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Case 1:19-cr-00490-RMB Document 36 Filed 07/24/19 Page 14 of 74 1a we our And that additional was already indicted by a grand £ dozens of alleged Ficant corroborated for which this prison. lements of the crimes They acknowledged in their submission that be able to show that the defendant under this evidence and the what does flee, ld meaningfully flight. fendant's one-page for what it does as the Court 1 Your Honor, with a case that's no longer covert, 2 have been able to dramatically expand the scope of 3 investigation in just the last week. 4 vidence builds on a case that 5 jury, that already included evidence o 6 victims, that already included signit 7 vidence, evidence that led to the charges 8 66-year-old defendant could serve up to 45 years in 9 The defendant has essentially conceded that the 10 government will be able to prove th 11 currently alleged. 12 the government likely will 13 engaged in sex acts for money with girls he knew wer 14 age. 15 Now, in the face of all of 16 extraordinary incentives for the defendant to 17 the defendant propose? Nothing that woul 18 mitigate the risks of danger and especially 19 THE COURT: Are you talking about the bail package 20 now? 21 MR. ROSSMILLER: Yes, your Honor. 22 So in the first instance, the d 23 financial disclosure form is more significant 24 not include than what it does. It is cursory, 25 said, at best. SOUTH BRN DISTR CT RE (212) 805-0300 PORTERS, P.C. DOJ-OGR-00000524