mirror-epstein-docs/results/IMAGES007/DOJ-OGR-00019989.json

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    "page_number": "130",
    "document_number": "39-2",
    "date": "04/01/2021",
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  "full_text": "Case 21-58, Document 39-2, 04/01/2021, 3068530, Page130 of 200\n67\noriginally without prejudice obviously for precisely the\nproceeding we are having, but it sounded like you were\nsuggesting that her current detention was in some way by design\nto prevent you from providing a full picture of her financial\nsituation. Is that the implication you are making?\nMR. COHEN: No, I am not saying that, your Honor. I\nam not going that far. What I am saying is, when you have a\nclient who will voluntary surrender, who is staying in the\ncountry despite an investigation, and the government instead\nchooses to arrest her and detain her, that limits in the early\ninstances your access to the client. It is complicated by the\nCOVID crisis and the other factors your Honor has pointed out\nin Stephens and in Williams-Bethea, and so it is very hard for\nus to pull together this financial information, and we have\ndone it as quickly as we could before the court. But the\nnotion that my client should have been able to answer off the\ntop of her head the questions from Pretrial Services about a\nreal estate transaction, for example, just doesn't make any\nsense. That's the point we are making.\nTHE COURT: Okay.\nMR. COHEN: One last point in that regard, your Honor,\nin the schedule we set today -- thank you, your Honor, for\napproving that -- the government is saying that it needs at\nleast until November to complete all discovery, including\nelectronic discovery. They have told us that there are two\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00019989",
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      "content": "Case 21-58, Document 39-2, 04/01/2021, 3068530, Page130 of 200",
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      "content": "originally without prejudice obviously for precisely the\nproceeding we are having, but it sounded like you were\nsuggesting that her current detention was in some way by design\nto prevent you from providing a full picture of her financial\nsituation. Is that the implication you are making?\nMR. COHEN: No, I am not saying that, your Honor. I\nam not going that far. What I am saying is, when you have a\nclient who will voluntary surrender, who is staying in the\ncountry despite an investigation, and the government instead\nchooses to arrest her and detain her, that limits in the early\ninstances your access to the client. It is complicated by the\nCOVID crisis and the other factors your Honor has pointed out\nin Stephens and in Williams-Bethea, and so it is very hard for\nus to pull together this financial information, and we have\ndone it as quickly as we could before the court. But the\nnotion that my client should have been able to answer off the\ntop of her head the questions from Pretrial Services about a\nreal estate transaction, for example, just doesn't make any\nsense. That's the point we are making.\nTHE COURT: Okay.\nMR. COHEN: One last point in that regard, your Honor,\nin the schedule we set today -- thank you, your Honor, for\napproving that -- the government is saying that it needs at\nleast until November to complete all discovery, including\nelectronic discovery. They have told us that there are two",
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      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
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      "type": "printed",
      "content": "DOJ-OGR-00019989",
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  "entities": {
    "people": [
      "MR. COHEN"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C.",
      "Pretrial Services"
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    "locations": [],
    "dates": [
      "04/01/2021",
      "November"
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    "reference_numbers": [
      "Case 21-58",
      "Document 39-2",
      "3068530",
      "DOJ-OGR-00019989"
    ]
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}