EFTA00025148.pdf

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Source set: data-set-8
Extracted text

EXHIBIT E 
EFTA00025148


Case 1:18-cr-00492-PGG Document 8 Filed 07/16/18 Page 1 of 10 
ORIGINA1 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
X 
UNITED STATES OF AMERICA 
INDICTMENT 
18 Cr. 
CLAUDIUS ENGLISH, 
a/k/a "Jay Barnes," 
a/k/a "Brent English," 
Defendant. 
X 
4 
COUNT ONE 
(Conspiracy to Engage in Sex Trafficking of Minors) 
The Grand Jury charges: 
1. 
In or about 2013, in the Southern District of New 
York and elsewhere, CLAUDIUS ENGLISH, a/k/a "Jay Barnes," a/k/a 
"Brent English," the defendant, and others known and unknown, 
conspired and agreed with each other to knowingly, in and affecting 
interstate 
and 
foreign commerce, 
recruit, 
entice, 
harbor, 
transport, provide, obtain, advertise, maintain, patronize, and 
solicit by any means persons who had not attained the age of 18 
years at the time (collectively, the "Minor Victims"), knowing, 
having had a reasonable opportunity to observe, and in reckless 
disregard of the fact that the Minor Victims had not attained the 
age of 18 years, and knowing that the Minor Victims would be caused 
to engage in commercial sex acts. 
(Title 18, United States Code, Sections 
1594(c), 1591(a) (1), (b) (1), and (b) (2) .) 
EFTA00025149


Case 1:18-cr-00492-PGG Document 8 Filed 07/16/18 Page 2 of 10 
COUNT TWO 
(Sex Trafficking of Minor Victim-1) 
The Grand Jury further charges: 
2. 
Between at least in or about March 2013 and at least 
in or about April 2013, in the Southern District of New York and 
elsewhere, CLAUDIUS ENGLISH, a/k/a "Jay Barnes," a/k/a "Brent 
English," the defendant, in or affecting interstate and foreign 
commerce, recruited, enticed, harbored, transported, provided, 
obtained, advertised, maintained, patronized, and solicited a 
person who had attained the age of 14 years but had not attained 
the age of 18 years at the time ("Minor Victim-1"), knowing, having 
had a reasonable opportunity to observe, and in reckless disregard 
of the fact that Minor Victim-1 had not atta…
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