{
  "document_metadata": {
    "page_number": "63",
    "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 63 of 91 63\n\n1 defendant, the less important it becomes to identify and restrain each and every asset over which defendants may\n2 exercise some control in order to mitigate risk of flight.\" So if the court -- and we have suggested them, but they may be\n3 modified by the court -- can put in place stringent bail conditions, we don't need to have a side-long, month-long\n4 hearing about my client's assets which is just designed to keep her in detention. That was an observation by Judge Raggi in\n5 Sabhnani.\n6 Judge, very quickly on the nature and circumstances of the offense and the weight of the evidence, we don't think,\n7 your Honor, this is the place to litigate legal motions. This is a bail hearing. It is not the place to litigate complex\n8 legal questions that we will be presenting to your Honor. It's very soon on the motion schedule, and we thank the court for\n9 agreeing to the schedule. But there are a few things that are worth pointing out.\n10 We believe there are very significant motions here that will affect whether this indictment survives at all or the shape of this indictment and, given the government's representation that it is not planning to supersede, will\n11 affect the shape of the entire case, or any case at all that proceeds before the court at trial, if there is a trial. That is exactly what we submit the court can consider, again, in exercising its discretion as to the weight of the evidence.\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00001940",
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      "content": "Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 63 of 91 63",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "1 defendant, the less important it becomes to identify and restrain each and every asset over which defendants may\n2 exercise some control in order to mitigate risk of flight.\" So if the court -- and we have suggested them, but they may be\n3 modified by the court -- can put in place stringent bail conditions, we don't need to have a side-long, month-long\n4 hearing about my client's assets which is just designed to keep her in detention. That was an observation by Judge Raggi in\n5 Sabhnani.\n6 Judge, very quickly on the nature and circumstances of the offense and the weight of the evidence, we don't think,\n7 your Honor, this is the place to litigate legal motions. This is a bail hearing. It is not the place to litigate complex\n8 legal questions that we will be presenting to your Honor. It's very soon on the motion schedule, and we thank the court for\n9 agreeing to the schedule. But there are a few things that are worth pointing out.\n10 We believe there are very significant motions here that will affect whether this indictment survives at all or the shape of this indictment and, given the government's representation that it is not planning to supersede, will\n11 affect the shape of the entire case, or any case at all that proceeds before the court at trial, if there is a trial. That is exactly what we submit the court can consider, again, in exercising its discretion as to the weight of the evidence.",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001940",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Judge Raggi"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "12/10/20"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "93",
      "DOJ-OGR-00001940"
    ]
  },
  "additional_notes": "The document appears to be a court transcript or legal document from a case with the reference number 1:20-cr-00330-AJN. The text is mostly printed, with no visible handwriting or stamps. The document is from the Southern District Reporters, P.C., and includes their contact information."
}