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Case 1:20-cr-00330-AJN Document4 Filed 07/02/20 Page 5of10 18 U.S.C. § 3142(g). Evidentiary rules do not apply at detention hearings, and the Government is entitled to present evidence by way of proffer, among other means. See 18 U.S.C. § 3142(f)(2); see also United States v. LaFontaine, 210 F.3d 125, 130-31 (2d Cir. 2000) (Government entitled to proceed by proffer in detention hearings). Where a judicial officer concludes after a hearing that “no condition or combination of conditions will reasonably assure the appearance of the person as required and the safety of any other person and the community, such judicial officer shall order the detention of the person before trial” 18 U.S.C. § 3142(e)(1). Additionally, where, as here, a defendant is charged with committing an offense involving a minor victim under 18 U.S.C. §§ 2422 or 2423, it shall be presumed, subject to rebuttal, that no condition or combination of conditions will reasonably assure the appearance of the defendant as required and the safety of the community. 18 U.S.C. § 3142(e)(3)(E). Il. Discussion For the reasons set forth below, the defendant presents an extreme risk of flight, and therefore she cannot overcome the statutory presumption in favor of detention in this case. Every one of the relevant factors to be considered as to flight risk — the nature and circumstances of the offense, the strength of the evidence, and the history and characteristics of the defendant — counsel strongly in favor of detention. A. The Nature and Circumstances of the Offense and the Strength of the Evidence The “nature and circumstances” of this offense favor detention. As the Indictment alleges, the defendant committed serious crimes involving the sexual exploitation of minors. See 18 U.S.C. § 3142(g)(1) (specifically enumerating “whether the offense. . . involves a minor victim” as a factor in bail applications). Indeed, the crimes of enticing and transporting minors for illegal sex DOJ-OGR-00001491