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Indictment COLE
Indictment COLE
Plaintiff,
v.
COUNT 1
(Sexual Exploitation and Attempted Sexual Exploitation of a Minor)
Between about February 2021 and about June 2021, the exact date being
unknown to the grand jury, in Kent County, in the Southern Division of the
knowingly used, persuaded, induced, and enticed, and attempted to use, persuade,
induce, and entice, a minor to engage in sexually explicit conduct for the purpose of
producing visual depictions of such conduct and that were produced using materials
attempted to use, persuade, induce, and entice a girl, Victim 1, who was
including, but not limited to, one or more of the seven images that he produced.
Case 1:21-cr-00147-PLM ECF No. 1, PageID.2 Filed 08/18/21 Page 2 of 8
The defendant produced the images using digital devices, including, but not limited
2
Case 1:21-cr-00147-PLM ECF No. 1, PageID.3 Filed 08/18/21 Page 3 of 8
COUNT 2
(Attempted Coercion and Enticement)
Between on or about June 1, 2021, and on or about June 23, 2021, in Kent
elsewhere,
individual who defendant believed was under the age of 18 years to engage in
sexual activity for which any person could be charged with a criminal offense.
sexual activity. Sex acts with the 14-year-old would constitute Third Degree
Sexual contact with the 14-year-old would constitute Fourth Degree Criminal
18 U.S.C. § 2422(b)
3
Case 1:21-cr-00147-PLM ECF No. 1, PageID.4 Filed 08/18/21 Page 4 of 8
COUNT 3
(Possession of Child Pornography)
On or about June 23, 2021, in the Southern Division of the Western District
minors, including, but not limited to, one or more of the images and videos listed
below:
Such images were produced using materials which had been shipped or transported
in interstate or foreign commerce, including, but not limited to, a Samsung, model
SM-102 cellular telephone, Motorola, model Razer MAXX cellular telephone, and a
Dell Latitude laptop computer, which were manufactured outside the State of
Michigan.
4
Case 1:21-cr-00147-PLM ECF No. 1, PageID.5 Filed 08/18/21 Page 5 of 8
FORFEITURE ALLEGATION
(Sexual Exploitation of a Minor and
Possession of Child Pornography)
shall forfeit to the United States of America any visual depiction described in 18
U.S.C. § 2252A; any matter which contains any such visual depiction that was
produced, transported, mailed, shipped, and received in violation of Title 18, United
States Code, Chapter 110; any property, real or personal, constituting or traceable
to gross profits or other proceeds obtained from the offenses; and any property, real
forfeited, as to all counts, includes, but is not limited to, the following:
If any of the property described above, as a result of any act or omission of the
defendant:
5
Case 1:21-cr-00147-PLM ECF No. 1, PageID.6 Filed 08/18/21 Page 6 of 8
U.S.C. § 2461(c).
18 U.S.C. § 2253
21 U.S.C. § 853(p)
28 U.S.C. § 2461(c)
18 U.S.C. § 2251
18 U.S.C. § 2252A
6
Case 1:21-cr-00147-PLM ECF No. 1, PageID.7 Filed 08/18/21 Page 7 of 8
FORFEITURE ALLEGATION
(Attempted Coercion and Enticement)
U.S.C. § 2428.
shall forfeit to the United States of America, any property, real or personal, used or
intended to be used to commit or to facilitate the commission of the offense and any
the defendant:
7
Case 1:21-cr-00147-PLM ECF No. 1, PageID.8 Filed 08/18/21 Page 8 of 8
18 U.S.C. § 2428
21 U.S.C. § 853(p)
28 U.S.C. § 2461(c)
18 U.S.C. § 2422
A TRUE BILL
__________________________________________
GRAND JURY FOREPERSON
___________________________________
DANIEL Y. MEKARU
Assistant United States Attorney