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Case 1:19-cr-00490-RMB Document36 _ Filed 07/24/19 Page 13 of 74 1 1 obtained records from a financial institution that has been 2 associated with the defendant confirming that the defendant 3 represented his net worth as more than $500 million. 4 Your Honor, just as one example, the defendant had a single 5 account at that financial institution totaling more than $110 6 million. 7 There can be no dispute whatsoever that this defendant 8 has vast assets and every incentive in the world to use those 9 assets to flee from justice. 10 Your Honor, the government seeking detention in this 11 case is not unusual. Defendants are routinely detained in this 12 district when facing such charges, and this defendant should be 13 treated no differently. The fact that he has considerable 14 resources to flee prosecution only makes the case for his 15 detention stronger. 16 On that note, with respect to the strength of the 17 evidence, again, last Monday, the government described its 18 evidence as "strong." Just a week later, after seven days of 19 this case being public following months of a covert 20 investigation, the evidence is already significantly stronger 21 and getting stronger every single day. 22 Many individuals identifying themselves as victims and 23 witnesses have contacted the government, and we are in the 24 process of receiving and corroborating this additional 25 evidence. SOUTHERN DISTRICT REPOR (212) 805-0300 TERS, P. DOJ-OGR-00000523