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Amateur Action BBS Indictment


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Computer underground Digest Tue June 14, 1994 Volume 6 : Issue 53
ISSN 1004-042X

Editors: Jim Thomas and Gordon Meyer ([email protected])
Archivist: Brendan Kehoe
Retiring Shadow Archivist: Stanton McCandlish
Shadow-Archivists: Dan Carosone / Paul Southworth
Ralph Sims / Jyrki Kuoppala
Ian Dickinson
Copy Dittoer: Etaoian Shrdlu

CONTENTS, #6.53 (Tue, June 14, 1994)

File 1--Amateur Action BBS Indictment

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----------------------------------------------------------------------

Date: Tue, 07 Jun 94 17:11 CDT
From: [email protected]
Subject: File 1--Amateur Action BBS Indictment

***WARNING: THE TEXT OF THE FOLLOWING INDICTMENT CONTAINS GRAPHIC
AND EXPLICIT DESCRIPTIONS OF SEX ACTS THAT SOME MAY FIND
OFFENSIVE***

((MODERATORS' NOTE: As we reported in CuD #6.35 and previously,
Amateur Action BBS in California has been the target of law
enforcement activity for several years. When a local raid failed to
produce anything illegal on the board, the US Postal Service ran what
has been described as a sting/entrapment ploy to charge the sysop,
Robert Thomas, with crimes that--while not violating California laws,
allegedly violate Tennessee statutes.

The allegations raise questions of obscenity and child pornography.
Because of their nature, such charges often fail to generate public
awareness, let alone sympathy. However, as reported earlier, the
issues in this case bear directly on First Amendment rights in
cyberspace. One of the most important issues is: Can a file or image
that is legal in one area of the US be subject to federal prosecution
because it might violate statutes in another area? Does the fact that
a person with a modem in Tennessee can transport files from a system
in California subject the California source to federal prosecution,
even though those operating the California system were not themselves
responsible for transfering files into Tennessee? The Amateur Action
BBS case raises many questions about judicial procedures, but the most
disturbing issue is this: If the prosecution is successful, it could
set a precedent in which freedom of speech is subverted on the Nets by
establishing as a standard the most restrictive criteria in a given
jurisdiction and making it the de facto national standard).

I thought the folks who read alt.sex.* and the other places where this
story has been posted might be interested in what an indictment for
50-60 years of jail time and a 2-3 million dollar fine looks like.
Such a sensible use of tax money, and law enforcement effort! (Hope
you all feel safer now.)

The thing which *really* steams me is that stuff on which the kiddy
porn count (11) is based was described by the postal inspector at the
time of the search as "sent without his (the sysop's) knowledge."
Furthermore, the same postal inspector told me that sending folks
unsolicited kiddy porn was "ordinary investigative procedure."

I have not bothered to look at the GIFs. They are still posted on the
BBS. Nobody has requested that they be made unavailable even to the
(unsophisticated?) people of western Tennessee. I do know that
descriptions of these things are "enhanced" (in such matters as
relations) to or beyond the limits of the possible. They are, after
all, fantasy.

This is a rough scan job. The copy I have is not that good, my
scanner is not the best at picking up this stuff, and I only spent a
few hours fixing the errors. Sorry, but I just can't take more time.

You might note the large amount of space they devoted to the forfeit
count. I wonder how much a chance to acquire the spiffy hardware
drove the whole investigation.

---Keith Henson

===========================================================

IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF TENNESSEE
WESTERN DIVISION

*
UNITED STATES OF AMERICA,
*
Plaintiff,
*
vs. Criminal No.____________
* 18 USC s 2
18 USC S 371
ROBERT ALAN THOMAS and * 18 USC s 1462
CARLEEN THOMAS, 18 USC s 1465
* 18 USC S 1467
Defendants. 18 USC s 2252(a)(1)
* 18 USC S 2256

I N D I C T M E N T

THE GRAND JURY CHARGES:
COUNT 1
1. Beginning at a date unknown to the Grand Jury, but at
least in or about February, 1991, and continuing thereafter until
on or about the date of this Indictment, in the Western District of
Tennessee, and elsewhere, the defendants,
---------------------- ROBERT ALAN THOMAS -------------------------
------------------------------ and --------------------------------
------------------------ CARLEEN THOMAS---------------------------
did knowingly and wilfully combine, conspire, confederate and agree
with each other and with other persons unknown to the Grand Jury,
to commit certain offenses against the United States of America,
that is:
(a) to knowingly use and caused to be used an express company
and common carrier, that is, United Parcel Service (UPS), for

1

carriage in interstate commerce, obscene video cassette tapes; in
violation of Title 18, United States Code, Section 1462;
(b) to knowingly use and caused to be used a facility and
means of interstate commerce, that is a combined computer/telephone
system, for the purpose of transporting obscene material in
interstate commerce; said obscene material being computer-generated
images, referred to as a Graphics Interchange Format ("GIF") files;
in violation of Title 18, United States Code, Section 1465.

FORM AND SUBSTANCE OF THE CONSPIRACY
2. It was a part of the conspiracy that, in or about
February, 1991, the defendants would establish a "computer bulletin
board" at their residence, 475 Tramway Drive, Milpitas, California,
using the name "Amateur Action Bulletin Board System" (AABBS).
3. It was further a part of the conspiracy that the
defendants would utilize a "mail drop" service known as Mail Boxes,
Etc., U.S.A., and 142 North Milpitas Blvd. #284, Milpitas,
California 95035, as the business address for Amateur Action
Bulletin Board System.
4, It was a further part of the conspiracy that the
defendants would utilize interstate telephone services in
conducting their computer bulletin board system, using specific
telephone numbers including (408) 263--3393 and (408) 263-3396.
5, It was a further part of the conspiracy that the
defendants, through the use of their computer bulletin board, would
advertise and sell obscene video cassette tapes and obscene

2

computer-generated images known as Graphics Interchange Format
(GIF) files to members of the public, nationwide.
6. It was a further part of the conspiracy that the
defendants would utilize an express company and common carrier,
that is United Parcel Service (UPS), to distribute their obscene
video cassette tapes to members of the public, nationwide.

7. Defendants generally used the following method of
operation in conducting their computer bulletin board (AABBS)
business with members of the public:
Defendants had multiple computers and 'modems at their
residence in Milpitas, California. A modem' is a device which
allows the transmission and receipt of computerized data,
interstate, over telephone lines between computers. Such
transmissions are known as uploads' by the computer sending the
data, and "downloads" by the computer receiving the data. Through
the use of a "modem" any person who also had a computer could
"connect" their computer with defendants computer by dialing
defendants' business telephone number and logging on to
defendants' system. Once ' logged on to defendant s computer
system a person could review advertisements, membership
application requirements, and other information on defendants
computer. Once obtaining membership and an individual password, a
person could, additionally, 'download Graphics Interchange Format
(GIF) files to his/her own computer, purchase video cassette tapes,

3

magazines, and "GIF Packs" and, if the defendants desired, have a
one-to-one computer conversation with the defendants through
defendants' use of the "chat" mode.
To obtain membership to defendants' business (AABBS), a person
had to complete an application and send a specified sum of money to
defendants. Defendants also allowed immediate membership to AABBS
if the person provided credit card information (Master Card or
Visa). For approximately $55.00, a person was entitled to a six-
month access to defendants' computer, with a 1.2 "megabyte"
download limit and a time limit of ninety (90) minutes per day.
For approximately $99.00, a person was entitled to a one-year
access to defendants' computer, with the same download and time
limits as the six-month membership.

OBJECT OF THE CONSPIRACY
8. It was a principal object of the conspiracy to carry out
and execute the abovesaid business, involving distribution of
obscene material, utilizing the computer bulletin board system, for
the ultimate personal gain, benefit, profit, advantage and
accommodation of the defendants and their co-conspirators.

OVERT ACTS
9 At all times hereinafter mentioned, during the pendency
of the conspiracy, the following overt acts were engaged in, at
least one of which furthered and effected the goals of said
combination, conspiracy, confederation and agreement:

4

(a) Between in or about February, 1991, and the date of this
Indictment, defendant made deposits to a checking account
(No.0098803083) styled "ROBERT A. THOMAS" with the Bank of America,
Milpitas, California.

(b) On or about February 18, 1991, defendant ROBERT
THOMAS signed a "Mailbox Service Agreement" with Mail Boxes Etc.,
U.S.A., 142 North Milpitas Blvd., Milpitas, California 95035.

© On or about October 10, 1991, defendant ROBERT
THOMAS opened a merchant account (No.4616510-1420-4937) with Peach
Tree Bancard corporation, 2001 Butterfield Rd., Downers Grove,
Illinois 60515.

All in violation of Title 18, United States Code, Section 371.

[nmt 5 yrs. or $250,000, or both,
not more than 3 yrs. supervised
release; together with a special
assessment of $50, see 18 U.S.C.
S3013(a))


COUNT 2

on or about september 3, 1993, in the Western District of

Tennessee, and elsewhere, the defendants
---------------------- ROBERT ALAN THOMAS -------------------------
------------------------------ and --------------------------------
------------------------ CARLEEN THOMAS---------------------------
knowingly used and caused to be used a facility and means of
interstate commerce, that is a combined computer/telephone system,
for the purpose of transporting obscene material in interstate
commerce from the State of California to the Western District of
the State of Tennessee; said obscene material being (1) a computer-

5

generated image referred to as a Graphics Interchange Format
("GIF") file entitled "AA-122O9.GIF" and more particularly
describe as "HE FUCKS A PIG! SHE FUCKS A DOG AND A HUGE PIG!
KINKY", (2) a computer-generated image, referred to as a Graphics
Interchange Format ("GIF") file, entitled "AA-122l7 GIF" and more
particularly Described as "KINKY! HORNY GIRLS SUCK HORSES! BIG
HORSE COCK IN HER TWAT!", and (3) a computer-generated image
referred to as a Graphics Interchange Format ("GIF'!) file, entitled
"AA-8589.GIF" and more particularly described as "SHE SUCKS HER
SON'S COCK! FATHER IS FUCKING HIS DAUGHTER !" in violation Of
Title l8, United States Code, Section 1465 and 2.

[nmt 5yrs, or $250,000, or both,
not more than 3 yrs, supervised
releasee together with a special
assessment of $50, see l8 U.S.C.
S 3O13(a)


COUNT 3

On or about September 7, 1993, in the Western District of
Tennessee, and elsewhere, the defendants,
---------------------- ROBERT ALAN THOMAS -------------------------
------------------------------ and --------------------------------
------------------------ CARLEEN THOMAS---------------------------
knowingly used and caused to be used a facility and means of
interstate commerce, that is a combined computer/telephone system,
for the purpose of transporting obscene material in interstate
commerce from the State of California to the Western District of
the State of Tennessee; said obscene material being (l) a computer-
generated image, referred to as a Graphics Interchange Format

6

("GIF") file, entitled "AA-8278.GIF" and more particularly
described as "FULL SCREEN VIEW! A HAIRLESS PUSSY NAILED TO A
TABLE!", (2) a computer-generated image, referred to as a Graphics
Interchange Format ("GIF") file, entitled "AA-7153.GIF" and more
particularly described as "MOTHER IS WATCHING HER DAUGHTER FUCK BIG
COCK! NO TITS!" (3) a computer-generated image, referred to as a
Graphics Interchange Format ("GIF") file, entitled "AA-8682.GIF"
and more particularly described as "HE MAKES HIS DAUGHTER SUCK
COCK! SHE IS FISTING HER SISTER!", and (4) a computer-generated
image, referred to as a Graphics Interchange Format ("GIF") file,
entitled "AA-11935.GIF" and more particularly described as "HE
FUCKS HIS DAUGHTERS HAIRLESS CUNT!" SHE FISTS HER MOTHER!" in
violation of Title 18, United States Code, Sections 1465 and 2.

[nmt 5 yrs. or $250,000, or both,
not more than 3 yrs. supervised
release; together with a special
assessment of $50, see 18 U.S.C.
S30@3(a))


COUNT 4

On or about September 8, 1993, in the Western District of
Tennessee, and elsewhere, the defendants,
---------------------- ROBERT ALAN THOMAS -------------------------
------------------------------ and --------------------------------
------------------------ CARLEEN THOMAS---------------------------
knowingly used and caused to be used a facility and means of
interstate commerce, that is a combined computer/telephone system,
or the purpose of transporting obscene material in interstate
commerce from the State of California to the Western District of

7

the State of Tennessee; said obscene material being a computer-
generated image, referred to as a Graphics Interchange Format
( "GIF" ) file, entitled "AA-15198. GIF" and more particularly
described as "BLONDE LOLITA HAS NO TITS! SUCKS HUGE COCK AND
DRINKS SPERM! "; in violation of Title 18, United States Code,
Sections 1465 and 2.

[nmt 5 yrs. or $250,000, or both,
not more than 3 yrs. supervised
release; together with a special
assessment of $50, see 18 U.S.C.
S3013 (a) )


COUNT 5

On or about September 13, 1993, in the Western District of
Tennessee, and elsewhere, the defendants,
---------------------- ROBERT ALAN THOMAS -------------------------
------------------------------ and --------------------------------
------------------------ CARLEEN THOMAS---------------------------
knowingly used and caused to be used a facility and means of
interstate commerce, that is a combined computer/telephone system,
for the purpose of transporting obscene material in interstate
commerce from the State of California to the Western District of
the State of Tennessee; said obscene material being a computer-
generated image, referred to as a Graphics Interchange Format
("GiF") file, entitled "AA-13216.GIF" and more particularly
described as "PUSSY PENETRATION! HORNY BRUNETTE GETS FUCKED BY A

8

HORSE!"; in violation of Title 18, United States Code, Sections
1465 and 2.

[nmt 5 yrs. or $250,000, or both,
not more than 3 yrs. supervised
release; together with a special
assessment of $50, see 18 U.S.C.
S3013(a)]


COUNT 6

On or about October 14, 1993, in the Western District of
Tennessee, and elsewhere, the defendants,

---------------------- ROBERT ALAN THOMAS -------------------------
------------------------------ and --------------------------------
------------------------ CARLEEN THOMAS---------------------------
knowingly used and caused to be used a facility and means of
interstate commerce, that is a combined computer/telephone system,
for the purpose of transporting obscene material in interstate
commerce from the State of California to the Western District of
the State of Tennessee; said obscene material being 1) a computer-
generated image, referred to as a Graphics Interchange Format
"GIF"') file, entitled "AA-13517.GIF'" and more particularly
described as "HORNY BLONDE JACKS OFF HORSE! HORSE CUM ON HER
HANDS!"', 2 ) a computer-generated image, referred to as a Graphics
interchange Format "GIF" ) file, entitled
"'AA-13521.GIF " and more
particularly described as "CLOSE-UP! BIG HORSE COCK IN HER CUNT!
HORSE CUM ON HER LEG" and (3) a computer-generated image, referred
to as a Graphics Interchange Format "GIF") file, entitled "AA-
16587.GIF" and more particularly described as "'SHE SUCKS THICK DOG

9

COCK! DOG SPERM ON HER LIPS AND CHIN."; in violation of Title 18,
United States Code, Sections 1465 and 2.

[nmt 5 yrs. or $250,000, or both,
not more than 3 yrs. supervised
release; together with a special
assessment of $50, see 18 U.S.C.
S3013(a)]

COUNT 7

On or about October 19, 1993, in the Western District of
Tennessee, and elsewhere, the defendants,
---------------------- ROBERT ALAN THOMAS -------------------------
------------------------------ and --------------------------------
------------------------ CARLEEN THOMAS---------------------------
knowingly used and caused to be used a facility and means of
interstate commerce, that is a combined computer/telephone system,
for the purpose of transporting obscene material in interstate
commerce from the State of California to the Western District of
the State of Tennessee; said obscene material being a computer-
generated image, referred to as a Graphics Interchange Format
("GIF") file, entitled "AA-17623.GIF" and more particularly
described as "YOUNG ASIAN HAS A THICK CLIT! DRINKS PISS FROM AN
UNCUT COCK!"; in violation of Title 18, United States Code,
Sections 1465 and 2.

[nmt 5 yrs. or $250,000, or both,
not more than 3 yrs. supervised
release; together with a special
assessment of $50, see 18 U.S.C.
S30i3(a)]

10

COUNT 8

Between in or about August 27, 1993, and on or about September
17, 1993, in the Western District of Tennessee, and elsewhere, the
defendants,
---------------------- ROBERT ALAN THOMAS -------------------------
------------------------------ and --------------------------------
------------------------ CARLEEN THOMAS---------------------------
knowingly used and caused to be used an express company and common
carrier, that is, United Parcel Service (UPS), for carriage in
interstate commerce from the State of California to the Western
district of the State of Tennessee, an obscene video cassette tape
(VHS format) entitled "K74" ; in violation of Title 18, United
States Code, Section 1462 and Section 2.

[nmt 5 yrs. or $250,000, or both,
not more than 3 yrs. supervised
release; together with a special
assessment of $50, see 18 V.S.C.
S3013(a)]


COUNT 9

Between in or about September 17, 1993, and on or about
October 10, 1993, in the Western District of Tennessee, and
elsewhere, the defendants,
---------------------- ROBERT ALAN THOMAS -------------------------
------------------------------ and --------------------------------
------------------------ CARLEEN THOMAS---------------------------
knowingly used and caused to be used an express company and common
carrier, that is, United Parcel Service (UPS), for carriage in
interstate commerce from the State of California to the Western
District of the State of Tennessee, obscene video cassette (apes,

11

that is, one (1) obscene video cassette tape (VHS format) entitled
"K17", one (1) obscene video cassette tape (VHS format) entitled
"K39", one (1) obscene video cassette tape (VHS format) entitled
"K40", and one (1) obscene video cassette tape (VHS format)
entitled "K47"; in violation of Title 18, United States Code,

Section 1462 and Section 2.

[nmt 5 yrs. or $250,000, or both,
not more than 3 yrs. supervised
release; together with a special
assessment of $50, see 18 U.S.C.
s3013(a)]

Count 10

Between on or about October 14, 1993, and on or about October
26, 1993, in the Western District of Tennessee, and elsewhere, the
defendants,
---------------------- ROBERT ALAN THOMAS -------------------------
------------------------------ and --------------------------------
------------------------ CARLEEN THOMAS---------------------------
knowingly used and caused to be used an express company and common
carrier, that is, United Parcel Service (UPS), for carriage in
interstate commerce from the State of California to the Western
District of the State of Tennessee, an obscene video cassette tape
(VHS format) entitled "A5" ; in violation of Title 18, United
States Code, Section 1462 and Section 2.

[nmt 5 yrs. or $250,000, or both,
not more than 3 yrs. supervised
release; together with a special
assessment of $50, see 18 U.S.C.
S3013(a)]


12

COUNT 11

Between on or about November 9, 1993, and on or about January
10, 1994, in the Western District of Tennessee, and elsewhere, the
defendant,
---------------------- ROBERT THOMAS -------------------------
knowingly caused to be transported and shipped in interstate
commerce by means of the United States Mail, visual depictions, the
production of which involved the use of a minor engaging in
sexually explicit conduct, as defined in Title 18, United States
Code, Section 2256, and the said visual depictions, (three (3)
magazines, bearing titles of "Little Girls Fuck Too!", "Lolita
Colour Special 6" and "Lolita Color Special 18", are of such
conduct; all in violation of Title 18, United States Code, Sections

2252(a)(I) and 2.

[nmt 10 yrs. or $250,000, or both,
not more than 3 yrs. supervised
release; together with a special
assessment of $50, see 18 U.S.C.
s3013(a)]


COUNT 12

FORFEITURE ALLEGATIONS

1. The allegations contained in Counts I through and
including 10 of this Indictment are incorporated by reference as if
fully set forth herein.

2. Upon conviction for violating Title 18, United States
Code, Section 1462 and Section 1465, the defendants, ROBERT ALAN
THOMAS and CARLEEN THOMAS, shall forfeit to the United States

13

(a) any obscene material produced, transported, mailed, shipped, or
received in violation of the abovesaid statutes; (b) any property,
real or personal, constituting or traceable to gross profits or
other proceeds obtained from the abovesaid offenses; and
© any property, real or personal, used or intended to be used to
commit or to promote the commission of the abovesaid offenses,
including but not limited to the following:

AI Generic mini-tower computer case containing the following
components:
486/66 MHz, 8 meg Mother Board with No Visible Serial Number (NVS).
Conner hard drive model CP30254H, serial #BM9A5R5.
Western Digital hard drive caviar 2120, serial #WT256014024.
AITCH scanner card serial #9204133.
Micro Tech serial port serial #1077324826.

ORCHID prodesigner 11 serial #108709.
ARTISOFT LAN card serial #0000026860.
TEAC 5.25 floppy drive serial #Q741028-
TEAC 3.25 floppy drive serial #N169923.
IDE Hard/Floppy disk controller serial #30037623.
Parallel port card serial #12H2TSX.
200W Power Supply serial #92270590.

A3 Generic mini-tower computer case containing the following
components:
486/66 MHz, 8 meg mother board serial #350192-02-0072.
Conner hard drive model CP301044, serial #AB9H768.

14

TEAC 5.25 floppy drive seria11##X544949,
TEAC 3.25 floppy drive seria11##F822088.
230w power supply serial ##0577558.
ARTISOFT LAN car serial #0000031886.
Modem card serial #41116688.
Diamond Computer Systems VGA card serial #100376.
IDE Hard/Floppy disk controller card serial #11784.

A8 Generic mini-tower computer case containing the following
components:
486/66 MHz mother board serial #30400960-AB4550F.
Conner hard drive model CP3o104H, serial #NcvFsz.
TEAC 5.25 floppy drive serial #R399738.
TEAC 3.25 floppy drive serial #E455874.
230w power supply serial #0676974.
DBI LAN card serial #000002884.
Modem Card serial #419116.
Diamond Computer Systems speed star VGA card serial #100374.
230w power Supply serial #0676974-
Hard/Floppy disk controller card with NVS'
Print card with NVS.

A9 Generic mini-tower computer case containing the following
components:
486/66 MHz mother board serial #A2092.
Conner hard drive model CP30254H, serial #BM9A5R5.

15

TEAc 5.25 floppy drive serial 3H881916.
TEAc 3.25 floppy drive serial #9178487YA.
ORCHID VGA card serial #052627.
DBI modem card serial #418366.
ARTISOFT LAN card 0000031885.
IDE Hard/Floppy disk controller card ES110075.

AIO Generic large tower case containing the following components:
g6 66 MHZ mother board, 8 meg aAM, AMI Bios chip #AA8402515.
Intel 4 /
Conner hard drive model cP3000, serial #E3ROBD.
TEAc 5.25 and 3.25 combination floppy drive serial #693213
ARTISOFT LAN card serial #NR0020743.
IDE hard/floppy disk controller card serial #117788.
60HZ/50HZ power supply with NVS.
Diamond computer Systems speed star pro VL super VGA card #1793.
DBI modem card serial #417728.

All Generic large tower case containing the following components
586/66 MHz mother board with NVS.
Micropolis hard drive model 1548-15 serial #1063812205.
Micropolis hard drive model 1908 serial #2012900077.
Micropolis hard drive model 1528-15 serial #3014681054.
Micropolis hard drive model 1598-15 serial #2063511102.
Micropolis hard drive model 1588 serial #1063555003.
TEAC 5.25 and 3.25 combination floppy drive serial #1152927.
Printer card with NVs.


16


ARTISOFT LAN card NR0020742.
SCCI hard/floppy disk controller card serial #B00686030.
Keypro keyboard serial #930309148.
Keypro keyboard serial #930309150.
Keypro keyboard serial #930309143.
Keypro keyboard serial #930309091.
Focus Electronic keyboard serial #1066735
Keyboard model RTIOI, serial #25896261.
Canon full color printer FP-510 serial #87121004.
Scanmaker microtek 1850 serial #S254401235.
BJS Data/FAX modem, scott plus/DSl serIal #4F50449.
Robotics Modem serial #0000930001226783.
Robotics Modem serial #0000930001226826.
Robotics Modem serial #0000930602012241.
Robotics Modem serial #0000930001226800.
Robotics Modem serial #0000930001226887.
Robotics Modem serial #0000930001226990.
Robotics Modem serial #0000930602011671.
Robotics Modem serial #0000930001226791.
Robotics Modem/Courier serial #0004470002948049.
Robotics Modem/Courier serial #0004470002997136.
Robotics Modem/Courier serial #0004470002996942.
Robotics Modem/Courier serial #0004470002996920.
Robotics Modem/Courier serial #0004470002947994.
Robotics Modem/Courier serial #0004470002997356.
Robotics Modem/Courier serial #0004470002948650.

17

Robotics modem/courier serial #0004470002948653.
Robotics modem/courier V.32 VIS serial #0066-30053021-050291.
Robotics modem/courier V.32 VIS serial #0066-30053022-050291.
Robotics Modem/Courier V.32 VIS serial #000661601200160.
Robotics Modem/Courier V.32 VIS serial #0066-16044914-020791.
Robotics Modem(Courier V.32 VIS serial #0066-16045973-030191.
Robotics Modem/Courier V.32 VIS serial #0066-16052337-050191.
Robotics Modem/Courier V.32 VIS serial #0066-16044692-020591.
Robotics Modem/Courier V.32 VIS serial #0066-16062421-082191.
Robotics Modem/Courier V.32 VIS serial #0066-30075067-012192.
Robotics Modem/Courier V.32 VIS serial #0000661601200138.
Robotics Modem/Courier V.32 VIS serial #0000661600840265.
Robotics Modem/Courier V.32 VIS serial #0000661600840254.
Robotics Modem/Courier V.32 VIS serial #0000661600840263.
Robotics Modem/Courier V.32 VIS serial #0000661600840262.
Robotics Modem/Courier V.32 VIS serial #0066-3006993-102891.
Robotics Modem/Courier V.32 VIS serial #0066-16057489-071191.
HP LaserJet 4P serial #L10293A.
HP ScanJet 2C serial #3265A25214.
Seiko monitor model CM1450 serial #15M5129A.
EYEQ monitor model 214S serial #109337806.
Northman monitor model WM12HC serial #1V0141500.
Panasonic portable VCR/monitor model PVM749, serial #BOSABOOII
Battery pack/adaptor for VCR/monitor serial #BOSABOOII.
Microsoft mouse 0665797.
Computer cabinet keys.

18

All pursuant to Title 18, United States Code, Section 1467.

[nmt 5 yrs. or $250,000, or both,
not more than 3 yrs. superVised
release; together with a special
assessment of $50, see 18 U.S.C.
S3013(a)]

A TRUE BILL:



F 0 R E P E R S 0 N



UNITED STATES ATTORNEY

DATE





19

------------------------------

End of Computer Underground Digest #6.53
************************************



 
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