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Case 1:19-cr-00490-RMB Document36- Filed 07/24/19 Page 19 of 74 ie 1 defendant. 2 THE COURT: Could you go back to those Florida police 3 reports and tell us what you think they demonstrate. 4 MR. ROSSMILLER: Yes, your Honor. 5 They certainly suggest that there were individuals who 6 believed that they were being harassed and interfered with by 7 the defendant or his agents. That was investigators or other 8 individuals working on behalf of or at the behest of the Q defendant. 10 Now, those aren't charges proven in court. Those 11 aren't convictions. But they certainly are factual occurrences 12 that people reported contemporaneously and that are significant 13 and concerning. 14 With respect to just a couple of the Court's 15 guestions, bouncing around just slightly, with respect to the 16 financial information which, again, is limited at best, the 17 government took no position on the defendant's sealing 18 application for, among other reasons, the fact that we did not 19 know what they were going to submit. We imagined that it would 20 be more detailed. 21 Secondly, the government obviously had just hours to 22 respond to the defendant's at that point. So we took no 23 position and of course defer to the Court as to whether ther 24 is a valid reason to seal such limited and summary information. 25 We will confer, your Honor, on whether we're able to SOUTHERN DISTR CT RE PORT (212) BRS, P.C. 805-0300 DOJ-OGR-00000529