This legal document, filed on April 16, 2021, is a portion of a legal argument defending an indictment against a motion to dismiss. The argument asserts that using pseudonyms for minor victims and providing an approximate date range (1994-1997) for the alleged crimes is legally sound, citing precedents like Stringer, Kidd, and Stavroulakis. It further argues the defendant is not prejudiced, as the government has provided and will provide specific details, such as victim birth information and witness names, during discovery.
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