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758 KB

Extraction Summary

4
People
4
Organizations
1
Locations
2
Events
1
Relationships
4
Quotes

Document Information

Type: Legal document
File Size: 758 KB
Summary

This legal document, filed on December 18, 2020, summarizes the defense's arguments from a bail hearing held on July 14, 2020. The defense urged the court to release the defendant, who was arrested by the FBI on July 2, 2020, citing family ties in the U.S. and offering to hire private security. The defense also addressed the government's concerns about the defendant's finances and willingness to provide more information to secure a bail bond.

People (4)

Name Role Context
defendant defendant
The subject of the legal proceedings, arrested by the FBI. The defense is arguing for their release on bail.
Epstein
Mentioned in the context that the defendant remained in the country and in touch with the Government following Epstei...
counsel legal counsel
Acted as an intermediary for the defendant to stay in touch with the Government.
six proposed co-signers co-signers
Mentioned as part of the defense's proposal for a bail bond.

Organizations (4)

Name Type Context
Federal Bureau of Investigation (“FBI”) government agency
Arrested the defendant on July 2, 2020.
Court judicial body
Held a bail hearing and was urged by the defense to release the defendant on bail.
Government government agency
Represents the prosecution, had concerns about the defendant's finances and transparency.
private security company company
The defense offered to hire one to monitor the defendant as a condition of bail.

Timeline (2 events)

2020-07-02
The Federal Bureau of Investigation (“FBI”) arrested the defendant.
Federal Bureau of Investigation defendant
2020-07-14
The Court held a lengthy bail hearing where the defense argued for the defendant's release.
Court defense Government

Locations (1)

Location Context
The defense emphasized the defendant's family ties and residence in the United States.

Relationships (1)

defendant adversarial (legal) Government
The Government is prosecuting the defendant, who was arrested by the FBI. The defense is arguing against the Government's position in court.

Key Quotes (4)

"And if the court determines that the conditions that we have proffered are insufficient or need further verification, as long as we can have some assurance of safety and confidentiality, we would recommend that the court keep the proceeding open, and we should be able to get whatever the court needs to satisfy it."
Source
— defense (A quote from the bail hearing transcript (Tr. 52) where the defense asks to keep proceedings open to provide more information for the bond.)
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Quote #1
"Even if the court were to assume for purposes of today’s proceeding that she has the means that the government claims she does, it does not affect the analysis. That is to be addressed in conditions, to be addressed if the court requires it, through verifications and further proceedings before the court."
Source
— defense (A quote from the bail hearing transcript (Tr. 59) arguing that the defendant's financial means should be addressed as part of bail conditions, not as a reason for detention.)
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Quote #2
"If the court desires to leave the proceeding open for a week and allow us to come back, if the court has concerns about the number of suretors, for example, verification information, information about financial issues, we think that, now that we have some ability to breathe a little bit, that we should be able to pull this together for the court’s consideration."
Source
— defense (A quote from the bail hearing transcript (Tr. 66) where the defense offers to take more time to address the court's concerns about the bail package.)
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Quote #3
"And if the court needs more information"
Source
— defense (An incomplete quote from the bail hearing transcript (Tr. 70).)
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Quote #4

Full Extracted Text

Complete text extracted from the document (2,303 characters)

Case 1:20-cr-00330-AJN Document 100 Filed 12/18/20 Page 6 of 36
On July 2, 2020, the Federal Bureau of Investigation (“FBI”) arrested the defendant.
Following extensive briefing, on July 14, 2020, the Court held a lengthy bail hearing. In its written
and oral submissions, the defense urged the Court to release the defendant on bail.
Among other things, the defense emphasized the defendant’s family ties and residence in
the United States (Dkt. 18 at 2, 3, 12), offered to hire a private security company to monitor the
defendant (Id. at 20), noted that the defendant remained in the country and was in touch with the
Government through counsel following Epstein’s arrest (Dkt. 18 at 12-13; Tr. 49, 52-55), argued
that the defendant went into hiding to avoid a media frenzy (Dkt. 18 at 14-16; Tr. 55-56), and
argued that detention would hamper the ability to prepare a defense (Tr. 42, 67-69). Responding
to the Government’s concerns about the lack of transparency about the defendant’s finances and
six proposed co-signers, the defense specifically asked the Court to keep the proceedings open if
the Court believed additional information or a more fulsome bond would be useful to the bail
determination. (Tr. 52 (“And if the court determines that the conditions that we have proffered are
insufficient or need further verification, as long as we can have some assurance of safety and
confidentiality, we would recommend that the court keep the proceeding open, and we should be
able to get whatever the court needs to satisfy it.”); Tr. 59 (“Even if the court were to assume for
purposes of today’s proceeding that she has the means that the government claims she does, it does
not affect the analysis. That is to be addressed in conditions, to be addressed if the court requires
it, through verifications and further proceedings before the court.”); Tr. 66 (“If the court desires to
leave the proceeding open for a week and allow us to come back, if the court has concerns about
the number of suretors, for example, verification information, information about financial issues,
we think that, now that we have some ability to breathe a little bit, that we should be able to pull
this together for the court’s consideration.”); Tr. 70 (“And if the court needs more information
3
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