kamala d. harris attorney general of california · pdf filecomplaint [felony] plaintiff, v....
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KAMALA D HARRIS
Attorney General of California TAWNYA AUSTIN F DF
I I lj
I
Deputy Attorney General State Bar No 198663
110 West A Street Suite 1100 San Diego CA 921 01 PO Box 85266 San Diego CA 92186-5266 Telephone (619) 645-2823 Fax (619) 645-2489 E-mail TawnyaAustindojcagov
Attorneysfor People ofthe State ofCal[(ornia
SUPERIOR COURT OF THE STATE OF CALIFORNIA
SAN DIEGO SUPER10R COURT
THE PEOPLE OF THE STATE OF Case No CALIFORNIA
COMPLAINT [FELONY] Plaintiff
v
KEVIN CHRISTOPHER BOLLAERT (DOB 6271986)
Defendant
The Attorney General of the State of California hereby accuses Kevin BOLLAERT of the
following criminal offenses
Countl
In and between December 2 2013 and September 17 2013 in the County of San Diego the
crime of Conspiracy in v iolation of Penal Code section 182 (a)() a felony was committed by
Kevin BOLLAERT who did unlawfully conspire together with another person and persons
whose identity is unknown to commit the crime of Identity Theft in violation of Penal Code
Complaint [Felony)
section 5305 a fel ony that pursuant to and for the purpose of carrying out the objectives and
2 purposes of the aforesaid conspiracy that Kevin BOLLAERT and others committed the
3 following overt acts at and in the County of San Diego overt act(s)
4 Overt Act 1
5 Between December 2 20 12 and September 17 2013 Kevin BOLLAERT was the
6 administrator of a websi te called ugotpostedcom
7 Over Act 2
8 Between December 2 2012 and September 172013 Kevin BOLLAERT with the
9 assistance of known a nd unknown conspirators posted Ten Thousand One Hundred Seventy
I 0 (I 0 170) private photographs containing nude and ex plicit images of individuals who did not give
11 permission for their private images to be posted online
12 Overt Act 3
13 Between December 2 2 012 and September 172013 Kevin BOLLAERT posted the
14 personal identi fying informat ion of over ten th ousand individuals in conjunction with pri vate
15 images of those individuals without their permi ssion
16 Overt Act 4
17 On July 122013 Kevin BOLLAERT failed to rem ove images of Jane Doe 6 following
18 the receipt of an email from Jane Doe 6 stating that due to private images of her a long with her
19 personal identifying information being posted on ugotpostedcom she was scared for my life
20 Peop le are calling my work p lace and they obta ined the information from thi s site I did not give
21 permission for anyone to put up those pictures or my personal information I have contacted the
22 police but these pictures need to come down Pl ease
23 Overt Act 5
24 On July 17 2013 Kevin BOLLAERT fai led to remove images of Jane Doe 8 fo llowing
25 the receipt of an email from Jane Doe 8 requesting h er private information and images be taken
26 down from ugotposted co m stating she was getting nonstop harassing messages
27
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Comp laint [Felony]
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Overt Act 6
Between June 20 2013 and August 26 2013 Kevin BOLLAERT received and reviewed
over 2000 emails from individuals requesting their personal identifying information and images
be removed from ugotpostedcom
Overt Act 7
In October of2012 Kevin BOLLAERT with the assistance of known and unknown
conspirators opened and updated an online account called changemyreputation com
Overt Act 8
Between December 2 2012 and September 17 2013 Kevin BOLLAERT collected in
excess of $1 OOOO(ten thousand dollars) via changemyreputationcom from individuals paying to
have the ir personal identifying information and images removed from ugotpostedcom
Count 2
On or about April4 2013 in the County of San Diego the crime ofldentity Theft in
vio lation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifying information of Jane Doe 1 and used that
informatio n for an unlawful purpose to wit to harass and annoy without the consent of Jane Doe
1
Count 3
On or about April4 2013 in the County of San Diego the crime ofidentity Theft in
vio lation of Pe nal Code section 530 5(a) a felony was committed by Kevin BOLLAERT who
did willfu lly and unlawfully obtain personal identifying information of Jane Doe 1 and used that
information for an unlawful purpose and to obtain and attempt to obtain credit goods services
and money without the consent of Jane Doe 1
Count 4
On or about April4 2013 in the County of San Diego the crime ofExtortion in violation
of Penal Code Section 520 a felony was committed by Kevin BOLLAERT who extm1ed money
and or other property from Jane Doe 1 by means of threat such as is mentioned in Penal Code
Section 519 to wit to expose or to impute to her any disgrace or expose an y secret affecting her
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Complaint [Felon y]
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Count 5
On or about April 18 20 13 in the County of San Diego the crime ofldentity Theft in
vio lation of Penal Code section 5305(a) a fel ony was committed by Kevin BOLLAERT who
did willfully and unlawfull y obtain personal identifying information of Jane Doe 2 and used that
information for an unlawful pmpose to wit to harass and annoy without the consent of Jane Doe
2
Count 6
On or about Apri l 18 2013 in the County of San Diego the crime of Identity Theft in
violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfull y obtain personal identifying information of Jane Doe 2 and used that
information for an unlawful purpose and to obtain and attempt to o btain credit goods services
and money w ithout the consent of Jane Doe 2
Count 7
On or about April 18 2013 in the County of San Diego the crime of Extortion in violation of
Penal Code Section 520 a fe lony was committed by Kevin BOLLAERT who extorted money
and or other property from Jane Doe 2 by means of threat such as is mentioned in Penal Code
Section 519 to wit to expose or to impute to her any disgrace or expose any secret affecting her
CountS
On or about April 29 2013 in the County of San Diego the cr ime of Identity T heft in
violation of Penal Code section 5305(a) a felony was committed b y Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifying infonnation of Jane Doe 3 and used that
information for an unlawful purpose to wit to harass and annoy without the consent of Jane Doe
3
Count 9
On or about April 29 2013 in the County of San Di ego the crime ofidentity Theft in
v iolati on of Penal Code section 5305(a) a felony was com mitted by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifying information of Jane Doe 3 and used that
4
Complaint [Felony]
information for an unlawful purpose and to obtai n and attempt to obtain cred it goods serv ices
2 and money without the consent of Jane Doe 3
3 CountlO
4 On or about May 13 2013 in the County of San Diego the crime ofldentity Theft in
5 violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
6 did wi llfull y and unl awfu lly obtain persona l identifying information of Jane Doe 4 and used that
7 inform ation for an unlawful purpose to wit to harass and annoy without the consent of Jane Doe
8 4
9 Countll
1 0 On or about May 13 20 13 in the County of San Diego the crime of Identity Theft in
11 vio lation of Penal Code section 5305(a) a fel ony was committed by Kev in BOLLAERT who
12 did willfully and unlawfully obtain personal identify ing information of Jane Doe 4 and used that
13 information for an unlawful purpose and to obtai n and attempt to obtain credit goods services
14 and money without the consent of Jane Doc 4
15 Count 12
16 On or about J ul y 6 20 13 in the County of San Diego the crime ofldentity Theft in
17 violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
18 did willfully and unlawfully obtain personal identify ing information of Jane Doe 5 and used that
19 information for an unlawful purpose to wit to harass and annoy without the consent of Jane Doe
20 5
2 1 Cou nt 13
22 On or about July 6 20 13 in the County of San Diego the crime ofldentity Theft in
23 v iolati on of Penal Code section 5305(a) a fe lony was committed by Kevin BOLLAERT who
24 did w illfull y and unlawfully obta in personal identifying information of Jane Doe 5 and used that
25 information for an unlawful purpose and to obtain and attempt to obtain credit goods services
26 and money w ithout the consent of Jane Doe 5
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Complaint Felony]
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Count 14
On or abo ut Ju ly 122013 in the County of San Diego the crime ofldentity Theft in
violation of Penal Code section 5305(a) a felon y was committed by Kevin BOLLAERT who
did willfull y and unlawfully obtain personal identifying inform atio n of Jane Doe 6 and used that
informati on for an unlawful purpose to wit to harass and annoy without the consent of Jane Doe
6
Count IS
On or about Jul y 12 2013 in the County of San Diego the crime ofldentity Theft in
violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifying informatio n of Jane Doe 6 and used that
information for an unl awful purpo se and to obtain and attempt to obtain credit goods services
and money wi thout the consent of Jane Doe 6
Count 16
On or about July 16 2013 in the County of San Diego the crime of Identity Theft in
v iolation of Penal Code section 5305(a) a felon y was committed by Kevin BOLLAERT who
did willfully and unlawfull y obtain personal identifying info rmation of Jane Doe 7 and used that
information for an unl awful purpose to wit to harass and annoy without the consent of Jane Doe
7
Countl7
On or about Jul y 16 2013 in the County of San Diego the crime of Identity Theft in
violation ofPenal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifyi ng information of Jane Doe 7 and used that
information for an unl awful purpose and to obtain and attempt to obtain cred it goods services
and mone y without the co nsent of Jane Doe 7
Countl8
On or about August 4 2013 in the County of San Diego the crime of Identity Theft in
violation of Penal Code section 5305(a) a fel ony was committed by Kevin BOLLAERT who
did willfully and unl awfully obtain p ersonal identifying informati on of Jane Doe 8 and used that
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Complaint [Felony]
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information for an unlawful purpose to w it to harass and annoy without the consent of Jane Doe
8
Count19
On or about August 4 20 13 in the County of San Diego the crime of Identity Theft in
violati on of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willful ly and unlawfully obtain personal identifying informati on of Jane Doe 8 and used that
information for an unl awful purpose a nd to obtain and attempt to obtai n credit goods services
and money without the consent of Jane Doe 8
Count20
On or about A ugust 6 20 I 3 in the County of San Diego the c rime ofldentity Theft in
v iolation of Penal Code secti on 5305(a) a felony was committed by Kevin BOLLAERT who
did wi llfully and unlawfully obtain personal identify ing information of Jane Doc 9 and used that
information for an unlawful purpose to wit to harass and annoy without the consent of Jane Doe
9
Count21
On or about August 6 20 I 3 in the County of San Diego the crime o f Identity Theft in
v iolation of Penal Code section 5305(a) a fe lony was committed by Kevin BOLLAERT who
d id willfully and unlawfully obtain personal identifying informatio n of Jane Doc 9 and used that
information for an unl awful purpose and to obtain and attempt to obtain credit goods services
and money without the consent of Jane Doe 9
Count 22
On or abo ut August 13 20 I 3 in the County of San Diego the crime ofldentity Theft in
vio lation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfull y obtain personal identifying information of Jane Doe I 0 and used
that information for an unlawful purpose to w it to harass and annoy without the consent of Jane
Doe 1 0
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Complaint [Fe lony]
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Count 23
On or about August 13 2013 in the County of San Diego the crime of Identity Theft in
vio lation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifying informati on of Jane Doe 1 0 and used
that information for an unlawful purpose and to obtain and attempt to obtain credit goods
services and money without the consent of Jane Doe 1 0
Count 24
On or about August 26 2013 in the County of San Diego the crime ofldentity Theft in
v iolation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifying information of Jane Doe 11 and used
that information for an unlawfu l purpose to w it to harass and annoy without the consent of Jane
Doe 11
Count 25
On or about August 26 20 13 in the County of San Diego the crime of Identity Theft in
v iolation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifying information of Jane Doe II and used
that information for an unlawful purpose and to obtain and attempt to obtain credit goods
services and money without the consent of Jane Doe 1 1
Count 26
O n or about September 4 2013 in the County of San Diego the crime ofldentity Theft in
violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identify ing information of Jane Doe 12 and used
that informati on for an unlawful purpose to wit to harass and annoy without the consent of Jane
Doe 12
Count 27
On or ab out September 4 20 13 in the County of San Diego the crime of Identity Theft in
violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did will full y and unlawfully obtain personal identifying information of Jane Doe 12 and used
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Complaint [Felony]
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that information for an unlawful purpose and to obtain and attempt to obtain credit goods
2 services and money without the consent ofJane Doe 12
3 Count28
4 On or about September 10 2013 in the County of San Diego the crime of Identity Theft
in violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT
6 who did willfully and unlawfully obtain personal identifying information of Jane Doe 13 and
7 used that information for an unlawful purpose to wit to harass and annoy without the consent of
8 Jane Doe 13
9 Count 29
On or about September 10 2013 in the County of San Diego the crime of Identity Theft
11 in violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT
12 who did willfully and unlawfully obtain personal identifying information of Jane Doe 13 and
13 used that information for an unlawful purpose and to obtain and attempt to obtain credit goods
14 services and money without the consent of Jane Doe 13
Count 30
16 On or about September 12 2013 in the County or San Diego the crime of Identity Theft
17 in violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT
18 who did willfully and unlawfully obtain personal identifying information of Jane Doe 14 and
19 used that information for an unlawful purpose to wit to harass and annoy without the consent of
Jane Doe 14
21 Count31
22 On or about September 12 2013 in the County of San Diego the crime ofidentity Theft
23 in violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT
24 who did willfully and unlawfully obtain personal identifying information of Jane Doe14 and
used that information for an unlawful purpose and to obtain and attempt to obtain credit goods
26 services and money without the consent of Jane Doe14
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Complaint [Felony)
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Dated
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December 10 2013 Respectfully Submitted
KAMALA D HARRIS Attorney General of California
TAWNYA AUSTIN Deputy Attorney General Attorneysfor the People ofthe State of California
10
Complaint [Felony)
section 5305 a fel ony that pursuant to and for the purpose of carrying out the objectives and
2 purposes of the aforesaid conspiracy that Kevin BOLLAERT and others committed the
3 following overt acts at and in the County of San Diego overt act(s)
4 Overt Act 1
5 Between December 2 20 12 and September 17 2013 Kevin BOLLAERT was the
6 administrator of a websi te called ugotpostedcom
7 Over Act 2
8 Between December 2 2012 and September 172013 Kevin BOLLAERT with the
9 assistance of known a nd unknown conspirators posted Ten Thousand One Hundred Seventy
I 0 (I 0 170) private photographs containing nude and ex plicit images of individuals who did not give
11 permission for their private images to be posted online
12 Overt Act 3
13 Between December 2 2 012 and September 172013 Kevin BOLLAERT posted the
14 personal identi fying informat ion of over ten th ousand individuals in conjunction with pri vate
15 images of those individuals without their permi ssion
16 Overt Act 4
17 On July 122013 Kevin BOLLAERT failed to rem ove images of Jane Doe 6 following
18 the receipt of an email from Jane Doe 6 stating that due to private images of her a long with her
19 personal identifying information being posted on ugotpostedcom she was scared for my life
20 Peop le are calling my work p lace and they obta ined the information from thi s site I did not give
21 permission for anyone to put up those pictures or my personal information I have contacted the
22 police but these pictures need to come down Pl ease
23 Overt Act 5
24 On July 17 2013 Kevin BOLLAERT fai led to remove images of Jane Doe 8 fo llowing
25 the receipt of an email from Jane Doe 8 requesting h er private information and images be taken
26 down from ugotposted co m stating she was getting nonstop harassing messages
27
28 2
Comp laint [Felony]
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Overt Act 6
Between June 20 2013 and August 26 2013 Kevin BOLLAERT received and reviewed
over 2000 emails from individuals requesting their personal identifying information and images
be removed from ugotpostedcom
Overt Act 7
In October of2012 Kevin BOLLAERT with the assistance of known and unknown
conspirators opened and updated an online account called changemyreputation com
Overt Act 8
Between December 2 2012 and September 17 2013 Kevin BOLLAERT collected in
excess of $1 OOOO(ten thousand dollars) via changemyreputationcom from individuals paying to
have the ir personal identifying information and images removed from ugotpostedcom
Count 2
On or about April4 2013 in the County of San Diego the crime ofldentity Theft in
vio lation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifying information of Jane Doe 1 and used that
informatio n for an unlawful purpose to wit to harass and annoy without the consent of Jane Doe
1
Count 3
On or about April4 2013 in the County of San Diego the crime ofidentity Theft in
vio lation of Pe nal Code section 530 5(a) a felony was committed by Kevin BOLLAERT who
did willfu lly and unlawfully obtain personal identifying information of Jane Doe 1 and used that
information for an unlawful purpose and to obtain and attempt to obtain credit goods services
and money without the consent of Jane Doe 1
Count 4
On or about April4 2013 in the County of San Diego the crime ofExtortion in violation
of Penal Code Section 520 a felony was committed by Kevin BOLLAERT who extm1ed money
and or other property from Jane Doe 1 by means of threat such as is mentioned in Penal Code
Section 519 to wit to expose or to impute to her any disgrace or expose an y secret affecting her
3
Complaint [Felon y]
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Count 5
On or about April 18 20 13 in the County of San Diego the crime ofldentity Theft in
vio lation of Penal Code section 5305(a) a fel ony was committed by Kevin BOLLAERT who
did willfully and unlawfull y obtain personal identifying information of Jane Doe 2 and used that
information for an unlawful pmpose to wit to harass and annoy without the consent of Jane Doe
2
Count 6
On or about Apri l 18 2013 in the County of San Diego the crime of Identity Theft in
violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfull y obtain personal identifying information of Jane Doe 2 and used that
information for an unlawful purpose and to obtain and attempt to o btain credit goods services
and money w ithout the consent of Jane Doe 2
Count 7
On or about April 18 2013 in the County of San Diego the crime of Extortion in violation of
Penal Code Section 520 a fe lony was committed by Kevin BOLLAERT who extorted money
and or other property from Jane Doe 2 by means of threat such as is mentioned in Penal Code
Section 519 to wit to expose or to impute to her any disgrace or expose any secret affecting her
CountS
On or about April 29 2013 in the County of San Diego the cr ime of Identity T heft in
violation of Penal Code section 5305(a) a felony was committed b y Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifying infonnation of Jane Doe 3 and used that
information for an unlawful purpose to wit to harass and annoy without the consent of Jane Doe
3
Count 9
On or about April 29 2013 in the County of San Di ego the crime ofidentity Theft in
v iolati on of Penal Code section 5305(a) a felony was com mitted by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifying information of Jane Doe 3 and used that
4
Complaint [Felony]
information for an unlawful purpose and to obtai n and attempt to obtain cred it goods serv ices
2 and money without the consent of Jane Doe 3
3 CountlO
4 On or about May 13 2013 in the County of San Diego the crime ofldentity Theft in
5 violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
6 did wi llfull y and unl awfu lly obtain persona l identifying information of Jane Doe 4 and used that
7 inform ation for an unlawful purpose to wit to harass and annoy without the consent of Jane Doe
8 4
9 Countll
1 0 On or about May 13 20 13 in the County of San Diego the crime of Identity Theft in
11 vio lation of Penal Code section 5305(a) a fel ony was committed by Kev in BOLLAERT who
12 did willfully and unlawfully obtain personal identify ing information of Jane Doe 4 and used that
13 information for an unlawful purpose and to obtai n and attempt to obtain credit goods services
14 and money without the consent of Jane Doc 4
15 Count 12
16 On or about J ul y 6 20 13 in the County of San Diego the crime ofldentity Theft in
17 violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
18 did willfully and unlawfully obtain personal identify ing information of Jane Doe 5 and used that
19 information for an unlawful purpose to wit to harass and annoy without the consent of Jane Doe
20 5
2 1 Cou nt 13
22 On or about July 6 20 13 in the County of San Diego the crime ofldentity Theft in
23 v iolati on of Penal Code section 5305(a) a fe lony was committed by Kevin BOLLAERT who
24 did w illfull y and unlawfully obta in personal identifying information of Jane Doe 5 and used that
25 information for an unlawful purpose and to obtain and attempt to obtain credit goods services
26 and money w ithout the consent of Jane Doe 5
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Complaint Felony]
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Count 14
On or abo ut Ju ly 122013 in the County of San Diego the crime ofldentity Theft in
violation of Penal Code section 5305(a) a felon y was committed by Kevin BOLLAERT who
did willfull y and unlawfully obtain personal identifying inform atio n of Jane Doe 6 and used that
informati on for an unlawful purpose to wit to harass and annoy without the consent of Jane Doe
6
Count IS
On or about Jul y 12 2013 in the County of San Diego the crime ofldentity Theft in
violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifying informatio n of Jane Doe 6 and used that
information for an unl awful purpo se and to obtain and attempt to obtain credit goods services
and money wi thout the consent of Jane Doe 6
Count 16
On or about July 16 2013 in the County of San Diego the crime of Identity Theft in
v iolation of Penal Code section 5305(a) a felon y was committed by Kevin BOLLAERT who
did willfully and unlawfull y obtain personal identifying info rmation of Jane Doe 7 and used that
information for an unl awful purpose to wit to harass and annoy without the consent of Jane Doe
7
Countl7
On or about Jul y 16 2013 in the County of San Diego the crime of Identity Theft in
violation ofPenal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifyi ng information of Jane Doe 7 and used that
information for an unl awful purpose and to obtain and attempt to obtain cred it goods services
and mone y without the co nsent of Jane Doe 7
Countl8
On or about August 4 2013 in the County of San Diego the crime of Identity Theft in
violation of Penal Code section 5305(a) a fel ony was committed by Kevin BOLLAERT who
did willfully and unl awfully obtain p ersonal identifying informati on of Jane Doe 8 and used that
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Complaint [Felony]
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information for an unlawful purpose to w it to harass and annoy without the consent of Jane Doe
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Count19
On or about August 4 20 13 in the County of San Diego the crime of Identity Theft in
violati on of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willful ly and unlawfully obtain personal identifying informati on of Jane Doe 8 and used that
information for an unl awful purpose a nd to obtain and attempt to obtai n credit goods services
and money without the consent of Jane Doe 8
Count20
On or about A ugust 6 20 I 3 in the County of San Diego the c rime ofldentity Theft in
v iolation of Penal Code secti on 5305(a) a felony was committed by Kevin BOLLAERT who
did wi llfully and unlawfully obtain personal identify ing information of Jane Doc 9 and used that
information for an unlawful purpose to wit to harass and annoy without the consent of Jane Doe
9
Count21
On or about August 6 20 I 3 in the County of San Diego the crime o f Identity Theft in
v iolation of Penal Code section 5305(a) a fe lony was committed by Kevin BOLLAERT who
d id willfully and unlawfully obtain personal identifying informatio n of Jane Doc 9 and used that
information for an unl awful purpose and to obtain and attempt to obtain credit goods services
and money without the consent of Jane Doe 9
Count 22
On or abo ut August 13 20 I 3 in the County of San Diego the crime ofldentity Theft in
vio lation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfull y obtain personal identifying information of Jane Doe I 0 and used
that information for an unlawful purpose to w it to harass and annoy without the consent of Jane
Doe 1 0
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Complaint [Fe lony]
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Count 23
On or about August 13 2013 in the County of San Diego the crime of Identity Theft in
vio lation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifying informati on of Jane Doe 1 0 and used
that information for an unlawful purpose and to obtain and attempt to obtain credit goods
services and money without the consent of Jane Doe 1 0
Count 24
On or about August 26 2013 in the County of San Diego the crime ofldentity Theft in
v iolation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifying information of Jane Doe 11 and used
that information for an unlawfu l purpose to w it to harass and annoy without the consent of Jane
Doe 11
Count 25
On or about August 26 20 13 in the County of San Diego the crime of Identity Theft in
v iolation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifying information of Jane Doe II and used
that information for an unlawful purpose and to obtain and attempt to obtain credit goods
services and money without the consent of Jane Doe 1 1
Count 26
O n or about September 4 2013 in the County of San Diego the crime ofldentity Theft in
violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identify ing information of Jane Doe 12 and used
that informati on for an unlawful purpose to wit to harass and annoy without the consent of Jane
Doe 12
Count 27
On or ab out September 4 20 13 in the County of San Diego the crime of Identity Theft in
violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did will full y and unlawfully obtain personal identifying information of Jane Doe 12 and used
8
Complaint [Felony]
5
10
15
20
25
that information for an unlawful purpose and to obtain and attempt to obtain credit goods
2 services and money without the consent ofJane Doe 12
3 Count28
4 On or about September 10 2013 in the County of San Diego the crime of Identity Theft
in violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT
6 who did willfully and unlawfully obtain personal identifying information of Jane Doe 13 and
7 used that information for an unlawful purpose to wit to harass and annoy without the consent of
8 Jane Doe 13
9 Count 29
On or about September 10 2013 in the County of San Diego the crime of Identity Theft
11 in violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT
12 who did willfully and unlawfully obtain personal identifying information of Jane Doe 13 and
13 used that information for an unlawful purpose and to obtain and attempt to obtain credit goods
14 services and money without the consent of Jane Doe 13
Count 30
16 On or about September 12 2013 in the County or San Diego the crime of Identity Theft
17 in violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT
18 who did willfully and unlawfully obtain personal identifying information of Jane Doe 14 and
19 used that information for an unlawful purpose to wit to harass and annoy without the consent of
Jane Doe 14
21 Count31
22 On or about September 12 2013 in the County of San Diego the crime ofidentity Theft
23 in violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT
24 who did willfully and unlawfully obtain personal identifying information of Jane Doe14 and
used that information for an unlawful purpose and to obtain and attempt to obtain credit goods
26 services and money without the consent of Jane Doe14
27
28
9
Complaint [Felony)
5
10
15
20
25
Dated
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
22
23
24
26
27
28
December 10 2013 Respectfully Submitted
KAMALA D HARRIS Attorney General of California
TAWNYA AUSTIN Deputy Attorney General Attorneysfor the People ofthe State of California
10
Complaint [Felony)
2
3
4
5
6
7
8
9
I 0
11
12
13
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Overt Act 6
Between June 20 2013 and August 26 2013 Kevin BOLLAERT received and reviewed
over 2000 emails from individuals requesting their personal identifying information and images
be removed from ugotpostedcom
Overt Act 7
In October of2012 Kevin BOLLAERT with the assistance of known and unknown
conspirators opened and updated an online account called changemyreputation com
Overt Act 8
Between December 2 2012 and September 17 2013 Kevin BOLLAERT collected in
excess of $1 OOOO(ten thousand dollars) via changemyreputationcom from individuals paying to
have the ir personal identifying information and images removed from ugotpostedcom
Count 2
On or about April4 2013 in the County of San Diego the crime ofldentity Theft in
vio lation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifying information of Jane Doe 1 and used that
informatio n for an unlawful purpose to wit to harass and annoy without the consent of Jane Doe
1
Count 3
On or about April4 2013 in the County of San Diego the crime ofidentity Theft in
vio lation of Pe nal Code section 530 5(a) a felony was committed by Kevin BOLLAERT who
did willfu lly and unlawfully obtain personal identifying information of Jane Doe 1 and used that
information for an unlawful purpose and to obtain and attempt to obtain credit goods services
and money without the consent of Jane Doe 1
Count 4
On or about April4 2013 in the County of San Diego the crime ofExtortion in violation
of Penal Code Section 520 a felony was committed by Kevin BOLLAERT who extm1ed money
and or other property from Jane Doe 1 by means of threat such as is mentioned in Penal Code
Section 519 to wit to expose or to impute to her any disgrace or expose an y secret affecting her
3
Complaint [Felon y]
5
10
15
20
25
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
22
23
24
26
27
28
Count 5
On or about April 18 20 13 in the County of San Diego the crime ofldentity Theft in
vio lation of Penal Code section 5305(a) a fel ony was committed by Kevin BOLLAERT who
did willfully and unlawfull y obtain personal identifying information of Jane Doe 2 and used that
information for an unlawful pmpose to wit to harass and annoy without the consent of Jane Doe
2
Count 6
On or about Apri l 18 2013 in the County of San Diego the crime of Identity Theft in
violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfull y obtain personal identifying information of Jane Doe 2 and used that
information for an unlawful purpose and to obtain and attempt to o btain credit goods services
and money w ithout the consent of Jane Doe 2
Count 7
On or about April 18 2013 in the County of San Diego the crime of Extortion in violation of
Penal Code Section 520 a fe lony was committed by Kevin BOLLAERT who extorted money
and or other property from Jane Doe 2 by means of threat such as is mentioned in Penal Code
Section 519 to wit to expose or to impute to her any disgrace or expose any secret affecting her
CountS
On or about April 29 2013 in the County of San Diego the cr ime of Identity T heft in
violation of Penal Code section 5305(a) a felony was committed b y Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifying infonnation of Jane Doe 3 and used that
information for an unlawful purpose to wit to harass and annoy without the consent of Jane Doe
3
Count 9
On or about April 29 2013 in the County of San Di ego the crime ofidentity Theft in
v iolati on of Penal Code section 5305(a) a felony was com mitted by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifying information of Jane Doe 3 and used that
4
Complaint [Felony]
information for an unlawful purpose and to obtai n and attempt to obtain cred it goods serv ices
2 and money without the consent of Jane Doe 3
3 CountlO
4 On or about May 13 2013 in the County of San Diego the crime ofldentity Theft in
5 violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
6 did wi llfull y and unl awfu lly obtain persona l identifying information of Jane Doe 4 and used that
7 inform ation for an unlawful purpose to wit to harass and annoy without the consent of Jane Doe
8 4
9 Countll
1 0 On or about May 13 20 13 in the County of San Diego the crime of Identity Theft in
11 vio lation of Penal Code section 5305(a) a fel ony was committed by Kev in BOLLAERT who
12 did willfully and unlawfully obtain personal identify ing information of Jane Doe 4 and used that
13 information for an unlawful purpose and to obtai n and attempt to obtain credit goods services
14 and money without the consent of Jane Doc 4
15 Count 12
16 On or about J ul y 6 20 13 in the County of San Diego the crime ofldentity Theft in
17 violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
18 did willfully and unlawfully obtain personal identify ing information of Jane Doe 5 and used that
19 information for an unlawful purpose to wit to harass and annoy without the consent of Jane Doe
20 5
2 1 Cou nt 13
22 On or about July 6 20 13 in the County of San Diego the crime ofldentity Theft in
23 v iolati on of Penal Code section 5305(a) a fe lony was committed by Kevin BOLLAERT who
24 did w illfull y and unlawfully obta in personal identifying information of Jane Doe 5 and used that
25 information for an unlawful purpose and to obtain and attempt to obtain credit goods services
26 and money w ithout the consent of Jane Doe 5
27
28
5
Complaint Felony]
2
3
4
5
6
7
8
9
1 0
11
I 2
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Count 14
On or abo ut Ju ly 122013 in the County of San Diego the crime ofldentity Theft in
violation of Penal Code section 5305(a) a felon y was committed by Kevin BOLLAERT who
did willfull y and unlawfully obtain personal identifying inform atio n of Jane Doe 6 and used that
informati on for an unlawful purpose to wit to harass and annoy without the consent of Jane Doe
6
Count IS
On or about Jul y 12 2013 in the County of San Diego the crime ofldentity Theft in
violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifying informatio n of Jane Doe 6 and used that
information for an unl awful purpo se and to obtain and attempt to obtain credit goods services
and money wi thout the consent of Jane Doe 6
Count 16
On or about July 16 2013 in the County of San Diego the crime of Identity Theft in
v iolation of Penal Code section 5305(a) a felon y was committed by Kevin BOLLAERT who
did willfully and unlawfull y obtain personal identifying info rmation of Jane Doe 7 and used that
information for an unl awful purpose to wit to harass and annoy without the consent of Jane Doe
7
Countl7
On or about Jul y 16 2013 in the County of San Diego the crime of Identity Theft in
violation ofPenal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifyi ng information of Jane Doe 7 and used that
information for an unl awful purpose and to obtain and attempt to obtain cred it goods services
and mone y without the co nsent of Jane Doe 7
Countl8
On or about August 4 2013 in the County of San Diego the crime of Identity Theft in
violation of Penal Code section 5305(a) a fel ony was committed by Kevin BOLLAERT who
did willfully and unl awfully obtain p ersonal identifying informati on of Jane Doe 8 and used that
6
Complaint [Felony]
2
3
4
5
6
7
8
9
I 0
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
information for an unlawful purpose to w it to harass and annoy without the consent of Jane Doe
8
Count19
On or about August 4 20 13 in the County of San Diego the crime of Identity Theft in
violati on of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willful ly and unlawfully obtain personal identifying informati on of Jane Doe 8 and used that
information for an unl awful purpose a nd to obtain and attempt to obtai n credit goods services
and money without the consent of Jane Doe 8
Count20
On or about A ugust 6 20 I 3 in the County of San Diego the c rime ofldentity Theft in
v iolation of Penal Code secti on 5305(a) a felony was committed by Kevin BOLLAERT who
did wi llfully and unlawfully obtain personal identify ing information of Jane Doc 9 and used that
information for an unlawful purpose to wit to harass and annoy without the consent of Jane Doe
9
Count21
On or about August 6 20 I 3 in the County of San Diego the crime o f Identity Theft in
v iolation of Penal Code section 5305(a) a fe lony was committed by Kevin BOLLAERT who
d id willfully and unlawfully obtain personal identifying informatio n of Jane Doc 9 and used that
information for an unl awful purpose and to obtain and attempt to obtain credit goods services
and money without the consent of Jane Doe 9
Count 22
On or abo ut August 13 20 I 3 in the County of San Diego the crime ofldentity Theft in
vio lation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfull y obtain personal identifying information of Jane Doe I 0 and used
that information for an unlawful purpose to w it to harass and annoy without the consent of Jane
Doe 1 0
7
Complaint [Fe lony]
5
10
15
20
25
2
3
4
6
7
8
9
11
12
13
14
I6
17
I8
I9
21
22
23
24
26
27
28
Count 23
On or about August 13 2013 in the County of San Diego the crime of Identity Theft in
vio lation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifying informati on of Jane Doe 1 0 and used
that information for an unlawful purpose and to obtain and attempt to obtain credit goods
services and money without the consent of Jane Doe 1 0
Count 24
On or about August 26 2013 in the County of San Diego the crime ofldentity Theft in
v iolation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifying information of Jane Doe 11 and used
that information for an unlawfu l purpose to w it to harass and annoy without the consent of Jane
Doe 11
Count 25
On or about August 26 20 13 in the County of San Diego the crime of Identity Theft in
v iolation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifying information of Jane Doe II and used
that information for an unlawful purpose and to obtain and attempt to obtain credit goods
services and money without the consent of Jane Doe 1 1
Count 26
O n or about September 4 2013 in the County of San Diego the crime ofldentity Theft in
violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identify ing information of Jane Doe 12 and used
that informati on for an unlawful purpose to wit to harass and annoy without the consent of Jane
Doe 12
Count 27
On or ab out September 4 20 13 in the County of San Diego the crime of Identity Theft in
violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did will full y and unlawfully obtain personal identifying information of Jane Doe 12 and used
8
Complaint [Felony]
5
10
15
20
25
that information for an unlawful purpose and to obtain and attempt to obtain credit goods
2 services and money without the consent ofJane Doe 12
3 Count28
4 On or about September 10 2013 in the County of San Diego the crime of Identity Theft
in violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT
6 who did willfully and unlawfully obtain personal identifying information of Jane Doe 13 and
7 used that information for an unlawful purpose to wit to harass and annoy without the consent of
8 Jane Doe 13
9 Count 29
On or about September 10 2013 in the County of San Diego the crime of Identity Theft
11 in violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT
12 who did willfully and unlawfully obtain personal identifying information of Jane Doe 13 and
13 used that information for an unlawful purpose and to obtain and attempt to obtain credit goods
14 services and money without the consent of Jane Doe 13
Count 30
16 On or about September 12 2013 in the County or San Diego the crime of Identity Theft
17 in violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT
18 who did willfully and unlawfully obtain personal identifying information of Jane Doe 14 and
19 used that information for an unlawful purpose to wit to harass and annoy without the consent of
Jane Doe 14
21 Count31
22 On or about September 12 2013 in the County of San Diego the crime ofidentity Theft
23 in violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT
24 who did willfully and unlawfully obtain personal identifying information of Jane Doe14 and
used that information for an unlawful purpose and to obtain and attempt to obtain credit goods
26 services and money without the consent of Jane Doe14
27
28
9
Complaint [Felony)
5
10
15
20
25
Dated
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
22
23
24
26
27
28
December 10 2013 Respectfully Submitted
KAMALA D HARRIS Attorney General of California
TAWNYA AUSTIN Deputy Attorney General Attorneysfor the People ofthe State of California
10
Complaint [Felony)
5
10
15
20
25
2
3
4
6
7
8
9
11
12
13
14
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18
19
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23
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26
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28
Count 5
On or about April 18 20 13 in the County of San Diego the crime ofldentity Theft in
vio lation of Penal Code section 5305(a) a fel ony was committed by Kevin BOLLAERT who
did willfully and unlawfull y obtain personal identifying information of Jane Doe 2 and used that
information for an unlawful pmpose to wit to harass and annoy without the consent of Jane Doe
2
Count 6
On or about Apri l 18 2013 in the County of San Diego the crime of Identity Theft in
violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfull y obtain personal identifying information of Jane Doe 2 and used that
information for an unlawful purpose and to obtain and attempt to o btain credit goods services
and money w ithout the consent of Jane Doe 2
Count 7
On or about April 18 2013 in the County of San Diego the crime of Extortion in violation of
Penal Code Section 520 a fe lony was committed by Kevin BOLLAERT who extorted money
and or other property from Jane Doe 2 by means of threat such as is mentioned in Penal Code
Section 519 to wit to expose or to impute to her any disgrace or expose any secret affecting her
CountS
On or about April 29 2013 in the County of San Diego the cr ime of Identity T heft in
violation of Penal Code section 5305(a) a felony was committed b y Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifying infonnation of Jane Doe 3 and used that
information for an unlawful purpose to wit to harass and annoy without the consent of Jane Doe
3
Count 9
On or about April 29 2013 in the County of San Di ego the crime ofidentity Theft in
v iolati on of Penal Code section 5305(a) a felony was com mitted by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifying information of Jane Doe 3 and used that
4
Complaint [Felony]
information for an unlawful purpose and to obtai n and attempt to obtain cred it goods serv ices
2 and money without the consent of Jane Doe 3
3 CountlO
4 On or about May 13 2013 in the County of San Diego the crime ofldentity Theft in
5 violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
6 did wi llfull y and unl awfu lly obtain persona l identifying information of Jane Doe 4 and used that
7 inform ation for an unlawful purpose to wit to harass and annoy without the consent of Jane Doe
8 4
9 Countll
1 0 On or about May 13 20 13 in the County of San Diego the crime of Identity Theft in
11 vio lation of Penal Code section 5305(a) a fel ony was committed by Kev in BOLLAERT who
12 did willfully and unlawfully obtain personal identify ing information of Jane Doe 4 and used that
13 information for an unlawful purpose and to obtai n and attempt to obtain credit goods services
14 and money without the consent of Jane Doc 4
15 Count 12
16 On or about J ul y 6 20 13 in the County of San Diego the crime ofldentity Theft in
17 violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
18 did willfully and unlawfully obtain personal identify ing information of Jane Doe 5 and used that
19 information for an unlawful purpose to wit to harass and annoy without the consent of Jane Doe
20 5
2 1 Cou nt 13
22 On or about July 6 20 13 in the County of San Diego the crime ofldentity Theft in
23 v iolati on of Penal Code section 5305(a) a fe lony was committed by Kevin BOLLAERT who
24 did w illfull y and unlawfully obta in personal identifying information of Jane Doe 5 and used that
25 information for an unlawful purpose and to obtain and attempt to obtain credit goods services
26 and money w ithout the consent of Jane Doe 5
27
28
5
Complaint Felony]
2
3
4
5
6
7
8
9
1 0
11
I 2
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Count 14
On or abo ut Ju ly 122013 in the County of San Diego the crime ofldentity Theft in
violation of Penal Code section 5305(a) a felon y was committed by Kevin BOLLAERT who
did willfull y and unlawfully obtain personal identifying inform atio n of Jane Doe 6 and used that
informati on for an unlawful purpose to wit to harass and annoy without the consent of Jane Doe
6
Count IS
On or about Jul y 12 2013 in the County of San Diego the crime ofldentity Theft in
violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifying informatio n of Jane Doe 6 and used that
information for an unl awful purpo se and to obtain and attempt to obtain credit goods services
and money wi thout the consent of Jane Doe 6
Count 16
On or about July 16 2013 in the County of San Diego the crime of Identity Theft in
v iolation of Penal Code section 5305(a) a felon y was committed by Kevin BOLLAERT who
did willfully and unlawfull y obtain personal identifying info rmation of Jane Doe 7 and used that
information for an unl awful purpose to wit to harass and annoy without the consent of Jane Doe
7
Countl7
On or about Jul y 16 2013 in the County of San Diego the crime of Identity Theft in
violation ofPenal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifyi ng information of Jane Doe 7 and used that
information for an unl awful purpose and to obtain and attempt to obtain cred it goods services
and mone y without the co nsent of Jane Doe 7
Countl8
On or about August 4 2013 in the County of San Diego the crime of Identity Theft in
violation of Penal Code section 5305(a) a fel ony was committed by Kevin BOLLAERT who
did willfully and unl awfully obtain p ersonal identifying informati on of Jane Doe 8 and used that
6
Complaint [Felony]
2
3
4
5
6
7
8
9
I 0
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
information for an unlawful purpose to w it to harass and annoy without the consent of Jane Doe
8
Count19
On or about August 4 20 13 in the County of San Diego the crime of Identity Theft in
violati on of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willful ly and unlawfully obtain personal identifying informati on of Jane Doe 8 and used that
information for an unl awful purpose a nd to obtain and attempt to obtai n credit goods services
and money without the consent of Jane Doe 8
Count20
On or about A ugust 6 20 I 3 in the County of San Diego the c rime ofldentity Theft in
v iolation of Penal Code secti on 5305(a) a felony was committed by Kevin BOLLAERT who
did wi llfully and unlawfully obtain personal identify ing information of Jane Doc 9 and used that
information for an unlawful purpose to wit to harass and annoy without the consent of Jane Doe
9
Count21
On or about August 6 20 I 3 in the County of San Diego the crime o f Identity Theft in
v iolation of Penal Code section 5305(a) a fe lony was committed by Kevin BOLLAERT who
d id willfully and unlawfully obtain personal identifying informatio n of Jane Doc 9 and used that
information for an unl awful purpose and to obtain and attempt to obtain credit goods services
and money without the consent of Jane Doe 9
Count 22
On or abo ut August 13 20 I 3 in the County of San Diego the crime ofldentity Theft in
vio lation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfull y obtain personal identifying information of Jane Doe I 0 and used
that information for an unlawful purpose to w it to harass and annoy without the consent of Jane
Doe 1 0
7
Complaint [Fe lony]
5
10
15
20
25
2
3
4
6
7
8
9
11
12
13
14
I6
17
I8
I9
21
22
23
24
26
27
28
Count 23
On or about August 13 2013 in the County of San Diego the crime of Identity Theft in
vio lation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifying informati on of Jane Doe 1 0 and used
that information for an unlawful purpose and to obtain and attempt to obtain credit goods
services and money without the consent of Jane Doe 1 0
Count 24
On or about August 26 2013 in the County of San Diego the crime ofldentity Theft in
v iolation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifying information of Jane Doe 11 and used
that information for an unlawfu l purpose to w it to harass and annoy without the consent of Jane
Doe 11
Count 25
On or about August 26 20 13 in the County of San Diego the crime of Identity Theft in
v iolation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifying information of Jane Doe II and used
that information for an unlawful purpose and to obtain and attempt to obtain credit goods
services and money without the consent of Jane Doe 1 1
Count 26
O n or about September 4 2013 in the County of San Diego the crime ofldentity Theft in
violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identify ing information of Jane Doe 12 and used
that informati on for an unlawful purpose to wit to harass and annoy without the consent of Jane
Doe 12
Count 27
On or ab out September 4 20 13 in the County of San Diego the crime of Identity Theft in
violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did will full y and unlawfully obtain personal identifying information of Jane Doe 12 and used
8
Complaint [Felony]
5
10
15
20
25
that information for an unlawful purpose and to obtain and attempt to obtain credit goods
2 services and money without the consent ofJane Doe 12
3 Count28
4 On or about September 10 2013 in the County of San Diego the crime of Identity Theft
in violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT
6 who did willfully and unlawfully obtain personal identifying information of Jane Doe 13 and
7 used that information for an unlawful purpose to wit to harass and annoy without the consent of
8 Jane Doe 13
9 Count 29
On or about September 10 2013 in the County of San Diego the crime of Identity Theft
11 in violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT
12 who did willfully and unlawfully obtain personal identifying information of Jane Doe 13 and
13 used that information for an unlawful purpose and to obtain and attempt to obtain credit goods
14 services and money without the consent of Jane Doe 13
Count 30
16 On or about September 12 2013 in the County or San Diego the crime of Identity Theft
17 in violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT
18 who did willfully and unlawfully obtain personal identifying information of Jane Doe 14 and
19 used that information for an unlawful purpose to wit to harass and annoy without the consent of
Jane Doe 14
21 Count31
22 On or about September 12 2013 in the County of San Diego the crime ofidentity Theft
23 in violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT
24 who did willfully and unlawfully obtain personal identifying information of Jane Doe14 and
used that information for an unlawful purpose and to obtain and attempt to obtain credit goods
26 services and money without the consent of Jane Doe14
27
28
9
Complaint [Felony)
5
10
15
20
25
Dated
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
22
23
24
26
27
28
December 10 2013 Respectfully Submitted
KAMALA D HARRIS Attorney General of California
TAWNYA AUSTIN Deputy Attorney General Attorneysfor the People ofthe State of California
10
Complaint [Felony)
information for an unlawful purpose and to obtai n and attempt to obtain cred it goods serv ices
2 and money without the consent of Jane Doe 3
3 CountlO
4 On or about May 13 2013 in the County of San Diego the crime ofldentity Theft in
5 violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
6 did wi llfull y and unl awfu lly obtain persona l identifying information of Jane Doe 4 and used that
7 inform ation for an unlawful purpose to wit to harass and annoy without the consent of Jane Doe
8 4
9 Countll
1 0 On or about May 13 20 13 in the County of San Diego the crime of Identity Theft in
11 vio lation of Penal Code section 5305(a) a fel ony was committed by Kev in BOLLAERT who
12 did willfully and unlawfully obtain personal identify ing information of Jane Doe 4 and used that
13 information for an unlawful purpose and to obtai n and attempt to obtain credit goods services
14 and money without the consent of Jane Doc 4
15 Count 12
16 On or about J ul y 6 20 13 in the County of San Diego the crime ofldentity Theft in
17 violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
18 did willfully and unlawfully obtain personal identify ing information of Jane Doe 5 and used that
19 information for an unlawful purpose to wit to harass and annoy without the consent of Jane Doe
20 5
2 1 Cou nt 13
22 On or about July 6 20 13 in the County of San Diego the crime ofldentity Theft in
23 v iolati on of Penal Code section 5305(a) a fe lony was committed by Kevin BOLLAERT who
24 did w illfull y and unlawfully obta in personal identifying information of Jane Doe 5 and used that
25 information for an unlawful purpose and to obtain and attempt to obtain credit goods services
26 and money w ithout the consent of Jane Doe 5
27
28
5
Complaint Felony]
2
3
4
5
6
7
8
9
1 0
11
I 2
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Count 14
On or abo ut Ju ly 122013 in the County of San Diego the crime ofldentity Theft in
violation of Penal Code section 5305(a) a felon y was committed by Kevin BOLLAERT who
did willfull y and unlawfully obtain personal identifying inform atio n of Jane Doe 6 and used that
informati on for an unlawful purpose to wit to harass and annoy without the consent of Jane Doe
6
Count IS
On or about Jul y 12 2013 in the County of San Diego the crime ofldentity Theft in
violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifying informatio n of Jane Doe 6 and used that
information for an unl awful purpo se and to obtain and attempt to obtain credit goods services
and money wi thout the consent of Jane Doe 6
Count 16
On or about July 16 2013 in the County of San Diego the crime of Identity Theft in
v iolation of Penal Code section 5305(a) a felon y was committed by Kevin BOLLAERT who
did willfully and unlawfull y obtain personal identifying info rmation of Jane Doe 7 and used that
information for an unl awful purpose to wit to harass and annoy without the consent of Jane Doe
7
Countl7
On or about Jul y 16 2013 in the County of San Diego the crime of Identity Theft in
violation ofPenal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifyi ng information of Jane Doe 7 and used that
information for an unl awful purpose and to obtain and attempt to obtain cred it goods services
and mone y without the co nsent of Jane Doe 7
Countl8
On or about August 4 2013 in the County of San Diego the crime of Identity Theft in
violation of Penal Code section 5305(a) a fel ony was committed by Kevin BOLLAERT who
did willfully and unl awfully obtain p ersonal identifying informati on of Jane Doe 8 and used that
6
Complaint [Felony]
2
3
4
5
6
7
8
9
I 0
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
information for an unlawful purpose to w it to harass and annoy without the consent of Jane Doe
8
Count19
On or about August 4 20 13 in the County of San Diego the crime of Identity Theft in
violati on of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willful ly and unlawfully obtain personal identifying informati on of Jane Doe 8 and used that
information for an unl awful purpose a nd to obtain and attempt to obtai n credit goods services
and money without the consent of Jane Doe 8
Count20
On or about A ugust 6 20 I 3 in the County of San Diego the c rime ofldentity Theft in
v iolation of Penal Code secti on 5305(a) a felony was committed by Kevin BOLLAERT who
did wi llfully and unlawfully obtain personal identify ing information of Jane Doc 9 and used that
information for an unlawful purpose to wit to harass and annoy without the consent of Jane Doe
9
Count21
On or about August 6 20 I 3 in the County of San Diego the crime o f Identity Theft in
v iolation of Penal Code section 5305(a) a fe lony was committed by Kevin BOLLAERT who
d id willfully and unlawfully obtain personal identifying informatio n of Jane Doc 9 and used that
information for an unl awful purpose and to obtain and attempt to obtain credit goods services
and money without the consent of Jane Doe 9
Count 22
On or abo ut August 13 20 I 3 in the County of San Diego the crime ofldentity Theft in
vio lation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfull y obtain personal identifying information of Jane Doe I 0 and used
that information for an unlawful purpose to w it to harass and annoy without the consent of Jane
Doe 1 0
7
Complaint [Fe lony]
5
10
15
20
25
2
3
4
6
7
8
9
11
12
13
14
I6
17
I8
I9
21
22
23
24
26
27
28
Count 23
On or about August 13 2013 in the County of San Diego the crime of Identity Theft in
vio lation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifying informati on of Jane Doe 1 0 and used
that information for an unlawful purpose and to obtain and attempt to obtain credit goods
services and money without the consent of Jane Doe 1 0
Count 24
On or about August 26 2013 in the County of San Diego the crime ofldentity Theft in
v iolation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifying information of Jane Doe 11 and used
that information for an unlawfu l purpose to w it to harass and annoy without the consent of Jane
Doe 11
Count 25
On or about August 26 20 13 in the County of San Diego the crime of Identity Theft in
v iolation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifying information of Jane Doe II and used
that information for an unlawful purpose and to obtain and attempt to obtain credit goods
services and money without the consent of Jane Doe 1 1
Count 26
O n or about September 4 2013 in the County of San Diego the crime ofldentity Theft in
violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identify ing information of Jane Doe 12 and used
that informati on for an unlawful purpose to wit to harass and annoy without the consent of Jane
Doe 12
Count 27
On or ab out September 4 20 13 in the County of San Diego the crime of Identity Theft in
violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did will full y and unlawfully obtain personal identifying information of Jane Doe 12 and used
8
Complaint [Felony]
5
10
15
20
25
that information for an unlawful purpose and to obtain and attempt to obtain credit goods
2 services and money without the consent ofJane Doe 12
3 Count28
4 On or about September 10 2013 in the County of San Diego the crime of Identity Theft
in violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT
6 who did willfully and unlawfully obtain personal identifying information of Jane Doe 13 and
7 used that information for an unlawful purpose to wit to harass and annoy without the consent of
8 Jane Doe 13
9 Count 29
On or about September 10 2013 in the County of San Diego the crime of Identity Theft
11 in violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT
12 who did willfully and unlawfully obtain personal identifying information of Jane Doe 13 and
13 used that information for an unlawful purpose and to obtain and attempt to obtain credit goods
14 services and money without the consent of Jane Doe 13
Count 30
16 On or about September 12 2013 in the County or San Diego the crime of Identity Theft
17 in violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT
18 who did willfully and unlawfully obtain personal identifying information of Jane Doe 14 and
19 used that information for an unlawful purpose to wit to harass and annoy without the consent of
Jane Doe 14
21 Count31
22 On or about September 12 2013 in the County of San Diego the crime ofidentity Theft
23 in violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT
24 who did willfully and unlawfully obtain personal identifying information of Jane Doe14 and
used that information for an unlawful purpose and to obtain and attempt to obtain credit goods
26 services and money without the consent of Jane Doe14
27
28
9
Complaint [Felony)
5
10
15
20
25
Dated
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
22
23
24
26
27
28
December 10 2013 Respectfully Submitted
KAMALA D HARRIS Attorney General of California
TAWNYA AUSTIN Deputy Attorney General Attorneysfor the People ofthe State of California
10
Complaint [Felony)
2
3
4
5
6
7
8
9
1 0
11
I 2
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Count 14
On or abo ut Ju ly 122013 in the County of San Diego the crime ofldentity Theft in
violation of Penal Code section 5305(a) a felon y was committed by Kevin BOLLAERT who
did willfull y and unlawfully obtain personal identifying inform atio n of Jane Doe 6 and used that
informati on for an unlawful purpose to wit to harass and annoy without the consent of Jane Doe
6
Count IS
On or about Jul y 12 2013 in the County of San Diego the crime ofldentity Theft in
violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifying informatio n of Jane Doe 6 and used that
information for an unl awful purpo se and to obtain and attempt to obtain credit goods services
and money wi thout the consent of Jane Doe 6
Count 16
On or about July 16 2013 in the County of San Diego the crime of Identity Theft in
v iolation of Penal Code section 5305(a) a felon y was committed by Kevin BOLLAERT who
did willfully and unlawfull y obtain personal identifying info rmation of Jane Doe 7 and used that
information for an unl awful purpose to wit to harass and annoy without the consent of Jane Doe
7
Countl7
On or about Jul y 16 2013 in the County of San Diego the crime of Identity Theft in
violation ofPenal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifyi ng information of Jane Doe 7 and used that
information for an unl awful purpose and to obtain and attempt to obtain cred it goods services
and mone y without the co nsent of Jane Doe 7
Countl8
On or about August 4 2013 in the County of San Diego the crime of Identity Theft in
violation of Penal Code section 5305(a) a fel ony was committed by Kevin BOLLAERT who
did willfully and unl awfully obtain p ersonal identifying informati on of Jane Doe 8 and used that
6
Complaint [Felony]
2
3
4
5
6
7
8
9
I 0
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
information for an unlawful purpose to w it to harass and annoy without the consent of Jane Doe
8
Count19
On or about August 4 20 13 in the County of San Diego the crime of Identity Theft in
violati on of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willful ly and unlawfully obtain personal identifying informati on of Jane Doe 8 and used that
information for an unl awful purpose a nd to obtain and attempt to obtai n credit goods services
and money without the consent of Jane Doe 8
Count20
On or about A ugust 6 20 I 3 in the County of San Diego the c rime ofldentity Theft in
v iolation of Penal Code secti on 5305(a) a felony was committed by Kevin BOLLAERT who
did wi llfully and unlawfully obtain personal identify ing information of Jane Doc 9 and used that
information for an unlawful purpose to wit to harass and annoy without the consent of Jane Doe
9
Count21
On or about August 6 20 I 3 in the County of San Diego the crime o f Identity Theft in
v iolation of Penal Code section 5305(a) a fe lony was committed by Kevin BOLLAERT who
d id willfully and unlawfully obtain personal identifying informatio n of Jane Doc 9 and used that
information for an unl awful purpose and to obtain and attempt to obtain credit goods services
and money without the consent of Jane Doe 9
Count 22
On or abo ut August 13 20 I 3 in the County of San Diego the crime ofldentity Theft in
vio lation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfull y obtain personal identifying information of Jane Doe I 0 and used
that information for an unlawful purpose to w it to harass and annoy without the consent of Jane
Doe 1 0
7
Complaint [Fe lony]
5
10
15
20
25
2
3
4
6
7
8
9
11
12
13
14
I6
17
I8
I9
21
22
23
24
26
27
28
Count 23
On or about August 13 2013 in the County of San Diego the crime of Identity Theft in
vio lation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifying informati on of Jane Doe 1 0 and used
that information for an unlawful purpose and to obtain and attempt to obtain credit goods
services and money without the consent of Jane Doe 1 0
Count 24
On or about August 26 2013 in the County of San Diego the crime ofldentity Theft in
v iolation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifying information of Jane Doe 11 and used
that information for an unlawfu l purpose to w it to harass and annoy without the consent of Jane
Doe 11
Count 25
On or about August 26 20 13 in the County of San Diego the crime of Identity Theft in
v iolation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifying information of Jane Doe II and used
that information for an unlawful purpose and to obtain and attempt to obtain credit goods
services and money without the consent of Jane Doe 1 1
Count 26
O n or about September 4 2013 in the County of San Diego the crime ofldentity Theft in
violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identify ing information of Jane Doe 12 and used
that informati on for an unlawful purpose to wit to harass and annoy without the consent of Jane
Doe 12
Count 27
On or ab out September 4 20 13 in the County of San Diego the crime of Identity Theft in
violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did will full y and unlawfully obtain personal identifying information of Jane Doe 12 and used
8
Complaint [Felony]
5
10
15
20
25
that information for an unlawful purpose and to obtain and attempt to obtain credit goods
2 services and money without the consent ofJane Doe 12
3 Count28
4 On or about September 10 2013 in the County of San Diego the crime of Identity Theft
in violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT
6 who did willfully and unlawfully obtain personal identifying information of Jane Doe 13 and
7 used that information for an unlawful purpose to wit to harass and annoy without the consent of
8 Jane Doe 13
9 Count 29
On or about September 10 2013 in the County of San Diego the crime of Identity Theft
11 in violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT
12 who did willfully and unlawfully obtain personal identifying information of Jane Doe 13 and
13 used that information for an unlawful purpose and to obtain and attempt to obtain credit goods
14 services and money without the consent of Jane Doe 13
Count 30
16 On or about September 12 2013 in the County or San Diego the crime of Identity Theft
17 in violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT
18 who did willfully and unlawfully obtain personal identifying information of Jane Doe 14 and
19 used that information for an unlawful purpose to wit to harass and annoy without the consent of
Jane Doe 14
21 Count31
22 On or about September 12 2013 in the County of San Diego the crime ofidentity Theft
23 in violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT
24 who did willfully and unlawfully obtain personal identifying information of Jane Doe14 and
used that information for an unlawful purpose and to obtain and attempt to obtain credit goods
26 services and money without the consent of Jane Doe14
27
28
9
Complaint [Felony)
5
10
15
20
25
Dated
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
22
23
24
26
27
28
December 10 2013 Respectfully Submitted
KAMALA D HARRIS Attorney General of California
TAWNYA AUSTIN Deputy Attorney General Attorneysfor the People ofthe State of California
10
Complaint [Felony)
2
3
4
5
6
7
8
9
I 0
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
information for an unlawful purpose to w it to harass and annoy without the consent of Jane Doe
8
Count19
On or about August 4 20 13 in the County of San Diego the crime of Identity Theft in
violati on of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willful ly and unlawfully obtain personal identifying informati on of Jane Doe 8 and used that
information for an unl awful purpose a nd to obtain and attempt to obtai n credit goods services
and money without the consent of Jane Doe 8
Count20
On or about A ugust 6 20 I 3 in the County of San Diego the c rime ofldentity Theft in
v iolation of Penal Code secti on 5305(a) a felony was committed by Kevin BOLLAERT who
did wi llfully and unlawfully obtain personal identify ing information of Jane Doc 9 and used that
information for an unlawful purpose to wit to harass and annoy without the consent of Jane Doe
9
Count21
On or about August 6 20 I 3 in the County of San Diego the crime o f Identity Theft in
v iolation of Penal Code section 5305(a) a fe lony was committed by Kevin BOLLAERT who
d id willfully and unlawfully obtain personal identifying informatio n of Jane Doc 9 and used that
information for an unl awful purpose and to obtain and attempt to obtain credit goods services
and money without the consent of Jane Doe 9
Count 22
On or abo ut August 13 20 I 3 in the County of San Diego the crime ofldentity Theft in
vio lation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfull y obtain personal identifying information of Jane Doe I 0 and used
that information for an unlawful purpose to w it to harass and annoy without the consent of Jane
Doe 1 0
7
Complaint [Fe lony]
5
10
15
20
25
2
3
4
6
7
8
9
11
12
13
14
I6
17
I8
I9
21
22
23
24
26
27
28
Count 23
On or about August 13 2013 in the County of San Diego the crime of Identity Theft in
vio lation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifying informati on of Jane Doe 1 0 and used
that information for an unlawful purpose and to obtain and attempt to obtain credit goods
services and money without the consent of Jane Doe 1 0
Count 24
On or about August 26 2013 in the County of San Diego the crime ofldentity Theft in
v iolation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifying information of Jane Doe 11 and used
that information for an unlawfu l purpose to w it to harass and annoy without the consent of Jane
Doe 11
Count 25
On or about August 26 20 13 in the County of San Diego the crime of Identity Theft in
v iolation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifying information of Jane Doe II and used
that information for an unlawful purpose and to obtain and attempt to obtain credit goods
services and money without the consent of Jane Doe 1 1
Count 26
O n or about September 4 2013 in the County of San Diego the crime ofldentity Theft in
violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identify ing information of Jane Doe 12 and used
that informati on for an unlawful purpose to wit to harass and annoy without the consent of Jane
Doe 12
Count 27
On or ab out September 4 20 13 in the County of San Diego the crime of Identity Theft in
violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did will full y and unlawfully obtain personal identifying information of Jane Doe 12 and used
8
Complaint [Felony]
5
10
15
20
25
that information for an unlawful purpose and to obtain and attempt to obtain credit goods
2 services and money without the consent ofJane Doe 12
3 Count28
4 On or about September 10 2013 in the County of San Diego the crime of Identity Theft
in violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT
6 who did willfully and unlawfully obtain personal identifying information of Jane Doe 13 and
7 used that information for an unlawful purpose to wit to harass and annoy without the consent of
8 Jane Doe 13
9 Count 29
On or about September 10 2013 in the County of San Diego the crime of Identity Theft
11 in violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT
12 who did willfully and unlawfully obtain personal identifying information of Jane Doe 13 and
13 used that information for an unlawful purpose and to obtain and attempt to obtain credit goods
14 services and money without the consent of Jane Doe 13
Count 30
16 On or about September 12 2013 in the County or San Diego the crime of Identity Theft
17 in violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT
18 who did willfully and unlawfully obtain personal identifying information of Jane Doe 14 and
19 used that information for an unlawful purpose to wit to harass and annoy without the consent of
Jane Doe 14
21 Count31
22 On or about September 12 2013 in the County of San Diego the crime ofidentity Theft
23 in violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT
24 who did willfully and unlawfully obtain personal identifying information of Jane Doe14 and
used that information for an unlawful purpose and to obtain and attempt to obtain credit goods
26 services and money without the consent of Jane Doe14
27
28
9
Complaint [Felony)
5
10
15
20
25
Dated
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
22
23
24
26
27
28
December 10 2013 Respectfully Submitted
KAMALA D HARRIS Attorney General of California
TAWNYA AUSTIN Deputy Attorney General Attorneysfor the People ofthe State of California
10
Complaint [Felony)
5
10
15
20
25
2
3
4
6
7
8
9
11
12
13
14
I6
17
I8
I9
21
22
23
24
26
27
28
Count 23
On or about August 13 2013 in the County of San Diego the crime of Identity Theft in
vio lation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifying informati on of Jane Doe 1 0 and used
that information for an unlawful purpose and to obtain and attempt to obtain credit goods
services and money without the consent of Jane Doe 1 0
Count 24
On or about August 26 2013 in the County of San Diego the crime ofldentity Theft in
v iolation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifying information of Jane Doe 11 and used
that information for an unlawfu l purpose to w it to harass and annoy without the consent of Jane
Doe 11
Count 25
On or about August 26 20 13 in the County of San Diego the crime of Identity Theft in
v iolation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identifying information of Jane Doe II and used
that information for an unlawful purpose and to obtain and attempt to obtain credit goods
services and money without the consent of Jane Doe 1 1
Count 26
O n or about September 4 2013 in the County of San Diego the crime ofldentity Theft in
violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did willfully and unlawfully obtain personal identify ing information of Jane Doe 12 and used
that informati on for an unlawful purpose to wit to harass and annoy without the consent of Jane
Doe 12
Count 27
On or ab out September 4 20 13 in the County of San Diego the crime of Identity Theft in
violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT who
did will full y and unlawfully obtain personal identifying information of Jane Doe 12 and used
8
Complaint [Felony]
5
10
15
20
25
that information for an unlawful purpose and to obtain and attempt to obtain credit goods
2 services and money without the consent ofJane Doe 12
3 Count28
4 On or about September 10 2013 in the County of San Diego the crime of Identity Theft
in violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT
6 who did willfully and unlawfully obtain personal identifying information of Jane Doe 13 and
7 used that information for an unlawful purpose to wit to harass and annoy without the consent of
8 Jane Doe 13
9 Count 29
On or about September 10 2013 in the County of San Diego the crime of Identity Theft
11 in violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT
12 who did willfully and unlawfully obtain personal identifying information of Jane Doe 13 and
13 used that information for an unlawful purpose and to obtain and attempt to obtain credit goods
14 services and money without the consent of Jane Doe 13
Count 30
16 On or about September 12 2013 in the County or San Diego the crime of Identity Theft
17 in violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT
18 who did willfully and unlawfully obtain personal identifying information of Jane Doe 14 and
19 used that information for an unlawful purpose to wit to harass and annoy without the consent of
Jane Doe 14
21 Count31
22 On or about September 12 2013 in the County of San Diego the crime ofidentity Theft
23 in violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT
24 who did willfully and unlawfully obtain personal identifying information of Jane Doe14 and
used that information for an unlawful purpose and to obtain and attempt to obtain credit goods
26 services and money without the consent of Jane Doe14
27
28
9
Complaint [Felony)
5
10
15
20
25
Dated
2
3
4
6
7
8
9
11
12
13
14
16
17
18
19
21
22
23
24
26
27
28
December 10 2013 Respectfully Submitted
KAMALA D HARRIS Attorney General of California
TAWNYA AUSTIN Deputy Attorney General Attorneysfor the People ofthe State of California
10
Complaint [Felony)
5
10
15
20
25
that information for an unlawful purpose and to obtain and attempt to obtain credit goods
2 services and money without the consent ofJane Doe 12
3 Count28
4 On or about September 10 2013 in the County of San Diego the crime of Identity Theft
in violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT
6 who did willfully and unlawfully obtain personal identifying information of Jane Doe 13 and
7 used that information for an unlawful purpose to wit to harass and annoy without the consent of
8 Jane Doe 13
9 Count 29
On or about September 10 2013 in the County of San Diego the crime of Identity Theft
11 in violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT
12 who did willfully and unlawfully obtain personal identifying information of Jane Doe 13 and
13 used that information for an unlawful purpose and to obtain and attempt to obtain credit goods
14 services and money without the consent of Jane Doe 13
Count 30
16 On or about September 12 2013 in the County or San Diego the crime of Identity Theft
17 in violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT
18 who did willfully and unlawfully obtain personal identifying information of Jane Doe 14 and
19 used that information for an unlawful purpose to wit to harass and annoy without the consent of
Jane Doe 14
21 Count31
22 On or about September 12 2013 in the County of San Diego the crime ofidentity Theft
23 in violation of Penal Code section 5305(a) a felony was committed by Kevin BOLLAERT
24 who did willfully and unlawfully obtain personal identifying information of Jane Doe14 and
used that information for an unlawful purpose and to obtain and attempt to obtain credit goods
26 services and money without the consent of Jane Doe14
27
28
9
Complaint [Felony)
5
10
15
20
25
Dated
2
3
4
6
7
8
9
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December 10 2013 Respectfully Submitted
KAMALA D HARRIS Attorney General of California
TAWNYA AUSTIN Deputy Attorney General Attorneysfor the People ofthe State of California
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Complaint [Felony)