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JCasenst9-cr-00490-RMB Document 40 _ Filed 07/26/19 Page 3of6 a 1 submissions. Those are the written submissions: principally 2 the indictment, the legal principles governing release versus 3 remand, the presumption of remand in 18 U.S.C. section 1591 4 cases, danger to others and the community. This topic has 5 seven subsections and fills over ten pages of the decision and 6 order. I think it is fair to say that it is the heart of this 7 decision, that is to say, dealing with danger to others and to 8 the community. 9 Then I deal with risk of flight. That has four 10 subsections or factors, which are substantially the same 11 factors that are used to analyze dangerousness. 12 Then, finally, the bail package proposed by the 13 defense. Specifically, find in the decision and order that 14 the government has established dangerousness to others and to 15 the community by clear and convincing evidence and also that 16 the government has established risk of flight by a 17 preponderance of the evidence. I also reject the proposed bail 18 package as irretrievably inadequate and go on in some detail 19 concerning what I consider to be its deficiencies. 20 Incidentally, am not suggesting that a different 21 bail package would be appropriate because I doubt that any bail 22 package can overcome danger to the community. 23 focus then on dangerousness to others, most 24 certainly including the minor victims in this case and 25 prospective victims as well. I cite and quote, for example, SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00000607