Case File
efta-01718335DOJ Data Set 10OtherEFTA01718335
Date
Unknown
Source
DOJ Data Set 10
Reference
efta-01718335
Pages
42
Persons
0
Integrity
Extracted Text (OCR)
EFTA DisclosureText extracted via OCR from the original document. May contain errors from the scanning process.
I.
And what additional evidence is there to support Count 9, which alleges that JE
and
used a facility of interstate commerce to persuade, induce, and entice Jane
Doe # to engage in prostitution? How man
calls have you been able
to document between Jane Doe #8 and
1.
I-Iow old was Jane Doe #8 at the time? And what is the activity that she
and JE engaged in that also violated Fl. Stat. 794.05?
J.
Is there anything you want to add regarding Count 25, which alleges that JE and
recruited and procured Jane Doe #8 to engage in commercial sex acts knowing
that she was a minor?
XI.
JANE DOE #9
A.
Who is Jane Doe #9? Have you testified about her previously?
1.
Is there anything that you want to clarify or add regarding your earlier
testimony?
B.
Has she been interviewed? In addition to her statements, who else provided
information regarding Jane Doe #9?
C.
During what period of time did Jane Doe #9 have contact with JE?
D.
How old was she during that time frame?
E.
How did she meet JE?
F.
And what sexual activity was she involved in with JE?
G.
Did she recruit anyone to go to JE's home?
H.
Does your prior testimony cover the evidence supporting the allegations in overt
acts 55, 61, 66-67, 102, 107-108, 140, 142-143, 150?
I.
And what additional evidence is there to support Count 10, which alleges that JE
and
used a facility of interstate commerce to persuade, induce, and entice Jane
Doe #9 to engage in prostitution? How man telephone calls have you been able
to document between Jane Doe #9 and
J.
Is there anything you want to add regarding Count 26, which alleges that JE and
I. recruited and procured Jane Doe #9 to engage in commercial sex acts knowing
that she was a minor?
Hays 8 o. 16
EFTA01718335
XII. • JANE DOE #10
A.
Who is Jane Doe #10? Have you testified about her previously?
B.
Has she been interviewed? In addition to her statements, who else provided
information regarding Jane Doe #10?
C.
During what period of time did Jane Doe #10 have contact with JE?
D.
How old was she during that time frame?
E.
How did she meet JE?
F.
And what sexual activity was she involved in with JE?
G.
Did she recruit anyone to go to JE's home?
H.
What evidence supports the allegations in overt acts 68-71, 145?
I.
And what additional evidence is there to support Count 11, which alleges that JE
and
used a facility of interstate commerce to persuade, induce, and entice Jane
Doe 410 to engage in prostitution? How man
calls have you been able
to document between Jane Doe #10 and
J.
Is there anything you want to add regarding Count 27, which alleges that JE and
10 recruited and procured Jane Doe #10 to engage in commercial sex acts
knowing that she was a minor?
ME. JANE DOE 411
A.
Who is Jane Doe 411? Have you testified about her previously?
1.
Is there anything that you want to clarify or add regarding your earlier
testimony?
B.
Has she been interviewed? In addition to her statements, who else provided
infonnation regarding Jane Doe #11?
C.
During what period of time did Jane Doe #11 have contact with JE?
D.
How old was she during that time frame?
Hays 9 o(1) 16
EFTA01718336
E.
How did she meet JE?
F.
And what sexual activity was she involved in with JE?
G.
Did she recruit anyone to go to JE's home?
H.
Can you summarize the evidence supporting the allegations in overt acts 78, 145-
148, 168?
I.
And what additional evidence is there to support Count 12, which alleges that JE
and
used a facility of interstate commerce to persuade, induce, and entice Jane
Doe #11 to engage in prostitution? How man telephone calls have you been able
to document between Jane Doe #11 and
J.
Is there anything you want to add regarding Count 28, which alleges that JE and
recruited and procured Jane Doe #11 to engage in commercial sex acts
owing that she was a minor?
XIV. JANE DOE #12
A.
Who is Jane Doe #12? Have you testified about her previously?
1.
Is there anything that you want to clarify or add regarding your earlier
testimony?
B.
Has she been interviewed? In addition to her statements, who else provided
information regarding Jane Doe #12?
C.
During what period of time did Jane Doe #12 have contact with JE?
D.
How old was she during that time frame?
E.
How did she meet JE?
F.
And what sexual activity was she involved in with JE?
G.
Did she recruit anyone to go to JE's home?
H. •
Can you summarize the evidence supporting the allegations in overt acts 80-84,
94, 106?
XV.
JANE DOE #13
Bays 10 o4) 16
EFTA01718337
A.
Who is Jane Doe #13? Have you testified about her previously?
1.
Is theist anything that you want to clarify or add regarding yoUr earlier
testimony?
B.
Has she been interviewed? In addition to her statements, who else provided
information regarding Jane Doe #13?
C.
During what period of time did Jane Doe #13 have contact with JE?
D.
How old was she during that time frame?
E.
How did she meet JE?
F.
And what sexual activity was she involved in with JE?
G.
Did she recruit anyone to go to JE's home?
H.
Does your prior testimony cover the evidence supporting the allegations in overt
acts 72-76, 109-110, 114-117, 136-137, 149, 160, 169, 171, 175, 178?
I.
And what additional evidence is there to support Count 13, which alleges that JE
and. used a facility of interstate commerce to persuade, induce, and entice Jane
Doe #13 to engage in prostitution? How si
telephone calls have you been able
to document between Jane Doe #13 and
1.
How old was Jane Doe #13 during this period? And what is the sexual
activity that she and JE engaged in that also violated Fl. Stat. 794.05?
J.
Is there anything you want to add regarding Count 29, which alleges that JE and
recruited and procured Jane Doe #13 to engage in commercial sex acts
knowing that she was a minor?
XVI. JANE DOE #14
A.
Who is Jane Doe #14? Have you testified about her previously?
1.
Is there anything that you want to clarify or add regarding your earlier
testimony?
B.
Has she been interviewed? In addition to her statements, who else provided
information regarding Jane Doe #14?
nays 11 o4) 16
EFTA01718338
C.
During what period of time did Jane Doe #14 have contact with JE?
D.
How old was she during that time frame?
E.
How did she meet JE?
F.
And what sexual activity was she involved in with JE?
G.
Did she recruit anyone to go to JE's home?
H.
Does your prior testimony cover the evidence supporting the allegations in overt
acts 103, 125-128, 135, 144, 152, 162-163, 166, 172, 180-181, 183, 208?
I.
And what additional evidence is there to support Count 14, which alleges that JE,
and
used a facility of interstate commerce to persuade, induce,
an entice ane •14
to engage in prostitution? How man y tele hone calls
have you been able to document between Jane Doe #14 and
And how
many between Jane Doe #14 and
J.
Is there an thin
rou want to add regarding Count 30, which alleges that JE,
and
recruited and procured Jane Doe #14 to engage in conunercia
sox acts knowing that she was a minor?
XVII. JANE DOE #15
A.
Who is Jane Doe #15? Have you testified about her previously?
1.
Is there anything that you want to clarify or add regarding your earlier .
testimony?
B.
Has she been interviewed? In addition to her statements, who else provided
information regarding Jane Doe #15?
C.
During what period of time did Jane Doe #15 have contact with JE?
D.
How old was she during that time frame?
E:
How did she meet JE?
F.
And what sexual activity was she involved in with JE?
G.
Did site recruit anyone to go to JE's home?
Hays 12
16
EFTA01718339
H.
Does your prior testimony cover the evidence supporting the allegations in overt
acts 94-100, 106?
I.
And what additional evidence is there to support Count 15, which alleges that SE
and. used a facility of interstate commerce to persuade, induce, and entice Jane
Doe #15 to engage in prostitution? How man
calls have you been able
to document between Jane Doe #15 and
XVIII. JANE DOE #16
A.
Who is Jane Doe #16? Have you testified about her previously?
1.
Is there anything that you want to clarify or add regarding your earlier
testimony?
B.
Has she been interviewed? In addition to her statements, who else provided
information regarding Jane Doe #16?
C.
During what period of time did Jane Doe #16 have contact with JE?
D.
How old was she during that time frame?
E.
How did she meet JE?
F.
And what sexual activity was she involved in with JE?
G.
Does your prior testimony cover the evidence supporting the allegations in overt
acts 153-158, 185-186?
H.
And what additional evidence is there to support Count 16, which alleges that JE
and. used a facility of interstate commerce to persuade, induce, and entice Jane
Doe #16 to engage in prostitution? Can you describe the evidence regarding the
indirect telephone contact between. and Jane Doe #16 via Jane Doe #5? Are
there controlled telephone calls?
1.
How old was Jane Doe #16? And what was the sexual activity that she
and JE engaged in that also violated Fl. Stat. 800.04?
XIX. JANE DOE #17
A.
Who is Jane Doe #17? Have you testified about her previously?
1.
Is there anything that you want to clarify or add regarding your earlier
Hays 13 och 16
EFTA01718340
testimony?
B.
Has she been interviewed? In addition to her statements, who else provided
information regarding Jane Doe #17?
C.
During what period of time did Jane Doe #17 have contact with JB?
D.
How old was she during that time frame?
E.
How did she meet JE?
F.
And what sexual activity was she involved in with JE?
G.
Did she recruit anyone to go to JE's home?
H.
Does your prior testimony cover the evidence supporting the allegations in overt
acts 118-119, 129-133, 187-188, 190, 193-194, 197-199, 201-202, 204-205, 207-
213?
I.
And what additional evidence is there to support Count 17, which alleges that JE,
and.
used a facility of interstate commerce to persuade, induce, and
entice ane Doe #17 to engage in prostitution? How man telephone calls have
you been able to document between Jane Doe #17 and
Between Jane Doe
#17 and
And between Jane Doe #17 and
1.
What was the sexual activity that Jane Doe #17 and JB engaged in that
also violated Fl. Stat. 794.05?
J.
Is there an ling you want to add regarding Count 31, which alleges that TB,.
M, and
recruited and procured Jane Doe #17 to engage in commercial sex
acts knowing that she was a minor?
)OC.
JANE DOE #18
A.
Who is Jane Doe #18? Have you testified about her previously?
1.
Is there anything that you want to clarify or add regarding your earlier
testimony?
B.
Has she been interviewed? In addition to her statements, who else provided
information regarding Jane Doe #18?
C.
During what period of time did Jane Doe #18 have contact with JE?
hays 14 of 16
EFTA01718341
D.
How old was she during that time frame?
E.
How did she meet JE?
F.
And what sexual activity was she involved in with JE?
G.
Did she recruit anyone to go to JE's home?
H.
Does your prior testimony cover the evidence supporting the allegations in overt
acts 118-123, 197?
I.
And what additional evidence is there to support Count 18, which alleges that 1E,
R
andi
used a facility of interstate commerce to persuade, induce, and entice
e Doe 1 i 8 to engage in prostitution? Howai telephone calls have you been
able to document between Jane Doe #18 and
And how many between
Jane Doe #18 and
XXI. JANE DOE #19
A.
Who is Jane Doe #19? Have you testified about her previously?
B.
Has she been interviewed? In addition to her statements, who else provided
information regarding Jane Doe #19?
C.
During what period of time did Jane Doe #19 have contact with JE?
D.
How old was she during that time frame?
E.
How did she meet JE?
F.
And what sexual activity was she involved in with JE?
G.
Did she recruit anyone to go to JE's home?
H.
Can you summarize the evidence supporting the allegations in overt acts 88-91?
XXII. TRAVEL COUNTS: COUNTS 19 THROUGH 22
A.
Count 19: July 16, 2004
1.
Who was aboard the flight on July 16, 2004?
Hays 15 o+ 16
EFTA01718342
2.
What telephone activity occurred prior to the flight on July 16th?
3.
And what telephone activity occurred while JE was in Palm Beach?
4.
What other documentary evidence is there to show that one of the
purposes of JE's July 16th trip was to engage in illicit sexual conduct?
B.
Count 20: March 31, 2005
1.
Who was aboard the flight on March 31, 2005?
2.
What telephone activity occurred prior to the flight on March 31st?
3.
And what telephone activity occurred while JE was in Palm Beach?
4.
What other documentary evidence is there to show that one of the
purposes of JE's March 31m trip was to engage in illicit sexual conduct?
C.
Count 21: September 18, 2005
1.
Who was aboard the flight on September 18, 2005?
2.
What telephone activity occurred prior to the flight on September 18th?
3.
And what telephone activity occurred while YE was in Palm Beach?
4.
What other documentary evidence is there to show that one of the
purposes of JE's September 18th trip was to engage in illicit sexual
conduct?
D.
Count 22: September 29, 2005
1.
Who was aboard the flight on September 29, 2005?
2.
What telephone activity occurred prior to the flight on September 29th?
3.
And what telephone activity occurred while JE was in Palm Beach?
4.
What other documentary evidence is there to show that one of the
purposes of JE's September 29th trip was to engage in illicit sexual
conduct?
Flays 16 o4 16
EFTA01718343
VICTIMS
EFTA01718344
•
I
•
EFTA01718345
Fel . Ji A • - ‘.o_ r
EFTA01718346
VICTIMS' ADDRESSES
EFTA01718347
Confidential Attorney Work Product
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Revised: September 16, 2008 (3:03pm)
EFTA01718348
Confidential Attorney Work Product
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Revised: September 16, 2008 (3:03pm)
EFTA01718349
Confidential Attorney Work Product
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Revised: September 16. 2008 (3:03pm)
EFTA01718350
Confidential Attorney Work Product
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Revised: September 16, 2008 (3:03pm)
EFTA01718351
Confidential Attorney Work Product
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Revised: September 16, 2008 (3:03pm)
EFTA01718352
Confidential Attorney Work Product
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Revised: September 16, 2008 (3:03pm)
EFTA01718353
Confidential Attorney Work Product
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Revised: September 16, 2008 (3:03pm)
EFTA01718354
Confidential Attorney Work Product
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Revised: September 16. 2008 (3:03pm)
EFTA01718355
Confidential Attorney Work Product
Page 9 of 9
Revised: September 16, 2008 (3:03pm)
EFTA01718356
CONFIDENTIAL & PRIVILEGED
I
ATTORNEY WORK PRODUCT
EFTA01718357
CONFIDENTIAL & PRIVILEGED
2
ATTORNEY WORK PRODUCT
EFTA01718358
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