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be N Ww ws Oo OY ~] oO Ke) Ww a OY 20 21 22 23 24 25 Case 1:19-cr-00490-RMB j782epsC kjc Document 20 Filed 07/16/19 Page 7 of 24 7 The government notes as an initial matter that this is a presumptio moreover, ea n case becaus sex traf ch of the Four Factors detention analysis strongly militates towards pretrial detention. Ficking is charged; and, to be considered in the So starting with the nature and seriousness of the e) Ffense, as previously discussed, the na of the crime are the most serious crime The defendant is all minors in multiple The seriousness ot potential pe incarceration on Counts One and Two, substantial nalties, period o which include up to 45 combined years of F the charge is also ret that the government's individual 1 dentifie d victims specified overt acts In Honor, I'm not going to go in victims, but has been det order to protect we can say that i ailed, it has b , and dozens of overall evidence is strong. in the indictment, Flected in ture and circumstances that this court sees. leged to have spent years sexually abusing locations and with dozens of victims. the and the likelihood of a f incarceration is supported by the fact There are multiple numerous victims alleged. the privacy of n credibl F the victims, your to detail about particular nformation provided by victims , and it has been corroborated by other witnesses and contemporaneous documents includi and records, Manhattan mansion, a Separately, ng Ss your Honor, [ will discuss from a recent search of the det SOUTH ERN D STR CT REPORT ERS, (212) 805-0300 fFendant's further in a moment. in just the last 36 hours, DOJ-OGR-00000412