mirror-epstein-docs/results/IMAGES007/DOJ-OGR-00019984.json

{
  "document_metadata": {
    "page_number": "125",
    "document_number": "39-2",
    "date": "04/01/2021",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 21-58, Document 39-2, 04/01/2021, 3068530, Page125 of 200\n62\nher. Well, when the bank drops you, you have to transfer your\nfunds out. That's true. That's what happened. So there is\nnothing in there that's sinister, there is nothing in there\nthat shows an intent to evade, an intent to evade, and nothing\nthere that we think warrants detention.\nOne last point on the financial stuff, your Honor, if\nI might. In the reply brief, we get a new allegation that an\nSDAR, a foreign filing was made in 2018 and 2019, disclosing\nthat our client had a foreign bank account. Let's stop there.\nOur client makes a legally required filing with the Treasury\nDepartment, obeys the law, and discloses a foreign bank\naccount, and the government is claiming that's evidence of\nhiding. This is all upside-down, your Honor. These are not\nfactors to be considered in exercising your discretion under\n3142.\nLet me turn very quickly to the other two factors that\nare relevant for today's purposes because, as your Honor has\npointed out, the government is not proceeding on a\ndangerousness claim. That is the (g)(1) and (g)(2) factors,\nthe nature and circumstances of the case, and the weight of the\nevidence.\nHere, I think we -- if you bear with me a moment, your\nHonor, here, one thing to keep in mind is an observation\nJudge Raggi made in the Sabhnani case, at page 77, where she\nsaid, \"The more effectively a court can physically restrain the\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00019984",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 21-58, Document 39-2, 04/01/2021, 3068530, Page125 of 200",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "her. Well, when the bank drops you, you have to transfer your\nfunds out. That's true. That's what happened. So there is\nnothing in there that's sinister, there is nothing in there\nthat shows an intent to evade, an intent to evade, and nothing\nthere that we think warrants detention.\nOne last point on the financial stuff, your Honor, if\nI might. In the reply brief, we get a new allegation that an\nSDAR, a foreign filing was made in 2018 and 2019, disclosing\nthat our client had a foreign bank account. Let's stop there.\nOur client makes a legally required filing with the Treasury\nDepartment, obeys the law, and discloses a foreign bank\naccount, and the government is claiming that's evidence of\nhiding. This is all upside-down, your Honor. These are not\nfactors to be considered in exercising your discretion under\n3142.\nLet me turn very quickly to the other two factors that\nare relevant for today's purposes because, as your Honor has\npointed out, the government is not proceeding on a\ndangerousness claim. That is the (g)(1) and (g)(2) factors,\nthe nature and circumstances of the case, and the weight of the\nevidence.\nHere, I think we -- if you bear with me a moment, your\nHonor, here, one thing to keep in mind is an observation\nJudge Raggi made in the Sabhnani case, at page 77, where she\nsaid, \"The more effectively a court can physically restrain the",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00019984",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Judge Raggi"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C.",
      "Treasury Department"
    ],
    "locations": [],
    "dates": [
      "2018",
      "2019",
      "04/01/2021"
    ],
    "reference_numbers": [
      "Case 21-58",
      "Document 39-2",
      "3068530",
      "3142",
      "DOJ-OGR-00019984"
    ]
  },
  "additional_notes": "The document appears to be a court transcript or legal document. It is typed and contains no handwritten text or stamps. The content is a legal argument or statement made in a court case."
}