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Case 1:19-cr-00490-RMB Document 20 j782epsC kjc Filed 07/ 16/19 Page 16 of 24 16 the department and what This is old stu that ensued is this tment is essentially a do-over. that was stuff a sophisticated three-year in this indictment the conduct that ment was should chill the blood of agr find out just investigation back in Florida is We do know we are talking about facts that the United ntered into the NPA, the That's how it feels who negotiates a deal with the United 1 So this is a huge problem for 2 solution ensues, and I suggest the solution 8 indictment. To us, this indic 4 The allegations are from 2002 to 2005. 5 This is ancient stuff This is the very 6 investigated by the feds in Florida, 7 investigation. Two of the alleged victims 8 are from Florida. The indictment here tracks 9 was investigated in Florida back before th 10 reached. Obviously we need to get discovery to 11 how inextricably linked th 12 with what's going on here. 13 ancient conduct. We do know we are talking about 14 are from 2002 to 2005, facts that were known to 15 States prosecutors before they 16 declination. This is essentially a redo. 17 to us. And if we are correct, that 18 very defense attorney 19 States. 20 In addition, we hav th 21 trafficking, and obviously it is usef 22 inquiry as to why the trafficking law was passed. 23 cover abhorrent conduct, where young gir] 24 are fooled, they are forced to come usual 25 places, work in brothels where they servic central al legation here is ful and relevant to make It is to s are kidnapped, they lly to unfamiliar 15, 20 guys ina SOUTHERN D STR (212) 805-0300 CT REPORTERS, P.C. DOJ-OGR-00000421