1:17-cr-20316-TLL-PTM Doc # 1 Filed 05/10/17 Pg 1 of 4 Pg ID 1

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MICHIGAN
NORTHERN DIVISION

LINITED STATES OF AMERICA,

Case: 1:17-cr-20316
Plaintift Judge: Ludington, Thomas L.
MJ: Monis, Patricia T.
Filed: 05-1G2017At 04.39 PM
SEALED MATTER (krc)
DEREK CHARLES CHAPMAN,

Defendant.

INDICTMENT

THE GRAND JURY CHARGES:

COT]NTONE
ATTEMPTED SEXUAL EXPLOITATION OT A CHILD
(18 U.S.C. $22s1(a) & (e))

In or around December 2015 to January 2016, in the Eastem District of

Michigan, the defendant, DEREK CHARLES CHAPMAN, did knowingly attempt

to coerce S.V., a 14 year old minor female, to engage in sexually explicit conduct

for the purpose ofproducing any visual depiction ofsuch conduct, knowing and

having reason to know that such visual depiction would be transported using any

means and facility of interstate and foreign commerce; knowing and having reason

to know that such visual depiction would be transported in and affecting interstate

and foreign commerce; using materials that have been mailed, shipped, and

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transported in and affecting interstate and foreign commerce by any means,

including by computer; that is, CHAPMAN attempted to coerce S.V. into

lasciviously exhibiting her genitals and pubic area, photographing those things, and

sending the photograph(s) to CHAPMAN using her cellular phone or tablet using a

text messaging service over the intemet when S.V. was in Washington state and

while CHAPMAN was in the Eastem District of Michigan, in violation of Title 18,

United States Code, Sections 2251(a) & (e).

COUNT TWO
RECEIPT OF CHILD PORNOGRAPHY
(1 8 U.S.C. $ 22s2 A(a)(z))

On or around March 1 1,2017, in the Eastern District of Michigan, Northern

Division, defendant, DEREK CHARLES CHAPMAN knowingly received and

attempted to receive one or more visual depictions that had been mailed, shipped

and transported in interstate and foreign commerce by any means, including by

computer, the production ofsuch visual depictions having involved the use of

minors engaging in sexually explicit conduct (as defined in Title 18, United States

Code, Section 2256(2)), in violation of Title 18, United States Code, Section

22s2A(a)(2).

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COUNT THREE
POSSESSION OF CHILD PORNOGRAPHY
(18 u.S.C. $ 22s2A(a)(s)(B))

On or about April 7, 2017 , in the Eastem District of Michigan, Northern

Division, defendant, DEREK CHARLES CHAPMAN, knowingly possessed one

Huawei cell phone and one Gateway laptop computer that contained images of

child pornography, as defined by Title 18, United States Code, Section 2256(8),

that had been shipped and transported using any means and facility of interstate

and foreign commerce and at least some of which involved a prepubescent minor

or a minor who has not attained the age of l2 years of age, in violation of Title 18,

United States Code, Section 2252A(a)(5)(B).

Dated: May 10,2017 THIS IS A TRUE BILL

DANIEL L. LEMISH
Acting United States Attomey s/GRAND J URY FOREPERSON

s/CHRISTOPHER W. RAWSTHORNE s/CRAIG F. WININGER

CHRISTOPHER W. RAWSTHORNE cRArG F. WTNTNGER (P57058)
Assistant U.S. Attomey Assistant U.S. Attorney
wI State Bar ID #1059889 Chief, Branch Offices
600 Church Street
Flint, MI 48502
(810) 766-st77
christopher.rawsthorne@usdoi. eov

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Com anion Case information MUST be com leted AUSA and initialed.
United Stat6 Oistrict Court Criminal Case Cover Sheet Case Number
Eastern Oistrict of Michigan

NOTE: lt is the responsibility ot the Assistant U.S. Attorney signing this torm to complt6 it accu.atgly ln all respects.

Case: '1:17-cr-20316
Judge: Ludington, Thomas L.
This may be a companion case based upon LCrR 57.10 (bx4)i: MJ: Monis, Patricia T.
Filed: 05-'lG2017At 04:39 pM
!ves Exo SEALED MATTER (krc)

Case Title: USA v. ggpEK CHARLES CHApMAN

County where offense occurred : CLARE

Check One: E Felony n Misdemeanor n Petty

X lndictmenV-lnformation -- no prior complaint.

-- based upon prior complaint [case number:
_lndictmenv_lnformation -- based upon LcrR 57.10 (d) Icomprete sup erseding section belowl.
-lndictmenu-lnformation
sup erseding Case lnformation
Superseding to Case No: Judge:

L Original case was terminated; no additional charges or defendants

t- Corrects errors; no additional charges or defendants.
! lnvolves, for plea purposes, different charges or adds counts.
! Embraces same subject matter but adds the additional defendants or charges below

Defendant name Charqes Prior Complaint (if applcable)

Please take notice that the below listed Assistant United States Aftorney is the attorney of record for
the above captioned case.
May 10,2017
Date
-
,+
Christooher W. Rawsthorne
Assistaht United States Attorney
2't0 Federal Building
600 Church Street
Flint, Michigan 48502
Telephone: (810) 766-5177
Email: Christopher. Rawsthorne@usdoj.gov
wt BAR# 1059889

same tran$ction or occurrence. Cases may be companaon cases even though one of lhem may have already been temjnated.
03h 112013