Free Redacted Document - District Court of Delaware - Delaware

Case 1 :07-cr-00096-SLR Document 3 Filed 06/26/2007 Page of 4 in
r I I [ _ r I A
il IN THE UNITED STATES DISTRICT COURT I `
FOR THE DISTRICT OF DELAWARE -
J [cg , I
UNITED STATES OF AMERICA, ) ig m
Plaintiftl T ` i
v. ) Criminal Action N0. 07- QL?
LEE FRANCIS BLOTZER, I
_ Defendant. I F I L E D
JUN- 2 E 2007
. INDICTMENT
A The Grand J1u·y for the District of Delaware charges that: Diiiia
Counts 1 - 4 A
From on or about February 24, 2003, through on or about January l9, 2007, in the District of i
Delaware, Lee Francis Blotzer, the defendant, knowingly received and attempted to receive child
pornography, that is, computer generated visual depictions in the form of computer files which are of
minors engaged in sexually explicit conduct, specifically, actual and simulated sexual intercourse and
the lascivious exhibition ofthe genitals and pubic area, which child pomography had been transported
in interstate and foreign commerce by computer, the dates being described more particularly, as follows:
@_vg_; Date Received i _
l January 19, 2007
. 2 March 25, 2003
3- March 7, 2003
4 February 24, 2003

’ _ 7 Cg;$i} QEOO096-SrR ¤0;]i.Q{ }»] 7 eiaiiiériagooi ii ii it FU
i. in violation of Title 18, United States Code, Section 2252A(a)(2) and (b)(l). _
QBJJLS. l t
On or about April 21, 2006, in the District of Delaware, Lee Francis Blotzer, the defendant,
knowingly transported and attempted to transport by computer in interstate and foreign commerce child 7
pornography, that is, a computer generated visual depiction in the form of a computer video file which
is of a minor engaged in sexually explicit conduct, specifically, actual and simulated sexual intercourse r
_ andthe lascivious exhibition ofthe genitals and pubic area, in violation of Title 18, United States Code,
Section 2252A.(a)(l) and (b)(1).
- @L6.
On or about February 28, 2007, in the District of Delaware, Lee Francis Blotzer, the defendant,
knowingly possessed a computer hard drive and other digital storage media that contained images of l
child pornography, that is, visual depictions which are of minors engaged in sexually explicit conduct,
specifically, actual and simulated sexual intercourse and the lascivious exhibition of the genitals and i
pubic area, which child pornography had been transported in interstate and foreign l commerce and
which had been produced using materials which had been transported in interstate commerce, in
violation of Title 18, United States Code, Section 2252A(a)(5)(B) and (b)(2).
Counts 7 — 10
From on or about February 24, 2003, through on or about January 19, 2007, in the District of
Delaware, Lee Francis Blotzer, the defendant, knowingly received and attempted to receive visual -
depictions, that is, computer files, that depict computer images that are or appear to be of minors
engaging in graphic sexual intercourse, and that lack serious literary, artistic, political, or scientific
value, which images had been transported in interstate and foreign commerce by computer, and which
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' I Case 1:07-cr-00096-SLR Document 3 Filed 06/26/2007 Page 3 of 4 .
i_ images had been produced using materials that had been shipped and transported in interstate or foreign
commerce, the dates being described more particularly, as follows:
‘ S Qgg Date Received
I 7 January 19, 2007 p
8 March 25, 2003
9 Mama 7, 2003
10 February 24, 2003
in violation of Title 18, United States Code, Sections 1466A(a)(2)(A) and (B), and 2252A(b)(1).
I Count 1 1
On or about April 21, 2006, in the District of Delaware, Lee Francis Blotzer, the defendant, _
knowingly distributed and attempted to distribute in interstate and foreign commerce visual depictions,
that is, a computer video file, that depict computer images that are or appear to be of a minor engaging
in graphic sexual intercourse, and that lacks serious literary, artistic, political, or scientific value, in
vioiation of Title 18, United States Code, Sections 1466A(a)(2)(A) and (B), and 2252A(b)(1).
Count 12
On or about February 28, 2007, in the District of Delaware, Lee Francis Blotzer, the defendant,
knowingly possessed visual depictions, that is, computer files, that depict computer images that are or
appear to be of minors engaging in graphic sexual intercourse, and that lack serious literary, artistic,
political, or scientitic value, which images had been transported in interstate and foreign commerce by
computer, and which images had been produced using materials that had been shipped and transported
in interstate or foreign commerce, in violation of Title 18, United States Code, Sections 1466A(b)(2)(A)
and (B), and 2252A(b)(2).
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Case 1:07-cr-00096-SLR Document 3 Filed 06/26/2007 Page 4 of 4
/ - I V I ‘ t
. A TRUE BILL:
A t»0t;tE;§‘“‘*"“""—”‘ at /
COLM F. CONNOLLY ‘
United States Attorney {
By: I _ , Q
,5.,4 Edmond F gowsk
Assistant United States Attorney t
Dated: W 25;/A 2[)[)`7 Q
A t
l 4