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CARLIE CHRISTENSEN, United States Attorney COUR r

CARLOS A. ESQUEDA, Assistant United States


Attorneys for the United States of America - 8 A I (: 23
185 South State Street, Suite 300 DIS1RICT OF U7k
Salt Lake City, Utah 84111-1506 BY: 11
Telephone: (801) 524-5682 DEJliTFrc--::'--'--
Facsimile: (801) 524-6924 . U.F(/'(
IN THE UNITED STATES DISTRICT COURT
DISTRICT OF UTAH, NORTHERN DIVISION
UNITED STATES OF AMERICA,
Plaintiff,
vs.
CHRISTOPHER STEIN EPPERSON,
Defendant.
The Grand Jury Charges:
INDICTMENT
VIO. 18 U.S.C. 242, DEPRIVATION
OF RIGHTS UNDER COLOR OF LAW.
1: 11-cr-00073
AssIgned To . S .
A . . am, DavId
SS/gn. Date: 618/2011
Description: USA v.
COUNT I
(Deprivation of Rights Under Color of Law, 18 U.S.C. 242)
On or about Early December 2009, in the Northern Division of the District of Utah,
CHRISTOPHER STEIN EPPERSON,
Case 1:11-cr-00073-DS Document 1 Filed 06/08/11 Page 1 of 3
the defendant herein, who was then a Wasatch County Deputy Sheriff, assigned to the
Department of Corrections, Heber City, Utah, while acting under color of law, did
sexually assault J.H., by committing or attempting to commit aggravated sexual abuse as
defined by 18 U.S.C. 2241, 2246, and thereby did willfully deprive J.H of the right
protected and secured by the Constitution and laws of the United States not to be deprived
of liberty without due process of law, which includes the right to bodily integrity; all in
violation of Title 18, United States Code, Section 242 .
. COUNT II
(Deprivation of Rights Under Color of Law, 18 U.S.C. 242)
On or about Mid December 2009, in the Northern Division of the District of Utah,
CHRISTOPHER STEIN EPPERSON,
the defendant herein, who was then a Wasatch County Deputy Sheriff, assigned to the
Department of Corrections, Heber City, Utah, while acting under color oflaw, did
sexually assault J.H., by touching either directly or through the clothing her breast, and
thereby did willfully deprive J.H of the right protected and secured by the Constitution
and laws of the United States not to be deprived of liberty without due process of law,
which includes the right to bodily integrity; all in violation of Title 18, United States
Code, Section 242.
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Case 1:11-cr-00073-DS Document 1 Filed 06/08/11 Page 2 of 3
COUNT III
(Deprivation of Rights Under Color of Law, 18 U.S.C. 242)
On or about December 23,2009, in the Northern Division of the District of Utah,
CHRISTOPHER STEIN EPPERSON,
the defendant herein, who was then a Wasatch County Deputy Sheriff, assigned to the'
Department of Corrections, Heber City, Utah, while acting under color oflaw, did
sexually assault J .H., by committing or attempting to commit aggravated sexual abuse as
defined by 18 U.S.C. 2241, 2246, and thereby did willfully deprive J.H of the right
protected and secured by the Constitution and laws of the United States not to be deprived
of liberty without due process of law, which includes the right to bodily integrity; all in
violation of Title 18, United States Code, Section 242.
CARLIE C. CHRISTENSEN
United States Attorney
Assistant United
A TRUE BILL:
FOREPERSON OF THE GRAND JURY
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Case 1:11-cr-00073-DS Document 1 Filed 06/08/11 Page 3 of 3

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