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Case 1:19-cr-00490-RMB Document 23 Filed 07/16/19 Page 3of3 Hon. Richard M. Berman United States District Judge July 16, 2019 Page 3 IV. Cash and Diamonds At the Detention Hearing, the Government informed the Court that diamonds and cash were seized from a safe in the defendant’s Manhattan residence. The Court inquired as to the value of these items. After conferring with law enforcement agents who have reviewed the materials from the safe, the Government has learned that the safe contained more than $70,000 in cash. In addition, the safe contained 48 loose diamond stones, ranging in size from approximately 1 carat to 2.38 carats, as well as a large diamond ring. The Government is currently unaware of whether the defendant maintains similar stashes of cash and/or jewels at his multiple properties, or in other locations. Such ready cash and loose diamonds are consistent with the capability to leave the jurisdiction at a moment’s notice. V. Conclusion For the reasons set forth herein, in the Government’s July 8, 2019 and July 12, 2019 detention memoranda, and on the record at the Detention Hearing, the Court should order that the defendant be detained pending trial. The defendant cannot meet his burden of overcoming the presumption that there is no combination of conditions that would reasonably assure his continued appearance in this case or protect the safety of the community were he to be released. Respectfully submitted, GEOFFREY S. BERMAN United States Attorney By: ___/s Alison Moe / Alex Rossmiller / Maurene Comey Assistant United States Attorneys Southern District of New York Tel: (212) 637-2225 / 2415 / 2324 Cc: Martin Weinberg, Esq., and Reid Weingarten, Esq., counsel for defendant DOJ-OGR-00000442