affect law enforcement interests.") (citing United States v. Amodeo, 71 F.3d 1044, 1050)); see also United States v. Park, 619 F. Supp. 2d 89, 94 (S.D.N.Y. 2009) (holding that the need to "maintain the secrecy of the Government's investigation" outweighed the public's right of access to certain sentencing d

sal criminality" and alleged to be a "high flight risk," granted release subject to conditions); United States v. Madoff, 586 F. Supp. 2d 240, 243 (S.D.N.Y. 2009) (Bernie Madoff, charged with "largest Ponzi scheme ever and alleged to be a "serious risk of flight," granted release subject to conditions). not

e investigation, as the individuals and entities under investigation would be put on notice." United States v. Madoff, 626 F. Supp. 2d 420, 427-28 (S.D.N.Y. 2009). And the Government's interest in protecting an ongoing investigation from the "danger of impairing law enforcement" may be a countervailing facto