Epstein Secrets

Cr. 047, 2018 WL 888744, at *9 (N.D. Cal. Feb. 2018) (same); United States v. Anderson, 384 F. Supp.2d 32, 41 (D.D.C. 2005) (same); United States v. Benatar, No. 02 Cr. 099, 2002 WL 31410262, at *3 (E.D.N.Y. Oct. 10, 2002) (same). 5. Private Security is Inadequate, Unfair, and Impractical Here The defe

elaborately replicate a detention facility without the confidence of security such a facility instills."' United States v. Orena, 986 F.2d 628, 632 (2d Cir. 1993) (quoting United States v. Gotti, 776 F. Supp. 666, 672 (E.D.N.Y. 1991) (rejecting private jail proposal)); see also Valerio, 9 F. Supp. 3d at

ed provides the motive for him do so and is another significant factor in assessing the risk of flight. See United States v. Jackson, 823 F.2d 4, 7 (2d Cir. 1987). So too is the strength of the evidence, detailed above and in the Government's Detention Memo. Indeed, that evidence, already robust less th

Cr. 047, 2018 WL 888744, at *9 (N.D. Cal. Feb. 2018) (same); United States v. Anderson, 384 F. Supp.2d 32, 41 (D.D.C. 2005) (same); United States v. Benatar, No. 02 Cr. 099, 2002 WL 31410262, at *3 (E.D.N.Y. Oct. 10, 2002) (same). 5. Private Security is Inadequate, Unfair, and Impractical Here The defe

n to dozens of victims who were abused in Florida. 2 While beyond the scope of a bail hearing, as discussed further below, it is well-established in the Second Circuit that absent an express provision to the contrary in the agreement, one District is not bound by the terms of an agreement entered into between a def

ion to dozens of victims who were abused in Florida. While beyond the scope of a bail hearing, as discussed further below, it is well-established in the Second Circuit that absent an express provision to the contrary in the agreement, one District is not bound by the terms of an agreement entered into between a def

community"). A finding of risk of flight must be supported by a preponderance of the evidence. See, e.g., United States v. Jackson, 823 F.2d 4, 5 (2d Cir. 1987); United States v. Chirnurenga, 760 F.2d 400, 405 (2d Cir. 1985). A finding of dangerousness must be supported by clear and convincing evidenc

Cr. 047, 2018 WL 888744, at *9 (N.D. Cal. Feb. 2018) (same); United States v. Anderson, 384 F.Supp.2d 32, 41 (D.D.C. 2005) (same); United States v. Benatar, No. 02 Cr. 099, 2002 WL 31410262, at *3 (E.D.N.Y. Oct. 10, 2002) (same). Finally, there can be little doubt that the defendant is in a position to

n to dozens of victims who were abused in Florida. 2 While beyond the scope of a bail hearing, as discussed further below, it is well-established in the Second Circuit that absent an express provision to the contrary in the agreement, one District is not bound by the terms of an agreement entered into between a def

as noted, the possibility of a severe sentence is a significant factor in assessing the risk of flight. See United States v. Jackson, 823 F.2d 4, 7 (2d Cir. 1987); see also United States v. Cisneros, 328 F.3d 610, 618 (10th Cir. 2003) (defendant was a flight risk because her knowledge of the seriousness

Cr. 047, 2018 WL 888744, at *9 (N.D. Cal. Feb. 2018) (same); United States v. Anderson, 384 F.Supp.2d 32, 41 (D.D.C. 2005) (same); United States v. Benatar, No. 02 Cr. 099, 2002 WL 31410262, at *3 (E.D.N.Y. Oct. 10, 2002) (same). Finally, there can be little doubt that the defendant is in a position to

ion to dozens of victims who were abused in Florida. While beyond the scope of a bail hearing, as discussed further below, it is well-established in the Second Circuit that absent an express provision to the contrary in the agreement, one District is not bound by the terms of an agreement entered into between a def

community"). A finding of risk of flight must be supported by a preponderance of the evidence. See, e.g., United States v. Jackson, 823 F.2d 4, 5 (2d Cir. 1987); United States v. Chirnurenga, 760 F.2d 400, 405 (2d Cir. 1985). A finding of dangerousness must be supported by clear and convincing evidenc

Cr. 047, 2018 WL 888744, at *9 (N.D. Cal. Feb. 2018) (same); United States v. Anderson, 384 F.Supp.2d 32, 41 (D.D.C. 2005) (same); United States v. Benatar, No. 02 Cr. 099, 2002 WL 31410262, at *3 (E.D.N.Y. Oct. 10, 2002) (same). Finally, there can be little doubt that the defendant is in a position to

n to dozens of victims who were abused in Florida. 2 While beyond the scope of a bail hearing, as discussed further below, it is well-established in the Second Circuit that absent an express provision to the contrary in the agreement, one District is not bound by the terms of an agreement entered into between a def

community"). A finding of risk of flight must be supported by a preponderance of the evidence. See, e.g., United States v. Jackson, 823 F.2d 4, 5 (2d Cir. 1987); United States v. Chimurenga, 760 F.2d 400, 405 (2d Cir. 1985). A finding of dangerousness must be supported by clear and convincing evidence

Cr. 047, 2018 WL 888744, at *9 (N.D. Cal. Feb. 2018) (same); United States v. Anderson, 384 F.Supp.2d 32, 41 (D.D.C. 2005) (same); United States v. Benatar, No. 02 Cr. 099, 2002 WL 31410262, at *3 (E.D.N.Y. Oct. 10, 2002) (same). Finally, there can be little doubt that the defendant is in a position to

Cr. 047, 2018 WL 888744, at *9 (N.D. Cal. Feb. 2018) (same); United States v. Anderson, 384 F.Supp.2d 32, 41 (D.D.C. 2005) (same); United States v. Benatar, No. 02 Cr. 099, 2002 WL 31410262, at *3 (E.D.N.Y. Oct. 10, 2002) (same). D. Private Security is Inadequate and Raises Numerous Questions and Chall

) (Bianco, J.) (collecting cases). The Second Circuit has never directly addressed this issue. See United States v. Sabhnani, 493 F.3d 63, 78 n.18 (2d Cir. 2007) ("The government has not argued and, therefore, EFTA00030252 --- PAGE BREAK --- Honorable Richard M. Berman United States District Judge

a preponderance of the evidence. See, e.g., United States v. Patriarca, 948 F.2d 789, 793 (1st Cir. 1991); United States v. Jackson, 823 F.2d 4, 5 (2d Cir. 1987); United States v. Chimurenga, 760 F.2d 400, 405 (2d Cir. 1985). A finding of dangerousness must be supported by clear and convincing evidence

ation for bail in part because home detention with electronic monitoring "at best . . . limits a fleeing defendant's head start"); United States v. Benatar, No. 02 Cr. 099, 2002 WL 31410262, at *3 (E.D.N.Y. Oct. 10, 2002) (same); see also United States v. Casteneda, No. 18 Cr. 047, 2018 WL 888744, at *9