOVID-19 and other health issues. The MDC's response to the pandemic was the subject of\nextensive evidentiary hearings in the context of a civil lawsuit in the Eastern District of New York.\nSee Chunn v. Edge, No. 20 Cr. 1590, 2020 WL 3055669 (E.D.N.Y. June 9, 2020). In Chunn, the\nDistrict Court conducted extensive fact gathering about the conditions at the MDC before\nconcluding that \"MDC officials have recognized COVID-19 as a serious threat and responded\naggressively.\" Id. at *1; see also id. at 25 (\"The MDC's response to COVID-19 has been\naggressive and has included, among other steps, massively restricting movement within the\nfacility, enhancing sanitation protocols, and creating quarantine and isolation units. And the data—\nthough limited—suggests that these measures have been quite effective in containing COVID-19\nthus far.\")\nNumerous judges in this District have rejected applications for release based on assertions\nabout the hypothetical risks of COVID-19, including multiple cases involving defendants who,\nunlike this defendant, suffer from underlying health conditions. See, e.g., United States v. Hanes-\nCalugaru, No. 19 Cr. 651, ECF No. 257 (S.D.N.Y. May 4, 2020) (Swain, J.) (denying pre-trial\nbail application by defendant who was on MDC's initial high-risk list but subsequently removed\nfollowing new CDC guidance (see ECF Nos. 239, 242, 257)); United States v. Curry, 19 Cr. 742,\nECF No. 37 (S.D.N.Y. Apr. 30, 2020) (Hellerstein, J.) (denying pre-trial bail application by\n3 The defendant also argues that the circumstances of the pandemic would pose a \"significant\nhurdle\" to the defendant's ability to flee. Opposition Memorandum at 16. The Government\nsubmits that the defendant has the means and resources to find her way out of the country, and a\nshort quarantine period abroad would be a small price to pay to avoid years in prison.\n14\nDOJ-OGR-00001625",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 22 Filed 07/13/20 Page 15 of 19",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "than any other inmate at the MDC, and thus she cannot claim any greater need for bail than the many inmates awaiting trial there.3",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The virus, of course, presents new and complex challenges for protecting inmates' health, but the BOP generally, and the MDC specifically, are prepared to handle the risks presented by COVID-19 and other health issues. The MDC's response to the pandemic was the subject of extensive evidentiary hearings in the context of a civil lawsuit in the Eastern District of New York.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "See Chunn v. Edge, No. 20 Cr. 1590, 2020 WL 3055669 (E.D.N.Y. June 9, 2020). In Chunn, the District Court conducted extensive fact gathering about the conditions at the MDC before concluding that \"MDC officials have recognized COVID-19 as a serious threat and responded aggressively.\" Id. at *1; see also id. at 25 (\"The MDC's response to COVID-19 has been aggressive and has included, among other steps, massively restricting movement within the facility, enhancing sanitation protocols, and creating quarantine and isolation units. And the data—though limited—suggests that these measures have been quite effective in containing COVID-19 thus far.\")",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Numerous judges in this District have rejected applications for release based on assertions about the hypothetical risks of COVID-19, including multiple cases involving defendants who, unlike this defendant, suffer from underlying health conditions. See, e.g., United States v. Hanes-Calugaru, No. 19 Cr. 651, ECF No. 257 (S.D.N.Y. May 4, 2020) (Swain, J.) (denying pre-trial bail application by defendant who was on MDC's initial high-risk list but subsequently removed following new CDC guidance (see ECF Nos. 239, 242, 257)); United States v. Curry, 19 Cr. 742, ECF No. 37 (S.D.N.Y. Apr. 30, 2020) (Hellerstein, J.) (denying pre-trial bail application by",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "3 The defendant also argues that the circumstances of the pandemic would pose a \"significant hurdle\" to the defendant's ability to flee. Opposition Memorandum at 16. The Government submits that the defendant has the means and resources to find her way out of the country, and a short quarantine period abroad would be a small price to pay to avoid years in prison.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "14",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001625",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [],
    "organizations": [
      "BOP",
      "MDC",
      "CDC",
      "District Court",
      "Eastern District of New York",
      "Government"
    ],
    "locations": [
      "New York",
      "MDC"
    ],
    "dates": [
      "07/13/20",
      "June 9, 2020",
      "May 4, 2020",
      "Apr. 30, 2020"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 22",
      "20 Cr. 1590",
      "19 Cr. 651",
      "19 Cr. 742",
      "ECF No. 257",
      "ECF Nos. 239, 242, 257",
      "ECF No. 37",
      "DOJ-OGR-00001625"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case, discussing the COVID-19 pandemic and its impact on the Metropolitan Detention Center (MDC). The text is printed and there are no visible stamps or handwritten notes."
}