mirror-epstein-docs/results/IMAGES001/DOJ-OGR-00001598.json

{
  "document_metadata": {
    "page_number": "18",
    "document_number": "18",
    "date": "07/10/20",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 18 of 26\n\n837 F.2d 48, 49-50 (2d Cir. 1988) (overturning district court's decision that defendant posed a flight risk based in part on the ground that the defendant took \"no steps\" to flee jurisdiction in three-week period between execution of search warrant at home and arrest); United States v. DiGiacomo, 746 F. Supp. 1176, 1179-80 (D. Mass. 1990) (concluding defendants did not present a flight risk because each of them \"for three years knew there was substantial evidence of the likely charges against them and did not attempt to flee before indictment\").\n\nIndeed, the absence of any allegation by the government that Ms. Maxwell was taking steps to leave the country at the time of her arrest is conspicuous. The government has offered no proof that she was making plans to leave the country. In fact, had the government alerted her counsel that she was about to be arrested, we would have arranged for Ms. Maxwell's prompt, voluntary surrender. Instead, the government arrested Ms. Maxwell without warning on the day before the July 4th holiday, thus ensuring that she would be in federal custody on the one-year anniversary of Epstein's arrest.\n\nc. Ms. Maxwell's Actions to Protect Herself From Intrusive Media Coverage and Death Threats Do Not Demonstrate an Intent to Flee\n\nFurthermore, the steps Ms. Maxwell took to leave the public eye after Epstein's arrest are not indicative of a risk of flight. The government notes that Ms. Maxwell dropped out of public view after Epstein's arrest, which the government seeks to portray as \"hiding\" from the law. The government further argues that she has taken several steps to avoid detection, including moving residences and switching her phone and email address. (Gov. Mem. at 8). But Ms. Maxwell did not take these steps to hide from law enforcement or evade prosecution. Instead, they were necessary measures that Ms. Maxwell was forced to",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 18 of 26",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "837 F.2d 48, 49-50 (2d Cir. 1988) (overturning district court's decision that defendant posed a flight risk based in part on the ground that the defendant took \"no steps\" to flee jurisdiction in three-week period between execution of search warrant at home and arrest); United States v. DiGiacomo, 746 F. Supp. 1176, 1179-80 (D. Mass. 1990) (concluding defendants did not present a flight risk because each of them \"for three years knew there was substantial evidence of the likely charges against them and did not attempt to flee before indictment\").",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Indeed, the absence of any allegation by the government that Ms. Maxwell was taking steps to leave the country at the time of her arrest is conspicuous. The government has offered no proof that she was making plans to leave the country. In fact, had the government alerted her counsel that she was about to be arrested, we would have arranged for Ms. Maxwell's prompt, voluntary surrender. Instead, the government arrested Ms. Maxwell without warning on the day before the July 4th holiday, thus ensuring that she would be in federal custody on the one-year anniversary of Epstein's arrest.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "c. Ms. Maxwell's Actions to Protect Herself From Intrusive Media Coverage and Death Threats Do Not Demonstrate an Intent to Flee",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "Furthermore, the steps Ms. Maxwell took to leave the public eye after Epstein's arrest are not indicative of a risk of flight. The government notes that Ms. Maxwell dropped out of public view after Epstein's arrest, which the government seeks to portray as \"hiding\" from the law. The government further argues that she has taken several steps to avoid detection, including moving residences and switching her phone and email address. (Gov. Mem. at 8). But Ms. Maxwell did not take these steps to hide from law enforcement or evade prosecution. Instead, they were necessary measures that Ms. Maxwell was forced to",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "14",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001598",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Maxwell",
      "Epstein"
    ],
    "organizations": [],
    "locations": [
      "Massachusetts"
    ],
    "dates": [
      "07/10/20",
      "July 4th"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 18",
      "837 F.2d 48",
      "746 F. Supp. 1176",
      "DOJ-OGR-00001598"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell. The text discusses the government's allegations and the defendant's actions. The document is well-formatted and free of significant damage or redactions."
}