{
  "document_metadata": {
    "page_number": "126",
    "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, Page126 of 200\n63\n\n1    defendant, the less important it becomes to identify and\n2    restrain each and every asset over which defendants may\n3    exercise some control in order to mitigate risk of flight.\" So\n4    if the court -- and we have suggested them, but they may be\n5    modified by the court -- can put in place stringent bail\n6    conditions, we don't need to have a side-long, month-long\n7    hearing about my client's assets which is just designed to keep\n8    her in detention. That was an observation by Judge Raggi in\n9    Sabhnani.\n10   Judge, very quickly on the nature and circumstances of\n11   the offense and the weight of the evidence, we don't think,\n12   your Honor, this is the place to litigate legal motions. This\n13   is a bail hearing. It is not the place to litigate complex\n14   legal questions that we will be presenting to your Honor. It's\n15   very soon on the motion schedule, and we thank the court for\n16   agreeing to the schedule. But there are a few things that are\n17   worth pointing out.\n18   We believe there are very significant motions here\n19   that will affect whether this indictment survives at all or the\n20   shape of this indictment and, given the government's\n21   representation that it is not planning to supersede, will\n22   affect the shape of the entire case, or any case at all that\n23   proceeds before the court at trial, if there is a trial. That\n24   is exactly what we submit the court can consider, again, in\n25   exercising its discretion as to the weight of the evidence.\n\n    SOUTHERN DISTRICT REPORTERS, P.C.\n    (212) 805-0300\n\n    DOJ-OGR-00001067",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 21-770, Document 20-2, 04/01/2021, 3068530, Page126 of 200",
      "position": "header"
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    {
      "type": "printed",
      "content": "1    defendant, the less important it becomes to identify and\n2    restrain each and every asset over which defendants may\n3    exercise some control in order to mitigate risk of flight.\" So\n4    if the court -- and we have suggested them, but they may be\n5    modified by the court -- can put in place stringent bail\n6    conditions, we don't need to have a side-long, month-long\n7    hearing about my client's assets which is just designed to keep\n8    her in detention. That was an observation by Judge Raggi in\n9    Sabhnani.\n10   Judge, very quickly on the nature and circumstances of\n11   the offense and the weight of the evidence, we don't think,\n12   your Honor, this is the place to litigate legal motions. This\n13   is a bail hearing. It is not the place to litigate complex\n14   legal questions that we will be presenting to your Honor. It's\n15   very soon on the motion schedule, and we thank the court for\n16   agreeing to the schedule. But there are a few things that are\n17   worth pointing out.\n18   We believe there are very significant motions here\n19   that will affect whether this indictment survives at all or the\n20   shape of this indictment and, given the government's\n21   representation that it is not planning to supersede, will\n22   affect the shape of the entire case, or any case at all that\n23   proceeds before the court at trial, if there is a trial. That\n24   is exactly what we submit the court can consider, again, in\n25   exercising its discretion as to the weight of the evidence.",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001067",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Judge Raggi"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "04/01/2021"
    ],
    "reference_numbers": [
      "Case 21-770",
      "Document 20-2",
      "3068530",
      "DOJ-OGR-00001067"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
}