{
  "document_metadata": {
    "page_number": "53",
    "document_number": "93",
    "date": "12/10/20",
    "document_type": "court transcript",
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  "full_text": "Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 53 of 91\n53\n1 seeking millions of dollars from a fund that's being set up.\n2 Something for the court to consider.\n3 She has also, as we mentioned, remained in the United\n4 States, even though she has known of the investigation.  How\n5 could she not?  It's been unbelievably public for the past\n6 year.  And we have been in regular contact with her -- with the\n7 government.  Your Honor asked that question, very careful\n8 question from the court, and we got a shimmy from the\n9 government in response.  We have been in contact with them,\n10 conservatively -- as we checked last night, because we thought\n11 you might ask -- conservatively eight to ten times in the past\n12 year, all for the same purpose, to urge them not to bring this\n13 case, which shouldn't have been brought.\n14\n15 Haddon Morgan is also experienced, is in regular contact with\n16 the government, would surrender their client, and they turn\n17 around and deny that to the court and deny that voluntary\n18 surrender would and could have and should have been possible\n19 here is, we submit, another factor for the court to consider.\n20 So let me turn to the reply brief.\n21 THE COURT:  Sorry.  If I may, Mr. Cohen, I just want\n22 to make sure I understand that last point.  Are you saying that\n23 defense counsel indicated to the government that, should there\n24 be an indictment returned, you were seeking to arrange a\n25 voluntary surrender?  Is that the contention?\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00001930",
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      "content": "Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 53 of 91",
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      "type": "printed",
      "content": "53",
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      "type": "printed",
      "content": "1 seeking millions of dollars from a fund that's being set up.\n2 Something for the court to consider.\n3 She has also, as we mentioned, remained in the United\n4 States, even though she has known of the investigation.  How\n5 could she not?  It's been unbelievably public for the past\n6 year.  And we have been in regular contact with her -- with the\n7 government.  Your Honor asked that question, very careful\n8 question from the court, and we got a shimmy from the\n9 government in response.  We have been in contact with them,\n10 conservatively -- as we checked last night, because we thought\n11 you might ask -- conservatively eight to ten times in the past\n12 year, all for the same purpose, to urge them not to bring this\n13 case, which shouldn't have been brought.\n14\n15 Haddon Morgan is also experienced, is in regular contact with\n16 the government, would surrender their client, and they turn\n17 around and deny that to the court and deny that voluntary\n18 surrender would and could have and should have been possible\n19 here is, we submit, another factor for the court to consider.\n20 So let me turn to the reply brief.\n21 THE COURT:  Sorry.  If I may, Mr. Cohen, I just want\n22 to make sure I understand that last point.  Are you saying that\n23 defense counsel indicated to the government that, should there\n24 be an indictment returned, you were seeking to arrange a\n25 voluntary surrender?  Is that the contention?",
      "position": "main content"
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      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001930",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "Mr. Cohen"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [
      "United States"
    ],
    "dates": [
      "12/10/20"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "93",
      "DOJ-OGR-00001930"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage to the document."
}