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Extraction Summary

3
People
3
Organizations
1
Locations
1
Events
1
Relationships
4
Quotes

Document Information

Type: Court transcript (bail proceeding)
File Size: 643 KB
Summary

This document is page 64 of a court transcript from a bail proceeding filed on December 10, 2020 (Case 1:20-cr-00330-AJN). Defense attorney Mr. Cohen argues that the government is using tactics to circumvent the Non-Prosecution Agreement (NPA) by indicting conduct that is 25 years old. He cites the 'Annabi case' regarding the reach of plea agreements binding U.S. Attorney offices.

People (3)

Name Role Context
Mr. Cohen Defense Attorney
Arguing regarding the NPA and the weight of evidence during a bail proceeding.
The Court Judge
Presiding judge (likely Judge Alison J. Nathan based on case number suffix AJN) asking clarifying questions.
AJN Judge
Initials in case caption (Alison J. Nathan).

Organizations (3)

Name Type Context
U.S. Attorney
Mentioned in the context of the Annabi case precedent regarding plea agreements.
Southern District Reporters, P.C.
Court reporting service listed in footer.
The Government
The prosecution team.

Timeline (1 events)

2020-12-10
Bail proceeding hearing where defense argues about the Non-Prosecution Agreement (NPA) and the age of the indictment charges.
Courtroom

Locations (1)

Location Context
Implied by the reporter's name (Southern District of New York).

Relationships (1)

Mr. Cohen Attorney/Judge The Court
Direct dialogue in transcript (Lines 23-25).

Key Quotes (4)

""The plea agreement binds only the office of the U.S. Attorney for the district in which the plea is entered unless it affirmatively appears that the agreement contemplates a broader restriction,""
Source
DOJ-OGR-00001941.jpg
Quote #1
"The government chose to indict conduct that's 25 years old, your Honor."
Source
DOJ-OGR-00001941.jpg
Quote #2
"It's an effort to dance around the NPA."
Source
DOJ-OGR-00001941.jpg
Quote #3
"This case is about tactics."
Source
DOJ-OGR-00001941.jpg
Quote #4

Full Extracted Text

Complete text extracted from the document (1,693 characters)

Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 64 of 91 64
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1 We believe there are significant motions relating to
2 the reach of the NPA, which we are not going to litigate here
3 before your Honor in a bail proceeding, that are not even
4 foreclosed by the cases the government does cite to you. They
5 cite to you the -- I'm going to skip this one, the Annabi case,
6 A-N-N-A-B-I case, which says, "The plea agreement binds only
7 the office of the U.S. Attorney for the district in which the
8 plea is entered unless it affirmatively appears that the
9 agreement contemplates a broader restriction," and that in part
10 is going to be our argument. So we will make it to your Honor
11 at the appropriate time. For today's purposes, it should be in
12 the mix in evaluating the weight of the evidence as should the
13 points I just made about the perjury charge and we think that
14 there are other significant legal challenges to the indictment.
15 We also think there are significant issues with the
16 weight of the evidence. The government chose to indict conduct
17 that's 25 years old, your Honor. You will see when you get our
18 motions that this, we think, is an effort to dance around the
19 NPA, to come into an earlier time period, a related time
20 period. It's all tactics. That's all this is about. This
21 case is about tactics. It's an effort to dance around the NPA.
22 But the fact of the matter is the government --
23 THE COURT: Mr. Cohen, I'm sorry, by that do you mean
24 that the time period charged is not covered by the NPA.
25 MR. COHEN: Right. Exactly. There is going to be
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
DOJ-OGR-00001941

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