{
  "document_metadata": {
    "page_number": "16",
    "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 16 of 22\n\ninstead opted to rely on the very uncommon definition of sexual abuse at §3509(a)(8) to save the day. See Esquivel-Quintana v. Sessions, 138 L. Ed. 2d 22 (2017) (finding that sexual abuse in a minor applies to those under 16). This is to say nothing of the fact sexual or physical abuse must be resolved as an expression. See Crocker v. Navient Sols. L.L.C. (5th Cir. 2019) (\"Courts must give effect to every clause or word if possible\"); Montclair v. Ramsdell 107 US 147, 152 (1883). Finally Dodge isn't even current on categorical holdings, United States v. Davis 139 S.Ct. 2319, n.10 (\"If anything, the statute's use of the present tense... supports a categorical reading.\") Section 3283's \"any offense involving\" is present tense, and doesn't mention \"conduct\". At the end of the day the Schneider decision was based on the sexual abuse definition at §3509(a)(8) not a categorical rationale. Notably that definition never came into play until the United States started misapplying §3283 to non Chapter 109A offenses in United States v. Panner 2007 U.S. Dist. Lexis 101192 (E.D. Cal. 2007) (Applying §3283 to Chapter 110 offense). See United States\n\n1. Added 221(l)(a) as sentence enhancement.\n\nDOJ-OGR-00005194",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 338 Filed 10/12/21 Page 16 of 22",
      "position": "header"
    },
    {
      "type": "handwritten",
      "content": "instead opted to rely on the very uncommon definition of sexual abuse at §3509(a)(8) to save the day. See Esquivel-Quintana v. Sessions, 138 L. Ed. 2d 22 (2017) (finding that sexual abuse in a minor applies to those under 16). This is to say nothing of the fact sexual or physical abuse must be resolved as an expression. See Crocker v. Navient Sols. L.L.C. (5th Cir. 2019) (\"Courts must give effect to every clause or word if possible\"); Montclair v. Ramsdell 107 US 147, 152 (1883). Finally Dodge isn't even current on categorical holdings, United States v. Davis 139 S.Ct. 2319, n.10 (\"If anything, the statute's use of the present tense... supports a categorical reading.\") Section 3283's \"any offense involving\" is present tense, and doesn't mention \"conduct\". At the end of the day the Schneider decision was based on the sexual abuse definition at §3509(a)(8) not a categorical rationale. Notably that definition never came into play until the United States started misapplying §3283 to non Chapter 109A offenses in United States v. Panner 2007 U.S. Dist. Lexis 101192 (E.D. Cal. 2007) (Applying §3283 to Chapter 110 offense). See United States",
      "position": "main body"
    },
    {
      "type": "handwritten",
      "content": "1. Added 221(l)(a) as sentence enhancement.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005194",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Esquivel-Quintana",
      "Crocker",
      "Navient",
      "Montclair",
      "Ramsdell",
      "Dodge",
      "Davis",
      "Schneider",
      "Panner"
    ],
    "organizations": [
      "United States",
      "Sessions",
      "Navient Sols. L.L.C.",
      "Courts",
      "DOJ"
    ],
    "locations": [
      "E.D. Cal"
    ],
    "dates": [
      "10/12/21",
      "2017",
      "2019",
      "1883",
      "2007"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "338",
      "§3509(a)(8)",
      "§3283",
      "221(l)(a)",
      "DOJ-OGR-00005194"
    ]
  },
  "additional_notes": "The document appears to be a court filing with handwritten notes. The text is mostly legible, but some words are difficult to read due to the handwriting quality."
}