{
  "document_metadata": {
    "page_number": "128",
    "document_number": "20-2",
    "date": "04/01/2021",
    "document_type": "court transcript",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 21-770, Document 20-2, 04/01/2021, 3068530, Page128 of 200\nk7e2MaxC kjc\n1 litigation before your Honor about what is in the NPA, and the\ngovernment, we expect, is going to take the position that\nunlike '07 is covered and nothing else. We disagree with that,\nwhich we will lay out for your Honor. What do they do? They\ndecide we will reach back and indict '94 to '97, totally\ntactical, your Honor. So now we have a case where the conduct\nis 25 years old, no tapes, no video, none of the sort of things\nyou would expect in that age of case, that we are going to have\nto defend, and we are going to defend. And I think it goes to\nthe court's consideration of the weight in the context of the\nonly application that's before your Honor, which is how to\nweigh the 3142 factors with the structure of the statute, with\nthe guidance of the Second Circuit and the Supreme Court, which\nis in favor of bail, in favor of bail on appropriate\nconditions.\nSo we submit that the package we laid out for the\ncourt is sufficient that we are certainly willing if the court\ndeems it necessary to leave the proceeding open and we think we\ncould be back before the court within a week if that is what\nthe court wants or there is more detail which has been hammered\nby the fact that our client has been, by design, by design,\nkept in custody. And let me just give your Honor a little\nflavor.\nTHE COURT: Wait, Mr. Cohen. I missed that last point\ncould you repeat it, please.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00001069",
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    {
      "type": "printed",
      "content": "Case 21-770, Document 20-2, 04/01/2021, 3068530, Page128 of 200",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "k7e2MaxC kjc",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "1 litigation before your Honor about what is in the NPA, and the\ngovernment, we expect, is going to take the position that\nunlike '07 is covered and nothing else. We disagree with that,\nwhich we will lay out for your Honor. What do they do? They\ndecide we will reach back and indict '94 to '97, totally\ntactical, your Honor. So now we have a case where the conduct\nis 25 years old, no tapes, no video, none of the sort of things\nyou would expect in that age of case, that we are going to have\nto defend, and we are going to defend. And I think it goes to\nthe court's consideration of the weight in the context of the\nonly application that's before your Honor, which is how to\nweigh the 3142 factors with the structure of the statute, with\nthe guidance of the Second Circuit and the Supreme Court, which\nis in favor of bail, in favor of bail on appropriate\nconditions.",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "So we submit that the package we laid out for the\ncourt is sufficient that we are certainly willing if the court\ndeems it necessary to leave the proceeding open and we think we\ncould be back before the court within a week if that is what\nthe court wants or there is more detail which has been hammered\nby the fact that our client has been, by design, by design,\nkept in custody. And let me just give your Honor a little\nflavor.",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "THE COURT: Wait, Mr. Cohen. I missed that last point\ncould you repeat it, please.",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001069",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Mr. Cohen"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C.",
      "Second Circuit",
      "Supreme Court"
    ],
    "locations": [],
    "dates": [
      "04/01/2021",
      "'07",
      "'94",
      "'97"
    ],
    "reference_numbers": [
      "Case 21-770",
      "Document 20-2",
      "3068530",
      "3142",
      "DOJ-OGR-00001069"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
}