{
  "document_metadata": {
    "page_number": "4",
    "document_number": "20-cr-330 (AJN) Document 110",
    "date": "2020-08-23",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "as a substitute for its prosecution of Epstein.3 The government's case is not what it represented to the Court at the initial bail hearing, which should weigh heavily in favor of granting bail.4\n\nII. The Government Has Not Carried Its Burden\n\nA. The Government Asks the Court to Ignore Ms. Maxwell's Substantial Ties to the United States, Including Her Spouse\n\nThe government incorrectly argues that the renewed bail application offers no new information and that the Court was \"already aware of\" the defendant's friends and family in the United States. (Gov. Mem. at 13). The government ignores that, since the initial bail hearing, Ms. Maxwell's spouse has come forward as a co-signor and has submitted a detailed letter describing his committed relationship with Ms. Maxwell for over four years and the important role she has played, and continues to play,\n\nIt also ignores that several of Ms. Maxwell's closest friends and family, many of whom are U.S. citizens and residents, have also come forward, at considerable personal risk, to support her bond with pledges of assets or letters of support. This information, which was not available to the Court at the time of the initial hearing, demonstrates Ms. Maxwell's strong ties to this country and weighs heavily in favor of bail.\n\nRather than address the merits, the government attempts to dismiss the significance of Ms. Maxwell's relationship with her spouse, noting that Ms. Maxwell told Pretrial Services that she was in the process of getting a divorce and that her spouse did not step forward as a co-signer at the initial bail hearing. (Id. at 13-14). The government is entirely\n\n3Moreover, the government failure to request regardless of whether it was legally obligated to do so, shows that the government has accepted the accusers' accounts without serious scrutiny. Given the government's ongoing Brady obligations, it is unsettling that the government would simply accept\n\n4Contrary to the government's assertion, the defense has not abandoned our legal challenges to the indictment. (Gov. Mem. at 10 n.1). We believe we have strong arguments that have only gotten stronger with the production of discovery. We will be making those arguments to the Court in our pretrial motions to be filed next month.",
  "text_blocks": [
    {
      "type": "printed",
      "content": "as a substitute for its prosecution of Epstein.3 The government's case is not what it represented to the Court at the initial bail hearing, which should weigh heavily in favor of granting bail.4",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "II. The Government Has Not Carried Its Burden",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "A. The Government Asks the Court to Ignore Ms. Maxwell's Substantial Ties to the United States, Including Her Spouse",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The government incorrectly argues that the renewed bail application offers no new information and that the Court was \"already aware of\" the defendant's friends and family in the United States. (Gov. Mem. at 13). The government ignores that, since the initial bail hearing, Ms. Maxwell's spouse has come forward as a co-signor and has submitted a detailed letter describing his committed relationship with Ms. Maxwell for over four years and the important role she has played, and continues to play,",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "It also ignores that several of Ms. Maxwell's closest friends and family, many of whom are U.S. citizens and residents, have also come forward, at considerable personal risk, to support her bond with pledges of assets or letters of support. This information, which was not available to the Court at the time of the initial hearing, demonstrates Ms. Maxwell's strong ties to this country and weighs heavily in favor of bail.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Rather than address the merits, the government attempts to dismiss the significance of Ms. Maxwell's relationship with her spouse, noting that Ms. Maxwell told Pretrial Services that she was in the process of getting a divorce and that her spouse did not step forward as a co-signer at the initial bail hearing. (Id. at 13-14). The government is entirely",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "3Moreover, the government failure to request regardless of whether it was legally obligated to do so, shows that the government has accepted the accusers' accounts without serious scrutiny. Given the government's ongoing Brady obligations, it is unsettling that the government would simply accept",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "4Contrary to the government's assertion, the defense has not abandoned our legal challenges to the indictment. (Gov. Mem. at 10 n.1). We believe we have strong arguments that have only gotten stronger with the production of discovery. We will be making those arguments to the Court in our pretrial motions to be filed next month.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "4",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001193",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Epstein",
      "Ms. Maxwell"
    ],
    "organizations": [
      "Pretrial Services",
      "Court"
    ],
    "locations": [
      "United States"
    ],
    "dates": [
      "next month"
    ],
    "reference_numbers": [
      "20-cr-330 (AJN) Document 110",
      "DOJ-OGR-00001193"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell. The text is mostly printed, with some redacted sections. The document is page 4 of a larger filing."
}