1. Whether the Bail Reform Act of 1984 ("BRA ") is facially unconstitutional, and/or unconstitutional as-applied to Petitioner in this case based (individually or collectively) on the BRA 's: (a) lack of a maximum duration on pretrial detention which results in arbitrariness and inconsistencies as to pretrial release in federal courts throughout the country, (b) lack of any requirements relative to a minimum standard of conditions and amenities to prevent pretrial detainees from being subject to conditions worse than sentenced federal prisoners and thus amounting to pre-conviction punishment, and (c) lack of an unqualified right of periodic review of whether continued detention is appropriate?

Whether the Bail Reform Act of 1984 is facially unconstitutional due to its lack of maximum detention duration, minimum conditions standards, and periodic review rights