{
  "document_metadata": {
    "page_number": "133",
    "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, Page133 of 200\nk7e2MaxC kjc\nrisk of flight or dangerousness, they are still entitled to the\nsame Sixth Amendment rights to access defense counsel to\nprepare their case.\nMR. COHEN: Of course, your Honor. My point was a\nmore narrow point. My point is that the facts in those cases\nare different from our case in a meaningful way and the court\nwas doing a different evaluation. That was the point I was\nmaking on this case.\nSo in conclusion, we believe this is a compelling case\nfor bail. We believe that the government, which has the burden\nof persuasion that never shifts, has not made a showing as\nrequired, that our client is a risk of flight. When you\nconsider the risk, as Judge Raggi put it, in Sabhnani, the\nactual risk of flight, not fantasy and not speculation, when\nyou consider that the only factors they really point to are\nones that the cases have already addressed, such as\ninternational travel and passports.\nWe also submit that the government has not carried its\nburden of showing there is no condition or combination of\nconditions that secure release.\nSo we would ask the court to grant bail today. And if\nthe court needs more information from us, we would respectfully\nrequest that the court leave the proceeding open for a week so\nthat 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-00001074",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 21-770, Document 20-2, 04/01/2021, 3068530, Page133 of 200",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "k7e2MaxC kjc",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "risk of flight or dangerousness, they are still entitled to the\nsame Sixth Amendment rights to access defense counsel to\nprepare their case.\nMR. COHEN: Of course, your Honor. My point was a\nmore narrow point. My point is that the facts in those cases\nare different from our case in a meaningful way and the court\nwas doing a different evaluation. That was the point I was\nmaking on this case.\nSo in conclusion, we believe this is a compelling case\nfor bail. We believe that the government, which has the burden\nof persuasion that never shifts, has not made a showing as\nrequired, that our client is a risk of flight. When you\nconsider the risk, as Judge Raggi put it, in Sabhnani, the\nactual risk of flight, not fantasy and not speculation, when\nyou consider that the only factors they really point to are\nones that the cases have already addressed, such as\ninternational travel and passports.\nWe also submit that the government has not carried its\nburden of showing there is no condition or combination of\nconditions that secure release.\nSo we would ask the court to grant bail today. And if\nthe court needs more information from us, we would respectfully\nrequest that the court leave the proceeding open for a week so\nthat 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-00001074",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "MR. COHEN",
      "Judge Raggi"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "04/01/2021"
    ],
    "reference_numbers": [
      "Case 21-770",
      "Document 20-2",
      "3068530",
      "DOJ-OGR-00001074"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
}