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  "document_metadata": {
    "page_number": "43",
    "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 43 of 91\nk7e2MaxC kjc\n\n1 I do want to note, before I go further, to pick up on\n2 something the court said. We have a proceeding now where the\n3 government is dribbling out facts or what they claim are facts\n4 that they could have and should have put in their opening\n5 memorandum so we would have had an opportunity to address them\n6 in writing before the court. That's not how this is supposed\n7 to proceed, your Honor, and I thank your Honor for pointing\n8 that out. Each --\n9 THE COURT: But, Mr. Cohen, please, by all means, you\n10 have had the reply in the time that I have as well. You\n11 shouldn't hesitate to respond to any of those facts now.\n12 MR. COHEN: I appreciate that, your Honor, and I'm\n13 going to proceed by proffer. I would have preferred to be able\n14 to submit something in writing, but obviously the way it was\n15 done, we were deprived of that chance.\n16 I also want to make clear that our client is not\n17 Epstein. She is not the monster that has been portrayed by the\n18 media and now the government. She is part of a very large and\n19 close family, with extensive familial relations, extensive\n20 friendships, extensive professional relationships. Many of\n21 these folks are on the call today, your Honor, and thank you,\n22 your Honor, for making that available, though not identified,\n23 which is something one would normally do in a traditional bail\n24 hearing, because of the very real concern that they have and\n25 our client has about her safety and about her privacy and her\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00001920",
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      "content": "Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 43 of 91",
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      "type": "printed",
      "content": "1 I do want to note, before I go further, to pick up on\n2 something the court said. We have a proceeding now where the\n3 government is dribbling out facts or what they claim are facts\n4 that they could have and should have put in their opening\n5 memorandum so we would have had an opportunity to address them\n6 in writing before the court. That's not how this is supposed\n7 to proceed, your Honor, and I thank your Honor for pointing\n8 that out. Each --\n9 THE COURT: But, Mr. Cohen, please, by all means, you\n10 have had the reply in the time that I have as well. You\n11 shouldn't hesitate to respond to any of those facts now.\n12 MR. COHEN: I appreciate that, your Honor, and I'm\n13 going to proceed by proffer. I would have preferred to be able\n14 to submit something in writing, but obviously the way it was\n15 done, we were deprived of that chance.\n16 I also want to make clear that our client is not\n17 Epstein. She is not the monster that has been portrayed by the\n18 media and now the government. She is part of a very large and\n19 close family, with extensive familial relations, extensive\n20 friendships, extensive professional relationships. Many of\n21 these folks are on the call today, your Honor, and thank you,\n22 your Honor, for making that available, though not identified,\n23 which is something one would normally do in a traditional bail\n24 hearing, because of the very real concern that they have and\n25 our client has about her safety and about her privacy and her",
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      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001920",
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  ],
  "entities": {
    "people": [
      "Mr. Cohen",
      "Epstein"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "locations": [],
    "dates": [
      "12/10/20"
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    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "93",
      "DOJ-OGR-00001920"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
}