DOJ-OGR-00001947.jpg
604 KB
Extraction Summary
4
People
2
Organizations
1
Locations
1
Events
2
Relationships
3
Quotes
Document Information
Type:
Court transcript
File Size:
604 KB
Summary
This document is a page from a court transcript dated December 10, 2020, from case 1:20-cr-00330-AJN. An attorney, Mr. Cohen, concludes his argument for his client's bail, asserting the government has failed to prove the client is a flight risk. He asks the judge to grant bail or to keep the proceeding open for a week to allow for the submission of more information.
People (4)
| Name | Role | Context |
|---|---|---|
| MR. COHEN | Attorney |
Speaker arguing for his client to be granted bail.
|
| your Honor | Judge |
The presiding judge being addressed by Mr. Cohen.
|
| Judge Raggi | Judge |
Mentioned in reference to a legal precedent in the case of Sabhnani.
|
| Sabhnani | Party in a previous legal case |
Mentioned as part of a case citation ('in Sabhnani') used by Mr. Cohen in his argument.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| SOUTHERN DISTRICT REPORTERS, P.C. | Company |
Listed at the bottom of the transcript page, likely the court reporting service.
|
| U.S. Government | Government agency |
Referred to as 'the government', which Mr. Cohen argues has the burden of proving his client is a flight risk.
|
Timeline (1 events)
2020-12-10
An attorney, Mr. Cohen, makes a concluding argument to the court to grant bail for his client.
Southern District Court (implied)
Locations (1)
| Location | Context |
|---|---|
|
Implied as the location of the court proceedings from the name 'SOUTHERN DISTRICT REPORTERS, P.C.'
|
Relationships (2)
Mr. Cohen refers to 'our client' and argues on their behalf for bail.
Mr. Cohen, an attorney, formally addresses the judge ('your Honor') during a court proceeding.
Key Quotes (3)
"So in conclusion, we believe this is a compelling case for bail."Source
— MR. COHEN
(Concluding his argument to the judge.)
DOJ-OGR-00001947.jpg
Quote #1
"We believe that the government, which has the burden of persuasion that never shifts, has not made a showing as required, that our client is a risk of flight."Source
— MR. COHEN
(Arguing that the prosecution has failed to meet its legal burden to deny bail.)
DOJ-OGR-00001947.jpg
Quote #2
"So we would ask the court to grant bail today. And if the court needs more information from us, we would respectfully request that the court leave the proceeding open for a week so that we can try to satisfy the court because we want to."Source
— MR. COHEN
(Making a direct request to the judge for bail or, alternatively, for more time to present information.)
DOJ-OGR-00001947.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (1,529 characters)
Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 70 of 91 70
k7e2MaxC kjc
k7e2MaxC kjc
1 risk of flight or dangerousness, they are still entitled to the
2 same Sixth Amendment rights to access defense counsel to
3 prepare their case.
4 MR. COHEN: Of course, your Honor. My point was a
5 more narrow point. My point is that the facts in those cases
6 are different from our case in a meaningful way and the court
7 was doing a different evaluation. That was the point I was
8 making on this case.
9 So in conclusion, we believe this is a compelling case
10 for bail. We believe that the government, which has the burden
11 of persuasion that never shifts, has not made a showing as
12 required, that our client is a risk of flight. When you
13 consider the risk, as Judge Raggi put it, in Sabhnani, the
14 actual risk of flight, not fantasy and not speculation, when
15 you consider that the only factors they really point to are
16 ones that the cases have already addressed, such as
17 international travel and passports.
18 We also submit that the government has not carried its
19 burden of showing there is no condition or combination of
20 conditions that secure release.
21 So we would ask the court to grant bail today. And if
22 the court needs more information from us, we would respectfully
23 request that the court leave the proceeding open for a week so
24 that we can try to satisfy the court because we want to.
25 Thank you, your Honor, for your time.
2 same Sixth Amendment rights to access defense counsel to
3 prepare their case.
4 MR. COHEN: Of course, your Honor. My point was a
5 more narrow point. My point is that the facts in those cases
6 are different from our case in a meaningful way and the court
7 was doing a different evaluation. That was the point I was
8 making on this case.
9 So in conclusion, we believe this is a compelling case
10 for bail. We believe that the government, which has the burden
11 of persuasion that never shifts, has not made a showing as
12 required, that our client is a risk of flight. When you
13 consider the risk, as Judge Raggi put it, in Sabhnani, the
14 actual risk of flight, not fantasy and not speculation, when
15 you consider that the only factors they really point to are
16 ones that the cases have already addressed, such as
17 international travel and passports.
18 We also submit that the government has not carried its
19 burden of showing there is no condition or combination of
20 conditions that secure release.
21 So we would ask the court to grant bail today. And if
22 the court needs more information from us, we would respectfully
23 request that the court leave the proceeding open for a week so
24 that we can try to satisfy the court because we want to.
25 Thank you, your Honor, for your time.
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
(212) 805-0300
DOJ-OGR-00001947
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein document