{
  "document_metadata": {
    "page_number": "115",
    "document_number": "39-2",
    "date": "04/01/2021",
    "document_type": "court transcript",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 21-58, Document 39-2, 04/01/2021, 3068530, Page115 of 200 52\n1 appealed by the government; decision of the court, release on strict conditions. That is how the law works and comes out in this area, but that's something, your Honor, that the government did not address. And if the court determines that the conditions that we have proffered are insufficient or need further verification, as long as we can have some assurance of safety and confidentiality, we would recommend that the court keep the proceeding open, and we should be able to get whatever the court needs to satisfy it. So that's the legal analysis that was absent in the government's presentation today and its papers.\nLet me now, because I have to, because this has been put out before your Honor in, of course, a public proceeding, let me respond to some of the allegations made for the first time in the reply brief, trying to spin facts to make my client look sinister to your Honor.\nHere is fact one: She is a risk of flight because she has been hiding out. Well, let's think about this. She has been litigating civil cases in this courthouse and other parts of the country since 2015, denying, as she does here before your Honor, that she did anything improper with regards to Mr. Epstein. We submit, your Honor, that is the opposite of somebody who is looking to flee. And in fact, one of the people who spoke before your Honor is a plaintiff in one of those lawsuits seeking millions of dollars from our client and\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00019974",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 21-58, Document 39-2, 04/01/2021, 3068530, Page115 of 200 52",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "1 appealed by the government; decision of the court, release on strict conditions. That is how the law works and comes out in this area, but that's something, your Honor, that the government did not address. And if the court determines that the conditions that we have proffered are insufficient or need further verification, as long as we can have some assurance of safety and confidentiality, we would recommend that the court keep the proceeding open, and we should be able to get whatever the court needs to satisfy it. So that's the legal analysis that was absent in the government's presentation today and its papers.\nLet me now, because I have to, because this has been put out before your Honor in, of course, a public proceeding, let me respond to some of the allegations made for the first time in the reply brief, trying to spin facts to make my client look sinister to your Honor.\nHere is fact one: She is a risk of flight because she has been hiding out. Well, let's think about this. She has been litigating civil cases in this courthouse and other parts of the country since 2015, denying, as she does here before your Honor, that she did anything improper with regards to Mr. Epstein. We submit, your Honor, that is the opposite of somebody who is looking to flee. And in fact, one of the people who spoke before your Honor is a plaintiff in one of those lawsuits seeking millions of dollars from our client and",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00019974",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Mr. Epstein"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "04/01/2021",
      "2015"
    ],
    "reference_numbers": [
      "Case 21-58",
      "Document 39-2",
      "3068530",
      "DOJ-OGR-00019974"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
}