DOJ-OGR-00002869.jpg

Case 1:20-cr-00330-PAE Document188 _ Filed 03/29/21 Page3of5 Page 3 Count Six of the S2 Indictment adds another new charge against the defendant. In particular, Count Six alleges that the defendant participated in the sex trafficking of a minor, and aided and abetted the same, in violation of 18 U.S.C. §§ 1591 and 2. The S2 Indictment specifically identifies Minor Victim-4 as the victim of this count. Count Seven of the S2 Indictment is identical to Count Five of the S1 Indictment and is otherwise unchanged. Count Eight of the S2 Indictment is identical to Count Six of the S1 Indictment and is otherwise unchanged. Il. Disclosures The Government has already produced to the defense all material that constitutes Rule 16 discovery related to the new allegations and charges contained in the S2 Indictment. In particular, the Government has from the outset approached its Rule 16 productions in this case as though the allegations covered a broader time period through at least 2005, rather than limiting those productions to the time period alleged in the S1 Indictment (1994 to 1997). As a result, the Government has already produced to the defense all Rule 16 material relevant to the S2 Indictment of which it is aware in the Prosecution Team’s possession. These Rule 16 materials included productions from the files of the Federal Bureau of Investigation (“FBI’’?) Palm Beach Resident Agency (the “FBI Florida Office’), the FBI New York Office, and the U.S. Attorney’s Office for the Southern District of New York. To assist the defense in preparing for trial on the new allegations contained in the S2 Indictment, today the Government provided the defense with Minor Victim-4’s month and year of birth. Additionally, in order to aid the defense in its trial preparation and review of the discovery, DOJ-OGR-00002869