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: : \ : \ Cas@€ds20Lcreo0880422E G @Oo@onentet4B5 FiledayibiH2 PagPdgefaof 11 e ; . fm UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK - - - - - - - - - - - - - - - - xX UNITED STATES OF AMERICA INDICTMENT - Vi. —_ 18 Cr. inten CLAUDIUS ENGLISH, a/k/a “Jay Barnes,” a/k/a “Brent English,” Defendant. ee COUNT ONE (Conspiracy to Engage in Sex Trafficking of Minors) The Grand Jury charges: 1. In or about 2013, in the Southern District of New York and elsewhere, CLAUDIUS ENGLISH, a/k/a “Jay Barnes,” a/k/a “Brent English,” the defendant, and others known and unknown, conspired and agreed with each other to knowingly, in and affecting interstate and foreign commerce, recruit, entice, harbor, transport, provide, obtain, advertise, maintain, patronize, and solicit by any means persons who had not attained the age of 18 years at the time (collectively, the “Minor Victims”), knowing, having had a reasonable opportunity to observe, and in reckless disregard of the fact that the Minor Victims had not attained the age of 18 years, and knowing that the Minor Victims would be caused to engage in commercial sex acts. (Title 18, United States Code, Sections 1594(c), 1591(a) (1), (b) (1), and (b) (2).) DOJ-OGR- 00006938