{
  "document_metadata": {
    "page_number": "95",
    "document_number": "20-2",
    "date": "04/01/2021",
    "document_type": "court transcript",
    "has_handwriting": false,
    "has_stamps": false
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  "full_text": "Case 21-770, Document 20-2, 04/01/2021, 3068530, Page95 of 200\n32\nshe passes. In other words, even though, as defense claims, that she is widely known, that there is press everywhere, she was able to pass during the purchase of a real estate transaction under a fake name and not be detected. So there really can be no question that the defendant is willing to lie about who she is, that she can live in hiding, that she has the means to do so. All of those things should be extremely concerning to the court, your Honor, as the court evaluates whether the defendant has the ability and willingness to live off the grid indefinitely. A year is an extremely long period of time to live in hiding, undetected by the public. And so all of those things are concerning.\nWith respect to the question of motive, your Honor, the government submits the court need not reach that ultimate issue, but we noted, your Honor, that there are indicia during the circumstances of the defendant's arrest that suggested that there was a motive to evade detection by law enforcement. But the bigger picture, your Honor, is the defendant's --\nTHE COURT: Ms. Moe --\nMS. MOE: -- ability --\nTHE COURT: -- I was surprised that that information wasn't provided until the reply brief. Was there a reason for that?\nMS. MOE: Yes, your Honor. The government wanted to be very careful to make sure we had full and accurate\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\nDOJ-OGR-00001036",
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      "content": "Case 21-770, Document 20-2, 04/01/2021, 3068530, Page95 of 200",
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    {
      "type": "printed",
      "content": "she passes. In other words, even though, as defense claims, that she is widely known, that there is press everywhere, she was able to pass during the purchase of a real estate transaction under a fake name and not be detected. So there really can be no question that the defendant is willing to lie about who she is, that she can live in hiding, that she has the means to do so. All of those things should be extremely concerning to the court, your Honor, as the court evaluates whether the defendant has the ability and willingness to live off the grid indefinitely. A year is an extremely long period of time to live in hiding, undetected by the public. And so all of those things are concerning.\nWith respect to the question of motive, your Honor, the government submits the court need not reach that ultimate issue, but we noted, your Honor, that there are indicia during the circumstances of the defendant's arrest that suggested that there was a motive to evade detection by law enforcement. But the bigger picture, your Honor, is the defendant's --",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "THE COURT: Ms. Moe --\nMS. MOE: -- ability --\nTHE COURT: -- I was surprised that that information wasn't provided until the reply brief. Was there a reason for that?\nMS. MOE: Yes, your Honor. The government wanted to be very careful to make sure we had full and accurate",
      "position": "main"
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    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001036",
      "position": "footer"
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  "entities": {
    "people": [
      "Ms. Moe"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "locations": [],
    "dates": [
      "04/01/2021"
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    "reference_numbers": [
      "Case 21-770",
      "Document 20-2",
      "3068530",
      "DOJ-OGR-00001036",
      "(212) 805-0300"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a clear and readable format. There are no visible redactions or damage."
}