From: (USANYS)" < To: ' (USANYS)" Subject: RE: Draft Indictment Date: Fri, 14 Jun 2019 13:57:20 +0000 Importance: Normal Yes — finishing up within the hour. From: (USANYS) Sent: Friday, June 14, 2019 9:54 AM To: (USANYS) Subject: RE: Draft Indictment Yeah, I was going to make the same research suggestion. Can you send me your comments when you can? Assuming I'm doing the next round want to make sure I understand yours so I can ensure team addressed them. From: (USANYS) Sent: Friday, June 14, 2019 9:53 AM To: (USANYS) Subject: RE: Draft Indictment I went to speak to about that and the option of charging it that way and superseding later — it is much preferable to it this way if we can because we do not want to charge a single victim count — both not to put it all on and to not suggest our case is that narrow. M, gut is that we can, but in my comments I asked the team to do some research on the unit of prosecution. From: (USANYS) c Sent: Friday, June 14, 2019 9:51 AM To: (USANYS) Subject: RE: Draft Indictment Also, on Count 1, are we sure we can charge a single count covering all conduct? I presume we plan to supersede, so this may be moot, but it'd be embarrassing to stumble out of the gate if we have to charge each person trafficked as a separate substantive... From: (USANYS) Sent: Thursday, June 13, 2019 10:57 PM To: (USANYS) Subject: Re: Draft Indictment Good — you may have to be the one to help get it there. Will loop you in if chain continues. Sent from my iPhone On Jun 13, 2019, at 10:35 PM, (USANYS) < > wrote: I agree with this. Sent from my iPhone EFTA00086797