{
  "document_metadata": {
    "page_number": "15",
    "document_number": "36",
    "date": "07/24/19",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:19-cr-00490-RMB Document 36 Filed 07/24/19 Page 15 of 74 15\nIt does not include a list of accounts. It does not include a list of financial institutions. It does not identify what types of currencies the defendant holds. It does nothing to identify the location of his holdings. It does nothing to identify high-value property such as diamonds or art, both of which were observed in abundance in just the government's search of his Manhattan mansion.\nThe other thing, your Honor, is we're just relying on the defendant's word for all of this. This is not sworn. It's not under penalty of perjury. There are no account statements. There are no bank records. There is nothing to validate this.\nThat's not to say that if this were validated, that this would somehow rise to the level of being granted bail, but it's notable with respect to the presumption in particular and also with respect to how the Court evaluates the defendant's assets that we are relying on him.\nThe defendant's financial disclosure form should alarm the Court, your Honor, not give it comfort that there are conditions that would keep the defendant from fleeing and prevent him from being a danger.\nWith respect to the proposed package, the defendant proposes the Court accept his Manhattan mansion as security for a bond. Now, the government has already designated that property for seizure making it worthless to the defendant. He proposes cosigners who couldn't possibly secure a package\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00000525",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:19-cr-00490-RMB Document 36 Filed 07/24/19 Page 15 of 74 15",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "It does not include a list of accounts. It does not include a list of financial institutions. It does not identify what types of currencies the defendant holds. It does nothing to identify the location of his holdings. It does nothing to identify high-value property such as diamonds or art, both of which were observed in abundance in just the government's search of his Manhattan mansion.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The other thing, your Honor, is we're just relying on the defendant's word for all of this. This is not sworn. It's not under penalty of perjury. There are no account statements. There are no bank records. There is nothing to validate this.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "That's not to say that if this were validated, that this would somehow rise to the level of being granted bail, but it's notable with respect to the presumption in particular and also with respect to how the Court evaluates the defendant's assets that we are relying on him.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The defendant's financial disclosure form should alarm the Court, your Honor, not give it comfort that there are conditions that would keep the defendant from fleeing and prevent him from being a danger.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "With respect to the proposed package, the defendant proposes the Court accept his Manhattan mansion as security for a bond. Now, the government has already designated that property for seizure making it worthless to the defendant. He proposes cosigners who couldn't possibly secure a package",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00000525",
      "position": "footer"
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  ],
  "entities": {
    "people": [],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [
      "Manhattan"
    ],
    "dates": [
      "07/24/19"
    ],
    "reference_numbers": [
      "1:19-cr-00490-RMB",
      "Document 36",
      "DOJ-OGR-00000525"
    ]
  },
  "additional_notes": "The document appears to be a court transcript or legal document related to a case involving a defendant. The text is typed and there are no visible handwritten notes or stamps. The document is from the Southern District Court and includes a reference to a specific case number and document number."
}