Case 1:19-cr-00286-AMD Document 43 Filed 03/12/20 Page 18 of 23 PageID #: 367
(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.
(Title 18, United States Code, Sections 2422(a), 2 and 3551 et seq.).
COUNT FOUR (Mann Act Coercion of Minor- Jane Doe #5)
41. In or about and between September 2015 and October 2015, within the Eastern District of New York, the Northern District of California and elsewhere, the defendant ROBERT SYLVESTER KELLY, together with others, did knowingly and intentionally persuade, induce, entice and coerce an individual who had not attained the age of 18 years, to wit: Jane Doe #5, to 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, using one or more facilities and means of interstate commerce.
(Title 18, United States Code, Sections 2422(b), 2 and 3551 et seq.)
COUNT FIVE (Mann Act Transportation of Minor - Jane Doe #5)
42. In or about and between September 2015 and October 2015, within the Eastern District ofNew York, the Northern District of California and elsewhere, the defendant ROBERT SYLVESTER KELLY, together with others, did knowingly and 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
