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Case 1:19-cr-00490-RMB Document11-1 Filed 07/12/19 Page 10 of 10 Honorable Henry Pitman United States Magistrate Judge July 8, 2019 Page 10 CONCLUSION As set forth above, in this case, the risk of flight in this case is extraordinarily real. The defendant is extremely wealthy, has extensive foreign contacts, and is charged with serious offenses that carry a potential statutory sentence of up to 45 years’ imprisonment—even a fraction of which could result in the defendant, who is 66 years old, spending the rest of his life in jail. In sum, the defendant’s transient lifestyle, his lack of family or community ties, his extensive international travel and ties outside the country, and his vast wealth, including his access to and ownership of private planes, all provide the defendant with the motive and means to become a successful fugitive. Further, the nature of the offenses he is alleged to have perpetrated—the abuse dozens of underage, vulnerable girls—along with his demonstrated willingness to harass, intimidate and otherwise tamper with victims and other potential witnesses against him, render his dangerousness readily apparent. Accordingly, the Government respectfully submits that the defendant cannot and will not be able to meet his burden of overcoming the strong presumption in favor of detention, that there are no conditions of bail that would assure the defendant’s presence in court proceedings in this case or protect the safety of the community, and that any application for bail should be denied. Very truly yours, GEOFRREY S. BERMAN United/States Attorney By: Alex Rossmiller / Alison Moe / Maurene Comey Assistant United States Attorney Southern District of New York Tel: (212) 637-2415 / 2225 / 2324 Cc: Martin Weinberg, Esq., and Reid Weingarten, Esq., counsel for defendant Hon. Richard M. Berman, United States District Judge DOJ-OGR-00000352