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11 12 13 14 16 17 18 19 21 22 23 24 26 27 28 KAMALA D. HARRISAttorney General of California TAWNYA AUSTIN
F.'
D
F
"' I I lj ' 'I 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: Tawnya.Austin@doj.ca.gov
Attorneys.for People ofthe State o.fCal[(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: 6/27/1986),
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 ofSan 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
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 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 " ugotposted.com".
7 Over Act 2
8 Between December 2, 2012 and September 17,2013, Kevin BOLLAERT, with the 9 assistance of known a nd unknown conspirators, posted Ten Thousand One Hundred Seventy I 0 (I0, 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 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.
1
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Overt Act 417 On July 12,2013, 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 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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2 3 4 5 6 7 8 9 I 0 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Overt Act 6
Between June 20, 2013 and August 26, 2013, Kevin
BOLLAERT
received and reviewedover 2000 emails from individuals requesting their personal identifying information and images be removed from ugotposted.com.
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 O,OOO(ten thousand dollars) via changemyreputation.com from individuals paying to
have the ir personal identifying information and images removed from ugotposted.com.
Count 2
On or about April4, 2013 , in the County of San Diego, the crime ofldentity Theft, in
vio lation of Penal Code section 530.5(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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On or about April 18, 20 13, in the County of San Diego, the crime ofldentity Theft, in vio lation of Penal Code section 530.5(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 ofIdentity Theft, in violation of Penal Code section 530.5(a), a felony , was committed by Kevin BOLLAERT, who did willfully and unlawfull y obtain personal identifying information ofJane Doe # 2 and used that 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 and or other property from Jane Doe #2 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 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 530.5(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 530.5(a), a felony , was com mitted by Kevin BOLLAERT, who did willfully and unlawfully obtain personal identifying information of Jane Doe #3 and used that
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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 .
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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 willfull 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 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 #4.15
Count
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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
BOLLA
E
RT,
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 #5.2 1
Cou
nt
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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
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1 0 11 I 2 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Count 14On or abo ut July 12,2013, in the County of San Diego , the crime ofldentity Theft, in violation of Penal Code section 530.5(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
violation of Penal Code section 530.5(a), a felony , was committed by Kevin BOLLAERT, who
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 ofJane 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 530.5(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 ofJane 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 530.5(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 530.5(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
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I 0 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28information for an unlawful purpose to w it, to harass and annoy, without the consent ofJane 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 530.5(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, and money, without the consent of Jane Doe #8 .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 530.5(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 information for an unlawful purpose to wit, to harass and annoy, without the consent of Jane Doe #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 530.5(a), a fe lony, was committed by Kevin BOLLAERT
,
who d id willfully and unlawfully obtain personal identifying informatio n ofJane Doc #9 and used that information for an unl awful purpose, and to obtain, and attempt to obtain credit, goods, services, and money, without the consent of Jane Doe #9.Count 22
On or abo ut August 13, 20 I 3, in the County of San Diego, the crime ofldentity Theft, in vio lation of Penal Code section 530.5(a), a felony , was committed by Kevin BOLLAERT
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who did willfully and unlawfull y obtain personal identifying information ofJane 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
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On or about August 13, 2013 , in the County of San Diego, the crime of Identity Theft, in vio lation of Penal Code section 530.5(a), a felony, was committed by Kevin BOLLAERT, who 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 530.5(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
On or about August 26, 20 13, in the County of San Diego, the crime of Identity Theft, in v iolation of Penal Code section 530.5(a), a felony , was committed by Kevin BOLLAERT, who did willfully and unlawfully obtain personal identifying information of Jane Doe # II 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 1.
Count 26
O n or about September 4 , 2013 , in the County of San Diego, the crime ofldentity Theft, in violation ofPenal Code section 530.5(a), a felony, was committed by Kevin BOLLAERT, who 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 violation of Penal Code section 530.5(a) , a felony , was committed by Kevin BOLLAERT, who did will full y and unlawfully obtain personal identifying information of Jane Doe # 12 and used
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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.
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 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 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
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
Jane Doe #14.
21 Count31
22 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
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
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6
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27 28December 10, 2013 Respectfully Submitted,
KAMALA D. HARRIS
Attorney General of California
TAWNYA AUSTIN
Deputy Attorney General
Attorneys.for the People ofthe State of California
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