W eeee Case 1 :07-cr—00065-GIVIS Document 15 Filed 05/10/2007 Page 1 of 4
» IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
)
Plaintiff, )
v. ) Criminal Action No. 07-
)
VVILLIAM EDWARD ROE, ) — et F- wr`,
) ( l_ _II .
Defendant, ) ,__ _ J A Q4,-A
INDICTMEN T
The Grand Jury for the District of Delaware charges that:
Countsg
From on or about August 21, 2005, through on or about March 17, 2007, in the District of
Delaware, William Edward Roe, the defendant, 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 of the 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:
Count Date Received
, 1 August 21, 2005
2 August 22, 2005 F
3 December 21, 2006 - I L E D
4 December 25, 2006 ` MAY I U 2007
5 January 15, 2007
J 0 Januar 10 2007 L, ¤?;¥¤T3?B“i‘%‘rE,?J$Elr ____,
7 March 17, 2007
in violation of Title 18, United States Code, Section 2252A(a)(2) and 1).
Case 1 :07-cr—00065-GIVIS Document 15 Filed 05/10/2007 Page 2 of 4
From on or about September 20, 2005, through on or about December 20, 2006, in the District
of Delaware, William Edward Roe, the defendant, knowingly transported and attempted to transport
by computer in interstate and foreign commerce 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 of the genitals and
pubic area, the dates being described more particularly, as follows:
Qgtgg Qate Transgorted
8 September 20, 2005
9 December 7, 2006
10 December 10, 2006
in violation of Title 18, United States Code, Section 2252A(a)(1) and (b)(1).
0 Count 11
On or about March 27, 2007 , in the District of Delaware, William Edward Roe, the defendant,
knowingly possessed a computer hard drive 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 ofthe genitals and pubic area, which child pornography
p had been transported in interstate and foreign commerce and which had been produced using materials
which had been transported in interstate commerce, in violation of Title 1 8, United States Code, Section
i 2252A(a)(5)(B) and (b)(2).
Counts 12 jjj
From on or about August 21, 2005, through on or about March 17, 2007, in the District of
Delaware, William Edward Roe, the defendant, knowingly received and attempted to receive visual
2
Case 1 :07-cr—00065-QIVIS Document 15 Filed 05/10/2007 Page 3 of 4
° 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, 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, the dates being described more particularly, as follows:
Caunt Qute Received
12 August 21, 2005
13 August 22, 2005
14 December 21, 2006
15 December 25, 2006
16 January 15, 2007
17 January 16, 2007
18 March 17, 2007
in violation of Title 18, United States Code, Sections l466A(a)(2)(A) and (B), and 2252A(b)(1).
Counts 19 - 21
From on or about September 20, 2005, through on or about December 10, 2006, in the District
of Delaware, William Edward Roe, the defendant, knowingly distributed and attempted to distribute
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, the dates being described more particularly, as follows;
Count Date Distributed
19 September 20, 2005
20 December 7, 2006
21 December 10, 2006
in violation of Title 18, United States Code, Sections 1466A(a)(2)(A) and (B), and 2252A(b)(l).
3
Case 1 :07-cr—00065-GIVIS Document 15 Filed 05/10/2007 Page 4101 4
knowingly possessed visual depictions, that is, computer tiles, 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, 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)I(2)(A)
and (B), and 2252A(b)(2).
A TRUE BILL:
Foreman _ V
COLM F. CZQNNOLLY
Ur1it<·gStafé?lltor;r\1ey r
ond Falgowski
_ Assistant United States Attorney
Dated: S'., (Q) ·-· O 7
4