177, 188 (Winter 2008) (“[T]here is not one consistent legitimate special circumstance that warrants release on bail.”). Multiple factors have led to this convoluted “special circumstances” standard. See Kelly, Bail in International Extraditions, supra, at 36-37. First, as discussed above, there is no clear authority on the issue of bail in international extradition proceedings. Second, it is not uncommon for defense attorneys to present a myriad of special circumstances in support of their client’s bail application. See, e.g., Nina Marino & Nicole Eiland, Defending International Extradition, 22 Crim. Just. 4, 7 (Winter 2008) (suggesting that the “best way to secure release pending the extradition proceedings is to throw in the proverbial kitchen sink”); Ramnath, 533 F.Supp.2d at 671 (<HOLDING>). This tactic results in courts considering,
holding failure to file statement of points is no bar to appeal holding statement of points in notice of appeal sufficient holding courts do not consider points not raised in briefs recognizing that respondents counsel strains too hard with specious arguments and summarily rejecting these patently gilded points holding that assessment of victim injury points was improper because the information did not allege the factual basis for the victim injury points