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

communal spaces, and limited access to hygiene products' [in correctional facilities] make community spread all but unavoidable." United States v. Williams-Bethea, No. 18-CR-78 (AJN), 2020 WL 2848098, at *5 (S.D.N.Y. June 2, 2020) (citation and internal quotation marks omitted). The risks are further enhanced

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

communal spaces, and limited access to hygiene products' [in correctional facilities] make community spread all but unavoidable." United States v. Williams-Bethea, No. 18-CR-78 (AJN), 2020 WL 2848098, at *5 (S.D.N.Y. June 2, 2020) (citation and internal quotation marks omitted). The risks are further enhanced

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 law of the statute, by its structure, favors release. The Supreme Court has and the Second Circuit has advised us that a very limited number of people should be detained prior to trial because of the statute's structure, and the government nowher

rly 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 n

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

communal spaces, and limited access to hygiene products' [in correctional facilities] make community spread all but unavoidable." United States v. Williams-Bethea, No. 18-CR-78 (AJN), 2020 WL 2848098, at *5 (S.D.N.Y. June 2, 2020) (citation and internal quotation marks omitted). The risks are further enhanced

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

communal spaces, and limited access to hygiene products' [in correctional facilities] make community spread all but unavoidable." United States v. Williams-Bethea, No. 18-CR-78 (AJN), 2020 WL 2848098, at *5 (S.D.N.Y. June 2, 2020) (citation and internal quotation marks omitted). The risks are further enhanced

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

communal spaces, and limited access to hygiene products' [in correctional facilities] make community spread all but unavoidable." United States v. Williams-Bethea, No. 18-CR-78 (AJN), 2020 WL 2848098, at *5 (S.D.N.Y. June 2, 2020) (citation and internal quotation marks omitted). The risks are further enhanced

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

(S.D.N.Y. Mar. 19, 2020) 5, 6, 7, 8 United States v. Veres, No. 3:20-CR-18-J-32JBT, 2020 WL 1042051 (M.D. Fla. Mar. 4, 2020) 18 United States v. Williams-Bethea, No. 18-CR-78 (MN), 2020 WL 2848098 (S.D.N.Y. June 2, 2020) 6 Statutes 18 U.S.C. § 3142 passim iii EFTA00093093 cggeei ThOesttuAlitqltdeggn

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 law of the statute, by its structure, favors release. The Supreme Court has and the Second Circuit has advised us that a very limited number of people should be detained prior to trial because of the statute's structure, and the government nowher

rly 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 n

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

communal spaces, and limited access to hygiene products' [in correctional facilities] make community spread all but unavoidable." United States v. Williams-Bethea, No. 18-CR-78 (AJN), 2020 WL 2848098, at *5 (S.D.N.Y. June 2, 2020) (citation and internal quotation marks omitted). The risks are further enhanced

(S.D.N.Y. Mar. 19, 2020) 5, 6, 7, 8 United States v. Peres, No. 3:20-CR-18-J-32JBT, 2020 WL 1042051 (M.D. Fla. Mar. 4, 2020) 18 United States v. Williams-Bethea, No. 18-CR-78 (MN), 2020 WL 2848098 (S.D.N.Y. June 2, 2020) 6 Statutes 18 U.S.C. § 3142 passim iii EFTA00018518 --- PAGE BREAK --- Case 1:2

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