government's argument and say and finding that there were it's clear and convincing evidence of my clients dangerous has failed why because when you look at each individual you know i guess spoke in the wheel they fail and we go through them judges that is a determining factor saying that was part of the totality of what we're able to show fact of lee though there was no linkage of his alleged blood membership to any type of criminal activity either in the case that is being litigated or prosecuted the eastern district or respect to any of the government's propers about violence or violence that is the bloods what they do is crime is not the fruit of the month club your honor that is true but there are basketball players who are bloods there are a rap singers who are bloods you know i'm not saying that is great to be a blood your honor i would want my son to be a blood but but the point is that in of itself doesn't show that you're involved in criminal activity just different types of blood so to speak so it but the point was the government should link that activity saying ok this was he's a blood and he was doing this for the bloods that never happened during our b is and there's you know we have the tapes and i had to more or less i can't discredit my client's voice and that was and i don't in sirius's we don't really look at that spoke as the strongest one in terms of pushing back against judge ross's determination the government has presented its case that's a fair inference for her to draw so i have to let that one stay as it is but i'm going further europe in terms of her decisions for instance she said in terms of the domestic violence incident that the and then when i did my investigation i was able to get the not only prosecutor from the state of georgia is show that what happens my client put a justification defense i was able to show that he was a lot a lot of firearm possessor he use it in defen and the case was withdrawn by the complainant some for some species reason as i look at it was his brother and his brother it is one of these family disputes but then the judge says well it shows that he's sort of a watching this a willingness to use use this with the intercept was in march of two thousand and sixteen before his arrest so he's under no conditions under no restriction at all so but what he's talking about is you know basically you have a very  cooperator who's sort of a bully he's he's he brings up the topic of violence each time and the judge got it right in the first instance which he said i didn't know whether this was a grudging you know get me off get off you know she she noted that he raised the issues each time and you know and then asked for the government to provide the tapes and the government so they could get him within an hour and they decided not to provide them and then the government and it got sort of confusing but the government now has clarified that you know part of the judge's determination was that the government stopped the acts of violence but it turned out in terms of the rival shooting which is called the so called rival shooting the government took no action to prevent it it never went forward after three months the government heard about it never intercepted him they wrestle him in july so they didn't need to stop him because nothing ever happened and then the other issue with the respect to this this cease matthews ashanti cease matthews it's other issue that they said they did prevent we did have the government's pro but every time they properly gets they get it wrong so how can it be clear convincing evidence if we're proffers or always mistaken it's not reasonable and the last thing your honor is this with respect to the blood's the government made a proffer from the that said while he was at the in d c that he made suggestive phone calls that he was going to drop a cooperator and then we get the tapes the government comes back and says no that's not correct because the that's actually right they're not right because there's nothing about violence because that's the context of the conversations if they don't show that so that each time they proffer it they get it wrong so in this one aspect we're supposed to trust them but we can't at this point and i might question their motives i'm simply saying they're getting it wrong  call to judge ross we indicated that we had listened to the call that we had received a call from the m d c indicating that they had intercepted a phone call that was threatening upon our review we provide we proffer to the court and presented actually the calls and transcript that showed not that it was a threatening call but that it was a call by the defendant alerting other members of the bloods that he was in jail and asking for their protection so to speak in jail so we offered them to support of our proffer that the defendant was part of the blood sort of dropping these players while the dropping of operators not what the tapes show that was what was initially said to us by the representative of the c when we got the calls it showed that he was reaching out to other blood members and the shooting incident he had along with a gun that's from that appears to be so you are yes he did have a license to carry the gun but in terms of the just said it was self defense yes mr houston alleges that it was it was self defense or somewhere i thought that was good and well respectfully judge the record the justification claim was made before judge ross and was made in georgia by the defense but at the records that we presented to the court there were there was no support for a justification defense what the records was that the defendant was in a confrontation with his girlfriend's brother whereupon he pulled out a gun and shot the brother in the leg there was evidence in the records that we put forth that at least one witness said that the defendant walked out of the room and returned to the room with a gun but never the less the more important point is that this the records not support the justification defense that the that mr houston now raises it i honor so taken together the government offered a number of factors that supported the judge's finding of clear and convincing evidence of dangerousness to begin the nature and the circumstances of the offense which mr houston did not challenge  people have no record but in this case beyond the record beyond the circumstances of the offense which involved the transfer of a large quantity of guns with a group of people the government proffered that the defendant was involved in plots to kill two in two different murder conspiracies a plot to kill rivals and a plot to kill a relative of one of the coconspirators charged in his indictment and certainly that was a clear and convincing evidence of his dangerousness he as judge ross noted he was willing to travel to another state in order to pursue paid in one or both of those plots to kill and taken together with his access to  we provided to the court of the two calls from march twenty sixth seen with c c one yes and so i am taken together with the his plots to kill two different individuals coupled with his gang membership which we offered proffered and supported with evidence including instagram photographs of him making gang signs and the prison call which i referred to earlier taken together with that and the shooting in georgia day perhaps if the issue is risk of flight the package the sufficiency of the package detaining him in the home or other things that might make it difficult for him to travel would be sufficient but given the clear and individual that the record changed greatly between new york it did your honor in atlanta we did not put forth evidence of the murder plots of the of the plots to kill both the rivals and the victims all we put before well judge if you're asking me about it in general i we were then as we are now dealing with safety issues that it was why we were sort of resistant to give over the tapes initially before judge ross but the what we put before judge ross is is just the transcript so in terms of what she relied upon in her determination that's what that's what we relied on a transcript that involved a statement that he was reports to talk about the murder plots one thing that the government really has admitted and i want to say this james was loud and clear a shot they cease matthews she's on bail she's supposedly one of the for the murder and that should resonate in ring loud she's the person they're talking about in the conversation that you know that's a person that's the person she wants killed she has bail so she's not been charged take your point but the point is the government controlled the record in her bail hearing they should if they really thought there was a real plot then why didn't they put it in front of that magistrate for this research being sees matthews if they really believe it why not proffer and then if it's really about their responsibility the fact that they're picking and choosing undermines the credibility with respect to the proffers that's the point with indulgence of the presiding judge who asked the government to answer the questions  which is a call on open questions of the not entitled answers i'd like to hear their answer and i'm fine with them having that opportunity on just two points also my client owns a home that was assessed down in georgia he's gainfully employed so he's willing to put up  to the amount of the package you know there's very little equity on it in all fairness there's maybe about ten thousand dollars worth of equity in it but for him a person of modest means that's a substantial investment that would be basically his life savings you know what he's been trying to  earn so you know this is not a person of you know of wealth and then also we put up seven shorter's and i do think moral suasion means something in that and also i know it's only a district court decision i i put in front of the judge but i think that's a fair and we know that that regularly occurs kill someone certainly she played a different role in the conspiracy that's charged she was a straw purchaser well mr bridges was a facilitator who had access to a serious amount of guns missy's matthews is charged with purchasing an a quantity of guns and then turning them over to others in the conspiracy so certainly the nature and the circumstances of her offense are different than mr bridges she has no record she has true but she has no arrest record i i'm sorry i don't have the exact same sashing the same record it's the same record i mean it's or it's a different record because if we we offered evidence of missy's matthews's involvement and her involvement in  the court has recognized that it's a dangerous gang that participates in an x revenge against rivals by violence so coupled with his access to guns and the plot to kill rivals and she is not a member of  knowledge you know your your knowledge might get refined as the case of but i do not understand the proposition that there is no condition of release that can secure confinement or detention would permit them to talk to other we've course that we've let we've let the organized crime families out on  your office let god be with the judge in the eastern district let john gotti out on bail in a case you're bringing certainly this man is not as dangerous as you know  bilk all i can say judges of the review of judge ross as judge ross is entitled to find the factors that she found she was appropriate and it was not clear or error for her to find as she did that the combination of the conditions in this a dangerous street gang that perpetrate significant violence i imagine that there are members that do not commit acts of violence here in there are members that claim to be bloods members when they are not in fact bloods members for purposes of he is not thank you thank you we will reserve decision