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Case 1:19-cr-00490-RMB Document 36 Filed 07/24/19 Page 11 of 74 11 1 provided no specific detailed financial information in its 2 submission. I'll get into that in a little bit more ina 3 moment. 4 But certainly the first question for a defendant of 5 this tremendous means is how much money does he have, where is 6 it, what are the accounts, is it in foreign accounts, how much 7 is in diamonds or art. These are all details that would be 8 necessary for the Court to even begin to consider this type of 9 application. 10 So, no. The presumption has not been rebutted. 11 However, your Honor, even if the defense w able at some 12 point to rebut the presumption by providing some more 13 information, there simply is no way that they can meet the 14 standard here. 15 The evaluation of the Bail Reform Act suggests that 16 all of those factors counsel in favor of remand, which we'll go 17 into in a little more detail. 18 THE COURT: It is accurate to say that you as the 19 government has the burden of persuasion or proof in this 20 instance. Right? 21 MR. ROSSMILLER: Yes, your Honor. There are good 22 reasons why sex trafficking has a presumption of detention and 23 even more so where a defendant, as this defendant has, has 24 previously been convicted of a sex offense. 25 And in connection with that, his dangerousness is SOUTH BRN DISTR CT REPORT ERS, (212) 805-0300 DOJ-OGR-00000521