mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00009493.json

{
  "document_metadata": {
    "page_number": "74",
    "document_number": "1:20-cr-00338",
    "date": "02/24/22",
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  "full_text": "Case 1:20-cr-00338-PAE Document 1616 Filed 02/24/22 Page 74 of 117 A-5917\n\nCAC3PARC 15\n1 I'm sitting here with a tolling agreement from the\n2 Southern District in a case of mine which says as of\n3 January 14. Which is faxed on January 16. But everybody\n4 wanted it to be effective two days before because that was the\n5 agreement, as happens in the Southern District. It happens\n6 everywhere. And it doesn't mean backdating. In this case it\n7 means this is the price.\n8 But all that is a long way of saying there is no proof\n9 that he knew this rule. There is no proof it was discussed\n10 with him. There is no proof he thought he knew these\n11 transactions were wrong. And at the end of the day, when one's\n12 argument is he must've known, that's a weak reed, particularly\n13 when this prejudice notion is harmless error like. After all,\n14 you have Justice Marshall's dissent in Strickland that says it\n15 should have been harmless error, it should have been under the\n16 government's burden. When you do harmless error analysis, you\n17 say two things: What is the nature of the error, and what's\n18 the proof. The nature of the error here is that a government\n19 partisan out to get him in particular was on the jury. That's\n20 a pretty serious error. The proof, far from overwhelming.\n21 As I say, I think if I can get you to the prejudice\n22 prong, we ought to see you in April and not in January and I\n23 hope that's the case.\n24 THE COURT: Thank you, Mr. Shechtman.\n25 Ms. Davis, does the government want to be heard?\nMs. Davis SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\n\nDOJ-OGR-00009493",
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      "type": "printed",
      "content": "Case 1:20-cr-00338-PAE Document 1616 Filed 02/24/22 Page 74 of 117 A-5917",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "CAC3PARC 15",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "1 I'm sitting here with a tolling agreement from the\n2 Southern District in a case of mine which says as of\n3 January 14. Which is faxed on January 16. But everybody\n4 wanted it to be effective two days before because that was the\n5 agreement, as happens in the Southern District. It happens\n6 everywhere. And it doesn't mean backdating. In this case it\n7 means this is the price.\n8 But all that is a long way of saying there is no proof\n9 that he knew this rule. There is no proof it was discussed\n10 with him. There is no proof he thought he knew these\n11 transactions were wrong. And at the end of the day, when one's\n12 argument is he must've known, that's a weak reed, particularly\n13 when this prejudice notion is harmless error like. After all,\n14 you have Justice Marshall's dissent in Strickland that says it\n15 should have been harmless error, it should have been under the\n16 government's burden. When you do harmless error analysis, you\n17 say two things: What is the nature of the error, and what's\n18 the proof. The nature of the error here is that a government\n19 partisan out to get him in particular was on the jury. That's\n20 a pretty serious error. The proof, far from overwhelming.\n21 As I say, I think if I can get you to the prejudice\n22 prong, we ought to see you in April and not in January and I\n23 hope that's the case.\n24 THE COURT: Thank you, Mr. Shechtman.\n25 Ms. Davis, does the government want to be heard?",
      "position": "middle"
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    {
      "type": "printed",
      "content": "Ms. Davis SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00009493",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "Mr. Shechtman",
      "Ms. Davis",
      "Justice Marshall"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C.",
      "THE COURT"
    ],
    "locations": [
      "Southern District"
    ],
    "dates": [
      "January 14",
      "January 16",
      "April",
      "January",
      "02/24/22"
    ],
    "reference_numbers": [
      "1:20-cr-00338",
      "A-5917",
      "1616",
      "DOJ-OGR-00009493"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a clear and legible text. There are no visible redactions or damage."
}