mirror-epstein-docs/results/IMAGES001/DOJ-OGR-00002191.json

{
  "document_metadata": {
    "page_number": "30",
    "document_number": "100",
    "date": "12/18/20",
    "document_type": "court document",
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  "full_text": "Case 1:20-cr-00330-AJN Document 100 Filed 12/18/20 Page 30 of 36\n\nIn urging a different conclusion, the defense again cites the same cases discussed in its initial briefing and at the July 14, 2020 hearing to argue that the proposed bail conditions are consistent with or exceed those approved by courts in this Circuit for “high-profile defendants with financial means and foreign citizenship.” (Mot. at 34; see Dkt. 18 at 16, 21; Tr. 48-51). The Court should reject the defense’s efforts to raise the same precedent that the Court already took into consideration when denying bail. “A motion for reconsideration may not be used . . . as a vehicle for relitigating issues already decided by the Court.” Jackson v. Goord, 664 F. Supp. 2d 307, 313 (S.D.N.Y. 2009) (internal quotation marks omitted). The Court already considered and rejected the defendant’s efforts to liken her case to other “serious and high-profile prosecutions where the courts, over the government’s objection, granted bail to defendants with significant financial resources.” (Tr. 88). Noting “crucial factual differences,” the Court described those cases, including United States v. Esposito, 309 F. Supp. 3d 24 (S.D.N.Y. 2018), United States v. Dreier, 596 F. Supp. 2d 831 (S.D.N.Y. 2009), and United States v. Madoff, 586 F. Supp. 2d 240 (S.D.N.Y. 2009), as “not on point and not persuasive,” and distinguished the defendant for a number of reasons, including the defendant’s “significant foreign connections.” (Tr. 88; see id. (distinguishing Esposito where the risk of flight appeared to “have been based on the resources available to defendant, not foreign connections or experience and a record of hiding from being found”); id. (distinguishing Madoff where “the defendant had already been released on a bail package agreed to by the parties for a considerable period of time before the government sought detention”)).\n\nThe Court already engaged in a fact-specific analysis in ordering the defendant detained. Among the reasons provided, the Court found that the “the defendant not only has significant financial resources, but has demonstrated sophistication in hiding those resources and herself.”\n\n27\nDOJ-OGR-00002191",
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      "content": "Case 1:20-cr-00330-AJN Document 100 Filed 12/18/20 Page 30 of 36",
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      "content": "In urging a different conclusion, the defense again cites the same cases discussed in its initial briefing and at the July 14, 2020 hearing to argue that the proposed bail conditions are consistent with or exceed those approved by courts in this Circuit for “high-profile defendants with financial means and foreign citizenship.” (Mot. at 34; see Dkt. 18 at 16, 21; Tr. 48-51). The Court should reject the defense’s efforts to raise the same precedent that the Court already took into consideration when denying bail. “A motion for reconsideration may not be used . . . as a vehicle for relitigating issues already decided by the Court.” Jackson v. Goord, 664 F. Supp. 2d 307, 313 (S.D.N.Y. 2009) (internal quotation marks omitted). The Court already considered and rejected the defendant’s efforts to liken her case to other “serious and high-profile prosecutions where the courts, over the government’s objection, granted bail to defendants with significant financial resources.” (Tr. 88). Noting “crucial factual differences,” the Court described those cases, including United States v. Esposito, 309 F. Supp. 3d 24 (S.D.N.Y. 2018), United States v. Dreier, 596 F. Supp. 2d 831 (S.D.N.Y. 2009), and United States v. Madoff, 586 F. Supp. 2d 240 (S.D.N.Y. 2009), as “not on point and not persuasive,” and distinguished the defendant for a number of reasons, including the defendant’s “significant foreign connections.” (Tr. 88; see id. (distinguishing Esposito where the risk of flight appeared to “have been based on the resources available to defendant, not foreign connections or experience and a record of hiding from being found”); id. (distinguishing Madoff where “the defendant had already been released on a bail package agreed to by the parties for a considerable period of time before the government sought detention”)).",
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    {
      "type": "printed",
      "content": "The Court already engaged in a fact-specific analysis in ordering the defendant detained. Among the reasons provided, the Court found that the “the defendant not only has significant financial resources, but has demonstrated sophistication in hiding those resources and herself.”",
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      "content": "DOJ-OGR-00002191",
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  "entities": {
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    "organizations": [
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    "locations": [
      "S.D.N.Y."
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    "dates": [
      "July 14, 2020",
      "12/18/20"
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    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 100",
      "Dkt. 18",
      "Tr. 48-51",
      "Tr. 88",
      "664 F. Supp. 2d 307",
      "309 F. Supp. 3d 24",
      "596 F. Supp. 2d 831",
      "586 F. Supp. 2d 240",
      "DOJ-OGR-00002191"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is printed and there are no visible stamps or handwritten notes. The document is well-formatted and legible."
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