{
  "document_metadata": {
    "page_number": "14",
    "document_number": "11",
    "date": "July 12, 2019",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 14 of 14\n\nHonorable Richard M. Berman\nUnited States District Judge\nJuly 12, 2019\nPage 14\n\nSecond, he is also wrong on the law. Courts have found that Section 1591 applied to both suppliers and consumers of commercial sex acts. See, e.g., United States v. Jungers, 702 F.3d 1066, 1069 (8th Cir. 2013) (upholding the conviction of a defendant who attempted to pay for oral sex from an underage girl and explaining: \"The sole issue raised on appeal is whether '[t]he plain and unambiguous provisions of 18 U.S.C. § 1591 apply to both suppliers and consumers of commercial sex acts.' We conclude they do.\") (alteration in original). The lone case cited by the defendant, Fierro v. Taylor, No. 11 Civ. 8573, 2012 WL 13042630 (S.D.N.Y. July 2, 2012), relied heavily on the statutory interpretation undertaken by two district courts in the District of South Dakota, United States v. Bonestroo, No. 11 Cr. 40016, 2012 WL 13704 (D.S.D. Jan. 4, 2012), and United States v. Jungers, 11 Cr. 40018, 2011 WL 6046495 (D.S.D. Dec. 5, 2011), both of which were explicitly overruled by the Eighth Circuit decision in Jungers, 702 F.3d 1066. In the seven years since Fierro has been decided, it does not appear to have been cited by a single other court. Additionally, other cases in this Circuit and elsewhere have upheld convictions of procurers or customers. See United States v. O'Connor, 650 F.3d 839 (2d Cir. 2011) (upholding convictions under Section 1591 of both the buyer and seller of a child); United States v. Cook, 782 F.3d 983 (8th Cir. 2015) (rejecting a constitutional challenge that Section 1591 would be void for vagueness if applied to purchasers); United States v. Mikoloyck, No. 09 Cr. 036, 2009 WL 4798900 (W.D. Mo. Dec. 7, 2009) (\"contrary to defendant's argument, 18 U.S.C. § 1591 clearly applies to those who attempt to purchase underage sex, not merely the pimps of actual exploited children\") (citing United States v. Roberts, 174 F. App'x 475 (11th Cir. 2006) (in which defendant was convicted under sections 1591(a) and 1594(a) even though no actual children were involved)).\n\nCONCLUSION\n\nAs set forth above, the defendant's proposed bail package is insufficient and insubstantial. Pretrial Services, victims, and the Government all recommend pretrial detention due to the unusual and concerning confluence of factors in this case, including the defendant's extraordinary wealth, demonstrated willingness to interfere with victims and witnesses, continued possession of lewd photographs of young females, and both the incentive and means to flee prosecution.\n\nVery truly yours,\n\nGEOFFREY S. BERMAN\nUnited States Attorney\n\nBy: _________________________________\nAlex Rossmiller / Alison Moe / Maurene Comey\nAssistant United States Attorney\nSouthern District of New York\nTel: (212) 637-2415 / 2225 / 2324\n\nCc: Martin Weinberg, Esq., and Reid Weingarten, Esq., counsel for defendant\n\nDOJ-OGR-00000342",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 14 of 14",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Honorable Richard M. Berman\nUnited States District Judge\nJuly 12, 2019\nPage 14",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Second, he is also wrong on the law. Courts have found that Section 1591 applied to both suppliers and consumers of commercial sex acts. See, e.g., United States v. Jungers, 702 F.3d 1066, 1069 (8th Cir. 2013) (upholding the conviction of a defendant who attempted to pay for oral sex from an underage girl and explaining: \"The sole issue raised on appeal is whether '[t]he plain and unambiguous provisions of 18 U.S.C. § 1591 apply to both suppliers and consumers of commercial sex acts.' We conclude they do.\") (alteration in original). The lone case cited by the defendant, Fierro v. Taylor, No. 11 Civ. 8573, 2012 WL 13042630 (S.D.N.Y. July 2, 2012), relied heavily on the statutory interpretation undertaken by two district courts in the District of South Dakota, United States v. Bonestroo, No. 11 Cr. 40016, 2012 WL 13704 (D.S.D. Jan. 4, 2012), and United States v. Jungers, 11 Cr. 40018, 2011 WL 6046495 (D.S.D. Dec. 5, 2011), both of which were explicitly overruled by the Eighth Circuit decision in Jungers, 702 F.3d 1066. In the seven years since Fierro has been decided, it does not appear to have been cited by a single other court. Additionally, other cases in this Circuit and elsewhere have upheld convictions of procurers or customers. See United States v. O'Connor, 650 F.3d 839 (2d Cir. 2011) (upholding convictions under Section 1591 of both the buyer and seller of a child); United States v. Cook, 782 F.3d 983 (8th Cir. 2015) (rejecting a constitutional challenge that Section 1591 would be void for vagueness if applied to purchasers); United States v. Mikoloyck, No. 09 Cr. 036, 2009 WL 4798900 (W.D. Mo. Dec. 7, 2009) (\"contrary to defendant's argument, 18 U.S.C. § 1591 clearly applies to those who attempt to purchase underage sex, not merely the pimps of actual exploited children\") (citing United States v. Roberts, 174 F. App'x 475 (11th Cir. 2006) (in which defendant was convicted under sections 1591(a) and 1594(a) even though no actual children were involved)).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "CONCLUSION",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "As set forth above, the defendant's proposed bail package is insufficient and insubstantial. Pretrial Services, victims, and the Government all recommend pretrial detention due to the unusual and concerning confluence of factors in this case, including the defendant's extraordinary wealth, demonstrated willingness to interfere with victims and witnesses, continued possession of lewd photographs of young females, and both the incentive and means to flee prosecution.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Very truly yours,\n\nGEOFFREY S. BERMAN\nUnited States Attorney",
      "position": "bottom"
    },
    {
      "type": "handwritten",
      "content": "",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "By: _________________________________\nAlex Rossmiller / Alison Moe / Maurene Comey\nAssistant United States Attorney\nSouthern District of New York\nTel: (212) 637-2415 / 2225 / 2324",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "Cc: Martin Weinberg, Esq., and Reid Weingarten, Esq., counsel for defendant",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00000342",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Richard M. Berman",
      "Geoffrey S. Berman",
      "Alex Rossmiller",
      "Alison Moe",
      "Maurene Comey",
      "Martin Weinberg",
      "Reid Weingarten"
    ],
    "organizations": [
      "United States District Court",
      "United States Attorney's Office",
      "Pretrial Services",
      "Government"
    ],
    "locations": [
      "New York",
      "South Dakota"
    ],
    "dates": [
      "July 12, 2019",
      "July 2, 2012",
      "January 4, 2012",
      "December 5, 2011",
      "December 7, 2009"
    ],
    "reference_numbers": [
      "1:19-cr-00490-RMB",
      "11",
      "DOJ-OGR-00000342"
    ]
  },
  "additional_notes": "The document appears to be a court filing in a criminal case, discussing the defendant's proposed bail package and recommending pretrial detention. The text is well-formatted and easy to read, with clear headings and section breaks. There are no visible redactions or damage to the document."
}