mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00011554.json

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    "page_number": "35",
    "document_number": "737",
    "date": "07/22/22",
    "document_type": "court transcript",
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  "full_text": "Case 1:20-cr-00330-PAE Document 737 Filed 07/22/22 Page 35 of 101\nM6SQmax1\nsaid, I don't need repetition of the arguments in the papers, but if there is any additional points you want to make, you're welcome to.\nMR. EVERDELL: Your Honor, just one point. I will be brief. The government in its papers makes the argument that the background commentary can't be relied upon as authoritative because it is not explanatory or interpretative of what the guideline is. I think that is incorrect.\nIt is not simply a recitation of what Congress was considering. That first sentence or two which talks about how this guideline can only be applied to offenders who represent a continuing danger to the community is interpretative of what the guideline is. The title of the guideline is repeat and dangerous sex offenders. That explanatory commentary explains how to interpret what dangerous means. It means someone who is continuously dangerous to the community, not someone who's never been accused of a crime in the 18 plus years since the crime in this case, and has never been accused of re-offending. So I don't agree with that point. This is authoritative guidance from the Sentencing Commission, and the Court should consider it as such. Thank you.\nTHE COURT: Ms. Moe, do you want to respond?\nMS. MOE: No, your Honor. We rest on our briefing on this issue, but thank you.\nTHE COURT: Thank you. Anything else?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00011554",
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      "content": "M6SQmax1",
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      "content": "said, I don't need repetition of the arguments in the papers, but if there is any additional points you want to make, you're welcome to.\nMR. EVERDELL: Your Honor, just one point. I will be brief. The government in its papers makes the argument that the background commentary can't be relied upon as authoritative because it is not explanatory or interpretative of what the guideline is. I think that is incorrect.\nIt is not simply a recitation of what Congress was considering. That first sentence or two which talks about how this guideline can only be applied to offenders who represent a continuing danger to the community is interpretative of what the guideline is. The title of the guideline is repeat and dangerous sex offenders. That explanatory commentary explains how to interpret what dangerous means. It means someone who is continuously dangerous to the community, not someone who's never been accused of a crime in the 18 plus years since the crime in this case, and has never been accused of re-offending. So I don't agree with that point. This is authoritative guidance from the Sentencing Commission, and the Court should consider it as such. Thank you.",
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      "type": "printed",
      "content": "THE COURT: Ms. Moe, do you want to respond?\nMS. MOE: No, your Honor. We rest on our briefing on this issue, but thank you.\nTHE COURT: Thank you. Anything else?",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00011554",
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  "entities": {
    "people": [
      "MR. EVERDELL",
      "MS. MOE"
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    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C.",
      "Sentencing Commission"
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    "dates": [
      "07/22/22"
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      "1:20-cr-00330-PAE",
      "737",
      "DOJ-OGR-00011554"
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}