Case 1:21-cr-00378-JFK Document 5 Filed 05/27/21 Page 1 of 2

. U.S. Department of Justice

United States Attorney

Southern District of New York

The Silvio J. Mollo Building

One Saint Andrew's Pla=a
New York, New York 10007

May 27, 2021

BY EMAIL
The Honorable Barbara Moses **Sealed Treatment Requested**
United States Magistrate Judge
Southern District of New York
500 Pearl Street
New York, New York 10007

Re: United States v. Apostolos Trovias, a/k/a "The Bull,"

21 Mag. 2220

Dear Judge Moses:

The Government writes to respectfully request that the Court unseal Complaint No. 21
Mag. 2220 and the associated arrest warrant for the limited purpose of allowing the Government
to pursue the extradition of defendant Apostolos Trovias from the Republic of Peru.

On February 25 , 2021, the Hon. Sarah Netburn, U.S. Magistrate Judge, approved the filing
of Criminal Complaint No. 21 Mag. 2220, which charged Apostolos Trovias, a/k/a "The Bull," in
one count with committing, and attempting to commit, securities fraud in violation of Title 18,
United States Code, Section 1348. Because Trovias was at liberty, and therefore could flee or
destroy evidence if Trovias were to learn of the Government's investigation, the Government
requested-and Judge Netburn ordered-that the complaint and an accompanying arrest warrant
would be received and maintained under seal until such time as Trovias is apprehended. Judge
Netburn did, however, unseal the complaint and arrest warrant for the limited purpose of
requesting legal assistance from law enforcement officers in the United States and Mexico in
connection with the Government's efforts to apprehend Trovias. By subsequent order, on March
2, 2021, Judge Lehrburger unsealed the Complaint for the limited purpose of pursuing extradition
from Mexico and for obtaining the assistance of the U.S. State Department and Interpol.

Since the Government's prior requests for limited unsealing, the Government has learned
that Apostolos Trovias has been found and arrested in the Republic of Peru. To formally request
the assistance of the Peruvian government, the Government intends to provide the criminal
complaint and arrest warrant to the Peruvian government.
 Case 1:21-cr-00378-JFK Document 5 Filed 05/27/21 Page 2 of 2

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Accordingly, the Government respectfully requests the Court's authorization to unseal the
complaint and arrest warrant for the limited purpose described above, and that those documents
otherwise be maintained under seal until further order of the Court.

Respectfully submitted,

AUDREY STRAUSS
United States Attorney for the
~ofNewYork

By:
Matthew Podolsky /Andrew Thomas
Assistant United States Attorneys
(212) 637-1947 /-2106

UNITED STA TES MAGISTRATE JUDGE