{
  "document_metadata": {
    "page_number": "48",
    "document_number": "93",
    "date": "12/10/20",
    "document_type": "court transcript",
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    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 48 of 91\n\nconditions. So what we did is we went through all the high profile cases in this courthouse in the past several years and other cases, cases like Madoff, cases like Dreier, cases like Esposito, where Judge Marrero ruled in 2018 relating to an alleged member of organized crime, and we went through those cases to find the conditions that were listed under 3142(c), and in those cases that would we believe be relevant and applicable here, and we believe we have listed them all. We understand that of course they would be subject to verification; and as we noted in our papers and I noted today, if we could have a guarantee of safety, if we could have a guarantee of privacy and confidentiality, and if the court required it, we believe there are other suretors who we could provide and perhaps other amounts of property as well. That is an issue. It is a real issue in this case. It is something the government is just avoiding, but it is real.\n\nSo let me talk now, your Honor, if I might, about the 3142(g)(3) factors, which are the factors relating to the history of the defendant.\n\nThe government said --\n\nTHE COURT: Mr. Cohen, just before you move to that, the three cases that you cited -- Esposito, Dreier, Madoff -- factually did any of those cases involve defendants with substantial international and foreign connections?\n\nMR. COHEN: No, I don't believe they did. The cases\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00001925",
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      "content": "Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 48 of 91",
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    {
      "type": "printed",
      "content": "conditions. So what we did is we went through all the high profile cases in this courthouse in the past several years and other cases, cases like Madoff, cases like Dreier, cases like Esposito, where Judge Marrero ruled in 2018 relating to an alleged member of organized crime, and we went through those cases to find the conditions that were listed under 3142(c), and in those cases that would we believe be relevant and applicable here, and we believe we have listed them all. We understand that of course they would be subject to verification; and as we noted in our papers and I noted today, if we could have a guarantee of safety, if we could have a guarantee of privacy and confidentiality, and if the court required it, we believe there are other suretors who we could provide and perhaps other amounts of property as well. That is an issue. It is a real issue in this case. It is something the government is just avoiding, but it is real.\n\nSo let me talk now, your Honor, if I might, about the 3142(g)(3) factors, which are the factors relating to the history of the defendant.\n\nThe government said --\n\nTHE COURT: Mr. Cohen, just before you move to that, the three cases that you cited -- Esposito, Dreier, Madoff -- factually did any of those cases involve defendants with substantial international and foreign connections?\n\nMR. COHEN: No, I don't believe they did. The cases",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001925",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Marrero",
      "Madoff",
      "Dreier",
      "Esposito",
      "Cohen"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C.",
      "DOJ"
    ],
    "locations": [],
    "dates": [
      "12/10/20",
      "2018"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "93",
      "3142(c)",
      "3142(g)(3)",
      "DOJ-OGR-00001925"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a clear and readable format. There are no visible redactions or damage."
}