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    "page_number": "54",
    "document_number": "93",
    "date": "12/10/20",
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  "full_text": "Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 54 of 91\n\n1 MR. COHEN: To be precise, we were urging them not to\n2 return an indictment and saying we were always available to\n3 speak. And, frankly, your Honor, I have been doing this kind\n4 of work for 33 years, everyone knows what that means.\n5 THE COURT: So you were implying --\n6 (Indiscernible crosstalk)\n7 THE COURT: You were implying that, though you were\n8 urging --\n9 MR. COHEN: Yes.\n10 THE COURT: -- or seeking to forestall the indictment,\n11 should there be an indictment, you were implying that you\n12 should be contacted for voluntary surrender.\n13 MR. COHEN: Yes, of course. And the day after our\n14 client was arrested, we got a note from the government sending\n15 the application to detention addressed to us and Haddon Morgan\n16 saying your client, Ms. Maxwell, was arrested yesterday. So\n17 there was no doubt that we represented her along with Haddon\n18 Morgan. There was no doubt that we were available and could\n19 have been contacted and worked this out. There was no doubt\n20 that we are confident we would have.\n21 Let me turn to the reply brief and the effort to throw\n22 some more dirt on my client that we again submit should not be\n23 considered as part of the governing legal standards here and\n24 the precise question before the court. You heard it today and\n25 in the brief we hear that at the time of her arrest, the agents\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00001931",
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      "content": "1 MR. COHEN: To be precise, we were urging them not to return an indictment and saying we were always available to speak. And, frankly, your Honor, I have been doing this kind of work for 33 years, everyone knows what that means. THE COURT: So you were implying -- (Indiscernible crosstalk) THE COURT: You were implying that, though you were urging -- MR. COHEN: Yes. THE COURT: -- or seeking to forestall the indictment, should there be an indictment, you were implying that you should be contacted for voluntary surrender. MR. COHEN: Yes, of course. And the day after our client was arrested, we got a note from the government sending the application to detention addressed to us and Haddon Morgan saying your client, Ms. Maxwell, was arrested yesterday. So there was no doubt that we represented her along with Haddon Morgan. There was no doubt that we were available and could have been contacted and worked this out. There was no doubt that we are confident we would have. Let me turn to the reply brief and the effort to throw some more dirt on my client that we again submit should not be considered as part of the governing legal standards here and the precise question before the court. You heard it today and in the brief we hear that at the time of her arrest, the agents",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "content": "DOJ-OGR-00001931",
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  "entities": {
    "people": [
      "MR. COHEN",
      "Haddon Morgan",
      "Ms. Maxwell"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "12/10/20"
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    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "93",
      "DOJ-OGR-00001931"
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}