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  "document_metadata": {
    "page_number": "105",
    "document_number": "20-2",
    "date": "04/01/2021",
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  "full_text": "Case 21-770, Document 20-2, 04/01/2021, 3068530, Page105 of 200\n42\n1 THE COURT: Thank you, Ms. Moe.\n2 Mr. Cohen, you may proceed.\n3 MR. COHEN: Thank you, your Honor. Thank you very much for the opportunity to be heard and also for accommodating us with regard to the briefing schedule. We appreciate that, your Honor.\n4 \n5 \n6 \n7 Your Honor, this is a very important proceeding for my client. It is critical and we submit, as we laid out in our papers, that under the Bail Reform Act and related case law, none of which, by the way, was discussed in the government's presentation, she is -- she ought to be released on a bail package with strict conditions, your Honor.\n8 \n9 \n10 \n11 \n12 \n13 And, frankly, in order to defend a case like this during the COVID crisis, with the extent of discovery which was discussed earlier in the proceeding, that's going to take the government until November to produce to us, the notion of preparing a defense with our client while she is in custody under these conditions is just not realistic.\n14 \n15 \n16 \n17 \n18 \n19 I would also like to take a moment, your Honor, to address a few things. As we noted in our papers, our client is not Jeffrey Epstein, and she has been the target of essentially endless media spin that apparently the government has picked up in its reply brief and in its presentation today, trying to portray her before the court as a ruthless, aimless, sinister person.\n20 \n21 \n22 \n23 \n24 \n25 \nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00001046",
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      "content": "Case 21-770, Document 20-2, 04/01/2021, 3068530, Page105 of 200",
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      "content": "42",
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      "content": "1 THE COURT: Thank you, Ms. Moe.\n2 Mr. Cohen, you may proceed.\n3 MR. COHEN: Thank you, your Honor. Thank you very much for the opportunity to be heard and also for accommodating us with regard to the briefing schedule. We appreciate that, your Honor.\n4 \n5 \n6 \n7 Your Honor, this is a very important proceeding for my client. It is critical and we submit, as we laid out in our papers, that under the Bail Reform Act and related case law, none of which, by the way, was discussed in the government's presentation, she is -- she ought to be released on a bail package with strict conditions, your Honor.\n8 \n9 \n10 \n11 \n12 \n13 And, frankly, in order to defend a case like this during the COVID crisis, with the extent of discovery which was discussed earlier in the proceeding, that's going to take the government until November to produce to us, the notion of preparing a defense with our client while she is in custody under these conditions is just not realistic.\n14 \n15 \n16 \n17 \n18 \n19 I would also like to take a moment, your Honor, to address a few things. As we noted in our papers, our client is not Jeffrey Epstein, and she has been the target of essentially endless media spin that apparently the government has picked up in its reply brief and in its presentation today, trying to portray her before the court as a ruthless, aimless, sinister person.\n20 \n21 \n22 \n23 \n24 \n25",
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      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
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      "content": "DOJ-OGR-00001046",
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  "entities": {
    "people": [
      "Ms. Moe",
      "Mr. Cohen",
      "Jeffrey Epstein"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C.",
      "DOJ"
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    "locations": [],
    "dates": [
      "04/01/2021",
      "November"
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    "reference_numbers": [
      "Case 21-770",
      "Document 20-2",
      "3068530",
      "DOJ-OGR-00001046"
    ]
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}