Document 1:13-cr-00492

COUNT TWO (Sex Trafficking of Minor Victim-1) The Grand Jury further charges: 2. 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-1."), knowing, having had a reasonable opportunity to observe, and in reckless disregard of the fact that Minor Victim-1 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-1, a seventeen-year-old girl, to travel from New Jersey to the Bronx, New York, where ENGLISH took photographs of Minor Victim-1, posted such photographs on an internet advertisement website, and harbored and transported Minor Victim-1 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.) 2 DOJ-OGR-00006014 --- PAGE BREAK --- COUNT FOUR (Sex Trafficking of Minor Victim-3) The Grand Jury further charges: 4. At least in or about November 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-3"), knowing, having had a reasonable opportunity to observe, and in reckless disregard of the fact that Minor Victim-3 had not attained the age of 18 years, and knowing that Minor Victim-3 would be caused to engage in commercial sex acts, to wit, ENGLISH recruited and enticed Minor Victim-3, a sixteen-year-old girl, to travel to the Bronx, New York, where ENGLISH took photographs of Minor Victim-3, intending such photographs to be posted on an internet advertisement website, and harbored Minor Victim-3 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.) 4 DOJ-OGR-00006941