Court Filing: 1:21-cr-02949-MV-DHH Document 30802 Filed 02/06/21 Page 11 of 36

The document argues that Mr. Robertson's pretrial release is necessary for the preparation of his trial defense under 18 U.S.C. § 3142(i) due to the complexity of the case and the limited time available before the trial reset for April 5, 2021. The court considers factors such as time, complexity, and inconvenience in determining whether to grant temporary release. The defendant's release is also argued to be required under 18 U.S.C. § 3142(e).