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Case 21-770, Document 57, 04/19/2021, 3080288, Page3 of 30 that the presumption of innocence is more than mere words on a page. This Reply responds to the arguments the Government does raise: 1. The Court did not conduct a “lengthy bail hearing.” Resp.§2. The transcript of the video arraignment and bail hearing spans only 91 pages, with the bail arguments on pages 22-79. The Government did not present any actual evidence at this brief hearing. Br.7-8,19-21. During the bail hearing, each time the Government mentioned the strength of its case, it cited to the Indictment. See, e.g., Ex.D, p.24 (“Turning first to the .. strength of the evidence, the indictment in this case arises ... . The indictment further charges that ...”); pg. 25 (“The indictment makes plain .. It was an ongoing scheme ... Given the strength of the government’s evidence ... there is an incredibly strong incentive for the defendant to flee ..). The court erred in agreeing that the Indictment itself demonstrates strength. Id. at 82 (“[I]t is appropriate to consider the strength of the evidence proffered by the government in assessing risk of flight. The government’s evidence at this early juncture of the case appears strong. Although the charged conduct took place many years ago, the indictment describes ...”). At no point did the Government introduce or even proffer any actual evidence. DOJ-OGR-00001375