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    "page_number": "67",
    "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 67 of 91\n\n1 originally without prejudice obviously for precisely the\n2 proceeding we are having, but it sounded like you were\n3 suggesting that her current detention was in some way by design\n4 to prevent you from providing a full picture of her financial\n5 situation. Is that the implication you are making?\n6 MR. COHEN: No, I am not saying that, your Honor. I\n7 am not going that far. What I am saying is, when you have a\n8 client who will voluntary surrender, who is staying in the\n9 country despite an investigation, and the government instead\n10 chooses to arrest her and detain her, that limits in the early\n11 instances your access to the client. It is complicated by the\n12 COVID crisis and the other factors your Honor has pointed out\n13 in Stephens and in Williams-Bethea, and so it is very hard for\n14 us to pull together this financial information, and we have\n15 done it as quickly as we could before the court. But the\n16 notion that my client should have been able to answer off the\n17 top of her head the questions from Pretrial Services about a\n18 real estate transaction, for example, just doesn't make any\n19 sense. That's the point we are making.\n20 THE COURT: Okay.\n21 MR. COHEN: One last point in that regard, your Honor,\n22 in the schedule we set today -- thank you, your Honor, for\n23 approving that -- the government is saying that it needs at\n24 least until November to complete all discovery, including\n25 electronic discovery. They have told us that there are two\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00001944",
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      "content": "Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 67 of 91",
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      "content": "1 originally without prejudice obviously for precisely the\n2 proceeding we are having, but it sounded like you were\n3 suggesting that her current detention was in some way by design\n4 to prevent you from providing a full picture of her financial\n5 situation. Is that the implication you are making?\n6 MR. COHEN: No, I am not saying that, your Honor. I\n7 am not going that far. What I am saying is, when you have a\n8 client who will voluntary surrender, who is staying in the\n9 country despite an investigation, and the government instead\n10 chooses to arrest her and detain her, that limits in the early\n11 instances your access to the client. It is complicated by the\n12 COVID crisis and the other factors your Honor has pointed out\n13 in Stephens and in Williams-Bethea, and so it is very hard for\n14 us to pull together this financial information, and we have\n15 done it as quickly as we could before the court. But the\n16 notion that my client should have been able to answer off the\n17 top of her head the questions from Pretrial Services about a\n18 real estate transaction, for example, just doesn't make any\n19 sense. That's the point we are making.\n20 THE COURT: Okay.\n21 MR. COHEN: One last point in that regard, your Honor,\n22 in the schedule we set today -- thank you, your Honor, for\n23 approving that -- the government is saying that it needs at\n24 least until November to complete all discovery, including\n25 electronic discovery. They have told us that there are two",
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      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
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      "content": "DOJ-OGR-00001944",
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  "entities": {
    "people": [
      "COHEN"
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    "organizations": [
      "Pretrial Services",
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    "dates": [
      "12/10/20",
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      "93",
      "DOJ-OGR-00001944"
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}