{
  "document_metadata": {
    "page_number": "11",
    "document_number": "300",
    "date": "06/15/21",
    "document_type": "court document",
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    "has_stamps": false
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  "full_text": "Case 1:20-cr-00330-PAE Document 300 Filed 06/15/21 Page 11 of 32\nL4TPDAYS\n1 First and foremost, we believe, I think, this case pretty much revolves around deterrence and whether Ms. Days will be a productive member of society when she returns or when she gets released. I think that's probably the central issue for the sentencing proceeding.\n2 We do agree -- there's no way we can disagree -- that Ms. Days does have several prior convictions. That's a given, and we agree that Ms. Days has been convicted of a felony narcotics, that's a given as well. I guess, it's my opinion in doing these sentencing proceedings so many times, I think the focus of this particular case, if we isolate it, would be whether or not -- or what would be deterrence to Ms. Days and what we believe would be sufficient to ensure that when she comes back out, that she's productive. The minimum of that, not the maximum. What the least we can do to make sure she's deterred.\n3 In our opinion, we believe the 60 months is appropriate for a number of reasons. One, we believe that, like most defendants when they get arrested in Federal Court, we believe that rehabilitation starts at the time that they are arrested and, generally, if they're detained, at the time when they are detained.\n4 In this particular situation, we think that Ms. Days' rehabilitation and her deterrence started at that time, while in MCC and MDC. Start with MCC. Ms. Days made sure that she\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\nDOJ-OGR-00004754",
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      "content": "Case 1:20-cr-00330-PAE Document 300 Filed 06/15/21 Page 11 of 32",
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      "content": "L4TPDAYS",
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      "content": "1 First and foremost, we believe, I think, this case pretty much revolves around deterrence and whether Ms. Days will be a productive member of society when she returns or when she gets released. I think that's probably the central issue for the sentencing proceeding.\n2 We do agree -- there's no way we can disagree -- that Ms. Days does have several prior convictions. That's a given, and we agree that Ms. Days has been convicted of a felony narcotics, that's a given as well. I guess, it's my opinion in doing these sentencing proceedings so many times, I think the focus of this particular case, if we isolate it, would be whether or not -- or what would be deterrence to Ms. Days and what we believe would be sufficient to ensure that when she comes back out, that she's productive. The minimum of that, not the maximum. What the least we can do to make sure she's deterred.\n3 In our opinion, we believe the 60 months is appropriate for a number of reasons. One, we believe that, like most defendants when they get arrested in Federal Court, we believe that rehabilitation starts at the time that they are arrested and, generally, if they're detained, at the time when they are detained.\n4 In this particular situation, we think that Ms. Days' rehabilitation and her deterrence started at that time, while in MCC and MDC. Start with MCC. Ms. Days made sure that she",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004754",
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  ],
  "entities": {
    "people": [
      "Ms. Days"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C.",
      "Federal Court",
      "MCC",
      "MDC"
    ],
    "locations": [],
    "dates": [
      "06/15/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "300",
      "DOJ-OGR-00004754"
    ]
  },
  "additional_notes": "The document appears to be a court transcript or sentencing memorandum. The text is typed, and there are no visible redactions or damage."
}