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rties located at 9 East 71st Street, NY, NY 10021 valued at $55,931,000, 49 Zorro Ranch Road, Stanley, New Mexico 87056 valued at $17,246,208, 358 El Brillo Way, Palm Beach, Florida 33480 valued at $12,380,209, 22 Avenue Foch, Paris France 75116 valued at $8,672,823, Great St. James Island No. 6A USVI
d States v. Chimurenga, 760 F.2d 400, 403 (2d Cir. 1985). "[E]ven a single incident of witness tampering ... [may be] sufficient to revoke bail." LaFontaine, 210 F.3d at 134. [6,7] To order detention based upon risk of flight, the Court must find by a preponderance of the evidence that "that no condi
rties located at 9 East 71st Street, NY, NY 10021 valued at $55,931,000, 49 Zorro Ranch Road, Stanley, New Mexico 87056 valued at $17,246,208, 358 El Brillo Way, Palm Beach, Florida 33480 valued at $12,380,209, 22 Avenue Foch, Paris France 75116 valued at $8,672,823, Great St. James Island No. 6A USVI
d States v. Chimurenga, 760 F.2d 400, 403 (2d Cir. 1985). "[E]ven a single incident of witness tampering ... [may be] sufficient to revoke bail." LaFontaine, 210 F.3d at 134. [6,7] To order detention based upon risk of flight, the Court must find by a preponderance of the evidence that "that no condi
s Exhibit No.'2 3 I (Incident Reports) Plainiifl's Exhibit No. 3 99 (i:etter,to Harry krischer) Plaintiffs Exliibit NoA. 131 (Ph<?tographs of.El Brillo Way) .Plaintiffs Exhibit No. 5 • 132 (Photo of358 El_ Brillo \yay) Dcfei1diint's Exhibil'.No. 6 218 (Subpeona Duces Tecum) Plaintiti's Exliib
rings and the government is entitled to present evidence by way of proffer, among other means. See 18. U.S.C. § 3142(f)(2); see also United States v. LaFontaine, 210 F.3d 125, 130-31 (2d Cir. 2000) (government entitled to proceed by proffer in detention hearings); Ferranti, 66 F.3d at 542 (same); United State
Entities connected to both El Brillo and LaFontaine

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