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Case 1:19-cr-00490-RMB Document 36 Filed 07/24/19 Page 27 of 74 27 1 to registration which was part of the obligations that he 2 accepted, and no one quarrels with his performance. 3 e went to the state. They returned the higher 4 charge. e went to jail. He did his strict probation with 5 home detention. And he's been registered since 2010. 6 I think these facts are important, not just because 7 they are the cornerstone of a potential legal defense, and I 8 won't go through all of the different factors that we believe 9 on a principal basis will distinguish this case from the 10 precedence that Mr. Rossmiller is relying on. 11 These were not two silos. The Southern District 12 didn't stand completely detached from the activities and the 13 events in Florida. But that's a motion to dismiss that will be 14 brought later. The premise is if we're right and they're wrong 15 and he's detained, he's lost freedom without punishment. 16 Your Honor asked about the rebuttable presumption, and 17 [ think this also goes back to the events of the 2007 and 2008 18 era. 19 THE COURT: So the presumption, first of all, the 20 people who wrote that presumption into law clearly know about 21 bail and history and the need for defendants to consult with 22 their counsel, etc. 23 But in this rather narrow class of cases, almost all 24 of them I think relating to children or young people, there ar 25 a whole series of cases, exceptions to be sure, where th SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00000537