{
  "document_metadata": {
    "page_number": "122",
    "document_number": "20-2",
    "date": "04/01/2021",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 21-770, Document 20-2, 04/01/2021, 3068530, Page122 of 200\n\n1 mentioned in its presentation, both in its papers and today,\n2 that relates to 3142(g)(3), which is the defendant's financial\n3 situation.\n4 Again, when you look at the case law, which is not\n5 addressed by the government at all, this is a person who has\n6 passports that can be surrendered, who has travel that can be\n7 restricted, who has citizenship that the courts have taking\n8 account of, and does have financial means. Does she have the\n9 financial means that the government says she has? We doubt it.\n10 But does she have hundreds of millions of dollars like those in\n11 the Madoff and Dreier case? No.\n12 But it doesn't matter. Even if the court were to\n13 assume for purposes of today's proceeding that she has the\n14 means that the government claims she does, it does not affect\n15 the analysis. That is to be addressed in conditions, to be\n16 addressed if the court requires it, through verifications and\n17 further proceedings before the court.\n18 And let me just address some of the allegations made\n19 in the government's brief about her financial situation. The\n20 government goes out and arrests our client even though she\n21 would have voluntarily surrendered, arrests her the day before\n22 a federal holiday, so she spends extra time in the\n23 New Hampshire prison before being transported here, and then\n24 says, how come you don't have a full account of your financial\n25 condition? How come, when Pretrial Services asked about it,\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00001063",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 21-770, Document 20-2, 04/01/2021, 3068530, Page122 of 200",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "1 mentioned in its presentation, both in its papers and today,\n2 that relates to 3142(g)(3), which is the defendant's financial\n3 situation.\n4 Again, when you look at the case law, which is not\n5 addressed by the government at all, this is a person who has\n6 passports that can be surrendered, who has travel that can be\n7 restricted, who has citizenship that the courts have taking\n8 account of, and does have financial means. Does she have the\n9 financial means that the government says she has? We doubt it.\n10 But does she have hundreds of millions of dollars like those in\n11 the Madoff and Dreier case? No.\n12 But it doesn't matter. Even if the court were to\n13 assume for purposes of today's proceeding that she has the\n14 means that the government claims she does, it does not affect\n15 the analysis. That is to be addressed in conditions, to be\n16 addressed if the court requires it, through verifications and\n17 further proceedings before the court.\n18 And let me just address some of the allegations made\n19 in the government's brief about her financial situation. The\n20 government goes out and arrests our client even though she\n21 would have voluntarily surrendered, arrests her the day before\n22 a federal holiday, so she spends extra time in the\n23 New Hampshire prison before being transported here, and then\n24 says, how come you don't have a full account of your financial\n25 condition? How come, when Pretrial Services asked about it,",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001063",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Madoff",
      "Dreier"
    ],
    "organizations": [
      "Pretrial Services",
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [
      "New Hampshire"
    ],
    "dates": [
      "04/01/2021"
    ],
    "reference_numbers": [
      "Case 21-770",
      "Document 20-2",
      "3068530",
      "DOJ-OGR-00001063"
    ]
  },
  "additional_notes": "The document appears to be a court transcript or legal document. It is typed and has a formal tone. There are no visible redactions or damage."
}