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JUSTICE COURT, LAS VEGAS TOWNSHIP
CLARK COUNTY, NEVADA

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THE STATE OF NEVADA,

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Plaintiff,

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CASE NO:

15F09138X

DEPT NO:

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-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

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NRS

201.210

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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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///

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///

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///
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COUNT 2 - POSSESSION OF VISUAL PRESENTATION DEPICTING SEXUAL
CONDUCT OF A CHILD

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did on or about June 4, 2015 wilfully, unlawfully, feloniously, and knowingly have in

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his possession a film, photograph, or other visual presentation depicting a child under the age

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of 16 years of age as the subject of a sexual portrayal or engaging in, simulating, or assisting

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others to engage in or simulate sexual conduct, to-wit: a video 7 minutes and 8 seconds in

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length depicting a compilation of children that were obviously prepubescent, as they were

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forced to perform oral sex on adult males until the male ejaculated into their faces and/or

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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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COUNT 3 - POSSESSION OF VISUAL PRESENTATION DEPICTING SEXUAL
CONDUCT OF A CHILD

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did on or about June 4, 2015 wilfully, unlawfully, feloniously, and knowingly have in

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his possession a film, photograph, or other visual presentation depicting a child under the age

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of 16 years of age as the subject of a sexual portrayal or engaging in, simulating, or assisting

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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
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in a hurry in an obvious complaint. She appears to be instructed to remove her pants once

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more and does so. The juvie bent over and shoved an object into her anus for minutes. At 6

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minutes the scene switches to the child sucking the same male's penis again. She sucks his

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penis for 1 minute and 21 seconds. At 7 minutes the scene switches to a nude shot of the child's

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buttocks. At 8 minutes the male begins to penetrate the child's anal opening. At 8 minutes and

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38 seconds the male begins to hold and touch the child with his left hand while rubbing his

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penis with his right hand. At 10 minutes 20 seconds the male penetrates the child's anus with

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his penis.

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COUNT 4 - POSSESSION OF VISUAL PRESENTATION DEPICTING SEXUAL
CONDUCT OF A CHILD

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did on or about June 4, 2015 wilfully, unlawfully, feloniously, and knowingly have in

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his possession a film, photograph, or other visual presentation depicting a child under the age

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of 16 years of age as the subject of a sexual portrayal or engaging in, simulating, or assisting

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others to engage in or simulate sexual conduct, to-wit: a video 11 minutes and 22 seconds long

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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
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minutes 4 seconds, the child turns over onto her stomach and the male penetrates her genital

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opening. At 10 minutes 55 seconds the child performs oral sex on the male again.

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COUNT 5 - POSSESSION OF VISUAL PRESENTATION DEPICTING SEXUAL
CONDUCT OF A CHILD

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did on or about June 4, 2015 wilfully, unlawfully, feloniously, and knowingly have in

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his possession a film, photograph, or other visual presentation depicting a child under the age

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of 16 years of age as the subject of a sexual portrayal or engaging in, simulating, or assisting

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others to engage in or simulate sexual conduct, to-wit: a video 4 minutes and 7 seconds long

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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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COUNT 6 - POSSESSION OF VISUAL PRESENTATION DEPICTING SEXUAL
CONDUCT OF A CHILD

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did on or about June 4, 2015 wilfully, unlawfully, feloniously, and knowingly have in

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his possession a film, photograph, or other visual presentation depicting a child under the age

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of 16 years of age as the subject of a sexual portrayal or engaging in, simulating, or assisting

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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
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anal and genital opening. At 1 minute and 10 seconds he tries to penetrate her anal opening

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with his penis, but ultimately penetrates the child's anal opening with his fingers. At 4 minutes

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and 19 seconds the male begins to forcefully shove his penis into the child's mouth.

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COUNT 7 - POSSESSION OF VISUAL PRESENTATION DEPICTING SEXUAL
CONDUCT OF A CHILD

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did on or about June 4, 2015 wilfully, unlawfully, feloniously, and knowingly have in

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his possession a film, photograph, or other visual presentation depicting a child under the age

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of 16 years of age as the subject of a sexual portrayal or engaging in, simulating, or assisting

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others to engage in or simulate sexual conduct, to-wit: a video 7 minutes and 51 seconds long

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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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COUNT 8 - POSSESSION OF VISUAL PRESENTATION DEPICTING SEXUAL
CONDUCT OF A CHILD

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did on or about June 4, 2015 wilfully, unlawfully, feloniously, and knowingly have in

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his possession a film, photograph, or other visual presentation depicting a child under the age

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of 16 years of age as the subject of a sexual portrayal or engaging in, simulating, or assisting

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others to engage in or simulate sexual conduct, to-wit: a video 18 minutes and 6 seconds long

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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
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all over the child's pelvis, stomach and genitals. The video zooms in on the child's genitals

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now covered in semen which is dripping onto the floor.

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COUNT 9 - POSSESSION OF VISUAL PRESENTATION DEPICTING SEXUAL
CONDUCT OF A CHILD

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did on or about June 4, 2015 wilfully, unlawfully, feloniously, and knowingly have in

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his possession a film, photograph, or other visual presentation depicting a child under the age

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of 16 years of age as the subject of a sexual portrayal or engaging in, simulating, or assisting

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others to engage in or simulate sexual conduct, to-wit: a video 3 minutes and 36 seconds

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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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COUNT 10 - POSSESSION OF VISUAL PRESENTATION DEPICTING SEXUAL
CONDUCT OF A CHILD

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did on or about June 4, 2015 wilfully, unlawfully, feloniously, and knowingly have in

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his possession a film, photograph, or other visual presentation depicting a child under the age

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of 16 years of age as the subject of a sexual portrayal or engaging in, simulating, or assisting

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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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COUNT 11 - POSSESSION OF VISUAL PRESENTATION DEPICTING SEXUAL
CONDUCT OF A CHILD

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did on or about June 4, 2015 wilfully, unlawfully, feloniously, and knowingly have in

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his possession a film, photograph, or other visual presentation depicting a child under the age

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of 16 years of age as the subject of a sexual portrayal or engaging in, simulating, or assisting

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others to engage in or simulate sexual conduct, to-wit: a video depicting two prepubescent

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girls completely nude. One child is holding an object in place while the other child moves up

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and down moving the object into and out of her genital opening. At 1 minute and 11 seconds

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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 Defendant’s conduct.

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COUNT 13 – 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 Defendant’s conduct.

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COUNT 14 – 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 Defendant’s conduct.
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COUNT 15 – ADMINISTRATION OF DRUG TO AID COMMISSION OF FELONY

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did, between January 1, 2015 and June 1, 2015, then and there willfully, unlawfully,

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

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intoxicating agent, to-wit: Ketamine and/or an unknown substance, with the intent thereby to

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

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COUNT 16 – OPEN OR GROSS LEWDNESS

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did then and there willfully and unlawfully and feloniously commit an act of open or

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

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COUNT 17 – ADMINISTRATION OF DRUG TO AID COMMISSION OF FELONY

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did, between January 1, 2015 and June 1, 2015, then and there willfully, unlawfully,

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

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intoxicating agent, to-wit: Ketamine and/or an unknown substance, with the intent thereby to

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

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COUNT 18 – ADMINISTRATION OF DRUG TO AID COMMISSION OF FELONY

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did, between January 1, 2015 and June 1, 2015, then and there willfully, unlawfully,

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

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intoxicating agent, to-wit: Ketamine and/or an unknown substance, with the intent thereby to

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

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COUNT 19 – ADMINISTRATION OF DRUG TO AID COMMISSION OF FELONY

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did, between January 1, 2015 and June 1, 2015, then and there willfully, unlawfully,

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

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intoxicating agent, to-wit: Ketamine and/or an unknown substance, with the intent thereby to

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

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COUNT 20 – ADMINISTRATION OF DRUG TO AID COMMISSION OF FELONY

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did, between January 1, 2015 and June 1, 2015, then and there willfully, unlawfully,

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

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intoxicating agent, to-wit: Ketamine and/or an unknown substance, with the intent thereby to

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enable or assist himself to commit a felony, to-wit: sexual assault.
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COUNT 21 – ADMINISTRATION OF DRUG TO AID COMMISSION OF FELONY

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did, between October 1, 2015 and December 31, 2014, then and there willfully,

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

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or intoxicating agent, to-wit: Ketamine and/or an unknown substance, with the intent thereby

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

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COUNT 22 – ADMINISTRATION OF DRUG TO AID COMMISSION OF FELONY

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did, between October 1, 2015 and December 31, 2014, then and there willfully,

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

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or intoxicating agent, to-wit: Ketamine and/or an unknown substance, with the intent thereby

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

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COUNT 23 – ADMINISTRATION OF DRUG TO AID COMMISSION OF FELONY

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did, between October 1, 2015 and December 31, 2014, then and there willfully,

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

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or intoxicating agent, to-wit: Ketamine and/or an unknown substance, with the intent thereby

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

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COUNT 24 – ADMINISTRATION OF DRUG TO AID COMMISSION OF FELONY

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did, between October 1, 2015 and December 31, 2014, then and there willfully,

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

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or intoxicating agent, to-wit: Ketamine and/or an unknown substance, with the intent thereby

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

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COUNT 25 – ADMINISTRATION OF DRUG TO AID COMMISSION OF FELONY

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did, between October 1, 2015 and December 31, 2014, then and there willfully,

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

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or intoxicating agent, to-wit: Ketamine and/or an unknown substance, with the intent thereby

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

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COUNT 26 – ADMINISTRATION OF DRUG TO AID COMMISSION OF FELONY

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did, between October 1, 2015 and December 31, 2014, then and there willfully,

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unlawfully, feloniously, and knowingly administer to I.S., a controlled substance, anesthetic,
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or intoxicating agent, to-wit: Ketamine and/or an unknown substance, with the intent thereby

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

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COUNT 27 – ADMINISTRATION OF DRUG TO AID COMMISSION OF FELONY

4

did, between October 1, 2015 and December 31, 2014, then and there willfully,

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

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or intoxicating agent, to-wit: Ketamine and/or an unknown substance, with the intent thereby

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

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COUNT 28 – ADMINISTRATION OF DRUG TO AID COMMISSION OF FELONY

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did, between October 1, 2015 and December 31, 2014, then and there willfully,

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unlawfully, feloniously, and knowingly administer to P.V., a controlled substance, anesthetic,

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or intoxicating agent, to-wit: Ketamine and/or an unknown substance, with the intent thereby

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

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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)

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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

H:\MEDIA REQUESTS\CRIMINAL COMPLAINTS\CHUNG, BINH-AMENDED-15F09138.DOCX

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