EFTA00030534

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If you wish to inspect any of the physical evidence referenced in these materials, including
items listed on search inventories, please let us know, and we will make arrangements for you to
do so.
The defendant also made oral statements when he was arrested on or about July 6, 2019.
Notes memorializing those statements are included in this production and are marked with control
number USAO 002273.
The Government recognizes its obligations under Brady v. Maryland, 373 U.S. 83 (1963),
and its progeny. Pursuant to those obligations, we are disclosing the information below. This
disclosure should not be taken to indicate that the Government believes the enclosed information
constitutes Brady material. Rather, we make this disclosure in an abundance of caution.
Specifically, the Government discloses the following:
• The victim identified in the Indictment as "Victim-1" received a grand jury subpoena
from the Southern District of Florida ("SDFL") in or about 2008. However, Victim-1
was never interviewed by law enforcement, including the West Palm Beach Police
Department, Federal Bureau of investigation ("FBI"), or SDFL in connection with their
investigation, and Victim-1 did not testify before the grand jury in SDFL. Victim-1 was
first interviewed by law enforcement regarding the defendant in or about 2019, after FBI
agents from the New York Field Office working with this Office approached Victim-1.
The victims identified in the Indictment as "Victim-2" and "Victim-3" were both
interviewed by law enforcement in connection with the SDFL investigation on multiple
occasions between in or around 2006 and in or around 2008. Victim-2 and Vicitm-3
were both identified as victims in the July 10, 2008 letter from SDFL to counsel for the
defendant. Victim-1 was not included on that list. Please note that all three of these
victims are currently represented by counsel.
• During an interview with FBI agents in West Palm Beach, Florida in or around 2007, the
victim identified in the Indictment as "Victim-2" stated that during her first contact with
the defendant, she told the defendant that she had just turned eighteen, when in fact she
was younger than eighteen at the time. In subsequent interviews, Victim-2 has told law
enforcement that the first time she met the defendant, she told him that she was 16, when
in fact she was younger than sixteen. Victim-2 further stated that she brought other
victims to the defendant's residence for sexualized massages. She initially told these
victims that they should tell the defendant that they were older than they in fact were.
Over time, however, Victim-2 stopped telling other victims this because she came to
understand that the defendant had a specific preference for underage girls.
• During the Palm Beach Police Department's investigation of the defendant in 2005, a
witness ("Witness-1") disclosed to detectives that the defendant had paid Witness-1 to
bring girls for sexualized massages, and that the defendant told her: "the younger the
better." Witness-1 described bringing multiple girls who were under the age of eighteen
to the defendant's residence in Florida. Witness-1 recalled bringing a girl who was over
eighteen, and that the defendant told Witness-1 that this girl was too old. Witness-1
06.20.2018
EFTA00030534