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Extracted Text (OCR)
Cas@€ds20kcr0680422EPG Bo fiovemsaes Fileday MGAad2 Pageagef4of 11
COUNT THREE
(Sex Trafficking of Minor Victim-2)
The Grand Jury further charges:
3. 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-2"), knowing, having
had a reasonable opportunity to observe, and in reckless disregard
of the fact that Minor Victim-2 had not attained the age of 18
years, and knowing that Minor Victim-1 would be caused to engage
in commercial sex acts, to wit, ENGLISH recruited and enticed Minor
Victim-2, a seventeen-year-old girl, to travel from New Jersey to
the Bronx, New York, where ENGLISH took photographs of Minor
Victim-2, posted such photographs on an internet advertisement
website, and harbored and transported Minor Victim-2 for the
purpose of engaging in sexual acts with other men in exchange for
money, some of which ENGLISH kept for himself.
{Title 18, United States Code,
Sections 1591(a){1) and (b) (2), and 2.)
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