Importantly, while the existence of a removal order is a factor in deciding flight risk, “it alone does not constitute clear and convincing evidence that Singh presented a flight risk justifying denial of bond.” Singh, No. 10-15715, slip. op at 14.Instead, courts should use the factors announced by the BIA in Matter of Guerra, 24 I&N Dec. 37, 40 (BIA 2006). In Matter of Guerra, the Board identified nine relevant factors:“(1) whether the alien has a fixed address in the United States; (2) the alien’s length of residence in the United States; (3) the alien’s family ties in the United States, and whether they may entitled the alien to reside permanently in the United States in the future; (4) the alien’s employment history; (5) the alien’s record of appearance in court; (6) the alien’s criminal record, including the extensiveness of criminal activity, the recency of such activity, and the seriousness of the offenses; (7) the alien’s history of immigration violations; (8) any attempts by the alien to flee prosecution or otherwise escape from authorities; and (9) the alien’s manner of entry into the United States.”