DOJ-OGR-00000576.pdf

Case 1:19-cr-00490-RMB Document 36 Filed 07/24/19 Page 66 of 74 66 1 That's not consistent with the explanation that he had 2 no idea that there was a federal case that would be brought 3 when he made the payments to his old associates. 4 The fact is, your Honor, the defendant thought he'd 5 gotten away with it. And the government really put its money 6 where its mouth is on this issue of notice and of the covert 7 nature of the investigation. 8 This investigation was going on for months, and the 9 government took extraordinary efforts not to have the defendant 10 find out about it, and he didn't. And neither did anyone else 11 until the case was unsealed. 12 Any number of people in this court who would have 13 loved to have reported the fact of this investigation, and it 14 didn't get out because the government was concerned that the 15 defendant would flee as we continue to be now. 16 Your Honor, this is the Southern District. The 17 defendant is indicted. He is in a grave position, and he has 18 every motive and every means to flee if he's released. 19 THE COURT: I have one question of you. 20 In your submission -- I think it was in your most 21 recent submission -- you mentioned that you had been contacted 22 by victims or their counsel probably or perhaps and that they 23 were of the view that there should not be any bail, any 24 release. 25 Are you aware if any of them wish to be heard? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00000576