mirror-epstein-docs/results/IMAGES001/DOJ-OGR-00001949.json

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    "page_number": "72",
    "document_number": "93",
    "date": "12/10/20",
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  "full_text": "Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 72 of 91 72 k7e2MaxC kjc 1 Turning to several specific points, your Honor, that I would like to respond to. I want to address the notion that the defendant would have surrendered if the government had asked her to. As defense counsel conceded, no offer along those lines was ever made. And of course the government doesn't have to accept the defense counsel's representation that their client would surrender. 8 In fact, the fact that the government took these measures to arrest the defendant reflects how seriously the government takes the risk of the defendant of flight. Why on earth would the government notify the defendant through her counsel that she was about to be indicted and arrested if the government had serious concerns that she was a risk of flight? That is exactly what occurred here. 15 In addition, it is interesting that defense counsel notes that it should have been obvious to the government that the defendant would have surrendered when, at the same time, in civil litigation in this district, defense counsel declined to accept service on behalf of plaintiffs who were seeking to sue the defendant in connection with some of these allegations, and they were required to seek leave of the court to serve the defendant through their counsel. 23 Your Honor, turning to the question of the defendant's finances there is still at this point no substantive response regarding defendant's finances or about the lack of candor to SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00001949",
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      "content": "k7e2MaxC kjc 1 Turning to several specific points, your Honor, that I would like to respond to. I want to address the notion that the defendant would have surrendered if the government had asked her to. As defense counsel conceded, no offer along those lines was ever made. And of course the government doesn't have to accept the defense counsel's representation that their client would surrender.",
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      "content": "8 In fact, the fact that the government took these measures to arrest the defendant reflects how seriously the government takes the risk of the defendant of flight. Why on earth would the government notify the defendant through her counsel that she was about to be indicted and arrested if the government had serious concerns that she was a risk of flight? That is exactly what occurred here.",
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      "content": "15 In addition, it is interesting that defense counsel notes that it should have been obvious to the government that the defendant would have surrendered when, at the same time, in civil litigation in this district, defense counsel declined to accept service on behalf of plaintiffs who were seeking to sue the defendant in connection with some of these allegations, and they were required to seek leave of the court to serve the defendant through their counsel.",
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      "content": "23 Your Honor, turning to the question of the defendant's finances there is still at this point no substantive response regarding defendant's finances or about the lack of candor to",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00001949",
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      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "dates": [
      "12/10/20"
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      "1:20-cr-00330-AJN",
      "93",
      "DOJ-OGR-00001949"
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