{
  "document_metadata": {
    "page_number": "10",
    "document_number": "388",
    "date": "10/29/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 388 Filed 10/29/21 Page 10 of 14\nsubmissions as evidence of flight. Ms. Maxwell supported her position with letters from her spouse and other friends and family members, as well as an affidavit from a witness to the circumstances of her arrest, all of which corroborated Ms. Maxwell's explanation that she took these measures to protect herself and her family from the press and others who would seek to harm them. These facts categorically do not support an inference that Ms. Maxwell intended to flee.\nThe Second Circuit's analysis in Al-Sadawi is instructive. In Al-Sadawi, the defendant's wife attempted to obtain expedited U.S. passports for herself and the defendant and purchased airline tickets for the two of them (but not their four children) to fly to Egypt two-and-a-half months after the defendant's co-conspirator was arrested. 432 F.3d at 423. The trial court allowed the government to introduce this evidence to show the defendant's intent to flee and to argue that it was proof of consciousness of guilt. Id. at 424. The Second Circuit disagreed and highlighted several flaws in the government's theory. First, Al-Sadawi had a valid Egyptian passport and could have traveled at any point up to the time of his arrest. Id. Second, \"he had known for at least six months\" that he was under government surveillance and that he had been directly implicated in the subject of the government's investigation, but \"did nothing consistent with an intention to flee.\" Id. at 424-25. Third, when Al-Sadawi was arrested an hour before the flight was scheduled to depart, there was no evidence that he intended to board the flight - he had not packed his bags, he did not have the tickets in his possession, and he had not left for the airport. Id. at 425. The circuit court noted that the facts \"differ[ed] sharply\" from those of United States v. Salameh, 152 F.3d 88 (2d Cir. 1998) (per curiam), where the court found the jury could properly infer consciousness of guilt from evidence that the defendant fled the country one day after the crime was committed. Al-Sadawi, 432 F.3d at 425 (citing Salameh, 152 F.3d at 7",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 388 Filed 10/29/21 Page 10 of 14",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "submissions as evidence of flight. Ms. Maxwell supported her position with letters from her spouse and other friends and family members, as well as an affidavit from a witness to the circumstances of her arrest, all of which corroborated Ms. Maxwell's explanation that she took these measures to protect herself and her family from the press and others who would seek to harm them. These facts categorically do not support an inference that Ms. Maxwell intended to flee.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "The Second Circuit's analysis in Al-Sadawi is instructive. In Al-Sadawi, the defendant's wife attempted to obtain expedited U.S. passports for herself and the defendant and purchased airline tickets for the two of them (but not their four children) to fly to Egypt two-and-a-half months after the defendant's co-conspirator was arrested. 432 F.3d at 423. The trial court allowed the government to introduce this evidence to show the defendant's intent to flee and to argue that it was proof of consciousness of guilt. Id. at 424. The Second Circuit disagreed and highlighted several flaws in the government's theory. First, Al-Sadawi had a valid Egyptian passport and could have traveled at any point up to the time of his arrest. Id. Second, \"he had known for at least six months\" that he was under government surveillance and that he had been directly implicated in the subject of the government's investigation, but \"did nothing consistent with an intention to flee.\" Id. at 424-25. Third, when Al-Sadawi was arrested an hour before the flight was scheduled to depart, there was no evidence that he intended to board the flight - he had not packed his bags, he did not have the tickets in his possession, and he had not left for the airport. Id. at 425. The circuit court noted that the facts \"differ[ed] sharply\" from those of United States v. Salameh, 152 F.3d 88 (2d Cir. 1998) (per curiam), where the court found the jury could properly infer consciousness of guilt from evidence that the defendant fled the country one day after the crime was committed. Al-Sadawi, 432 F.3d at 425 (citing Salameh, 152 F.3d at 7",
      "position": "main body"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell",
      "Al-Sadawi",
      "Salameh"
    ],
    "organizations": [
      "Second Circuit"
    ],
    "locations": [
      "Egypt",
      "U.S."
    ],
    "dates": [
      "10/29/21",
      "1998"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 388",
      "432 F.3d",
      "152 F.3d 88"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell. The text discusses the Second Circuit's analysis in Al-Sadawi and its relevance to the current case. The document is well-formatted and free of significant damage or redactions."
}