{
  "document_metadata": {
    "page_number": "9",
    "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 9 of 22 4 when Congress corrected this as a technical correction1. Conforming Repeal in 1994 they knowingly did not include or reference the Child Abuse definitions of § 3509(a)(3)-(a)(9), (11) which appear to be for tort law and are clearly incompatible with the child definition at § 3509(a)(2). These civil definitions are for Reporting of abuse. See 18 USC § 2258 which references them from Title 42. See Ibarra v. Holder, 736 F.3d 902, 910 (10th Cir. 2013). (Civil and criminal definitions frequently differ). \"Courts do not lightly assume that Congress has omitted from its adopted text requirements that it nonetheless intends to apply.\" Jama v. Immigration & Customs Enforcement, 543 U.S. 335, 341 (2005). After one technical correction and two later amendments surely Congress knew what it was doing by not including or referencing the § 3509(a) definitions from § 2258. Furthermore, the limitation was misplaced. \"Proper statutory construction requires considering a phrase's placement and purpose in the statutory scheme...The meaning of statutory language plain or not depends on context.\" Brown v. Gardner, 513 US 115, 118 (1994). 1. see § 3509 (a)(10) sex crime definition DOJ-OGR-00005187",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 338 Filed 10/12/21 Page 9 of 22 4",
      "position": "header"
    },
    {
      "type": "handwritten",
      "content": "when Congress corrected this as a technical correction1. Conforming Repeal in 1994 they knowingly did not include or reference the Child Abuse definitions of § 3509(a)(3)-(a)(9), (11) which appear to be for tort law and are clearly incompatible with the child definition at § 3509(a)(2). These civil definitions are for Reporting of abuse. See 18 USC § 2258 which references them from Title 42. See Ibarra v. Holder, 736 F.3d 902, 910 (10th Cir. 2013). (Civil and criminal definitions frequently differ). \"Courts do not lightly assume that Congress has omitted from its adopted text requirements that it nonetheless intends to apply.\" Jama v. Immigration & Customs Enforcement, 543 U.S. 335, 341 (2005). After one technical correction and two later amendments surely Congress knew what it was doing by not including or referencing the § 3509(a) definitions from § 2258. Furthermore, the limitation was misplaced. \"Proper statutory construction requires considering a phrase's placement and purpose in the statutory scheme...The meaning of statutory language plain or not depends on context.\" Brown v. Gardner, 513 US 115, 118 (1994). 1. see § 3509 (a)(10) sex crime definition",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005187",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Holder",
      "Gardner"
    ],
    "organizations": [
      "Immigration & Customs Enforcement"
    ],
    "locations": [],
    "dates": [
      "10/12/21",
      "1994",
      "2005"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "338",
      "§ 3509(a)(3)-(a)(9)",
      "§ 3509(a)(2)",
      "§ 2258",
      "§ 3509(a)",
      "§ 3509 (a)(10)"
    ]
  },
  "additional_notes": "The document appears to be a court filing with handwritten notes. The handwriting is clear and legible. There are no visible redactions or damage to the document."
}