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be NO Ww ws Oo OY ~] oO Ke} a oO he be No (ee) = Hs Oo _ OY a ~] a oO a Ke} 20 21 22 23 24 25 Case 1:19-cr-00490-RMB j782epsC kjc also paying certain vic Document 20 Filed 07/16/19 subject to the defendant's sexual abuse. The indictment alleges that the det this conduct at at least in Manhattan and his estate in locations, to the defendant, nude, the victims' genitals. two locations, Palm incl Page 6 of 24 6 tims to recruit other girls to be Fendant undertook uding his mansion Beach, Florida. victims were initially recruited particularly vulnerable, wer knew he was abusing underage girls. alleges that the def with others, which would be pert typically include one or more sex acts, These victims, The indictment would become increasingly sexual in nature, In both to provide massages Formed nude or partially and would including contact with who were often as young as 14, fendant perpetrated thes and the defendant further crimes by working these abusive encounters. Regarding the det extraordinarily wealthy, District o private island Paris, France. private jets and rout man of £ New York. the United States and abroad, mobile, in the U.S. Virgin Among other things, Fini te means, our submission, to nearly in he has tremendous incentives to use flee prosecution. fFendant himself, the det your Honor; including employees and associates who tinely uses them to travel abroad. your Honor, and, facilitated he is and unattached to the Southern He maintains at least six residences in including the ownership of a Islands and a residence in Fendant owns two He is a as set forth in those means SOUTHERN D STR CT RE PORT ERS, (212) 805-0300 DOJ-OGR-00000411