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743 KB

Extraction Summary

4
People
1
Organizations
2
Locations
2
Events
1
Relationships
1
Quotes

Document Information

Type: Legal document
File Size: 743 KB
Summary

This legal document, filed on July 2, 2020, is a motion arguing for the pre-trial detention of a 58-year-old defendant. The prosecution asserts the defendant is a significant flight risk due to the serious nature of the charges, which involve targeting minors over several years and carry a potential 35-year sentence. The argument is supported by the strength of the evidence, including victim testimony corroborated by flight records and diary entries, and legal precedent suggesting long sentences increase the incentive to flee.

People (4)

Name Role Context
the defendant Defendant
The subject of the legal filing, accused of crimes involving minors, facing up to 35 years in prison, and considered ...
Moscaritolo Defendant in a cited case
Mentioned in the case citation 'United States v. Moscaritolo'.
Alindato-Perez Defendant in a cited case
Mentioned in the case citation 'United States v. Alindato–Perez'.
Multiple victims Victim
Mentioned as having provided detailed, credible, and corroborated information against the defendant.

Organizations (1)

Name Type Context
United States government agency
Mentioned as the plaintiff in the cited cases 'United States v. Moscaritolo' and 'United States v. Alindato–Perez'.

Timeline (2 events)

2020-07-02
Filing of Document 4 in Case 1:20-cr-00330-AJN.
The defendant repeatedly engaged in conduct targeting girls as young as 14 years old, for a period of years, and involving multiple minors.
the defendant multiple minors

Locations (2)

Location Context
District of New Hampshire, mentioned in a case citation.
District of Puerto Rico, mentioned in a case citation.

Relationships (1)

the defendant criminal Multiple victims
The document states the defendant targeted 'girls as young as 14 years old' and that 'Multiple victims have provided detailed, credible, and corroborated information against the defendant.'

Key Quotes (1)

"[T]he steeper the potential sentence, the more probable the flight risk is, especially considering the strong case of the government . . . ."
Source
— United States v. Moscaritolo, No. 10 Cr. 4 (JL), 2010 WL 309679, at *2 (D.N.H. Jan. 26, 2010) (Quoted from a previous case to support the argument that the defendant is a flight risk due to the potential for a long sentence.)
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Quote #1

Full Extracted Text

Complete text extracted from the document (2,242 characters)

Case 1:20-cr-00330-AJN Document 4 Filed 07/02/20 Page 6 of 10
acts are so serious that both crimes carry a statutory presumption that no condition or combination of conditions will reasonably assure the appearance of the defendant as required. 18 U.S.C. § 3142 (e)(3)(E). The defendant repeatedly engaged in this conduct, targeting girls as young as 14 years old, for a period of years, and involving multiple minors.
These offenses carry significant penalties, and the defendant faces up to 35 years’ imprisonment if convicted. The possibility of a substantial sentence is a significant factor in assessing the risk of flight. See United States v. Moscaritolo, No. 10 Cr. 4 (JL), 2010 WL 309679, at *2 (D.N.H. Jan. 26, 2010) (“[T]he steeper the potential sentence, the more probable the flight risk is, especially considering the strong case of the government . . . .”) (quoting United States v. Alindato–Perez, 627 F. Supp. 2d 58, 66 (D.P.R. 2009)). Here, the defendant is facing a statutory maximum of decades in prison. This fact alone would provide a compelling incentive for anyone to flee from prosecution, but the incentive to flee is especially strong for this defendant, who, at age 58, faces the very real prospect of spending a substantial portion of the rest of her life in prison.
The strength of the evidence in this case underscores the risk that the defendant will become a fugitive. As the facts set forth in the Indictment make plain, the evidence in this case is strong. Multiple victims have provided detailed, credible, and corroborated information against the defendant. The victims are backed up contemporaneous documents, records, witness testimony, and other evidence. For example, flight records, diary entries, business records, and other evidence corroborate the victims’ account of events. This will be compelling evidence of guilt at any trial in this case, which weighs heavily in favor of detention.
The passage of time between the defendant’s conduct and these charges does not counsel otherwise. As an initial matter, all of the conduct is timely charged, pursuant to 18 U.S.C. § 3283, which was amended in 2003 to extend the limitations period for conduct that was timely as of the
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DOJ-OGR-00001492

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