{
  "document_metadata": {
    "page_number": "6",
    "document_number": "4",
    "date": "07/02/20",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 4 Filed 07/02/20 Page 6 of 10\na\nacts are so serious that both crimes carry a statutory presumption that no condition or combination\nof conditions will reasonably assure the appearance of the defendant as required. 18 U.S.C. § 3142\n(e)(3)(E). The defendant repeatedly engaged in this conduct, targeting girls as young as 14 years\nold, for a period of years, and involving multiple minors.\nThese offenses carry significant penalties, and the defendant faces up to 35 years'\nimprisonment if convicted. The possibility of a substantial sentence is a significant factor in\nassessing the risk of flight. See United States v. Moscaritolo, No. 10 Cr. 4 (JL), 2010 WL 309679,\nat *2 (D.N.H. Jan. 26, 2010) (\"[T]he steeper the potential sentence, the more probable the flight\nrisk is, especially considering the strong case of the government . . . .\") (quoting United States v.\nAlindato-Perez, 627 F. Supp. 2d 58, 66 (D.P.R. 2009)). Here, the defendant is facing a statutory\nmaximum of decades in prison. This fact alone would provide a compelling incentive for anyone\nto flee from prosecution, but the incentive to flee is especially strong for this defendant, who, at\nage 58, faces the very real prospect of spending a substantial portion of the rest of her life in prison.\nThe strength of the evidence in this case underscores the risk that the defendant will become\na fugitive. As the facts set forth in the Indictment make plain, the evidence in this case is strong.\nMultiple victims have provided detailed, credible, and corroborated information against the\ndefendant. The victims are backed up contemporaneous documents, records, witness testimony,\nand other evidence. For example, flight records, diary entries, business records, and other evidence\ncorroborate the victims' account of events. This will be compelling evidence of guilt at any trial\nin this case, which weighs heavily in favor of detention.\nThe passage of time between the defendant's conduct and these charges does not counsel\notherwise. As an initial matter, all of the conduct is timely charged, pursuant to 18 U.S.C. § 3283,\nwhich was amended in 2003 to extend the limitations period for conduct that was timely as of the\n5\nDOJ-OGR-00001492",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 4 Filed 07/02/20 Page 6 of 10",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "acts are so serious that both crimes carry a statutory presumption that no condition or combination\nof conditions will reasonably assure the appearance of the defendant as required. 18 U.S.C. § 3142\n(e)(3)(E). The defendant repeatedly engaged in this conduct, targeting girls as young as 14 years\nold, for a period of years, and involving multiple minors.\nThese offenses carry significant penalties, and the defendant faces up to 35 years'\nimprisonment if convicted. The possibility of a substantial sentence is a significant factor in\nassessing the risk of flight. See United States v. Moscaritolo, No. 10 Cr. 4 (JL), 2010 WL 309679,\nat *2 (D.N.H. Jan. 26, 2010) (\"[T]he steeper the potential sentence, the more probable the flight\nrisk is, especially considering the strong case of the government . . . .\") (quoting United States v.\nAlindato-Perez, 627 F. Supp. 2d 58, 66 (D.P.R. 2009)). Here, the defendant is facing a statutory\nmaximum of decades in prison. This fact alone would provide a compelling incentive for anyone\nto flee from prosecution, but the incentive to flee is especially strong for this defendant, who, at\nage 58, faces the very real prospect of spending a substantial portion of the rest of her life in prison.",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "The strength of the evidence in this case underscores the risk that the defendant will become\na fugitive. As the facts set forth in the Indictment make plain, the evidence in this case is strong.\nMultiple victims have provided detailed, credible, and corroborated information against the\ndefendant. The victims are backed up contemporaneous documents, records, witness testimony,\nand other evidence. For example, flight records, diary entries, business records, and other evidence\ncorroborate the victims' account of events. This will be compelling evidence of guilt at any trial\nin this case, which weighs heavily in favor of detention.",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "The passage of time between the defendant's conduct and these charges does not counsel\notherwise. As an initial matter, all of the conduct is timely charged, pursuant to 18 U.S.C. § 3283,\nwhich was amended in 2003 to extend the limitations period for conduct that was timely as of the",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "5",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001492",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [],
    "organizations": [
      "United States"
    ],
    "locations": [
      "D.N.H.",
      "D.P.R."
    ],
    "dates": [
      "07/02/20",
      "Jan. 26, 2010",
      "2003"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 4",
      "10 Cr. 4 (JL)",
      "DOJ-OGR-00001492"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text discusses the defendant's risk of flight and the strength of the evidence against them. The document is well-formatted and free of significant damage or redactions."
}