IN
THE
UNITED STATES
DISTRICT COURT FOR THE WESTERN DISTRICT
OF TEXAS
SAN
ANTONIO DIVISION UNITED STATES
OF
AMERICA, Plaintiff,
V.
2013
OCT
2
TiJ
10:
59
§
CRIMINAL
NO.
IINDICTM.J44T
§
[Violation:
18
U.S.C.1591(a),
§
Sex
Trafficking
of
Children,
§
-
Count
1]
MARCUS DESHAWN
WRIGHT
(1), §
MALCOLM
DEANDRE COPELAND
(2),
§
ArvIBER
DOAK
(3),
§
....
.
......
-.
:.
§
Defendants.
§
THE GRAND JURY CHARGES:
COUNT
ONE
[18
U.S.C.
§
1591(a)]
That
on
or
about the
24th
day
of
August,
2013,
within the Western District
of
Texas, the
Defendants,
MARCUS DESHAWN
WRIGHT, MALCOLM
DEANDRE COPELAND,
and
AMBER
DOAK
did knowingly,
in
and
affecting interstate
and foreign commerce, recruit, entice, harbor, transport,
provide, obtain
and
maintain, by
any
means
a
person, that
is
T.J., knowing,
and in
reckless
disregard
of
the fact,
that
T.J.
had not attained 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)
and
159
1(b)(2).
ROBERT PITMAN UNITED TAFES
ATTOR1EY
BY:
I
/
Assistant United
States
Attorney
Case 5:13-cr-00806-FB Document 31 Filed 10/02/13 Page 1 of 1
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