Case 3:i2-cr-00317-L

Document 19 Filed 10/03/12 Page 1 of 11 PagelD 46

U.S. DISTRICT COURT NORTHERN DISTRICT OF TEXAS

FILED
IN THE UNITED STATES D STRICT COUR T FOR THE N O R T H E R N DIS1RICT O Tj?CA D A L L A S DIVIS ION
7

~"

C L E R K , U.S. DISTRICT COURT

UNITED STATES OF A M E R I C A VS. BARRETTLANCASTERBROWN(l)

Deputy

v CRIMINAL NO. 8. " 1 2CB

- 3 1 ? * Il

INDICTMENT The Grand Jury charges: INTRODUCTION At ail times material to this indictment, or as otherwise specified, 1. Barrett Lancaster Brown created Project P M in approximately 2010. Project P M

was a IRC/wiki-based blogger network created to allow Brown and those he associated with to share information and achieve or pursue certain goals. Barrett Lancaster Brown used the website wiki.echelon2.org to operate Project P M . 2. On September 4, 2012, Barrett Lancaster Brown used his Twitter.com account

BarrettBrownLOL, and posted the following comments: a. "Don't be a pussy. Call up every facist and tell them you're watching. http://www.youtube.com/watch?v=4gcptY8nel4 ... #ProjectPM." "Have you doxed a pig today? Be ready for the dvolution - have a list informationliberation.com/?id=40815 #Anonymous." "Don't know how to shoot? You've got five years to learn. Maybe less.http://www.youtube.com/watch?v=wkqSIZaBhUY&list=UUv 1F lZ4TdveCyva7okPRmSA&index=l&feature=plcp ... #Anonymous #ProjectPM #blackbloc."

b.

c.

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d.

"#DHS stocking up on ammo. Are you? http://www.youtube.com/watch?v=wkqSIZaBhUY&list=UUvlFlZ4 TdveCyva7okPRmSA&index=l&feature=plcp ... Don't wait. Retaliate." "Have a plan to kill every government you meet. #ProjectPM tinychat.com/BarrettBrown #Anonymous Echelon2.org."

e.

3.

On September 7, 2012, Barrett Lancaster Brown used his Twitter.com account

BarrettBrownLOL, and posted the following comments: a. "Kids! Overthrow the US government loi https://www.youtube.com/watch?v=pHCdS70248g ..." "@Badger32d I've experienced other end of the gun, watching mom detained by U.S. armed thugs. See you on the streets!" "#ProjectPM - Everyone in #Anonymous with balls is either with us or awaiting trial. Don't wait. Retaliate."

b.

c.

4.

On September 7, 2012, Barrett Lancaster Brown used his Twitter.com account

BarrettBrownLOL, and posted a message saying "Organize. Choose your pig. Make your move. Pastebin.com/HFxBIHv #ProjectPM #Anonymous #blackbloc dvolution." 5. On September 8, 2012, Barrett Lancaster Brown used his Twitter.com account

BarrettBrownLOL, and posted the following comments: a. "Democrats do not fear Republicans who fear no Democrat, but both will learn to fear anarchists now that net gives us revenge #ProjectPM." "So now if I don't take my opiates I guess I get to feel 2 years of betrayal by country, loss of best kids in West to feds. Fuck you." "Last outlet that ran my work, Guardian, no longer responding. Nothing restrains me now from finishing my real work #ProjectPM."

b.

c.

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d.

"Journalists allow the guilty to escape. #ProjectPM ensures the guilty will be known to their children as they are, forever." "Help #ProjectPM plan, excute further attacks #PantherModerns tinychat.com/barrettbrown #Anonymous #Wikileaks http://cryptome.org/2012/09/frey-chat-brown-02.htm ..." "@_Dantalion No. I'd shoot you w/ my shotgun if you came near my home in Texas, where even I can legally kill ppl https://www.youtube.com/watch?v=wkqSIZaBhUY&list=UUvlFlZ4 TdveCyva7okPRmSA&index=2&feature=plcp ..." "Not mad at you, mad at #FBI @AaronBarr which I've got taken care of now anyway loi e-mail hacks pastebin.com/12crnMjP."

e.

f.

g.

6.

On September 10, 2012, Barrett Lancaster Brown used his Twitter.com account

BarrettBrownLOL and posted the following comments: a. "#FBI Now you know I know. I get call from Agent [RS] in 24 hrs, my laptops on plane to Dallas or I release in 25 #Anonymous."
1

7.

On September 10, 2012, Barrett Lancaster Brown used his Twitter.com account

BarrettBrownLOL, and re-posted the message " A dead man can't leak stuff... Illegally shoot the son of a bitch." 8. On September 11, 2012, Barrett Lancaster Brown used his Twitter.com account

BarrettBrownLOL, and posted the following comments: a. "0 uploading now, dropping in 30 minutes #Anonymous #Wikileaks #ProjectPM #PantherModerns #FBI #Agent[RS]." "-1 youtube.com/watch?v=klvPlX... #Anonymous #ProjectPM #Wikileaks #FBI #PantherModerns #Agent[RS] #OffThePigs #Blackbloc."

b.

Per local practice, the victim's name has been redacted from the Indictment. The rdaction will appear as [RS].
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c.

"@AsheraResearch M y mother is being threatened with charges by #FBI due in part to your lies. Mention her again and see what happens." "If what #HBGary did to me was lgal, it will be just as lgal when I do some of it to #Agent[RS]." "#ProjectPM backs up its claims, threats. Don't wait. Retaliate. #OpClydeTolson #Anonymous #Wikileaks http://www.youtube.com/watch?v= klvPlXx60H4&feature =youtu.be ..."
: ::

d.

e.

f.

"As I'il explain further tomorrow, I will regard any further armed raids as potential #Zeta assassination attempts and respond accordingly." "#Agent[RS] claimed my warrants weren't public due to #Zeta threat. He knows it's serious and won't mind i f I shoot any suspects." "Threat to put my mom in prison last mistake #Agent[RS] will ever fucking make http://www.youtube.com/watch7vHdvP 1 Xx60H4&feature=autoplay&list= UUvlFlZ4TdveCyva7okPRmSA&playnext=l ... #OpClydeTolson."

g.

h.

9.

On September 11, 2012, Barrett Lancaster Brown published a self made video

on YouTube.com, entitled Why FBI Agent [RS] Has Two Weeks To Send my Property Back, Part 1/3. 10. On September 11, 2012, Barrett Lancaster Brown published a self made video

on YouTube.com, entitled FBI Ultimatum Pt 2. In the video, Brown stated: a. b. "[T]his is part two of a two part sries of why I'm fucking angry." "From now on I am a bad guy, and I'm going to prove that in the coming months, using the court System, using the mdia, using my group ProjectPM, which has always been secretly to some extent created for the purpose of wiping out this fucking government and certain mdia institutions, and through other means at my disposai, some of which are known, some of which are known to a few, and some of which are still secret.... I want everyone to know the

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demand I am making to the FBI today, which is that I will have my stuff returned to me in two weeks." c. "They have two weeks to get send it ail back, and twenty-four hours from now I will receive a call from [RS] himself, apologizing for what happened."

11.

On September 11, 2012, after Barrett Lancaster Brown published the two videos

on YouTube.com, he used his Twitter.com account BarrettBrownLOL, and stated "[d]one for the day, see part 3 of #OpClydeTolson tomorrow. Send me info on #Agent[RS] - use @AaronBarr ethics re: family members." 12. On September 12, 2012, Barrett Lancaster Brown published a self made video

on YouTube.com, entitled Why I'm Going to Destroy FBI Agent [RS] Part Three: Revenge of the Lithe. In the video: a. Brown called FBI Spcial Agent [RS] a "fucking chicken shit little faggot cocksucker" and indicated that "we are investigating [him] now." Brown called FBI Spcial Agent [RS] "a criminal, who is involved in a criminal conspiracy." Brown stated "[fjhat's why [RS]'s life is over, but when I say his life is over, I don't say F m going to kill him, but I am going to ruin his life and look into his fucking kids." Brown stated "[a]ny armed officiais of the US government, particularly the FBI, will be regarded as potential Zeta assassin squads, and as the FBI and DPD know . . . I'm armed, that I corne from a military family, that I was taught to shoot by a Vietnam vet and by my father a master hunter . . . I will shoot ail of them and kill them if they corne." Brown stated "[a]nd frankly, you know, it was pretty obvious I was

b.

c.

d.

e.

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going to be dead before I was forty or so, so, I wouldn't mind going out with two FBI sidearms like a fucking Egyptian Pharaoh. Adios" 13. When Barrett Lancaster Brown published the video Why I'm Going to Destroy

FBI Agent [RS] Part Three: Revenge of the Lithe on September 12, 2012, he inserted a comment on YouTube.com requesting other persons to "[s]end ail info on Agent [RS] to barriticus@gmail.com so FBI can watch me look up his kids."

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COUNT ONE Internet Threats 18U.S.C. 875(c) The Grand Jury hereby adopts, realleges, and incorportes by rfrence ail of the allgations in the Introduction of this Indictment. From on or after March 6, 2012, through and including on or about September 12, 2012, in the Dallas Division of the Northern District of Texas, the dfendant Barrett Lancaster Brown, knowingly and willfully did transmit in interstate and foreign commerce communications containing threats to injure the person of another, that being, Barrett Lancaster Brown transmitted messages through the Internet on his Twitter.com account and his YouTube.com account, threatening to shoot and injure agents of the Fdral Bureau of Investigation, and specifically focusing on Fdral Bureau of Investigation Spcial Agent [RS]. In violation of 18 U.S.C. 875(c).

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COUNT TWO Conspiracy to Make Publically Available Restricted Personal Information of an Employe of the United States 18U.S.C. 371 (18U.S.C. 119) The Grand Jury hereby adopts, realleges, and incorportes by rfrence ail of the allgations in the Introduction of this Indictment. Between on or about March 5, 2012 through on or about September 12, 2012, in the Dallas Division of the Northern District of Texas, the dfendant Barrett Lancaster Brown, knowingly and willfully did combine, conspire, confederate, and agre with other persons known and unknown to the grand jury, to commit an offense against the United States, to wit: to make restricted personal information about Fdral Bureau of Investigation Spcial Agent [RS] and his immdiate family publically available with the intent to threaten and intimidate the Spcial Agent and to incite the commission of a crime of violence against the Spcial Agent in violation of 18 U.S.C. 119, in that in September 2012 in the Northern District of Texas, Barrett Lancaster Brown requested another person known to the grand jury to assist him find on the Internet restricted information about Fdral Bureau of Investigation Spcial Agent [RS] and [RS]'s family, and that other person agreed to do so, and furthermore, the other person did conduct a search on the Internet for the restricted information. In violation of 18 U.S.C. 371 (18 U.S.C. 119).

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COUNT THREE Retaliation Against a Fdral Law Enforcement Officer (18 U.S.C. 115(a)(l)(B) and (b)(4)) The Grand Jury hereby adopts, realleges and incorportes by rfrence ail of the allgations in the Introduction of this Indictment. Between on or about March 5, 2012 through on or about September 12, 2012, in the Dallas Division of the Northern District of Texas, the dfendant Barrett Lancaster Brown, did knowingly and willfully threaten to assault a Fdral Law enforcement officer, with the intent to impede, intimidate, and interfre with such Fdral Law enforcement officer while engaged in the performance of officiai duties, and with the intent to retaliate against such Fdral Law enforcement officer on account of the performance of officiai duties. In violation of 18 U.S.C. 115(a)(l)(B) and (b)(4). A TRUE BILL:

S A R A H R. S A L D A N A UNITED STATES A T T O R N E Y

C A N D I N A S. H E A T H Assistant United States Attorney State of Texas Bar No. 09347450 1100 Commerce Street, 3rd Floor Dallas, Texas 75242 Tlphone: 214.659.8600 candina.heath@usdoj .gov
Indictment - Page 9

Case 3:12-cr-00317-L

Document 19 Filed 10/03/12 Page 10 of 11 P*agelD 55

IN THE UNITED STATES DISTRICT COURT FOR THE N O R T H E R N DISTRICT OF T E X A S D A L L A S DIVISION THE UNITED STATES OF A M E R I C A v. BARRETT LANCASTER BROWN

INDICTMENT 18 U.S.C. 875(c) Internet Threats 18 U.S.C. 371 (18 U.S.C. 119) Conspiracy to Make Publically Available Restricted Personal Information of an Employe of the United States 18 U.S.C. 115(a)(l)(B) and (b)(4) Retaliation Against a Fdral Law Enforcement Officer

3 Counts A true bill rendered

DALLAS Filed in open court this day of October 2012

FOREPERSON

Clerk
Dfendant already in Fdral Custody since 9/13/12 at Mansfield

UNITED STATES D f ^ ^ T / M A G I S T R A T E JUDGE Magistrate Case pending 3:12-MJ-405

y ^ ^ ^ ^ ^ ^ / /<
/ < y 3

Case 3:12-cr-00413-B Document 1 Filed 12/04/12 Page 1 of 6 PagelD 1

CLF/X US DISTRICT COURT ; -RTHERN DIST.OF TX

Q^\G\H

IN THE UNITED STATES DISTRICT COURT FOR THE N O R T H E R N DISTRICT OF T E X A S D A L L A S DIVISION

flLED
2

'

.l'5

DEPUTY CLERK.

UNITED STATES OF A M E R I C A VS. B A R R E T T L A N C A S T E R B R O W N (1) The Grand Jury charges:

NO. J[ # 1 2CR " 41 3 " B

INDICTMENT Count One Traffic in Stolen Authentication Features (18 U.S.C. 1028(a)(2), (b)(l)(B), and (c)(3)(A)) Aid and Abet (18 U.S.C. 2 ) On or about December 25, 2011, in the Dallas Division of the Northern District of Texas and elsewhere, dfendant Barrett Lancaster Brown, aided and abetted by persons known and unknown to the Grand Jury, in and affecting interstate commerce, did knowingly traffic in more than five authentication features knowing that such features were stolen and produced without lawful authority, in that Brown transferred the hyperlink "http://wikisend.com/download/597646/stratfor_full_b.txt.gz" from the Internet Relay Chat (IRC) channel called "#Anonops" to an IRC channel under Brown's control called "#ProjectPM," said hyperlink provided access to data stolen from the company Stratfor Global Intelligence, to include in excess of 5,000 crdit card account numbers,

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the card holders' identification information, and the authentication features for the crdit cards known as the Card Vrification Values (CVV), and by transferring and posting the hyperlink, Brown caused the data to be made available to other persons online without the knowledge and authorization of Stratfor Global Intelligence and the card holders. In violation of 18 U.S.C. 2 and 1028(a)(2), (b)(l)(B), and (c)(3)(A).

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Count Two Access Device Fraud (18 U.S.C. 1029(a)(3) and (c)(l)(A)(i)) Aid and Abet (18 U.S.C. 2 ) From on or about December 25, 2011, through at least on or about March 6, 2012, in the Dallas Division of the Northern District of Texas and elsewhere, dfendant Barrett Lancaster Brown, aided and abetted by persons known and unknown to the Grand Jury, with intent to defraud did possess at least fifteen and more devices unauthorized access devices in and affecting interstate and foreign commerce, in that Brown possessed stolen crdit card account numbers and the authentication features for the crdit cards known as the Card Vrification Values (CVV) without the knowledge and authorization of the card holders. In violation of 18 U.S.C. 2 and 1029(a)(3), and (c)(l)(A)(i).

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Counts Two Through Twelve Aggravated Identity Theft (18 U.S.C. 1028A(a)(l)) Aid and Abet (18 U.S.C. 2)

From on or about December 25, 2011 through at least on or about March 6, 2012, in the Dallas Division of the Northern District of Texas and elsewhere, dfendant Barrett Lancaster Brown, aided and abetted by persons known and unknown to the Grand Jury, during and in relation to a felony violation of 18 U.S.C. 1028(a)(2), knowingly transferred and possessed without lawful authority the means of identification of the persons below referenced, said means of identification consisting of the crdit card account numbers; the corresponding authentication features for the crdit cards known as the Card Vrification Values (CVV); the card holders' names and usernames for online account access; and the card holders' physical addresses, phone numbers, and email addresses. COUNT CARD HOLDER BM CD BH BL BS BC CITY, STATE AMERICAN EXPRESS CC # (last four digits) 5003 4011 1007 2004 1009 3009 CC C V V (redacted) 4*87 9*71 4*28 4*20 8*55 4*10

3 4 5 6 7 8
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Houston, T X Dallas, T X Spicewood, T X Galveston,TX Dallas, T X Dallas, T X

Case 3:12-cr-00413-B Document 1 Filed 12/04/12 Page 5 of 6 PagelD 5

9 10

BW MT

Dallas, T X Coco Beach, FL

2732 4007

7*16 9*98

COUNT

CARD HOLDER KR BJ

CITY, STATE

MASTER C A R D CC # (last four digits) 6394 6444

CC C V V (redacted) 4*8 4*3

11 12

Tucson, A Z Richardson, TX

In violation of 18 U.S.C. 2 and 1028A(a)(l). A TRUE B I L L :

S A R A H R. S A L D A N A UNITED STATES A T T O R N E Y

Assistant United States Attorney Northern District of Texas State of Texas Bar No. 09347450 1100 Commerce Street, 3rd Floor Dallas, Texas 75242 office: 214.659.8600 fax: 214.659.8805 candina.heath@usdoj .gov

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Case 3:12-cr-00413-B

Document 1 Filed 12/04/12

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IN THE UNITED STATES DISTRICT COURT FOR THE N O R T H E R N DISTRICT OF T E X A S D A L L A S DIVISION THE UNITED STATES OF A M E R I C A v. B A R R E T T L A N C A S T E R B R O W N (1)

INDICTMENT 18 U.S.C. 1028(a)(2), (b)(l)(B), and (c)(3)(A); 18 U.S.C. 2 Traffic in Stolen Authentication Features; and A i d and Abet 18 U.S.C. 1029(a)(3) and (c)(l)(A)(i); and 18 U.S.C. 2 Access Device Fraud; and A i d and Abet 18 U.S.C. 1028A(a)(l); and 18 U.S.C. 2 Aggravated Identity Theft; and A i d and Abet

12 Counts A true bill rendered

DALLAS Filed in open court this day of December, 2012

FOREEERSON

Clerk
Dfendant already in Fdral Cust

since^JM2/af#ansfit

UNITED STATES DiSTR4G [GfsTRATE JUDG'E Magistrate Case pending 3:12-MJ-405

Case 3:13-cr-00030-B ' Document 1 Filed 01/23/13 Page 1 of 4 PagelD 1

' U S DISTRICT C O U R T N O R T H E R N DISTRICT OF T E X A S

FILED

0^

IN THE UNITED STATES DISTRICT COURT p ~ FOR THE N O R T H E R N DISTRICT OF 1 E X A S JAN 2 3 2013 D A L L A S DIVISION
C L E R K , U.S.. DISTRICT C O U R T By.

UNITED STATES OF A M E R I C A VS. NO. B A R R E T T L A N C A S T E R B R O W N (1)

Deputy

3 - 1 3 C RO 0 3 0 " B

The Grand Jury charges: INDICTMENT Count One Obstruction: Concealment of Evidence (18 U.S.C. 1519) A i d and Abet (18 U.S.C. 2 ) On or about March 6, 2012, in the Dallas Division of the Northern District of Texas, the dfendant Barrett Lancaster Brown, aided and abetted by K M , did knowingly conceal tangible objects, namely two laptop computers containing records, documents, and digital data, with the intent to impede, obstruct, and influence the investigation and proper administration of any matter within the jurisdiction of any dpartaient and agency of the United States, and in relation to and in contemplation of any such matter, in that Barrett Lancaster Brown and K M concealed two laptop computers in K M ' s rsidence in the Northern District of Texas prior to the excution of a search warrant at K M ' s rsidence, said search warrant having been issued by a United States Magistrate Judge in the Dallas Division of the Northern District of Texas, and the
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excution of the search warrant was in relation to an investigation conducted by the Dallas Division of the Fdral Bureau of Investigation, an agency of the United States Department of Justice. In violation of 18 U.S.C. 1519 and 18 U.S.C. 2 .

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Count Two Obstruction: Corruptly Concealing Evidence (18 U.S.C. 1512(c)(l)) Aid and Abet (18 U.S.C. 2 ) On or about March 6, 2012, in the Dallas Division of the Northern District of Texas, the dfendant Barrett Lancaster Brown aided and abetted by K M , did knowingly and corruptly conceal and attempt to conceal records, documents, and digital data contained on two laptop computers, with the intent to impair the integrity and availability of the records, documents, and digital data contained on the laptop computers for use in an officiai proceeding, that being: (1) a proceeding before a fdral Grand Jury in the Northern District of Texas; and (2) a proceeding before a United States Magistrate Judge in the Northern District of Texas specifically related to search warrants issued on March 5, 2012. In violation of 18 U.S.C. 1512(c)(l) and 18 U.S.C. 2.

Assistant United States Attorney Northern District of Texas State of Texas Bar No. 09347450 1100 Commerce Street, 3rd Floor Dallas, Texas 75242 office: 214.659.8600 fax: 214.659.8805 candina.heath@usdoj .gov
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IN THE UNITED STATES DISTRICT COURT FOR THE N O R T H E R N DISTRICT OF T E X A S D A L L A S DIVISION THE UNITED STATES OF A M E R I C A v. B A R R E T T L A N C A S T E R B R O W N (1)

INDICTMENT 18 U.S.C. 1519; 18 U.S.C. 2 Obstruction: Concealment of Evidence; A i d and Abet 18 U.S.C. 1512(c)(l); 18 U.S.C. 2 Obstruction: Corruptly Concealing Evidence; A i d and Abet

2 Counts A true bill rendered

DALLAS Filed in open court this_j____ day of January, 2013

FOREPERSON

Dfendant Barrett Lancaster Brown in Fdral Cust

UNITED STATES DISTRICT/MAGISTRATE JUDG No Criminal matter pending