{
  "document_metadata": {
    "page_number": "121",
    "document_number": "20-2",
    "date": "04/01/2021",
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  "full_text": "Case 21-770, Document 20-2, 04/01/2021, 3068530, Page121 of 200\n\n1 regular contact with the government, is removed in a property\n2 in the United States. That's the opposite of hiding. So we\n3 think that those kinds of facts, I'm sure, your Honor, if your\n4 Honor decides to keep the proceedings open and give us a chance\n5 to come on some issues, I'm sure we will have some more facts\n6 tomorrow and the next day, all with the disclaimer, we just\n7 learned this, your Honor. They have been investigating this\n8 case for ten years, your Honor, okay?\n9\n10 So let me turn now to another factor that the\n11 government made argument about briefly, two more factors under\n12 31(g)(3), the history and characteristics of the defendant. We\n13 heard several times that there was a -- that detention should\n14 be warranted because there is a perjury charge. Very quickly,\n15 your Honor, we submit this does not tip the balance in the 3142\n16 analysis that the court has to perform.\n17 First and foremost, the defendant is, of course,\n18 presumed innocent; and, secondly, the allegation and nature of\n19 the perjury, if the court has been through the indictment, is\n20 someone who denies guilt, who says they are innocent, is asked\n21 in a deposition did you do that and says no, the government\n22 charges them with perjury. That is not -- other than the fact\n23 that it's an indicted charge, they are still entitled to the\n24 weight the court would give a not indicted charge. That's all\n25 the weight it should be given.\n\nLet me turn to another factor that the government\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00001062",
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      "content": "Case 21-770, Document 20-2, 04/01/2021, 3068530, Page121 of 200",
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      "content": "1 regular contact with the government, is removed in a property\n2 in the United States. That's the opposite of hiding. So we\n3 think that those kinds of facts, I'm sure, your Honor, if your\n4 Honor decides to keep the proceedings open and give us a chance\n5 to come on some issues, I'm sure we will have some more facts\n6 tomorrow and the next day, all with the disclaimer, we just\n7 learned this, your Honor. They have been investigating this\n8 case for ten years, your Honor, okay?\n9\n10 So let me turn now to another factor that the\n11 government made argument about briefly, two more factors under\n12 31(g)(3), the history and characteristics of the defendant. We\n13 heard several times that there was a -- that detention should\n14 be warranted because there is a perjury charge. Very quickly,\n15 your Honor, we submit this does not tip the balance in the 3142\n16 analysis that the court has to perform.\n17 First and foremost, the defendant is, of course,\n18 presumed innocent; and, secondly, the allegation and nature of\n19 the perjury, if the court has been through the indictment, is\n20 someone who denies guilt, who says they are innocent, is asked\n21 in a deposition did you do that and says no, the government\n22 charges them with perjury. That is not -- other than the fact\n23 that it's an indicted charge, they are still entitled to the\n24 weight the court would give a not indicted charge. That's all\n25 the weight it should be given.\n\nLet me turn to another factor that the government",
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    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001062",
      "position": "footer"
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  "entities": {
    "people": [
      "defendant"
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    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C.",
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    "locations": [
      "United States"
    ],
    "dates": [
      "04/01/2021"
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    "reference_numbers": [
      "Case 21-770",
      "Document 20-2",
      "3068530",
      "DOJ-OGR-00001062"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
}