SUPERIOR COURT OF THE STATE OF CALIFORNIA SAN DIEGO SUPER10R COURT. Case No. Plaintiff, Defendant.

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1 KAMALA D. HARRIS Attorney General of California TAWNYA AUSTIN Deputy Attorney General State Bar No. 1 1 West A Street, Suite 10 San Diego, CA 01 P.O. Box San Diego, CA - Telephone: (1) - Fax: (1) - Attorneys.for People ofthe State o.fcal[(ornia F F.' "' I I lj ' 'I D SUPERIOR COURT OF THE STATE OF CALIFORNIA SAN DIEGO SUPERR COURT THE PEOPLE OF THE STATE OF CALIFORNIA, v. KEVIN CHRISTOPHER BOLLAERT (DOB: //1), Plaintiff, Defendant. Case No. COMPLAINT [FELONY] The Attorney General of the State of California hereby accuses Kevin BOLLAERT ofthe following criminal offenses: Countl In and between December, 1 and September 1, 1, in the County ofsan Diego the crime of Conspiracy, in v iolation of Penal Code section 1, (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 Complaint [Felony)

2 section 0., a fel ony ; that pursuant to and for the purpose of carrying out the objectives and purposes of the aforesaid conspiracy, that Kevin BOLLAERT and others committed the following overt acts at and in the County of San Diego, overt act(s): Overt Act 1 Between December, 1 and September 1, 1, Kevin BOLLAERT was the administrator of a websi te called " ugotposted.com". Over Act Between December, 1 and September 1,1, Kevin BOLLAERT, with the assistance of known a nd unknown conspirators, posted Ten Thousand One Hundred Seventy I 0 (I0, ) private photographs containing nude and ex plicit images of individuals who did not give permission for their private images to be posted online. 1 Overt Act 1 Between December, 1 and September 1,1, Kevin BOLLAERT posted the 1 personal identi fying informat ion of over ten th ousand individuals in conjunction with pri vate 1 images of those individuals without their permi ssion. 1 Overt Act 1 On July 1,1, Kevin BOLLAERT failed to rem ove images ofjane Doe # following 1 the receipt ofan from Jane Doe # stating that due to private images of her, a long with her 1 personal identifying information, being posted on ugotposted.com she was "... scared for my life! Peop le are calling my work p lace and they obta ined the information from thi s site! I did not give permission for anyone to put up those pictures or my personal information. I have contacted the police but these pictures need to come down! Pl ease!". Overt Act On July 1, 1, Kevin BOLLAERT fai led to remove images of Jane Doe # fo llowing the receipt of an from Jane Doe # requesting h er private information and images be taken down from ugotposted. co m stating she was "getting nonstop harassing messages..." Comp lai nt [Felony]

3 Overt Act I Between June, 1 and August, 1, Kevin BOLLAERT received and reviewed over 00 s from individuals requesting their personal identifying information and images be removed from ugotposted.com. Overt Act. In October of1 Kevin BOLLAERT with the assistance of known and unknown conspirators opened and updated an online account called changemyreputation.com. Overt Act Between December, 1 and September 1, 1, 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 On or about April, 1, in the County of San Diego, the crime ofldentity Theft, in vio lation of Penal Code section 0.(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 On or about April, 1, in the County of San Diego, the crime ofidentity Theft, in vio lation of Pe nal Code section 0.(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 On or about April, 1, in the County of San Diego, the crime ofextortion, in violation of Penal Code Section, 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 1, to wit, to expose, or to impute to her any disgrace or expose an y secret affecting her. Complaint [Felon y]

4 Count On or about April 1, 1, in the County of San Diego, the crime ofldentity Theft, in vio lation of Penal Code section 0.(a), a fel ony, was committed by Kevin BOLLAERT, who did willfully and unlawfull y obtain personal identifying information of Jane Doe # and used that information for an unlawful pmpose to wit, to harass and annoy, without the consent of Jane Doe #. Count On or about Apri l 1, 1, in the County of San Diego, the crime ofidentity Theft, in violation ofpenal Code section 0.(a), a felony, was committed by Kevin BOLLAERT, who did willfully and unlawfull y obtain personal identifying information ofjane Doe # 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 #. Count On or about April 1, 1, in the County of San Diego, the crime of Extortion, in violation of Penal Code Section, a fe lony was committed by Kevin BOLLAERT, who extorted money and or other property from Jane Doe # by means ofthreat such as is mentioned in Penal Code Section 1, to wit, to expose, or to impute to her any disgrace or expose any secret affecting her. CountS On or about April, 1, in the County of San Diego, the cr ime of Identity T heft, in violation of Penal Code section 0.(a), a felony, was committed b y Kevin BOLLAERT, who did willfully and unlawfully obtain personal identifying infonnation of Jane Doe # and used that information for an unlawful purpose to wit, to harass and annoy, without the consent of Jane Doe #. Count On or about April, 1, in the County of San Di ego, the crime ofidentity Theft, in v iolati on of Penal Code section 0.(a), a felony, was com mitted by Kevin BOLLAERT, who did willfully and unlawfully obtain personal identifying information of Jane Doe # and used that Complaint [Felony]

5 information for an unlawful purpose, and to obtai n, and attempt to obtain cred it, goods, serv ices, and money, without the consent of Jane Doe #. CountlO On or about May 1, 1, in the County of San Diego, the crime ofldentity Theft, in violation of Penal Code section 0.(a), a felony, was committed by Kevin BOLLAERT, who did wi llfull y and unl awfu lly obtain persona l identifying information of Jane Doe # and used that inform ation for an unlawful purpose to wit, to harass and annoy, without the consent of Jane Doe #. Countll On or about May 1, 1, in the County of San Diego, the crime of Identity Theft, in vio lation of Penal Code section 0.(a), a fel ony, was committed by Kev in BOLLAERT, who 1 did willfully and unlawfully obtain personal identify ing information of Jane Doe # and used that 1 information for an unlawful purpose, and to obtai n, and attempt to obtain credit, goods, services, 1 and money, without the consent of Jane Doc #. 1 Count 1 1 On or about J ul y, 1, in the County ofsan Diego, the crime ofldentity Theft, in 1 violation of Penal Code section 0.(a), a felony, was committed by Kevin BOLLAERT, who 1 did willfully and unlawfully obtain personal identify ing information of Jane Doe # and used that 1 information for an unlawful purpose to wit, to harass and annoy, without the consent of Jane Doe #. Cou nt 1 On or about July, 1, in the County of San Diego, the crime ofldentity Theft, in v iolati on of Penal Code section 0.(a), a fe lony, was committed by Kevin BOLLAERT, who did w illfull y and unlawfully obta in personal identifying information of Jane Doe # and used that information for an unlawful purpose, and to obtain, and attempt to obtain credit, goods, services, and money, w ithout the consent of Jane Doe #. Complaint!Felony]

6 Count 1 I On or abo ut July 1,1, in the County of San Diego, the crime ofldentity Theft, in violation of Penal Code section 0.(a), a felon y, was committed by Kevin BOLLAERT, who did willfull y and unlawfully obtain personal identifying inform atio n of Jane Doe # and used that informati on for an unlawful purpose to wit, to harass and annoy, without the consent of Jane Doe #. Count IS On or about Jul y 1, 1, in the County of San Diego, the crime ofldentity Theft, in violation of Penal Code section 0.(a), a felony, was committed by Kevin BOLLAERT, who did willfully and unlawfully obtain personal identifying informatio n ofjane Doe # 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 #. Count 1 On or about July 1, 1, in the County of San Diego, the crime of Identity Theft, in v iolation of Penal Code section 0.(a), a felon y, was committed by Kevin BOLLAERT, who did willfully and unlawfull y obtain personal identifying info rmation of Jane Doe # and used that information for an unl awful purpose to wit, to harass and annoy, without the consent ofjane Doe #. Countl On or about Jul y 1, 1, in the County of San Diego, the crime of Identity Theft, in violation ofpenal Code section 0.(a), a felony, was committed by Kevin BOLLAERT, who did willfully and unlawfully obtain personal identifyi ng information ofjane Doe # 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 #. Countl On or about August, 1, in the County of San Diego, the crime of Identity Theft, in violation of Penal Code section 0.(a), a fel ony, was committed by Kevin BOLLAERT, who did willfully and unl awfully obtain p ersonal identifying informati on of Jane Doe # and used that Complaint [Felony]

7 information for an unlawful purpose to w it, to harass and annoy, without the consent ofjane Doe #. I Count1 On or about August, 1, in the County of San Diego, the crime of Identity Theft, in violati on of Penal Code section 0.(a), a felony, was committed by Kevin BOLLAERT, who did willful ly and unlawfully obtain personal identifying informati on of Jane Doe # 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 #. Count On or about A ugust, I, in the County of San Diego, the c rime ofldentity Theft, in v iolation of Penal Code secti on 0.(a), a felony, was committed by Kevin BOLLAERT, who did wi llfully and unlawfully obtain personal identify ing information of Jane Doc # and used that information for an unlawful purpose to wit, to harass and annoy, without the consent of Jane Doe #. Count On or about August, I, in the County of San Diego, the crime o f Identity Theft, in v iolation of Penal Code section 0.(a), a fe lony, was committed by Kevin BOLLAERT, who d id willfully and unlawfully obtain personal identifying informatio n ofjane Doc # 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 #. Count On or abo ut August 1, I, in the County of San Diego, the crime ofldentity Theft, in vio lation of Penal Code section 0.(a), a felony, was committed by Kevin BOLLAERT, 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 #. Complaint [Fe lony]

8 Count I 1 I I On or about August 1, 1, in the County of San Diego, the crime of Identity Theft, in vio lation of Penal Code section 0.(a), a felony, was committed by Kevin BOLLAERT, who did willfully and unlawfully obtain personal identifying informati on of Jane Doe # 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 On or about August, 1, in the County of San Diego, the crime ofldentity Theft., in v iolation of Penal Code section 0.(a), a felony, was committed by Kevin BOLLAERT, who did willfully and unlawfully obtain personal identifying information of Jane Doe # and used that information for an unlawfu l purpose to w it, to harass and annoy, without the consent of Jane Doe #. Count On or about August, 1, in the County of San Diego, the crime of Identity Theft, in v iolation of Penal Code section 0.(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 #. Count O n or about September, 1, in the County of San Diego, the crime ofldentity Theft, in violation ofpenal Code section 0.(a), a felony, was committed by Kevin BOLLAERT, who did willfully and unlawfully obtain personal identify ing information ofjane Doe # 1 and used that informati on for an unlawful purpose to wit, to harass and annoy, without the consent of Jane Doe #1. Count On or ab out September, 1, in the County of San Diego, the crime of Identity Theft, in violation of Penal Code section 0.(a), a felony, was committed by Kevin BOLLAERT, who did will full y and unlawfully obtain personal identifying information ofjane Doe # 1 and used Complaint [Felony]

9 that information for an unlawful purpose, and to obtain, and attempt to obtain credit, goods, services, and money, without the consent ofjane Doe #1. Count On or about September, 1, in the County of San Diego, the crime of Identity Theft, in violation of Penal Code section 0.(a), a felony, was committed by Kevin BOLLAERT, who did willfully and unlawfully obtain personal identifying information of Jane Doe #1 and used that information for an unlawful purpose to wit, to harass and annoy, without the consent of Jane Doe # 1. Count On or about September, 1, in the County of San Diego, the crime of Identity Theft, in violation of Penal Code section 0.(a), a felony, was committed by Kevin BOLLAERT, 1 who did willfully and unlawfully obtain personal identifying information of Jane Doe #1 and 1 used that information for an unlawful purpose, and to obtain, and attempt to obtain credit, goods, 1 services, and money, without the consent of Jane Doe # 1. 1 Count 0 1 On or about September 1, 1, in the County or San Diego, the crime of Identity Theft, 1 in violation of Penal Code section 0.(a), a felony, was committed by Kevin BOLLAERT, 1 who did willfully and unlawfully obtain personal identifying information of Jane Doe # 1 and 1 used that information for an unlawful purpose to wit, to harass and annoy, without the consent of Jane Doe #1. Count1 On or about September 1, 1, in the County ofsan Diego, the crime ofidentity Theft, in violation of Penal Code section 0.(a), a felony, was committed by Kevin BOLLAERT, who did willfully 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 ofjane Doe#1. Complaint [Felony)

10 Dated: December, 1 Respectfully Submitted, KAMALA D. HARRIS Attorney General of California TAWNYA AUSTIN Deputy Attorney General Attorneys.for the People ofthe State of California Complaint [Felony)

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