DOJ-OGR-00001082.jpg
634 KB
Extraction Summary
4
People
2
Organizations
1
Locations
4
Events
2
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
634 KB
Summary
This document is a page from a court transcript dated April 1, 2021, where an attorney is arguing against their client being a flight risk. The attorney distinguishes their client's case from the U.S. v. Zarger case cited by the government, noting their client was in New Hampshire at the time of arrest and not making plans to leave the country. The attorney also references a prior felony conviction of a Mr. Epstein and a previous proceeding before Judge Berman.
People (4)
| Name | Role | Context |
|---|---|---|
| Mr. Epstein | Defendant/Subject of discussion |
Mentioned as having a prior felony conviction for similar conduct.
|
| Judge Berman | Judge |
Presided over a previous proceeding where a package with two suretors was offered.
|
| Judge Gleeson | Judge |
Mentioned in relation to the U.S. v. Zarger case in 2000.
|
| Zarger | Party in a legal case |
Named in the "U.S. v. Zarger case" cited by the government.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| government | government agency |
Referred to as the opposing party in the legal case, which cited the U.S. v. Zarger case.
|
| SOUTHERN DISTRICT REPORTERS, P.C. | company |
Listed at the bottom of the page, likely the court reporting service that transcribed the proceeding.
|
Timeline (4 events)
2000
The U.S. v. Zarger case presided over by Judge Gleeson.
Courtroom (unspecified)
2021-04-01
A court hearing where a defense attorney is making arguments, likely regarding bail.
Courtroom (unspecified)
Unnamed speaker (attorney)
Presiding Judge
The arrest of the speaker's client.
New Hampshire
Unnamed client
A prior proceeding before Judge Berman concerning Mr. Epstein, where a package with two suretors was offered.
Courtroom (unspecified)
Locations (1)
| Location | Context |
|---|---|
|
The location where the speaker's client was at the time of arrest.
|
Relationships (2)
Unnamed speaker
→
professional
→
defendant, our client
The speaker refers to the defendant as "our client," indicating an attorney-client relationship.
The document is a transcript of a court proceeding where the government is the prosecuting party against the defendant.
Key Quotes (3)
"And as to the risk of flight factors, Mr. Epstein had a prior felony conviction for conduct similar to that alleged in the indictment."Source
— Unnamed speaker (attorney)
(Acknowledging a risk factor related to a client or related individual.)
DOJ-OGR-00001082.jpg
Quote #1
"That is the situation, frankly, in the U.S. v. Zarger case, the case by Judge Gleeson in 2000, that the government cites in its brief, but of course doesn't discuss the facts. There is nothing to that effect here."Source
— Unnamed speaker (attorney)
(Distinguishing the client's situation from a case cited by the prosecution to argue against flight risk.)
DOJ-OGR-00001082.jpg
Quote #2
"To the contrary, the defendant, our client, is sitting in New Hampshire at the time of the arrest."Source
— Unnamed speaker (attorney)
(Arguing that the client was not hiding or planning to flee, as they were at a known location at the time of arrest.)
DOJ-OGR-00001082.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (1,715 characters)
Case 21-770, Document 20-2, 04/01/2021, 3068530, Page141 of 200
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1 because the conduct is 25 years old, among other reasons.
2 And as to the risk of flight factors, Mr. Epstein had
3 a prior felony conviction for conduct similar to that alleged
4 in the indictment. The package before Judge Berman was only
5 two suretors, and any properties that were offered to
6 Judge Berman at the proceeding were already subject to
7 forfeiture and so could not be proposed. So it is a very, very
8 different situation in that case which was not raised by the
9 government, and that's why we didn't address it.
10 The last point which I meant to raise earlier, your
11 Honor, and I will end with this, and I should have raised it
12 earlier, what we sometimes see in bail cases, and I'm sure your
13 Honor has seen this, is the government says, well, the
14 defendant was hiding and we have evidence, your Honor, that the
15 defendant was making plans to leave the country. That is the
16 situation, frankly, in the U.S. v. Zarger case, the case by
17 Judge Gleeson in 2000, that the government cites in its brief,
18 but of course doesn't discuss the facts. There is nothing to
19 that effect here. To the contrary, the defendant, our client,
20 is sitting in New Hampshire at the time of the arrest. So
21 there is no evidence that there was some sort of imminence for
22 the court to consider.
23 So not to repeat all the arguments we made, we thank
24 the court for your time and for reading the submissions and
25 listening, and we just think, Judge, when you step back, the
2 And as to the risk of flight factors, Mr. Epstein had
3 a prior felony conviction for conduct similar to that alleged
4 in the indictment. The package before Judge Berman was only
5 two suretors, and any properties that were offered to
6 Judge Berman at the proceeding were already subject to
7 forfeiture and so could not be proposed. So it is a very, very
8 different situation in that case which was not raised by the
9 government, and that's why we didn't address it.
10 The last point which I meant to raise earlier, your
11 Honor, and I will end with this, and I should have raised it
12 earlier, what we sometimes see in bail cases, and I'm sure your
13 Honor has seen this, is the government says, well, the
14 defendant was hiding and we have evidence, your Honor, that the
15 defendant was making plans to leave the country. That is the
16 situation, frankly, in the U.S. v. Zarger case, the case by
17 Judge Gleeson in 2000, that the government cites in its brief,
18 but of course doesn't discuss the facts. There is nothing to
19 that effect here. To the contrary, the defendant, our client,
20 is sitting in New Hampshire at the time of the arrest. So
21 there is no evidence that there was some sort of imminence for
22 the court to consider.
23 So not to repeat all the arguments we made, we thank
24 the court for your time and for reading the submissions and
25 listening, and we just think, Judge, when you step back, the
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
(212) 805-0300
DOJ-OGR-00001082
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