{
  "document_metadata": {
    "page_number": "73",
    "document_number": "93",
    "date": "12/10/20",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 73 of 91\n1 the court, significantly.\n2 And while we recognize that it appears that the\n3 defendant's extensive resources may be in complicated banking\n4 records, at a basic level, the defense argument is that she\n5 cannot remember off the top of her head just how many millions\n6 of dollars she has. That should cause the court serious\n7 concern.\n8 A bail hearing, your Honor, is not an opportunity for\n9 the defendant to slowly reveal information until the court\n10 deems it sufficient. That is not sufficient process here.\n11 That is not appropriate. This information is coming out in\n12 dribs and drabs, and defendant should not be in a position to\n13 slowly but surely concede, as the government reveals, that she\n14 has been less than candid with the court about her finances.\n15 There are serious concerns here.\n16 With respect to the notion that the defendant could\n17 just surrender her passports, there are of course no\n18 limitations this court could set on a foreign government\n19 issuing travel documents to defendant or accepting her if she\n20 were to enter into that country.\n21 And finally, your Honor, with respect to the case law\n22 that defense has cited, they ignore the obvious comparator\n23 case, which is Judge Berman's decision regarding Jeffrey\n24 Epstein, who was arrested both on risk of flight grounds and on\n25 dangerousness grounds. And as Judge Berman detailed, the\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00001950",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 73 of 91",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "1 the court, significantly.\n2 And while we recognize that it appears that the\n3 defendant's extensive resources may be in complicated banking\n4 records, at a basic level, the defense argument is that she\n5 cannot remember off the top of her head just how many millions\n6 of dollars she has. That should cause the court serious\n7 concern.\n8 A bail hearing, your Honor, is not an opportunity for\n9 the defendant to slowly reveal information until the court\n10 deems it sufficient. That is not sufficient process here.\n11 That is not appropriate. This information is coming out in\n12 dribs and drabs, and defendant should not be in a position to\n13 slowly but surely concede, as the government reveals, that she\n14 has been less than candid with the court about her finances.\n15 There are serious concerns here.\n16 With respect to the notion that the defendant could\n17 just surrender her passports, there are of course no\n18 limitations this court could set on a foreign government\n19 issuing travel documents to defendant or accepting her if she\n20 were to enter into that country.\n21 And finally, your Honor, with respect to the case law\n22 that defense has cited, they ignore the obvious comparator\n23 case, which is Judge Berman's decision regarding Jeffrey\n24 Epstein, who was arrested both on risk of flight grounds and on\n25 dangerousness grounds. And as Judge Berman detailed, the",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001950",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Jeffrey Epstein",
      "Judge Berman"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "12/10/20"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 93",
      "DOJ-OGR-00001950"
    ]
  },
  "additional_notes": "The document appears to be a court transcript or legal document. The text is printed and there are no visible handwritten notes or stamps. The document is from a court case involving a defendant and references a previous case involving Jeffrey Epstein."
}