DOJ-OGR-00001942.jpg
615 KB
Extraction Summary
3
People
5
Organizations
0
Locations
2
Events
3
Relationships
1
Quotes
Document Information
Type:
Legal document
File Size:
615 KB
Summary
This document is a partial transcript from a legal proceeding, dated December 10, 2020, where a lawyer is arguing before a judge ('your Honor') regarding a client who has been in custody. The arguments involve the application of legal factors (3142 factors), guidance from the Second Circuit and Supreme Court, and the historical context of the alleged conduct. The judge ('THE COURT') interrupts Mr. Cohen to ask for clarification on a point.
People (3)
| Name | Role | Context |
|---|---|---|
| your Honor | Judge |
Addressed by the speaker, presiding over the litigation.
|
| Mr. Cohen |
Addressed by THE COURT, likely a lawyer or party involved in the case.
|
|
| our client | Client |
The party being represented by the speaker, who has been kept in custody.
|
Organizations (5)
| Name | Type | Context |
|---|---|---|
| NPA | Legal/Governmental entity or act |
Mentioned in the context of litigation.
|
| government | Government agency |
Expected to take a position in the litigation.
|
| Second Circuit | Court |
Provides guidance for legal factors.
|
| Supreme Court | Court |
Provides guidance for legal factors.
|
| SOUTHERN DISTRICT REPORTERS, P.C. | Company |
Entity responsible for transcribing the court proceedings.
|
Timeline (2 events)
A lawyer is presenting arguments to a judge regarding a client's case, discussing past conduct (1994-1997), bail factors (3142 factors), and the client's custody. The judge interrupts to ask for clarification from Mr. Cohen.
Court (implied by 'THE COURT', 'Second Circuit', 'Supreme Court', 'Southern District')
Relationships (3)
The Court addresses Mr. Cohen directly, asking him to repeat a point, indicating he is speaking before the court.
The speaker refers to 'our client' who has been 'kept in custody' and for whom they are making arguments.
The speaker addresses the judge as 'your Honor' and presents arguments to them.
Key Quotes (1)
"Wait, Mr. Cohen. I missed that last point could you repeat it, please."Source
— THE COURT
(The judge interrupting Mr. Cohen to ask for clarification on a point he just made.)
DOJ-OGR-00001942.jpg
Quote #1
Full Extracted Text
Complete text extracted from the document (1,587 characters)
Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 65 of 91
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1 litigation before your Honor about what is in the NPA, and the
2 government, we expect, is going to take the position that
3 unlike '07 is covered and nothing else. We disagree with that,
4 which we will lay out for your Honor. What do they do? They
5 decide we will reach back and indict '94 to '97, totally
6 tactical, your Honor. So now we have a case where the conduct
7 is 25 years old, no tapes, no video, none of the sort of things
8 you would expect in that age of case, that we are going to have
9 to defend, and we are going to defend. And I think it goes to
10 the court's consideration of the weight in the context of the
11 only application that's before your Honor, which is how to
12 weigh the 3142 factors with the structure of the statute, with
13 the guidance of the Second Circuit and the Supreme Court, which
14 is in favor of bail, in favor of bail on appropriate
15 conditions.
16 So we submit that the package we laid out for the
17 court is sufficient that we are certainly willing if the court
18 deems it necessary to leave the proceeding open and we think we
19 could be back before the court within a week if that is what
20 the court wants or there is more detail which has been hammered
21 by the fact that our client has been, by design, by design,
22 kept in custody. And let me just give your Honor a little
23 flavor.
24 THE COURT: Wait, Mr. Cohen. I missed that last point
25 could you repeat it, please.
2 government, we expect, is going to take the position that
3 unlike '07 is covered and nothing else. We disagree with that,
4 which we will lay out for your Honor. What do they do? They
5 decide we will reach back and indict '94 to '97, totally
6 tactical, your Honor. So now we have a case where the conduct
7 is 25 years old, no tapes, no video, none of the sort of things
8 you would expect in that age of case, that we are going to have
9 to defend, and we are going to defend. And I think it goes to
10 the court's consideration of the weight in the context of the
11 only application that's before your Honor, which is how to
12 weigh the 3142 factors with the structure of the statute, with
13 the guidance of the Second Circuit and the Supreme Court, which
14 is in favor of bail, in favor of bail on appropriate
15 conditions.
16 So we submit that the package we laid out for the
17 court is sufficient that we are certainly willing if the court
18 deems it necessary to leave the proceeding open and we think we
19 could be back before the court within a week if that is what
20 the court wants or there is more detail which has been hammered
21 by the fact that our client has been, by design, by design,
22 kept in custody. And let me just give your Honor a little
23 flavor.
24 THE COURT: Wait, Mr. Cohen. I missed that last point
25 could you repeat it, please.
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
(212) 805-0300
DOJ-OGR-00001942
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