DOJ-OGR-00001072.json 4.5 KB

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  1. {
  2. "document_metadata": {
  3. "page_number": "131",
  4. "document_number": "20-2",
  5. "date": "04/01/2021",
  6. "document_type": "court transcript",
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  10. "full_text": "Case 21-770, Document 20-2, 04/01/2021, 3068530, Page131 of 200\n\n1 investigations. There is the investigation of our client and\n2 there is the investigation of Mr. Epstein. And they are, in\n3 the government's words, in our words together, voluminous\n4 materials. We haven't seen any of it yet, but voluminous,\n5 including voluminous electronic materials. The notion that we\n6 would be able to in any meaningful way review these with our\n7 client to prepare the case for motion and for trial under the\n8 current pandemic situation is just not realistic. It is not\n9 meaningful. It is not fair. And I should say, as your Honor\n10 noted, in the Stephens case, we are not faulting the Bureau of\n11 Prisons. We are not faulting the Marshal Service. We\n12 understand they are doing the best they can under the\n13 circumstances. But this is just not realistic. We have\n14 conduct that's alleged to be 25 years old. You have extensive\n15 discovery that's going to take the government, if they hit the\n16 deadlines your Honor set -- and we all know that sometimes it\n17 doesn't happen -- four and a half months to provide, and the\n18 government wants our client to remain in custody that whole\n19 time, without being able to meet with us in person, with\n20 limited access in some form of administrative seg., apparently\n21 because they are afraid of what happened with Mr. Epstein, I\n22 don't know, and it is just not a realistic way to prepare a\n23 case, particularly, your Honor, when, as we submit, the\n24 conditions and combination of conditions to secure her release\n25 can be satisfied here under your Honor's guidance.\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00001072",
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  14. "content": "Case 21-770, Document 20-2, 04/01/2021, 3068530, Page131 of 200",
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  19. "content": "1 investigations. There is the investigation of our client and\n2 there is the investigation of Mr. Epstein. And they are, in\n3 the government's words, in our words together, voluminous\n4 materials. We haven't seen any of it yet, but voluminous,\n5 including voluminous electronic materials. The notion that we\n6 would be able to in any meaningful way review these with our\n7 client to prepare the case for motion and for trial under the\n8 current pandemic situation is just not realistic. It is not\n9 meaningful. It is not fair. And I should say, as your Honor\n10 noted, in the Stephens case, we are not faulting the Bureau of\n11 Prisons. We are not faulting the Marshal Service. We\n12 understand they are doing the best they can under the\n13 circumstances. But this is just not realistic. We have\n14 conduct that's alleged to be 25 years old. You have extensive\n15 discovery that's going to take the government, if they hit the\n16 deadlines your Honor set -- and we all know that sometimes it\n17 doesn't happen -- four and a half months to provide, and the\n18 government wants our client to remain in custody that whole\n19 time, without being able to meet with us in person, with\n20 limited access in some form of administrative seg., apparently\n21 because they are afraid of what happened with Mr. Epstein, I\n22 don't know, and it is just not a realistic way to prepare a\n23 case, particularly, your Honor, when, as we submit, the\n24 conditions and combination of conditions to secure her release\n25 can be satisfied here under your Honor's guidance.",
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  24. "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
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  28. "type": "printed",
  29. "content": "DOJ-OGR-00001072",
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  32. ],
  33. "entities": {
  34. "people": [
  35. "Mr. Epstein"
  36. ],
  37. "organizations": [
  38. "Bureau of Prisons",
  39. "Marshal Service",
  40. "SOUTHERN DISTRICT REPORTERS, P.C."
  41. ],
  42. "locations": [],
  43. "dates": [
  44. "04/01/2021"
  45. ],
  46. "reference_numbers": [
  47. "Case 21-770",
  48. "Document 20-2",
  49. "3068530",
  50. "DOJ-OGR-00001072"
  51. ]
  52. },
  53. "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
  54. }