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fe No Ww ws oO OY ~] oO Ke} ha oO a fe N Ww = ws Oo a OY = ~] a oO a Ke) 20 21 22 23 24 25 Case 1:19-cr-00490-RMB Document36 _ Filed 07/24/19 Page 10 of 74 10 the defense what additional insight about this episode they can share with us to support their position in these proceedings. So, as all good lawyers, I reserve the right to have more questions, you heard on the issue of remand versus bail. If you can include some or all of these questions in your presentation, that would be great. But I'm happy to begin with Mr. Rossmiller and have and I probably will. MR. ROSSMILLER: Yes, your Honor. Your Honor, the government seeks pretrial detention in this case due to the extraordinary risk of flight and the danger presented by the defendant to the community, a danger that is not speculative but, rather, is evident from his prior actions. Asa pretrial services and the reguests of the victims that the defendant be detained. As the Court pointed out, with the sex trafficking result, we join with the recommendation from (e) combination of Ffense charged here, there is a presumption that no release conditions could reasonably assure the defendant's appearance and the protection of the public. The Court asked whether the presumption has been rebutted, and the answer is no. There has been no information provided by the defendant to rebut that presumption in this case. And in particular, as the Court noted, the defendant SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00000520