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    "page_number": "58",
    "document_number": "93",
    "date": "12/10/20",
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  "full_text": "Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 58 of 91 58\n\n1 regular contact with the government, is removed in a property in the United States. That's the opposite of hiding. So we\n2 in the United States.  think that those kinds of facts, I'm sure, your Honor, if your Honor decides to keep the proceedings open and give us a chance\n3 to come on some issues, I'm sure we will have some more facts tomorrow and the next day, all with the disclaimer, we just\n4 learned this, your Honor. They have been investigating this case for ten years, your Honor, okay?\n5\n6 So let me turn now to another factor that the government made argument about briefly, two more factors under\n7 31(g)(3), the history and characteristics of the defendant. We heard several times that there was a -- that detention should\n8 be warranted because there is a perjury charge. Very quickly, your Honor, we submit this does not tip the balance in the 3142\n9 analysis that the court has to perform.\n10 First and foremost, the defendant is, of course, presumed innocent; and, secondly, the allegation and nature of\n11 the perjury, if the court has been through the indictment, is someone who denies guilt, who says they are innocent, is asked\n12 in a deposition did you do that and says no, the government charges them with perjury. That is not -- other than the fact\n13 that it's an indicted charge, they are still entitled to the weight the court would give a not indicted charge. That's all\n14 the weight it should be given.\n15 Let me turn to another factor that the government\n16\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00001935",
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      "content": "1 regular contact with the government, is removed in a property in the United States. That's the opposite of hiding. So we\n2 in the United States.  think that those kinds of facts, I'm sure, your Honor, if your Honor decides to keep the proceedings open and give us a chance\n3 to come on some issues, I'm sure we will have some more facts tomorrow and the next day, all with the disclaimer, we just\n4 learned this, your Honor. They have been investigating this case for ten years, your Honor, okay?\n5\n6 So let me turn now to another factor that the government made argument about briefly, two more factors under\n7 31(g)(3), the history and characteristics of the defendant. We heard several times that there was a -- that detention should\n8 be warranted because there is a perjury charge. Very quickly, your Honor, we submit this does not tip the balance in the 3142\n9 analysis that the court has to perform.\n10 First and foremost, the defendant is, of course, presumed innocent; and, secondly, the allegation and nature of\n11 the perjury, if the court has been through the indictment, is someone who denies guilt, who says they are innocent, is asked\n12 in a deposition did you do that and says no, the government charges them with perjury. That is not -- other than the fact\n13 that it's an indicted charge, they are still entitled to the weight the court would give a not indicted charge. That's all\n14 the weight it should be given.\n15 Let me turn to another factor that the government",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
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      "content": "DOJ-OGR-00001935",
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    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "locations": [
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    "dates": [
      "12/10/20"
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      "1:20-cr-00330-AJN",
      "Document 93",
      "DOJ-OGR-00001935"
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}