Defense Argument p.6 — 3142(c) Factors: Not Flight Risk, Not Danger

Page 6 of defense argument outline. Distinguishes 3142(i) from 3142(g) renewed motion. Cites US v. Lee, Buswell, Dupree, Jeffries, Birbragher. Calls for relief under 3142(c) factors: not a flight risk, not a danger to community. Notes government conceded history/characteristics weighed for release. References ECF 168-1, pgs 64-72 — Ryans work detail reviews all perfect, no disciplinary issues, no finding of fact on September 5 event.

Source: J6 Scan 8 folder / Drive