DOJ-OGR-00000436.jpg
617 KB
Extraction Summary
6
People
3
Organizations
1
Locations
3
Events
2
Relationships
1
Quotes
Document Information
Type:
Legal document
File Size:
617 KB
Summary
This document is page 6 of a legal filing dated July 16, 2019, addressed to Judge Richard M. Berman. The author refutes the judge's suggestion that sex offender recidivism rates increase after 15 years, citing two studies that conclude the opposite. The document also mentions a New Mexico detective, Deborah Anaya, and speculation by a third-party counsel, Mr. Boies, regarding alleged payments in late 2018.
People (6)
| Name | Role | Context |
|---|---|---|
| Richard M. Berman | Judge |
Addressed as "Hon. Richard M. Berman" and "Your Honor"; recipient of the document.
|
| Deborah Anaya | Detective |
Mentioned as a "New Mexico official".
|
| Mr. Boies | Third-party counsel |
Mentioned as having speculated about alleged payments.
|
| Hanson | Author |
Cited as the lead author of a 2014 study titled “High-Risk Sex Offenders May Not Be High Risk Forever”.
|
| Ira Mark | Author |
Cited as a co-author of a 2015 study titled “‘Frightening and High’: The Supreme Court’s Crucial Mistake About Sex Cr...
|
| Tara Ellman | Author |
Cited as a co-author of a 2015 study titled “‘Frightening and High’: The Supreme Court’s Crucial Mistake About Sex Cr...
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Journal of Interpersonal Violence | Publication |
Cited as the publisher of the Hanson et al. study in March 2014.
|
| Supreme Court | Government agency |
Mentioned in the title of the study by Ira Mark & Tara Ellman.
|
| Constitutional Commentary | Publication |
Cited as the publisher of the Ira Mark & Tara Ellman study.
|
Locations (1)
| Location | Context |
|---|---|
|
Detective Deborah Anaya is described as a "New Mexico official" and a ranch is located there.
|
Relationships (2)
The document is a formal legal filing addressed to "Hon. Richard M. Berman" as "Your Honor," indicating a counsel-to-judge relationship within a legal case.
Mr. Boies is identified as "third-party counsel," indicating his legal role in the proceedings.
Key Quotes (1)
"actually go[] up at 15 years"Source
— Your Honor (Richard M. Berman)
(A suggestion made by the judge from the bench regarding sex offender recidivism rates, which the author of the document is arguing against.)
DOJ-OGR-00000436.jpg
Quote #1
Full Extracted Text
Complete text extracted from the document (1,323 characters)
Case 1:19-cr-00490-RMB Document 22 Filed 07/16/19 Page 6 of 9
Hon. Richard M. Berman
July 16, 2019
Page 6
July 16, 2019
Page 6
appropriate New Mexico official, Detective Deborah Anaya, when he
spent any time at his ranch there. (The underlying documents are
available upon request.)
spent any time at his ranch there. (The underlying documents are
available upon request.)
Sixth, though some studies may well indicate that sex offender
recidivism rates “actually go[] up at 15 years,” as Your Honor suggested
from the bench,5 others reach the opposite conclusion. For example, a
respected study found that the relapse risk drops substantially the longer
a person remains sex-offense free in the community. 6 Another
determined that it’s mistaken to think of anyone who’s been offense-free
for 15 years as high-risk.7
recidivism rates “actually go[] up at 15 years,” as Your Honor suggested
from the bench,5 others reach the opposite conclusion. For example, a
respected study found that the relapse risk drops substantially the longer
a person remains sex-offense free in the community. 6 Another
determined that it’s mistaken to think of anyone who’s been offense-free
for 15 years as high-risk.7
Seventh, to the extent third-party counsel (Mr. Boies) speculated
that the alleged November 28 and December 3, 2018 payments8 were
that the alleged November 28 and December 3, 2018 payments8 were
5 7/15/19 Tr. 34.
6 Hanson et al., “High-Risk Sex Offenders May Not Be High Risk Forever,” Journal
of Interpersonal Violence (March 2014),
https://www.researchgate.net/publication/261069441_High-
Risk_Sex_Offenders_May_Not_Be_High_Risk_Forever.
7 Ira Mark & Tara Ellman, “‘Frightening and High’: The Supreme Court’s Crucial
Mistake About Sex Crime Statistics” (2015). Constitutional Commentary. 419.
https://scholarship.law.umn.edu/concomm/419.
8 7/12/19 Ltr. 11.
6 Hanson et al., “High-Risk Sex Offenders May Not Be High Risk Forever,” Journal
of Interpersonal Violence (March 2014),
https://www.researchgate.net/publication/261069441_High-
Risk_Sex_Offenders_May_Not_Be_High_Risk_Forever.
7 Ira Mark & Tara Ellman, “‘Frightening and High’: The Supreme Court’s Crucial
Mistake About Sex Crime Statistics” (2015). Constitutional Commentary. 419.
https://scholarship.law.umn.edu/concomm/419.
8 7/12/19 Ltr. 11.
DOJ-OGR-00000436
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