{
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    "page_number": "64",
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    "date": "07/24/19",
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  "full_text": "Case 1:19-cr-00490-RMB Document 36 Filed 07/24/19 Page 64 of 74 64\n1\nHere's how we know that it's not the case that someone\n2\nwho doesn't commit a crime for 15 years, if that is the case\n3\nhere, but for someone who has not been convicted of a crime for\n4\n15 years, that that establishes the rebuttal of presumption.\n5\nThe reason we know that's not the case is because someone who is 70 years old who is arrested for the very first time who's lived a law-abiding life for 70 years is still subject to the presumption.\n6\n7\n8\nSo the idea that if you're convicted of a crime and then you're not convicted of a crime for a while, that that itself rebuts the presumption, really turns the presumption on its head. That simply doesn't make any sense, your Honor.\n9\n10\n11\n12\nWith respect to the idea that it's old conduct which is related, the statute of limitations goes very far back. And in fact, there is no explanation for this type of crime.\n13\n14\n15\nCongress has decided that if you commit sex crimes against children, you will have to look over your shoulder for the rest of your life. And that's as it should be, your Honor.\n16\n17\n18\nCertainly there is no argument here from the defense regarding the statute of limitations.\n19\n20\nThe defense has argued a couple different times about a couple different things that if there was a crime, it would have been charged. So in discussions of obstruction, in discussions of witness tampering.\n21\n22\n23\nYour Honor, the idea that if there was misconduct it\n24\n25\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00000574",
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      "content": "Case 1:19-cr-00490-RMB Document 36 Filed 07/24/19 Page 64 of 74 64",
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      "type": "printed",
      "content": "Here's how we know that it's not the case that someone who doesn't commit a crime for 15 years, if that is the case here, but for someone who has not been convicted of a crime for 15 years, that that establishes the rebuttal of presumption. The reason we know that's not the case is because someone who is 70 years old who is arrested for the very first time who's lived a law-abiding life for 70 years is still subject to the presumption. So the idea that if you're convicted of a crime and then you're not convicted of a crime for a while, that that itself rebuts the presumption, really turns the presumption on its head. That simply doesn't make any sense, your Honor. With respect to the idea that it's old conduct which is related, the statute of limitations goes very far back. And in fact, there is no explanation for this type of crime. Congress has decided that if you commit sex crimes against children, you will have to look over your shoulder for the rest of your life. And that's as it should be, your Honor. Certainly there is no argument here from the defense regarding the statute of limitations. The defense has argued a couple different times about a couple different things that if there was a crime, it would have been charged. So in discussions of obstruction, in discussions of witness tampering. Your Honor, the idea that if there was misconduct it",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "content": "DOJ-OGR-00000574",
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  "entities": {
    "people": [],
    "organizations": [
      "Congress",
      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "locations": [],
    "dates": [
      "07/24/19"
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      "DOJ-OGR-00000574",
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  "additional_notes": "The document appears to be a court transcript or legal document. The text is typed and there are no visible handwritten notes or stamps. The document is from a court case with the reference number 1:19-cr-00490-RMB."
}