{
  "document_metadata": {
    "page_number": "64",
    "document_number": "93",
    "date": "12/10/20",
    "document_type": "court transcript",
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  "full_text": "Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 64 of 91\nk7e2MaxC kjc\n1 We believe there are significant motions relating to\n2 the reach of the NPA, which we are not going to litigate here\n3 before your Honor in a bail proceeding, that are not even\n4 foreclosed by the cases the government does cite to you. They\n5 cite to you the -- I'm going to skip this one, the Annabi case,\n6 A-N-N-A-B-I case, which says, \"The plea agreement binds only\n7 the office of the U.S. Attorney for the district in which the\n8 plea is entered unless it affirmatively appears that the\n9 agreement contemplates a broader restriction,\" and that in part\n10 is going to be our argument. So we will make it to your Honor\n11 at the appropriate time. For today's purposes, it should be in\n12 the mix in evaluating the weight of the evidence as should the\n13 points I just made about the perjury charge and we think that\n14 there are other significant legal challenges to the indictment.\n15 We also think there are significant issues with the\n16 weight of the evidence. The government chose to indict conduct\n17 that's 25 years old, your Honor. You will see when you get our\n18 motions that this, we think, is an effort to dance around the\n19 NPA, to come into an earlier time period, a related time\n20 period. It's all tactics. That's all this is about. This\n21 case is about tactics. It's an effort to dance around the NPA.\n22 But the fact of the matter is the government --\n23 THE COURT: Mr. Cohen, I'm sorry, by that do you mean\n24 that the time period charged is not covered by the NPA.\n25 MR. COHEN: Right. Exactly. There is going to be\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00001941",
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      "content": "Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 64 of 91",
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    {
      "type": "printed",
      "content": "k7e2MaxC kjc",
      "position": "header"
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      "type": "printed",
      "content": "1 We believe there are significant motions relating to\n2 the reach of the NPA, which we are not going to litigate here\n3 before your Honor in a bail proceeding, that are not even\n4 foreclosed by the cases the government does cite to you. They\n5 cite to you the -- I'm going to skip this one, the Annabi case,\n6 A-N-N-A-B-I case, which says, \"The plea agreement binds only\n7 the office of the U.S. Attorney for the district in which the\n8 plea is entered unless it affirmatively appears that the\n9 agreement contemplates a broader restriction,\" and that in part\n10 is going to be our argument. So we will make it to your Honor\n11 at the appropriate time. For today's purposes, it should be in\n12 the mix in evaluating the weight of the evidence as should the\n13 points I just made about the perjury charge and we think that\n14 there are other significant legal challenges to the indictment.\n15 We also think there are significant issues with the\n16 weight of the evidence. The government chose to indict conduct\n17 that's 25 years old, your Honor. You will see when you get our\n18 motions that this, we think, is an effort to dance around the\n19 NPA, to come into an earlier time period, a related time\n20 period. It's all tactics. That's all this is about. This\n21 case is about tactics. It's an effort to dance around the NPA.\n22 But the fact of the matter is the government --\n23 THE COURT: Mr. Cohen, I'm sorry, by that do you mean\n24 that the time period charged is not covered by the NPA.\n25 MR. COHEN: Right. Exactly. There is going to be",
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      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001941",
      "position": "footer"
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  "entities": {
    "people": [
      "Mr. Cohen"
    ],
    "organizations": [
      "U.S. Attorney",
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "12/10/20"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 93",
      "DOJ-OGR-00001941"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
}