IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Alexandria Division UNITED STATES OF AMERICA

) No. 1:11-CR-526 ) ) Count 1: Conspiracy to Commit ) Forced Labor and Visa Fraud ) (18 U.S.C. § 371) ) ) Counts 2 & 3: Forced Labor and ) Attempted Forced Labor ) (18 U.S.C. § 1589(a)) ) ) Counts 4 & 5: Visa Fraud ) (18 U.S.C. § 1546(a)) ) ) Counts 6 & 7: Unlawful Conduct With ) Respect to Documents in Furtherance of ) Forced Labor ) (18 U.S.C. § 1592) ) ) Count 8: Conspiracy to Harbor and Conceal ) an Alien and to Encourage an Alien to Come ) to the United States ) (8 U.S.C. § 1324(a)(1)(A)(v)(I)) ) ) Counts 9 & 10: Alien Harboring for ) Commercial Advantage and ) Private Financial Gain ) (8 U.S.C. § 1324(a)(1)(A)(iii), (iv) & (B)(i)) ) ) Counts 11-17: False Statements ) (18 U.S.C. § 1001(a)(2)) ) ) Forfeiture Notice

v.

MERVAT MOHAMED FAWZY SALEH TOLAN, a.k.a. “Murvat Tolan” a.k.a. “Mirvat Toulan,” and (counts 1 - 13) NABIL ABDEL KHALEK TALAAT, (counts 1 - 10, 14 - 17) Defendants.

INDICTMENT November 2011Term - At Alexandria

GENERAL ALLEGATIONS THE GRAND JURY CHARGES THAT: Introduction At all times relevant to this Indictment: 1. Defendant MERVAT MOHAMED FAWZY SALEH TOLAN, also known as

“Murvat Tolan,” also known as “Mirvat Toulan,” was a citizen of the Arab Republic of Egypt and had permanent resident status in the United States, and resided at a home on Blackstone Terrace in Vienna, Virginia. MERVAT MOHAMED FAWZY SALEH TOLAN was an employee of Embassy of the United Arab Emirates in Washington, D.C. and was the wife of codefendant NABIL ABDEL KHALEK TALAAT. 2. Defendant NABIL ABDEL KHALEK TALAAT was a citizen of the Arab

Republic of Egypt, had permanent resident status in the United States, and resided at a home on Blackstone Terrace in Vienna, Virginia with his wife and two sons. 3. From at least March 2006 to March 2011, the defendants employed a number of

women who were citizens of nations other than the United States, to serve as housemaids and to nurse and care for the defendants’ son, who was a person with a disability and who was unable to walk without assistance. These women include: a. A citizen of the Republic of Indonesia identified herein as “S.S.,”

who resided at the defendants’ house on Blackstone Terrace and worked for the defendants from on or about March 25, 2006 to on or about March 16, 2009; and b. A citizen of the Republic of Indonesia identified herein as “N.C.,”

who was also the daughter of S.S. and who resided at the defendants’ house on -2-

Blackstone Terrace and worked for the defendants from on or about October 8, 2008 to on or about March 16, 2009. 4. Citizens of certain foreign countries who seek admission to the United States were

required by United States law to obtain a visa prior to entry. United States visas were issued by the U.S. Department of State. 5. An A-3 visa was a visa issued by the U.S. Department of State to attendants,

servants, and personal employees of an ambassador, public minister, or career diplomatic or consular officer of a foreign government.

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COUNT ONE Conspiracy to Commit Forced Labor and Visa Fraud (18 U.S.C. § 371) THE GRAND JURY FURTHER CHARGES THAT: 6. Paragraphs 1 through 5 of this Indictment are specifically re-alleged and

incorporated by reference as if they were fully set forth here. 7. From in and around January 2006 through November 2, 2011, in the Eastern

District of Virginia and elsewhere, the defendants, MERVAT MOHAMED FAWZY SALEH TOLAN and NABIL ABDEL KHALEK TALAAT, did knowingly and unlawfully combine, conspire, and agree with each other and persons known and unknown to the Grand Jury to commit an offense against the United States, namely, to commit the crime of Forced Labor, in violation of Title 18, United States Code, Section 1589, and to commit the crime of Visa Fraud, in violation of Title 18 United States Code, Section 1546(a). Manner and Means of the Conspiracy 8. The purpose of the conspiracy was to obtain the labor and services of the workers

and thereby ensure that, for less than the minimum wage, the defendants enjoyed the consistent labor and services of live-in housemaids and care for their disabled son. The manner and means by which the conspirators conducted the conspiracy included the following: a. countries; b. the defendants exercised control over and isolated the workers by the defendants sought to hire unsophisticated women from Asian

requiring the workers to live in the basement of the defendants’ residence;

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c.

the defendants paid the workers less than the amounts stated in the

written employment contracts, paid less than the minimum and prevailing wage for comparable work, and never paid additional wages for overtime work; d. to obtain U.S. visas for the workers, the defendants would cause

employment contracts to be submitted to the United States Department of State in support of A-3 Visa applications knowing that the workers would never be paid the wages and salary rates specified in the contracts; e. the defendants would induce, instruct, solicit, and encourage the

workers to apply for and obtain A-3 United States visas; f. the defendants imposed rules on some of the workers in an effort to

exercise control over them, to isolate them, and to prevent them from making friends and obtaining assistance from anyone who might have helped them to escape from the defendants, such as: (1) a rule that the S.S. and N.C. not open the door for

anyone other than the defendants and their family members; (2) a rule that S.S. and N.C. speak only the Arabic

language in the defendants’ house; (3) a rule that S.S. and N.C. not leave the defendants’

house, or be outside of the house for an extended period, except when accompanied by the defendants or a member of the defendants’ family;

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(4)

a rule that S.S. and N.C. not speak to the defendants’

neighbors or anyone else not related to the defendants; (5) a rule that S.S. and N.C. not dial the telephone

themselves and that S.S. and N.C. inform the defendants whom they wished to call on the telephone; and (6) a rule that S.S. and N.C. not watch television programs

that used the English language. g. the defendants would attempt to frighten and exercise control over

S.S. and thereby compel S.S. and N.C. to remain with the defendants, by informing S.S. that: (1) if S.S. attempted to leave or go outside the defendants’

house, the police would know and the police would arrest and imprison S.S.; and (2) if S.S. escaped or ran away, the defendants would

report S.S. to the police and the police would catch S.S., put S.S. in jail, and send S.S. back to Indonesia; and h. the defendants would exercise control over S.S. and N.C. by

confiscating and retaining possession of the workers’ passports and the U.S. visas and U.S. I-94 documents contained therein.

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Overt Acts 9. In furtherance of the conspiracy and to effect the objects thereof, the defendants

and their co-conspirators knowingly performed and caused to be performed overt acts in the Eastern District of Virginia and elsewhere. These acts included the following: a. Defendant MERVAT MOHAMED FAWZY SALEH TOLAN paid

a woman whose initials are “NZ” to obtain the labor and services of S.S. b. On or about March 25, 2006, defendant MERVAT MOHAMED

FAWZY SALEH TOLAN picked up S.S. from an airport and drove S.S. to the defendants’ house in Vienna, Virginia. c. On or about March 25, 2006, defendant MERVAT MOHAMED

FAWZY SALEH TOLAN took possession of S.S.’s Indonesian passport and retained possession of it until S.S. obtained a new Indonesian passport. d. On approximately three occasions, after S.S. asked defendant

MERVAT MOHAMED FAWZY SALEH TOLAN to return S.S.’s passport to her, defendant MERVAT MOHAMED FAWZY SALEH TOLAN refused to return S.S.’s Indonesian passport to S.S. e. Defendant MERVAT MOHAMED FAWZY SALEH TOLAN drove

and escorted S.S. to the Indonesian embassy in Washington, D.C. to obtain a new Indonesian passport and defendant MERVAT MOHAMED FAWZY SALEH TOLAN took S.S.’s new passport from S.S. around the same day that S.S. obtained the new passport from the Indonesian embassy.

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f.

Approximately once each week from in and around April 2006 to in

and around July 2008, and approximately three times between in and around August 2008 and on or about March 16, 2009, defendant NABIL ABDEL KHALEK TALAAT repeatedly ordered S.S. to give defendant NABIL ABDEL KHALEK TALAAT massages while he was naked, repeatedly instructed S.S. to masturbate defendant NABIL ABDEL KHALEK TALAAT until he ejaculated, and threatened S.S. not to tell anyone about this. g. Throughout the period she worked for the defendants, the defendants

would frequently yell at, scold, and berate S.S. for, among other things, moving too slowly and for attempting to speak to the neighbors. h. From on or about August 31, 2008 to on or about March 16, 2009, the

defendants required S.S. to work at least fifteen hours each day, seven days per week, with only a single day off, performing such tasks as cleaning the defendants’ home, cooking for the defendants and their family, washing the defendants’ cars, shoveling snow, mowing the lawn, tending the garden, performing yard work, and caring for the defendants’ disabled son. i. On a few occasions between on or about March 25, 2006 and on or

about March 16, 2009, the defendants told S.S. that if she ever escaped, the defendants would call the police, the police would arrest S.S., S.S. would be put in jail, and S.S. would be sent back to Indonesia. j. Between on or about April 2006 and on or about March 16, 2009,

defendant MERVAT MOHAMED FAWZY SALEH TOLAN refused to pay S.S. on a regular basis and only paid S.S. after S.S. repeatedly requested payment. -8-

k.

After S.S. was injured (when she fell down stairs located in the

defendants’ house while she was attempting to carry the defendants’ disabled son), the defendants refused S.S.’s requests for medical treatment. l. Between in and around April 2006 through on or about March 16,

2009, the defendants paid S.S. amounts that were substantially less than the $1,132.80 monthly salary defendant MERVAT MOHAMED FAWZY SALEH TOLAN had promised to pay in the written contract submitted in support of S.S.’s visa application. m. In and around July 2008, when S.S. was preparing to return to

Indonesia to renew her visa and arrange for N.C. to come to the defendants’ house, defendant NABIL ABDEL KHALEK TALAAT promised S.S. that if she returned to work for the defendants the defendants would pay S.S. more money and that S.S. could work at a restaurant the defendants claimed they were planning to open. n. In and around July 2008, defendant MERVAT MOHAMED FAWZY

SALEH TOLAN instructed S.S. to repeatedly sign her name to a form entitled “Proof of Monthly Salary Provided by Mervat Tolan (Employer) And Received by S.S. . . . .” o. In and around July 2008, defendant MERVAT MOHAMED FAWZY

SALEH TOLAN told S.S. to lie to and mislead officials from the U.S. Department of State that, among other things, she was paid consistent with the terms of the contract.

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p.

In and around July 2008, defendant MERVAT MOHAMED FAWZY

SALEH TOLAN told S.S. that if anyone ever asked about S.S.’s wages S.S. should not tell them the amounts that the defendants’ actually paid S.S., instead, S.S. should say that the defendants paid her $1,132.80 per month. q. In and around July 2008, defendant MERVAT MOHAMED FAWZY

SALEH TOLAN gave S.S. contracts to be provided to the Department of State when S.S. reapplied for an A-3 visa in Jakarta, Indonesia. r. In and around August 2008, defendant MERVAT MOHAMED

FAWZY SALEH TOLAN spoke to S.S. over the telephone, while S.S. was in Indonesia, about obtaining a U.S. visa. s. On or about August 31, 2008, defendant MERVAT MOHAMED

FAWZY SALEH TOLAN picked up S.S. from Dulles International Airport and drove her to the defendants’ residence in Vienna, Virginia. t. On or about October 8, 2008, defendant MERVAT MOHAMED

FAWZY SALEH TOLAN picked up N.C. from Dulles International Airport and drove her to the defendants’ residence in Vienna, Virginia. u. On or about October 8, 2008, on the day that N.C. arrived at Dulles

International Airport, defendant MERVAT MOHAMED FAWZY SALEH TOLAN scolded N.C. for having someone call the defendants’ house and MERVAT MOHAMED FAWZY SALEH TOLAN instructed N.C. that she was not allowed to talk to other people.

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v.

On or about October 8, 2008, on the day that N.C. arrived at the

defendants’ residence, defendant MERVAT MOHAMED FAWZY SALEH TOLAN took possession of N.C.’s Indonesian passport and its contents, including the visa issued by the U.S. Department of State, and then told N.C. that she, defendant MERVAT MOHAMED FAWZY SALEH TOLAN, was going to keep the passport. w. From on or about October 8, 2008 to in and around December 2008,

the defendants required N.C. and S.S. to live in a small room in their basement which contained only one bed, resulting in N.C. having to sleep on some blankets on the floor next to the bed. x. Defendant MERVAT MOHAMED FAWZY SALEH TOLAN

instructed N.C. that N.C. was not allowed to leave the defendants’ residence. y. Between on or about October 8, 2008 and on or about March 16,

2009, the defendants required N.C. to work approximately thirteen hours each day, sometimes more, seven days per week, without a single day off, which left N.C. exhausted. z. Defendant NABIL ABDEL KHALEK TALAAT required N.C. to

massage defendant NABIL ABDEL KHALEK TALAAT on several occasions. aa. Beginning approximately one to two weeks after N.C. began working

for the defendants, defendant NABIL ABDEL KHALEK TALAAT began exposing his erect penis to N.C. and defendant NABIL ABDEL KHALEK TALAAT attempted to grope and fondle N.C.’s breasts multiple times.

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bb.

Approximately two to three months after N.C. began working for the

defendants, on approximately three occasions, defendant NABIL ABDEL KHALEK TALAAT held onto N.C. to prevent N.C. from fleeing, forced N.C.’s head to defendant NABIL ABDEL KHALEK TALAAT’s groin, and forced N.C. to perform oral sex on defendant NABIL ABDEL KHALEK TALAAT until he ejaculated. cc. Approximately one week after the second sexual assault, defendant

NABIL ABDEL KHALEK TALAAT again attempted to grab N.C. and force N.C. to perform oral sex, but when N.C. fled defendant NABIL ABDEL KHALEK TALAAT shook his fist at N.C. and angrily yelled something to the effect of “beware.” dd. Defendant NABIL ABDEL KHALEK TALAAT warned N.C. not to

tell anyone what defendant NABIL ABDEL KHALEK TALAAT had done to N.C. ee. The defendants paid S.S. and N.C. less than the amounts promised in

the contracts which the defendants had signed and submitted to the U.S. Department of State. (In violation of Title 18, United States Code, Section 371.)

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COUNTS TWO & THREE Forced Labor and Attempted Forced Labor (18 U.S.C. §§ 1589(a), 1594(a)) THE GRAND JURY FURTHER CHARGES THAT: 10. Paragraphs 1 through 9 of this Indictment are specifically re-alleged and

incorporated by reference as if they were fully set forth here. 11. On or about to and from the dates set forth below, in the Eastern District of

Virginia and elsewhere, defendants MERVAT MOHAMED FAWZY SALEH TOLAN and NABIL ABDEL KHALEK TALAAT, aiding and abetting one another, did knowingly attempt to provide and obtain, and did knowingly provide and obtain, the labor and services of the persons listed below, each person set forth below constituting a separate count of this Indictment: Count 2 3 Victim S.S. N.C. Dates (Around/About) August 31, 2008 to March 16, 2009 October 8, 2008 to March 16, 2009

by threats of serious harm to, and physical restraint against, that person and another person, by means of any scheme, plan, and pattern intended to cause the person to believe that, if the person did not perform such labor and services, that person and another person would suffer serious harm and physical restraint, and by means of the abuse and threatened abuse of law and the legal process. (In violation of Title 18, United States Code, Sections 1589(a) (2008), 1594(a), and 2.)

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COUNTS FOUR & FIVE VISA FRAUD (18 U.S.C. § 1546(a)) THE GRAND JURY FURTHER CHARGES THAT: 12. Paragraphs 1 through 11 of this Indictment are specifically re-alleged and

incorporated by reference as if they were fully set forth here. 13. On or about August 1, 2008, in the Eastern District of Virginia and elsewhere,

defendants MERVAT MOHAMED FAWZY SALEH TOLAN and NABIL ABDEL KHALEK TALAAT, aiding and abetting one another, did knowingly and willfully aid, abet, counsel, command, induce, and procure another person to utter, use, attempt to use, possess, obtain, accept, and receive an immigrant visa, namely an A-3 visa, for entry into the United States and as evidence of authorized stay and employment in the United States, knowing that the A-3 visa had been procured by means of false claims and statements, and to have been otherwise procured by fraud and unlawfully obtained, each visa recipient set forth below constituting a separate count of this Indictment: Count 4 5 Visa Recipient S.S. N.C.

(In violation of Title 18, United States Code, Sections 1546(a) and 2.)

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COUNTS SIX & SEVEN UNLAWFUL CONDUCT WITH RESPECT TO DOCUMENTS IN FURTHERANCE OF FORCED LABOR (18 U.S.C. § 1592) THE GRAND JURY FURTHER CHARGES THAT: 14. Paragraphs 1 through 13 of this Indictment are specifically re-alleged and

incorporated by reference as if they were fully set forth here. 15. On or about to and from the dates set forth below, in the Eastern District of

Virginia and elsewhere, defendants MERVAT MOHAMED FAWZY SALEH TOLAN and NABIL ABDEL KHALEK TALAAT, aiding and abetting one another, attempted to and did knowingly conceal, remove, confiscate, and possess the actual and purported passport and other immigration documents of the person listed below, in the course of a violation and with the intent to violate Title 18, United States Code, Section 1589, and to prevent and restrict and attempt to prevent and restrict, without lawful authority, the liberty to move and travel of the person listed below, in order to maintain the labor and services of the person listed below, when the person listed below was a victim of a severe form of trafficking in persons, each person set forth below constituting a separate count of this Indictment: Count 6 7 Victim S.S. N.C. Dates (Around/About) August 31, 2008 to March 16, 2009 October 8, 2008 to March 16, 2009

(In violation of Title 18, United States Code, Sections 1589(a), 1592(a), and 2.)

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COUNT EIGHT CONSPIRACY TO CONCEAL AND HARBOR AN ALIEN AND TO INDUCE AN ALIEN TO COME TO THE UNITED STATES (8 U.S.C. § 1324(a)(1)(A)(v)(I)) THE GRAND JURY FURTHER CHARGES THAT: 16. Paragraphs 1 through 15 of this Indictment are specifically re-alleged and

incorporated by reference as if they were fully set forth here. 17. An alien whose visa was procured by fraud or misrepresentation of a material fact

is inadmissible and such alien’s presence in the United States is unlawful and in violation of law. 18. From in and around March 2006 to on or about November 2, 2011, in Fairfax

County, in the Eastern District of Virginia and elsewhere, the defendants, MERVAT MOHAMED FAWZY SALEH TOLAN and NABIL ABDEL KHALEK TALAAT, knowingly and unlawfully did conspire with each other and with persons known and unknown to the Grand Jury: (1) to conceal, harbor, and shield from detection in the defendants’ house an alien, knowing and in reckless disregard of the fact that such alien remained in the United States in violation of law, and (2) to encourage and induce an alien to come to, enter, and reside in the United Sates, knowing and in reckless disregard of the fact that such coming to, entry, and residence is and will be in violation of law. (In violation of Title 8, United States Code, Sections 1324(a)(1)(A)(v)(I) & (B)(i).)

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COUNTS NINE & TEN HARBORING AND INDUCING AN ALIEN TO COME TO THE UNITED STATES (8 U.S.C. § 1324(a)(1)(A)(iii), (iv), & (B)(i)) THE GRAND JURY FURTHER CHARGES THAT: 19. Paragraphs 1 through 18 of this Indictment are specifically re-alleged and

incorporated by reference as if they were fully set forth here. 20. From in or about March 2006 to on or about November 2, 2011, in Fairfax

County, in the Eastern District of Virginia and elsewhere, the defendants, MERVAT MOHAMED FAWZY SALEH TOLAN and NABIL ABDEL KHALEK TALAAT, aiding and abetting one another, for purposes of commercial advantage and private financial gain, did (1) conceal, harbor, and shield from detection, and attempted to conceal, harbor, and shield from detection, an alien listed below, in the defendants’ house, knowing and in reckless disregard of the fact that such alien had come to, entered, and remained in the United States in violation of law, and did (2) encourage and induce an alien listed below to come to, enter, and reside in the United States, knowing and in reckless disregard of the fact that such coming to, entry, and residence is and will be in violation of law, each alien set forth below constituting a separate count of this Indictment: Count 9 10 Alien S.S. N.C. Dates (Around/About) August 31, 2008 to March 16, 2009 October 8, 2008 to March 16, 2009

(In violation of Title 8, United States Code, Sections 1324(a)(1)(A)(iii), (iv), and (B)(i), and Title 18, United States Code, Section 2.)

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COUNTS ELEVEN - THIRTEEN FALSE STATEMENTS TO A FEDERAL AGENT (18 U.S.C. § 1001(a)) THE GRAND JURY FURTHER CHARGES THAT: 21. Paragraphs 1 through 5 of this Indictment are specifically re-alleged and

incorporated by reference as if they were fully set forth here. 22. On or about December 10, 2010, in Fairfax County, in the Eastern District of

Virginia and elsewhere, in a matter within the jurisdiction of the executive branch of the Government of the United States, defendant MERVAT MOHAMED FAWZY SALEH TOLAN knowingly did make materially false, fictitious and fraudulent statements and representations to a Special Agent of the U.S. Department of State, in connection with a criminal investigation, and each statement and representation set forth below constituting a separate count of this Indictment: Count 11 False Declaration/Statement Defendant MERVAT MOHAMED FAWZY SALEH TOLAN always paid S.S. more than $400 per month. S.S. did not work after 5:00 p.m. while S.S. was employed by the defendants. S.S. had possession of S.S.’s passport the entire time that S.S. lived at the defendants’ residence. The Truth Defendant MERVAT MOHAMED FAWZY SALEH TOLAN sometimes paid S.S. less than $400 per month. S.S. frequently worked after 5:00 p.m. while S.S. was employed by the defendants. Defendant MERVAT MOHAMED FAWZY SALEH TOLAN took possession and maintained custody of S.S.’s passport while S.S. lived at the defendants’ residence.

12

13

(In violation of Title 18, United States Code, Section 1001(a)(2).)

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COUNTS FOURTEEN - SEVENTEEN FALSE STATEMENTS TO A FEDERAL AGENT (18 U.S.C. § 1001(a)(2)) THE GRAND JURY FURTHER CHARGES THAT: 23. Paragraphs 1 through 5 of this Indictment are specifically re-alleged and

incorporated by reference as if they were fully set forth here. 24. On or about December 10, 2010, in Fairfax County, in the Eastern District of

Virginia and elsewhere, in a matter within the jurisdiction of the executive branch of the Government of the United States, defendant NABIL ABDEL KHALEK TALAAT knowingly did make materially false, fictitious and fraudulent statements and representations to a Special Agent of the U.S. Department of State, in connection with a criminal investigation, and each statement and representation set forth below constituting a separate count of this Indictment: Count 14 False Declaration/Statement Defendant NABIL ABDEL KHALEK TALAAT never performed any sex acts with N.C. The Truth Defendant NABIL ABDEL KHALEK TALAAT forced N.C. to perform oral sex on defendant NABIL ABDEL KHALEK TALAAT. Defendant NABIL ABDEL KHALEK TALAAT frequently instructed S.S. to massage him. Defendant MERVAT MOHAMED FAWZY SALEH TOLAN took possession and maintained custody of S.S.’s passport while S.S. lived at the defendants’ residence.

15

Defendant NABIL ABDEL KHALEK TALAAT never asked or told S.S. to massage him. S.S. had possession of her own passport the entire time that S.S. lived at the defendants’ residence.

16

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17

After S.S. fell and struck her head on a wall, S.S. told defendant NABIL ABDEL KHALEK TALAAT that she was fine and S.S. declined to go to the hospital.

After S.S. fell and struck her head on a wall, S.S. asked defendant NABIL ABDEL KHALEK TALAAT to obtain medical attention for S.S. because S.S. was injured.

(In violation of Title 18, United States Code, Section 1001(a)(2).)

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CRIMINAL FORFEITURE NOTICE Pursuant to Rule 32.2(a) of the Federal Rules of Criminal Procedure, Section 982(a)(6)(A) of Title 18, and Section 1594(d) of Title 18, the defendants are hereby notified that, upon conviction of any of the offenses charged in Counts One through Three and Counts Nine through Eleven of this Indictment, the defendants shall forfeit to the United States any property, real or personal that, among other things: (1) constitutes, or is derived from, or is traceable to, the proceeds obtained directly or indirectly from the commission of the offenses; or (2) was used to facilitate, or was intended to be used to facilitate, the commission of the offenses. Pursuant to Title 21, United States Code, Section 853(p), as incorporated by Title 18, United States Code, Section 982(b), the defendants shall forfeit substitute property, if, by any act or omission of the defendants, the property described above, or any portion thereof, cannot be located upon the exercise of due diligence; has been transferred, sold to, or deposited with a third party; has been placed beyond the jurisdiction of the Court; has been substantially diminished in value; or has been commingled with other property which cannot be divided without difficulty. (Pursuant to Title 18, United States Code, Sections 982(a)(6) and 1594(d).)

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A TRUE BILL

_____________________________ FOREPERSON

Neil H. MacBride United States Attorney

Michael J. Frank Special Assistant United States Attorney __________________________ G. Zachary Terwilliger Assistant United States Attorney

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