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Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 46 of 91
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So we underst
process,
relevant to the
again, we don
Ms. Moe tried
but we
t have spin.
submit
to put bet
determination bet
tand why the court has to
Fore the court today.
The big
46
follow this
t that these presentations just are not
And,
fact that the government,
Fore you through the victim is that
supposedly someone had called in a civil action
two-year-old child.
your Honor.
spin, spin.
So we are here to consider bail.
the statute.
the statute.
that
factors,
because
want to point
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No
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We should consider your
So let me jus
In turning
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out th
now an oral presenta
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that really disposes o
Maxwell.
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t put that
to the statute,
Honor is very
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your Honor,
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iar with
to one side.
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ly that was phrased,
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We should consider
Honor's guidance under
I determine
fF what weight to give.
turning to the
the standard,
it, but I do
at,
tion,
dard
in an opening brief
and
and
reply brief
the government has not once
has.
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And that is th
ther
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not that case
subject to the least restrictive condition or combination of
conditions."
3142 (e), (
f),
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"the court
ute,
under 3142(c),
to your Honor nor the burden
to be release ROR"
shall
order pretrial
says that
that it
"even
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release
course,
in light of
the provisions on detention,
SOUTHE
RN D
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BRS, Pes
(212)
805-0300
that the
DOJ-OGR-00001923