mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00003672.json

{
  "document_metadata": {
    "page_number": "20 of 22",
    "document_number": "206",
    "date": "04/16/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 206 Filed 04/16/21 Page 20 of 22\nage—to travel with the requisite intent. 18 U.S.C. § 2422(a). Section 2423(a) requires only the transportation of a child with the requisite intent, 18 U.S.C. § 2423(a); it does not necessarily entail “the employment, use, persuasion, inducement, enticement, or coercion of a child” to do anything other than travel. If a defendant entices an adult to travel for the purpose of engaging in unlawful sexual activity, a § 2422(a) offense has been committed, but no sexual abuse of a child has occurred. If a defendant transports a minor with the intent (unknownst to the minor) that the minor will engage in sexual activity, no sexual activity occurs, and there is no “employment, use, persuasion, inducement, enticement, or coercion” to engage in sexual activity, a § 2423(a) offense has been committed, but no sexual abuse of a child has occurred.\nWhile the government cites several cases in which courts have found § 3283 applicable to particular statutes, it cites only one case in which either a § 2422(a) or § 2423(a) offense has been held to involve “sexual abuse” within the meaning of § 3283. In United States v. Vickers, No. 13 Cr. 128 (RJA) (HKS), 2014 WL 1838255 (W.D.N.Y. May 8, 2014), the court held that a § 2423(a) offense involved sexual abuse; instead, the court used a fact-based approach. Id. at *11 (“defendant Vickers is charged with transportation of a minor in violation of [§ 2423(a)] and it is alleged that the defendant did have sexual contact with Victim 1”) (emphasis added). No court has held that either the enticement of an individual to travel or the transportation of a minor necessarily entails “sexual abuse” within the meaning of § 3283. It does not. The government therefore cannot and should not prevail.\n15\nDOJ-OGR-00003672",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 206 Filed 04/16/21 Page 20 of 22",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "age—to travel with the requisite intent. 18 U.S.C. § 2422(a). Section 2423(a) requires only the transportation of a child with the requisite intent, 18 U.S.C. § 2423(a); it does not necessarily entail “the employment, use, persuasion, inducement, enticement, or coercion of a child” to do anything other than travel. If a defendant entices an adult to travel for the purpose of engaging in unlawful sexual activity, a § 2422(a) offense has been committed, but no sexual abuse of a child has occurred. If a defendant transports a minor with the intent (unknownst to the minor) that the minor will engage in sexual activity, no sexual activity occurs, and there is no “employment, use, persuasion, inducement, enticement, or coercion” to engage in sexual activity, a § 2423(a) offense has been committed, but no sexual abuse of a child has occurred.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "While the government cites several cases in which courts have found § 3283 applicable to particular statutes, it cites only one case in which either a § 2422(a) or § 2423(a) offense has been held to involve “sexual abuse” within the meaning of § 3283. In United States v. Vickers, No. 13 Cr. 128 (RJA) (HKS), 2014 WL 1838255 (W.D.N.Y. May 8, 2014), the court held that a § 2423(a) offense involved sexual abuse; instead, the court used a fact-based approach. Id. at *11 (“defendant Vickers is charged with transportation of a minor in violation of [§ 2423(a)] and it is alleged that the defendant did have sexual contact with Victim 1”) (emphasis added). No court has held that either the enticement of an individual to travel or the transportation of a minor necessarily entails “sexual abuse” within the meaning of § 3283. It does not. The government therefore cannot and should not prevail.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "15",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003672",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Vickers",
      "Victim 1"
    ],
    "organizations": [
      "Department of Justice"
    ],
    "locations": [
      "W.D.N.Y."
    ],
    "dates": [
      "04/16/21",
      "May 8, 2014"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 206",
      "13 Cr. 128 (RJA) (HKS)",
      "DOJ-OGR-00003672"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is printed and there are no visible stamps or handwritten notes. The document is well-formatted and legible."
}