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Defendant.
INDICTMENT
COT]NTONE
ATTEMPTED SEXUAL EXPLOITATION OT A CHILD
(18 U.S.C. $22s1(a) & (e))
to coerce S.V., a 14 year old minor female, to engage in sexually explicit conduct
for the purpose ofproducing any visual depiction ofsuch conduct, knowing and
having reason to know that such visual depiction would be transported using any
means and facility of interstate and foreign commerce; knowing and having reason
to know that such visual depiction would be transported in and affecting interstate
and foreign commerce; using materials that have been mailed, shipped, and
I
1:17-cr-20316-TLL-PTM Doc # 1 Filed 05/10/17 Pg 2 of 4 Pg ID 2
lasciviously exhibiting her genitals and pubic area, photographing those things, and
sending the photograph(s) to CHAPMAN using her cellular phone or tablet using a
text messaging service over the intemet when S.V. was in Washington state and
while CHAPMAN was in the Eastem District of Michigan, in violation of Title 18,
COUNT TWO
RECEIPT OF CHILD PORNOGRAPHY
(1 8 U.S.C. $ 22s2 A(a)(z))
attempted to receive one or more visual depictions that had been mailed, shipped
computer, the production ofsuch visual depictions having involved the use of
minors engaging in sexually explicit conduct (as defined in Title 18, United States
Code, Section 2256(2)), in violation of Title 18, United States Code, Section
22s2A(a)(2).
2
1:17-cr-20316-TLL-PTM Doc # 1 Filed 05/10/17 Pg 3 of 4 Pg ID 3
COUNT THREE
POSSESSION OF CHILD PORNOGRAPHY
(18 u.S.C. $ 22s2A(a)(s)(B))
Huawei cell phone and one Gateway laptop computer that contained images of
child pornography, as defined by Title 18, United States Code, Section 2256(8),
that had been shipped and transported using any means and facility of interstate
and foreign commerce and at least some of which involved a prepubescent minor
or a minor who has not attained the age of l2 years of age, in violation of Title 18,
DANIEL L. LEMISH
Acting United States Attomey s/GRAND J URY FOREPERSON
,
1:17-cr-20316-TLL-PTM Doc # 1 Filed 05/10/17 Pg 4 of 4 Pg ID 4
Com anion Case information MUST be com leted AUSA and initialed.
United Stat6 Oistrict Court Criminal Case Cover Sheet Case Number
Eastern Oistrict of Michigan
NOTE: lt is the responsibility ot the Assistant U.S. Attorney signing this torm to complt6 it accu.atgly ln all respects.
Case: '1:17-cr-20316
Judge: Ludington, Thomas L.
This may be a companion case based upon LCrR 57.10 (bx4)i: MJ: Monis, Patricia T.
Filed: 05-'lG2017At 04:39 pM
!ves Exo SEALED MATTER (krc)
Please take notice that the below listed Assistant United States Aftorney is the attorney of record for
the above captioned case.
May 10,2017
Date
-
,+
Christooher W. Rawsthorne
Assistaht United States Attorney
2't0 Federal Building
600 Church Street
Flint, Michigan 48502
Telephone: (810) 766-5177
Email: Christopher. Rawsthorne@usdoj.gov
wt BAR# 1059889
same tran$ction or occurrence. Cases may be companaon cases even though one of lhem may have already been temjnated.
03h 112013