{
  "document_metadata": {
    "page_number": "18",
    "document_number": "20",
    "date": "07/16/19",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
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  "full_text": "Case 1:19-cr-00490-RMB Document 20 Filed 07/16/19 Page 18 of 24 18\n1 traditional issues that we look at, the issues involved, let's\n2 start with that, we believe we have extremely powerful motions\n3 relating to the government seeking two bites at the apple and\n4 for due process reasons, double jeopardy reasons, we don't\n5 think that will stand. We also think fundamentally what's at\n6 issue here is not trafficking. That's not why the statute was\n7 passed.\n8 The risk to others, what we have here is at least ten\n9 years post incarceration in the State of Florida of conduct\n10 that has never been challenged by anyone until now. The\n11 registration requirements are onerous. He is under constant\n12 surveillance. Law enforcement knows, if they choose to look,\n13 exactly where he is at any time.\n14 The risk of flight, what is true is from the moment of\n15 Judge Marra's litigation in the Southern District of Florida,\n16 the defendant knew that there would be challenges to the NPA.\n17 From 2013 on, there were representations made in court that\n18 that challenge was ongoing, and the defendant never sought to\n19 flee, never anticipated a time when he would flee, continued to\n20 live his law-abiding life. So the risk of flight, I think, is\n21 dramatically overstated in the government's presentation.\n22 I think the traditional remedies that the court finds\n23 appropriate in case after case -- a large cash bond; passport\n24 relinquished; waiving extradition; a bracelet on; some form of\n25 supervision that is adequate to guarantee his appearance, it\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00000423",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:19-cr-00490-RMB Document 20 Filed 07/16/19 Page 18 of 24 18",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "1 traditional issues that we look at, the issues involved, let's\n2 start with that, we believe we have extremely powerful motions\n3 relating to the government seeking two bites at the apple and\n4 for due process reasons, double jeopardy reasons, we don't\n5 think that will stand. We also think fundamentally what's at\n6 issue here is not trafficking. That's not why the statute was\n7 passed.\n8 The risk to others, what we have here is at least ten\n9 years post incarceration in the State of Florida of conduct\n10 that has never been challenged by anyone until now. The\n11 registration requirements are onerous. He is under constant\n12 surveillance. Law enforcement knows, if they choose to look,\n13 exactly where he is at any time.\n14 The risk of flight, what is true is from the moment of\n15 Judge Marra's litigation in the Southern District of Florida,\n16 the defendant knew that there would be challenges to the NPA.\n17 From 2013 on, there were representations made in court that\n18 that challenge was ongoing, and the defendant never sought to\n19 flee, never anticipated a time when he would flee, continued to\n20 live his law-abiding life. So the risk of flight, I think, is\n21 dramatically overstated in the government's presentation.\n22 I think the traditional remedies that the court finds\n23 appropriate in case after case -- a large cash bond; passport\n24 relinquished; waiving extradition; a bracelet on; some form of\n25 supervision that is adequate to guarantee his appearance, it",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00000423",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Judge Marra"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [
      "Florida",
      "Southern District of Florida"
    ],
    "dates": [
      "07/16/19",
      "2013"
    ],
    "reference_numbers": [
      "1:19-cr-00490-RMB",
      "Document 20",
      "DOJ-OGR-00000423"
    ]
  },
  "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."
}