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also paying certain victims to recruit other girls to be
subject to the defendant's sexual abuse.
The indictment alleges that the defendant undertook
4 this conduct at at least two locations, including his mansion
5 in Manhattan and his estate in Palm Beach, Florida. In both
6 locations, victims were initially recruited to provide massages
7 to the defendant, which would be performed nude or partially
8 nude, would become increasingly sexual in nature, and would
9 typically include one or more sex acts, including contact with
10 the victims' genitals. These victims, who were often
11 particularly vulnerable, were as young as 14, and the defendant
12 knew he was abusing underage girls. The indictment further
13 alleges that the defendant perpetrated these crimes by working
14 with others, including employees and associates who facilitated
15 these abusive encounters.
16 Regarding the defendant himself, your Honor, he is
17 extraordinarily wealthy, mobile, and unattached to the Southern
18 District of New York. He maintains at least six residences in
19 the United States and abroad, including the ownership of a
20 private island in the U.S. Virgin Islands and a residence in
21 Paris, France. Among other things, the defendant owns two
22 private jets and routinely uses them to travel abroad. He is a
23 man of nearly infinite means, your Honor; and, as set forth in
24 our submission, he has tremendous incentives to use those means
25 to flee prosecution.
SOUTHERN P.C.
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