Case 1:05-cr-20444-PAS Document 50 Entered on FLSD Docket 08/01/2005 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORID A Case No. 05-20444-CR-Seitz(s) 18 U.S.C. 1591(a)(1 ) 18 U.S.C. 1591(a)(2) 18 U.S.C. 2422(b ) 18 U.S.C. 2423(e ) UNITED STATES OF AMERIC A vs. MARK MADISON, JUSTIN EVANS, and CHAD YEARBY, Defendants. SUPERSEDING INDICTMENT The Grand Jury charges that : COUNT 1 From in or about December 2004 to in or about May 2005, the exact dates being unknown to the Grand Jury, in Miami-Dade County, in the Southern District of Florida, the defendant, JUSTIN EVANS, did knowingly, in and affecting interstate and foreign commerce, recruit, entice, harbor, transport, provide, and obtain by any means a person, that is, Jane Doe #1, knowing that force, fraud, and coercion as described in Title 18, United States Code, Section 1591(c)(2)(A) and (B) would be used to cause the person to engage in a commercial sex act and that the person had not obtained the age of 18 years and would be caused to engage in a commercial sex act, in violation of Title 18, United States Code, Section 1591( a)(1).
Case 1:05-cr-20444-PAS Document 50 Entered on FLSD Docket 08/01/2005 Page 2 of 8 Pursuant to Title 18, United States Code, Section 1591(b)(1), it is further alleged that the offense was effected by force, fraud, and coercion. COUNT 2 From on or about April 17, 2005 to on or about May 6, 2005, in Miami-Dade County, in the Southern District of Florida, and elsewhere, the defendants, MARK MADISON and CHAD YEARBY, did knowingly, in and affecting interstate and foreign commerce, recruit, entice, harbor, transport, provide, and obtain by any means a person, that is, Jane Doe #2, knowing that force, fraud, and coercion as described in Title 18, United States Code, Section 1591 (c)(2)(a) and (B) would be used to cause the person to engage in a commercial sex act and that the person had not obtained the age of 18 years and would be caused to engage in a commercial sex act, in violation of Title 18, United States Code, Sections 1591(a)(1) and 2. Pursuant to Title 18, United States Code, Section 1591(b)(1), it is further alleged that the offense was effected by force, fraud, and coercion. defendants, COUNT 3 On or about May 6, 2005, in Miami-Dade County, in the Southern District of Florida, the MARK MADISON, JUSTIN EVANS, and CHAD YEARBY, did knowingly benefit, financially and by receiving something of value, from participation in a venture which had engaged in an act, in and affecting interstate and foreign commerce, of recruiting, 2
Case 1:05-cr-20444-PAS Document 50 Entered on FLSD Docket 08/01/2005 Page 3 of 8 enticing, harboring, transporting, providing, and obtaining by any means persons, that is, Jane Doe #2 and Jane Doe #3, knowing that force, fraud, and coercion as desc ri bed in Title 18, United States Code, Section 1591 (c)(2)(a) and (B) would be used to cause the persons to engage in commercial sex acts and that the persons had not obtained the age of 18 years and would be caused to engage in commercial sex acts, in violation of Title 18, United States Code, Sections 1591(a)(2) and 2. Pursuant to Title 18, United States Code, Section 1591(b)(1), it is further alleged that the offense was effected by force, fraud, and coercion. COUNT 4 Beginning on or about February 22, 2005 and continuing through March 2005, the exact date being unknown to the Gr and Jury, in Miami -Dade County, in the Southern District of Flo rida, and elsewhere, the defend ant, JUSTIN EVANS, using a facility and means of interstate and foreign commerce, did knowingly persuade, induce, and entice an individual who had not attained the age of 18 years, that is, Jane Doe #1, to engage in prostitution, in violation of Title 18, United States Code, Section 2422(b). COUNT 5 From on or about April 17, 2005, to on or about May 6, 2005, in Miami-Dade County, in the Southern District of Florida, the defendants, MARK MADISON and CHAD YEARBY, did knowingly and intentionally combine, conspire, confederate, and agree to transport individual s who had not attained the age of 18 years, that is, Jane Doe #2 and Jane Doe #3, in interstate 3
Case 1:05-cr-20444-PAS Document 50 Entered on FLSD Docket 08/01/2005 Page 4 of 8 commerce, with the intent that the individuals engage in prostitution, in violation of Title 18, United States Code, Section 2423( a), all in violation of Title 18, United States Code, Section 2423(e). R. ALEXANDER ACOSTA UNITED STATES ATTORNEY MARC OSBORN E ASSISTANT UNITED STATES ATTORNEY 4
UNI FEU 51-Al ES UIS I KIG I UUUK I Case 1:05-cr-20444-PAS Document SOUTHERN 50 DISTRICT Entered on OF FLSD FLORID Docket A 08/01/2005 Page 5 of 8 UNITED STATES OF AMERICA CASE NO. 05-20444 -CR-SEITZ(s) vs. MARK MADISON, et al., Court Division : (Select One) CERTIFICATE OF TRIAL ATTORNEY* Defendants. / Superseding Case Information : X Miam i - FTL WP West FTP I do hereby certify that : New Defendant(s) Yes No _X. Number of New Defendants Total number of counts 5 1. I have carefully considered the allegations of the indictment, the number of defendants, the number of probable witnesses and the legal complexities of the Indictment/Information attached hereto. 2. I am aware that the information supplied on this statement will be relied upon by the Judges of this Court in setting their calendars and scheduling criminal trials under the mandate of the Speedy Trial Act, Title 28 U.S.C. Section 3161. 3. Interpreter: (Yes or No) No List language and/or dialec t 4. This case will take 4 days for the parties to try. 5. Please check appropriate category and type of offense listed below ::, (Check onlyone) (Check only one ) I 0 to 5 days X Petty II 6 to 10 days Minor III 11 to 20 days Misdem. IV 21 to 60 days Felony V 61 days and ove r 6. Has this case been previously filed in this District Court? (Yes or No) YPs If yes : Judge : Spitz (Attach copy of dispositive order ) Case No. ni_21)444 Has a complaint been filed in this matter? (Yes or No) No If yes : Magistrate Case No. Related Miscellaneous numbers : Defendant(s) in federal custody as of July 13-2005 Defendant(s) in state custody as of May 6, 2005 Rule 20 from the District o f Is this a potential death penalty case? (Yes or No) 7. Does this case originate from a matter pending in the U.S. Attorney's Office prior to April 1, 2003? - Yes X No 8. Does this case originate from a matter pending in the U. S. Attorney's Office prior to April 1, 1999? Yes X No If yes, was it pending in the Central Region? _ Yes - N o 9. Does this case originate from a matter pending in the Northern Region of the U.S. Attorney's Office prior to October 14, 2003? Yes X N o 10. Does this case originate from a matter pending in the Narcotics Section (Miami) prior to May 18, 2003? - Yes X N o No X Penalty Sheet(s) attached MARC I. OSBORN E ASSISTANT UNITED STATES ATTORNEY COURT ID NO. A5500796 REV.1/14/04
Case 1:05-cr-20444-PAS Document 50 Entered on FLSD Docket 08/01/2005 Page 6 of 8 Defendant ' s Name: MARK MADISO N Case No : 05-20444-CR -Seitz( s) Count # : 2 SEX TRAFFICKING O F CHILDREN 18 U.S.C. 1591(a)(1 ) * Max. Pen alty: Life imprisonmen t Count # : 3 SEX TRAFFICKING O F CHILDREN 18 U.S.C. 1591(a)(2 ) *Max. Penalty : Life imprisonmen t Count # : 5 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORID A PENALTY SHEE T CONSPIRACY TO TRANSPORT A MINOR FOR PURPOSES OF PROSTITUTION 18 U.S.C. 6 2423(e ) *Max. Penalty: 30 years' imprisonmen t Count # : *Max. Penalty : *Refers only to possible term of incarceration, does not include possible fines, restitution, special assessments, parole terms, or forfeitures that may be applicable.
Case 1:05-cr-20444-PAS Document 50 Entered on FLSD Docket 08/01/2005 Page 7 of 8 Defendant ' s Name : JUSTIN EVANS Case No : 05-20444-CR-Seitz(s ) Count # : 1 SEX TRAFFICKING OF CHILDREN 18 U.S.C. $ 1591(a)(1 ) * Max. Pen alty : Life imprisonmen t Count # : 3 SEX TRAFFICKING OF CHILDREN 18 U.S.C. S 1591(a)(2 ) *Max. Penalty : Life imprisonmen t Count # : 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORID A PENALTY SHEET INDUCING A MINOR TO ENGAGE IN PROSTITUTION 18 U.S.C. 2422(b ) *\1ax. Penalty : 30 years' imprisonmen t Count # : *1\Iax. Penalty : *Refers only to possible term of incarceration, does not include possible fines, restitution, special assessments, parole terms, or forfeitures that may be applicable.
Case 1:05-cr-20444-PAS Document 50 Entered on FLSD Docket 08/01/2005 Page 8 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORID A PENALTY SHEE T Defendant ' s Name : CHAD YEARBY Case No : 05-20444-CR-Seitz(s ) Count # : 2 SEX TRAFFICKING OF CHILDREN 18 U.S.C. 1591(a)(1 ) * Max. Penalty : Life imprisonmen t Count # : 3 SEX TRAFFICKING OF CHILDRE N 18 U.S.C. 1591(a)(2) *Max. Penalty : Life imprisonment Count # : 5 CONSPIRACY TO TRANSPORT A MINOR FOR PURPOSES OF PROSTITUTION 18 U.S.C. ~ 2423(e ) *M ax. Penalty: 30 years' imprisonmen t Count # : *Max. P enalty : *Refers only to possible term of incarceration, does not include possible fines, restitution, special assessments, parole terms, or forfeitures that may be applicable.