mirror-epstein-docs/results/IMAGES001/DOJ-OGR-00001079.json

{
  "document_metadata": {
    "page_number": "138",
    "document_number": "20-2",
    "date": "04/01/2021",
    "document_type": "court transcript",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 21-770, Document 20-2, 04/01/2021, 3068530, Page138 of 200\nk7e2MaxC kjc\n1 it is clear that defendant has not met her burden to rebut the\n2 presumption of detention in this case. The government urges\n3 the court to detain this defendant, consistent with the\n4 recommendation of Pretrial Services and the request of the\n5 victims. It is important, your Honor, that there be a trial in\n6 this case, and the government has serious concerns that the\n7 defendant will flee if afforded the opportunity.\n8 Thank you, your Honor.\n9 THE COURT: Briefly, Ms. Moe, just a couple of legal\n10 questions.\n11 Mr. Cohen argued that you failed to address directly\n12 the standards, the burdens under the statutory provision, and\n13 that you have avoided the fact of the government continuing to\n14 carry the burden by a preponderance of the evidence with\n15 respect to risk of flight and whether there are measures that\n16 could assure appearance. Do you dispute anything legally\n17 suggested by Mr. Cohen in terms of the standard that applies?\n18 MS. MOE: Your Honor, the government submits that the\n19 standard is clear. It is the defendant's burden of production\n20 to rebut the presumption that there are no set of conditions\n21 that could reasonably assure her continued appearance in this\n22 case. The government has the ultimate burden of persuasion,\n23 but it is the defendant's burden of production. She has failed\n24 to meet that burden for the reasons we set forth in our\n25 briefing and arguments today.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
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      "content": "Case 21-770, Document 20-2, 04/01/2021, 3068530, Page138 of 200",
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    {
      "type": "printed",
      "content": "k7e2MaxC kjc",
      "position": "header"
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    {
      "type": "printed",
      "content": "1 it is clear that defendant has not met her burden to rebut the\n2 presumption of detention in this case. The government urges\n3 the court to detain this defendant, consistent with the\n4 recommendation of Pretrial Services and the request of the\n5 victims. It is important, your Honor, that there be a trial in\n6 this case, and the government has serious concerns that the\n7 defendant will flee if afforded the opportunity.\n8 Thank you, your Honor.\n9 THE COURT: Briefly, Ms. Moe, just a couple of legal\n10 questions.\n11 Mr. Cohen argued that you failed to address directly\n12 the standards, the burdens under the statutory provision, and\n13 that you have avoided the fact of the government continuing to\n14 carry the burden by a preponderance of the evidence with\n15 respect to risk of flight and whether there are measures that\n16 could assure appearance. Do you dispute anything legally\n17 suggested by Mr. Cohen in terms of the standard that applies?\n18 MS. MOE: Your Honor, the government submits that the\n19 standard is clear. It is the defendant's burden of production\n20 to rebut the presumption that there are no set of conditions\n21 that could reasonably assure her continued appearance in this\n22 case. The government has the ultimate burden of persuasion,\n23 but it is the defendant's burden of production. She has failed\n24 to meet that burden for the reasons we set forth in our\n25 briefing and arguments today.",
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    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "Ms. Moe",
      "Mr. Cohen",
      "defendant"
    ],
    "organizations": [
      "Pretrial Services",
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [],
    "dates": [
      "04/01/2021"
    ],
    "reference_numbers": [
      "Case 21-770",
      "Document 20-2",
      "3068530"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with a clear and legible format. There are no visible redactions or damage."
}