MWC:USAO# 2009R00900

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MARYLAND

UNITED STATES OF AMERICA *

* CRIMINAL NO. MJG-10-099
v. *
* (Sexual Exploitation and Attempted Sexual
JEREMY GUZEWICZ, * Exploitation of a Child, 18 U.S.C. §§
* 2251(a) & (e); Receipt and Distribution of
Defendant * Child Pornography, 18 U.S.C. 2252(a)(2);
Possession of Child Pornography, 18 U.S.C.
*
§§ 2252A(a)(5)(B) & 2256; Extortion, 18
*
U.S.C. §§ 875(b) & (d); Forfeiture, 18
* U.S.C. § 2253)
*
*******

SUPERSEDING INDICTMENT

COUNT ONE

The Grand Jury for the District of Maryland charges that:

At all times relevant to this Indictment:

INTRODUCTION

1. JEREMY GUZEWICZ resided at 14 Dowling Circle, Apartment T3, Parkville,

Maryland, 21234. .

2. Teenchat.com is a social networking site available on the Internet and marketed

towards teenagers. The site purports to facilitate communication among teenagers who dialogue

with other teenagers sharing similar interests in chat rooms referred to as “hangouts.”

3. JEREMY GUZEWICZ used the e-mail account sfk5000@hotmail.com to register

as a user on teenchat.com, using the screen name “StepDad4YngF”.

4. JEREMY GUZEWICZ portrayed himself on teenchat.com as an older man with

stepchildren.
 5. JEREMY GUZEWICZ is a male born in 1982 and has no children.

6. JEREMY GUZEWICZ, using the screen name “StepDad4YngF”, introduced

himself on teenchat.com to a minor female, identified herein as Jane Doe.

7. Jane Doe is a female born in 1993 and she has lived in Massachusetts her entire life.

Jane Doe informed JEREMY GUZEWICZ that she was twelve years old when he first began

communicating with her.

8. JEREMY GUZEWICZ, soon thereafter, ordered Jane Doe to send him personal

photographs over the Internet depicting, among other things, i) her genital area and breasts, and

ii) penetration of her vagina with foreign objects.

9. JEREMY GUZEWICZ sent Jane Doe a photograph of a penis, which he

represented to be his own.

10. JEREMY GUZEWICZ called Jane Doe multiple times over the telephone. During

the telephone calls, JEREMY GUZEWICZ instructed Jane Doe to make gagging and choking

sounds as he masturbated.

11. JEREMY GUZEWICZ threatened Jane Doe that he would tell her parents that she

was communicating with strangers online, and that he would travel to Massachusetts to rape Jane

Doe, if she did not send additional photographs of herself or comply with his instructions.

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 THE CHARGE

(Sexual Exploitation and Attempted Sexual Exploitation of a Child)

12. From on or about July 1, 2006 to on or about November 17, 2009, in the District of

Maryland, and elsewhere, the defendant,

JEREMY GUZEWICZ,

attempted to and did knowingly employ, use, persuade, induce, entice, and coerce Jane Doe, a

minor, to engage in sexually explicit conduct for the purpose of transmitting any live visual

depiction of such conduct, knowing and having reason to know that such visual depiction would

be transmitted using any means and facility of interstate and foreign commerce, and knowing

and having reason to know that such visual depiction would be transmitted in and affecting

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

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

computer.

18 U.S.C. §§ 2251(a) and 2251(e)

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 COUNT TWO

(Distribution of Child Pornography)

And the Grand Jury for the District of Maryland further charges that:

1. Paragraphs 1 through 11 of Count One are incorporated here.

2. On or about July 11, 2009, in the District of Maryland, and elsewhere, the

defendant,

JEREMY GUZEWICZ,

did knowingly distribute any visual depiction using any means and facility of interstate and

foreign commerce, and that had been mailed shipped and transported in and affecting interstate

and foreign commerce, and which contained materials which had been so mailed, shipped and

transported, by any means including by computer, and knowingly reproduces any visual

depiction for distribution using any means and facility of interstate and foreign commerce and in

and affecting interstate and foreign commerce and through the mails, the production of which

involved the use of a minor engaged in sexually explicit conduct, as defined in Title 18, United

States Code, Section 2256(2), and such depiction being of such conduct, that is, the defendant

distributed visual depictions of minors engaging in sexually explicit conduct, including, but not

limited to, a file with the following title: “Pthc Doctor’s Office with 5yo & 7yo girls 7m58s.avi”,

a moving digital image file that depicts a prepubescent girl masturbating an adult male, the adult

male fondling the girl’s vagina, and the adult male attempting to engage in vaginal intercourse

with the girl.

18 U.S.C. §§ 2252(a)(2) & 2256

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 COUNT THREE

(Distribution of Child Pornography)

And the Grand Jury for the District of Maryland further charges that:

1. Paragraphs 1 through 11 of Count One are incorporated here.

2. On or about July 11, 2009, in the District of Maryland, and elsewhere, the

defendant,

JEREMY GUZEWICZ,

did knowingly distribute any visual depiction using any means and facility of interstate and

foreign commerce, and that had been mailed shipped and transported in and affecting interstate

and foreign commerce, and which contained materials which had been so mailed, shipped and

transported, by any means including by computer, and knowingly reproduces any visual

depiction for distribution using any means and facility of interstate and foreign commerce and in

and affecting interstate and foreign commerce and through the mails, the production of which

involved the use of a minor engaged in sexually explicit conduct, as defined in Title 18, United

States Code, Section 2256(2), and such depiction being of such conduct, that is, the defendant

distributed visual depictions of minors engaging in sexually explicit conduct, including, but not

limited to, a file with the following title: “7yo swallows daddys load (1m6sec).avi”, a moving

digital image file that depicts a prepubescent girl performing oral copulation on an adult male

until the adult male ejaculates in the girl’s mouth.

18 U.S.C. §§ 2252(a)(2) & 2256

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 COUNT FOUR

(Distribution of Child Pornography)

And the Grand Jury for the District of Maryland further charges that:

1. Paragraphs 1 through 11 of Count One are incorporated here.

2. On or about July 28, 2009, in the District of Maryland, and elsewhere, the

defendant,

JEREMY GUZEWICZ,

did knowingly distribute any visual depiction using any means and facility of interstate and

foreign commerce, and that had been mailed shipped and transported in and affecting interstate

and foreign commerce, and which contained materials which had been so mailed, shipped and

transported, by any means including by computer, and knowingly reproduces any visual

depiction for distribution using any means and facility of interstate and foreign commerce and in

and affecting interstate and foreign commerce and through the mails, the production of which

involved the use of a minor engaged in sexually explicit conduct, as defined in Title 18, United

States Code, Section 2256(2), and such depiction being of such conduct, that is, the defendant

distributed visual depictions of minors engaging in sexually explicit conduct, including, but not

limited to, a file with the following title: “Vicky The missing oral cumshot (v.good).avi”, a

moving digital image that depicts an adult male ejaculating into a prepubescent girl’s mouth and

the adult male then inserting his penis into the girl’s mouth.

18 U.S.C. §§ 2252(a)(2) & 2256

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 COUNT FIVE

(Receipt of Child Pornography)

And the Grand Jury for the District of Maryland further charges that:

1. Paragraphs 1 through 11 of Count One are incorporated here.

2. On or about May 17, 2009, in the District of Maryland, and elsewhere, the

defendant,

JEREMY GUZEWICZ,

did knowingly receive any visual depiction using any means and facility of interstate and foreign

commerce, and that had been mailed, shipped and transported in and affecting interstate and

foreign commerce, and which contained materials which had been so mailed, shipped and

transported, by any means including by computer, the production of which involved the use of a

minor engaged in sexually explicit conduct, as defined in Title 18, United States Code, Section

2256(2), and such depiction being of such conduct, that is, the defendant received visual

depictions on a Compaq Presario SR1625NX desktop computer, serial number MXY5450H14,

which was of minors engaging in sexually explicit conduct, including, but not limited to, a file

with the following title: “6yo give uncle a great handjob (use this to show kids how to give a

decent handjob)(with sound),.mpg”, a moving digital image file that depicts a child masturbating

an adult male to ejaculation.

18 U.S.C. §§ 2252(a)(2) & 2256

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 COUNT SIX

(Receipt of Child Pornography)

And the Grand Jury for the District of Maryland further charges that:

1. Paragraphs 1 through 11 of Count One are incorporated here.

2. On or about July 9, 2009, in the District of Maryland, and elsewhere, the

defendant,

JEREMY GUZEWICZ,

did knowingly receive any visual depiction using any means and facility of interstate and foreign

commerce, and that had been mailed, shipped and transported in and affecting interstate and

foreign commerce, and which contained materials which had been so mailed, shipped and

transported, by any means including by computer, the production of which involved the use of a

minor engaged in sexually explicit conduct, as defined in Title 18, United States Code, Section

2256(2), and such depiction being of such conduct, that is, the defendant received visual

depictions on a Compaq Presario SR1625NX desktop computer, serial number MXY5450H14,

which was of minors engaging in sexually explicit conduct, including, but not limited to, a file

with the following title: “2009(gracel series) deep pussy fuck.mpg”, a moving digital image file

that depicts an adult male engaging in vaginal intercourse with a prepubescent girl.

18 U.S.C. §§ 2252(a)(2) & 2256

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 COUNT SEVEN

(Possession of Child Pornography)

And the Grand Jury for the District of Maryland further charges that:

1. Paragraphs 1 through 11 of Count One are incorporated here.

2. On or about November 17, 2009, in the District of Maryland, and elsewhere, the

defendant,

JEREMY GUZEWICZ,

did knowingly possess and knowingly access with intent to view any material that contained an

image of child pornography, as defined in Title 18, United States Code, § 2256(8)(A), which

image had been mailed, shipped and transported using any means and facility of interstate and

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

including by computer, and which was produced using materials that had been mailed, shipped,

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

computer, that is, the defendant did posses a Compaq Presario desktop computer, serial number

MXY5450H14, which contained child pornography, including, but not limited to, files with the

following titles: “Misc249.jpg”; “goldi_tied_hanging.jpg”; and “69(1)(1).jpg”.

18 U.S.C. §2252A(a)(5)(B)

COUNT EIGHT

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 (Possession of Child Pornography)

And the Grand Jury for the District of Maryland further charges that:

1. Paragraphs 1 through 11 of Count One are incorporated here.

2. On or about November 17, 2009, in the District of Maryland, and elsewhere, the

defendant,

JEREMY GUZEWICZ,

did knowingly possess and knowingly access with intent to view any material that contained an

image of child pornography, as defined in Title 18, United States Code, § 2256(8)(A), which

image had been mailed, shipped and transported using any means and facility of interstate and

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

including by computer, and which was produced using materials that had been mailed, shipped,

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

computer, that is, the defendant did posses an Acer Aspire desktop computer, serial number

2601285949, which contained child pornography, including, but not limited to, files with the

following titles: “vicky_mummy.mpg”; “r@ygold_mexicangirl11.mpg”; and

“10yrold+dog.mpeg”.

18 U.S.C. §2252A(a)(5)(B)

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 COUNT NINE

(Possession of Child Pornography)

And the Grand Jury for the District of Maryland further charges that:

1. Paragraphs 1 through 11 of Count One are incorporated here.

2. On or about November 17, 2009, in the District of Maryland, and elsewhere, the

defendant,

JEREMY GUZEWICZ,

did knowingly possess and knowingly access with intent to view any material that contained an

image of child pornography, as defined in Title 18, United States Code, § 2256(8)(A), which

image had been mailed, shipped and transported using any means and facility of interstate and

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

including by computer, and which was produced using materials that had been mailed, shipped,

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

computer, that is, the defendant did posses a HP Pavilion desktop computer, serial number

MX13961092, which contained child pornography, including, but not limited to, files with the

following titles: “Pthc Ultra Hard Pedo Child Porn Pedofilia (New) 056(5).jpg”; “Pthc-

Collection of Pedo Pics 215.jpg”; and “Misc138.jpg”.

18 U.S.C. §2252A(a)(5)(B)

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 COUNT TEN

(Extortion)

And the Grand Jury for the District of Maryland further charges that:

1. Paragraphs 1 through 11 of Count One are incorporated here.

2. On or about August 10, 2009, in the District of Maryland, and elsewhere, the

defendant,

JEREMY GUZEWICZ,

with intent to extort from Jane Doe a thing of value, transmitted in interstate and foreign

commerce a communication containing a threat to injure Jane Doe, to wit: the defendant, in

Maryland, transmitted a computer communication to Jane Doe in Massachusetts containing a

threat to injure Jane Doe.

18 U.S.C. § 875(b)

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 COUNT ELEVEN

(Extortion)

And the Grand Jury for the District of Maryland further charges that:

1. Paragraphs 1 through 11 of Count One are incorporated here.

2. On or about August 10, 2009, in the District of Maryland, and elsewhere, the

defendant,
JEREMY GUZEWICZ,

with intent to extort from Jane Doe a thing of value, transmitted in interstate and foreign

commerce a communication containing a threat to injure the reputation of Jane Doe, to wit: the

defendant, in Maryland, transmitted a computer communication to Jane Doe in Massachusetts

containing a threat to injure the reputation of Jane Doe.

18 U.S.C. § 875(d)

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 FORFEITURE
1. The allegations contained in Counts 1 through 9 of this Indictment are incorporated
here for the purpose of alleging forfeitures pursuant to Title 18, United States Code, § 2253.
2. Pursuant to Title 18, United States Code, § 2253, upon conviction of an
offense in violation of Title 18, United States Code, §§ 2251 and 2252, the defendant,
JEREMY GUZEWICZ, shall forfeit to the United States of America:
a. Any visual depiction described in Title 18, United States Code, §§§
2251, 2251A, or 2252, or any book, magazine, periodical, film, videotape,
or other matter which contains any such visual depiction, which was
produced, transported, mailed, shipped or received in violation of Title 18,
United States Code, Chapter 110;
b. Any property, real or personal, constituting or traceable to gross profits or
other proceeds obtained from the offense; and
c. Any property, real or personal, used or intended to be used to commit or to
promote the commission of the offense.
The property to be forfeited includes, but is not limited to, the following:
a. Compaq Presario SR1625NX desktop computer,
S/N: MXY5450H14;
b. Acer Aspire desktop computer, S/N: 2601285949;
c. HP Pavilion xt993 desktop computer, S/N: MX13961092;
d. Samsung SCH-U340 cell phone, S/N: 01507663180; and
e. Samsung SCH-U340 cell phone, S/N: 02212866082;
3. If any of the property described above, as a result of any act or omission
of the defendant:
a. has been placed beyond the jurisdiction of the court;
b. has been substantially diminished in value; or
c. has been commingled with other property which cannot be divided
without difficulty,

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the United States of America shall be entitled to forfeiture of substitute property pursuant to Title
21, United States Code, § 853(p), as incorporated by Title 18, United States Code, §
2253(b) and by Title 28, United States Code, § 2461(c).
18 U.S.C. § 2253; F.R.Crim.P. 32.2(a)

____________________________________
ROD J. ROSENSTEIN
UNITED STATES ATTORNEY
A TRUE BILL:

_______________________
Foreperson

_______________________
Date

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