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<v ->The Justice Department has just filed a complaint</v>

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against the individual we alleged

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committed this heinous crime,

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which had killed 10 people,

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all of whom were Black and wounded three others.

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The complaint we have filed today

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charges Payton Gendron with 10 counts

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of committing a hate crime resulting in death.

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three counts of committing a hate crime

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involving an attempt to kill,

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10 counts of using a firearm to commit murder

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during and in relation to a crime of violence,