Amended Criminal Complaint

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JUSTICE COURT, LAS VEGAS TOWNSHIP

CLARK COUNTY, NEVADA
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THE STATE OF NEVADA,
Plaintiff,
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CASE NO:
15F09138X
DEPT NO:
-vsBINH MINH CHUNG, aka,

Ben Minh Chung #1136698,
AMENDED
CRIMINAL COMPLAINT
Defendant.
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The Defendant above named having committed the crimes of USE OF MINOR IN
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PRODUCING PORNOGRAPHY (Category A Felony - NRS 200.700, 200.710.1, 200.750 -
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NOC 50367); POSSESSION OF VISUAL PRESENTATION DEPICTING SEXUAL
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CONDUCT OF A CHILD (Category B Felony - NRS 200.700, 200.730 - NOC 50374);
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SEXUAL ASSAULT (Category A Felony - NRS 200.364, 200.366 - NOC 50095); OPEN OR
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GROSS
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ADMINISTRATION OF DRUG TO AID COMMISSION OF A FELONY (Category B
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Felony - NRS 200.405 - NOC 50170), in the manner following, to-wit: That the said
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Defendant, on or between January 1, 2013 and June 4, 2015, at and within the County of Clark,
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State of Nevada,
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COUNT 1 - USE OF MINOR IN PRODUCING PORNOGRAPHY
LEWDNESS
(Gross
Misdemeanor
NRS
201.210
NOC
50971);
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did on or between January 1, 2013 and September 30, 2014 wilfully, unlawfully,
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feloniously, and knowingly, use, encourage, entice or permit A.K., a minor under the age of
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18, to simulate or engage in, or assist others to simulate or engage in sexual conduct, to-wit:
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exposing the said A.K.'s breasts and/or kissing or fondling the said A.K.'s breasts, thereafter
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Defendant touching and/or rubbing and/or fondling the said A.K.'s genital area over her
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clothes, for the purpose of producing a pornographic performance.
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H:\MEDIA REQUESTS\CRIMINAL COMPLAINTS\CHUNG, BINH-AMENDED-15F09138.DOCX
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COUNT 2 - POSSESSION OF VISUAL PRESENTATION DEPICTING SEXUAL

CONDUCT OF A CHILD
did on or about June 4, 2015 wilfully, unlawfully, feloniously, and knowingly have in
his possession a film, photograph, or other visual presentation depicting a child under the age
of 16 years of age as the subject of a sexual portrayal or engaging in, simulating, or assisting
others to engage in or simulate sexual conduct, to-wit: a video 7 minutes and 8 seconds in
length depicting a compilation of children that were obviously prepubescent, as they were
forced to perform oral sex on adult males until the male ejaculated into their faces and/or
mouths. Children were prepubescent based on they were small in stature, had small features,
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and body parts like the breasts of females appearing undeveloped. They also had lack of hair
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on their bodies or pubic areas. The children fought, winced, and in many shots attempting to
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turn away from the adult males. In an attempt to count what seemed like endless amounts of
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children being orally assaulted. There were approximately 49 children in the compilation.
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None of the adult males in the compilation were identified.
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CONDUCT OF A CHILD
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others to engage in or simulate sexual conduct, to-wit: a video 11 minutes and 25 seconds long
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depicting an adult male in gray sweats standing over a prepubescent. The male pulled down
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his pants and the child began to suck his penis. The child turning away and male pulled his
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back towards him and reinserted his penis into her mouth. The child looked up at the male as
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if he gained her attention somehow. After being attentive to something he was saying for a
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moment, the child began to massage the adult's scrotum. At approximately 2 minutes and 25
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seconds, the scene switches to the child standing on a bed. She becomes attentive as if
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receiving instruction prior to pulling down her pants becoming nude from the waist down. She
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began to masturbate, rubbing her genital area for a brief moment before pulling her pants up
in a hurry in an obvious complaint. She appears to be instructed to remove her pants once
more and does so. The juvie bent over and shoved an object into her anus for minutes. At 6
minutes the scene switches to the child sucking the same male's penis again. She sucks his
penis for 1 minute and 21 seconds. At 7 minutes the scene switches to a nude shot of the child's
buttocks. At 8 minutes the male begins to penetrate the child's anal opening. At 8 minutes and
38 seconds the male begins to hold and touch the child with his left hand while rubbing his
penis with his right hand. At 10 minutes 20 seconds the male penetrates the child's anus with
his penis.

CONDUCT OF A CHILD
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depicting a prepubescent female being led into a dim room. She has long brown hair and is
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wearing a white outfit worn by small children and babies called "onesie." The child is lead by
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a heavy set adult male wearing dark sweats. The child is thrown onto a bed that has sheets
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with red and white stripes. The child removes her clothes. Both the adult and the child appear
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to be nude except for the mask the male is wearing. At 2 minutes the child begins to
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masturbate. At 2 minutes 18 seconds the male still nude, leads the nude child into a restroom
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and films her as she urinates. At 2 minutes 55 seconds, the male performs oral sex, licking the
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child's genital area. At 3 minutes and 40 seconds the male sucks the breasts of the child and
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kisses her mouth. Both are still nude. At 4 minutes and 43 seconds, the child is seen rubbing
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the adult male's penis. At 5 minutes and 2 seconds the child is on her knees sucking the male's
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penis. The male begins to aggressively penetrate the child's mouth by humping against her
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face. At 5 minutes and 46 seconds the male repositions the child and penetrates her genital
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opening with his penis. At 7 minutes and 14 seconds, the male uses some kind of lubricant on
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the child. At 8 minutes and 53 seconds the child is seen performing oral sex again. At 10
minutes 4 seconds, the child turns over onto her stomach and the male penetrates her genital
opening. At 10 minutes 55 seconds the child performs oral sex on the male again.

CONDUCT OF A CHILD
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and has a title called "Preteen Toy Story" depicting a tutorial for fathers on how to use
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"everyday items" as a sex toy for "your preteen daughter." It concludes the introduction by
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saying "all of these toys can be used in your girl's pussy or ass." The video presents lubricant,
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a "proper digital camera" and a camcorder as essential items. At 30 seconds the video goes
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into detail to forewarn fathers, "if you play with your daughter's pussy, it will turn red for a
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while.", "make sure your wife is not planning to bathe your daughter right after you had sex
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with her." The tutorial continues, to explain how there is a graduation of household items. For
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example the video suggests using thermometers for infants and graduating to pacifiers and
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bottles. Each instruction had an illustration. For example, when it was explained that a father
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should graduate from thermometers to pacifiers and bottles, there were photos of a crying baby
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with thermometers and pacifiers shoved into her genital and anal opening. Other items
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suggested and illustrated in this manner were enima bulbs, pencils, pens, markers, cigar tubes
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and a banana at 3 minutes and 11 seconds with an 8 year old girl.
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CONDUCT OF A CHILD
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others to engage in or simulate sexual conduct, to-wit: a video 5 minutes and 1 second
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depicting a prepubescent girl lying face down while an adult male rubs his penis against her
anal and genital opening. At 1 minute and 10 seconds he tries to penetrate her anal opening
with his penis, but ultimately penetrates the child's anal opening with his fingers. At 4 minutes
and 19 seconds the male begins to forcefully shove his penis into the child's mouth.

CONDUCT OF A CHILD
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with a title called "Mossi 11 year old Dad says "I come first." The video depicts a prepubescent
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girl lying on a bed completely nude. The video focusses on the child's genitals. At 48 seconds,
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a male fondles the child's genitals while she sucks his penis. At 1 minute 52 seconds the male
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positions himself between the child's legs and penetrates her genital opening with his penis.
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This lasts for two minutes while the child winces and contorts her face in obvious pain. At 5
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minutes and 8 seconds the male digitally penetrates the child's genital opening who appears to
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be in even more pain and begins to panic and push away. At 7 minutes and 47 seconds the
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suspect penetrates the child's genital opening again despite her reactions and humps her for
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the remainder of the video.
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CONDUCT OF A CHILD
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depicting an elementary aged girl. After 8 seconds she is instructed to remove her underwear.
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The female is hairless and undeveloped. She is obviously a child. After 12 minutes of posing
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and spreading her legs to reveal her genitals in different poses, the adult male begins to rub his
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penis against the child's genital opening. At 15 minutes and 22 seconds, the male ejaculates
all over the child's pelvis, stomach and genitals. The video zooms in on the child's genitals
now covered in semen which is dripping onto the floor.

CONDUCT OF A CHILD
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others to engage in or simulate sexual conduct, to-wit: a video 3 minutes and 36 seconds
depicting a prepubescent child. The child in the video immediately disrobes revealing herself
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to be a very young girl. At 28 seconds an adult male bounds the child's breasts causing
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discoloration. At 50 seconds the child was bound to beams from a low ceiling. At 2 minutes
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and 8 seconds the scene changes to the child now bound to a bench. She is bound at her thighs,
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waist, and her upper arms are bound over her shoulders. The male is now nude from the waist
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down. The male twists the child's nipples and fondles her genital area. At 3 minutes and 2
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seconds, the male straddles the child's face and begins to forcefully dip his penis into her
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mouth. He then masturbates while dipping his scrotum into the child's mouth.
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CONDUCT OF A CHILD
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others to engage in or simulate sexual conduct, to-wit: a video 1 minute and 36 seconds
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depicting two prepubescent children. They are in a bed together occasionally appearing to
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become attentive to someone off camera. The male lies on top of the female and shoves his
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genitalia against hers. Female then turns onto her stomach and spreads her buttocks while the
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male shoves his genitalia into them.
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///
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///
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CONDUCT OF A CHILD
others to engage in or simulate sexual conduct, to-wit: a video depicting two prepubescent
girls completely nude. One child is holding an object in place while the other child moves up
and down moving the object into and out of her genital opening. At 1 minute and 11 seconds
the children change roles. At 2 minutes and 15 seconds, the scene changes and a child is
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sucking an adult male's penis until the end of the video.
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COUNT 12 SEXUAL ASSAULT
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did then and there willfully, unlawfully, and feloniously sexually assault and subject
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H.K., a female person, to sexual penetration, to-wit: sexual intercourse: by placing his penis
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into the genital opening of the said H.K., against her will, or under conditions in which
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Defendant knew, or should have known, that H.K. was mentally or physically incapable of
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resisting or understanding the nature of Defendants conduct.
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COUNT 15 ADMINISTRATION OF DRUG TO AID COMMISSION OF FELONY
did, between January 1, 2015 and June 1, 2015, then and there willfully, unlawfully,
feloniously, and knowingly administer to H.K., a controlled substance, anesthetic, or
intoxicating agent, to-wit: Ketamine and/or an unknown substance, with the intent thereby to
enable or assist himself to commit a felony, to-wit: sexual assault.
COUNT 16 OPEN OR GROSS LEWDNESS
did then and there willfully and unlawfully and feloniously commit an act of open or
gross lewdness by grabbing and/or groping the breasts of A.K.
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feloniously, and knowingly administer to A.K., a controlled substance, anesthetic, or
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feloniously, and knowingly administer to L.R., a controlled substance, anesthetic, or
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feloniously, and knowingly administer to C.N., a controlled substance, anesthetic, or
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feloniously, and knowingly administer to L.R., a controlled substance, anesthetic, or
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did, between October 1, 2015 and December 31, 2014, then and there willfully,
unlawfully, feloniously, and knowingly administer to H.C., a controlled substance, anesthetic,
or intoxicating agent, to-wit: Ketamine and/or an unknown substance, with the intent thereby
to enable or assist himself to commit a felony, to-wit: sexual assault.
unlawfully, feloniously, and knowingly administer to C.G., a controlled substance, anesthetic,
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unlawfully, feloniously, and knowingly administer to C.G., a controlled substance, anesthetic,
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unlawfully, feloniously, and knowingly administer to S.H., a controlled substance, anesthetic,
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unlawfully, feloniously, and knowingly administer to L.M., a controlled substance, anesthetic,
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unlawfully, feloniously, and knowingly administer to I.S., a controlled substance, anesthetic,

unlawfully, feloniously, and knowingly administer to L.T., a controlled substance, anesthetic,
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unlawfully, feloniously, and knowingly administer to P.V., a controlled substance, anesthetic,
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All of which is contrary to the form, force and effect of Statutes in such cases made and
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provided and against the peace and dignity of the State of Nevada. Said Complainant makes
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this declaration subject to the penalty of perjury.
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08/04/15
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15F09138X/jm/SVU
LVMPD EV# 1506043283
(TK1)
CASE HISTORY
SUBMITTING DETECTIVE:
S. TAYLOR #8718
(TK1)
JC CASE NO.
15F09138X
DATES OF
OFFENSE:
On or between
07/01/14 - 06/04/15
06/22/15
CC:
AGENCY:
LVMPD
DC CASE NO.
DR#/CIT#
1506043283
GJ CASE NO.
DEFENDANT(S):
BINH MINH CHUNG, aka, Ben Minh Chung #1136698
CHARGES:
USE OF MINOR IN PRODUCING PORNOGRAPHY (Category A Felony - NRS

200.700, 200.710.1, 200.750 - NOC 50367) and POSSESSION OF VISUAL
PRESENTATION DEPICTING SEXUAL CONDUCT OF A CHILD (Category B
Felony - NRS 200.700, 200.730 - NOC 50374)
DATE
DEPT.
ATTY.
REMARKS
ARRESTED 06/20/15

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1

JUSTICE COURT, LAS VEGAS TOWNSHIP

THE STATE OF NEVADA,

-vsBINH MINH CHUNG, aka,

PRODUCING PORNOGRAPHY (Category A Felony - NRS 200.700, 200.710.1, 200.750 -

NOC 50367); POSSESSION OF VISUAL PRESENTATION DEPICTING SEXUAL

CONDUCT OF A CHILD (Category B Felony - NRS 200.700, 200.730 - NOC 50374);

ADMINISTRATION OF DRUG TO AID COMMISSION OF A FELONY (Category B

COUNT 1 - USE OF MINOR IN PRODUCING PORNOGRAPHY

clothes, for the purpose of producing a pornographic performance.

COUNT 2 - POSSESSION OF VISUAL PRESENTATION DEPICTING SEXUAL

None of the adult males in the compilation were identified.

COUNT 3 - POSSESSION OF VISUAL PRESENTATION DEPICTING SEXUAL

COUNT 4 - POSSESSION OF VISUAL PRESENTATION DEPICTING SEXUAL

COUNT 5 - POSSESSION OF VISUAL PRESENTATION DEPICTING SEXUAL

and a banana at 3 minutes and 11 seconds with an 8 year old girl.

COUNT 6 - POSSESSION OF VISUAL PRESENTATION DEPICTING SEXUAL

COUNT 7 - POSSESSION OF VISUAL PRESENTATION DEPICTING SEXUAL

the remainder of the video.

COUNT 8 - POSSESSION OF VISUAL PRESENTATION DEPICTING SEXUAL

now covered in semen which is dripping onto the floor.

COUNT 9 - POSSESSION OF VISUAL PRESENTATION DEPICTING SEXUAL

COUNT 10 - POSSESSION OF VISUAL PRESENTATION DEPICTING SEXUAL

male shoves his genitalia into them.

COUNT 11 - POSSESSION OF VISUAL PRESENTATION DEPICTING SEXUAL

sucking an adult male's penis until the end of the video.

COUNT 12 SEXUAL ASSAULT

resisting or understanding the nature of Defendants conduct.

COUNT 13 SEXUAL ASSAULT

resisting or understanding the nature of Defendants conduct.

COUNT 14 SEXUAL ASSAULT

resisting or understanding the nature of Defendants conduct.

COUNT 15 ADMINISTRATION OF DRUG TO AID COMMISSION OF FELONY

feloniously, and knowingly administer to H.K., a controlled substance, anesthetic, or

enable or assist himself to commit a felony, to-wit: sexual assault.

COUNT 16 OPEN OR GROSS LEWDNESS

gross lewdness by grabbing and/or groping the breasts of A.K.

COUNT 17 ADMINISTRATION OF DRUG TO AID COMMISSION OF FELONY

feloniously, and knowingly administer to A.K., a controlled substance, anesthetic, or

enable or assist himself to commit a felony, to-wit: sexual assault.

COUNT 18 ADMINISTRATION OF DRUG TO AID COMMISSION OF FELONY

feloniously, and knowingly administer to L.R., a controlled substance, anesthetic, or

enable or assist himself to commit a felony, to-wit: sexual assault.

COUNT 19 ADMINISTRATION OF DRUG TO AID COMMISSION OF FELONY

feloniously, and knowingly administer to C.N., a controlled substance, anesthetic, or

enable or assist himself to commit a felony, to-wit: sexual assault.

COUNT 20 ADMINISTRATION OF DRUG TO AID COMMISSION OF FELONY

feloniously, and knowingly administer to L.R., a controlled substance, anesthetic, or

enable or assist himself to commit a felony, to-wit: sexual assault.

COUNT 21 ADMINISTRATION OF DRUG TO AID COMMISSION OF FELONY

unlawfully, feloniously, and knowingly administer to H.C., a controlled substance, anesthetic,

to enable or assist himself to commit a felony, to-wit: sexual assault.

COUNT 22 ADMINISTRATION OF DRUG TO AID COMMISSION OF FELONY

unlawfully, feloniously, and knowingly administer to C.G., a controlled substance, anesthetic,

to enable or assist himself to commit a felony, to-wit: sexual assault.

COUNT 23 ADMINISTRATION OF DRUG TO AID COMMISSION OF FELONY

unlawfully, feloniously, and knowingly administer to C.G., a controlled substance, anesthetic,

to enable or assist himself to commit a felony, to-wit: sexual assault.

COUNT 24 ADMINISTRATION OF DRUG TO AID COMMISSION OF FELONY

unlawfully, feloniously, and knowingly administer to S.H., a controlled substance, anesthetic,

to enable or assist himself to commit a felony, to-wit: sexual assault.

COUNT 25 ADMINISTRATION OF DRUG TO AID COMMISSION OF FELONY

unlawfully, feloniously, and knowingly administer to L.M., a controlled substance, anesthetic,

to enable or assist himself to commit a felony, to-wit: sexual assault.