Epstein Secrets

is case. (Gov. Mem. at 4-5.) This oversimplifies the governing standard. Although the severity of potential punishment is a relevant consideration, the Second Circuit "require[s] more than evidence of the commission of a serious crime and the fact of a potentially long sentence to support a finding of risk of fli

be denied bail pending trial."' Sabhnani, 493 F.3d at 75 (citation and internal quotation marks omitted). 8 See also Letter of Sean Hecker to Hon. Margo K. Brodie (July 8, 2020), Federal Defenders of New York, Inc. v. Federal Bureau of Prisons, et at, No. 19 Civ. 660 (E.D.N.Y.) (Doc. No. 78) (detailing absence

is case. (Gov. Mem. at 4-5.) This oversimplifies the governing standard. Although the severity of potential punishment is a relevant consideration, the Second Circuit "require[s] more than evidence of the commission of a serious crime and the fact of a potentially long sentence to support a finding of risk of fli

be denied bail pending trial."' Sabhnani, 493 F.3d at 75 (citation and internal quotation marks omitted). 8 See also Letter of Sean Hecker to Hon. Margo K. Brodie (July 8, 2020), Federal Defenders of New York, Inc. v. Federal Bureau of Prisons, et at, No. 19 Civ. 660 (E.D.N.Y.) (Doc. No. 78) (detailing absence

is case. (Gov. Mem. at 4-5.) This oversimplifies the governing standard. Although the severity of potential punishment is a relevant consideration, the Second Circuit "require[s] more than evidence of the commission of a serious crime and the fact of a potentially long sentence to support a finding of risk of fli

be denied bail pending trial."' Sabhnani, 493 F.3d at 75 (citation and internal quotation marks omitted). 8 See also Letter of Sean Hecker to Hon. Margo K. Brodie (July 8, 2020), Federal Defenders of New York, Inc. v. Federal Bureau of Prisons, et at, No. 19 Civ. 660 (E.D.N.Y.) (Doc. No. 78) (detailing absence

is case. (Gov. Mem. at 4-5.) This oversimplifies the governing standard. Although the severity of potential punishment is a relevant consideration, the Second Circuit "require[s] more than evidence of the commission of a serious crime and the fact of a potentially long sentence to support a finding of risk of fli

be denied bail pending trial."' Sabhnani, 493 F.3d at 75 (citation and internal quotation marks omitted). 8 See also Letter of Sean Hecker to Hon. Margo K. Brodie (July 8, 2020), Federal Defenders of New York, Inc. v. Federal Bureau of Prisons, et at, No. 19 Civ. 660 (E.D.N.Y.) (Doc. No. 78) (detailing absence

is case. (Gov. Mem. at 4-5.) This oversimplifies the governing standard. Although the severity of potential punishment is a relevant consideration, the Second Circuit "require[s] more than evidence of the commission of a serious crime and the fact of a potentially long sentence to support a finding of risk of fli

be denied bail pending trial."' Sabhnani, 493 F.3d at 75 (citation and internal quotation marks omitted). 8 See also Letter of Sean Hecker to Hon. Margo K. Brodie (July 8, 2020), Federal Defenders of New York, Inc. v. Federal Bureau of Prisons, et at, No. 19 Civ. 660 (E.D.N.Y.) (Doc. No. 78) (detailing absence

risonment for turning off a light in a lighthouse to expose a ship to danger). Even if there were evidence to back up the four anonymous accusers, the Second Circuit "require[s] more than evidence of the commission of a serious crime and the fact of a potential long sentence to support a finding of risk of fligh

ld be denied bail pending trial.'" Sabhnani, 493 F.3d at 75 (citation and internal quotation marks omitted). See also Letter of Sean Hecker to Hon. Margo K. Brodie (July 8, 2020), Federal Defenders of New York Inc. v. Federal Bureau of Prisons, et at, No. 19 Civ. 660 (E.D.N.Y.) (Doc. No. 78) (detailing absence

is case. (Gov. Mem. at 4-5.) This oversimplifies the governing standard. Although the severity of potential punishment is a relevant consideration, the Second Circuit "require[s] more than evidence of the commission of a serious crime and the fact of a potentially long sentence to support a finding of risk of fli

be denied bail pending trial."' Sabhnani, 493 F.3d at 75 (citation and internal quotation marks omitted). 8 See also Letter of Sean Hecker to Hon. Margo K. Brodie (July 8, 2020), Federal Defenders of New York, Inc. v. Federal Bureau of Prisons, et at, No. 19 Civ. 660 (E.D.N.Y.) (Doc. No. 78) (detailing absence

be denied bail pending trial."' Sabhnani, 493 F.3d at 75 (citation and internal quotation marks omitted). 8 See also Letter of Sean Hecker to Hon. Margo K. Brodie (July 8, 2020), Federal Defenders of New York, Inc. v. Federal Bureau of Prisons, et at, No. 19 Civ. 660 (E.D.N.Y.) (Doc. No. 78) (detailing absence

t that presumption by coming forward with evidence that [she] does not pose ... a risk of flight." See United States v. English, 629 F.3d 311, 319 (2d Cir. 2011) (quotation omitted). This rebuttable presumption can be readily satisfied, United States v. Conway, No. 4-11-70756 MAG (DMR), 2011 WL 3421321,

is case. (Gov. Mem. at 4-5.) This oversimplifies the governing standard. Although the severity of potential punishment is a relevant consideration, the Second Circuit "require[s] more than evidence of the commission of a serious crime and the fact of a potentially long sentence to support a finding of risk of fli