Case 1:19-cr-00286-AMD Document 43 Filed 03/12/20 Page 13 of 23 PageID #: 362
intentionally transport an individual who had not attained the age of 18 years, to wit: Jane Doe #5, in interstate commerce, with intent that such individual engage in sexual activity for which a person can be charged with a criminal offense, to wit: violations of California Penal Law Sections 261.5(a) and 261.5(b) (unlawful sexual intercourse with a person under 18 years old), in that KELLY engaged in sexual intercourse with Jane Doe #5 who was under 18 years old, while he was more than three years older than Jane Doe #5, in violation of Title 18, United States Code, Sections 2423(a) and 2.
Racketeering Act Ten (Sexual Exploitation of a Child- Jane Doe #5)
30. In or about and between September 2015 and December 30, 2015, both dates being approximate and inclusive, within the Northern District of California, the Northern District of Illinois and elsewhere, the defendant ROBERT SYLVESTER KELLY, together with others, did knowingly and intentionally employ, use, persuade, induce, entice and coerce a minor, to wit: Jane Doe #5, to engage in sexually explicit conduct for the purpose of producing one or more visual depictions of such conduct, which visual depictions were produced using materials that had been mailed, shipped and transported in and affecting interstate and foreign commerce, in violation of Title 18, United States Code, Sections 2251(a), 2251(e) and 2.
Racketeering Act Eleven (Forced Labor - Jane Doe #5)
31. In or about and between April 2015 and December 2018, both dates being approximate and inclusive, within the Northern District of Georgia, the Northern District of Illinois and elsewhere, the defendant ROBERT SYLVESTER KELLY, together with others, did knowingly and intentionally obtain the labor and services of a person, to wit:
