UNITED STATES DISTRICT COURT

FOR THE CENTRAL DISTRICT OF CALIFORNIA

June 2016 Grand Jury

UNITED STATES OF AMERICA,
Plaintiff,
v.

CHRISTINA ELIZABETH BANKSTON,
aka "Christina Elizabeth
McGill,"
aka "Troy Leatherby,"
aka "Jacky Jasper,"
aka "Greg Comeau,"
aka "Browbuster,"

Defendant.

 

 

 

 

The Grand Jury charges:

 


[18 U.S.C. and
2261(b)(5): Stalking; l8 U.S.C.

1030(a)(2)(C), 
Unauthorized Access
to a Protected Computer to Obtain
Information; 18 U.S.C. 

1030(a)(7)(B), 
Extortion by Threat to Obtain
Information and Impair
Confidentiality of Information of
a Protected Computer; 18 U.S.C.

1028A(a)(1): Aggravated Identity
Theft]

COUNTS ONE THROUGH 

[18 U.S.C. 2261(b)(5)]

COURSE OF CONDUCT

USE OF INTERSTATE COMMERCE FACILITY TO ENGAGE IN THREATENING

1. Beginning on a date unknown to the Grand Jury, but no later

than March 9, 2014, and continuing to on or about September 5,12014,

in Los Angeles County, within the Central District of California, and

 

 

 

 

elsewhere, defendant CHRISTINA ELIZABETH BANKSTON, also known as

2 "Christina Elizabeth McGill," aka "Troy Leatherby," aka

3 ?Jacky Jasper," aka "Greg Comeau," aka "Browbuster," ("defendant

4 with the intent to harass and intimidate Kristen Jenner
5 ("Victim Jenner"), Katherine Ellena ("Victim Ellena"), Caitlyn

6 Jenner, then known as Bruce Jenner ("Victim C. Jenner"), Jennifer

7 Stith ("Victim Stith"), Victim A, Victim B, and others known and

8 unknown to the Grand Jury (collectively, "the used

9 facilities of interstate commerce, including cellular telephone
10 networks, electronic mail ("email"), text messages, interstate wires,
11 and the Internet, to engage in a course of conduct, described in
12 paragraph 2 below, that caused, attempted to cause, and would have
13 been reasonably expected to cause, substantial emotional distress to
14 the Victims and their immediate family members.

15 B. DESCRIPTION OF COURSE OF CONDUCT

16 2. Defendant course of conduct included, among

17 other things, the following:

18 a. Between on or about March 9, 2014 and March 10, 2014,
19 defendant BANKSTON, using the name "Troy,h an email account, and

20 multiple telephone numbers, sent 89 chat messages and 19 text

21 messages to Victim Jenner. In those messages, among other things

22 defendant BANKSTON, stating that defendant BANKSTON was located in
23 Beverly Hills, California, and knowing that Victim Jenner resided in
24 Los Angeles County, asked to meet Victim Jenner in person because

25 defendant BANKSTON claimed to have a "sex tape" of Victim Jenner

26 which defendant BANKSTON claimed to have sent to an online media

27 website. I

28

 

 

 

about March 12, 2014, defendant BANKSTON sent

Victim Jenner six anonymous text messages, including:

i. "Can I eat you out," "Oh you can't block me

forever love."

ii. "Die! I feel special and honored to rock it! Love

momma Kris."
defendant BANKSTON sent

c. On or about March 14, 2014,

Victim Jenner 29 anonymous text messages from multiple telephone

numbers, including the following:

i. "Hey beautiful remember when you were getting all
those crazy calls from the uk and you posted it! Why won't you post

mine with me contacting you?," "Instagram me make me famous.?

ii. "Kris put this on TMZ make me famousll," "Kris we

have all your numbers now make 'me famous 
Kris I looked on the FBI most wanted list

and I'm not there! I'm disappointed in you! Put me on Instagram tho

goodnight you!"

d. On March 22, 2014, defendant BANKSTON, using multiple

telephone numbers, sent 34 anonymous text messages to Victim Jenner.

In those messages, among other things, defendant BANKSTON:

i. Stated that she had a "sex tape" of Victim Jenner

that defendant BANKSTON wanted to sell to an adult film studio.

"Let's talk," "My bad lets stalk."

ii. Stated,

e. On or about March 24, 2014, at approximately 4:00

BANKSTON used a telephone to call a friend of

Victim Jenner, and, impersonating Victim Jenner, falsely told Victim

Jenner's friend that something had been published about the friend on

the Internet.

 

about March 25, 2014, defendant BANKSTON, using

multiple phone numbers, sent 8 anonymous text messages to Victim

Jenner. In those messages, among other things, defendant BANKSTON

repeatedly referenced Victim Jenner's inability to "block" defendant

BANKSTON's communications to Victim Jenner, and stated, "This is

getting creepy [again]."

g. On or about March 26, 2014, defendant BANKSTON sent 11

anonymous text messages to Victim Jenner. In those messages, among

other things, defendant BANKSTON stated that defendant BANKSTON had

conducted an interview with a reporter from an online website about a
sex tape of Victim Jenner that defendant BANKSTON claimed to have.
h. On or about April 6, 2014, defendant BANKSTON, using

multiple telephone numbers, sent 7 anonymous text messages to

Victim Jenner. In those messages, among'other'things, defendant
BANKSTON asked Victim Jenner to call her and meet at a hotel room in

Beverly Hills, California, knowing that Victim Jenner lived in the

area.
i. On or about April 12, 2014, defendant BANKSTON, using
the name "Troy Leatherby" and multiple telephone numbers, sent 54

text messages to Victim Jenner. In those messages, among other

things, defendant BANKSTON:
i. Asked Victim Jenner to meet her at a hotel in the

Los Angeles area to "come fucc with me."

ii. Repeatedly referenced Victim Jenner's inability
to block telephone numbers.
Stated that she wanted to make a "sex tape" with

Victim Jenner to sell for a million dollars.

 

 

iv. Made multiple references to wanting to see

Victim Jenner naked or engaged in sexual activity.
j. On or about April 13, 2014, defendant BANKSTON, using

the name "Troy" and multiple telephone numbers, sent 60 text messages

to Victim Jenner, including the following:
i, want eat you through you're sexy to [me].your area

today lets do it."

k. Between on or about April 16, 2014 and April 18, 2014,

defendant BANKSTON, using multiple telephone numbers, sent 23
anonymous text messages to Victim Jenner, including the following:
1. "Kris has her own personal stalker."
ii. "Heard you were in the hOSpital," "I?m on my way
to see you soon if you're home."
.1. On or about April 19, 2014, defendant BANKSTON, using
multiple telephone numbers, sent 49 anonymous text messages to
among other things, defendant

Victim Jenner. In those messages,

BANKSTON:
i. Stated, "Ahh kris you have a stalker 101."
ii. Told Victim Jenner that defendant BANKSTON had
obtained Victim Jenner's "password" from a named employee of a
restaurant at which Victim Jenner had eaten, and "now your fucked."
Stated, "Change be a better person and then maybe
then we will stop ducking up your world you lousy useless bitch."
m. On or about April 27, 2014, defendant BANKSTON, using
multiple telephone numbers, sent two anonymous text messages and made

approximately 22 telephone calls to a person whom defendant BANKSTON

knew to be a friend of Victim Jenner. In those calls and text

5

 

 

messages, among other things, defendant BANKSTON, while impersonating
Victim Jenner, told the friend that Victim Jenner had cancer and
needed the telephone number of Victim Jenner's husband, Victim
C. Jenner, to get a ride to the hospital.

n. On or about April 27, 2014, defendant BANKSTON used a
telephone to cause Los Angeles County Sheriff's Department to send
emergency response personnel to ViCtim Jenner's residence by telling
an emergency service operator that defendant Victim
Jenner and falsely stating that Victim Jenner's sister, whose true
first name defendant BANKSTON provided, was cutting her wrists at
Victim Jenner's residence as part of a suicide attempt.

o. On or about June 9, 2014, defendant BANKSTON used a2
telephone to call Victim Ellena, whom defendant knew worked for
Victim Jenner. During the call, defendant BANKSTON asked for Victim
Ellena by Victim Ellena's first name, said that it-had taken a long
time to find Victim Ellena's telephone number, laughed, and hung up.

p. Between on or about June 9, 2014 and June 10, 2014,
gain

defendant BANKSTON, used the Internet to, on multiple occasions,

unauthorized access to and change the password for Victim Jenner's
among other things,

Apple iCloud account. Using that account,

defendant BANKSTON:

1. Used an iCloud feature to locate Victim Jenner's
iPhone at Victim Jenner's residence in Los Angeles County.'

ii. Impersonated Victim Jenner in a text message
conversation with Victim C. Jenner.

Sent 24 texts messages from Victim Jenner's Apple
iCloud account to Victim C. Jenner, after Victim C. Jenner became
aware of the impersonation, including, the following:

6

 

 

could try but could never find me,"



"Dumb fuck," "u could never find me," "Dumb fuck," "Good luck I fuck

your wife," "And she loves it."

"Kris hates blacks and we made it to TMZ bye

Bruce."

"Tell [first name of Victim C. Jenner's

former spouse] she's a hot piece of ass and she's next."
iv. Impersonated Victim Jenner in a text message

conversation with Victim Jenner's daughter, Victim A, then a minor.

q. On or about June 10, 2014, defendant BANKSTON used the

Internet to gain unauthorized access to Victim Jenner's Instagram
account. Using that account, defendant BANKSTON publically posted,

under Victim Jenner's name and photograph, negative comments about

"blacks," and disparaging remarks about a member of ViCtim Jenner's

family.

r. On or about June 11, 2014, defendant BANKSTON sent ten
anonymous text messages to Victim Jenner. In those messages, among
other things, defendant BANKSTON described herself as "the best

hacker in the word," said that she would next hack into
Victim Jenner's Twitter account, and threatened to "release"
publically defendant BANKSTON's prior text message conversation with
Victim A, as well as "pics and emails."

defendant BANKSTON sent six

s. On or about June 11, 2014,

anonymous text messages to Victim C. Jenner, including "After you
told me go fuck myself i decided to go fuck your wife instead."

t. On or about June 11, 2014, defendant BANKSTON used the
Internet to attempt to gain unauthorized access to and reset the 7
password for Victim Jenner's Apple iCloud account.

7

 

 

about June 11, 2014, defendant BANKSTON used a

telephone to call an employee at Instagram LLC. .In the call,

defendant BANKSTON identified herself with Victim Jenneris name and

attempted to change the passwords of Victim Jenner's Instagram and

Facebook accounts.

v. Between on or about June 11, 2014 and June 12, 2014,

defendant BANKSTON used the Internet to gain unauthorized access to

an email account of Victim B, Victim Jenner's daughter. Using the

account, defendant BANKSTON read and copied private email messages

between Victim and Victim B's husband..

w. On or about June 13, 2014, defendant BANKSTON used a

telephone to call Victim Ellena. During the call, defendant BANKSTON
referenced the_nameskof Victim Ellena's mother, father, and brother,

and said that defendant BANKSTON was "coming after" Victim Ellena's

"next."

mother Defendant BANKSTON then made several attempts to call

Victim Ellena's mother.

K. On or about June 19, 2014, defendant BANKSTON, using

the name "Greg Comeau," used a telephone to make three telephone

calls to Victim Jenner. During the calls, among other things,

defendant Victim Jenner that someone had had broken.
into Victim Jenner?s "phone" and computer accounts, could view Victim

Jenner's emails, and was stalking Victim C. Jenner and others.

y. On or about June 19, 2014, defendant BANKSTON sent

seven anonymous text messages to Victim Jenner, including, "This is

the fun part about it," "No matter how much yOu change numbers we
find them," and "So now we find and seek your home 

multiple telephone calls to Victim Stith, whom defendant BANKSTON

8

 

 

During the calls, among

knew worked for Victim Jenner at an office.

other things, dEfendant BANKSTON told Victim Stith that Victim Stith

was being watched at the office and not to leave the office.
defendant BANKSTON sent

aa. On or about June 24, 2014,

three anonymous text messages to Victim B, among other things,
falsely stating that she was pregnant by Victim B's husband.

bb. On or about June 24, 2014, defendant BANKSTON, using
the name "jacky jasper," sent 20 text messages to Victim C. Jenner,
including "1 saw you getting coffee in your blue bike shorts today,"

and still wanna know if I can fuck your pretty wife."

cc. Between on or about July 19, 2014 and July 20, 2014,

defendant BANKSTON used the Internet to post on the website
lipstickalley.com a number of messages about Victim Jenner and
Victim Jenner's family under a public discussion thread that
among other

defendant BANKSTON created. Those messages included,

things, the following:

i. An offer to provide, upon request, defendant
June 10, 2014 text message conversation with Victim A,
representing it to be a conversation between Victim Jenner and
Victim A.

ii. A series of messages that identified and
published the telephone numbers for Victim Jenner's residence and
cellular telephone, Victim A, another daughter of Victim Jenner, and
one of Victim Jenner's friends.
defendant BANKSTON sent

dd. On or about July 31, 2014,

.Victim Jenner an email stating, am so in love with you, it's

crazy, you know me btw. Can you come to the Bay Area? I wanna fuck

you So bad."

 

about August 4, 2014, defendant BANKSTON sent

series of an email messages to Victim Jenner and Victim Ellena.

Those messages included, among other things, the following:

i. An email to Victim Ellena stating, "Tell kris 

for wiping my iPad now I can't use it. I'll expect a new one this

week."

ii. An email to Victim Ellena titled, "I'm tracking
this," that contained location and other information regarding
Victim Ellena's email address and phone service, and the statement

"Here's your ip.;..and info! I want my iPad."

An email to Victim Jenner stating, "Call in extra

security I'm tracking you..Who's in Glendale? Look

somewhere on your a tracking device 101 101. Well you

'do like the cameras don't'you? have priVate intamate shots of you

too they will be published on lipstickalley tonight if I get no

call or ipad."

iv. An email to Victim Jenner titled "Your Stalker,"

that stated, "You want to see stalker I'm going to show you stalker

-now fetch me a new iPad 1.5 hours till show 

ff. On or about August 6, 2014, using the name "Mr Troy,"

and the email address defendant BANKSTON

sent a series of emails to Victim Jenner and Victim Ellena. Those

emails included, the following:

i. An email to Victim Ellena titled, "Troy leatherby

I'm here," stating, "I'm here. I'm the one who put out the sex tape

rumors I am the one who broke into her iCloud. I am here from San

Francisco lets meet. Ive been on you guys since april tell the guy

who answered the phone at the house I'm here. Tell him I had a bad

10

 

connection. Tell everyone I'm in townll Hahahah. Brace yourself

I'm here for my iPad. 6'4 green eyes and will see you and kris soon.

Thanks kat."

ii. An email to Victim Ellena stating, "There's no

use for you guys to keep changing numbers I am a hacker an work IT I
can find out your new number within days I've hacked the camera in

homes don't fuck with me just get me my iPad ill meet you anywhere

for it but you guys owe me an iPad. Katherine I've been in your

iCloud brace yourselves. I want my iPad ill meet anywhere to get

it."

An email to Victim Ellena stating, "Clear the

fucking house I'm in the area. I'm n0w connected to KJ wireless

I am IT I can see everything on this network. Don't play

*matlock You won't find met? Tel the boy who's

answering the house numbers I will duck him for lying to me. I don't

You will learn soon. I'm withinn a 5 mi radius of



iv. An email to Victim Jenner stating, I'm gonna duck

like games.

Kris's home.

you right in your pussy hole you are mine and am in love."
v. An email to Victim Ellena stating, "I'm going to
fuck you right in your pussy hole when I see you."

gg. On or about August 7, 2014, defendant BANKSTON sent by

email to Victim Ellena four audio files purporting to reflect

recordings of "Troy" speaking on the telephone. In these audio
files, among other things, defendant BANKSTON references stalking
Victim Jenner and her family over many months, including putting
tracking devices on Victim Jenner's vehicles, obtaining phone numbers

from restaurants that Victim Jenner had attended, using someone to

11

 

imitate Victim Jenner's voice on the telephone with Victim Jenner's
friends, seeking to obtain naked photographs of Victim Jenner,
traveling to Los Angeles County where Victim Jenner lived, and
hacking into Victim Jenner's iCloud and Instagram accounts.

hh. On or about August 8, 2014, using the name "Mr Troy,"
and the email address defendant
BANKSTON, knowing Victim Ellena was in San Francisco, sent an email
message to Victim Ellena stating, among other things, "I'm assuming
youfre in the Bay Area now! Is Kris with you?"
ii. On or about August 10, 2014, defendant BANKSTON used
the Internet to post on the website lipstickalley.com a number of
messages under a public discussion thread that defendant BANKSTON
Those messages

created titled, "The stalking of Kris Jenner."

.included, among other things, statements-about a stalker putting

tracking devices on Victim Jenner?s car, breaking into and tracking
Victim Jenner's iPhone, and obtaining naked photographs of

Victim Jenner.

jj. On or about August 15, 2014, defendant BANKSTON,
knowing that Victim Ellena was located at the offices of 
Entertainment Television in Los Angeles, California, sent
Victim Ellena an email saying, "you're at network I see you."
kk. On or about September 5, 2014, defendant BANKSTON told
agents from the Federal Bureau of Investigation that a person named
"Troy Leatherby" would be going to Victim Jenner's home the next day
and might the house or set it on fire,? or commit "some kind of

massacre," knowing that this was false.

12

 

COUNTS

3. Defendant engaged in the course of conduct and used the
facilities of interstate commerce described in paragraph 2 above,
with the intent to harass and intimidate the folloWing persons, and
caused, attempted to cause, and would have been reasonably expected
to cause, substantial emotional distress to that person and their

immediate family members.

COUNT: VICTIM:

ONE Victim Jenner
TWO Victim Ellena
THREE Victim C. Jenner
FOUR Victim A

FIVE Victim 

SIX Victim Stith

l3

 

 

COUNT SEVEN

[18 U.S.C. 1030(a)(2)(C), 

On or about June 10, 2014, in Los Angeles County, within the
Central District of California, and elsewhere, defendant CHRISTINA
"Christina Elizabeth

ELIZABETH BANKSTON, also known as

McGill," aka "Troy Leatherby," aka "Jacky Jasper," aka "Greg Comeau,"
aka "Browbuster," knowingly and intentionally accessed without
authorization and in excess of authorization a protected computer, as
Section

that term is defined in Title 18, United States Code,

a server of Apple Inc., and thereby obtained

lO30(e)(2), namely,

information, namely, the contents of an iCloud account belonging to
Kristen Jenner ("Victim Jenner") and the location of Victim Jenner's
iPhone, in furtherance of criminal and tortious acts, to wit,
stalking in-violation of 18 U.S.C. and 2261(b)(5), as
alleged in Counts One through Six of this Indictment, and the

California State Tort of Invasion of Privacy.

14

 

28'

"tortious acts,

 

 

COUNT EIGHT

[18 U.S.C. 1030(about June 10, 2014, in Los Angeles County, within the

Central District of California, and elsewhere, defendant 

ELIZABETH BANKSTON, also known as "Christina Elizabeth
McGill," aka "Troy Leatherby," aka "Jacky Jasper," aka "Greg Comeau,"
aka "Browbuster," knowingly and intentionally accessed without
authorization and in excess of authorization a protected computer, as
that term is defined in Title 18, United States Code, Section

1030(e)(2), namely, a server of Apple Inc., and thereby obtained
information, namely, the contents of an iCloud account belonging to
Kristen Jenner, and iMessage communications with Caitlyn Jenner, then
known as Bruce Jenner and Victim A, in furtherance of criminal and

to wit, stalking in violation of 
and 226l(b)(5), as alleged in Counts One through Six of

this Indictment, and the California State Tort of Invasion of

Privacy.

15

 

COUNT NINE
[l8 U.S.C. 1030(a)(2)(c), 

On or about June 11, 2014, in Los Angeles County, within the

Central District of California, and elsewhere, defendant CHRISTINA

ELIZABETH BANKSTON, also known as "Christina Elizabeth
McGill," aka "Troy Leatherby," aka "Jacky Jasper," "aka "Greg
Comeau," aka "Browbuster," knowingly and intentionally attempted to

access without authorization and in excess of authorization a

,protected computer, as that term is defined in Title 18, United

States Code, Section lO30(e)(2), namely, a/server of Instagram, and

thereby obtained information, namely, the contents of an Instagram

account belonging to Kristen Jenner, in furtherance of criminal and

tortious acts, to wit, stalking in violation of 18 U.S.C. 
and 226l(b)(5), as alleged in Counts One through Six of
this Indictment, and the California State Tort of Invasion of

Privacy.

16

 

 

COUNT TEN

[18 U.S.C. 1030(a)(2)(C), 

On or about June 11, 2014, in Los Angeles County, within the

Central District of California, and elsewhere, defendant CHRISTINA

ELIZABETH BANKSTON, also known as "Christina Elizabeth

McGill," aka "Troy Leatherby," aka "Jacky Jasper," aka "Greg Comeau,"
aka "Browbuster," knowingly and intentionally accessed without

authorization and in excess of authorization a protected computer, as

that term is defined in Title 18, United States Code, Section

1030(e)(2), namely, a server of AOL Inc., and thereby obtained
information, namely, the contents of an AOL email account belonging
to wit,

to Victim B, in furtherance of criminal and tortious acts,

stalking in violation of 18 U.S.C. and 226l(b)(5), as
alleged in Counts One through SiX'of this Indictment, and the

California State Tort of Invasion of Privacy.

17

 

10

11

12

13

14COUNT ELEVEN
[18 U.S.C. 1030(a)(7)(B), 

On or about August 6, 2014, in Los Angeles County, within the'
Central District of California, and elsewhere, defendant CHRISTINA
ELIZABETH BANKSTON, also known as "Christina Elizabeth
McGill," aka "Trovaeatherby," aka "Jacky Jasper," aka "Greg Comeau,?
aka "Browbuster," with intent to extort money and other things of
value, transmitted in interstate and foreign commerce an email to

Katherine Ellena ("Victim Ellena"), containing a threat to obtain

information from a protected computer without authorization and to

impair the confidentiality of information obtained from a protected

icomputer without authorization, namely, information from Victim

Ellena's iCloud account.

18

 

 

COUNT TWELVE
[18 U.S.C. 1028A(a)(l)]
On or about June 10, 2014, in Los Angeles County, within the
Central District of California, and elsewhere, defendant CHRISTINA
ELIZABETH BANKSTON, also known as ?Christina Elizabeth
McGill," aka "Troy Leatherby," aka "Jacky Jasper," aka "Greg," aka
"Browbuster," knowingly transferred, possessed, and used, without
lawful authority, a means of identification of another person, that
is, the username, password, and security answer of Kristen Jenner,
during_and in relation to Unauthorized Access to a Protected Computer
to Obtain Information, a felony violation of Title 18, United States

Code, Sections 1030(a)(2)(C), and as charged in Count

Seven of this Indictment.

l9

 

 

10

11

12

13

COUNT THIRTEEN 
[18 Use. 1028A(a) 
On or about June 10, 2014, in Los Angeles County, within the
defendant CHRISTINA

Central District of California, and elsewhere,

ELIZABETH BANKSTON, also known as "Christina Elizabeth
McGill," aka "Troy Leatherby," aka "Jacky Jasper," aka "Greg," aka
"Browbuster," knowingly transferred, possessed, and used, without
lawful authority, a means of identification of another person, that
is, the username, password, and security answer of Kristen Jenner,
during and in relation to Unauthorized Access to a.Protected Computer
to Obtain Information, a felony violation of Title 18, United States
and as charged in Count

Code, Sections 

Eight of this Indictment.

14mm_m_ 

 

 

COUNTHFOURTEEN

[18 U.S.C. 1028A(a)(1)]

On or about June 11, 2014, in Los Angeles County, within the

Central District of California, and elsewhere, defendant CHRISTINA

ELIZABETH BANKSTON, also known as "Christina Elizabeth

McGill," aka "Troy Leatherby," aka "Jacky JaSper," aka "Greg Comeau,"

aka "Browbuster," knowingly transferred, possessed, and used, without

lawful authority, a means of identification of another persOn, that
is, the name of Kristen Jenner, during and in relation to the

attempted Unauthorized Access to a Protected Computer to Obtain

Information, a felony violation of Title 18, United States Code,

Sections lO30(a)(2)(C), and as charged in Count

Nine of this Indictment.

21

 

COUNT FIFTEEN
[18 U.S.C. 1028A(a)(1)]
Between on or about June 11, 2014 in Los Angeles County,
within the Central District of California, and elsewhere, defendant
CHRISTINA ELIZABETH BANKSTON, also known as "Christina

Elizabeth McGill," aka "Troy Leatherby," aka "Jacky Jasper," aka
"Greg Comeau," aka "Browbuster," knowingly transferred, posSessed,
and used, without lawful authority, a means of identification of
another person, that is, the username, password, and security answer
of Victim B, during and in relation to Unauthorized Access to a

Protected Computer to Obtain Information, a felony violation of



22

 

 

Title 18, United States Code, Sections 1030(a)(2)(C), and

as charged in Count Ten of this Indictment.

A TRUE BILL



Foreperson

EILEEN M. DECKER
United States Attorney

230% We

PATRICIA A. DONAHUE
Assistant United States Attorney
Chief, National Security Division

TRACY L. WILKISON

Assistant United States Attorney
Chief, Cyber Intellectual
Property Crimes Section

s. CHRISTENSEN

Assistant United States Attorney
Deputy Chief,

Cyber Intellectual Property
Crimes Section

DAVID KOWAL

Assistant United States Attorney
Cyber Intellectual Property
Crimes Section

23