{
  "document_metadata": {
    "page_number": "54",
    "document_number": "382",
    "date": "10/29/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 382 Filed 10/29/21 Page 54 of 69\n\nVI. CERTAIN EVIDENCE OR ARGUMENT THAT MINOR VICTIMS CONSENTED TO SEXUAL ABUSE MAY BE ADMISSIBLE.\n\nThe government seeks blanket preclusion of evidence or argument that the accusers \"consented to sexual abuse.\" It bears noting that the Indictment does not charge sexual abuse.\n\nThe charged offenses allege \"sexual activity\" (Counts One through Four) and \"sex trafficking\" (Counts Five and Six).\n\nThe age of consent for sexual contact purposes varies by jurisdiction. The offenses charged in the S2 Indictment allege sexual activity with minors and focus on age, rather than mental or physical incapacity. Accordingly, to qualify as sexual activity with a minor, the statute must prohibit sexual acts based at least on age of the purported victim. See Esquival-Quintana v. Sessions, 137 S. Ct. 1562 (2017). As the Supreme Court noted, \"state criminal codes aid our interpretation of 'sexual abuse of a minor' by offering useful context.\" Id. at 1577 n.3. For purposes of sexual activity alleged in this case, the definition of \"minor\" varies among states and nations: New York defines \"minor\" as a person under the age of 1728; Florida: under the age of 1829; United Kingdom: under the age of 1630; France: under the age of 15.31 New Mexico does not have a specific age of consent statute but criminalizes all sexual contact of a minor under the age of 13 when no coercion or force is involved.32 In the context of the charged offense focusing\n\n28 NY Penal Law Ann. § 130.03(3)(a).\n29 Fla. Stat. § 794.05(1). At the time of the charged offenses in Counts Five and Six, individuals under the age of 18 could be charges with prostitution. In 2016, the law was changed, decriminalizing prostitution of by individuals under the age of 18.\n30 Sexual Offences Act, Chap. 44.\n31 Penal Code, Article 227-25.\n32 NM Stat. Ann. § 30-9-13(A)(1). New Mexico criminalizes sexual contact of minor on a child 13 to 18 years old when coercion is involved. § 30-9-12(A)(2).\n\n46\nDOJ-OGR-00005509",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 382 Filed 10/29/21 Page 54 of 69",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "VI. CERTAIN EVIDENCE OR ARGUMENT THAT MINOR VICTIMS CONSENTED TO SEXUAL ABUSE MAY BE ADMISSIBLE.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The government seeks blanket preclusion of evidence or argument that the accusers \"consented to sexual abuse.\" It bears noting that the Indictment does not charge sexual abuse.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The charged offenses allege \"sexual activity\" (Counts One through Four) and \"sex trafficking\" (Counts Five and Six).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The age of consent for sexual contact purposes varies by jurisdiction. The offenses charged in the S2 Indictment allege sexual activity with minors and focus on age, rather than mental or physical incapacity. Accordingly, to qualify as sexual activity with a minor, the statute must prohibit sexual acts based at least on age of the purported victim. See Esquival-Quintana v. Sessions, 137 S. Ct. 1562 (2017). As the Supreme Court noted, \"state criminal codes aid our interpretation of 'sexual abuse of a minor' by offering useful context.\" Id. at 1577 n.3. For purposes of sexual activity alleged in this case, the definition of \"minor\" varies among states and nations: New York defines \"minor\" as a person under the age of 1728; Florida: under the age of 1829; United Kingdom: under the age of 1630; France: under the age of 15.31 New Mexico does not have a specific age of consent statute but criminalizes all sexual contact of a minor under the age of 13 when no coercion or force is involved.32 In the context of the charged offense focusing",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "28 NY Penal Law Ann. § 130.03(3)(a).\n29 Fla. Stat. § 794.05(1). At the time of the charged offenses in Counts Five and Six, individuals under the age of 18 could be charges with prostitution. In 2016, the law was changed, decriminalizing prostitution of by individuals under the age of 18.\n30 Sexual Offences Act, Chap. 44.\n31 Penal Code, Article 227-25.\n32 NM Stat. Ann. § 30-9-13(A)(1). New Mexico criminalizes sexual contact of minor on a child 13 to 18 years old when coercion is involved. § 30-9-12(A)(2).",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "46",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00005509",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Esquival-Quintana"
    ],
    "organizations": [
      "Supreme Court"
    ],
    "locations": [
      "New York",
      "Florida",
      "United Kingdom",
      "France",
      "New Mexico"
    ],
    "dates": [
      "10/29/21",
      "2016",
      "2017"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "382",
      "DOJ-OGR-00005509"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case involving sexual offenses. The text discusses the age of consent and the definition of 'minor' in various jurisdictions. There are no visible redactions or damage to the document."
}