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This document is a transcript from a court hearing on April 1, 2021, where a defense attorney argues for their client's pretrial release. The attorney contends that the government has the unwavering burden to prove the client is a flight risk and has failed to do so, citing precedent from the Supreme Court and a Second Circuit case written by Judge Raggi. The attorney also informs the court that they have proactively prepared a bail package for consideration, subject to verification by Pretrial Services.

This document is a page from a court transcript dated December 10, 2020. An attorney is arguing for their client's pretrial release, citing precedent from the Supreme Court and the Second Circuit to assert that the burden of proof lies with the government to demonstrate the client is a flight risk. The attorney criticizes the government for not meeting this burden and introduces a prepared bail package for the judge's consideration.