{
  "document_metadata": {
    "page_number": "70",
    "document_number": "93",
    "date": "12/10/20",
    "document_type": "court transcript",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 70 of 91\nrisk of flight or dangerousness, they are still entitled to the same Sixth Amendment rights to access defense counsel to prepare their case.\nMR. COHEN: Of course, your Honor. My point was a more narrow point. My point is that the facts in those cases are different from our case in a meaningful way and the court was doing a different evaluation. That was the point I was making on this case.\nSo in conclusion, we believe this is a compelling case for bail. We believe that the government, which has the burden of persuasion that never shifts, has not made a showing as required, that our client is a risk of flight. When you consider the risk, as Judge Raggi put it, in Sabhnani, the actual risk of flight, not fantasy and not speculation, when you consider that the only factors they really point to are ones that the cases have already addressed, such as international travel and passports.\nWe also submit that the government has not carried its burden of showing there is no condition or combination of conditions that secure release.\nSo we would ask the court to grant bail today. And if the court needs more information from us, we would respectfully request that the court leave the proceeding open for a week so that we can try to satisfy the court because we want to.\nThank you, your Honor, for your time.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00001947",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 70 of 91",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "risk of flight or dangerousness, they are still entitled to the same Sixth Amendment rights to access defense counsel to prepare their case.\nMR. COHEN: Of course, your Honor. My point was a more narrow point. My point is that the facts in those cases are different from our case in a meaningful way and the court was doing a different evaluation. That was the point I was making on this case.\nSo in conclusion, we believe this is a compelling case for bail. We believe that the government, which has the burden of persuasion that never shifts, has not made a showing as required, that our client is a risk of flight. When you consider the risk, as Judge Raggi put it, in Sabhnani, the actual risk of flight, not fantasy and not speculation, when you consider that the only factors they really point to are ones that the cases have already addressed, such as international travel and passports.\nWe also submit that the government has not carried its burden of showing there is no condition or combination of conditions that secure release.\nSo we would ask the court to grant bail today. And if the court needs more information from us, we would respectfully request that the court leave the proceeding open for a week so that we can try to satisfy the court because we want to.\nThank you, your Honor, for your time.",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001947",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "MR. COHEN",
      "Judge Raggi"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "12/10/20"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 93",
      "DOJ-OGR-00001947"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with clear and legible text. There are no visible redactions or damage."
}