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CRIMINAL COMPLAINT

Count One – Production of Child Pornography
the defendant violated:
Code Section Offense Description
Title 18, United States Code, Sections 2251(a) knowingly employed, used, persuaded, induced, and enticed a minor, namely Victim A, to engage in sexually explicit conduct for the purpose of producing a visual depiction of such conduct, which visual depiction defendant knew and had reason to know would be transported and transmitted using any means and facility of interstate and foreign commerce, and which visual depiction was transported and transmitted using any means and facility of interstate and foreign commerce

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