Dec 10, 2013 - 18 the receipt ofan email from Jane Doe #6 stating that due to private images of her, a long with her. 19
KAMALA
D. HARRIS
Attorney General of California 2
3 4 5
6 7
TAWNYA AUSTIN
F
Deputy Attorney General State Bar No. 198663 110 West A Street, Suite 1100
San Diego, CA 921 01
P.O. Box 85266
San Diego, CA 92186-5266
Telephone: (619) 645-2823
Fax: (619) 645-2489
E-mail:
[email protected]
D
F.'
"'I
I
lj ' 'I
Attorneys.for People ofthe State o.fCal[(ornia
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 SAN DIEGO SUPER10R COURT 10 11 12 13
THE PEOPLE OF THE STATE OF CALIFORNIA,
Case No.
COMPLAINT [FELONY]
14 Plaintiff, 15
v. 16 17
KEVIN CHRISTOPHER BOLLAERT (DOB: 6/27/1986),
18 Defendant. 19 20 21 22 23
The Attorney General of the State of California hereby accuses Kevin BOLLAERT of the following criminal offenses:
24
Countl
25
In and between December 2, 2013 and September 17, 2013, in the County of San Diego the
26
crime of Conspiracy, in v iolation of Penal Code section 182, (a)(!) a felony , was committed by
27
Kevin BOLLAERT who did unlawfully conspire together with another person and persons
28
whose identity is unknown to commit the crime of Identity Theft, in violation of Penal Code
Complaint [Felony)
section 530.5, 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
foll owing overt acts at and in the County of San Diego, overt act(s):
4 5 6 7
8 9
Overt Act 1 Between December 2, 20 12 and September 17, 2013 , Kevin BOLLAERT was the adm inistrator of a websi te called " ugotposted.com".
Over Act 2 Between December 2, 20 12 and September 17,2013, Kevin BOLLAERT, with the assistance of known a nd unknown conspirators, posted Ten Thousand One Hundred Seventy
I0
(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 13
Overt Act 3 Between December 2, 2 012 and September 17,2013 , 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 17
Overt Act 4 On July 12,20 13, 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 ugotposted.com 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 24
Overt Act 5 On July 17, 20 13, 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 lai nt [Felony]
Overt Act 6
2
Between June 20, 2013 and August 26, 2013, Kevin BOLLAERT received and reviewed
3
over 2000 emails from individuals requesting their personal identifying information and images
4
be removed from ugotposted.com.
5
Overt Act. 7
In October of2012 Kevin BOLLAERT with the assistance of known and unknown
6
7
conspirators opened and updated an online account called changemyreputation .com.
8
Overt Act 8
Between December 2, 2012 and September 17, 2013, Kevin BOLLAERT collected in
9
I0
excess of $1 O,OOO(ten thousand dollars) via changemyreputation.com from individuals paying to
11
have the ir personal identifying information and images removed from ugotposted.com.
12
Count 2
13
On or about April4, 2013 , in the County of San Diego, the crime ofldentity Theft, in
14
vio lation of Penal Code section 530.5(a), a felony, was committed by Kevin BOLLAERT, who
15
did willfully and unlawfully obtain personal identifying information of Jane Doe #1 and used that
16
informatio n for an unlawful purpose to wit, to harass and annoy, without the consent of Jane Doe
17
# 1.
18
19
Count 3
On or about April4, 2013 , in the County of San Diego, the crime ofidentity Theft, in
20
vio lation of Pe nal Code section 530 .5(a), a felony , was committed by Kevin BOLLAERT, who
21
did willfu lly and unlawfully obtain personal identifying information of Jane Doe #1 and used that
22
information for an unlawful purpose, and to obtain, and attempt to obtain credit, goods, services,
23
and money, without the consent of Jane Doe # 1.
24
25
Count 4
On or about April4, 2013, in the County of San Diego, the crime ofExtortion, in violation
26
of Penal Code Section 520, a felony was committed by Kevin BOLLAERT, who extm1ed money
27
and or other property from Jane Doe# 1 by means of threat such as is mentioned in Penal Code
28
Section 519, to wit, to expose, or to impute to her any disgrace or expose an y secret affecting her. 3
Complaint [Felon y]
Count 5 2
On or about April 18, 20 13, in the County of San Diego, the crime ofldentity Theft, in
3
vio lation of Penal Code section 530.5(a), a fel ony, was committed by Kevin BOLLAERT, who
4
did willfully and unlawfull y obtain personal identifying information of Jane Doe #2 and used that
5
information for an unlawful pmpose to wit, to harass and annoy, without the consent of Jane Doe
6
# 2.
7
Count 6
8 9
On or about Apri l 18, 2013, in the County of San Diego, the crime of Identity Theft, in violation of Penal Code section 530.5(a), a felony , was committed by Kevin BOLLAERT, who
10
did willfully and unlawfull y obtain personal identifying information of Jane Doe # 2 and used that
11
information for an unlawful purpose, and to obtain, and attempt to o btain credit, goods, services,
12
and money, w ithout the consent of Jane Doe #2.
Count 7
13
14
On or about April 18, 2013 , in the County of San Diego, the crime of Extortion, in violation of
15
Penal Code Section 520, a fe lony was committed by Kevin BOLLAERT, who extorted money
16
and or other property from Jane Doe #2 by means of threat such as is mentioned in Penal Code
17
Section 519, to wit, to expose, or to impute to her any disgrace or expose any secret affecting her.
18
CountS
19
On or about April 29, 2013 , in the County of San Diego, the cr ime of Identity T heft, in
20
violation of Penal Code section 530.5(a), a felony, was committed b y Kevin BOLLAERT, who
21
did willfully and unlawfully obtain personal identifying infonnation of Jane Doe #3 and used that
22
information for an unlawful purpose to wit, to harass and annoy , without the consent of Jane Doe
23
#3 .
24 25
Count 9 On or about April 29, 2013 , in the County of San Di ego, the crime ofidentity Theft, in
26
v iolati on of Penal Code section 530.5(a), a felony , was com mitted by Kevin BOLLAERT, who
27
did willfully and unlawfully obtain personal identifying information of Jane Doe #3 and used that
28 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 530.5(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
10
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 530.5(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.
Count 12
15 16
On or about J ul y 6, 20 13 , in the County of San Diego, the crime ofldentity Theft, in
17
violation of Penal Code section 530.5(a), a felony, was committed by Kevin BOLLAERT, who
18
did willfully and unlawfully obtain personal identify ing information of Jane Doe #5 and used that
19
information for an unlawful purpose to wit, to harass and annoy, without the consent of Jane Doe
20
#5.
21
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 530.5(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 .
27
28 5 Complaint !Felony]
Count 14 2
On or abo ut Ju ly 12,20 13, in the County of San Diego , the crime ofldentity Theft, in
3
violation of Penal Code section 530.5(a), a felon y, was committed by Kevin BOLLAERT, who
4
did willfull y and unlawfully obtain personal identifying inform atio n of Jane Doe #6 and used that
5
informati on for an unlawful purpose to wit, to harass and annoy, without the consent of Jane Doe
6
#6.
7
Count IS On or about Jul y 12 , 2013 , in the County of San Diego, the crime ofldentity Theft, in
8
9
violation of Penal Code section 530.5(a), a felony , was committed by Kevin BOLLAERT, who
10
did willfully and unlawfully obtain personal identifying informatio n of Jane Doe #6 and used that
11
information for an unl awful purpo se, and to obtain, and attempt to obtain credit, goods, services,
I2
and money , wi thout the consent of Jane Doe #6. Count 16
13
On or about July 16, 2013, in the County of San Diego, the crime of Identity Theft, in
14 15
v iolation of Penal Code section 530.5(a), a felon y, was committed by Kevin BOLLAERT, who
16
did willfully and unlawfull y obtain personal identifying info rmation of Jane Doe # 7 and used that
17
information for an unl awful purpose to wit, to harass and annoy, without the consent of Jane Doe
18
#7.
19 20
Countl7 On or about Jul y 16, 2013 , in the County of San Diego, the crime of Identity Theft, in
21
violation ofPenal Code section 530.5(a), a felony , was committed by Kevin BOLLAERT, who
22
did willfully and unlawfully obtain personal identifyi ng information of Jane Doe # 7 and used that
23
information for an unl awful purpose, and to obtain , and attempt to obtain cred it, goods , services,
24
and mone y, without the co nsent of Jane Doe #7.
25 26
Countl8 On or about August 4 , 2013 , in the County of San Diego, the crime of Identity Theft, in
27
violation of Penal Code section 530.5(a), a fel ony, was committed by Kevin BOLLAERT, who
28
did willfully and unl awfully obtain p ersonal identifying informati on of Jane Doe #8 and used that 6
Complaint [Felony]
information for an unlawful purpose to w it, to harass and annoy, without the consent of Jane Doe 2
#8.
Count19
3 4
On or about August 4, 20 13, in the County of San Diego, the crime of Identity Theft, in
5
violati on of Penal Code section 530.5(a), a felony, was committed by Kevin BOLLAERT, who
6
did willful ly and unlawfully obtain personal identifying informati on of Jane Doe #8 and used that
7
information for an unl awful purpose, a nd to obtain, and attempt to obtai n credit, goods, services,
8
and money, without the consent of Jane Doe #8 .
9
Count20
I0
On or about A ugust 6, 20 I 3, in the County of San Diego, the c rime ofldentity Theft, in
11
v iolation of Penal Code secti on 530.5(a), a felony , was committed by Kevin BOLLAERT, who
12
did wi llfully and unlawfully obtain personal identify ing information of Jane Doc #9 and used that
13
information for an unlawful purpose to wit, to harass and annoy, without the consent of Jane Doe
14
#9 .
Count21
15 16
On or about August 6, 20 I 3, in the County of San Diego, the crime o f Identity Theft, in
17
v iolation of Penal Code section 530.5(a), a fe lony, was committed by Kevin BOLLAERT, who
18
d id willfully and unlawfully obtain personal identifying informatio n of Jane Doc #9 and used that
19
information for an unl awful purpose, and to obtain, and attempt to obtain credit, goods, services,
20
and money, without the consent of Jane Doe #9.
Count 22
21 22
On or abo ut August 13, 20 I 3, in the County of San Diego, the crime ofldentity Theft, in
23
vio lation of Penal Code section 530.5(a), a felony , was committed by Kevin BOLLAERT, who
24
did willfully and unlawfull y obtain personal identifying information of Jane Doe# I 0 and used
25
that information for an unlawful purpose to w it, to harass and annoy, without the consent of Jane
26
Doe # 10.
27 28 7 Complaint [Fe lony]
Count 23 2
On or about August 13, 2013 , in the County of San Diego, the crime of Identity Theft, in
3
vio lation of Penal Code section 530.5(a), a felony, was committed by Kevin BOLLAERT, who
4
did willfully and unlawfully obtain personal identifying informati on of Jane Doe # 10 and used
5
that information for an unlawful purpose, and to obtain, and attempt to obtain credit, goods,
6
services, and money, without the consent of Jane Doe #1 0.
7 8 9
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 530.5(a), a felony , was committed by Kevin BOLLAERT, who
10
did willfully and unlawfully obtain personal identifying information of Jane Doe # 11 and used
11
that information for an unlawfu l purpose to w it, to harass and annoy, without the consent of Jane
12
Doe # 11.
Count 25
13 14
On or about August 26, 20 13, in the County of San Diego, the crime of Identity Theft, in
15
v iolation of Penal Code section 530.5(a), a felony , was committed by Kevin BOLLAERT, who
I6
did willfully and unlawfully obtain personal identifying information of Jane Doe # II and used
17
that information for an unlawful purpose , and to obtain, and attempt to obtain credit, goods,
I8
services, and money, without the consent of Jane Doe # 1 1.
I9
Count 26
20
O n or about September 4 , 2013 , in the County of San Diego, the crime ofldentity Theft, in
21
violation of Penal Code section 530.5(a), a felony, was committed by Kevin BOLLAERT, who
22
did willfully and unlawfully obtain personal identify ing information of Jane Doe # 12 and used
23
that informati on for an unlawful purpose to wit, to harass and annoy, without the consent of Jane
24
Doe #12.
25
Count 27
26
On or ab out September 4 , 20 13 , in the County of San Diego, the crime of Identity Theft, in
27
violation of Penal Code section 530.5(a) , a felony , was committed by Kevin BOLLAERT, who
28
did will full y and unlawfully obtain personal identifying information of Jane Doe # 12 and used 8
Complaint [Felony]
that information for an unlawful purpose, and to obtain, and attempt to obtain credit, goods, 2
services, and money, without the consent of Jane Doe #12.
Count28
3 4
On or about September 10, 2013 , in the County of San Diego , the crime of Identity Theft,
5
in violation of Penal Code section 530.5(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 10
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 530.5(a), a felony, was committed by Kevin BOLLAERT,
12
who did willfully and unlawfully obtain personal identifying information of Jane Doe #13 and
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
15 16
On or about September 12, 2013 , in the County or San Diego, the crime of Identity Theft,
17
in violation of Penal Code section 530.5(a), a felony, was committed by Kevin BOLLAERT,
18
who did willfully and unlawfully obtain personal identifying information of Jane Doe # 14 and
19
used that information for an unlawful purpose to wit, to harass and annoy, without the consent of
20
Jane Doe #14.
21 22
Count31 On or about September 12, 2013 , in the County of San Diego, the crime ofidentity Theft,
23
in violation of Penal Code section 530.5(a), a felony, was committed by Kevin BOLLAERT,
24
who did willfully and unlawfully obtain personal identifying information of Jane Doe# 14 and
25
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 Doe# 14.
27 28 9 Complaint [Felony)
Dated: December 10, 2013
Respectfully Submitted,
2
KAMALA D. HARRIS Attorney General of California
3
4
5 TAWNY A AUSTIN
6
Deputy Attorney General Attorneys.for the People ofthe State of California
7
8
9
10 11
12
13
14
15 16
17
18
19
20 21
22
23
24
25
26
27
28
10
Complaint [Felony)