{
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    "page_number": "52",
    "document_number": "93",
    "date": "12/10/20",
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  "full_text": "Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 52 of 91\n1 appealed by the government; decision of the court, release on\n2 strict conditions. That is how the law works and comes out in\n3 this area, but that's something, your Honor, that the government did not address. And if the court determines that\n4 the conditions that we have proffered are insufficient or need\n5 further verification, as long as we can have some assurance of\n6 safety and confidentiality, we would recommend that the court\n7 keep the proceeding open, and we should be able to get whatever\n8 the court needs to satisfy it. So that's the legal analysis\n9 that was absent in the government's presentation today and its\n10 papers.\n11\n12 Let me now, because I have to, because this has been\n13 put out before your Honor in, of course, a public proceeding,\n14 let me respond to some of the allegations made for the first\n15 time in the reply brief, trying to spin facts to make my client\n16 look sinister to your Honor.\n17 Here is fact one: She is a risk of flight because she\n18 has been hiding out. Well, let's think about this. She has\n19 been litigating civil cases in this courthouse and other parts\n20 of the country since 2015, denying, as she does here before\n21 your Honor, that she did anything improper with regards to\n22 Mr. Epstein. We submit, your Honor, that is the opposite of\n23 somebody who is looking to flee. And in fact, one of the\n24 people who spoke before your Honor is a plaintiff in one of\n25 those lawsuits seeking millions of dollars from our client and\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00001929",
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      "content": "Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 52 of 91",
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      "type": "printed",
      "content": "1 appealed by the government; decision of the court, release on\n2 strict conditions. That is how the law works and comes out in\n3 this area, but that's something, your Honor, that the government did not address. And if the court determines that\n4 the conditions that we have proffered are insufficient or need\n5 further verification, as long as we can have some assurance of\n6 safety and confidentiality, we would recommend that the court\n7 keep the proceeding open, and we should be able to get whatever\n8 the court needs to satisfy it. So that's the legal analysis\n9 that was absent in the government's presentation today and its\n10 papers.\n11\n12 Let me now, because I have to, because this has been\n13 put out before your Honor in, of course, a public proceeding,\n14 let me respond to some of the allegations made for the first\n15 time in the reply brief, trying to spin facts to make my client\n16 look sinister to your Honor.\n17 Here is fact one: She is a risk of flight because she\n18 has been hiding out. Well, let's think about this. She has\n19 been litigating civil cases in this courthouse and other parts\n20 of the country since 2015, denying, as she does here before\n21 your Honor, that she did anything improper with regards to\n22 Mr. Epstein. We submit, your Honor, that is the opposite of\n23 somebody who is looking to flee. And in fact, one of the\n24 people who spoke before your Honor is a plaintiff in one of\n25 those lawsuits seeking millions of dollars from our client and",
      "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-00001929",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Mr. Epstein"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "12/10/20",
      "2015"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "93",
      "DOJ-OGR-00001929"
    ]
  },
  "additional_notes": "The document appears to be a court transcript or legal document. The text is clear and legible, with no visible redactions or damage."
}