2023.01.22 - Indictment (D. Col. Doc. No. 1)
2023.01.22 - Indictment (D. Col. Doc. No. 1)
Defendant.
________________;/
INDICTMENT
Traveling in Foreign Commerce with the Purpose of Engaging in Illicit Sexual Conduct
18 u.s.c. § 2423(b)
Between in or around November 2006, and continuing through in or around December 2010,
in Miami-Dade County, in the Southern District of Florida, and elsewhere, the defendant,
a United States citizen, did travel in foreign commerce from the United States, that is, Miami
International Airport in Miami, Florida, to Haiti, for the purpose of engaging in any illicit sexual
conduct, as defined in Title 18, United States Code, Section 2423(f), with another person under 18
years of age, in violation of Title 18, United States Code, Section 2423(b).
FORFEITURE ALLEGATIONS
1. The allegations of this Indictment are re-alleged and by this reference fully
incorporated herein for the purpose of alleging forfeiture to the United States of America of certain
2. Upon conviction of a violation of Title 18, United States Code, Section 2423, as
alleged in this Indictment, the defendant shall forfeit to the United States any property, real or
personal, that was used or intended to be used to commit or to facilitate the commission of such
violation and any property, real or personal, constituting or derived from any proceeds traceable
to such violation, pursuant to Title 18, United States Code, Section 2428.
All pursuant to Title 18, United States Code, Section 2428, and the procedures set forth in
Title 21, United States Code, Section 853, as incorporated by Title 28, United States Code, Section
2461.
A TRUE BILL
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MARKENZY LAPOINTE
UNITED STATES ATTORNEY
JESSICAURBAN
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TRIAL ATTORNEY
CHILD EXPLOITATION AND OBSCENITY SECTION
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TRIAL ATTORNEY
CHILD EXPLOITATION AND OBSCENITY SECTION
2
Case No. 1:24-mj-00012-MEH Document 1 filed 01/22/24 USDC Colorado pg 3 of 4
Case 1:24-cr-20008-KMW *SEALED* Document 3 Entered on FLSD Docket 01/19/2024 Page 3
UNITED STATESofDISTRICT
4 COURT
SOUTHERN DISTRICT OF FLORIDA
6.
Has this case been previously filed in this District Court? (Yes or No) o
_N___
Ifyes, Judge_________ _ Case No.______________ _
7. Has a complaint been filed in this matter? (Yes or No)--- No
Ifyes, Magistrate Case No.___________ _
8. Does this case relate to a previously filed matter in this District Court? (Yes or No)_N_o__
Ifyes, Judge___________ Case No. ______________ _
9. Defe ndant(s)in fe deral custody as of_____________________ _
10. Defendant(s)in state custody as of _____________________ _
11. Rule 20 from the ____ District of -------
12. Is this a potential death penalty case? (Yes or No) No__
__
13. Does this case originate from a matter pending in the Northern Region ofthe U.S. Attorney's Office
prior to August 8, 2014 (Mag. Judge Shaniek Maynard? (Yes or No)--- No
14. Does this case originate from a matter pending in the Central Region ofthe U.S. Attorney's Office
prior to October 3, 2019 (Mag. Judge Jared Strauss? (Yes or No)N_o _ _
15. Did this matter involve the participation ofor consultation with now Magistrate Judge Eduardo I. Sanchez
during his tenure at the U.S. Attorney's Office, which concluded on January 22, 2023?_N___ o
By:�
�'/f»rK
'iaceeEiizabeth Monk
Assistant United States Attorney
FL Bar No. 100322
Case No. 1:24-mj-00012-MEH Document 1 filed 01/22/24 USDC Colorado pg 4 of 4
Case 1:24-cr-20008-KMW *SEALED* Document 3 Entered on FLSD Docket 01/19/2024 Page 4
of 4
PENALTY SHEET
Case No:
Count#: 1
Traveling in Foreign Commerce with the Purpose of Engaging in Illicit Sexual Conduct
*Refers only to possible term of incarceration, does not include possible fines, restitution,
special assessments, parole terms, or forfeitures that may be applicable.
Case No. 1:24-mj-00012-MEH Document 1-1 filed 01/22/24 USDC Colorado pg 1 of 1
Mp
MIAMI
Michelle Paschal