Case 2:20-cr-00165-JJT Document 65 Filed 04/29/20 Page 1 of 12

1 MICHAEL BAILEY
United States Attorney
2 District of Arizona
3 ANDREW C. STONE
Assistant United States Attorney
4 Arizona State Bar No. 026543
JAMES R. KNAPP
5 Assistant U.S. Attorney
Arizona State Bar No. 021166
6 Two Renaissance Square
40 N. Central Ave., Suite 1800
7 Phoenix, Arizona 85004
Telephone: 602-514-7500
8 Email: andrew.stone@usdoj.gov
Email: james.knapp2@usdoj.gov
9 Attorneys for Plaintiff
10
IN THE UNITED STATES DISTRICT COURT
11
FOR THE DISTRICT OF ARIZONA
12
13 United States of America, No. CR-20-00165-001-PHX-JJT
14 Plaintiff,
RESPONSE TO DEFENDANT’S
15 vs. OBJECTION TO COURT ORDER
DENYING MOTION TO REOPEN
16 DETENTION HEARING
John Michael Caruso,
17
Defendant.
18
19
20 Defendant’s third attempt at pre-trial release should be denied. Defendant, through
21 his three separately retained law firms, filed an objection to the Court’s recent order by
22 recycling many of the same arguments that Magistrate Judge Burns twice correctly denied.
23 In addition to raising COIVD-19 concerns, which aren’t unique to Defendant, he has
24 shifted to an attack on the investigating case agent.
25 None of Defendant’s arguments change the analysis: Defendant has access to money
26 and an incentive to flee; for these reasons, Defendant is a flight risk and should remain
27 detained.
28
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1 MEMORANDUM OF POINTS AND AUTHORITIES

2 I. Procedural Background1
3 A. Court’s Most Recent Detention Order
4 On April 8, 2020, Magistrate Judge Burns denied Defendant’s emergency motion
5 to reopen his detention hearing. (Doc. 50.) The Court analyzed Defendant’s two new
6 grounds for release, which include: (1) the spread of COVID-19, and (2) Mr. Price’s
7 increase in bond payment from $140,000 to $300,000. The Court found that the increase
8 in secured bond did not “change this Court’s previous analysis and conclusion.” (Doc. 50
9 at 3.) This was due to Mr. Price’s relationship with Defendant and his father and because
10 the increased bond amount “is not sufficient to assure the safety of the community or
11 Defendant’s appearance given the numerous other factors cited by the Court in support of
12 detention.” (Id. at 3-4.)
13 The Court, while noting that COVID-19 presents a serious health risk, found that
14 Defendant only speculated as to his increased risk of contracting the virus while in pretrial
15 detention at CoreCivic. (Doc. 50 at 4.) Judge Burns noted CoreCivic’s procedure for
16 minimizing the risk and its detection and treatment capacity. (Id.) Finally, the Court
17 underscored that Defendant is 28 years old and has no reported underlying medical
18 conditions. (Id.)
19 The Court also noted that while some courts have found that the current pandemic
20 justified release of certain previously detained defendants, other courts rejected similar
21 requests, “thus supporting review on a case-by-case basis.” (Id.) Finally, the Court found
22 that Defendant did not establish how his trial preparation is hampered in any significant
23 way by COVID-19. (Id.)
24 B. Defendant’s Objection to Court’s Detention Order
25 In response to the Court denying Defendant’s motion, he filed the current objection.
26 (Doc. 53.) Defendant supports his objection with three main arguments:
27 1
The government incorporates the factual and procedural background from its
28 response to Defendant’s motion to reopen detention hearing (Doc. 49), and only
supplements with additional information.

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1 (1) The increase in bond from $140,000 to $300,000 is sufficient to assure the
2 safety of the community and Defendant’s appearance in future proceedings;
3 (2) The danger from the spread of COVID-19 warrants Defendant’s release; and
4 (3) The government presented false and misleading information the Court.
5 None of these arguments has merit.
6 II. Law and Argument2
7 The Court should deny Defendant’s request for release. For all the reasons stated
8 in the government’s previous motions (Docs. 14 & 49) and the Court’s orders (Docs. 27 &
9 50), Defendant’s arguments related to the increased bond amount and COVID-19 concerns
10 are insufficient to overcome the applicable factors set forth in 18 U.S.C. § 3142(g).
11 Defendant’s newest argument is an attempt to impugn the investigating case agent.
12 Defendant no doubt believes if he can call into question some of the case agent’s
13 statements, then he can make the broader argument that the Court can’t trust any statement
14 made by the government. This strategy fails.
15 A. Special Agent James Lamerson’s Declaration Was Accurate
16 Defendant raises issues with three of the five paragraphs in SA Lamerson’s
17 declaration. (Doc. 53 at 3-5, 11-13.) Defendant argues that paragraphs three through five
18 present “false and misleading information.” (Id. at 11.) This argument doesn’t withstand
19 scrutiny.
20 Defendant did not raise any issues with respect to the first two paragraphs of SA
21 Lamerson’s declaration. Paragraph two states that the “net loss to victims of the Zima
22 Digital Assets investment fraud scheme now appears to exceed $15 million.”3 (Doc. 49-1
23 at ¶ 2.) Further, SA Lamerson makes clear that the “investigation has revealed no evidence
24 that the alleged Zima Digital Assets cryptocurrency hedge fund exists.” (Id.) SA
25
2
26 The government does not rehash its legal arguments made in its response filed
April 6, 2020 (Doc. 47), but does incorporate those arguments by reference.
27 3
The loss amount has now increased to over $16 million based on victim interviews
28 and financial records.

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1 Lamerson provides a list of how Defendants transferred money, including $1 million to

2 purchase stock in a synthetic diamond company, a $500,000 cashier’s check to fabricate a
3 custom car, and $50,000 transferred to a law firm. (Id.) Finally, the declaration provides:
4 “Although the majority of investor funds have been traced, investigators continue to
5 identify assets for Caruso.” (Id.) Defendant raises no issues with any of these statements.
6 1. Defendant’s Criminal History
7 Defendant argues that the third paragraph in SA Lamerson’s declaration
8 “mischaracterizes Mr. Caruso’s criminal history.” (Doc. 53 at 12-13.) Defendant appears
9 to claim that the following statements are misleading: “Caruso was involved in an extortion
10 scheme with his father in which a victim was threatened with having his hands and penis
11 cut off if he did not pay $200,000. Caruso was convicted and served time in prison for his
12 role.” (Doc. 49-1 at ¶ 3; Doc. 53 at 12-13.) First, Defendant argues that because Caruso
13 Sr. was “never charged with any extortion scheme in Florida” it makes SA Lamerson’s
14 statement wrong, despite the fact that the police report confirms Caruso Sr.’s involvement.4
15 Further, Defendant argues that because his conviction was for “conspiracy to commit
16 extortion and threats” and the “underlying extortion count was dismissed,” SA Lamerson’s
17 statements are misleading. Defendant does not contest the conviction’s factual basis that
18 “a victim was threatened with having his hands and penis cut off.” Initially, Defendant did
19 not serve any prison time, but because he violated his probation—by committing further
20 felonies—ultimately, he “served time in prison for his role.” Defendant’s highly technical
21 argument for why this crime did not involve threatened violence and intimidation does not
22 make SA Lamerson’s statements misleading. Indeed, SA Lamerson’s declaration
23 accurately reflected Defendant’s crime.
24 Defendant next expresses a grievance at SA Lamerson’s statement about Defendant
25 being investigated by the Scottsdale Police Department for an alleged murder-for-hire
26 scheme. (Doc. 53 at 13.) Defendant believes SA Lamerson’s introductory words of “more
27 4
Defendant doesn’t contest that his father was involved. For good reason. The
28 police report makes clear that his father had a significant role in the extortion scheme. (See
redacted and excerpted Police Report, attached as Exhibit B.)

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1 recently” is “terribly misleading.” The Florida felony occurred in 2009 and the Scottsdale
2 investigation began in March 2011. (See Doc. 9 at 4; Doc. 53-1 at 14.) Defendant,
3 therefore, posits that this factual statement is “terribly misleading.” Defendant also
4 ascribes a malevolent motive to SA Lamerson for including this one sentence about a
5 previous criminal investigation of Defendant. Rather than “to inflame the senses of the
6 Court,” the government believed it relevant under 18 U.S.C. § 3142(g)(3).
7 2. Defendant’s and Caruso Sr.’s Contacts with Victims
8 Defendant believes SA Lamerson’s declaration “mischaracterizes” his, and his
9 father’s, contact with victims. (Doc. 53 at 11.) Again, Defendant doesn’t dispute that he
10 and his father have contacted victims. Indeed, he makes clear that the Court has issued no
11 order prohibiting such contact. (Id. at 12.) He also does not offer any statements from
12 himself or his father that contradict or refute any of the statements attributed to them in SA
13 Lamerson’s declaration. Rather, Defendant submits repetitive declarations from a handful
14 of investors out of the dozens who were victimized by Defendants. The main thrust of the
15 declarations is that these victims did not feel threatened, were not promised that they would
16 get their money back if they cooperated with Caruso, and all communications were nothing
17 but cordial and respectful. (Doc. 53 at 12.)
18 Defendant does not appear to take issue with the actual statements attributed by SA
19 Lamerson to either Caruso. Rather, he is upset by SA Lamerson’s characterization that
20 Caruso Sr. “made veiled threats.” This seems to be a difference in interpretation. The
21 statements made to the victims speak for themselves. (Doc. 49-1 at 3.) The government
22 believes that when Defendant’s father calls victims and mentions his mafia connections,
23 suggests he’s taking notes about who is supporting Defendant, and informs victims that
24 “Johnny sends his regards,” those are veiled threats. Defendant disagrees. That’s fine.
25 But none of these statements in SA Lamerson’s declaration is false or misleading.
26 Defendant then pushes further, suggesting that if anyone is in the wrong, it’s SA
27 Lamerson for speaking with witnesses who were victimized by Defendants’ Ponzi scheme.
28 (Doc. 53 at 12.) Defendant laments that “[SA Lamerson] continues to contact witnesses,

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1 [and] tell them that Caruso has stolen or lost their money.” (Id.) True. Indeed, SA
2 Lamerson will continue to interview witnesses to ensure that victims are afforded their
3 statutory rights. 18 U.S.C. § 3771. Defendant also alleges that SA Lamerson “make[s]
4 disparaging comments about both Carusos, all to curry favor, stoke unjustified fears of the
5 Carusos, and persuade witnesses to cooperate.” (Doc. 53 at 12.) The government
6 disagrees. Defendant stole over $16 million from victim-investors. Fear that money sent
7 to Defendant is gone, appears to be justified. The government’s focus is attempting to
8 bring Defendants to justice and secure as much restitution to compensate victims as
9 possible.
10 3. Caruso Sr.’s Discussion about Mr. Price
11 Defendant’s most violent objection to SA Lamerson’s declaration appears to be with
12 respect to Mr. Price. (Doc. 49-1 at ¶ 5.) As an initial matter, Defendant does not dispute
13 that he sent Art in Motion at least $20,000 obtained from victim-investors. Nor that at the
14 time of the government’s filing, records at the Arizona Corporation Commission stated that
15 Caruso Sr. and Mr. Price were the directors and incorporators of Art in Motion. (Doc. 53-
16 1 at 3 (showing an update to the ACC records dated April 14, 2020).) Nor that Defendant
17 received text messages from his father seeking money. (Id.)
18 The sole objection appears to be the statement, “On April 2, 2020, Caruso Sr.
19 confirmed to his parole officer that Price is still his business partner for Art in Motion and
20 he previously described Price as a 50% partner.” (Doc. 53 at 4-5.) Defendant claims the
21 government mischaracterized the relationship between Caruso Sr. and Price. In support,
22 Defendant submitted a declaration from a paralegal in Mr. Baskin’s law firm. (Doc. 53-1
23 at 8.) The declaration states that the paralegal participated in a phone call with Shaun
24 Hayes, who is Caruso Sr.’s parole officer. According to the declaration, Officer Hayes and
25 Caruso Sr. did not speak about Mr. Price on April 2, 2020, and before April 6, 2020, Mr.
26 Hayes “assumed that Mr. Price was a silent business partner in Art in Motion.” (Doc. 53-
27 1 at 8, ¶¶ 5, 7.)
28

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1 Officer Hayes, however, has a more nuanced understanding. (See Declaration of

2 Shaun Hayes, dated April 27, 2020, attached as Exhibit A.) Officer Hayes did not have to
3 assume anything as Caruso Sr. “told [him] that Mr. Price was a 50% partner in Art in
4 Motion.” (Id. at ¶ 3.) On April 2, 2020, Caruso Sr. did not specifically mention Mr. Price
5 as a business partner, but when Officer Hayes asked about the business Caruso Sr. told him
6 that “everything is the same.” (Id. at ¶ 2.) It wasn’t until April 6, 2020—the same date the
7 government filed its response to Defendant’s motion—that Caruso Sr. called Officer Hayes
8 and first told him that Mr. Price was no longer a partner in the business. (Id. at ¶ 4.)
9 Accordingly, even though Mr. Price’s name wasn’t mentioned on April 2, 2020, when
10 Caruso Sr. responded to Officer Hayes’s question about the business by saying that
11 “everything is the same,” a reasonable interpretation of that statement is that ownership
12 remained “the same.”
13 In truth, the government doesn’t know the precise contours of Mr. Price’s actual
14 relationship with either Defendant or Caruso Sr. The purpose of pointing out the
15 connections between Mr. Price and Caruso Sr. is simply to show that Mr. Price appeared
16 to have a financial interest in Art in Motion and that business received victim funds, which
17 suggests the arrangement may not be above board.
18 B. The Proposed $300,000 Bond Is Woefully Inadequate To Address
19 Caruso’s Flight Risk
20 Regardless of the relationship between Price and Caruso Sr., the proposed $300,000
21 bond is insufficient to address the serious flight risk concerns. Defendant has known since
22 before his first detention hearing the precise information the government requested in order
23 to consider release conditions for him: a full accounting of the funds and assets controlled
24 by Defendants received through Zima Digital Assets. The government has had this
25 conversation with five different attorneys for Defendant—two of whom still represent him.
26 A full accounting is critical to provide the government, and this Court, with assurances that
27 Defendant does not have victim money stashed away to aid him in flight. For example,
28 Defendant somehow has money to pay for attorneys in Arizona, Nevada, and Florida to

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1 represent him when he’s only reported earnings of $22,800 since November 2017.5
2 Clearly, he has access to money. Where it is and how much is available to him, remain
3 unanswered questions.
4 Further, the loss amount associated with the scheme continues to increase as the
5 government speaks to more victims and gains access to additional financial records:
6 - On January 29, 2020, when the government lodged a criminal complaint against
7 Defendants the loss amount was thought to be “at least $7.5 million.” (Doc. 3
8 at ¶ 23.)
9 - On February 18, 2020, when a grand jury returned an indictment against
10 Defendants, the loss amount was “more than $9 million.” (Doc. 30 at ¶ 3.)
11 - On April 6, 2020, when the government responded to Defendant’s second
12 motion for release, the loss amount had increased to “exceed $15 million.” (Doc.
13 49-1 at ¶ 2.)
14 - Today, that amount has increased to over $16 million.
15 With the loss amount having grown by over $8 million in the last three months, Defendant
16 could certainly have sufficient funds to pay Mr. Price $300,000 and still abscond.
17 Defendant’s “track record of dishonesty” does not help his argument. (See Doc. 27.)
18 C. Defendant’s Continued Detention is Appropriate under 18 U.S.C. § 3142
19 1. Defendant’s Individualized Assessment Supports Detention
20 The Court needs to conduct an individual assessment of the factors under the Bail
21 Reform Act. See United States v. Cox, 2020 WL 1491180, at *2 (D. Nev. March 27, 2020)
22 (judges need to review information pertaining to the factors identified under 18 U.S.C.
23 § 3142(g) and that information aids in the individualized assessment that will result in the
24 release or detention of defendant). This case-by-case review negates the import of the
25 cases cited by Defendant where courts have released defendants or detainees due, at least
26 in part, to COVID-19 concerns. (Doc. 53 at 7-8.) As Judge Burns noted, “although some
27
5
28 Defendant’s legal funds do not appear to be flowing from his father and mother
either, as evidenced by a third party offering to pay Defendant’s bond.

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1 Courts have found that the current pandemic in certain circumstances justified release of a
2 previously detained defendant, many courts have not, thus supporting review on a case-by-
3 case basis.” (Doc. 50 (citing United States v. Motley, No. 19-cr-00026-LRH-WGC-1 (D.
4 Nev. April 2, 2020, No. 137 at 6).) Judge Burns also agreed with this Court’s decision in
5 United States v. Caddo. (Id. (“too much is speculative to outweigh the legitimate
6 countervailing concerns the government raises”).)
7 As the Court is aware, CoreCivic has protocols in place regarding COVID-19 with
8 respect to prevention, identification, treatment, surveillance, isolation, testing, and
9 protecting the uninfected. These measures are constantly changing, and include the
10 following:
11
(1) New inmates are being screened by having a full set of vital signs taken,
12 which includes checking temperatures, assessing possible symptoms (flu-like
symptoms, coughing) and “chronic care” needs, along with completing an in-depth
13
health inquiry. Based on this intake screening, new inmates will be quarantined, if
14 necessary. New inmates are housed together and isolated from the general
population for 14 days as a precautionary measure.
15
16 (2) Nurses are screening inmates in the cellblocks in Phoenix and Tucson: testing
temperatures, checking whether an inmate had an upper respiratory infection within
17 the last 14 days and inquiring about known exposures. If they determine someone
18 poses a risk, that inmate will be masked and possibly quarantined.
19 (3) Based on guidance from the Centers for Disease Control and Prevention
20 (“CDC”), CoreCivic has identified a “high risk” watch list of inmates. The facility
will be keeping a close eye on these inmates. Some of these “high risk” inmates
21 may already be in the infirmary. An inmate will not be moved just because s/he is
22 identified as “high risk.” For example, just because an inmate is HIV positive, s/he
may not be included on the list or isolated. Instead, the decision is based on the
23 individual inmate’s current health situation.
24
(4) CoreCivic has increased sanitization measures to be more comprehensive
25 and more frequent in accordance with CDC guidelines.
26
(5) All inmates are being instructed on CDC guidelines to prevent transmission
27 of COVID-19, including the importance of frequent hand washing, covering coughs,
not touching the face, etc. All inmates were provided with masks on April 13, 2020.
28

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1
(6) Inmates are being tested before they leave a facility to go to court, and if they
2 register a temperature greater than 100.4 F, they are not transported to court. (Due
to a recent nurse’s positive COVID-19 test, which is discussed below, the Court has
3
directed USMS not to transport any inmates from CoreCivic to court. Currently, it
4 is expected that this order will remain in effect until at least May 12, 2020.)
5
(7) Employees are screened at the beginning of each shift and are not permitted
6 to work if they have a fever. All employees were provided with masks on April 13,
2020, and they are required to wear them.
7
8 (8) CoreCivic is following CDC recommendations. They are coordinating with
local health and fire departments and have contingency plans in place with local
9 hospitals.
10 As of April 28, 2020, no inmates at CoreCivic Central Arizona Florence
11 Correctional Complex (“FCC Florence”) have tested positive for COVID-19. A nurse who
12 exhibited symptoms upon return from a cruise in early March tested positive. She did not
13 work for 14 days and then was cleared to work. On April 25, 2020, a corrections officer
14 tested positive for COVID-19. He has not been in the facility since April 24, 2020. At the
15 direction of the Arizona Department of Health, 115 inmates are being quarantined as a
16 precaution. These inmates were in the unit where the affected officer worked. In an email
17 received by the government on April 29, 2020, at 1:57 pm, Deputy Warden Arlene Hickson
18 reported that four inmates from the quarantine unit who show some symptoms, though
19 none has a fever, will be tested for COVID-19. These four inmates will be moved to an
20 empty unit under quarantine guidelines to monitor pending the test results. On April 27,
21 2020, a nurse tested positive for COVID-19. She has not been in the facility since April
22 23, 2020. Finally, another nurse, who has been away from FCC Florence since April 24,
23 2020, also tested positive for COVID-19. CoreCivic is working to determine who may
24 have been exposed to the virus based on contacts with these nurses and will take action in
25 accordance with the policies outlined above.
26 In Defendant’s individualized assessment, his age and health must be considered.
27 18 U.S.C. § 3142(g)(3)(A). Defendant is young—28 years old—without any underlying
28 health conditions. (Doc. 50 at 4.) The data from the virus demonstrates that individuals

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1 with Defendant’s age and health are at much less risk than older, less healthy individuals.
2 Specifically, in Maricopa County as of April 29, 2020, 140 people have died due to
3 COVID-19.6 Out of those deaths, 89% were 65 years or older and 98% were high risk
4 (meaning 65 years or older or at least one chronic medical condition). Id.
5 2. This Case Isn’t Overly Complex
6 Defendant argues for his release under 18 U.S.C. § 3142(i) due in large part to the
7 “complexity of this matter.”7 (Doc. 53 at 8.) Defendant states that this case “is extremely
8 complex,” and necessitates “a deep understanding of trading cryptocurrencies,
9 cryptocurrency storage, and record-keeping on a several blockchains.” (Id. at 9.)
10 Defendant is mistaken. This case is straightforward. Defendant defrauded investors out
11 of millions of dollars. The investigation has revealed no evidence that a cryptocurrency
12 hedge fund exists. (Doc. 49-1 at 2.) If Defendant did trade or store cryptocurrencies, he
13 has provided no evidence of it to the government despite numerous requests to his counsel
14 for such information.
15 Defendant also attempts to compare his situation to the defendant in United States
16 v. Stephens, but that case is readily distinguishable. (Doc. 53 at 8-10 (citing Stephens, 2020
17 WL 1295155 (S.D.N.Y. March 19, 2020)).) In Stephens, the court found that changed
18 circumstances appropriately caused a reconsideration of defendant’s bail conditions.
19 Unlike Caruso, however, the first changed circumstance for Stephens was that the
20 government’s primary evidence to demonstrate the danger he posed to the community had
21 been undermined. Id. at *1 (“this new information nonetheless indicates that the
22 Government’s case is weaker than it believed it to be at the March 6 hearing and bears
23 upon the Court’s prior conclusion”). The other major difference between these matters is
24 that Stephens had an evidentiary hearing later that same month and thus the Court
25 6
Alison Steinbach, Arizona Coronavirus Update, Arizona Republic, (April 29,
26 2020), https://www.azcentral.com/story/news/local/arizona-
health/2020/04/29/coronavirus-arizona-cases-exceed-7-200-304-deaths/3043292001/, last
27 visited April 29, 2020.
7
28 Defendant is also ineligible for temporary release for all the reasons asserted by
the government in its previous response. (Doc. 49 at 10.)

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1 concluded that his “ability to prepare his defenses” was impacted. Id. at 3. Here,
2 Defendant’s trial is not scheduled to start until September. The timing is very different.
3 Cf. United States v. Kennedy, 2020 WL 1493481, at *5 (E.D. Mich. March 27, 2020)
4 (releasing defendant who had an evidentiary hearing scheduled for June 4, 2020).
5 Defendant has not shown that temporary release is necessary for his defense preparation or
6 for any other compelling reasons.
7 III. Conclusion
8 Defendant’s risk of flight has not changed since Judge Burns first detained him in
9 early February. No conditions or combination of conditions will reasonably assure his
10 appearance or the safety of the community. He should remain detained.
11 Respectfully submitted this 29th day of April, 2020.
12 MICHAEL BAILEY
United States Attorney
13 District of Arizona
14 s/Andrew C. Stone
ANDREW C. STONE
15 JAMES R. KNAPP
Assistant U.S. Attorneys
16
17
18
19
20 CERTIFICATE OF SERVICE
21 I hereby certify that on this same date, I electronically transmitted the attached
document to the Clerk’s Office using the CM/ECF System for filing and transmittal of a
22 Notice of Electronic Filing to the applicable CM/ECF registrants.
23 s/ Marjorie Dieckman
24 U.S. Attorney’s Office
25
26
27
28

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Exhibit A
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Exhibit B
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