{
  "document_metadata": {
    "page_number": "3",
    "document_number": "22",
    "date": "July 16, 2019",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:19-cr-00490-RMB Document 22 Filed 07/16/19 Page 3 of 9\n\nHon. Richard M. Berman\nJuly 16, 2019\nPage 3\n\nplain text - expressly providing that the presumption is \"[s]ubject to rebuttal,\" and otherwise mandating bail on the \"least restrictive\" conditions that reasonably assure the defendant's presence and community safety - on its head. It defies legislative intent. It thwarts the presumption of innocence. And it violates the Fifth, Sixth and Fourteenth amendment rights to due process, counsel, a defense and equal protection, not to mention the Eighth Amendment guarantee of bail - all based on a suspect if not invidious classification. To be sure, wealthy defendants do not deserve preferential treatment. But they certainly shouldn't be singled out for worse treatment - in effect, categorically disqualified from bail, at least in a presumption case - on the basis of their net worth.\n\nSecond, it bears emphasis that the presumption is hardly an insurmountable bar to release in a § 1591 prosecution.3 To the contrary, courts have determined that there are suitable conditions under which\n\n3 E.g., US v. Brinson, No. 13-CR-04-GKF, 2013 WL 11305792 (N.D. Okla. Feb. 8, 2013); US v. Afyare, No. 3:10-cr-00260, 2011 WL 1397820 (M.D. Tenn. April 13, 2011); US v. Gardner, 523 F. Supp. 2d 1025 (N.D. Cal. 2007).\n\nDOJ-OGR-00000433",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:19-cr-00490-RMB Document 22 Filed 07/16/19 Page 3 of 9",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Hon. Richard M. Berman\nJuly 16, 2019\nPage 3",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "plain text - expressly providing that the presumption is \"[s]ubject to rebuttal,\" and otherwise mandating bail on the \"least restrictive\" conditions that reasonably assure the defendant's presence and community safety - on its head. It defies legislative intent. It thwarts the presumption of innocence. And it violates the Fifth, Sixth and Fourteenth amendment rights to due process, counsel, a defense and equal protection, not to mention the Eighth Amendment guarantee of bail - all based on a suspect if not invidious classification. To be sure, wealthy defendants do not deserve preferential treatment. But they certainly shouldn't be singled out for worse treatment - in effect, categorically disqualified from bail, at least in a presumption case - on the basis of their net worth.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Second, it bears emphasis that the presumption is hardly an insurmountable bar to release in a § 1591 prosecution.3 To the contrary, courts have determined that there are suitable conditions under which",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "3 E.g., US v. Brinson, No. 13-CR-04-GKF, 2013 WL 11305792 (N.D. Okla. Feb. 8, 2013); US v. Afyare, No. 3:10-cr-00260, 2011 WL 1397820 (M.D. Tenn. April 13, 2011); US v. Gardner, 523 F. Supp. 2d 1025 (N.D. Cal. 2007).",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00000433",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Richard M. Berman"
    ],
    "organizations": [],
    "locations": [
      "Oklahoma",
      "Tennessee",
      "California"
    ],
    "dates": [
      "July 16, 2019",
      "February 8, 2013",
      "April 13, 2011",
      "2007"
    ],
    "reference_numbers": [
      "1:19-cr-00490-RMB",
      "Document 22",
      "§ 1591",
      "No. 13-CR-04-GKF",
      "No. 3:10-cr-00260",
      "523 F. Supp. 2d 1025",
      "DOJ-OGR-00000433"
    ]
  },
  "additional_notes": "The document appears to be a court filing, likely a memorandum or brief, discussing the presumption of bail in certain cases. The text is printed and there are no visible stamps or handwritten notes. The document is page 3 of a 9-page document."
}