{
  "document_metadata": {
    "page_number": "135",
    "document_number": "20-2",
    "date": "04/01/2021",
    "document_type": "court document",
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    "has_stamps": false
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  "full_text": "Case 21-770, Document 20-2, 04/01/2021, 3068530, Page135 of 200\n\n1 Turning to several specific points, your Honor, that I\n2 would like to respond to. I want to address the notion that\n3 the defendant would have surrendered if the government had\n4 asked her to. As defense counsel conceded, no offer along\n5 those lines was ever made. And of course the government\n6 doesn't have to accept the defense counsel's representation\n7 that their client would surrender.\n8 In fact, the fact that the government took these\n9 measures to arrest the defendant reflects how seriously the\n10 government takes the risk of the defendant of flight. Why on\n11 earth would the government notify the defendant through her\n12 counsel that she was about to be indicted and arrested if the\n13 government had serious concerns that she was a risk of flight?\n14 That is exactly what occurred here.\n15 In addition, it is interesting that defense counsel\n16 notes that it should have been obvious to the government that\n17 the defendant would have surrendered when, at the same time, in\n18 civil litigation in this district, defense counsel declined to\n19 accept service on behalf of plaintiffs who were seeking to sue\n20 the defendant in connection with some of these allegations, and\n21 they were required to seek leave of the court to serve the\n22 defendant through their counsel.\n23 Your Honor, turning to the question of the defendant's\n24 finances there is still at this point no substantive response\n25 regarding defendant's finances or about the lack of candor to\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00001076",
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      "content": "Case 21-770, Document 20-2, 04/01/2021, 3068530, Page135 of 200",
      "position": "header"
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    {
      "type": "printed",
      "content": "1 Turning to several specific points, your Honor, that I\n2 would like to respond to. I want to address the notion that\n3 the defendant would have surrendered if the government had\n4 asked her to. As defense counsel conceded, no offer along\n5 those lines was ever made. And of course the government\n6 doesn't have to accept the defense counsel's representation\n7 that their client would surrender.\n8 In fact, the fact that the government took these\n9 measures to arrest the defendant reflects how seriously the\n10 government takes the risk of the defendant of flight. Why on\n11 earth would the government notify the defendant through her\n12 counsel that she was about to be indicted and arrested if the\n13 government had serious concerns that she was a risk of flight?\n14 That is exactly what occurred here.\n15 In addition, it is interesting that defense counsel\n16 notes that it should have been obvious to the government that\n17 the defendant would have surrendered when, at the same time, in\n18 civil litigation in this district, defense counsel declined to\n19 accept service on behalf of plaintiffs who were seeking to sue\n20 the defendant in connection with some of these allegations, and\n21 they were required to seek leave of the court to serve the\n22 defendant through their counsel.\n23 Your Honor, turning to the question of the defendant's\n24 finances there is still at this point no substantive response\n25 regarding defendant's finances or about the lack of candor to",
      "position": "main content"
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    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001076",
      "position": "footer"
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  ],
  "entities": {
    "people": [],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "04/01/2021"
    ],
    "reference_numbers": [
      "Case 21-770",
      "Document 20-2",
      "3068530",
      "DOJ-OGR-00001076"
    ]
  },
  "additional_notes": "The document appears to be a court transcript or legal document. It is typed and contains no handwritten text or stamps. The content is a legal argument or statement made by a representative of the government in a court case."
}