kevin bollaert felony complaint

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  • 8/9/2019 Kevin Bollaert Felony Complaint

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    KAMALA

    D HARRIS

    Attorney

    General of California

    TAWNYA

    USTIN

    F. D

     

    '

    I l

    I

    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]  

    Attorneys.for People the State o.fCal[ ornia

    SUPERIOR COURT OF THE

    STATE OF

    CALIFORNIA

    SAN DIEGO SUPER10R COURT

    THE PEOPLE OF THE STATE OF Case No.

    CALIFORNIA

    COMPLAINT [FELONY]

    Plaintiff

    ,

    v.

    KEVIN CHRISTOPHER BOLLAERT

    DOB: 6/27/1986),

    Defendant.

    The Attorney

    General

    of

    the State

    of

    California hereby accuses

    Kevin BOLLAERT

    of the

    following criminal offenses:

    Countl

    In and

    between

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

    crime of Conspiracy, in violation of Penal Code section 182, (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 [Felon

    y)

    mailto:[email protected]:[email protected]

  • 8/9/2019 Kevin Bollaert Felony Complaint

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    section 530.5, a felony; that pursuant to and for the purpose

    of

    carr

    ying out

    the objectives and

    2 purposes

    of

    the aforesaid conspiracy, that Kevin

    BOLLAERT

    and others committed the

    3 foll

    ow

    ing overt acts at and in the County

    of

    San Diego, overt act(s):

    4 Overt Act 1

    5 Between December 2, 20 12 and September

    17

    , 2013, Kev

    in BOLLAERT

    was the

    6 adm in istrator

    of

    a website called " ugotposted.com".

    Over Act 2

    8 Between Dece

    mb

    er 2,

    20

    12 and Sept

    ember

    17

    ,2013,

    Kevin BOLLAERT with the

    9 assistance

    of

    known and unknown conspirators, posted Ten Thousand One Hundred Seventy

    I0 0, 170) private photographs containing nude and explicit images of individuals who did not give

    permission for their private images to be posted online.

    12 Overt ct 3

    13 Between December 2, 2012 and September 17 ,2013, Kevin BOLLAERT posted the

    14 personal identify ing information of over ten thousand individuals in conjunction with private

    15 ima

    ges

    of

    those individuals without their permission.

    16

    Overt Act 4

    17

    On July 1

    2,20

    13

    , Kevin

    BOLLAERT

    fa

    il

    ed to remove i

    mages

    of

    Jane Doe #6 following

    18 the receipt

    of

    an email from Jane Doe #6 stating that due to private images

    of

    her, along with her

    19 personal identifying information, being posted on ugotposted.com

    she

    was " ... scared for my life

    20 People are calling my work place and they obtained the information from this site I did not give

    21 permission for anyone to put up those pictures or my personal inform ati

    on

    . I have contacted the

    22 police but these pic

    tu

    res need to come down Pleas

    e

    ".

    23

    Overt Act 5

    24 On

    Ju

    ly 17,

    20

    13, Kevin BOLLAERT failed to remove images

    of

    Jane Doe #8 following

    25

    the receipt

    of

    an email from Jane Doe #8 requesting her private informati

    on

    and images be taken

    26 down from ugotposted.com stating she was

    g

    etting nonstop harassing messages. .."

    27

    28

    2

    Complai

    nt

    [Fe lony]

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    Count 5

    On or about

    April

    8 , 20 13, in the County of

    San

    Diego, the

    crime

    ofldentity Theft, in

    violation of Penal

    Code

    section 530.5(a), a felony,

    was

    committed

    by Kevin

    BOLLAERT

    who

    did willfully and unla

    wf

    ully obtain personal identifying

    inf

    ormation

    of

    Jane Doe 2 and used that

    information for an unlawful pmpose to wit, to harass and annoy, wi

    th

    out the consent of Jane Doe

    2

    Count 6

    On or

    about

    April

    8

    ,

    2013,

    in

    the

    County of

    San

    Diego, the

    crime of

    Identity Theft, in

    violation of Penal

    Code

    section 530.5(a), a felony ,

    was commi

    tted by

    Kevin

    BOLLAERT  who

    did willfully

    and

    unlawfully obtain personal identifying informati

    on

    of

    Jane

    Doe 2 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 2.

    Count 7

    On or

    about April 18, 2013, in

    the Co

    unty of San Diego, the crime of

    Exto

    rtion, in vio lation of

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

    and

    or other

    property from

    Jane

    Doe 2 by means of threat such as is mentioned in Penal Code

    Section 519,

    to

    wit,

    to

    expose,

    or

    to impute to her any disgrace

    or expose

    any s

    ecr

    et affecting her.

    ountS

    On or

    about

    April

    29

    ,

    2013

    , in the County of

    San

    Diego,

    the

    cr

    im

    e of Identity Theft, in

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

    BOLLAERT

    who

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

    information for an unlawful purpose to wit, to harass

    and

    annoy wit hout the consent of Jane Doe

    3.

    Count 9

    On

    or

    about April 29, 2013, in the County of San Diego, the crime

    ofidentity

    Theft, in

    violation of Penal Code section 530.5(a), a felony, was committed

    by

    Kevin

    BOLLAERT 

    who

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

    Compla

    int

    [

    Fel

    ony]

  • 8/9/2019 Kevin Bollaert Felony Complaint

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

    2 and

    mon

    ey, without the consent

    of

    Jane Doe #3.

    3

    CountlO

    4

    On

    or about May 13, 2013, in the County

    of

    San Diego, the

    cr

    im

    e

    oflde

    ntity

    Th

    eft, in

    5 violation

    of

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

    6 did wi llfully and unl awfu ly obtain personal identifying information

    of

    Jane Doe #4 and used that

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

    #4.

    9 ountll

    10

    On

    or about May 13, 20 3 , in the County

    of

    San Diego, the c

    ri

    me

    of

    Identity Theft, in

    violation

    of

    Penal Code section 530.5(a), a felony, was committed

    by

    Kevin

    BOLLAERT

    who

    2 d id willfully and unlawfully obtain personal identifying in formation of Jane Doe #4 and used that

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

    14 and

    money

    , without the consent

    of

    Jane Doc #4.

    15 Count

    12

    16 On or about July 6, 2013, in the County of San Diego, the crime ofldentity Theft, in

    17 violation of Penal Code section 530.5(a), a felony, was committed

    by

    Kevin

    BOLLAE

    RT

     

    who

    18 did willfully and unlawfully obtain personal identifying information

    of

    Jane Doe #5 and used that

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

    20 #5.

    21 Cou

    nt

    13

    22

    On

    or about July 6, 20 13, in the County

    of

    San Diego, the crime ofldentity Theft, in

    23 violati

    on of

    Penal

    Co

    de section 530.5(a), a felony, was committed by Kevin BOLLAERT who

    24 did willfully and unlawfully

    ob

    tain personal identifying information

    of

    Jane Doe #5 and used that

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

    6

    and

    money

    , without the consent of Jane Doe #5 .

    27

    28

    5

    Complaint Felony]

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    Count 14

    On or about

    Ju

    ly 12

     2 0

    13 , in the County

    of

    San Di ego the crime

    ofldentity

    Theft, in

    violation of Penal

    Code

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

    did willfully and

    unla

    wfu

    ll

    y obtain personal identif

    yi

    ng

    in f

    ormation

    of

    Jane Doe 6 and used that

    in f

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

    Doe

    6.

    Count IS

    On or about July 12, 2013 , in the County

    of

    San Diego, the crime

    ofldentity

    Theft, in

    violation of Penal

    Code

    section 530.5(a), a felony was

    comm

    itted by Kevin BOLLAERT who

    did willfully and unlawfully obtain personal identifying

    in f

    ormation

    of

    Jane Doe 6 and used

    tha

    t

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

    and money, without the consent

    of

    Jane Doe 6.

    Count 6

    On or about July 16, 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

    did willfully and unlawfully obtain personal identifying information of Jane Doe 7 and used that

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

    of

    Jane

    Doe

    7.

    Countl

    On or about July 16, 2013 , in the County

    of

    San Diego, the crime

    of

    Identity Theft, in

    violation

    ofPenal Code

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

    did willfully and unlawfully obtain personal identifying information

    of

    Jane Doe 7 and used that

    information for an unlawf

    ul

    purpose, and to obtain, and att

    emp

    t to obtain credit goods, services,

    and money without the consent of Jane Doe 7.

    Countl8

    On or about August 4 , 2013, in the County

    of

    San

    Di

    ego, the crime of Identity Theft, in

    violation of Penal

    Code

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

    did willfully and unlawfully obtain personal identifying information of Jane Doe 8 and used that

    6

    Complaint [Felony]

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    Count 3

    On or about August 13, 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

    did willfully and unlawfu

    ll

    y obtain personal

    identif

    ying informati on

    of

    Jane

    Doe

    10

    and

    used

    that information

    fo

    r an unlawful purpose, and to obtain, and attempt

    to

    obtain credit, goods,

    services,

    and

    money without the consent of Jane Doe 1 0.

    Count 24

    On or about August 26, 2013, in the Co unty of San Diego, the crime ofldentity Theft., in

    violation of

    Pen

    al

    Code

    section 530.5(a), a felony , was committed by Kevin

    BOLLAERT 

    who

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

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

    Doe 11.

    Count 25

    On or a

    bout

    August 26 , 20 13, in the County of San Diego, the c

    rime

    of Identity Theft, in

    violation of Penal

    Code

    section 530.5(a), a felony was committed by

    Kevin

    BOLLAERT  who

    did willfully and

    unlaw

    fu

    ll

    y obtain personal

    identif

    ying information

    of Jane Doe

    II and used

    tha

    t i

    nf

    o

    rm

    ation for an

    unla

    wf

    ul purpose and to obtain,

    and

    attempt

    to

    obtain credit, goods,

    services, and money without the

    consent

    of Jane

    Do

    e 11.

    Count 26

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

    violation

    of

    Penal

    Code

    section 530.5(a), a

    fe

    l

    ony

    , was

    comm

    itted

    by

    Kevin BOLLAERT who

    did

    willfully

    and

    unlawfully obtain personal identifying

    in forma

    tion

    of

    Jane

    Doe

    12 and used

    that

    in f

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

    Doe 12.

    Count 27

    On or about

    September

    4, 20 13, 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

    did willfully and unl aw fully

    obta

    in personal i

    de

    ntifying in formation of Jane Doe 12 and used

    8

    Complaint

    [F

    elony]

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    10

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    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.

    3 Count 8

    4

    On

    or

    about

    September

    10, 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

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

    7 used that information for an unlawful purpose

    to

    wit, to harass

    and annoy,

    without the consent of

    8 Jane

    Doe

    13.

    9

    Count 29

    On or about September 10, 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

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

    3

    used that information for an unlawful

    purpose

    , and to obtain, and attempt to obtain credit, goods,

    14 services, and

    money,

    without the consent of Jane Doe 13.

    Count 30

    16 On

    or

    about

    September

    12, 2013, in the County or San Diego,

    the

    crime of Identity Theft,

    17 in

    viola

    tion

    of

    Penal

    Code

    section

    530

    .5(a), a felony, was co

    mmitted

    by Kevin

    BOLLAERT 

    18 who did willfully

    and

    unlawfully obtain personal identifying information of Jane Doe 14

    and

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

    Jane

    Doe

    14.

    2 Count31

    22

    On or about September 12, 2013, in the County of

    San

    Diego, the crime

    ofidentity

    Theft,

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

    BOLLAERT 

    24

    who did willfully and unlawfully

    obtain

    personal identifying information of Jane Doe 14 and

    used that information for an unlawful purpose, and to obtain,

    and

    attempt to obtain credit, goods,

    26

    services, and money, without the consent of Jane

    Doe

    14.

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    9

    Complaint [Fe

    lon

    y)

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    Dated:

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    December

    10,

    2013

    Respectfully Submitted,

    KAMALA D. HARRIS

    Attorney General

    of

    California

    T W YA

    AUSTIN

    Deputy Attorney General

    Attorneys for the People ofth State of

    California

    10

    Complaint [Felony)