Case Document 1 Filed 08/28/18 Page 1 of 28 Page ID FILED DISTRICT com, 1 AUG 282018 In; xtIr* CLERK, Us 1r Hug/41E} WM. UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA June 2018 Grand Jury UNITED STATES OF AMERICA, CR Egon} ?a $565 - 0 Pmmu?, v. [18 U. S. C. 2261(b)(5): Stalking; 18 U. S. C. RICHARD GREGORY BAUER, 1030(a)(2)(C), (c aka ?Steve Smith,? Unauthorized Access to a Protected aka ?John Smith,? Computer to Obtain Information in aka ?Garret,? Furtherance of a Criminal or Tortious Act; 18 U.S.C. Defendant. 1028A(a)(1): Aggravated Identity Theft] The Grand Jury charges: COUNT ONE [18 U.S.C. 2261(b)(5)] 1. Beginning on or about February 7, 2015, and continuing to on or about June 11, 2018, in Los Angeles County, within the Central District of California, and elsewhere, defendant RICHARD GREGORY BAUER, also known as ?Steve Smith,? aka ?John Smith," aka ?Garret? with the intent to harass and intimidate Victim A, used an interactive computer service, electronic communication service, electronic communication system of interstate commerce, and Case Document 1 Filed 08/28/18 Page 2 of 28 Page ID other facilities of interstate and foreign commerce, namely, e?mail, interstate wires, and the Internet, to engage in a course of conduct, described in paragraph 2 below, that caused, attempted to cause, and would reasonably be expected to cause substantial emotional distress to Victim A. 2. Defendant course of conduct included, among other things, the following, all conducted in a manner designed to hide defendant true identity from Victim A, except where otherwise indicated: a. On or about February 7 and 8, 2015, defendant BAUER, without concealing his identity, sent Victim A a series of Facebook messages asking her a set of questions, purportedly for a project in his ?human societies class.? The questions, which Victim A answered, included typical questions used to reset online passwords, for example, the name of Victim A?s first pet. b. Beginning on or about March 28, 2017, and continuing through on or about June 11, 2018, defendant BAUER possessed, without Victim A?s authorization, an electronic database file containing approximately 178,889 text messages between Victim A and various recipients. c. On or about August 24, 2017, defendant BAUER sent Victim A an e?mail message with the subject ?Pics of you.? The e? mail attached a topless photograph of Victim A and the body of the message included the following: ?so a mutual friend gave me some pictures of you, and said you would give more. I liked what i saw. I assume this is you? i have more. So what do you say about II giving me some more? I dont want to put these Case Document 1 Filed 08/28/18 Page 3 of 28 Page ID #23 d. On or about August 24, 2017, defendant BAUER sent Victim A the following Facebook messages: i. ?this is the [Victim from woodland right?? ii. ?i sent you an email you may want to read? ?if you dont want your nude pictures on the internet respond back.? e. On or about August 26, 2017, defendant BAUER sent Victim A an emmail message with the subject ?your nudes.? The emmail attached the same topless photograph identified in paragraph 2.a above, and the body of the message included the following: ?i guess you dont care about having your fiance know about your nude pics on the to this email.? f. On or about January 5, 2018, defendant BAUER sent Victim A the following two e?mail messages: i. A message with the subject ?pics for your fiance The e?mail attached three selfie?style photographs of Victim A, two of which depicted her topless. The body of the message included the following: ?Hello [Victim how would you like these pictures for your fiance? don?t worry, i have many," and ?this isn?t a keep these and the many others i have from getting out. you will respond to this email.? ii. A follow?up message with the same subject, and the following in the body: guess you really don?t care about your fiance?s g. On or about January 9, 2018, defendant BAUER sent Victim A an e?mail message with the subject ?Great Wedding Information.? The emmail attached one of the topless photographs identified in paragraph 2.f.i above, another selfie?style photograph, 3 Case DOCument 1 Filed 08/28/18 Page 4 of 28 Page ID and a sexually explicit photograph. The body of the message the following: ?Hello [Victim Attached you will see some that will be most interesting for your upcoming what would your fiance think or your students think if these made public?? included pictures and ?now were Case Document 1 Filed 08/28/18 Page 5 of 28 Page ID #25 COUNT TWO [18 U.S.C. 1030(a)(2)(C), Beginning on or about January 6, 2017, and ending no later than January 11, 2018, in Los Angeles County, within the Central District of California, and elsewhere, defendant RICHARD GREGORY BAUER, also known as ?Steve Smith,? aka ?John Smith,? aka ?Garret,? intentionally accessed without authorization and in excess of authorization a computer, namely, a computer used by Victim B, and thereby obtained information, namely, computer account logins and passwords, from a protected computer, as that term is defined in Title 18, United States Code, Section 1030(e)(2)(B), in furtherance of criminal and tortious acts, to wit, Stalking in violation of 18 2261(b)(5), and the California State tort of Invasion of Privacy. Case Document 1 Filed 08/28/18 Page 6 of 28 Page ID #26 COUNT THREE [18 U.S.C. 2261(b)(5)] 1. Beginning on or about February 16, 2015, and continuing to on or about January 5, 2018, in Los Angeles County, within the Central District of California, and elsewhere, defendant RICHARD GREGORY BAUER, also known as ?Steve Smith,? aka ?John Smith,? aka ?Garret? with the intent to harass and intimidate Victim B, used an interactive computer service, electronic communication service, electronic communication system of interstate commerce, and other facilities of interstate and foreign commerce, namely, e?mail, interstate wires, and the Internet, to engage in a course of conduct, described in paragraph 2 below, that caused, attempted to cause, and would reasonably be expected to cause substantial emotional distress to Victim B. 2. Defendant course of conduct included, among other things, the following, all conducted in a manner designed to hide defendant true identity from Victim B, except where otherwise indicated: a. On or about February 16, 2015, defendant BAUER, without concealing his identity, sent Victim a series of Facebook messages asking her a set of questions, purportedly for a project in his ?human societies class.? The questions, which Victim answered, included typical questions used to reset online passwords, for example, the city where Victim B?s parents met. b. On or about January 6, 2017, defendant BAUER, without concealing his identity, sent Victim a series of Facebook messages asking Victim to help him test some software that he claimed to have written to improve image files. At defendant request, 6 Case Document 1. Filed 08/28/18 Page 7 of 28 Page ID #27 Victim installed the software, which was in reality malware intended by defendant BAUER to give him unauthorized access to Victim B?s computer. c. On or about August 24, 2017, defendant BAUER sent Victim the following Facebook messages: i. ?hi is this [Victim that lives in woodland?? ii. ?you should read the email i sent you? ?if you done want nude pictures of you on the internet respond back? d. On or about August 24, 2017, defendant BAUER sent Victim the following two e?mail messages: i. A message with the subject ?pictures of you.? The e?mail attached a topless photograph of Victim B, and the body of the message included the following: ?a mutual friend gave me some pictures of you assured me you could give me more. I assume the attached pic is would hate for these to get out so when can i get a new one? i have more." ii. A message with the subject ?if you dont want your nude pictures on the internet respond to this email.? The e?mail included the same topless photograph identified in paragraph 2.d.i above with the following message in the body: ?i have more." e. On or about January 5, 2018, defendant BAUER sent Victim the following two e?mail messages: i. A message with the subject ?pics just for you!? The e-mail attached the same topless photograph identified in paragraph 2.d.i above and another nude photograph of Victim The body of the message included the following: ?hello [Victim please take a look at these pics we gathered just for you,? and ?i have many 7 Case Document 1 Filed 08/28/18 Page 8 of 28 Page ID is not a joke. if you don?t want these and the others made public. respond to this.? f. A follow?up message with the following in the body: guess you don?t care if the whole world knows youre a was going to offer a proposal to keep your pics off the internet, but i guess you dont care.? Case Document 1 Filed 08/28/18 Page 9 of 28 Page ID #29 COUNT FOUR [18 U.S.C. 226l(b)(5)] 1. Beginning on or about August 21, 2016, and continuing to on or about January 5, 2018, within the Central District of California, and elsewhere, defendant RICHARD GREGORY BAUER, also known as ?Steve Smith,? aka ?John Smith,? aka ?Garret? with the intent to harass and intimidate Victim C, used an interactive computer service, electronic communication service, electronic communication system of interstate commerce, and other facilities of interstate and foreign commerce, namely, e?mail, interstate wires, and the Internet, to engage in a course of conduct, described in paragraph 2 below, that caused, attempted to cause, and would reasonably be expected to cause substantial emotional distress to Victim C. 2. Defendant course of conduct included, among other things, the following, all conducted in a manner designed to hide defendant true identity from Victim C, except where otherwise indicated: a. On or about August 21, 2016, defendant BAUER, without concealing his identity, sent Victim a series of Facebook messages asking her a set of questions, purportedly for a project in his ?human studies class.? The questions, which Victim answered, included typical questions used to reset online passwords, for example, the first car that Victim owned. b. On or about January 5, 2018, defendant BAUER sent Victim an e?mail with the subject ?Pictures for you!" The e~mail attached a topless selfie?style photograph of Victim The body of the message included the following: ?Hello [Victim.C], please have a 9 Case Document 1 Filed 08/28/18 Page 10 of 28 Page ID #:10 look at a sample for the pictures we have collected just for you!? and ?and I have you don?t want them public i suggest you respond to this. this is not a joke.? c. On or about January 5, 2018, defendant BAUER sent Victim a folloqup e?mail containing the following: i want four pictures of you daily. 1) fully clothed with your face visible 2) bra and underwear, your face doesn?t have to be visible 3) just underwear, your face doesn?t have to be visible 4) naked, your face doesn?t have to be visible if you do this, those pictures will not go public. what is your answer d. On or about January 5, 2018, defendant BAUER sent Victim a follow?up e?mail containing the following: ?this is fair, especially considering you don?t know how many pictures I e. On or about January 5, 2018, defendant BAUER sent Victim a follow?up e?mail containing the following: would take the deal, especially considering you don?t know how many pictures I have.? f. On or about January 5, 2018, defendant BAUER sent Victim a followHup e?mail containing the following: ?don?t think deleting your facebook will keep people from seeing i take it that means you do not take the deal?? g. On or about January 5, 2018, defendant BAUER sent Victim a follow?up e?mail containing the following: ?very well it seems you made your choice, well I didn?t want do this but you leave me no option.? h. On or about January 5, 2018, defendant BAUER sent Victim a follow?up e?mail containing the following: ?ok gave you a fair deal. If you change your mind at a later date, than I 10 Case Document 1 Filed 08/28/18 Page 11 of 28 Page ID #:11 will stop leaking your pictures on the internet. As of now, you are about to become one of the more popular girls on 4chan.? 11 Case Document 1 Filed 08/28/18 Page 12 of 28 Page ID #212 COUNT FIVE [l8 U.S.C. l030(a)(2)(C), On or about January 5, 2018, in Los Angeles County, within the Central District of California, and elsewhere, defendant RICHARD GREGORY BAUER, also known as ?Steve Smith,? aka ?John Smith,? aka ?Garret,? intentionally accessed without authorization and in excess of authorization a computer, namely, a server of Google, Inc., and thereby obtained information, namely, the contents of a Google e? mail account belonging to Victim C, from a protected computer, as that term is defined in Title l8, United States Code, Section in furtherance of criminal and tortious acts, to wit, Stalking in violation of 18 U.S.C. 226l(b)(5), and the California State tort of Invasion of Privacy. 12 Case Document 1 Filed 08/28/18 Page 13 of 28 Page ID #213 COUNT SIX [18 U.S.C. 1028A(a)(1)] On or about January 5, 2018, in Los Angeles County, within the Central District of California, and elsewhere, defendant RICHARD GREGORY BAUER, also known as ?Steve Smith,? aka ?John Smith," aka ?Garret? knowingly possessed and used, without lawful authority, a means of identification that defendant BAUER knew belonged to another person, that is the, username and password of Victim C, during and in relation to the offense of Unauthorized Access to a Protected Computer in Furtherance of a Criminal or Tortious Act, a felony Violation of Title 18, United States Code, Section 1030(a)(2)(C), as charged in Count Five of this Indictment. 13 Case Document 1 Filed ?_08/28/18 Page 14 of 28 Page ID #:14 COUNT SEVEN [18 U.S.C. 1030(a)(2)(C), Beginning on or about January 8, 2017, and ending no later than January 11, 2018, in Los Angeles County, within the Central District of California, and elsewhere, defendant RICHARD GREGORY BAUER, also known as ?Steve Smith,? aka ?John Smith,? aka ?Garret,? intentionally accessed without authorization and in excess of authorization a computer, namely, a computer used by Victim D, and thereby obtained information, namely, computer account logins and passwords, from a protected computer, as that term is defined in Title 18, United States Code, Section 1030(e)(2)(B), in furtherance of criminal and tortious acts, to wit, Stalking in violation of 18 U.S.C. 2261(b)(5), and the California State tort of Invasion of Privacy. 14 Case Document 1 Filed 08/28/18 Page 15 of 28 Page ID #215 COUNT EIGHT [18 U.S.C. 1030(a)(2)(C), Beginning on or about February 28, 2017, and ending no later than January 11, 2018, in Los Angeles County, within the Central District of California, and elsewhere, defendant RICHARD GREGORY BAUER, also known as ?Steve Smith,? aka ?John Smith,? aka ?Garret,? intentionally accessed without authorization and in excess of authorization a computer, namely, a server of Facebook, Inc., and thereby obtained information, namely, the contents of a Facebook account belonging to Victim D, from a protected computer, as that term is defined in Title 18, United States Code, Section 1030(e)(2)(B), in furtherance of criminal and tortious acts, to wit, Stalking in violation of 18 U.S.C. 2261(b)(5), and the California State tort of Invasion of Privacy. 15 Case Document 1 Filed 08/28/18 Page 16 of 28 Page ID #216 COUNT NINE [18 U.S.C. 1028A(a)(l)] On or about February 28, 2017, in Los Angeles County, within the Central District of California, and elsewhere, defendant RICHARD GREGORY BAUER, also known as ?Steve Smith,? aka ?John Smith,? aka ?Garret? knowingly possessed and used, without lawful authority, a means of identification that defendant BAUER knew belonged to another person, that is, the username and password of Victim D, during and in relation to the offense of Unauthorized Access to a Protected Computer in Furtherance of a Criminal or Tortious Act, a felony violation of Title 18, United States Code, Section 1030(a)(2)(C), as charged ianount Eight of this Indictment. l6 Case Document 1 Filed 08/28/18 Page 17 of 28 Page ID #217 COUNT TEN [l8 U.S.C. 1030(a)(2)(C), Beginning on or about January 27, 2017, and ending no later than January 11, 2018, in Los Angeles County, within the Central District of California, and elsewhere, defendant RICHARD GREGORY BAUER, also known as ?Steve Smith,? aka ?John Smith,? aka ?Garret,? intentionally accessed without authorization and in excess of authorization a computer, namely, a computer used by Victim E, and thereby obtained information, namely, computer account logins and passwords, from a protected computer, as that term is defined in Title 18, United States Code, Section 1030(e)(2)(B), in furtherance of criminal and tortious acts, to wit, Stalking in violation of 18 U.S.C. 226l(b)(5), and the California State tort of Invasion of Privacy. 17 Case Document 1 Filed 08/28/18 Page 18 of 28 Page ID #:18 COUNT ELEVEN [18 U.S.C. 2261(b)(5)] 1. Beginning on or about August 21, 2017, and continuing to on or about January 10, 2018, in Los Angeles County, within the Central District of California, and elsewhere, defendant RICHARD GREGORY BAUER, also known as ?Steve Smith,? aka ?John Smith,? aka ?Garret? with the intent to harass and intimidate Victim F, used an interactive computer service, electronic communication service, electronic communication system of interstate commerce, and other facilities of interstate and foreign commerce, namely, e-mail, social media, interstate wires, and the Internet, to engage in a course of conduct, described in paragraph 2 below, that caused, attempted to cause, and would reasonably be expected to cause substantial emotional distress to Victim F. 2. Defendant course of conduct included, among other things, the following, all conducted in a manner designed to hide defendant true identity from Victim F: a. On or about August 21, 2017, defendant BAUER sent Victim an e?mail with the subject ?You dont want those pics out on the internet.? The e?mail included a nude photograph of Victim F, and the body of the message instructed Victim to ?check your fb messenger or more of these will go on the internet.? b. On or about August 21, 2017, defendant BAUER sent Victim the following Facebook messages: i. ?hi is this [Victim from a woodland ca?? ii. ?a mutual friend of ours gave me some pictures of you and assured me you would be nice enough to give me more? 18 Case Document 1 Filed 08/28/18 Page 19 of 28 Page ID #219 ?i don?t want to put them on the internet for everyone else to see if possible.? iv. ?and i have proof that this is not a joke? c. On or about August 21, 2017, defendant BAUER sent Victim a Facebook message containing the same nude photograph identified in paragraph 2.a above, and the following Facebook messages: i. ?i think you remember thiis picture, i have more? ii. ?this [Victim from woodland?? ?so you want your nudes on the internet?? d. On or about August 24, 2017, defendant BAUER sent Victim an e-mail with the subject ?if you dont want your nude pictures on the internet respond to this.? The e?mail included the same nude photograph identified in paragraph 2.a above and another topless photograph of Victim F, with the following message in the body: ?i have plenty more too.? e. On or about August 26, 2017, defendant BAUER sent Victim an e?mail with the subject ?you have 4 hours.? The body of the message instructed Victim F: ?you have 4 hours to respond to my email or i will post you nude pictures on the internet.? f. On or about August 27, 2017, defendant BAUER sent Victim an e~mail with the subject ?look at this.? The ewmail included the same nude photograph identified in paragraph 2.a above and the following message in the body: ?i will make your pictures public unless you respond to this. i dont want money, or your identity information, just to talk. 1 dont want to embarass your 19 Case Document 1 Filed 08/28/18 Page 20 of 28 Page ID #220 g. On or about August 28, 2017, defendant BAUER sent Victim an e?mail with the subject ?youre wrong,? and the following message in the body: ?listen bitch, if you think changing your email address will protect you, you?re wrong. now all i want to do is simply talk. its up to you to avoid to public knowing youre a slut.? h. On or about January 4, 2018, defendant BAUER sent Victim an e?mail with the subject ?you thought wrong,? and the following in the message body: hey there [Victim you thought you could duck me by changing your email address? I guess you honestly dont care about have your nudes spread on the internet? I would prefer to keep these to myself, but if you continue to ignore me, I have no other option. You know the sheer amount of pictures you took and that i have at my disposal. Do you really want those out? respond to this email with ?fuck you mr.smith? so I know you read it. mr.smith i. On or about January 4, 2018, defendant BAUER sent Victim a follow?up e?mail which included five topless photographs of Victim and the following message in the body: ?and just in case you think im kidding, i have attached some of the photos. see for your self. Don?t ignore me j. On or about January 8, 2018, defendant BAUER sent Victim another follow?up e?mail with the following message in the body: ?do you really think getting rid of your facebook will work this time?? 20 Case Document 1 Filed 08/28/18 Page 21 of 28 Page ID #221 COUNT TWELVE [l8 U.S.C. 2261(b)(5)] 1. Beginning on or about August 24, 2017, and continuing to on or about January 11, 2018, in Los Angeles County, within the Central District of California, and elsewhere, defendant RICHARD GREGORY BAUER, also known as ?Steve Smith,? aka ?John Smith,? aka ?Garret? with the intent to harass and intimidate Victim G, used an interactive computer service, electronic communication service, electronic communication system of interstate commerce, and other facilities of interstate and foreign commerce, namely, emmail, social media, Google Chat, interstate wires, and the Internet, to engage in a course of conduct, described in paragraph 2 below, that caused, attempted to cause, and would reasonably be expected to cause substantial emotional distress to Victim G. 2. Defendant course of conduct included, among other things, the following, all conducted in a manner designed to hide defendant true identity from Victim G: a. On or about August 24, 2017, defendant BAUER sent Victim a topless photograph of Victim using a Facebook message, followed by the message: ?if you dont want your other nude pics on the internet, respond to this.? b. On or about August 25, 2017, defendant BAUER sent Victim an e?mai1 with the subject ?your pictures.? The e?mail included the same topless photograph of Victim identified in paragraph 2.a above, and the body of the message included: ?a mutual friend gave me this and many more, if you dont want these getting out on the internet, respond to this email and lets talk." 21 Case Document 1 Filed 08/28/18 Page 22 of 28 Page ID #:22 c. On or about August 26, 2017, defendant BAUER sent Victim an e?mail with the subject ?4 hours,? with a body that read: ?you have 4 hours to respond to my email before i make those nude pictures public.? d. On or about August 26, 2017, defendant BAUER sent Victim an e?mail with the subject ?getting rid of fb isn?t the answer,? with a body that read: ?tell you give me your icloud password and a selfie of bf will never know about this.? e. On or about January 5, 2018, defendant BAUER sent Victim an e~mail with the subject ?Pictures For The New Year.? The e?mail attached a topless photograph of Victim and a photograph of Victim in lingerie. The body of the message included the following: ?Hello [Victim To welcome in the new year, we have collected a few photos that we thought you would like to see and share in the fond memories. As you can see these are no ordinary photos. If you dont want these on the internet, you will respond to this email.? f. On or about January 5, 2018, defendant BAUER sent Victim the following Google Chat message: ?hello [Victim this might be easier to talk on, don?t keep me waiting too long.? g. On or about January 9, 20l8, defendant BAUER sent Victim an ewmail with the subject ?Hello and the following body: you like to hear my proposition to keeping those private?? h. On or about January 11, 2018, defendant BAUER sent Victim an e?mail with the subject ?Hello [Victim and the following body: ?So I see you have tried to ignore my emails do 22 Case Document 1 Filed 08/28/18 Page 23 of 28 Page ID #223 you think this is the best strategy to avoid those pictures getting on the internet? I have a proposition for you in order for them to remain private. Would you like to hear it? Make no mistake, I will post them. Let?s at least have a little Chat about it first.? 23 Case Document 1 Filed 08/28/18 Page 24 of 28 Page ID #:24 COUNT THIRTEEN [18 U.S.C. 2261(b)(5)] 1. Beginning on or about January 28, 2017, and continuing to on or about January 11, 2018, in Los Angeles County, within the Central District of California, and elsewhere, defendant RICHARD GREGORY BAUER, also known as ?Steve Smith,? aka ?John Smith,? aka ?Garret? with the intent to harass and intimidate ViCtim H, used an interactive computer service, electronic communication service, electronic communication system of interstate commerce, and other facilities of interstate and foreign commerce, namely, e?mail, interstate wires, and the Internet, to engage in a course of conduct, described in paragraph 2 below, that caused, attempted to cause, and would reasonably be expected to cause substantial emotional distress to Victim H. 2. Defendant BAUER's course of conduct included, among other things, the following, all conducted in a manner designed to hide defendant true identity from Victim H, except where otherwise indicated: a. Beginning on or about January 10, 2017 and continuing through on or about February 11, 2017, defendant BAUER, without concealing his identity, sent Victim a series of Facebook messages asking Victim to help him test some software that he claimed to have written to improve image files. On or about January 27, 2017, Defendant BAUER sent the software to Victim in a Facebook message. The software was in reality malware intended by defendant BAUER to give him unauthorized access to Victim H?s computer. b. On or about January 3, 2018, defendant BAUER sent Victim an e?mail with the subject ?Is this you? I think so.? The 24 Case Document 1 Filed 08/28/18 Page 25 of 28 Page ID #225 e-mail attached two selfie?style photographs of Victim H, one of which was topless. The body of the message included the following: Hello [Victim If you do not want these posted on the internet for everyone to see, you will respond to this email. I do not want money or any other personal information. Just to talk. I have attached just some of the pictures I have of you, believe me when I say I have many more. This is not a joke c. On or about January 4, 2018, defendant BAUER sent Victim a follow~up e?mail with the following body: ?wow [Victim didn?t think you would want your boyfriend to find those on the internet for everyone to d. On or about January 5, 2018, defendant BAUER sent Victim a follow-up e?mail with the following body: see you deleted your facebook. That will not stop people from seeing your pictures. Now I?m trying to be fair here, all i want to do is talk, but if you keep on ignoring me, I will post them.? e. On or about January 5, 2018, defendant BAUER sent Victim a follow?up e?mail. The body of the message included the following: my proposal is this I want four daily photos of you fully clothed with face bra and panties with no face no bra but panties on with no face )fully nude with no face you do this and your nude photos stay privateabout January 5, 2018, defendant BAUER sent Victim a follow?up e?mail with the following body: ?or you could ignore me for a little big longer and just accept they will be on the internet for everyone to see, and with your cute little face in them too. 25 Case Document 1 Filed 08/28/18 Page 26 of 28 Page ID #226 COUNT FOURTEEN [18 U.S.C. 226l(b)(5)] 1. Beginning on or about January 8, 2018, and continuing to on or about January 10, 2018, within the Central District of California, and elsewhere, defendant RICHARD GREGORY BAUER, also known as ?Steve Smith,? aka ?John Smith,? aka ?Garret? with the intent to harass and intimidate Victim I, used an interactive computer service, electronic communication service, electronic communication system of interstate commerce, and other facilities of interstate and foreign commerce, namely, e?mail, interstate wires, and the Internet, to engage in a course of conduct, described in paragraph 2 below, that caused, attempted to cause, and would reasonably be expected to cause substantial emotional distress to Victim I . 2. Defendant course of conduct included, among other things, the following, all conducted in a manner designed to hide defendant true identity from Victim I: a. On or about January 8, 2018, defendant BAUER sent Victim I an e?mail with the subject ?Pictures You Have To See!" The ewmail attached two photographs of Victim I, and included the I following in the body: Hello [Victim Over the years we have collected some pictures for you to look back on and You wouldn?t want those tits to be exposed publicly right? With all the work you do? I have the photos, and no this is not a joke. Respond to this email and we can talk about a proposition I have for b. On or about January 8, 2018, defendant BAUER sent Victim I a follow?up e?mail including the following: ?Wow [Victim 26 Case Document 1 Filed 08/28/18 Page 27 of 28 Page ID #227 didn?t realize you wanted all your [Entity co-workers to know you?re a slut? c. On or about January 9, 2018, defendant BAUER sent Victim I a follow-up e?mail including the following: ?it?s rude to ignore a conversation d. On or about January 9, 2018, defendant BAUER sent an ewmail to an undercover law enforcement officer posing as Victim I with the subject fproposition.? The body of the message included the following: hi there, so here is my proposition, and you can take it or leave it, just be aware of.the consequences if you to keep those pictures private I am requesting the following: 4 daily pictures. l)selfie of your face 2) bra and underwear no face 3)no bra only underwear no face 4) no clothes no face choice about January 9, 2018, defendant BAUER sent Victim I a followHup e?mail including the following: ?so i take it by your silence that you are refusing the proposition?? f. On or about January 9, 2018, defendant BAUER sent an e?mail to an undercover law enforcement officer posing as Victim I with the subject ?Ultimatum." The body of the message included the following: [Victim for someone so scared for your work image, you don?t act like it. My proposition is a reasonable one. You clearly are ignoring these so I?m giving you one final chance, otherwise all of [Entity will know the slutty things you can do and have done with that body of yours. I have tried to be fare. Now, what is your work image worth to you? 27 Case Document 1 Filed 08/28/18 Page 28 of 28 Page ID #228 Me dumping your nude body all over the internet so everyone knows about it, or you sending me a couple explicit ones without a face so no one really knows who it is but me? thechoiceijsyours[VictimZIJ, foryour work?s sake I hope you make the right one . A TRUE BILL 26/ Foreperson NICOLA T. HANNA United States Attorney We (1. PATRICK R. FITZGE LD Assistant United States Attorney Chief, National Security Division RYAN WHITE Assistant United States Attorney Chief, Cyber Intellectual Property Crimes Section JENNIE L. WANG Assistant United States Attorney Deputy Chief, Cyber Intellectual Property Crimes Section KHALDOUN SHOBAKI Assistant United States Attorney Cyber Intellectual Property Crimes Section 28