mirror-epstein-docs/results/IMAGES007/DOJ-OGR-00019992.json

{
  "document_metadata": {
    "page_number": "133",
    "document_number": "39-2",
    "date": "04/01/2021",
    "document_type": "court transcript",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 21-58, Document 39-2, 04/01/2021, 3068530, Page133 of 200\nk7e2MaxC kjc\nrisk of flight or dangerousness, they are still entitled to the\nsame Sixth Amendment rights to access defense counsel to\nprepare their case.\nMR. COHEN: Of course, your Honor. My point was a\nmore narrow point. My point is that the facts in those cases\nare different from our case in a meaningful way and the court\nwas doing a different evaluation. That was the point I was\nmaking on this case.\nSo in conclusion, we believe this is a compelling case\nfor bail. We believe that the government, which has the burden\nof persuasion that never shifts, has not made a showing as\nrequired, that our client is a risk of flight. When you\nconsider the risk, as Judge Raggi put it, in Sabhnani, the\nactual risk of flight, not fantasy and not speculation, when\nyou consider that the only factors they really point to are\nones that the cases have already addressed, such as\ninternational travel and passports.\nWe also submit that the government has not carried its\nburden of showing there is no condition or combination of\nconditions that secure release.\nSo we would ask the court to grant bail today. And if\nthe court needs more information from us, we would respectfully\nrequest that the court leave the proceeding open for a week so\nthat we can try to satisfy the court because we want to.\nThank you, your Honor, for your time.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00019992",
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      "content": "Case 21-58, Document 39-2, 04/01/2021, 3068530, Page133 of 200",
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    {
      "type": "printed",
      "content": "k7e2MaxC kjc",
      "position": "header"
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      "type": "printed",
      "content": "1 risk of flight or dangerousness, they are still entitled to the\n2 same Sixth Amendment rights to access defense counsel to\n3 prepare their case.\n4 MR. COHEN: Of course, your Honor. My point was a\n5 more narrow point. My point is that the facts in those cases\n6 are different from our case in a meaningful way and the court\n7 was doing a different evaluation. That was the point I was\n8 making on this case.\n9 So in conclusion, we believe this is a compelling case\n10 for bail. We believe that the government, which has the burden\n11 of persuasion that never shifts, has not made a showing as\n12 required, that our client is a risk of flight. When you\n13 consider the risk, as Judge Raggi put it, in Sabhnani, the\n14 actual risk of flight, not fantasy and not speculation, when\n15 you consider that the only factors they really point to are\n16 ones that the cases have already addressed, such as\n17 international travel and passports.\n18 We also submit that the government has not carried its\n19 burden of showing there is no condition or combination of\n20 conditions that secure release.\n21 So we would ask the court to grant bail today. And if\n22 the court needs more information from us, we would respectfully\n23 request that the court leave the proceeding open for a week so\n24 that we can try to satisfy the court because we want to.\n25 Thank you, your Honor, for your time.",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00019992",
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  ],
  "entities": {
    "people": [
      "MR. COHEN",
      "Judge Raggi"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "04/01/2021"
    ],
    "reference_numbers": [
      "Case 21-58",
      "Document 39-2",
      "3068530",
      "DOJ-OGR-00019992"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
}