EFTA00066344

BAIL: 18 U.S.C. §3142(g)

In light of the 3142(g) factors, the Government submits that [the presumption is overcome / the defendant cannot overcome the presumption], and accordingly that detention is warranted. In particular, we submit that [a preponderance of the evidence demonstrates that the defendant is a flight risk / that clear and convincing evidence demonstrates that the defendant is a danger to the community].

<table border="1"><tr><td>(1): NATURE &amp; CIRCUMSTANCES OF CHARGED OFFENSE
(Violence; Terrorism; Minor Victim;
Controlled Substance; Firearm; Explosive)</td><td></td></tr><tr><td>(2): WEIGHT OF EVIDENCE</td><td></td></tr><tr><td>(3): HISTORY AND CHARACTERISTICS OF THE DEFENDANT
(A): Character;
Physical/Mental Condition;
Family Ties;
Financial Condition;
Length of Residence;
Community Ties;
Past Conduct;
Drug/Alcohol History;
Criminal History;
History of Appearances at Court.
(B): At time of offense, under federal or state supervision (pre- or post-trial)</td><td></td></tr><tr><td>(4): DANGER TO ANY PERSON OR THE COMMUNITY</td><td></td></tr></table>