EFTA Document EFTA01718335

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 . 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