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Case Document 23 Filed 10/07/15 Page 1 of 6
UNITED STATES OF AMERICA Criminal No. 3: 15-CR-196 (TJM)
v. Superseding Indictment (SI)
a/k/a ?Tone?,
Violations: 18 U.S.C. 1591(a)(1),
(C)
Traf?cking Of A Child]
18 U.S.C. 1591(a)(2),
1). (C) [Sex
Traf?cking Of A Child]
18 U.S.C. 2422(1))
[Persuading And Inducing A
Child To Engage ln
Prostitution]
9 Counts
Defendant. County of Offense: Broome
COUNT 1
[Sex Traf?cking Child]
From in or about August of 2014 through in or about December of 2014, in Broome
County in the Northern District of New York and elsewhere, defendant ANTONIO T.
BALLARD knowingly, in and affecting interstate commerce, recruited, enticed, harbored,
transported, provided, obtained, and maintained by any means a person with the initials, T. M., a
minor under the age of 18, knowing and in reckless disregard of the fact that means of force,
threats of force and coercion and a combination of such means would be used to cause T.M. to
Case Document 23 Filed 10/07/15 Page 2 of 6
engage in a commercial sex act; knowing and in reckless disregard of the fact that T.M. would be
caused to engage in a commercial sex act; knowing and in reckless disregard of the fact that
T.M. had not attained the age of 18 years; and having had had a reasonable opportunity to
observe T.M., in violation of Title 18, United States Code, Sections 1591(a)(1) That
violation was effected by means of force, threats of force, and coercion, in violation of Title 18,
United States Code, Section 1591(b)(1) and the person recruited, enticed, harbored, transported,
provided, and obtained had attained the age of 14 years, but had not attained the age of 18 years
at the time of the offence, in violation of Title 18, United States Code, Section 1591(b)(2).
COUNT 2
[Sex Trafficking Of A Child]
From in or about August of 2014 through in or about December of 2014, in Broome
County in the Northern District of New York and elsewhere, defendant ANTONIO T.
BALLARD knowingly bene?tted, ?nancially and by receiving a thing of value, from
participation in a venture which had engaged in an act described in violation of Title 18, United
States Code, Section 1591(a)(l) knowing and in reckless disregard of the fact that means of
force, threats of force and coercion and a combination of such means would be used to cause
T.M. to engage in a commercial sex act; knowing and in reckless disregard of the fact that T.M.
would be caused to engage in a commercial sex act; knowing and in reckless disregard of the fact
that T.M. had not attained the age of 18 years; and having had had a reasonable opportunity to
observe T.M., in violation of Title 18, United States Code, Sections 1591(a)(2) That
violation was effected by means of force, threats of force, and coercion, in violation of Title l8,
United States Code, Section 1591(b)( 1) and the person recruited, enticed, harbored, transported,
provided, and obtained had attained the age of 14 years, but had not attained the age of 18 years
at the time of the offence, in violation of Title 18, United States Code, Section 1591(b)(2).
Case Document 23 Filed 10/07/15 Page 3 of 6
COUNT 3
[Persuading And Inducing A Child To Engage In Prostitution]
From in or about August of 2014 through in or about December of 2014, in Broome
County in the Northern District of New York and elsewhere, defendant ANTONIO T.
BALLARD, while using a means and facility of interstate commerce, knowingly persuaded,
induced, enticed, and coerced an individual who had not attained the age of 18 years, that is
T.M., to engage in prostitution, in violation of Title 18, United States Code, Section 2422(b).
COUNT 4
[Sex Traf?cking Of A Child]
From in or about September of 2014 through in or about December of 2014, in Broome
County in the Northern District of New York and elsewhere, defendant ANTONIO T.
BALLARD knowingly, in and affecting interstate commerce, recruited, enticed, harbored,
transported, provided, obtained, and maintained by any means a person with the initials, A.W., a
minor under the age of 18, knowing and in reckless disregard of the fact that A.W. would be
caused to engage in a commercial sex act; knowing and in reckless disregard of the fact that
A.W. had not attained the age of 18 years; and having had had a reasonable opportunity to
observe A.W., in violation of Title 18, United States Code, Sections 1591(a)(1) The
person recruited, enticed, harbored, transported, provided, and obtained had attained the age of
14 years, but had not attained the age of 18 years at the time of the offence, in violation of Title
18, United States Code, Section 1591(b)(2). i
COUNT 5
[Sex Traf?cking Of A Child]
From in or about September of 2014 through in or about December of 2014, in Broome
County in the Northern District of New York and elsewhere, defendant ANTONIO T.
BALLARD knowingly bene?tted, ?nancially and by receiving a thing of value, from
Case Document 23 Filed 10/07/15 Page 4 of 6
participation in a venture which had engaged in an act described in violation of Title 18, United
States Code, Section 159l(a)(l) knowing and in reckless disregard of the fact that A.W. would
be caused to engage in a commercial sex act; knowing and in reckless disregard of the fact that
A.W. had not attained the age of 18 years; and having had had a reasonable opportunity to
observe A.W., in violation of Title 18, United States Code, Sections lS9l(a)(2) The
person recruited, enticed, harbored, transported, provided, and obtained had attained the age of
14 years, but had not attained the age of 18 years at the time of the offence, in violation of Title
18, United States Code, Section lS9l(b)(2).
COUNT 6
[Persuading And Inducing A Child To Engage [n Prostitution]
From in or about September of 2014 through in or about December of 2014, in Broome
County in the Northern District of New York and elsewhere, defendant ANTONIO T.
BALLARD, while using a means and facility of interstate commerce, knowingly persuaded,
induced, enticed, and coerced an individual who had not attained the age of 18 years, that is
A.W., to engage in prostitution, in violation of Title 18, United States Code, Section 2422(1)).
COUNT 7
[Sex Trafficking Child]
From in or about September of 2014 through in or about December of 2014, in Broome
County in the Northern District of New York and elsewhere, defendant ANTONIO T.
BALLARD knowingly, in and affecting interstate commerce, recruited, enticed, harbored,
transported, provided, obtained, and maintained by any means a person with the initials, A.G., a
minor under the age of 18, knowing and in reckless disregard of the fact that A.G. would be
caused to engage in a commercial sex act; knowing and in reckless disregard of the fact that A.G.
had not attained the age of 18 years; and having had had a reasonable opportunity to observe
Case Document 23 Filed 10/07/15 Page 5 of 6
AG, in violation of Title 18, United States Code, Sections 1591(a)(1) The person
recruited, enticed, harbored, transported, provided, and obtained had attained the age of 14 years,
but had not attained the age of 18 years at the time of the offence, in violation of Title 18, United
States Code, Section 159l(b)(2).
COUNT 8
[Sex Traf?cking Child]
From in or about September of 2014 through in or about December of 2014, in Broome
County in the Northern District of New York and elsewhere. defendant ANTONIO T.
BALLARD knowingly benefitted, ?nancially and by receiving a thing of value, from
participation in a venture which had engaged in an act described in violation of Title 18, United
States Code, Section 1591(a)(1) knowing and in reckless disregard of the fact that A.G. would be
caused to engage in a commercial sex act; knowing and in reckless disregard of the fact that AC.
had not attained the age of 18 years; and having had had a reasonable opportunity to observe
A.G., in violation of Title 18, United States Code, Sections 1591(a)(2) The person
recruited, enticed, harbored, transported, provided, and obtained had attained the age of 14 years,
but had not attained the age of 18 years at the time of the offence, in violation of Title 18, United
States Code, Section 1591(b)(2).
COUNT 9
[Persuading And Inducing A Child To Engage ln Prostitution]
From in or about September of 2014 through in or about December of 2014, in Broome
County in the Northern District of New York and elsewhere, defendant ANTONIO T.
BALLARD, while using a means and facility of interstate commerce, knowingly persuaded,
induced, enticed, and coerced an individual who had not attained the age of 18 years, that is
A.G., to engage in prostitution, in violation of Title 18, United States Code, Section 2422(b).
Case Document 23 Filed 10/07/15 Page 6 of 6
Dated: October 7, 2015
A TRUE BILL,
Grand ry,
United States Attorney
By: WV
Miros?fav Lovric
Assistant United States Attorney
Bar Roll No. 301490