{
  "document_metadata": {
    "page_number": "132",
    "document_number": "20-2",
    "date": "04/01/2021",
    "document_type": "court transcript",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 21-770, Document 20-2, 04/01/2021, 3068530, Page132 of 200\nk7e2MaxC kjc\n1    And in response to that, the government said, well, too bad, COVID crisis, too bad, Ms. Maxwell, we are not going to let you out. We are not going to let you out because you might get infected, we are not going to let you out because, you know, because it will be tough preparing your trial. And they cite to your honor, in reply, two pages of cases, very limited parentheticals. If you actually read those cases, they are totally different from our situation, your Honor. The cases they cite on health risks in the prison environment, they cite 14 cases, 12 of them are dangerousness cases, people who are convicted of multiple felonies, including weapons felonies. The courts in those cases determined the COVID factors do not outweigh that analysis. They cite nine cases on the preparation and access to counsel. Several of them are dangerousness cases, and the other ones that have some discussion of flight risk are so extremely different from our case as to not be relevant.\nJudge, I don't know how we could possibly prepare this case, getting four months of discovery, including electronic discovery, and in over 25 years of conduct, with a client who is in custody, who we can't meet with in person. And I'm not faulting the BOP. I understand why they have to do what they have to do, and your Honor has made the same point, but it is just we have to be in the real world here. We have to --\nTHE COURT: Whether defendants are detained because of\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00001073",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 21-770, Document 20-2, 04/01/2021, 3068530, Page132 of 200",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "k7e2MaxC kjc",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "1    And in response to that, the government said, well, too bad, COVID crisis, too bad, Ms. Maxwell, we are not going to let you out. We are not going to let you out because you might get infected, we are not going to let you out because, you know, because it will be tough preparing your trial. And they cite to your honor, in reply, two pages of cases, very limited parentheticals. If you actually read those cases, they are totally different from our situation, your Honor. The cases they cite on health risks in the prison environment, they cite 14 cases, 12 of them are dangerousness cases, people who are convicted of multiple felonies, including weapons felonies. The courts in those cases determined the COVID factors do not outweigh that analysis. They cite nine cases on the preparation and access to counsel. Several of them are dangerousness cases, and the other ones that have some discussion of flight risk are so extremely different from our case as to not be relevant.\nJudge, I don't know how we could possibly prepare this case, getting four months of discovery, including electronic discovery, and in over 25 years of conduct, with a client who is in custody, who we can't meet with in person. And I'm not faulting the BOP. I understand why they have to do what they have to do, and your Honor has made the same point, but it is just we have to be in the real world here. We have to --",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "THE COURT: Whether defendants are detained because of",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001073",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell"
    ],
    "organizations": [
      "BOP",
      "SOUTHERN DISTRICT REPORTERS, P.C.",
      "DOJ"
    ],
    "locations": [],
    "dates": [
      "04/01/2021"
    ],
    "reference_numbers": [
      "Case 21-770",
      "Document 20-2",
      "3068530",
      "DOJ-OGR-00001073"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
}