12/10/2020 Indictment Against Jeremiah Harris

Case: 1:20-cr-00637 Document #: 28 Filed: 12/10/20 Page 1 of 8 PageID #:96
FI/1L0E D ER
12 /2020
. BRUTO N UNITED STATES DISTRICT COURT
THOMA.SDGIS T R IC T COURT NORTHERN DISTRICT OF ILLINOIS
CLERK, U .S
EASTERN DIVISION Judge Manish S. Shah
MagistrateJudge M. David Weisman
UNITED STATES OF AMERICA
No. 20 CR 637
v.
Violations: Title 18, United States Code,
JEREMIAH I{ARRIS Sections 225L(a), 22524(a) (2) (A) and
@)(1), 2422b) and 2423@)
COUNT ONE
The SPECIAL JANUARY 2020 GRAND JURY charges:
Beginning from approximately in or around December 2018 and continuing to
approximately in or around. March 2020, at Naperville, in the Northern District of
Illinois, Eastern Division, and elsewhere,
JEREMIAH IIARRIS,
defendant herein, did knowingly use, persuade, induce, and entice a minor, namely
Minor 1, to engage in sexually explicit conduct for the purpose of producing a visual
depiction of such conduct, and for the purpose of transmitting a live visual depiction
of such conduct, which visual depiction defendant knew and had reason to know
would be transported and transmitted using any means and facility of interstate and
foreign commerce, and that visual depiction was produced and transmitted using
materials that had been mailed, shipped, and transported in and affecting interstate
and foreign commerce by any means, and which visual depiction was actually
transported and. transmitted. in and affecting interstate and foreign commerce;
In violation of Title 18, United States Code, Section 225L(a).

COUNT TWO
The SPECIAL JANUARY 2020 GRAND JURY further charges:
On or about May 3, 2019, at Orlando, in the Middle District of Florida, Orlando
Division,
JEREMIAH HARRIS,
defendant herein, using a facility and means of interstate commerce, namely, the
internet, did knowingly persuade, induce, and entice Minor 1, a minor who had riot
attained the age of 18 years, to engage in sexual activity for which the defendant
could be charged with a criminal offense;
In violation of Title l-8, United States Code, Section 2422b).

COUNT THREE
Beginning from approximately in or around JuLy 2020 and continuing to
approximately in or around August 2020, at Naperville, in the Northern District of
Illinois, Eastern Division, and elsewhere,
JEREMIAH IIARRIS,
defendant herein, knowingly received and attempted to receive child pornography, as
defi.ned in Title 18, United States Code, Section 2256(8)(4), using a means and facility
of interstate commerce, and that had been shipped and transported in and affecting
interstate commerce by any means, including by computer;
In rriolation of Tit1e 18, United States Code, Section 22524(a)(2)(A) and (b)(1).
COUNT FOUR
Beginning from approximately in or around July 2020 and continuing to

approximately in or around August 2020, at Naperville, in the Northern District of
Illinois, Eastern Division, and elsewhere
JEREMIAH HARRIS,
d.epiction of such cond.uct, and for the purpose of transmitting a live visual depiction
and foreiglr commerce by any means, and which visual depiction was actually
transported and transmitted in and affecting interstate and foreign commerce;
In violation of Title 18, United States Code, Section 225I(a).

COUNT FTYE
The SPECIAL JANUARY 2020 GRA,ND JURY turther charges:
Beginning from approximately in or around February 2019 and continuing to
approximately in or around May 2019, at Corsicana, in the Northern District of
Texas, Dallas Division, and elsewhere,
JEREMIAH HARRIS,
depiction of such conduct, which visual depiction defendant knew and had reason to
know would be transported and transmitted using any means and facility of
interstate and foreign commerce, and that visual depiction was produced and
transmitted using materials that had been mailed, shipped, and transported in and
affecting interstate and foreign commerce by any means, and which visual depiction
was actually transported and transmitted in and affecting interstate and foreign
commerce;
In violation of Title 18, United States Code, Section 2257(a).

COUNT SD(
Beginning from approximately in or around August 2017 and continuing to
approximately in or around May 2Q19, at Corsicana, in the Northern District of
Texas, Dallas Division, and elsewhere,
JEREMIAH HARRIS,
depiction of such conduct, and for the purpose of transmitting a live visual depiction
and foreign commerce by any means, and which visual depiction was actually
transported and transmitted in and affecting interstate and foreign commerce;
In violation of Title 18, United States Code, Section 225L(a).

COUNT SEVEN
The SPECIAL JANUARY 2020 GRAND ruRY further charges:
On or about May 2, 20L9, at Dallas, in the Northern District of Texas, Dallas
Division, and elsewhere,
JEREMIATI IIARRIS,
defendant herein, traveled in interstate commerce, from Texas to Florida, for the
purpose of engaging in illicit sexual conduct as defi,ned in Title 18, United States
Code, Section 2423(f), in that he traveled with intent to engage in a sexual act with
Minor 5, who was 15 years o1d, and who was at least four years younger than
defendant;
In violation of Title 18, United States Code, Section 2423b).

FORFEITURE ALLEGATION
The SPECIAL JANUARY 2O2O GRAND JURY further alleges:
1. Upon conviction of an offense in violation of Title 18, United States Code,
Section 225L or 2252A as set forth in this Indictment, defendant shall forfeit to the
United States of America any matter which contains visual depictions described in
Title 18, United States Code, Section 2252A; any property constituting and traceable
to gross profits and other proceeds obtained from such offense; and any property used
and intended to be used to commit and to promote the commission of such offense,
and any property traceable to such property, as provided by Title 18, United States
Code, Section 2253(a).
2. The property to be forfeited includes, but is not limited to the following
specifi.c property: an App1e iPhone 11 Pro Max, S/N G6TCC8AYN70K, bearing IMEI
353892108825699.
A TRUE BILL:
FOREPERSON
Signed by Timothy J. Storino on behalf of the

UNITED STATES ATTORNEY

12/10/2020 Indictment Against Jeremiah Harris

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Case: 1:20-cr-00637 Document #: 28 Filed: 12/10/20 Page 1 of 8 PageID #:96

The SPECIAL JANUARY 2020 GRAND JURY charges:

Beginning from approximately in or around December 2018 and continuing to

approximately in or around. March 2020, at Naperville, in the Northern District of

Illinois, Eastern Division, and elsewhere,

transported and. transmitted. in and affecting interstate and foreign commerce;

In violation of Title 18, United States Code, Section 225L(a).

The SPECIAL JANUARY 2020 GRAND JURY further charges:

On or about May 3, 2019, at Orlando, in the Middle District of Florida, Orlando

could be charged with a criminal offense;

In violation of Title l-8, United States Code, Section 2422b).

The SPECIAL JANUARY 2020 GRAND JURY further charges:

Beginning from approximately in or around JuLy 2020 and continuing to

approximately in or around August 2020, at Naperville, in the Northern District of

Illinois, Eastern Division, and elsewhere,

defendant herein, knowingly received and attempted to receive child pornography, as

interstate commerce by any means, including by computer;

The SPECIAL JANUARY 2020 GRAND JURY further charges:

Beginning from approximately in or around July 2020 and continuing to

Illinois, Eastern Division, and elsewhere

transported and transmitted in and affecting interstate and foreign commerce;

In violation of Title 18, United States Code, Section 225I(a).

The SPECIAL JANUARY 2020 GRA,ND JURY turther charges:

Beginning from approximately in or around February 2019 and continuing to

approximately in or around May 2019, at Corsicana, in the Northern District of

Texas, Dallas Division, and elsewhere,

In violation of Title 18, United States Code, Section 2257(a).

The SPECIAL JANUARY 2020 GRAND JURY further charges:

Beginning from approximately in or around August 2017 and continuing to

approximately in or around May 2Q19, at Corsicana, in the Northern District of

Texas, Dallas Division, and elsewhere,

transported and transmitted in and affecting interstate and foreign commerce;

In violation of Title 18, United States Code, Section 225L(a).

The SPECIAL JANUARY 2020 GRAND ruRY further charges:

On or about May 2, 20L9, at Dallas, in the Northern District of Texas, Dallas

Division, and elsewhere,

In violation of Title 18, United States Code, Section 2423b).

The SPECIAL JANUARY 2O2O GRAND JURY further alleges:

1. Upon conviction of an offense in violation of Title 18, United States Code,

Code, Section 2253(a).

2. The property to be forfeited includes, but is not limited to the following

Signed by Timothy J. Storino on behalf of the

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