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Case 1:20-cr-00330-PAE Document670 Filed 06/22/22 Page6of55 new evidence that was not available to the Government at the time the defendant was indicted in late June 2020 or at the time Jeffrey Epstein was indicted in 2019. Throughout its investigation, the Government followed the facts where they led, without fear or favor. B. The Charges On June 29, 2020, a grand jury sitting in this District returned an indictment charging the defendant in six counts. (Dkt. No. 1). On July 2, 2020, the Federal Bureau of Investigation (“FBI’’) arrested the defendant. (PSR 4 77). On July 8, 2020, a grand jury sitting in this District returned a superseding indictment containing the same charges, with ministerial corrections. (Dkt. No. 17). On March 29, 2021, a grand jury sitting in this District returned a superseding indictment (the “Indictment”) which charged the defendant in eight counts. (Dkt. No. 187). Count One of the Indictment charged the defendant with conspiring with Jeffrey Epstein and others to entice minors to travel to engage in illegal sex acts from in or about 1994 through in or about 2004, in violation of 18 U.S.C. § 371. Count Two charged the defendant with enticing Minor Victim-1 to travel to engage in illegal sex acts, and aiding and abetting the same, in violation 18 U.S.C. §§ 2422 and 2. Count Three charged the defendant with conspiring with Epstein and others to transport minors to participate in illegal sex acts from in or about 1994 through in or about 2004, in violation of 18 U.S.C. § 371. Count Four charged the defendant with transporting Minor Victim-1 to participate in illegal sex acts, and aiding and abetting the same, in violation of 18 U.S.C. §§ 2423 and 2. Count Five charged the defendant with participating in a sex trafficking conspiracy between approximately 2001 and 2004, in violation of 18 U.S.C. § 371. Count Six charged the defendant with sex trafficking of Minor Victim-4, and aiding and abetting the same, in violation of 18 U.S.C. §§ 1591 and 2. Counts Seven and Eight charged the defendant with perjury, in violation of 18 Us, § 1623. DOJ-OGR-00010541