Defense Argument p.8 — Millan/Rivera Cite, Conclusion: Grant Pretrial Release

Page 8 (final) of defense argument outline. Cites US v. Millan, 4 F.3d 1038, 1041 (2d Cir. 1993) and discusses El-Gabrowny dictum on substantial delay. Conclusion: Defendant has shown release necessary for trial prep because litigation strategies stolen multiple times. Government 90-minute defense fails. Question of dangerousness irrelevant but new evidence of Nicholss extraordinary character — assisting law enforcement, saving lives — weighs in his favor. Asks court to grant pretrial release tailored to trial preparation.

Source: J6 Scan 8 folder / Drive