Complaint - State of California

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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

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TAWNYA AUSTIN

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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]

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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),

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The Attorney General of the State of California hereby accuses Kevin BOLLAERT of the following criminal offenses:

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Countl

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

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

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

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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

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foll owing overt acts at and in the County of San Diego, overt act(s):

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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

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

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permission for their private images to be posted online.

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Overt Act 3 Between December 2, 2 012 and September 17,2013 , Kevin BOLLAERT posted the

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

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images of those individuals without their permi ssion.

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Overt Act 4 On July 12,20 13, Kevin BOLLAERT failed to rem ove images of Jane Doe # 6 following

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

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personal identifying information, being posted on ugotposted.com she was " ... scared for my life!

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

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

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police but these pictures need to come down! Pl ease! ".

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Overt Act 5 On July 17, 20 13, Kevin BOLLAERT fai led to remove images of Jane Doe #8 fo llowing

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

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

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Comp lai nt [Felony]

Overt Act 6

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

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

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be removed from ugotposted.com.

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Overt Act. 7

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

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conspirators opened and updated an online account called changemyreputation .com.

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Overt Act 8

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

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excess of $1 O,OOO(ten thousand dollars) via changemyreputation.com from individuals paying to

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have the ir personal identifying information and images removed from ugotposted.com.

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Count 2

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

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vio lation of Penal Code section 530.5(a), a felony, was committed by Kevin BOLLAERT, who

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

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

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# 1.

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Count 3

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

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

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

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

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and money, without the consent of Jane Doe # 1.

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Count 4

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

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

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

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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

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vio lation of Penal Code section 530.5(a), a fel ony, was committed by Kevin BOLLAERT, who

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

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

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# 2.

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Count 6

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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

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

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

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and money, w ithout the consent of Jane Doe #2.

Count 7

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

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

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and or other property from Jane Doe #2 by means of threat such as is mentioned in Penal Code

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

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CountS

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

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violation of Penal Code section 530.5(a), a felony, was committed b y Kevin BOLLAERT, who

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

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

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#3 .

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Count 9 On or about April 29, 2013 , in the County of San Di ego, the crime ofidentity Theft, in

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v iolati on of Penal Code section 530.5(a), a felony , was com mitted by Kevin BOLLAERT, who

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

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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 .

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CountlO

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

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violation of Penal Code section 530.5(a), a felony, was committed by Kevin BOLLAERT, who

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

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

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#4.

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Countll

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

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vio lation of Penal Code section 530.5(a), a fel ony, was committed by Kev in BOLLAERT , who

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

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

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and money, without the consent of Jane Doc #4.

Count 12

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

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violation of Penal Code section 530.5(a), a felony, was committed by Kevin BOLLAERT, who

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did willfully and unlawfully obtain personal identify ing information of Jane Doe #5 and used that

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

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#5.

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Cou nt 13

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

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v iolati on of Penal Code section 530.5(a), a fe lony, was committed by Kevin BOLLAERT, who

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

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

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and money, w ithout the consent of Jane Doe #5 .

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Count 14 2

On or abo ut Ju ly 12,20 13, in the County of San Diego , the crime ofldentity Theft, in

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violation of Penal Code section 530.5(a), a felon y, was committed by Kevin BOLLAERT, who

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

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

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#6.

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

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violation of Penal Code section 530.5(a), a felony , was committed by Kevin BOLLAERT, who

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

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

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and money , wi thout the consent of Jane Doe #6. Count 16

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

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v iolation of Penal Code section 530.5(a), a felon y, was committed by Kevin BOLLAERT, who

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

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

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#7.

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Countl7 On or about Jul y 16, 2013 , in the County of San Diego, the crime of Identity Theft, in

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violation ofPenal Code section 530.5(a), a felony , was committed by Kevin BOLLAERT, who

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

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

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and mone y, without the co nsent of Jane Doe #7.

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Countl8 On or about August 4 , 2013 , in the County of San Diego, the crime of Identity Theft, in

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violation of Penal Code section 530.5(a), a fel ony, was committed by Kevin BOLLAERT, who

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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.

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

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violati on of Penal Code section 530.5(a), a felony, was committed by Kevin BOLLAERT, who

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

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

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and money, without the consent of Jane Doe #8 .

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

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v iolation of Penal Code secti on 530.5(a), a felony , was committed by Kevin BOLLAERT, who

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

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

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

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v iolation of Penal Code section 530.5(a), a fe lony, was committed by Kevin BOLLAERT, who

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

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

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and money, without the consent of Jane Doe #9.

Count 22

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

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vio lation of Penal Code section 530.5(a), a felony , was committed by Kevin BOLLAERT, who

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

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

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Doe # 10.

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Count 23 2

On or about August 13, 2013 , in the County of San Diego, the crime of Identity Theft, in

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vio lation of Penal Code section 530.5(a), a felony, was committed by Kevin BOLLAERT, who

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did willfully and unlawfully obtain personal identifying informati on of Jane Doe # 10 and used

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

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services, and money, without the consent of Jane Doe #1 0.

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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

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

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

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Doe # 11.

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On or about August 26, 20 13, in the County of San Diego, the crime of Identity Theft, in

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v iolation of Penal Code section 530.5(a), a felony , was committed by Kevin BOLLAERT, who

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

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

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services, and money, without the consent of Jane Doe # 1 1.

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Count 26

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

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violation of Penal Code section 530.5(a), a felony, was committed by Kevin BOLLAERT, who

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

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

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Doe #12.

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Count 27

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

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violation of Penal Code section 530.5(a) , a felony , was committed by Kevin BOLLAERT, who

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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

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

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in violation of Penal Code section 530.5(a), a felony, was committed by Kevin BOLLAERT,

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

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

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Jane Doe # 13.

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Count 29 On or about September 10, 2013, in the County of San Diego, the crime of Identity Theft,

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in violation of Penal Code section 530.5(a), a felony, was committed by Kevin BOLLAERT,

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

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

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services, and money, without the consent of Jane Doe # 13.

Count 30

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

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in violation of Penal Code section 530.5(a), a felony, was committed by Kevin BOLLAERT,

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who did willfully and unlawfully obtain personal identifying information of Jane Doe # 14 and

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

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Jane Doe #14.

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Count31 On or about September 12, 2013 , in the County of San Diego, the crime ofidentity Theft,

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in violation of Penal Code section 530.5(a), a felony, was committed by Kevin BOLLAERT,

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who did willfully and unlawfully obtain personal identifying information of Jane Doe# 14 and

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

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services, and money, without the consent of Jane Doe# 14.

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Dated: December 10, 2013

Respectfully Submitted,

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KAMALA D. HARRIS Attorney General of California

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5 TAWNY A AUSTIN

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Deputy Attorney General Attorneys.for the People ofthe State of California

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Complaint [Felony)