33mm UNITED STATES DISTRICT COURT 9 FOR THE CENTRAL DISTRICT OF CALIFORNIA 10 I October 2013? Grand Jury . 11 UNITED STATES OF AMERICA, CR NO. l3?C a ?g 12 Plaintiff, 13 v. [18 U.S.C. 371: Conspiracy; 18 U.S.C. 1030(6.) (2) (C), -14 HUNTER .) Unauthorized CHARLES EVENS, Access to a Protected Computer 15 aka ?Gary,? to Obtain Information; 18 U.S.C. I I 1028A(a)(1): Aggravated 16 Defendants. Identity Theft; 18 U.S.C. 2: I Aiding and Abetting and Causing l7 an Act To Be Done] 18 .19 The Grand Jury charges:* 20 COUNT ONE 21 [1'8 U.S.C. 371] 22 A.r INTRODUCTION 23 1. At all times relevant to this Indictment: 24 a. Defendant HUNTER MOORE resided in 25 Woodland, California. 26 b. Defendant MOORE operated the website 27 on which he posted, among other things, 28 nude or sexually explicit photos of victims submitted by other ase Document 1 Filed 12/20/13 Page 1 of 13 Page ID 90 Ma 02: 31111111 03113 Case Document 1 Filed 12/20/13 Page 2 of 13 'Page ID individuals withoUt the victim?s permission for purposes of revenge. c. Defendant CHARLES EVENS, also known as ?Gary? resided in the Central District of California. Id. Defendant MOORE used the following e?mail accounts: isanyoneup@gmail.com and e. Defendant EVENS used the following e?mail accounts: and f. The online form used to submit images on defendant website is hosted through JotForm.com. g. Defendant_MOORE used online Paypal accounts with the following user IDs: .?Hunter Moore,? ?Catalyst Web Services,? and ?quebella.? K.L., P.K., T.G., S.M., and Victims L.B., V.E., T.K. maintained e?mail accounts that contained, among other .things, nude pictures of themselves and others. (?Googlef) provided e?mail services pi. Google, Inc. to users all over the world. j. Yahoo! Inc. (?Yahoo!f) provided e?mail services to users all over the world. B. THE OBJECT OF THE CONSPIRACY 2. Beginning on an unknown date and continuing through on or about May 2, 2012, in Los Angeles County, within the Central District of California, and elsewhere, defendants MOORE and EVENS, together with others known and unknown to the Grand Jury, knowingly combined, conspired, and agreed to commit the 2 pase Document 1 Filed 12/20/13 Page 3 of 13 Page ID following offense against the United States: To access a protected computer without authorization to obtain information for private financial gain, in violation of Title 18, United States Code, Sections 1030(a)(2)(C), C: THE MEANS OF THE CONSPIRACY 3. .The object of the conspiracy was carried out, and to be carried out, in substance, as follows: a. .Defendant EVENS would gain unauthorized access ?to the e?mail accounts of hundreds of victims (the ?victims? accounts?) by various means, including ?hacking? into the victims? accounts, and obtain information, including nude pictures, belonging to the victims and stored on the victimst accounts.. b. Defendant EVENS would send nude pictures obtained_ from the Victims? accounts to defendant MOORE in exchange for payment. c. Defendant MOORE, aware that defendant EVENS had obtained the nude pictures by gaining unauthorized access into the victims? accounts, would send payments to defendant EVENS using Paypal or directly from his bank account in exchange for the nude pictures, would offer defendant EVENS additional money to obtain unlawfully additional nude pictures, and would post the victims"nude pictures.on his website, without the victims? authorization. D. OVERT ACTS 4. In furtherance of the conSpiracy and to accomplish its object, defendants EVENS, together with others known and unknown to the Grand Jury, committed, and willfully caused 3 base Document 1 Filed 12/20/13 Page 4 of 13 Page ID others to commit, the following overt acts, among others, in the Central District of California and elsewhere:- Overt Act No. 1: On or about October 10, 2011, defendant EVENS sent to defendant MOORE an eemail discussing ?how to hack e?mails.? Overt Act No. 2: On or about October 15, 2011, defendant MOORE sent to defendant EVENS an e-mail asking defendant EVENS to work for him. Overt Act No. 3: on or about October 17, 2011, defendant MOORE sent to defendant EVENS an e-mail offering to pay defendant EVENS $200 per week using Paypal. a Overt Act No. 4: On or about October 17, 2011, defendant EVENS sent to defendant MOORE an e-mail stating that the hacking that defendant EVENS is doing is illegal. Overt Act No. 5: On or about October 17, 2011, defendant MOORE sent to defendant EVENS an e?mail stating that he is employing defendant EVENS and instructing defendant EVENS to use an anonymous Paypal account to avoid.detection of their scheme and connection to each other. Overt Act No. 6: On or about October 17, 2011, defendant MOORE sent to defendant EVENS an e?mail stating that defendant EVENS would receive payments ?from catalyst or something paypal,? 'Overt Act No. 7: On or about October 18, 2011, defendant MOORE sent to defendant EVENS an e?mail asking defendant_EVENS to send him naked pictures and stating that he would send payments to defendant EVENS using Paypal. Erase Document 1 Filed 12/20/13 Page 5 of 13 Page ID Overt Act No. 8: On or about October 29, 2011, defendant MOORE sent to defendant EVENS an e~mail stating that they needed to create new e?mail accounts and delete evidence of the hacking scheme. Overt Act No. 9: on or about_December 8, 2011, defendant EVENS sent to defendant MOORE an e?mail asking for $250 for nude 'pictures of ?6 guys and 6 girls.? Overt Act No. 10: On or about December 8, 2011, defendant MOORE sent to defendant EVENS an e?mail stating he would like ?as many as possible? (referring to the nude pictures that defendant EVENS had obtained by hacking into the victims? accounts). Overt Act No. 11: On or about December 8, 2011, defendant EVENS accessed victim e?mail account without authorization. Overt Act No. 12: On or about December 8, 2011, defendant EVENS obtained pictures, including a nude_picture, of victim L.B. from victim e?mail account. On or about December 11, 2011L Overt Act No. 13: defendant EVENS submitted pictures, including a nude picture, of victim to defendant website, On or about December 14, 2011, Overt Act No. 14: defendant MOORE paid $145.70 to defendant EVENS using Paypal. On or about December 29, 2011, Overt Act No. 15: defendant MOORE posted a nude picture of victim L.B. on his website, Case Document 1 Filed 12/20/13 Page 6 of 13 Page ID Overt Act No. 16: On or about December 30, 2011, defendant EVENS accessed victim e?mail account without authorization. Overt Act No. 17: On or about December 30, 2011, defendant EVENS obtained pictures, including a nude picture, of victim V.E. from victim e?mail account. On or about December 31, 2011, Overt Act No. 18: defendant MOORE sent to defendant EVENS an e?mail stating he needed all the nude pictures defendant EVENS had obtained by hacking into the victims? accounts. Overt Act No. 19: On or about January 1, 2012, defendant EVENS accessed victim e-mail account without authorization. Overt Act No. 20: On or about January 1, 2012, defendant EVENS obtained nude pictures of victim K.L. from victim K.L.rs e?mail account. Overt Act No. 21: On or about January 2, 2012, defendant MOORE sent to defendant EVENS an e-mail asking defendant EVENS to ?hack more.? Overt Act No. 22: On or about January 4, 2012, defendant EVENS accessed victim e?mail account without authorization. Overt Act No. 23: On or about January 4, 2012, defendant obtained pictures, including a nude picture, of victim D.W. from victim e-mail account. Overt Act No. 24: On or about January 7, 2012, defendant' EVENS accessed victim e?mail account without authorization. 'posted a nude picture of CaSe Document 1 Filed 12/20/13 Page 7 of 13 Page ID Overt Actho. 25: On or-about January 7, 2012, defendant EVENS obtained pictures, inCluding nude pictures, of victim T.G. and others from victim TrG.?s e?mail account. _Overt Act No. 26: On or about January 8, 2012, defendant MOORE sent to defendant EVENS an e?mail asking defendant EVENS to ?hack all week for me? and stating that he could pay idefendant EVENS. Overt Act No. 27: On or about January 8, 2012, defendant .EVENS submitted pictures, including a nude picture, of victim K.L. to defendant website, Overt Act No. 28: On or about January 8, 2012, defendant EVENS submitted pictures, including a nude picture, of victim D.W. to defendant website, Overt Act No. 29: On or about January 8, 2012, defendant MOORE paid $294 to defendant EVENS using Paypal., Overt Act No. 30: On or about January 8, 2012, defendant MOORE posted a nude picture of victim D.W. on his website website, . Overt Act No. 31: On or about January 9, 2012, defendant EVENS submitted pictures, including a nude picture, of victim V.E. to defendant website, Overt Act No. 32: On or about January 9, 2012, defendant victim K.L. on his website website, Overt Act No. 33: On or about January 9, 2012, defendant EVENS submitted pictures, including a nude picture, of victim T.G. to defendant MOORE's webSite, base Document 1 Filed 12/20/13 Page 8 of 13 Page ID On or about January_9, 2012, defendant Overt Act No. 34: MOO-RE paid $264 to defendant EVENS using Paypal. On or about January 12, 2012, defendant Overt Act No. 35: MOORE posted a nude picture of victim V.E. on his website. website, On_or about January 16, 2012, defendant Overt Act NO. 36: MOORE sent to defendant EVENS an e?mail asking defendant EVENS to ?hack more.? Overt Act No. 37: -On or about January 22, 2012, defendant EVENE accessed victim e-mail account without ,authorization. Overt. Act No. 38: On or about January 22, 2012, defendant EVENS obtained nude pictures of victim S.M. from victim e?mail account. Overt Act No. 39: On or about January 24, 2012, defendant EVENS submitted pictures, including a nude picture, of victim S.M. to defendant website, On or about January 25, 2012, defendant Overt Act NO. 40: MOORE paid $200 to defendant EVENS using Paypal. Overt Act No. 41: On or about January 27, 2012, defendant MOORE posted a nude picture of victim S.M. on his website I - . Overt Act No. 42: On or about January 29, 2012, defendant to defendant EVENS an e-mail stating he needed nude pictures. On or about January 29, 2012, defendant Overt Act No. 43; EVENS accessed victim T.K.'s eamail account without authorization. base Document 1 Filed 12/20/13 Page 9 of 13' Page ID Overt Act No. 44: On or about January 29, 2012, defendant obtained pictures, including a nude picture, of victim T.K. from victim e?mail account. ?Overt Act No. 45: On or about January 29, 2012, defendant EVENS submitted pictures, including a nude picture, of victim T.K. to defendant website, On or about January 29, 2012, defendant Overt Act No. 46: MOORE paid $350 to defendant EVENS using Paypal. Overt Act No. 47: On or about January 29, 2012, defendant MOORE posted a nude picture_of victim T.K. on his website website, 2012, Overt Act No. 48: On or about February 21, 'defendant MOORE sent to defendant EVENS an e?mail requesting nude pictures of ?7 girls and 3 dudesi? '_Overt Act No. 49: On or about February 21, 2012, defendant MOORE sent to defendant EVENS an e~mail confirming defendant mother?s e-mail address as quebella2011@gmail.com. 2012, Overt Act No. 50: on or about February 21, defendant EVENS sent to defendant MOORE an e?mail requesting a wire transfer. Overt Act No. 51: On or about February 21, 2012, defendant EVENS sent to defendant MOORE an e?mail containing defendant bank account information. Overt Act No. 52: On or about_February 21, 2012, defendant MOORE electronically transferred $500 from his bank account to defendant EVENS. '28 ase Document 1 Filed 12/20/13 Page 10 of 13 Page ID #:10 - Overt Act No. 53: On or about February 23, 2012, defendant MOQRE electronically transferred $135 from his bank account to defendant EVENS. Overt Act No; 54: On or about February 23, 2012, defendant MOORE sent to defendant EVENS an e?mail stating that he ?only sent 135.? 'Overt Act No. 55: On or about March 2, 2012, defendant MOORE sent to defendant EVENS an e?mail asking defendant EVENS to submit nude pictures so defendant MOORE could ?send the other 1k.? Overt Act No. 56: On or about March 2, 2012, defendant_ MOORE electronically transferred $900 from his bank account to defendant EVENS. Overt Act No. 57: On or about March 2, 2012, defendant EVENS sent to defendant MOORE an e?mail confirming that he had received $900. 10 10Lise Document 1 Filed 12/20/13 Page 11 Of 13 Page ID #:11 COUNTS TWO THROUGH EIGHT [18 U.S.C. 1030(a?) (2) (C), (2) (B) 2] 5. The Grand Jury hereby repeats and realleges paragraphs 1, 3, and 4 of this Indictment, including all subparagraphs, as if fully set forth herein. 6. On or about the dates set forth below, in Los Angeles County, within the Central District of California, and elsewhere, defendants HUNTER MOORE and CHARLES EVENS, also known as ?Gary,? aiding and abetting one another, knowingly and intentionally accessed and caused to be accessed without authorization, and thereby obtained information, namely, the contents of the following victim's e-mail account, from a computer used in and affecting interstate-and foreign commerce, namely, a server of the service provider described below, for purposes of private financial gain: COUNT DATE ACCOUNT HOLDER SERVICE PROVIDER VICTIM TWO 12/8/2011 L.B. Google THREE 12/30/2011 v.E. Google FOUR 1/1/2012 K.L. Google FIVE *1/4/2012 P.L. Google SIX 1/7/2012 Yahoo} SEVEN 1/22/2012 s.M. Google .EIGHT 1/29/2012 T.K. Google ll' COUNTS NINE THROUGH FIFTEEN [18 U.S.C. 1028A(ay(1), 2] The Grand Jury hereby repeats and realleges paragraphs if fully set forth herein. On or about the dates set forth below, in Los Angeles (2) (B) (if: ase Document 1 Filed 12/20/13 Page 12 Of 13 Page ID #:12 l, 3, and 4 of this Indictment, including all subparagraphs, as County, within the Central District of California, and elsewhere, defendants HUNTER MOORE and CHARLES EVENS, also known as ?Gary,? aiding and abetting one another, knowingly and without lawful authority possessed and used, and willfully caused others to possess-and use, means of identification of other persons, that is, the usernames of the below?described individuals, during and in relation to the below-described felony violations of unauthorized access to a protected computer to obtain information for private financial gain, in violation of Title 18, United States Code, Sections COUNT DATE VICTIM RELATED COUNT NINE L.B. TWO - TEN 12/30/2011 V.E. THREE ELEVEN 1/1/2012 K.L FOUR TWELVE 1/4/2012 P.L. EIVET THIRTEEN 1/7/2012 T.G. SIX 12 ese Document 1 Filed 12/29/13 Page 13 of 13 Page ID #:13 COUNT DATE VICTIM RELATED COUNT FOURTEEN 1/22/2012 S.M. SEVEN FIFTEEN 1/29/2012 T.K. EIGHT A TRUE BILL Foreperson ANDRE BIROTTE JR. United States Attorney lgiiEE/E. DUGDALE Assistant United States Attorney Chiefh Criminal Division WESLEY L. HSU Assistant United States Attorney Chief, Cyber and Intellectual Property Crimes Section VANDEVELDE Assistant United States Attorney Deputy Chief, Cyber and Intellectual Property Crimes Section WENDY T. WU Assistant United States Attorney Cyber and Intellectual PrOperty Crimes Section? 13