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- {
- "document_metadata": {
- "page_number": "48",
- "document_number": "36",
- "date": "07/24/19",
- "document_type": "court document",
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- "has_stamps": false
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- "full_text": "Case 1:19-cr-00490-RMB Document 36 Filed 07/24/19 Page 48 of 74 48\nthat your Honor has clear and convincing proof occurred, much less the predictive factor that if Mr. Epstein was released under the kind of combination of conditions, there would be any risk of his influencing adversely a witness, now that there is a federal prosecution. That would be self-destructive. It would constitute a crime with a nexus to what the statutes require.\nBut the conditions also, your Honor, radically limit -- we've asked your Honor for home detention, and I will get to the monetary conditions and the risk of flight in a moment.\nWe've asked for home detention. We've asked for the visiting list to be approved by pretrial, meaning almost nobody except Mr. Weingarten and myself, Mr. Fernich, lawyers on our defense team.\nWe would rip out the cell phones. There is one line. We consent to the monitoring of that line. We consent to the waiver of search and seizure. These are the conditions that have been accepted and, again, not always, Judge. There are detention orders.\nI'm a Boston lawyer. I remember arguing before the Former Chief Judge Mark Wolf on behalf of a defendant who was arrested about two months after an induction ceremony for organized crime about 20 years ago.\nAnd Judge Wolf found that along with financial\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\nDOJ-OGR-00000558",
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- "content": "Case 1:19-cr-00490-RMB Document 36 Filed 07/24/19 Page 48 of 74 48",
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- "type": "printed",
- "content": "that your Honor has clear and convincing proof occurred, much less the predictive factor that if Mr. Epstein was released under the kind of combination of conditions, there would be any risk of his influencing adversely a witness, now that there is a federal prosecution. That would be self-destructive. It would constitute a crime with a nexus to what the statutes require.",
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- "content": "But the conditions also, your Honor, radically limit -- we've asked your Honor for home detention, and I will get to the monetary conditions and the risk of flight in a moment.",
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- "type": "printed",
- "content": "We've asked for home detention. We've asked for the visiting list to be approved by pretrial, meaning almost nobody except Mr. Weingarten and myself, Mr. Fernich, lawyers on our defense team.",
- "position": "main"
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- "type": "printed",
- "content": "We would rip out the cell phones. There is one line. We consent to the monitoring of that line. We consent to the waiver of search and seizure. These are the conditions that have been accepted and, again, not always, Judge. There are detention orders.",
- "position": "main"
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- {
- "type": "printed",
- "content": "I'm a Boston lawyer. I remember arguing before the Former Chief Judge Mark Wolf on behalf of a defendant who was arrested about two months after an induction ceremony for organized crime about 20 years ago.",
- "position": "main"
- },
- {
- "type": "printed",
- "content": "And Judge Wolf found that along with financial",
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- "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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- "content": "DOJ-OGR-00000558",
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- "entities": {
- "people": [
- "Mr. Epstein",
- "Mr. Weingarten",
- "Mr. Fernich",
- "Judge Wolf",
- "Mark Wolf"
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- "organizations": [
- "SOUTHERN DISTRICT REPORTERS, P.C."
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- "locations": [
- "Boston"
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- "dates": [
- "07/24/19",
- "20 years ago"
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- "1:19-cr-00490-RMB",
- "Document 36",
- "DOJ-OGR-00000558"
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