{
  "document_metadata": {
    "page_number": "78",
    "document_number": "93",
    "date": "12/10/20",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 78 of 91 78\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\nDOJ-OGR-00001955",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 78 of 91 78",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "because the conduct is 25 years old, among other reasons.\nAnd as to the risk of flight factors, Mr. Epstein had\na prior felony conviction for conduct similar to that alleged\nin the indictment. The package before Judge Berman was only\ntwo suretors, and any properties that were offered to\nJudge Berman at the proceeding were already subject to\nforfeiture and so could not be proposed. So it is a very, very\ndifferent situation in that case which was not raised by the\ngovernment, and that's why we didn't address it.\nThe last point which I meant to raise earlier, your\nHonor, and I will end with this, and I should have raised it\nearlier, what we sometimes see in bail cases, and I'm sure your\nHonor has seen this, is the government says, well, the\ndefendant was hiding and we have evidence, your Honor, that the\ndefendant was making plans to leave the country. That is the\nsituation, frankly, in the U.S. v. Zarger case, the case by\nJudge Gleeson in 2000, that the government cites in its brief,\nbut of course doesn't discuss the facts. There is nothing to\nthat effect here. To the contrary, the defendant, our client,\nis sitting in New Hampshire at the time of the arrest. So\nthere is no evidence that there was some sort of imminence for\nthe court to consider.\nSo not to repeat all the arguments we made, we thank\nthe court for your time and for reading the submissions and\nlistening, 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-00001955",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Mr. Epstein",
      "Judge Berman",
      "Judge Gleeson"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [
      "New Hampshire"
    ],
    "dates": [
      "12/10/20",
      "2000"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 93",
      "DOJ-OGR-00001955"
    ]
  },
  "additional_notes": "The document appears to be a court transcript or legal document related to a case involving Mr. Epstein. The text is typed and there are no visible handwritten notes or stamps. The document includes a reference to a specific case (U.S. v. Zarger) and mentions judges and locations."
}