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BILL OF PARTICULARSCR 09-263 RMW 1

JOSEPH P. RUSSONIELLO (CSBN 44332)United States Attorney

BRIAN J. STRETCH (CSBN 163973)Chief, Criminal Division

ELISE BECKER (NYSBN 2540730)GRANT P. FONDO (CSBN 181530)Assistant United States Attorneys

450 Golden Gate Avenue San Francisco, California 94102

Telephone: (415) 436-7200 Facsimile: (415) 436-7234Emails: elise.becker@usdoj.gov

grant.fondo@usdoj.gov

Attorneys for the Plaintiff

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN JOSE DIVISION

UNITED STATES OF AMERICA ) CR 09-263 RMW)

Plaintiff, ) BILL OF PARTICULARS)

v. ))

JOSEPH BUDDENBERG, )MARYAM KHAJAVI, )NATHAN POPE, A/K/A NATHAN KNOERL, )ADRIANA STUMPO, )

)Defendants. )

)

Pursuant to a written request by defendant Adriana Stumpo, joined by defendant Nathan

Pope, the government submits this Bill of Particulars to specify the particular dates, locations,

and acts underlying the course of conduct charge and supporting the conspiracy charge against all

four defendants.

The governments theory is that the following facts constitute a course of conduct committed

for the purpose of damaging or interfering with the operations of the University of California

(UC), an academic enterprise that uses animals for research, which intentionally placed, and

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attempted to place the following individuals in reasonable fear of the death of or serious bodily

injury to that person or their family, and that the following acts were committed by one or more

of the defendants in furtherance of the conspiracy:

On or about October 21, 2007, defendants Joseph Buddenberg, Nathan Pope, and Adriana

Stumpo engaged in acts of threats, trespassing, harassment, and intimidation against L.B. and his

family, as reflected in UC Berkeley Police Department case number 07-04650, and El Cerrito

Police Department case number 2007-19698;

On or about January 27, 2008, defendants Joseph Buddenberg, Maryam Khajavi, Nathan

Pope, and Adriana Stumpo engaged in acts of threats, harassment, and intimidation against R.B.,

Y.D., B.D.L., R.F., J.G., S.G., M.M.P., and their families, as reflected in Berkeley Police

Department case number 08-4788, and UC Berkeley Police Department case number 08-00377;

On or about February 2, 2008, defendant Joseph Buddenberg engaged in acts of threats,

trespass, harassment, and intimidation against R.B. and his family as reflected in UC Berkeley

Police Department case number 08-00489 and Berkeley Police Department case number 08-

5861;

On or about February 17, 2008, defendants Maryam Khajavi, Nathan Pope, and Adriana

Stumpo engaged in acts of trespass, vandalism, harassment, and intimidation against R.B., J.C.,

R.F., J.G., F.W., and F.T., and their families, as reflected in Berkeley Police Department case

numbers 08-08397, 08-08399, 08-8411, 08-8415, and 08-8427, and UC Berkeley Police

Department case number 08-00737;

On or about February 24, 2008, defendants Joseph Buddenberg, Maryam Khajavi, Nathan

Pope, and Adriana Stumpo engaged in acts of threats, criminal trespass, harassment, and

intimidation against L.H. and her family, as reflected in Santa Cruz Police Department case

number 08S-01584;

On or about March 23, 2008, defendant Joseph Buddenberg engaged in acts of threats,

trespass, vandalism, harassment, and intimidation against Y.D., J.G., J.C., I.Z., R.F., and S.G.,

and their families, as reflected in Oakland Police Department case number 08-021897, and UC

Berkeley Police Department case numbers 08-01251 and 08-1252;

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On or about March 30, 2008, defendant Joseph Buddenberg engaged in acts of threats,

trespass, vandalism, harassment, and intimidation against L.B., M.M.P., J.G., and their families,

as reflected in Berkeley Police Department case number 08-15993, UC Berkeley Police

Department case number 08-01329, El Cerrito Police Department case number 08-06074, and

Oakland Police Department case number 08-023788;

From on or about July 27, 2008, through on or about July 29, 2008, defendants Joseph

Buddenberg, Nathan Pope, and Adriana Stumpo engaged in conduct, including obtaining

information relating to bio-medical researchers at UC Santa Cruz and distributing a flyer at Caf

Pergolesi in Santa Cruz which was an act of threat, harassment, and intimidation against the

thirteen individuals listed in the flyer, as reflected in Santa Cruz Police Department case number

08S-06774.

This Bill of Particulars does not list all of the evidence that the government will seek to

introduce in support of the charges. This Bill of Particulars does not include acts committed by

one or more of the defendants that the government will seek to introduce at trial as evidence of

other crimes, wrongs, or acts under Fed. R. Crim. P. 404(b).

Dated: April 9, 2010 Respectfully submitted,

JOSEPH P. RUSSONIELLOUNITED STATES ATTORNEY

/s/ Elise BeckerGrant FondoAssistant United States Attorneys

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