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Case 1:20-cr-00330-PAE Document188 _ Filed 03/29/21 Page2of5 Page 2 I. Comparison of the S1 Indictment and the S2 Indictment Count One of the S2 Indictment charges the defendant with participating in a conspiracy to entice minors to travel, in violation of 18 U.S.C. § 371, which is the same statutory violation as Count One of the S1 Indictment. Whereas Count One of the $1 Indictment alleged that this conspiracy lasted through in or about 1997, Count One of the S2 Indictment alleges that the conspiracy continued through in or about 2004 and specifically identifies a fourth victim, Minor Victim-4, who was a victim of this conspiracy between approximately 2001 and 2004. Count Two of the S2 Indictment remains identical to Count Two of the S1 Indictment and is unchanged. Count Three of the S2 Indictment charges the defendant with participating in a conspiracy to transport minors, in violation of 18 U.S.C. § 371, which is the same statutory violation as Count Three of the $1 Indictment. Whereas Count Three of the S1 Indictment alleged that this conspiracy lasted through in or about 1997, Count Three of the S2 Indictment alleges that the conspiracy continued through in or about 2004 and specifically identifies a fourth victim, Minor Victim-4, who was a victim of this conspiracy between approximately 2001 and 2004. Count Four of the S2 Indictment remains identical to Count Four of the S1 Indictment and is unchanged. Count Five of the S2 Indictment adds a new charge against the defendant. In particular, Count Five alleges that the defendant participated in a sex trafficking conspiracy between approximately 2001 and 2004, in violation of 18 U.S.C. § 371. The S2 Indictment specifically identifies Minor Victim-4 as a victim of this conspiracy. DOJ-OGR- 00002868