{
  "document_metadata": {
    "page_number": "22",
    "document_number": "36",
    "date": "07/24/19",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:19-cr-00490-RMB Document 36 Filed 07/24/19 Page 22 of 74\n\n1\nBefore 1984, before the Bail Reform Act, there was an\n2\nEighth Amendment that the United States Supreme Court\nguaranteed bail to anyone who wasn't charged with a capital offense, and the justices wrote continuously that was because detention impairs a defendant's ability to prepare a defense.\n\n6\nIn this case, the government has told us there's going to be an enormous amount of discovery. The stakes are grave, and one of the most important reasons for Mr. Epstein's release is to permit him the right to fully prepare a defense.\n\n10\nThe second reason that before 1984 there was an entitlement to bail was because of the presumption of innocence and because of the basic premise of the American criminal justice system that you don't punish first and have a trial second; that non-convicted citizens don't get detained which is essentially a label for punishment.\n\n16\nThere is no way to replace the freedom if Mr. Epstein is to prevail on these charges. If the government's over a decade of delay is found prejudicial by the Court which thereafter dismisses the charges, if the Court determines that the nonpros agreement was circumvented by the prosecutors in Florida when they encouraged their witnesses and their witnesses' lawyers to go to the Southern District and catalyze and create a case. That's unique.\n\n23\nThese were not two silos, the Southern District of Florida and the Southern District of New York. It is more than\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00000532",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:19-cr-00490-RMB Document 36 Filed 07/24/19 Page 22 of 74",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Before 1984, before the Bail Reform Act, there was an Eighth Amendment that the United States Supreme Court guaranteed bail to anyone who wasn't charged with a capital offense, and the justices wrote continuously that was because detention impairs a defendant's ability to prepare a defense. In this case, the government has told us there's going to be an enormous amount of discovery. The stakes are grave, and one of the most important reasons for Mr. Epstein's release is to permit him the right to fully prepare a defense. The second reason that before 1984 there was an entitlement to bail was because of the presumption of innocence and because of the basic premise of the American criminal justice system that you don't punish first and have a trial second; that non-convicted citizens don't get detained which is essentially a label for punishment. There is no way to replace the freedom if Mr. Epstein is to prevail on these charges. If the government's over a decade of delay is found prejudicial by the Court which thereafter dismisses the charges, if the Court determines that the nonpros agreement was circumvented by the prosecutors in Florida when they encouraged their witnesses and their witnesses' lawyers to go to the Southern District and catalyze and create a case. That's unique. These were not two silos, the Southern District of Florida and the Southern District of New York. It is more than",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00000532",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Epstein"
    ],
    "organizations": [
      "United States Supreme Court",
      "Southern District Reporters, P.C."
    ],
    "locations": [
      "Florida",
      "New York",
      "Southern District of Florida",
      "Southern District of New York"
    ],
    "dates": [
      "1984",
      "07/24/19"
    ],
    "reference_numbers": [
      "1:19-cr-00490-RMB",
      "Document 36",
      "DOJ-OGR-00000532"
    ]
  },
  "additional_notes": "The document appears to be a court transcript or legal document related to the case of Mr. Epstein. The text is printed and there are no visible handwritten notes or stamps. The document includes a header with case information and a footer with the name and contact information of the court reporters."
}