Free Redacted Document - District Court of Delaware - Delaware

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El3lll\@TEl@ R s
Ei _ , .2 EDAGTED
IN THE UNITED STATES DISTRICT COU
FOR THE DISTRICT OF DELAWA 5 H
UNITED STATES OF AMERICA, )
Plaintiff, g /7;
v. ) Criminal Action No. 08- K
MATTHEW PALMER, i
Defendant. i
INDICTMENT
The Grand Jury for the District of Delaware charges that:
COUNTS ONE TO FIVE
From on or about September 5, 2007, through on or about September S, 2007, in the District of
Delaware, Matthew Palmer, defendant herein, 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 pornography had been transported
in interstate and foreign commerce by computer, the dates being described more particularly, as follows:
@1;:; Date Received
l September 5, 2007
2 September 5, 2007
3 September 5, 2007
4 September 8, 2007
5 September 8, 2007

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in violation of Title l8, United States Code, Section 2252A(a)(2) and (b)(l).
COUNT SIX
On or about August 2, 2007, in the District of Delaware, Matthew Palmer, defendant herein,
knowingly attempted to distribute by computer in interstate and foreign commerce 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 pubic area, in
violation of Title 18, United States Code, Section 2252A(a)(2) and (b)(l).
COUNT SEVEN
On or about October 18, 2007, in the District of Delaware, Matthew Palmer, defendant herein,
knowingly possessed a computer hard drive and other digital storage media that contained images of
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
pubic area, which child pornography had been transported in interstate and foreign commerce and which
had been produced using materials which had been transported in interstate and foreign commerce, in
violation of Title 18, United States Code, Section 2252A(a)(5)(B) and (b)(2).
COUNTS EIGHT TO TWELVE
From on or about September 5, 2007, through on or about September 8, 2007, in the District of
Delaware, Matthew Palmer, defendant herein, knowingly received and attempted to receive visual
depictions, that is, computer files that depict computer images that are or appear to be of a minor
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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, the dates
being described more particularly as follows:
Count Date Received
8 September 5, 2007
9 September 5, 2007
10 September 5, 2007
ll September 8, 2007
12 September 8, 2007
in violation of Title 18, United States Code, Sections 1-466A(a)(2)(A) and (B), and 2252A(b)(1).
COUNT THIRTEEN
On or about August 2, 2007, in the District of Delaware, Matthew Palmer, defendant herein,
knowingly attempted to distribute by computer in interstate and foreign commerce 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, in
violation of Title 18, United States Code, Sections l466A(a)(2)(A) and (B), and 2252A(b)(l).
COUNT FOURTEEN
On or about October 18, 2007, in the District of Delaware, Matthew Palmer, defendant herein,
knowingly possessed visual depictions, that is, computer files, that depict computer images that are or
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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 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 l466A(b)(2)(A)
and (B), and 2252A(b)(2).
A TRUE BILL:
COLM F. CONNOLLY
United States Attorney
Christopher J. Burke
Assistant United States Attorney
Dated: March 13, 2008
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