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substantial enough to get the message through to them that what they did was wrong, they just might do it again. And that I think is something that is important for the Court to take into consideration.
As to the request for surrender and delayed incarceration and bail pending appeal, and the claim of a medical condition. Obviously the medical condition mentioned is not so substantial that it can't be handled within the Federal prison system.
it is the position of the United States that the defendants should not be granted bail pending appeal. As the Court is well aware, I am sure, they have the burden at this stage in the proceeding of establishing that there is a substantial question of law or fact which is likely to result in a reversal or new trial.
I don't think we have seen that, Judge. In the pretrial or the post-trial pleadings there just hasn't been a substantial question raised. Mr. Anderson touched on it very briefly. I don't know if the Court wants me to catalogue each of the different issues that have been raised and discussed why I believe they are not substantial. Suffice it to say that I think that in virtually every instance there is controlling law in this Circuit which, or from the Supreme Court, which clearly answers the claims which the defendants are making.

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