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Case 1:19-cr-00490-RMB Document36 _ Filed 07/24/19 Page 12 of 74 12 1 clear from his willingness to tamper with witnesses and victims 2 as the Court can see from the two police reports produced to 3 the Court and from the defendant's payments just months ago to 4 individuals associated with the defendant during the relevant 5 time. The Court asked a question about that 6 Your Honor, we just became aware of those payments 7 late last week. We, frankly, don't have additional information 8 other than that they were paid, that they were paid to two 9 individuals who were associated with the defendant at the time, 10 and that those two individuals are both listed in the 11 non-prosecution agreement. 12 So there is certainly an inference there that the 13 defendant was attempting to influence them right around when he 14 came back into public consciousness. 15 Your Honor, the victims in this case seek detention 16 and fear his release. And most of all, he is an extraordinary 17 flight risk. As the government has discussed, he has six 18 homes. He owns two private islands. He owns a residence in 19 France. And he has told his own financial institution that he 20 is worth more than $500 million. 21 In the government's filing last Monday, we described 22 the defendant as being extraordinarily wealthy which was 23 confirmed by the defens ven in his very minimal financial 24 disclosure. 25 Since the government's initial filing, we have SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00000522