{
  "document_metadata": {
    "page_number": "7",
    "document_number": "338",
    "date": "10/12/21",
    "document_type": "court document",
    "has_handwriting": true,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 338 Filed 10/12/21 Page 7 of 22 2 it intended each teim to have a particular meaning); Lockhart v. United States 136 S.Ct. 958,964 (2016) (\"cannon of superfluity assists whole competing interpretation gives effect to every clause and word of a statute\"). There is a competing interpretation described below that uses the plain language and leaves no term insignificant. The Fifth Circuit's solution makes little sense in that surely Congress would have just added the two exploitation teims to the sexual Abuse definition had that been the intent.3 The sexual abuse definition includes \"other forms of exploitation\", perhaps like indentured. Given this ambiguity repose should apply \"... we have stated before 'the principle that criminal limitation statutes are to be liberally inteipreted in favor of repose',\" Toussie v. United States, 397 U.S. 112, 114-15 (1975); \"A limitation carving out an exception should apply to cases shown to be clearly within its purpose.\" United States v. The Elwoin, 272 US 633 (1926). 1. The Fifth Circuit provided no independent analysis instead relying on United States v. Coutentos, 651 F.3d 809, 816-817 (8th Cir. 2011) and United States v. carpenter, 680 F.3d 1101, 1103 (9th Cir. 2012). DOJ-OGR-00005185",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 338 Filed 10/12/21 Page 7 of 22",
      "position": "header"
    },
    {
      "type": "handwritten",
      "content": "2",
      "position": "margin"
    },
    {
      "type": "printed",
      "content": "it intended each teim to have a particular meaning); Lockhart v. United States 136 S.Ct. 958,964 (2016) (\"cannon of superfluity assists whole competing interpretation gives effect to every clause and word of a statute\"). There is a competing interpretation described below that uses the plain language and leaves no term insignificant. The Fifth Circuit's solution makes little sense in that surely Congress would have just added the two exploitation teims to the sexual Abuse definition had that been the intent.3 The sexual abuse definition includes \"other forms of exploitation\", perhaps like indentured. Given this ambiguity repose should apply \"... we have stated before 'the principle that criminal limitation statutes are to be liberally inteipreted in favor of repose',\" Toussie v. United States, 397 U.S. 112, 114-15 (1975); \"A limitation carving out an exception should apply to cases shown to be clearly within its purpose.\" United States v. The Elwoin, 272 US 633 (1926).",
      "position": "main"
    },
    {
      "type": "handwritten",
      "content": "1. The Fifth Circuit provided no independent analysis instead relying on United States v. Coutentos, 651 F.3d 809, 816-817 (8th Cir. 2011) and United States v. carpenter, 680 F.3d 1101, 1103 (9th Cir. 2012).",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005185",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [],
    "organizations": [
      "United States"
    ],
    "locations": [],
    "dates": [
      "10/12/21",
      "2016",
      "1975",
      "1926",
      "2011",
      "2012"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "338",
      "DOJ-OGR-00005185"
    ]
  },
  "additional_notes": "The document appears to be a court filing with handwritten notes in the margin and at the bottom of the page. The text is mostly printed, with some handwritten annotations."
}