DOJ-OGR-00001944.jpg

631 KB

Extraction Summary

4
People
3
Organizations
0
Locations
3
Events
4
Relationships
5
Quotes

Document Information

Type: Court transcript / legal document
File Size: 631 KB
Summary

This document is a page from a court transcript dated December 10, 2020, discussing a client's detention and the discovery process. Mr. Cohen argues that his client's arrest, despite voluntary surrender, limits access and that the COVID crisis complicates gathering financial information. He also highlights the government's request for an extended discovery period until November.

People (4)

Name Role Context
MR. COHEN Speaker
Responding to a question, making arguments regarding a client's detention and discovery.
THE COURT Speaker
Acknowledging Mr. Cohen's statement.
your Honor Judge
Addressed by Mr. Cohen.
client Subject of discussion
Mr. Cohen's client, who voluntarily surrendered but was arrested and detained. Also, the subject of financial informa...

Organizations (3)

Name Type Context
SOUTHERN DISTRICT REPORTERS, P.C.
Transcription service for the court proceeding.
Pretrial Services
Organization that asked questions about a real estate transaction.
government
The entity that arrested and detained the client, and is requesting until November to complete discovery.

Timeline (3 events)

2020-12-10
Court proceeding/hearing where Mr. Cohen is speaking.
Court
Client's arrest and detention despite voluntary surrender.
Discussion of discovery timeline, with the government requesting until November.
Court

Relationships (4)

MR. COHEN attorney-client client
MR. COHEN refers to 'my client' and 'your access to the client'.
MR. COHEN attorney-judge THE COURT
Mr. Cohen addresses 'your Honor' and the Court responds.
client defendant-prosecutor/state government
The client was arrested and detained by the government.
client subject of inquiry Pretrial Services
Pretrial Services asked questions about the client's real estate transaction.

Key Quotes (5)

"Is that the implication you are making?"
Source
DOJ-OGR-00001944.jpg
Quote #1
"MR. COHEN: No, I am not saying that, your Honor. I am not going that far. What I am saying is, when you have a client who will voluntary surrender, who is staying in the country despite an investigation, and the government instead chooses to arrest her and detain her, that limits in the early instances your access to the client."
Source
DOJ-OGR-00001944.jpg
Quote #2
"It is complicated by the COVID crisis and the other factors your Honor has pointed out in Stephens and in Williams-Bethea, and so it is very hard for us to pull together this financial information, and we have done it as quickly as we could before the court."
Source
DOJ-OGR-00001944.jpg
Quote #3
"But the notion that my client should have been able to answer off the top of her head the questions from Pretrial Services about a real estate transaction, for example, just doesn't make any sense. That's the point we are making."
Source
DOJ-OGR-00001944.jpg
Quote #4
"MR. COHEN: One last point in that regard, your Honor, in the schedule we set today -- thank you, your Honor, for approving that the government is saying that it needs at least until November to complete all discovery, including electronic discovery. They have told us that there are two"
Source
DOJ-OGR-00001944.jpg
Quote #5

Full Extracted Text

Complete text extracted from the document (1,555 characters)

Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 67 of 91
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originally without prejudice obviously for precisely the
proceeding we are having, but it sounded like you were
suggesting that her current detention was in some way by design
to prevent you from providing a full picture of her financial
situation. Is that the implication you are making?
MR. COHEN: No, I am not saying that, your Honor. I
am not going that far. What I am saying is, when you have a
client who will voluntary surrender, who is staying in the
country despite an investigation, and the government instead
chooses to arrest her and detain her, that limits in the early
instances your access to the client. It is complicated by the
COVID crisis and the other factors your Honor has pointed out
in Stephens and in Williams-Bethea, and so it is very hard for
us to pull together this financial information, and we have
done it as quickly as we could before the court. But the
notion that my client should have been able to answer off the
top of her head the questions from Pretrial Services about a
real estate transaction, for example, just doesn't make any
sense. That's the point we are making.
THE COURT: Okay.
MR. COHEN: One last point in that regard, your Honor,
in the schedule we set today -- thank you, your Honor, for
approving that the government is saying that it needs at
least until November to complete all discovery, including
electronic discovery. They have told us that there are two
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
DOJ-OGR-00001944

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