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602 KB
Extraction Summary
4
People
3
Organizations
0
Locations
1
Events
2
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
602 KB
Summary
This document is a page from a court transcript dated April 1, 2021. An attorney, Mr. Cohen, is making a concluding argument to a judge to grant bail for his client. He argues that the government has failed to meet its burden of proving the client is a flight risk, distinguishing the current case from others and citing a precedent from Judge Raggi in the Sabhnani case before formally requesting the court to grant bail.
People (4)
| Name | Role | Context |
|---|---|---|
| MR. COHEN | Attorney/Counsel |
Speaker in the transcript, arguing for his client to be granted bail.
|
| your Honor | Judge |
Addressed by MR. COHEN during a court proceeding.
|
| Judge Raggi | Judge |
Mentioned by MR. COHEN in reference to a previous case (Sabhnani) regarding the definition of flight risk.
|
| Sabhnani | Party in a legal case |
Mentioned as the name of a case cited by MR. COHEN.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| SOUTHERN DISTRICT REPORTERS, P.C. | company |
Listed at the bottom of the transcript as the court reporting service.
|
| the court | government agency |
Mentioned throughout as the body being addressed and asked to grant bail.
|
| the government | government agency |
Mentioned as the opposing party in the case, which has the burden of persuasion to show the client is a flight risk.
|
Timeline (1 events)
2021-04-01
An attorney, MR. COHEN, makes a concluding argument to a judge to grant bail for his client.
Courtroom (implied)
Relationships (2)
MR. COHEN refers to "our client" while arguing on their behalf in court, indicating an attorney-client relationship.
MR. COHEN addresses "your Honor" formally in a court proceeding, indicating the professional relationship between an attorney and a judge.
Key Quotes (3)
"So in conclusion, we believe this is a compelling case for bail."Source
— MR. COHEN
(The beginning of the concluding statement in an argument for bail.)
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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 opposing party has failed to meet its legal burden of proof.)
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Quote #2
"So we would ask the court to grant bail today."Source
— MR. COHEN
(Directly requesting the judge to grant his client's release on bail.)
DOJ-OGR-00001074.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (1,799 characters)
Case 21-770, Document 20-2, 04/01/2021, 3068530, Page133 of 200 70
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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-00001074
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