{
  "document_metadata": {
    "page_number": "61",
    "document_number": "93",
    "date": "12/10/20",
    "document_type": "court document",
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  "full_text": "Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 61 of 91\nk7e2MaxC kjc\n1 The government also says, well, she has 15 different bank accounts -- and here we get some hedging language -- that are by or associated with her. No detail, no explanation to the court, just more dirt. Well, she has three bank accounts that she disclosed. She believes that there are more, for example, with respect to the not-for-profit that she ran for almost a decade before she was forced to shut it down because of the issues in the media and the attention and the firestorm. So it is some number less. And if it's important to the court, we will do our best to pull it together. But under the relevant cases, it doesn't change the analysis.\n12 And then we go through the last one, your Honor. They say in their brief that she did transfers of funds. One was a transfer of 500,000. We believe that what that is was a bond maturing. So when a bond matures, it is transferred out.\n16 And then there was another one, and the government sort of changes its mind between its opening brief and its reply brief and I'm sure by tomorrow they will have some new speculation for your Honor, but essentially let's call it a several hundred thousand transfer out of and account in June and July of 2019. What's that refer to? It refers to one of the themes we have been talking about in our submission and today your Honor. When Mr. Epstein was arrested, it had all kinds of effects on our client, one of which was that the bank in question referenced in the government's submission dropped\n25 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00001938",
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      "content": "Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 61 of 91",
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    {
      "type": "printed",
      "content": "k7e2MaxC kjc",
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      "type": "printed",
      "content": "1 The government also says, well, she has 15 different bank accounts -- and here we get some hedging language -- that are by or associated with her. No detail, no explanation to the court, just more dirt. Well, she has three bank accounts that she disclosed. She believes that there are more, for example, with respect to the not-for-profit that she ran for almost a decade before she was forced to shut it down because of the issues in the media and the attention and the firestorm. So it is some number less. And if it's important to the court, we will do our best to pull it together. But under the relevant cases, it doesn't change the analysis.",
      "position": "body"
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    {
      "type": "printed",
      "content": "12 And then we go through the last one, your Honor. They say in their brief that she did transfers of funds. One was a transfer of 500,000. We believe that what that is was a bond maturing. So when a bond matures, it is transferred out.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "16 And then there was another one, and the government sort of changes its mind between its opening brief and its reply brief and I'm sure by tomorrow they will have some new speculation for your Honor, but essentially let's call it a several hundred thousand transfer out of and account in June and July of 2019. What's that refer to? It refers to one of the themes we have been talking about in our submission and today your Honor. When Mr. Epstein was arrested, it had all kinds of effects on our client, one of which was that the bank in question referenced in the government's submission dropped",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00001938",
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  ],
  "entities": {
    "people": [
      "Mr. Epstein"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "12/10/20",
      "June and July of 2019"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 93",
      "DOJ-OGR-00001938"
    ]
  },
  "additional_notes": "The document appears to be a court transcript or legal document. The text is mostly printed, with no visible handwriting or stamps. The content discusses a legal case involving a client and the government, referencing bank accounts and financial transactions."
}