mirror-epstein-docs/results/IMAGES001/DOJ-OGR-00000521.json

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    "document_number": "36",
    "date": "07/24/19",
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  "full_text": "Case 1:19-cr-00490-RMB Document 36 Filed 07/24/19 Page 11 of 74\n1 provided no specific detailed financial information in its submission. I'll get into that in a little bit more in a moment.\n2\n3 But certainly the first question for a defendant of this tremendous means is how much money does he have, where is it, what are the accounts, is it in foreign accounts, how much is in diamonds or art. These are all details that would be necessary for the Court to even begin to consider this type of application.\n4\n5 So, no. The presumption has not been rebutted.\n6 However, your Honor, even if the defense were able at some point to rebut the presumption by providing some more information, there simply is no way that they can meet the standard here.\n7\n8 The evaluation of the Bail Reform Act suggests that all of those factors counsel in favor of remand, which we'll go into in a little more detail.\n9\n10 THE COURT: It is accurate to say that you as the government has the burden of persuasion or proof in this instance. Right?\n11\n12 MR. ROSSMILLER: Yes, your Honor. There are good reasons why sex trafficking has a presumption of detention and even more so where a defendant, as this defendant has, has previously been convicted of a sex offense.\n13\n14 And in connection with that, his dangerousness is\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "content": "1 provided no specific detailed financial information in its submission. I'll get into that in a little bit more in a moment.\n2\n3 But certainly the first question for a defendant of this tremendous means is how much money does he have, where is it, what are the accounts, is it in foreign accounts, how much is in diamonds or art. These are all details that would be necessary for the Court to even begin to consider this type of application.\n4\n5 So, no. The presumption has not been rebutted.\n6 However, your Honor, even if the defense were able at some point to rebut the presumption by providing some more information, there simply is no way that they can meet the standard here.\n7\n8 The evaluation of the Bail Reform Act suggests that all of those factors counsel in favor of remand, which we'll go into in a little more detail.\n9\n10 THE COURT: It is accurate to say that you as the government has the burden of persuasion or proof in this instance. Right?\n11\n12 MR. ROSSMILLER: Yes, your Honor. There are good reasons why sex trafficking has a presumption of detention and even more so where a defendant, as this defendant has, has previously been convicted of a sex offense.\n13\n14 And in connection with that, his dangerousness is",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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    "dates": [
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      "1:19-cr-00490-RMB",
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