{
  "document_metadata": {
    "page_number": "16",
    "document_number": "20",
    "date": "07/16/19",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:19-cr-00490-RMB Document 20 Filed 07/16/19 Page 16 of 24 16\n\nSo this is a huge problem for the department and what solution ensues, and I suggest the solution that ensued is this indictment. To us, this indictment is essentially a do-over. The allegations are from 2002 to 2005. This is old stuff. This is ancient stuff. This is the very stuff that was investigated by the feds in Florida, a sophisticated three-year investigation. Two of the alleged victims in this indictment are from Florida. The indictment here tracks the conduct that was investigated in Florida back before the agreement was reached. Obviously we need to get discovery to find out just how intricately linked the investigation back in Florida is with what's going on here. We do know we are talking about ancient conduct. We do know we are talking about facts that are from 2002 to 2005, facts that were known to the United States prosecutors before they entered into the NPA, the declination. This is essentially a redo. That's how it feels to us. And if we are correct, that should chill the blood of every defense attorney who negotiates a deal with the United States.\n\nIn addition, we have -- the central allegation here is trafficking, and obviously it is useful and relevant to make inquiry as to why the trafficking law was passed. It is to cover abhorrent conduct, where young girls are kidnapped, they are fooled, they are forced to come usually to unfamiliar places, work in brothels where they service 15, 20 guys in a\n\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\n\nDOJ-OGR-00000421",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:19-cr-00490-RMB Document 20 Filed 07/16/19 Page 16 of 24 16",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "So this is a huge problem for the department and what solution ensues, and I suggest the solution that ensued is this indictment. To us, this indictment is essentially a do-over. The allegations are from 2002 to 2005. This is old stuff. This is ancient stuff. This is the very stuff that was investigated by the feds in Florida, a sophisticated three-year investigation. Two of the alleged victims in this indictment are from Florida. The indictment here tracks the conduct that was investigated in Florida back before the agreement was reached. Obviously we need to get discovery to find out just how intricately linked the investigation back in Florida is with what's going on here. We do know we are talking about ancient conduct. We do know we are talking about facts that are from 2002 to 2005, facts that were known to the United States prosecutors before they entered into the NPA, the declination. This is essentially a redo. That's how it feels to us. And if we are correct, that should chill the blood of every defense attorney who negotiates a deal with the United States.",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "In addition, we have -- the central allegation here is trafficking, and obviously it is useful and relevant to make inquiry as to why the trafficking law was passed. It is to cover abhorrent conduct, where young girls are kidnapped, they are fooled, they are forced to come usually to unfamiliar places, work in brothels where they service 15, 20 guys in a",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00000421",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [],
    "organizations": [
      "United States",
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [
      "Florida"
    ],
    "dates": [
      "2002",
      "2005",
      "07/16/19"
    ],
    "reference_numbers": [
      "1:19-cr-00490-RMB",
      "Document 20",
      "DOJ-OGR-00000421"
    ]
  },
  "additional_notes": "The document appears to be a court transcript or legal document discussing a case involving human trafficking allegations. 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."
}