following the declaration of a mistrial as a result of the onslaught or the coronavirus and the interruption of the trial that he had been in the middle of we had doing there i've never been in the position which is representing somebody i've never met to not have a conversation with other than on the telephone and i'm not been able to review the discovery we add to that or your  not only have i not been able to discuss it with the defendant no longer has any discovery i'm told because there was a shake up at the court at the jail and in the course of the search for for some kind of illegal very fair question your honor and i think the answer is very straightforward as well this is a situation where there was clear the the woman involved was free to leave it any time which is not in my own experience  and in fact her mother is miles away ten minutes drive away and she's met with her mother on a regular basis so she needed a way out mother was right the guy needed help mom get me out of the she was out in ninety nine nine percent of these cases these women don't have their own phone they don't have anywhere to go they don't have it with reach out to they are literally prisoners in this sexual trafficking trafficking business this is not only not the case but it because of her ability to break free and she chose to do but she also was running her own freelance business when she wasn't working on full the same and through this one route she had  to other knockout it from several other people and that's what the evidence supports so she's really not in the traditional friends trap and oftentimes these people are trapped not just because of the drugs but because the fear of violence violence what the inability to get drugs and i' situation in terms of the likelihood of success of a conviction and way that with all the other factors that are appropriate for bail i would happen to get some level of course here on that he would be right spot yes good morning may it please the court my name is rashmi bhaskar un and i represent the united states in this appeal and in the court below the court could affirm judge angle myer's detention because he did not clearly err in concluding that new condition or combination of conditions could reasonably ashore carl andrews appearance in court or address the danger he present in addition and for reasons judge angle meyer made no mistake in denying andrew's temporary relief under section three thousand one hundred and forty two dollars under the court's deferential clear error standard this court reverses the detention decision only if it has a definite and firm conviction that a mistake has been made or you're in the middle of the trial we are cooperating witness was you know they said trustworthy until we got down to prosecution it was focused on this one individual who  and says he to precept somewhat unusual circumstances could you comment on that for me please yes and thank you for the question the government dropped the recounts several days or a couple of days before the start of trial flight judge and going i relied on several factors one of them was the fact that the defendant faces year mandatory minimum sentence and as judge angle meyer observed the defendant depreciation of his ribs the risk of conviction today that the defendant lengthy criminal history of leaving paper detention couldn't because his criminal history includes convictions that spoke to the integrity of the justice system i think another factor that that kind of bears on the defendant the syrians to the rule of law that's worth mentioning is that you know that excessive any suggestion that the defendant has it and newfound appreciation for the rule of law that's simply belied by the fact that he submitted thank you for the question the purpose of the government's adjournment request was because within the last week or so the government learned that one of its key witnesses was diagnosed with cancer and was undergoing brain surgery this past friday and in light of that mental condition and the fact that that witness would be starting chemotherapy the government believes that that witness would not be in a position to testify or prepare for a trial this year to the government for the purpose underlying the defendants interests including the fact that you know everyone is working very hard during the pandemic to restore access in person access to his lawyers and this additional delay which is you know not a not not a extremely long delay talk no your honor the government's position is that it still has evidence beyond a reasonable doubt to convict the defendant even if this witness who although the government believes is an important witness the government's case does not rise or fall on that w government an opportunity to see whether its this witness would be in a position to classify a trial that said the government is prepared to proceed to trial without this witness not a way to prepare a case especially with someone i've not met and where we have the ability to make a bail package that will protect the protect the community he doesn't leave the palace other than to see his lawyer opportunity to meet with my client and prepare our case prepare a defense review the evidence with them i mean the vacuum here all right i think we understand the arguments thank you very much we will reserve decision and try to get you an answer promptly thank you so much thank you