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Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 5 of 14
Honorable Richard M. Berman
United States District Judge
July 12, 2019
Page 5

Indeed, while the defendant has still not filled out a financial affidavit, under penalty of perjury, in connection with his application for bail, his token effort to account for his finances makes painfully clear the need for detention. The defendant reports having an extraordinary amount of money in both total assets and cash or cash-equivalent holdings. And while the defendant repeatedly represents in his Release Motion that his assets are “in the United States,” there is absolutely nothing in the defendant’s minimal financial submission to verify that.

Indeed, and as discussed further below, even assuming the defendant’s assets are presently in the United States, nothing in the proposed package would prevent the defendant from transferring liquid assets out of the country quickly and in anticipation of flight or relocation. The defendant is an incredibly sophisticated financial actor with decades of experience in the industry and significant ties to financial institutions and actors around the world. He could easily transfer funds and holdings on a moment’s to places where the Government would never find them so as to ensure he could live comfortably while a fugitive.

But perhaps most important, even were the defendant to sacrifice literally all of his current assets, there is every indication that he would immediately be able to resume making millions or tens of millions of dollars per year outside of the United States. He already earns at least $10,000,000 per year, according to records from Institution-1, while living in the U.S. Virgin Islands, traveling extensively abroad, and residing in part in Paris, France; there would be little to stop the defendant from fleeing, transferring his unknown assets abroad, and then continuing to do whatever it is he does to earn his vast wealth from a computer terminal beyond the reach of extradition.4

That the defendant faces up to 45 years of incarceration on the current counts with which he is charged provides the motive for him do so and is another significant factor in assessing the risk of flight. See United States v. Jackson, 823 F.2d 4, 7 (2d Cir. 1987). So too is the strength of the evidence, detailed above and in the Government’s Detention Memo. Indeed, that evidence, already robust less than a week ago when the Indictment was unsealed, is growing stronger by the day. Just since the Indictment was unsealed, several additional women, in multiple jurisdictions, have identified themselves to the Government as having been victimized by the defendant when they were minors. Moreover, pursuant to judicially-authorized search warrants, the Government has discovered and seized a significant volume of photographs of nude and seminude young women and girls in the defendant’s Manhattan residence, and is in the process of reviewing dozens of electronic discs that contain still more such photos.5 And dozens of individuals have called the Government in recent days to convey information regarding the defendant and the allegations

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4 As noted in the Government’s Detention Memo, the defendant is a frequent traveler and regularly travels to and from the United States, including approximately more than 20 flights in which he traveled to or from a foreign country since 2018 alone. Extensive international travel of this nature further demonstrates a significant risk of flight. See, e.g., United States v. Anderson, 384 F. Supp. 2d 32, 36 (D.D.C. 2005).

5 The Government’s review of these materials, seized earlier this week, remains ongoing.

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