mirror-epstein-docs/results/IMAGES007/DOJ-OGR-00019980.json

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  "document_metadata": {
    "page_number": "121",
    "document_number": "39-2",
    "date": "04/01/2021",
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  "full_text": "Case 21-58, Document 39-2, 04/01/2021, 3068530, Page121 of 200\n\n1 regular contact with the government, is removed in a property in the United States. That's the opposite of hiding. So we think that those kinds of facts, I'm sure, your Honor, if your Honor decides to keep the proceedings open and give us a chance to come on some issues, I'm sure we will have some more facts tomorrow and the next day, all with the disclaimer, we just learned this, your Honor. They have been investigating this case for ten years, your Honor, okay?\n\nSo let me turn now to another factor that the government made argument about briefly, two more factors under 31(g)(3), the history and characteristics of the defendant. We heard several times that there was a -- that detention should be warranted because there is a perjury charge. Very quickly, your Honor, we submit this does not tip the balance in the 3142 analysis that the court has to perform.\n\nFirst and foremost, the defendant is, of course, presumed innocent; and, secondly, the allegation and nature of the perjury, if the court has been through the indictment, is someone who denies guilt, who says they are innocent, is asked in a deposition did you do that and says no, the government charges them with perjury. That is not -- other than the fact that it's an indicted charge, they are still entitled to the weight the court would give a not indicted charge. That's all the weight it should be given.\n\nLet me turn to another factor that the government\n\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300\n\nDOJ-OGR-00019980",
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      "content": "1 regular contact with the government, is removed in a property in the United States. That's the opposite of hiding. So we think that those kinds of facts, I'm sure, your Honor, if your Honor decides to keep the proceedings open and give us a chance to come on some issues, I'm sure we will have some more facts tomorrow and the next day, all with the disclaimer, we just learned this, your Honor. They have been investigating this case for ten years, your Honor, okay?\n\nSo let me turn now to another factor that the government made argument about briefly, two more factors under 31(g)(3), the history and characteristics of the defendant. We heard several times that there was a -- that detention should be warranted because there is a perjury charge. Very quickly, your Honor, we submit this does not tip the balance in the 3142 analysis that the court has to perform.\n\nFirst and foremost, the defendant is, of course, presumed innocent; and, secondly, the allegation and nature of the perjury, if the court has been through the indictment, is someone who denies guilt, who says they are innocent, is asked in a deposition did you do that and says no, the government charges them with perjury. That is not -- other than the fact that it's an indicted charge, they are still entitled to the weight the court would give a not indicted charge. That's all the weight it should be given.\n\nLet me turn to another factor that the government",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "content": "DOJ-OGR-00019980",
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    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C.",
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    "locations": [
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    "dates": [
      "04/01/2021"
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      "Case 21-58",
      "Document 39-2",
      "3068530",
      "DOJ-OGR-00019980"
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