{
  "document_metadata": {
    "page_number": "131",
    "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, Page131 of 200\n\n1    investigations. There is the investigation of our client and\n2    there is the investigation of Mr. Epstein. And they are, in\n3    the government's words, in our words together, voluminous\n4    materials. We haven't seen any of it yet, but voluminous,\n5    including voluminous electronic materials. The notion that we\n6    would be able to in any meaningful way review these with our\n7    client to prepare the case for motion and for trial under the\n8    current pandemic situation is just not realistic. It is not\n9    meaningful. It is not fair. And I should say, as your Honor\n10   noted, in the Stephens case, we are not faulting the Bureau of\n11   Prisons. We are not faulting the Marshal Service. We\n12   understand they are doing the best they can under the\n13   circumstances. But this is just not realistic. We have\n14   conduct that's alleged to be 25 years old. You have extensive\n15   discovery that's going to take the government, if they hit the\n16   deadlines your Honor set -- and we all know that sometimes it\n17   doesn't happen -- four and a half months to provide, and the\n18   government wants our client to remain in custody that whole\n19   time, without being able to meet with us in person, with\n20   limited access in some form of administrative seg., apparently\n21   because they are afraid of what happened with Mr. Epstein, I\n22   don't know, and it is just not a realistic way to prepare a\n23   case, particularly, your Honor, when, as we submit, the\n24   conditions and combination of conditions to secure her release\n25   can be satisfied here under your Honor's guidance.\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00001072",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 21-770, Document 20-2, 04/01/2021, 3068530, Page131 of 200",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "1    investigations. There is the investigation of our client and\n2    there is the investigation of Mr. Epstein. And they are, in\n3    the government's words, in our words together, voluminous\n4    materials. We haven't seen any of it yet, but voluminous,\n5    including voluminous electronic materials. The notion that we\n6    would be able to in any meaningful way review these with our\n7    client to prepare the case for motion and for trial under the\n8    current pandemic situation is just not realistic. It is not\n9    meaningful. It is not fair. And I should say, as your Honor\n10   noted, in the Stephens case, we are not faulting the Bureau of\n11   Prisons. We are not faulting the Marshal Service. We\n12   understand they are doing the best they can under the\n13   circumstances. But this is just not realistic. We have\n14   conduct that's alleged to be 25 years old. You have extensive\n15   discovery that's going to take the government, if they hit the\n16   deadlines your Honor set -- and we all know that sometimes it\n17   doesn't happen -- four and a half months to provide, and the\n18   government wants our client to remain in custody that whole\n19   time, without being able to meet with us in person, with\n20   limited access in some form of administrative seg., apparently\n21   because they are afraid of what happened with Mr. Epstein, I\n22   don't know, and it is just not a realistic way to prepare a\n23   case, particularly, your Honor, when, as we submit, the\n24   conditions and combination of conditions to secure her release\n25   can be satisfied here under your Honor's guidance.",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001072",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Mr. Epstein"
    ],
    "organizations": [
      "Bureau of Prisons",
      "Marshal Service",
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "04/01/2021"
    ],
    "reference_numbers": [
      "Case 21-770",
      "Document 20-2",
      "3068530",
      "DOJ-OGR-00001072"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
}