mirror-epstein-docs/results/IMAGES008/DOJ-OGR-00021790.json

{
  "document_metadata": {
    "page_number": "1 of 2",
    "document_number": "101",
    "date": "March 10, 2024",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 22-1426, Document 101, 03/10/2024, 3614237, Page1 of 2\nU.S. Department of Justice\nUnited States Attorney\nSouthern District of New York\nThe Silvio J. Mollo Building\nOne Saint Andrew's Plaza\nNew York, New York 10007\nMarch 10, 2024\nBy CM/ECF\nCatherine O'Hagan Wolfe, Clerk of Court\nUnited States Court of Appeals for the Second Circuit\nThurgood Marshall U.S. Courthouse\n40 Foley Square\nNew York, New York 10007\nRe: United States v. Ghislaine Maxwell, Docket No. 22-1426\nArgument date: March 12, 2023\nDear Ms. Wolfe:\nThe Government respectfully submits this letter, pursuant to Federal Rule of Appellate Procedure 28(j), to inform this Court of United States v. Watkins, 940 F.3d 152 (2d Cir. 2019).\nIn Watkins, this Court explained that the portion of the Bail Reform Act, 18 U.S.C. § 3142(f)(1)(E), that required a detention hearing for \"any felony . . . that involves a minor victim . . .\" permits a court to conduct a \"conduct-specific inquiry in which the judicial officer may look beyond the elements of the charged offense to consider the actual conduct underlying the arrestee's charged offense.\" 940 F.3d at 165, 167. Because that phrase \"refers to a 'minor victim,' it \"suggest[s] factual details surrounding the charged conduct.\" Id. at 166. The Court also noted the absence of a textual trigger for the categorical approach like \"that has as an element.\" Id. at 166 n.70. The Court further explained that its conclusion was reinforced by legislative history, namely, the inclusion of Section 3142(f)(1)(E) in a statute intended to \"afford minor victims of crime the greatest degree of protection.\" Id. at 166.\nThe Court contrasted Section 3142(f)(1)(E) with another portion of the Act that contains the word \"involves\" but requires use of the categorical approach, because that text \"refers, variously, to a 'crime,' an 'offense,' and a 'felony,'\" indicating an emphasis on the nature of the legal charge rather than \"factual details.\" Id. (quoting 18 U.S.C. § 3182(f)(1) (discussing \"a case that involves . . . a crime of violence . . .\"); see id. at 162-65.\nDOJ-OGR-00021790",
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      "content": "Case 22-1426, Document 101, 03/10/2024, 3614237, Page1 of 2\nU.S. Department of Justice\nUnited States Attorney\nSouthern District of New York\nThe Silvio J. Mollo Building\nOne Saint Andrew's Plaza\nNew York, New York 10007\nMarch 10, 2024",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "By CM/ECF\nCatherine O'Hagan Wolfe, Clerk of Court\nUnited States Court of Appeals for the Second Circuit\nThurgood Marshall U.S. Courthouse\n40 Foley Square\nNew York, New York 10007",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, Docket No. 22-1426\nArgument date: March 12, 2023\nDear Ms. Wolfe:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The Government respectfully submits this letter, pursuant to Federal Rule of Appellate Procedure 28(j), to inform this Court of United States v. Watkins, 940 F.3d 152 (2d Cir. 2019).\nIn Watkins, this Court explained that the portion of the Bail Reform Act, 18 U.S.C. § 3142(f)(1)(E), that required a detention hearing for \"any felony . . . that involves a minor victim . . .\" permits a court to conduct a \"conduct-specific inquiry in which the judicial officer may look beyond the elements of the charged offense to consider the actual conduct underlying the arrestee's charged offense.\" 940 F.3d at 165, 167. Because that phrase \"refers to a 'minor victim,' it \"suggest[s] factual details surrounding the charged conduct.\" Id. at 166. The Court also noted the absence of a textual trigger for the categorical approach like \"that has as an element.\" Id. at 166 n.70. The Court further explained that its conclusion was reinforced by legislative history, namely, the inclusion of Section 3142(f)(1)(E) in a statute intended to \"afford minor victims of crime the greatest degree of protection.\" Id. at 166.\nThe Court contrasted Section 3142(f)(1)(E) with another portion of the Act that contains the word \"involves\" but requires use of the categorical approach, because that text \"refers, variously, to a 'crime,' an 'offense,' and a 'felony,'\" indicating an emphasis on the nature of the legal charge rather than \"factual details.\" Id. (quoting 18 U.S.C. § 3182(f)(1) (discussing \"a case that involves . . . a crime of violence . . .\"); see id. at 162-65.",
      "position": "middle"
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    {
      "type": "printed",
      "content": "DOJ-OGR-00021790",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "Catherine O'Hagan Wolfe",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "U.S. Department of Justice",
      "United States Attorney",
      "United States Court of Appeals for the Second Circuit"
    ],
    "locations": [
      "New York",
      "Southern District of New York",
      "The Silvio J. Mollo Building",
      "One Saint Andrew's Plaza",
      "Thurgood Marshall U.S. Courthouse",
      "40 Foley Square"
    ],
    "dates": [
      "March 10, 2024",
      "March 12, 2023"
    ],
    "reference_numbers": [
      "22-1426",
      "101",
      "3614237",
      "DOJ-OGR-00021790"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from the U.S. Department of Justice to the Clerk of Court, discussing a legal case and referencing specific statutes and court decisions. The document is well-formatted and free of significant damage or redactions."
}