DOJ-OGR-00000530.jpg

Case 1:19-cr-00490-RMB Document 36 Filed 07/24/19 Page 20 of 74 20 1 provide a sample of the search warrant materials. Those 2 materials remain under review. They are, generally speaking, 3 many, many, many photographs of nude and partially nude women 4 and girls who appear to be young. 5 The government has identified at least one individual 6 in those photos who has self-identified as a victim of the 7 defendant. And, frankly, it is a lot of material that we are 8 continuing to work through. 9 With respect to the sex offender registration of the 10 defendant in other states, your Honor, following up on the 11 Court's question last week, we did confer with New York state 12 authorities. 13 There is no particular result from this case in terms 14 of his registration in New York. He remains registered, but 15 there is no specific consequence as to him being charged or 16 arrested in this case and no change of his status. He is 17 already, of course, at the highest status of risk for 18 re-offense. 19 Just very briefly, your Honor, with respect to some of 20 the other arguments that defense counsel made -—- 21 THE COURT: Are you familiar with whether or not there 22 are other proceedings in other jurisdictions of a similar 28 nature to Judge Pickholz's decision? 24 MR. ROSSMILLER: We are not aware of any similar 25 proceedings. That's not to say that there aren't any, but the SOUTH ERN D STR CT R EH PORT ERS, P. (212) 805-0300 DOJ-OGR-00000530