KAMALA D. HARRIS Attorney General of California · PDF fileCOMPLAINT [FELONY] Plaintiff, v....

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KAMALA D HARRIS

Attorney General of California TAWNYA AUSTIN F DF

I I lj

I

Deputy Attorney General State Bar No 198663

110 West A Street Suite 1100 San Diego CA 921 01 PO Box 85266 San Diego CA 92186-5266 Telephone (619) 645-2823 Fax (619) 645-2489 E-mail TawnyaAustindojcagov

Attorneysfor People ofthe State ofCal[(ornia

SUPERIOR COURT OF THE STATE OF CALIFORNIA

SAN DIEGO SUPER10R COURT

THE PEOPLE OF THE STATE OF Case No CALIFORNIA

COMPLAINT [FELONY] Plaintiff

v

KEVIN CHRISTOPHER BOLLAERT (DOB 6271986)

Defendant

The Attorney General of the State of California hereby accuses Kevin BOLLAERT of the

following criminal offenses

Countl

In and between December 2 2013 and September 17 2013 in the County of San Diego the

crime of Conspiracy in v iolation of Penal Code section 182 (a)() a felony was committed by

Kevin BOLLAERT who did unlawfully conspire together with another person and persons

whose identity is unknown to commit the crime of Identity Theft in violation of Penal Code

Complaint [Felony)

section 5305 a fel ony that pursuant to and for the purpose of carrying out the objectives and

2 purposes of the aforesaid conspiracy that Kevin BOLLAERT and others committed the

3 following overt acts at and in the County of San Diego overt act(s)

4 Overt Act 1

5 Between December 2 20 12 and September 17 2013 Kevin BOLLAERT was the

6 administrator of a websi te called ugotpostedcom

7 Over Act 2

8 Between December 2 2012 and September 172013 Kevin BOLLAERT with the

9 assistance of known a nd unknown conspirators posted Ten Thousand One Hundred Seventy

I 0 (I 0 170) private photographs containing nude and ex plicit images of individuals who did not give

11 permission for their private images to be posted online

12 Overt Act 3

13 Between December 2 2 012 and September 172013 Kevin BOLLAERT posted the

14 personal identi fying informat ion of over ten th ousand individuals in conjunction with pri vate

15 images of those individuals without their permi ssion

16 Overt Act 4

17 On July 122013 Kevin BOLLAERT failed to rem ove images of Jane Doe 6 following

18 the receipt of an email from Jane Doe 6 stating that due to private images of her a long with her

19 personal identifying information being posted on ugotpostedcom she was scared for my life

20 Peop le are calling my work p lace and they obta ined the information from thi s site I did not give

21 permission for anyone to put up those pictures or my personal information I have contacted the

22 police but these pictures need to come down Pl ease

23 Overt Act 5

24 On July 17 2013 Kevin BOLLAERT fai led to remove images of Jane Doe 8 fo llowing

25 the receipt of an email from Jane Doe 8 requesting h er private information and images be taken

26 down from ugotposted co m stating she was getting nonstop harassing messages

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28 2

Comp laint [Felony]

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Overt Act 6

Between June 20 2013 and August 26 2013 Kevin BOLLAERT received and reviewed

over 2000 emails from individuals requesting their personal identifying information and images

be removed from ugotpostedcom

Overt Act 7

In October of2012 Kevin BOLLAERT with the assistance of known and unknown

conspirators opened and updated an online account called changemyreputation com

Overt Act 8

Between December 2 2012 and September 17 2013 Kevin BOLLAERT collected in

excess of $1 OOOO(ten thousand dollars) via changemyreputationcom from individuals paying to

have the ir personal identifying information and images removed from ugotpostedcom

Count 2

On or about April4 2013 in the County of San Diego the crime ofldentity Theft in

vio lation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who

did willfully and unlawfully obtain personal identifying information of Jane Doe 1 and used that

informatio n for an unlawful purpose to wit to harass and annoy without the consent of Jane Doe

1

Count 3

On or about April4 2013 in the County of San Diego the crime ofidentity Theft in

vio lation of Pe nal Code section 530 5(a) a felony was committed by Kevin BOLLAERT who

did willfu lly and unlawfully obtain personal identifying information of Jane Doe 1 and used that

information for an unlawful purpose and to obtain and attempt to obtain credit goods services

and money without the consent of Jane Doe 1

Count 4

On or about April4 2013 in the County of San Diego the crime ofExtortion in violation

of Penal Code Section 520 a felony was committed by Kevin BOLLAERT who extm1ed money

and or other property from Jane Doe 1 by means of threat such as is mentioned in Penal Code

Section 519 to wit to expose or to impute to her any disgrace or expose an y secret affecting her

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Complaint [Felon y]

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Count 5

On or about April 18 20 13 in the County of San Diego the crime ofldentity Theft in

vio lation of Penal Code section 5305(a) a fel ony was committed by Kevin BOLLAERT who

did willfully and unlawfull y obtain personal identifying information of Jane Doe 2 and used that

information for an unlawful pmpose to wit to harass and annoy without the consent of Jane Doe

2

Count 6

On or about Apri l 18 2013 in the County of San Diego the crime of Identity Theft in

violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who


information for an unlawful purpose and to obtain and attempt to o btain credit goods services

and money w ithout the consent of Jane Doe 2

Count 7

On or about April 18 2013 in the County of San Diego the crime of Extortion in violation of

Penal Code Section 520 a fe lony was committed by Kevin BOLLAERT who extorted money


Section 519 to wit to expose or to impute to her any disgrace or expose any secret affecting her

CountS

On or about April 29 2013 in the County of San Diego the cr ime of Identity T heft in

violation of Penal Code section 5305(a) a felony was committed b y Kevin BOLLAERT who

did willfully and unlawfully obtain personal identifying infonnation of Jane Doe 3 and used that

information for an unlawful purpose to wit to harass and annoy without the consent of Jane Doe

3

Count 9

On or about April 29 2013 in the County of San Di ego the crime ofidentity Theft in

v iolati on of Penal Code section 5305(a) a felony was com mitted by Kevin BOLLAERT who


4

Complaint [Felony]

information for an unlawful purpose and to obtai n and attempt to obtain cred it goods serv ices

2 and money without the consent of Jane Doe 3

3 CountlO

4 On or about May 13 2013 in the County of San Diego the crime ofldentity Theft in

5 violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who

6 did wi llfull y and unl awfu lly obtain persona l identifying information of Jane Doe 4 and used that

7 inform ation for an unlawful purpose to wit to harass and annoy without the consent of Jane Doe

8 4

9 Countll

1 0 On or about May 13 20 13 in the County of San Diego the crime of Identity Theft in

11 vio lation of Penal Code section 5305(a) a fel ony was committed by Kev in BOLLAERT who

12 did willfully and unlawfully obtain personal identify ing information of Jane Doe 4 and used that

13 information for an unlawful purpose and to obtai n and attempt to obtain credit goods services

14 and money without the consent of Jane Doc 4

15 Count 12

16 On or about J ul y 6 20 13 in the County of San Diego the crime ofldentity Theft in



19 information for an unlawful purpose to wit to harass and annoy without the consent of Jane Doe

20 5

2 1 Cou nt 13

22 On or about July 6 20 13 in the County of San Diego the crime ofldentity Theft in

23 v iolati on of Penal Code section 5305(a) a fe lony was committed by Kevin BOLLAERT who

24 did w illfull y and unlawfully obta in personal identifying information of Jane Doe 5 and used that

25 information for an unlawful purpose and to obtain and attempt to obtain credit goods services

26 and money w ithout the consent of Jane Doe 5

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5

Complaint Felony]

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Count 14

On or abo ut Ju ly 122013 in the County of San Diego the crime ofldentity Theft in

violation of Penal Code section 5305(a) a felon y was committed by Kevin BOLLAERT who

did willfull y and unlawfully obtain personal identifying inform atio n of Jane Doe 6 and used that

informati on for an unlawful purpose to wit to harass and annoy without the consent of Jane Doe

6

Count IS

On or about Jul y 12 2013 in the County of San Diego the crime ofldentity Theft in


did willfully and unlawfully obtain personal identifying informatio n of Jane Doe 6 and used that

information for an unl awful purpo se and to obtain and attempt to obtain credit goods services

and money wi thout the consent of Jane Doe 6

Count 16

On or about July 16 2013 in the County of San Diego the crime of Identity Theft in

v iolation of Penal Code section 5305(a) a felon y was committed by Kevin BOLLAERT who

did willfully and unlawfull y obtain personal identifying info rmation of Jane Doe 7 and used that

information for an unl awful purpose to wit to harass and annoy without the consent of Jane Doe

7

Countl7

On or about Jul y 16 2013 in the County of San Diego the crime of Identity Theft in

violation ofPenal Code section 5305(a) a felony was committed by Kevin BOLLAERT who

did willfully and unlawfully obtain personal identifyi ng information of Jane Doe 7 and used that

information for an unl awful purpose and to obtain and attempt to obtain cred it goods services

and mone y without the co nsent of Jane Doe 7

Countl8

On or about August 4 2013 in the County of San Diego the crime of Identity Theft in

violation of Penal Code section 5305(a) a fel ony was committed by Kevin BOLLAERT who

did willfully and unl awfully obtain p ersonal identifying informati on of Jane Doe 8 and used that

6

Complaint [Felony]

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information for an unlawful purpose to w it to harass and annoy without the consent of Jane Doe

8

Count19

On or about August 4 20 13 in the County of San Diego the crime of Identity Theft in

violati on of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who

did willful ly and unlawfully obtain personal identifying informati on of Jane Doe 8 and used that

information for an unl awful purpose a nd to obtain and attempt to obtai n credit goods services


Count20

On or about A ugust 6 20 I 3 in the County of San Diego the c rime ofldentity Theft in

v iolation of Penal Code secti on 5305(a) a felony was committed by Kevin BOLLAERT who

did wi llfully and unlawfully obtain personal identify ing information of Jane Doc 9 and used that


9

Count21

On or about August 6 20 I 3 in the County of San Diego the crime o f Identity Theft in

v iolation of Penal Code section 5305(a) a fe lony was committed by Kevin BOLLAERT who

d id willfully and unlawfully obtain personal identifying informatio n of Jane Doc 9 and used that

information for an unl awful purpose and to obtain and attempt to obtain credit goods services


Count 22

On or abo ut August 13 20 I 3 in the County of San Diego the crime ofldentity Theft in


did willfully and unlawfull y obtain personal identifying information of Jane Doe I 0 and used

that information for an unlawful purpose to w it to harass and annoy without the consent of Jane

Doe 1 0

7

Complaint [Fe lony]

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Count 23



did willfully and unlawfully obtain personal identifying informati on of Jane Doe 1 0 and used

that information for an unlawful purpose and to obtain and attempt to obtain credit goods

services and money without the consent of Jane Doe 1 0

Count 24

On or about August 26 2013 in the County of San Diego the crime ofldentity Theft in

v iolation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who

did willfully and unlawfully obtain personal identifying information of Jane Doe 11 and used

that information for an unlawfu l purpose to w it to harass and annoy without the consent of Jane

Doe 11

Count 25



did willfully and unlawfully obtain personal identifying information of Jane Doe II and used



Count 26

O n or about September 4 2013 in the County of San Diego the crime ofldentity Theft in


did willfully and unlawfully obtain personal identify ing information of Jane Doe 12 and used

that informati on for an unlawful purpose to wit to harass and annoy without the consent of Jane

Doe 12

Count 27

On or ab out September 4 20 13 in the County of San Diego the crime of Identity Theft in


did will full y and unlawfully obtain personal identifying information of Jane Doe 12 and used

8

Complaint [Felony]

5

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20

25


2 services and money without the consent ofJane Doe 12

3 Count28

4 On or about September 10 2013 in the County of San Diego the crime of Identity Theft

in violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT

6 who did willfully and unlawfully obtain personal identifying information of Jane Doe 13 and

7 used that information for an unlawful purpose to wit to harass and annoy without the consent of

8 Jane Doe 13

9 Count 29

On or about September 10 2013 in the County of San Diego the crime of Identity Theft

11 in violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT


13 used that information for an unlawful purpose and to obtain and attempt to obtain credit goods

14 services and money without the consent of Jane Doe 13

Count 30

16 On or about September 12 2013 in the County or San Diego the crime of Identity Theft




Jane Doe 14

21 Count31

22 On or about September 12 2013 in the County of San Diego the crime ofidentity Theft


24 who did willfully and unlawfully obtain personal identifying information of Jane Doe14 and

used that information for an unlawful purpose and to obtain and attempt to obtain credit goods

26 services and money without the consent of Jane Doe14

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28

9

Complaint [Felony)

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Dated

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December 10 2013 Respectfully Submitted

KAMALA D HARRIS Attorney General of California

TAWNYA AUSTIN Deputy Attorney General Attorneysfor the People ofthe State of California

10

Complaint [Felony)

section 5305 a fel ony that pursuant to and for the purpose of carrying out the objectives and

2 purposes of the aforesaid conspiracy that Kevin BOLLAERT and others committed the

3 following overt acts at and in the County of San Diego overt act(s)

4 Overt Act 1

5 Between December 2 20 12 and September 17 2013 Kevin BOLLAERT was the

6 administrator of a websi te called ugotpostedcom

7 Over Act 2

8 Between December 2 2012 and September 172013 Kevin BOLLAERT with the

9 assistance of known a nd unknown conspirators posted Ten Thousand One Hundred Seventy

I 0 (I 0 170) private photographs containing nude and ex plicit images of individuals who did not give

11 permission for their private images to be posted online

12 Overt Act 3

13 Between December 2 2 012 and September 172013 Kevin BOLLAERT posted the

14 personal identi fying informat ion of over ten th ousand individuals in conjunction with pri vate

15 images of those individuals without their permi ssion

16 Overt Act 4

17 On July 122013 Kevin BOLLAERT failed to rem ove images of Jane Doe 6 following

18 the receipt of an email from Jane Doe 6 stating that due to private images of her a long with her

19 personal identifying information being posted on ugotpostedcom she was scared for my life

20 Peop le are calling my work p lace and they obta ined the information from thi s site I did not give

21 permission for anyone to put up those pictures or my personal information I have contacted the

22 police but these pictures need to come down Pl ease

23 Overt Act 5

24 On July 17 2013 Kevin BOLLAERT fai led to remove images of Jane Doe 8 fo llowing

25 the receipt of an email from Jane Doe 8 requesting h er private information and images be taken

26 down from ugotposted co m stating she was getting nonstop harassing messages

27

28 2

Comp laint [Felony]

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Overt Act 6




Overt Act 7



Overt Act 8




Count 2





1

Count 3






Count 4





3

Complaint [Felon y]

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Count 5





2

Count 6






Count 7





CountS





3

Count 9




4

Complaint [Felony]



3 CountlO





8 4

9 Countll






15 Count 12





20 5

2 1 Cou nt 13






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5

Complaint Felony]

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1 0

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Count 14





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Count IS






Count 16





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Countl7






Countl8




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Complaint [Felony]

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Count19






Count20





9

Count21






Count 22





Doe 1 0

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Complaint [Fe lony]

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Count 23






Count 24





Doe 11

Count 25






Count 26





Doe 12

Count 27




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Complaint [Felony]

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3 Count28





8 Jane Doe 13

9 Count 29






Count 30





Jane Doe 14

21 Count31






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Complaint [Felony)

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Dated

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Complaint [Felony)

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Overt Act 6




Overt Act 7



Overt Act 8




Count 2





1

Count 3






Count 4





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Complaint [Felon y]

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Count 5





2

Count 6






Count 7





CountS





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Count 9




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Complaint [Felony]



3 CountlO





8 4

9 Countll






15 Count 12





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2 1 Cou nt 13






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5

Complaint Felony]

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1 0

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I 2

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Count 14





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Count IS






Count 16





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Countl7






Countl8




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Complaint [Felony]

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I 0

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Count19






Count20





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Count21






Count 22





Doe 1 0

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Complaint [Fe lony]

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Count 23






Count 24





Doe 11

Count 25






Count 26





Doe 12

Count 27




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Complaint [Felony]

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3 Count28





8 Jane Doe 13

9 Count 29






Count 30





Jane Doe 14

21 Count31






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Complaint [Felony)

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Dated

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Complaint [Felony)

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Count 5





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Count 6






Count 7





CountS





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Count 9




4

Complaint [Felony]



3 CountlO





8 4

9 Countll






15 Count 12





20 5

2 1 Cou nt 13






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28

5

Complaint Felony]

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1 0

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I 2

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Count 14





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Count IS






Count 16





7

Countl7






Countl8




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Complaint [Felony]

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I 0

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Count19






Count20





9

Count21






Count 22





Doe 1 0

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Complaint [Fe lony]

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Count 23






Count 24





Doe 11

Count 25






Count 26





Doe 12

Count 27




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Complaint [Felony]

5

10

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20

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3 Count28





8 Jane Doe 13

9 Count 29






Count 30





Jane Doe 14

21 Count31






27

28

9

Complaint [Felony)

5

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20

25

Dated

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10

Complaint [Felony)



3 CountlO





8 4

9 Countll






15 Count 12





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2 1 Cou nt 13






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Complaint Felony]

2

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1 0

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I 2

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Count 14





6

Count IS






Count 16





7

Countl7






Countl8




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Complaint [Felony]

2

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I 0

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Count19






Count20





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Count21






Count 22





Doe 1 0

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Complaint [Fe lony]

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Count 23






Count 24





Doe 11

Count 25






Count 26





Doe 12

Count 27




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Complaint [Felony]

5

10

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3 Count28





8 Jane Doe 13

9 Count 29






Count 30





Jane Doe 14

21 Count31






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Complaint [Felony)

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Dated

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Complaint [Felony)

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Count 14





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Count IS






Count 16





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Countl7






Countl8




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Complaint [Felony]

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Count19






Count20





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Count21






Count 22





Doe 1 0

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Complaint [Fe lony]

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Count 23






Count 24





Doe 11

Count 25






Count 26





Doe 12

Count 27




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Complaint [Felony]

5

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3 Count28





8 Jane Doe 13

9 Count 29






Count 30





Jane Doe 14

21 Count31






27

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9

Complaint [Felony)

5

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Dated

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10

Complaint [Felony)

2

3

4

5

6

7

8

9

I 0

11

12

13

14

15

16

17

18

19

20

21

22

23

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25

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8

Count19






Count20





9

Count21






Count 22





Doe 1 0

7

Complaint [Fe lony]

5

10

15

20

25

2

3

4

6

7

8

9

11

12

13

14

I6

17

I8

I9

21

22

23

24

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27

28

Count 23






Count 24





Doe 11

Count 25






Count 26





Doe 12

Count 27




8

Complaint [Felony]

5

10

15

20

25



3 Count28





8 Jane Doe 13

9 Count 29






Count 30





Jane Doe 14

21 Count31






27

28

9

Complaint [Felony)

5

10

15

20

25

Dated

2

3

4

6

7

8

9

11

12

13

14

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17

18

19

21

22

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28




10

Complaint [Felony)

5

10

15

20

25

2

3

4

6

7

8

9

11

12

13

14

I6

17

I8

I9

21

22

23

24

26

27

28

Count 23






Count 24





Doe 11

Count 25






Count 26





Doe 12

Count 27




8

Complaint [Felony]

5

10

15

20

25



3 Count28





8 Jane Doe 13

9 Count 29






Count 30





Jane Doe 14

21 Count31






27

28

9

Complaint [Felony)

5

10

15

20

25

Dated

2

3

4

6

7

8

9

11

12

13

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17

18

19

21

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10

Complaint [Felony)

5

10

15

20

25



3 Count28





8 Jane Doe 13

9 Count 29






Count 30





Jane Doe 14

21 Count31






27

28

9

Complaint [Felony)

5

10

15

20

25

Dated

2

3

4

6

7

8

9

11

12

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14

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17

18

19

21

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10

Complaint [Felony)

5

10

15

20

25

Dated

2

3

4

6

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8

9

11

12

13

14

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19

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10

Complaint [Felony)

KAMALA D. HARRIS Attorney General of California · PDF fileCOMPLAINT [FELONY] Plaintiff, v....

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Transcript of KAMALA D. HARRIS Attorney General of California · PDF fileCOMPLAINT [FELONY] Plaintiff, v....