Case 4:20-cr-40033-LLP Document 1 Filed 02/04/20 Page 1 of 4 PageID #: 1

UNITED STATES DISTRICT COURT
DISTRICT OF SOUTH DAKOTA
SOUTHERN DIVISION

UNITED STATES OF AMERICA,
Plaintiff,

CR ''•20-CR-40033

REDACTiolNDICTMENT
SEXUAL ABUSE and ABUSIVE

vs.

SEXUAL CONTACT

PEDRO IBARRA-PEROCIER,
Defendant.

18 U.S.C. §§ 1152, 2242(1),
2244(a)(2), 2246(2), and 2246(3)

The Grand Juiy charges:
COUNT 1

On or about between approximately January 2017, and August 2018, in
Wagner, Charles Mix County, in Indian country, in the District of South Dakota,

the Defendant, Pedro Ibarra-Perocier, did knowingly cause and attempt to cause
Adult Victim #1, an Indian whose identity is known to the Grand Jury, to engage
in a sexual act by threatening and placing Adult Victim #1 in fear, all in violation
of 18 U.S.C. §§ 1152, 2242(1), and 2246(2).
COUNT 2

On or about between approximately January 2014, and February 2017, in
Wagner, Charles Mix County, in Indian country, in the District of South Dakota,

the Defendant, Pedro Ibarra-Perocier, did knowingly cause and attempt to cause

Adult Victim #2, an Indian whose identity is known to the Grand Jury, to engage
in a sexual act by threatening and placing Adult Victim #2 in fear, all in violation
of 18 U.S.C. §§ 1152, 2242(1), and 2246(2).

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COUNT 3

On or about between approximately April 2018, and August 2018, in
Wagner, Charles Mix County, in Indian country, in the District of South Dakota,

the Defendant, Pedro Ibarra-Perocier, did knowingly cause and attempt to cause
Adult Victim #3, an Indian whose identity is known to the Grand Jury, to engage
in a sexual act by threatening and placing Adult Victim #3 in fear, all in violation
of 18 U.S.C. §§ 1152, 2242(1), and 2246(2).
COUNT 4

On or about between approximately April 2018, and June 2018, in
Wagner, Charles Mix County, in Indian country, in the District of South Dakota,

the Defendant, Pedro Ibarra-Perocier, did knowingly cause and attempt to cause

Adult Victim #4, an Indian whose identity is known to the Grand Jury, to engage
in a sexual act by threatening and placing Adult Victim #4 in fear, all in violation
of 18 U.S.C. §§ 1152, 2242(1), and 2246(2).
COUNT 5

On or about between approximately January 2017, and August 2018, in
Wagner, Charles Mix County, in Indian country, in the District of South Dakota,

the Defendant, Pedro Ibarra-Perocier, did knowingly engage in, and attempt to
engage in, sexual contact with Adult Victim #1, an Indian whose identity is
known to the Grand Jury, by threatening and placing Adult Victim #1 in fear, all

in violation of 18 U.S.C. §§ 1152, 2244(a)(2), and 2246(3).

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COUNT 6

On or about between approximately January 2014, and February 2017, in
Wagner, Charles Mix County, in Indian country, in the District of South Dakota,

the Defendant, Pedro Ibarra-Perocier, did knowingly engage in, and attempt to
engage in, sexual contact with Adult Victim #2, an Indian whose identity is
known to the Grand Jury, by threatening and placing Adult Victim #2 in fear, all
in violation of 18 U.S.C. §§ 1152, 2244(a)(2), and 2246(3).
COUNT 7

On or about between approximately April 2018, and August 2018, in
Wagner, Charles Mix County, in Indian country, in the District of South Dakota,
the Defendant, Pedro Ibarra-Perocier, did knowingly engage in, and attempt to
engage in, sexual contact with Adult Victim #3, an Indian whose identity is
known to the Grand Jury, by threatening and placing Adult Victim #3 in fear, all
in violation of 18 U.S.C. §§ 1152, 2244(a)(2), and 2246(3).
COUNT 8

On or about between approximately August 2016, and June 2018, in

Wagner, Charles Mix County, in Indian country, in the District of South Dakota,

the Defendant, Pedro Ibarra-Perocier, did knowingly engage in, and attempt to
engage in, sexual contact with Adult Victim #4, an Indian whose identity is
known to the Grand Jury, by threatening and placing Adult Victim #4 in fear, all

in violation of 18 U.S.C. §§ 1152, 2244(a)(2), and 2246(3).

 Case 4:20-cr-40033-LLP Document 1 Filed 02/04/20 Page 4 of 4 PageID #: 4

A TRUE BILL:
REDACTED

Foreperson
RONALD A. PARSONS, JR.

United States Attorney