DOJ-OGR-00000414.jpg

be N Ww ws Oo OY ~] oO Ke) Ww a OY 20 21 22 23 24 25 Case 1:19-cr-00490-RMB 3782epscC about his kjc The defendant has refused income or assets Document 20 for the Filed 07/16/19 Pretrial Page 9 of 24 9 to answer any questions Services report, so the scope of his wealth and his assets remains entirely concealed to the government and to the court. But the defendant certainly has access to endless means to flee, including two private jets. He has no meaningful family ties, and any argument that h United States is properties ignores h favor of is ability to properties behind in authorities to live of wealth, accounting of. in France, and all of! moving F his extensiv would keep him in the simply leave those beyond the reach of U.S. wealth abroad, extensive I should add, risk of a presumption the sexual abuse of With Flight. case, respect minors, that the court He travels abroad ex doesn't even have any tensively, has a residence those factors Further contribute to the to danger and obstruction, again, this is and not only is the defendant charged with he has previously pled guilty to solicitation of an underage girl. This court knows that defendants are routinely detained in this district when facing such charges and that this is not an unusual position for the government to take. It is further concerning that there are credibl allegations his agents fact ther ngaged in witness tampering and harassment, from the prior investigation that the defendant or and in is evidence that he was contemplating pleading SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00000414