Cary Anderson Indictment - WUSA9.com

LM F: USAO 2012R00336IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF MARYLANDUNITED STATES OF AMERICA ** CRIMINAL NO.v. ** (Sexual Exploitation of a Minor for theCARY ANDERSON, **Purpose of Producing ChildPornography, 18 U.S.C. § 2251(a);Defendant **********Forfeiture, 18 U.S.C. § 2253, 28 U.S.C.§ 2461(c))INDICTMENTCOUNT ONEThe Grand Jury for the District of Maryland charges that:On or about February 17, 2012, in the District of Maryland, the defendant,CARY ANDERSON,did knowingly employ, use, persuade, induce, entice, and coerce a minor to engage in sexuallyexplicit conduct as defined in Title 18, United States Code, Section 2256(2), for the purpose ofproducing a visual depiction of such conduct, and the visual depiction had been produced andtransmitted using materials that had been mailed, shipped, and transported in and affecting interstateand foreign commerce by any means, including by computer, that is, the defendant produced visualdepictions of a minor, specifically a 13 year old female, A.M., engaged in sexually explicit conduct,including, but not limited to, files titled 0217122137a.jpg, 0217122139.jpg, 0217122140.jpg and0217122141.jpg, that depict the defendant performing oral sex on A.M., a picture of A.M.’sgenitals, and the defendant’s hand in A.M.’s anus.18 U.S.C. § 2251(a)

COUNT TWOThe Grand Jury for the District of Maryland further charges that:On or about February 18, 2012, in the District of Maryland, the defendant,CARY ANDERSON,did knowingly employ, use, persuade, induce, entice, and coerce a minor to engage in sexuallyexplicit conduct as defined in Title 18, United States Code, Section 2256(2), for the purpose ofproducing a visual depiction of such conduct, and the visual depiction had been produced andtransmitted using materials that had been mailed, shipped, and transported in and affecting interstateand foreign commerce by any means, including by computer, that is, the defendant produced visualdepictions of a minor, specifically a 13 year old female, A.M., engaged in sexually explicit conduct,including, but not limited to, files titled 0218121750.jpg, 0218121820a.jpg, 0218121957b.jpg and0218122000.jpg, that depict A.M. performing oral sex on the defendant, a picture of A.M.’s genitals,and the defendant’s and A.M. inserting objects into her genitals.18 U.S.C. § 2251(a)

COUNT THREEThe Grand Jury for the District of Maryland further charges that:On or about February 19, 2012, in the District of Maryland, the defendant,CARY ANDERSON,did knowingly employ, use, persuade, induce, entice, and coerce a minor to engage in sexuallyexplicit conduct as defined in Title 18, United States Code, Section 2256(2), for the purpose ofproducing a visual depiction of such conduct, and the visual depiction had been produced andtransmitted using materials that had been mailed, shipped, and transported in and affecting interstateand foreign commerce by any means, including by computer, that is, the defendant produced visualdepictions of a minor, specifically a 13 year old female, A.M., engaged in sexually explicit conduct,including, but not limited to, files titled 0219121142.jpg, and 0219121143.jpg, that depict A.M.’sgenitals and the defendant inserting his fingers into A.M.’s genitals.18 U.S.C. § 2251(a)

COUNT FOURThe Grand Jury for the District of Maryland further charges that:On or about February 20, 2012, in the District of Maryland, the defendant,CARY ANDERSON,did knowingly employ, use, persuade, induce, entice, and coerce a minor to engage in sexuallyexplicit conduct as defined in Title 18, United States Code, Section 2256(2), for the purpose ofproducing a visual depiction of such conduct, and the visual depiction had been produced andtransmitted using materials that had been mailed, shipped, and transported in and affecting interstateand foreign commerce by any means, including by computer, that is, the defendant produced visualdepictions of a minor, specifically a 13 year old female, A.M., engaged in sexually explicit conduct,including, but not limited to, files titled 0220120735.jpg, 0220120736.jpg, 0220121112.jpg and0220121133.jpg, that depict the defendant inserting his fist into A.M.’s anus, the defendant digitallypenetrating A.M.’s anus, the defendant engaging in sexual intercourse with A.M, and the defendantperforming oral sex on A.M.18 U.S.C. § 2251(a)

COUNT FIVEThe Grand Jury for the District of Maryland further charges that:On or about February 24, 2012, in the District of Maryland, the defendant,CARY ANDERSON,did knowingly employ, use, persuade, induce, entice, and coerce a minor to engage in sexuallyexplicit conduct as defined in Title 18, United States Code, Section 2256(2), for the purpose ofproducing a visual depiction of such conduct, and the visual depiction had been produced andtransmitted using materials that had been mailed, shipped, and transported in and affecting interstateand foreign commerce by any means, including by computer, that is, the defendant produced visualdepictions of a minor, specifically a 15 year old female, E.W., engaged in sexually explicit conduct,including, but not limited to, files titled 0224121241.jpg, 0224121242.jpg, and 0224121417.jpg, thatdepict E.W.’s genitals.18 U.S.C. § 2251(a)

COUNT SIXThe Grand Jury for the District of Maryland further charges that:On or about February 24, 2012, in the District of Maryland, the defendant,CARY ANDERSON,did knowingly employ, use, persuade, induce, entice, and coerce a minor to engage in sexuallyexplicit conduct as defined in Title 18, United States Code, Section 2256(2), for the purpose ofproducing a visual depiction of such conduct, and the visual depiction had been produced andtransmitted using materials that had been mailed, shipped, and transported in and affecting interstateand foreign commerce by any means, including by computer, that is, the defendant produced visualdepictions of minors, specifically a 15 year old female, E.W., and a 13 year old female, A.M.,engaged in sexually explicit conduct, including, but not limited to, files titled 0224121949.jpg and0224121959a.jpg, that depict E.W. performing oral sex on A.M. and A.M. inserting an object intoE.W.’s vagina.18 U.S.C. § 2251(a)

FORFEITURE ALLEGATIONThe Grand Jury for the District of Maryland further charges that:1. Pursuant to Title 18, United States Code, Section 2253, upon convictions of theoffenses set forth in Counts One through Six of this Indictment, in violation of Title 18, UnitedStates Code, Section 2251(a), the defendant,CARY ANDERSON,,shall forfeit to the United States of America:a. Any visual depiction described in Title 18, United States Code, sections 2251,2251A, or 2252, or any book, magazine, periodical, film, videotape, or other matter which containsany such visual depiction, which was produced, transported, mailed, shipped or received in violationof Title 18, United States Code, Chapter 110;b. Any property, real or personal, constituting or traceable to gross profits orother proceeds obtained from the offenses; andc. Any property, real or personal, used or intended to be used to commit or topromote the commission of the offenses.The property to be forfeited includes, but is not limited to, the following: a Motorola Razorcamera phone, s/n: 626GJY34GXF, and a 2GB SanDisk microSD card.2. If any of the property described above, as a result of any act or omissionof the defendant:a. cannot be located upon the exercise of due diligence;b. has been transferred or sold to, or deposited with, a third party;c. has been placed beyond the jurisdiction of the court;d. has been substantially diminished in value; or

e. has been commingled with other property which cannot be divided withoutdifficulty, the United States of America shall be entitled to forfeiture of substitute property pursuantto Title 21, United States Code, Section 853(p), as incorporated by Title 18, United States Code,Section 2253(b) and Title 28, United States Code, Section 2461(c).18 U.S.C. § 225328 U.S.C. § 2461(c)A TRUE BILL:Rod J. RosensteinUnited States AttorneyForeperson____________________________Date