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Case 1:19-cr-00490-RMB Document11i_ Filed 07/12/19 Page 6 of 14 Honorable Richard M. Berman United States District Judge July 12, 2019 Page 6 contained in the Indictment. All this in less than a week, and all in addition to an Indictment that already alleges the existence of dozens of victims in New York and dozens of victims in Florida. B. The Proposed Bond is Inadequate to Overcome the Presumption of Detention The defendant’s “slate of highly restrictive” measures which purportedly “amply suffice to secure his release” are neither highly restrictive nor amply sufficient. Rather, they are effectively standard conditions of home confinement, monitoring, and bond unsecured by the defendant’s assets—broken out into 14 pieces. The Government will address the most concerning and salient elements of the defendant’s proposal below. 1. Lack of Meaningful Bond Security The defendant proposes that the Court accept his Manhattan mansion as the primary security for a personal recognizance bond of an indeterminate amount, to be co-signed by the defendant’s brother and a friend. Release Motion at 4. This is plainly insufficient. As an initial matter, and as noted above, the defendant’s Manhattan mansion has been identified in the Indictment as subject to forfeiture because it is alleged to have been used to commit or facilitate the commission of the sex trafficking offenses charged there. See 18 U.S.C. § 1594(c)(1). Because the defendant would thus be likely to lose that property following a conviction, it provides no value whatsoever as collateral. See 18 U.S.C. § 3142(g)(4) (“In considering the conditions of release described . . . the judicial officer... shall decline to accept the designation, or the use as collateral, of property that, because of its source, will not reasonably assure the appearance of the person as required.”). And while the defendant offers to also pledge his private jet as additional collateral, there is absolutely no reason to assume that the defendant would not readily trade his private plane for his freedom. Indeed, the defendant, who has a net worth of more than $500 million, by his own admission recently sold a second plane and thus presumably has cash on hand to replace the posted aircraft without difficulty if need be. Nor does the proposed security of properties owned by two identified co-signers meaningfully change the calculus. As further described below, the defendant provides no information about the value or equity of the property of his brother, Mark (the “Palm Beach Property”), or the significance of that property in the context of his brother’s own net worth.°® Similarly, the defendant provides no details regarding the “investment interests” of his friend Mr. Mitchell, nor any reason to believe the loss of those “interests” would be meaningful to Mr. Mitchell, let alone the defendant. More generally, given the defendant’s proffered net worth, the defendant could easily make his co-signers whole — and even reward them — were he to flee. The proposed security, in sum, should give the Court little comfort the defendant would appear in Court if released on bail. Tn fact, the defendant’s own submission makes clear that the Palm Beach Property is not his brother’s exclusive residence and that his brother lives elsewhere for half of the year. DOJ-OGR- 00000334