mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00003116.json

{
  "document_metadata": {
    "page_number": "182",
    "document_number": "204",
    "date": "04/16/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 182 of 239\n1838255, at *1, 4-6 (W.D.N.Y. May 8, 2014) (denying motion to dismiss indictment charging enticement of a minor, in violation of 18 U.S.C. 2423(a), \"between in or about 2000 to in or about 2004,\" because \"the Indictment states all the elements of the crime charged by tracking the statutory language,\" as well as \"the nature of the criminal activity\" and \"the underlying facts\").\n\"This is especially true in cases of sexual abuse of children: allegations of sexual abuse of underage victims often proceed without specific dates of offenses,\" including \"[i]n cases of continuing sexual abuse,\" for which \"it is sufficient for the indictment to specify a period of time—rather than a specific date—in which defendant committed the acts at issue . . . .\" United States v. Young, No. 08 Cr. 285 (KMK), 2008 WL 4178190, at *2 (S.D.N.Y. Sept. 4, 2008) (internal quotation mark omitted) (quoting Edwards v. Mazzuca, No. 00 Civ. 2290 (RJS), 2007 WL 2994449, at *5 (S.D.N.Y. Oct. 15, 2007)). Indeed, \"[b]ecause minors often are not capable of remembering the exact dates when the alleged acts occurred, ‘fairly large time windows in the context of child abuse prosecutions are not in conflict with constitutional notice requirements.’\" Young, 2008 WL 4178190, at *2 (quoting Valentine v. Konteh, 395 F.3d 626, 632 (6th Cir. 2005)).\nThe same is true here. The minor victims in this case cannot reasonably be expected to recall the exact dates when particular instances of abuse took place during their adolescence. This is especially so for Minor Victim-1, who experienced numerous instances of abuse over multiple years of her youth. Providing the approximate ranges of dates during which the offenses took place fully satisfies the requirements of an adequately pled charging instrument. The defendant cites no authority to the contrary, and her motion to dismiss should accordingly be denied.\nThird, the Indictment lists in clear detail the allegations relevant to each element of every criminal statute for which she is charged. Beyond simply “parroting the language of a federal criminal statute,” Resendiz-Ponce, 549 U.S. at 108, the Indictment provides extensive detail\n155\nDOJ-OGR-00003116",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 182 of 239",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "1838255, at *1, 4-6 (W.D.N.Y. May 8, 2014) (denying motion to dismiss indictment charging enticement of a minor, in violation of 18 U.S.C. 2423(a), \"between in or about 2000 to in or about 2004,\" because \"the Indictment states all the elements of the crime charged by tracking the statutory language,\" as well as \"the nature of the criminal activity\" and \"the underlying facts\").",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "\"This is especially true in cases of sexual abuse of children: allegations of sexual abuse of underage victims often proceed without specific dates of offenses,\" including \"[i]n cases of continuing sexual abuse,\" for which \"it is sufficient for the indictment to specify a period of time—rather than a specific date—in which defendant committed the acts at issue . . . .\" United States v. Young, No. 08 Cr. 285 (KMK), 2008 WL 4178190, at *2 (S.D.N.Y. Sept. 4, 2008) (internal quotation mark omitted) (quoting Edwards v. Mazzuca, No. 00 Civ. 2290 (RJS), 2007 WL 2994449, at *5 (S.D.N.Y. Oct. 15, 2007)). Indeed, \"[b]ecause minors often are not capable of remembering the exact dates when the alleged acts occurred, ‘fairly large time windows in the context of child abuse prosecutions are not in conflict with constitutional notice requirements.’\" Young, 2008 WL 4178190, at *2 (quoting Valentine v. Konteh, 395 F.3d 626, 632 (6th Cir. 2005)).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The same is true here. The minor victims in this case cannot reasonably be expected to recall the exact dates when particular instances of abuse took place during their adolescence. This is especially so for Minor Victim-1, who experienced numerous instances of abuse over multiple years of her youth. Providing the approximate ranges of dates during which the offenses took place fully satisfies the requirements of an adequately pled charging instrument. The defendant cites no authority to the contrary, and her motion to dismiss should accordingly be denied.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Third, the Indictment lists in clear detail the allegations relevant to each element of every criminal statute for which she is charged. Beyond simply “parroting the language of a federal criminal statute,” Resendiz-Ponce, 549 U.S. at 108, the Indictment provides extensive detail",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "155",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003116",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Minor Victim-1"
    ],
    "organizations": [
      "DOJ"
    ],
    "locations": [
      "W.D.N.Y.",
      "S.D.N.Y.",
      "6th Cir."
    ],
    "dates": [
      "May 8, 2014",
      "2000",
      "2004",
      "Sept. 4, 2008",
      "Oct. 15, 2007",
      "04/16/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204",
      "08 Cr. 285 (KMK)",
      "00 Civ. 2290 (RJS)",
      "DOJ-OGR-00003116"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case involving sexual abuse of minors. The text is printed and there are no visible stamps or handwritten notes. The document is well-formatted and legible."
}