DOJ-OGR-00001955.jpg
635 KB
Extraction Summary
4
People
2
Organizations
1
Locations
4
Events
1
Relationships
2
Quotes
Document Information
Type:
Legal document
File Size:
635 KB
Summary
This document is a transcript from a legal proceeding where an attorney argues for their client, likely concerning bail. The attorney refutes the government's claim that the client is a flight risk by distinguishing the current case from precedents like 'U.S. v. Zarger' and a prior case involving a 'Mr. Epstein', emphasizing that their client was in New Hampshire at the time of arrest and not making plans to flee.
People (4)
| Name | Role | Context |
|---|---|---|
| Mr. Epstein |
Mentioned as having a prior felony conviction and being involved in a previous case with different circumstances rega...
|
|
| Judge Berman | Judge |
Presided over a previous proceeding where a bail package was offered for Mr. Epstein.
|
| Zarger | Defendant |
Mentioned in the context of the 'U.S. v. Zarger case' from 2000, cited by the government.
|
| Judge Gleeson | Judge |
Presided over the U.S. v. Zarger case in 2000.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| government | government agency |
Mentioned as the opposing party in the legal case, which cited the U.S. v. Zarger case and claims the defendant is a ...
|
| 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, which the government cited in its brief.
2020-12-10
An attorney is making an argument to a judge, likely regarding a bail hearing, contrasting their client's case with others.
Southern District (implied)
Unnamed attorney (speaker)
Unnamed judge ('your Honor')
Unnamed defendant ('our client')
The arrest of the defendant ('our client').
New Hampshire
Unnamed defendant ('our client')
A prior proceeding involving Mr. Epstein before Judge Berman concerning a bail package.
Locations (1)
| Location | Context |
|---|---|
|
The location where the defendant was at the time of their arrest.
|
Relationships (1)
Unnamed attorney (speaker)
→
Attorney-Client
→
Unnamed defendant ('our client')
The speaker refers to the defendant as 'our client' while making legal arguments on their behalf.
Key Quotes (2)
"To the contrary, the defendant, our client, is sitting in New Hampshire at the time of the arrest."Source
— Unnamed attorney
(Used to argue against the government's assertion that the defendant is a flight risk, contrasting the client's situation with the facts of a case cited by the government.)
DOJ-OGR-00001955.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 attorney
(Distinguishing the current case from a precedent (U.S. v. Zarger) used by the prosecution to argue the defendant was a flight risk.)
DOJ-OGR-00001955.jpg
Quote #2
Full Extracted Text
Complete text extracted from the document (1,893 characters)
Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 78 of 91
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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-00001955
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