{
  "document_metadata": {
    "page_number": "141",
    "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, Page141 of 200\n\n1    because the conduct is 25 years old, among other reasons.\n2    And as to the risk of flight factors, Mr. Epstein had\n3    a prior felony conviction for conduct similar to that alleged\n4    in the indictment. The package before Judge Berman was only\n5    two suretors, and any properties that were offered to\n6    Judge Berman at the proceeding were already subject to\n7    forfeiture and so could not be proposed. So it is a very, very\n8    different situation in that case which was not raised by the\n9    government, and that's why we didn't address it.\n10    The last point which I meant to raise earlier, your\n11    Honor, and I will end with this, and I should have raised it\n12    earlier, what we sometimes see in bail cases, and I'm sure your\n13    Honor has seen this, is the government says, well, the\n14    defendant was hiding and we have evidence, your Honor, that the\n15    defendant was making plans to leave the country. That is the\n16    situation, frankly, in the U.S. v. Zarger case, the case by\n17    Judge Gleeson in 2000, that the government cites in its brief,\n18    but of course doesn't discuss the facts. There is nothing to\n19    that effect here. To the contrary, the defendant, our client,\n20    is sitting in New Hampshire at the time of the arrest. So\n21    there is no evidence that there was some sort of imminence for\n22    the court to consider.\n23    So not to repeat all the arguments we made, we thank\n24    the court for your time and for reading the submissions and\n25    listening, and we just think, Judge, when you step back, the\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00001082",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 21-770, Document 20-2, 04/01/2021, 3068530, Page141 of 200",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "1    because the conduct is 25 years old, among other reasons.\n2    And as to the risk of flight factors, Mr. Epstein had\n3    a prior felony conviction for conduct similar to that alleged\n4    in the indictment. The package before Judge Berman was only\n5    two suretors, and any properties that were offered to\n6    Judge Berman at the proceeding were already subject to\n7    forfeiture and so could not be proposed. So it is a very, very\n8    different situation in that case which was not raised by the\n9    government, and that's why we didn't address it.\n10    The last point which I meant to raise earlier, your\n11    Honor, and I will end with this, and I should have raised it\n12    earlier, what we sometimes see in bail cases, and I'm sure your\n13    Honor has seen this, is the government says, well, the\n14    defendant was hiding and we have evidence, your Honor, that the\n15    defendant was making plans to leave the country. That is the\n16    situation, frankly, in the U.S. v. Zarger case, the case by\n17    Judge Gleeson in 2000, that the government cites in its brief,\n18    but of course doesn't discuss the facts. There is nothing to\n19    that effect here. To the contrary, the defendant, our client,\n20    is sitting in New Hampshire at the time of the arrest. So\n21    there is no evidence that there was some sort of imminence for\n22    the court to consider.\n23    So not to repeat all the arguments we made, we thank\n24    the court for your time and for reading the submissions and\n25    listening, and we just think, Judge, when you step back, the",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001082",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Mr. Epstein",
      "Judge Berman",
      "Judge Gleeson"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [
      "New Hampshire"
    ],
    "dates": [
      "04/01/2021",
      "2000"
    ],
    "reference_numbers": [
      "Case 21-770",
      "Document 20-2",
      "3068530",
      "DOJ-OGR-00001082"
    ]
  },
  "additional_notes": "The document appears to be a court transcript or legal document. It is typed and contains no handwritten text or stamps. The content discusses a legal case and references various legal precedents and individuals involved in the case."
}