DOJ-OGR-00000330.jpg
1.14 MB
Extraction Summary
5
People
5
Organizations
5
Locations
3
Events
2
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
1.14 MB
Summary
This legal document is a filing arguing against granting bail to a defendant accused of a years-long scheme of sexually abusing dozens of underage girls. The prosecution contends that the defendant's proposed bail package is inadequate, he is a flight risk due to his wealth and private jet, and he poses a danger to the community. The document details the allegations, including that the defendant paid victims and victim-recruiters in cash in locations like New York and Palm Beach, and urges the Court to order him detained pending trial.
People (5)
| Name | Role | Context |
|---|---|---|
| Richard M. Berman | United States District Judge |
The document is addressed to Honorable Richard M. Berman.
|
| The defendant | Defendant |
The central figure of the document, accused of sexual abuse and seeking bail.
|
| victims | Victim |
Described as victims of the defendant's sexual abuse, including underage girls.
|
| co-signers | Co-signer |
Two individuals proposed by the defendant for his bail package, noted as highlighting his minimal community ties.
|
| victim-recruiters | Recruiter |
Victims who were paid by the defendant to recruit additional girls to be sexually abused.
|
Organizations (5)
| Name | Type | Context |
|---|---|---|
| United States District Judge | government agency |
The title of the recipient of the document, indicating the court system.
|
| The Court | government agency |
Referred to throughout the document as the body that should reject the defendant's bail application.
|
| Government | government agency |
Mentioned as having identified a property for forfeiture.
|
| Pretrial Services | government agency |
An agency that has recommended the defendant's detention.
|
| federal grand jury | legal body |
The body that returned an indictment charging the defendant.
|
Timeline (3 events)
2019-07-12
A document was filed with the court arguing against the defendant's bail application.
United States District Court
The defendant's legal team
The prosecution
A years-long scheme to sexually abuse underage girls, involving recruitment, payment, and exploitation.
New York and Palm Beach
A federal grand jury returned an indictment charging the defendant with violating Title 18, United States Code Section 1519, and conspiracy.
the District
Locations (5)
| Location | Context |
|---|---|
|
Mentioned in the context of the defendant being located and returned to the country if he flees.
|
|
|
The judicial district where the case is being heard and where the defendant is noted to lack family ties.
|
|
|
Proposed as the appropriate place to house the defendant.
|
|
|
One of the locations where the defendant exploited underage victims.
|
|
|
One of the locations where the defendant exploited underage victims.
|
Relationships (2)
The document describes a 'years-long scheme to sexually abuse underage girls' where the defendant paid victims for sex acts.
The defendant 'actively encouraged certain victims to recruit additional girls' and 'paid these victim-recruiters hundreds of dollars for each additional girl they brought to him'.
Key Quotes (3)
"deregister or otherwise ground"Source
— The defendant
(A promise made by the defendant regarding his private jet as part of his bail proposal, which the document calls meaningless.)
DOJ-OGR-00000330.jpg
Quote #1
"Indictment"Source
— federal grand jury
(The name of the legal document charging the defendant with federal crimes.)
DOJ-OGR-00000330.jpg
Quote #2
"massages"Source
— The defendant
(The pretext used to initially recruit victims, which would then become sexual in nature.)
DOJ-OGR-00000330.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (3,728 characters)
Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 2 of 14
Honorable Richard M. Berman
United States District Judge
July 12, 2019
Page 2
United States District Judge
July 12, 2019
Page 2
law, seeks to diminish and demean the harm caused to the many victims of the defendant’s
appalling sexual abuse, and utterly fails to meet its burden of rebutting the presumption that no
condition or combination of conditions will reasonably assure the appearance of the defendant as
required and the safety of the community. Rather than even attempting to address the grave risks
of releasing a defendant with extraordinary financial resources and a history of abusing minors,
the defendant instead proposes a bail package that amounts to little more than a barely-secured
bond masquerading as a 14-point plan. The Court should reject the defendant’s application and
order him detained pending trial.
appalling sexual abuse, and utterly fails to meet its burden of rebutting the presumption that no
condition or combination of conditions will reasonably assure the appearance of the defendant as
required and the safety of the community. Rather than even attempting to address the grave risks
of releasing a defendant with extraordinary financial resources and a history of abusing minors,
the defendant instead proposes a bail package that amounts to little more than a barely-secured
bond masquerading as a 14-point plan. The Court should reject the defendant’s application and
order him detained pending trial.
Among other things, the proposed bail package contemplates the defendant pledging as the
principal security a property that has already been identified by the Government as subject to
forfeiture upon the defendant’s conviction, and which therefore is of no value as collateral. His
proposed global waiver of extradition is unenforceable, and even if enforceable would be little
comfort to victims forced to wait additional years while the defendant is located and returned to
this country. The promise to “deregister or otherwise ground” his private jet is meaningless given
his wealth and ability to easily secure other means of travel. The two co-signers he proposes only
further highlight his minimal community ties, including his lack of any family in or near the
District. Electronic monitoring would merely give the defendant less of a head start in fleeing—
and does not guard against the risk of him endangering victims in the very home where he has
continued to hoard nude images of young women and girls. And the private security force he
proposes to guard his gilded cage, a proposal already rejected by this Court in similar
circumstances, simply reinforces the obvious fact that the defendant should be housed where he
can be secured at all times: a federal correctional center.
principal security a property that has already been identified by the Government as subject to
forfeiture upon the defendant’s conviction, and which therefore is of no value as collateral. His
proposed global waiver of extradition is unenforceable, and even if enforceable would be little
comfort to victims forced to wait additional years while the defendant is located and returned to
this country. The promise to “deregister or otherwise ground” his private jet is meaningless given
his wealth and ability to easily secure other means of travel. The two co-signers he proposes only
further highlight his minimal community ties, including his lack of any family in or near the
District. Electronic monitoring would merely give the defendant less of a head start in fleeing—
and does not guard against the risk of him endangering victims in the very home where he has
continued to hoard nude images of young women and girls. And the private security force he
proposes to guard his gilded cage, a proposal already rejected by this Court in similar
circumstances, simply reinforces the obvious fact that the defendant should be housed where he
can be secured at all times: a federal correctional center.
The defendant faces a presumption of detention, Pretrial Services has recommended
detention, and victims of the defendant seek his detention. Because there are no set of conditions
short of incarceration that can reasonably assure the appearance of the defendant or reasonably
protect the community from the dangers he poses if released, the Court should order him detained.
detention, and victims of the defendant seek his detention. Because there are no set of conditions
short of incarceration that can reasonably assure the appearance of the defendant or reasonably
protect the community from the dangers he poses if released, the Court should order him detained.
BACKGROUND
As previously set forth, a federal grand jury in this District returned an indictment (the
“Indictment”) charging the defendant with violating Title 18, United States Code Section 1519,
and conspiracy to commit the same.
“Indictment”) charging the defendant with violating Title 18, United States Code Section 1519,
and conspiracy to commit the same.
As charged by the grand jury, the facts giving rise to those counts involve a years-long
scheme to sexually abuse underage girls. Specifically, the defendant enticed and recruited dozens
of minor girls to engage in sex acts with him, for which he paid the victims hundreds of dollars in
cash, in at least two different states. Victims were initially recruited to provide “massages” to the
defendant, which would be performed nude or partially nude, would become increasingly sexual
in nature, and would typically include one or more sex acts, including groping and direct or indirect
contact with victims’ genitals. To perpetuate this exploitation of underage girls, the defendant
actively encouraged certain victims to recruit additional girls to be similarly sexually abused. He
paid these victim-recruiters hundreds of dollars for each additional girl they brought to him,
creating a network of underage victims for him to exploit in New York and Palm Beach.
scheme to sexually abuse underage girls. Specifically, the defendant enticed and recruited dozens
of minor girls to engage in sex acts with him, for which he paid the victims hundreds of dollars in
cash, in at least two different states. Victims were initially recruited to provide “massages” to the
defendant, which would be performed nude or partially nude, would become increasingly sexual
in nature, and would typically include one or more sex acts, including groping and direct or indirect
contact with victims’ genitals. To perpetuate this exploitation of underage girls, the defendant
actively encouraged certain victims to recruit additional girls to be similarly sexually abused. He
paid these victim-recruiters hundreds of dollars for each additional girl they brought to him,
creating a network of underage victims for him to exploit in New York and Palm Beach.
DOJ-OGR-00000330
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