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E COURT REPORTER: Good afternoon, your Honor. Kristen Carannante. THE COURT: Good afternoon, and thank you so much. We also have on the audio line Pretrial Services Officer Leah Harmon and -- THE PRETRIAL SERVICES OFFICER: Hello, your Honor. Good afternoon. THE COURT: Good afternoon. Thank you. We are here to
n that never shifts, has not made a showing as required, that our client is a risk of flight. When you consider the risk, as Judge Raggi put it, in Sabhnani, the actual risk of flight, not fantasy and not speculation, when you consider that the only factors they really point to are ones that the cases
the defendant should be housed where he can be secured at all times: a federal correctional center. The defendant faces a presumption of detention, Pretrial Services has recommended detention, and victims of the defendant seek his detention. Because there are no set of conditions short of incarceration that can
Page: EFTA00015533 →Supp. 3d 283, 292 (E.D.N.Y. 2014) (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, we have no occasion to consider whether it would be `contrary
Page: EFTA00015539 →WL 3536277 (2d Cir. June 30, 2020) 10 United States v. Moscaritolo, No. 10 Cr. 4 (JL), 2010 WL 309679 (D.N.H. Jan. 26, 2010) 18 United States v. Sabhnani, 493 F.3d 63 (2d Cir. 2007) 9, 10, 16, 18 United States v. Salerno, 481 U.S. 739 (1987) 9 United States v. Stephens, 15-CR-95 (AJN), 2020 WL 1
Page: EFTA00018518 →ted to the Southern and Eastern Districts of New York; (iii) surrender of all travel documents with no new applications; (iv) strict supervision by Pretrial Services; (v) home confinement at a residence in the Southern District of New York with electronic GPS monitoring; (vi) visitors limited to Ms. Maxwell's imm
Page: EFTA00018522 →the defendant should be housed where he can be secured at all times: a federal correctional center. The defendant faces a presumption of detention, Pretrial Services has recommended detention, and victims of the defendant seek his detention. Because there are no set of conditions short of incarceration that can
Page: EFTA00028786 →Supp. 3d 283, 292 (E.D.N.Y. 2014) (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, we have no occasion to consider whether it would be `contrary
Page: EFTA00028792 →t the defendant should be housed where he can be secured at all times: a federal correction center. The defendant faces a presumption of detention, Pretrial Services has recommended detention, and victims of the defendant seek his detention. The Court should order him detained. BACKGROUND A. Overview and Offens
Page: EFTA00030248 →Supp. 3d 283, 292 (E.D.N.Y. 2014) (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
Page: EFTA00030252 →Entities connected to both Pretrial Services and Sabhnani

Jeffrey Epstein
PERSON
United States
LOCATION
Michael Cohen
PERSON
Ghislaine Maxwell
PERSONBoustani
PERSONMartin Weinberg
PERSONthe Southern District
LOCATIONSecond Circuit
ORGANIZATION
Geoffrey S. Berman
PERSON
Harry Reid
PERSON
Michael Jackson
PERSONFBI
ORGANIZATIONJeffrey Pagliuca
PERSON
Reid Weingarten
PERSON
Department of Justice
ORGANIZATION
Richard M. Berman
PERSONZarrab
PERSON
United Kingdom
LOCATION
George Mitchell
PERSONBonestroo
PERSON