Not a member of Pastebin yet?
Sign Up,
it unlocks many cool features!
- Case 3:17-mj-00257-BF Document 1 Filed 03/31/17 Page 1 of i,
- IN THE UNITED STATES DISTRICT
- FOR THE NORTHERN DISTRICT OF TEXAS
- DALLAS DIVISION
- UNITED STATES OF AMERICA No. 51 35" 5F
- v. - U.S. DISTRICT COURT
- NORTHERN DISTRICT or TEXAS
- JUSTIN SHAFER FILED
- I MR 3' I 20!?
- CRIMINAL COMPLAINT ,e
- - CLERK, U.S. URT
- I, the complainant in this case, state that the following is true Ilo the?le In 0 nd
- belief: 61W
- From in or about May 2016 through and including March 21, 2017, in the Dallas and Fort
- Worth Divisions of the Northern District of Texas and elsewhere, defendant JUSTIN
- SHAFER, knowingly and with the intent to harass and intimidate and to place under
- surveillance with intent to harass and intimidate a person, namely N. and his spouse,
- did knowingly and intentionally use an interactive computer service and an electronic
- communication service to engage in a course of conduct that caused, attempted to cause,
- and would be reasonably expected to cause substantial emotional distress to that person;
- in that JUSTIN SHAFER used his Twitter account to post derogatory and in?ammatory
- statements about Hopp and personal identifying information of Hopp and his immediate
- family and his wife online.
- In violation of 18 U.S.C. and 18 U.S.C. 2261(b)(5).
- This criminal complaint is based on the facts set out in the attached af?davit.
- RONNIE o. BUENTELLO
- Special Agent
- Federal Bureau of Investigation
- Sworn to before me and signed in my presence in Dallas, Texas, on March
- UNITED STATES MAGISTRATE JUDGE
- Case 3:17-mj-00257-BF Document 1 Filed 03/31/17 Page 2 of 20 PageID 2
- AFFIDAVIT IN SUPPORT OF COMPLAINT
- 1, Ronnie O. Buentello, being ?rst duly sworn, hereby depose and state as follows:
- 1. I am a Special Agent (SA) with the Federal Bureau of Investigation (FBI) duly
- appointed and acting according to law. I have been employed as an FBI SA since
- February of 201 1. Prior to becoming a SA, I was employed by the FBI as an Electronic
- Technician. Since January 2013, I have been assigned to investigate violations of federal
- law including violations involving computer crime, such as malicious computer activity,
- computer intrusions, and internet fraud schemes. Since being employed with the FBI, I
- have received training and expertise in various forms of computer technology along with
- industry recognized cyber forensic and security training to investigate computer crimes. I
- have participated in the execution of numerous searches and seizures pursuant to warrants
- authorizing the seizure of evidence related to the unauthorized access of protected
- computer systems. Based on my training, experience, and my participation in other
- investigations involving individuals engaged in offenses like the current offenses, I know
- that individuals and/or business engaged in ?nancial crimes often maintain documents
- and ?nancial records for long periods of time, particularly when they are involved in
- ongoing criminal conduct over a long period of time. I also know that individuals and/or
- businesses keep some, if not all, of their records in electronic form, such as on a
- computer. I know that documents and records can be in the form of printed documents or
- stored in computer memory or on computer disks or other computer storage mediums.
- 2. Upon information and belief, there is probable cause to believe that between in or
- about May 2016, and continuing through and including March 21, 2017, defendant
- Affidavit Page 1
- Case 3:17-mj-00257-BF Document 1 Filed 03/31/17 Page 3 of 20 PageID 3
- JUSTIN SHAFER, knowingly and with the intent to harass and intimidate and place
- under surveillance with intent to harass and intimidate another person, did knowingly and
- intentionally use an interactive computer service and an electronic communication
- service to engage in a course of conduct that caused, attempted to cause, and would be
- reasonably expected to cause substantial emotional distress to that person, in violation of
- 18 U.S.C. Cyber Stalking.
- 3. Upon information and belief, there is probable cause to believe that between in or
- after May 2016, through on or about March 21, 2017, defendant JUSTIN SHAFER,
- knowingly and with the intent to harass, intimidate, and place under surveillance with the
- intent to harass and intimidate FBI SA Nathan Hopp, his immediate family members, and
- his spouse. Specifically JUSTIN SHAFER used his Twitter Inc. account @jshafer817
- and his Facebook Inc. account to publicize personal identifying information of SA Hopp,
- his family, and his spouse, to include a past residence address, and acebook pro?le
- accounts belonging to SA Hopp?s mother, cousin, and spouse, and ex-wife, in an attempt
- to harass and intimidate SA Hopp and his family members. Furthermore, JUSTIN
- SHAFER, knowingly and willfully, sent a Facebook ?friend request? to SA Hopp?s
- spouse, and sent direct messages through Facebook to her. JUSTIN SHAFER started to
- ?follow? SA Hopp?s spouse?s Twitter account, in an attempt to harass and intimidate her. -
- Additionally, JUSTIN SHAFER sent an email from his email address,
- justinshafer@gmail.com, to SA Hopp?s business email address. Because of the contact by
- JUSTIN SHAFER, SA Hopp observed the tweets on Twitter feed, and
- reported the criminal conduct for further investigation.
- Affidavit - Page 2
- Case 3:17-mj-00257-BF Document 1 Filed 03/31/17 Page 4 of 20 PageID 4
- 4. The information contained in this af?davit is based on my investigation, including
- information obtained from other Agents, review of data, and my experience and
- background as an FBI SA. I have not included each and every fact known to me
- concerning this investigation. I have set forth only the facts that I believe are necessary
- to establish probable cause to believe that a violation of 18 U.S.C. 2261A.
- APPLICABLE CRIMINAL STATUTES
- 5. There is probable cause to believe that JUSTIN SHAFER has committed a
- violation of 18 U.S.C. The pertinent sections of the statutes are set out below:
- 18 U.S.C. Stalking
- Whoever, with the intent to kill, injure, harass, intimidate, or place under
- surveillance with intent to kill, injure, harass, or intimidate another person, uses
- the mail, any interactive computer service or electronic communication service or
- electronic communication system of interstate commerce, or any other facility of
- interstate or foreign commerCe to engage in a course of conduct that causes,
- attempts to cause, or would be reasonably expected to cause substantial emotional
- distress to a person described in clause or of paragraph shall be
- punished as provided in section 2261(b) of this title (5 years).
- 6. The clauses in paragraph identify the ?person? as:
- that person;
- (ii) an immediate family member (as de?ned in section 115) of that person; or
- 'a spouse or intimate partner of that person.
- 7. 18 U.S.C. 115(c)(2) de?nes an immediate family member as follows:
- (A) his spouse, parent, brother or sister, child or person to whom he stands in
- loco parentis; or
- (B) any other person living in his household and related to him by blood or
- marriage.
- PROBABLE CAUSE
- Affidavit Page 3
- Case 3:17-mj-00257-BF Document 1 Filed 03/31/17 Page 5 of 20 PageID 5
- 8. By way of background, FBI Dallas opened an investigation on February 19,2016
- based on JUSTIN actions of accessing an FTP server belonging to Patterson
- Companies Inc., (PCI) without permission, in which SA Nathan Hopp was the
- primary Case Agent. On February 6, 2016, JUSTIN SHAFER accessed an FTP server
- belonging to PCI without permission and downloaded approximately 22,000
- patient records. PCI sells dental products to dental of?ces, including a management
- software, called Eaglesoft. Eaglesoft allows dental of?ces to store patient?s personal
- identifying information (PII) and personal health information (PHI). PCI was able to
- determine the internet protocol (IP) address used to access the FTP server belonged to
- JUSTIN SHAFER, residing in North Richland Hills, Texas.
- 9. Pursuant to a search warrant approved in the Northern District of Texas, FBI 7 I
- Dallas executed a search warrant at JUSTIN residence on May 25, 2016,
- searching for evidence associated with the accessing of computer systems, and the
- acquisition and dissemination of personal identifying information and health information
- of thousands of individuals. On or about May 25, 2016, JUSTIN SHAFER began
- posting comments on the online social media networking service, Twittercom, and
- tagged the Twitter pro?les; ?@FBIDallas,? and JUSTIN SHAF ER also posted
- comments referring to ?Special Agent Nathan Hawk.?
- 10. On June 29, 2016, FBI Atlanta (NDGA) opened a criminal computer intrusion
- investigation on an individual using the online moniker, ?TheDarkOverlord,? who
- It is believed that JUSTIN SHAFER believed SA Nathan Hopp?s true name to be ?Nathan Hawk.?
- Affidavit Page 4
- Case 3:17-mj-00257-BF Document 1 Filed 03/31/17 Page 6 of 720 PageID 6
- claimed to have stolen 655,000 patient medical records and attempted to extort the
- medical facilities he victimized. As part of their case, FBI Atlanta is investigating
- JUSTIN SHAFER as a co-conspirator of ?TheDarkOverlord.? Subsequent media
- reports con?rmed ?TheDarkOverlord? had posted the records for sales where he was
- seeking 60 Bitcoins2 for a armington, Missouri database of 47,864 records,
- which was found on JUSTIN computer during a search warrant executed on
- January 29, 2017; 170 Bitcoins for a Central/Midwest database containing
- 207,572 records; and 300 Bitcoins for a Blue Cross/Blue Shield S)
- database containing 396,458 records. Since his appearance in June 2016,
- ?TheDarkOverlord? has claimed approximately 15 major computer breaches and the sale
- of one million customer PII records, and engaged in extortion of the victims across the
- Unites States, targeting medical providers, ?nancial companies, large US. corporations,
- and even a provider of cancer services in Indiana. In most cases, ?TheDarkOverlord?
- extorted his victims with verbose, condescending, and abusive language, and taunted
- victim companies, their employees, and (in at least one case) the children of victim
- employees. ?TheDarkOverlord? has carried out threats to release data when victims
- declined to pay, and has made implied threats to FBI Agents in Atlanta and New Orleans.
- 11. Collaboration between multiple FBI Divisions has subsequently identi?ed
- signi?cant links (IP addresses, emails, social media accounts) between
- ?TheDarkOverlord? and JUSTIN SHAF ER. On January 29, 2017, FBI Dallas, FBI
- 2 Bitcoins are a type of digital currency in which techniques are used to regulate the generation of units
- of currency and verify the transfer of funds, operating independently of a central bank.
- Affidavit - Page 5
- Case 3:17-mj-00257-BF Document 1 Filed 03/31/17 Page 7 of 20 PageID 7
- Atlanta, FBI Saint Louis, FBI New Orleans, and FBI Newark executed a search warrant
- at JUSTIN residence, located in North Richland Hills, Texas. At the time of
- entry, JUSTIN SHAFER was logged into at least two different workstations in his home
- of?ce and garage. During the execution of the search warrant, the FBI seized
- approximately 29 evidence items, including desktops, laptops, hard drives, router, several
- cell phones, numerous universal serial bus (USB) drives, and an Xbox game
- console. A chat session appearing to be with ?TheDarkOverlord? was observed on a
- computer during the execution of the search warrant. In the months following the initial
- search warrant on May 25, 2016, several online media outlets published articles
- defending Shafer as a ?security researcher? and admonished the FBI for executing a
- search warrant at his residence.? SA Nathan Hopp was present for both search warrants
- that were executed on May 25, 2016 and on January 29, 2017.
- 12. The United States Attorney?s Of?ce (USAO) and the FBI are investigating the
- cyber stalking and disclosure of personal information of an Agent of the Federal
- Government. On March 21, 2017, at approximately 8:54 am, SA Hopp received an
- email on his government email account from JUSTIN SHAFER from the email address
- justinshafer@gmail.com, with the subject of the email titled ?Hola? and the content of the
- email was a ?smiling face? emoji. Pursuant to a Federal Search Warrant issued out of the
- Northern District of Texas, records reveal the email address justinshafer@gmail.com is
- used by JUSTIN SHAFER. Additionally, beginning on March 21, 2017 at
- approximately 4:11 am, JUSTIN SHAFER began posting a series of tweets which
- made available personal information about SA Hopp and his family, to include his
- Affidavit Page 6
- Case 3:17-mj-00257-BF Document 1 Filed 03/31/17 Page 8 of 20 PageID 8
- cousin, his ex-wife, his mother, and his wife. Af?ant believes that JUSTIN SHAFER
- engaged in the criminal conduct described herein from his residence in Tarrant County,
- Texas. SA Hopp and his spouse reside in the NDTX and received and observed the
- communications from JUSTIN SHAFER on devices in the NDTX.
- 13. Some of the tweets posted by JUSTIN SHAFER included the following:
- Name Twitter Time Date Post
- Account
- Justin Shafer @JShafer817 4:11am Mar 21, there is a Nathan Hopp at
- 2017 the Dallas
- Justin Shafer @JShafer817 5:22am Mar 21, 3
- 2017
- ..
- facebook pro?les that I can
- tell.
- Justin Shafer @JShafer817 6:06am Mar 21,
- 2017 Closer.
- Justin Shafer @JShafer817 7:00am Mar 21, Close as I will get.
- 2017
- Justin Shafer @JShafer817 7:11am Mar 21, Skinnier version of this
- 2017 dude:
- 1 HYYCIX7
- Is Nathan Hawk.
- Justin Shafer @JShafer817 7:28am Mar 21, Elizabeth
- 2017
- Justin Shafer @JShafer817 7:30am Mar 21, Bingo:
- 2017
- 3 The Universal Resource Locator (URL) link posted on Twittercom is a link to the website,
- crowrivermediacom, in which the webpage is an obituary of an individual named Ervil Hopp.
- 4 The URL link posted on Twittercom is a link to the website, stateoftexas.info, in which is a past address
- location for SA Nathan Hopp and his spouse. .
- 5 The URL link posted on Twittercom is a link to a acebook pro?le, belonging to Susan Hopp, SA
- Hopp?s Mother.
- 5 The URL link posted on Twitter. com is a link to a Facebook pro?le, belonging to Katy Olson, SA
- Hopp?s ex-wife.
- 7 The URL link posted on Twittercom is a link to a acebook pro?le, belonging to Bruce Hopp, SA
- Hopp?s cousin.
- 3 The URL link posted on Twitter.com is a link to a Facebook pro?le, belonging to Elizabeth Hopp, SA
- Hopp?s wife.
- Affidavit - Page 7
- Case 3:17-mj-00257-BF Document 1 Filed 03/31/17 Page 9 of 20 PageID 9
- Name Twitter Time Date Post
- Account
- Justin Shafer @JShafer817 7:31am Mar 21, She kept her maiden name
- 2017 on
- Justin Shafer @JShafer817 7 :3 9am Mar 21, Back the blue.
- 2017
- Justin Shafer @JShafer817 7:56am Mar 21, @bethahopp
- 2017 @PogoWasRight This is
- Nathan Hawk?s wife --
- Justin Shafer @JShafer817 8:47am Mar 21, @bethahopp .
- 2017 @PogoWasRight -
- Based on this complaint.
- The epileptic tweet.
- Justin Shafer @JShafer817 11:19am Mar 21, @dawgSu @abtnatural
- 20 17 @Popehat
- @associatesmind
- @PogoWasRight
- Mike @dawg8u 1 1 :20am Mar 21, @abtnatural @Popehat
- Honcho 2017 @associatesmind Nathan
- Hopp is the least busy FBI
- agent of all time.
- 14. On January 9, 2017, before the execution of the NDGA search warrant, Shafer
- posted on Twitter that he called the Dallas FBI office and left a message for SA Nathan
- ?Hawk.? JUSTIN SHAFER posted on Twitter.com the following:
- Name Twitter Date Post
- Account
- Justin Shafer @JShafer817 January 9, 2017 Called the Dallas FBI today an
- for Nathan Hawk.
- 9 The image is an image of Dallas, Texas skyline, stating ?Back the Blue.? The image was posted by
- Elizabeth Hopp, and JUSTIN SHAFER shared her image on his Twitter pro?le feed.
- ?0 The URL link posted on Twittercom is a Northern District of Texas Dallas Division, Criminal
- Complaint of John Rayne Rivello, in which SA Hopp was the affiant.
- Affidavit Page 8
- Case 3:17-mj-00257-BF Document 1 Filed 03/31/17 Page 10 of 20 PageID 10
- 15. In the days following the execution of the NDGA search warrant (January 31,
- 2017), Shafer posted a series of ?tweets? about the execution of the search warrant.
- 16. On February 6, 2017, and on February 13, 2017, JUSTIN SHAFER posted
- numerous ?tweets? referring to SA Hopp, and seems to post threatening comments
- directed to FBI Dallas. The tweets posted by JUSTIN SHAFER included the following
- Name Twitter Time Date Post
- Account
- Justin Shafer @JShafer817 8:46am Feb 6, 2016 @FBIDallas takes big
- men to steal a 5 year old
- kid?s saved games from his
- WII.. But that is who you are.
- Worthless, without integrity.
- Justin Shafer @JShafer817 8:46am Feb 6, 2016 @FBIDallas Cowards.
- Justin Shafer @JShafer817 8:46am Feb 6, 2016 @FBIDallas And
- Nathan Hawk is full of shit.
- Justin Shafer @JShafer817 8:52am Feb 6, 2016 @FBIDallas ?smiling
- face emoji?
- Justin Shafer @JShafer817 3:59am Feb 13, Next time you send
- 2017 van to threaten me, you
- know what you are getting
- yourself into. Stay out of
- trouble FBI.
- 17. On March 18, 2017, JUSTIN SHAFER referenced the Criminal Complaint of
- John Rayne Rivello and tagged @FBIDallas. JUSTIN SHAFER posted the following
- tweet on his Twitter account:
- Name Twitter Time Date Post
- Account
- Justin Shafer @JShafer817 4:22am Mar 18,2017 @punishedmelpl,
- @FBIDallas Holy Shit! It
- Affidavit Page 9
- Case 3:17-mj-00257-BF Document 1 Filed 03/31/17 Page 11 of 20 PageID 11
- gave that dude a seizure.
- Wow!
- 18. On or about March 21, 2017, JUSTIN SHAFER shared a photo which SA
- Hopp?s wife posted on her acebook pro?le webpage. The photo was posted by SA
- Hopp?s wife on July 8, 2016, which consisted of an image of the Dallas, Texas skyline
- with the words ?Back The Blue? within the image. Subsequent comments from JUSTIN
- post and other individuals stated the following:11
- Facebook
- Pro?le
- Comment
- Justin Shafer
- She is Elizabeth Augenstein Hopp, married to Nathan Hopp.. AKA..
- Nathan Hawk. FBI Agent. 59 I ?gured it out from this document. The
- jew_goldstein thing going around.
- Justin Shafer
- Doxxed
- Darrell Pruitt
- So you found him!
- Justin Shafer
- Idid!
- Darrell Pruitt
- What an asshole.
- Justin Shafer
- mil Pruitt is a.possibilitx-. Q.
- further damage to my car ..
- Darrell Pruitt
- I guess I missed that.
- Justin Shafer
- Darrell Pruitt Yeah..he was the one That leaves like 20
- other people to ?gather evidence?..My wife found her missing ring last
- week. . .. So that is good
- Justin Shafer
- ?He knows what he did? Darrell Pruitt
- Darrell Pruitt
- Where have I heard that phrase yea! The TDA
- '1 It is unclear at this junction any involvement of ?Darrell Pruitt,? if any, bey0nd the communication above between
- Shafer Pruitt on this post.
- Affidavit - Page 10
- Case 3:17-mj-00257-BF Document 1 Filed 03/31/17 Page 12 of 20 PageID 12
- Justin Shafer
- That?s two people now! Llanfair Cruz
- Affidavit Page 11
- Case 3:17-mj-00257-BF Document 1 Filed 03/31/17 Page 13 of 20 PageID 13
- A copy of the screen capture is included for clarification below:
- F. Jaw-52 mews 3
- 1% mac
- Liv-7e in Ncr?th i?i'z
- Jami?: Shams: 55th il ?ew} Augerzslenre pawn
- it Ems has
- Mm mm
- From Ken-er
- Photos
- as
- dad naming, 93?s;an
- ia ?rm 19%? My?!
- ml
- uh Uke szment A Share:
- Jti?h? Sham/r aha ls Elizamrh Augxemsmin Hop? marriml Mailman
- :?gurea! l? Bunion! (his dbcumen! ?me
- lihn- Emily a:
- Jusxm Shah?? Dunno
- j? Like ?nal; 3 ms;
- Jumm Shain
- - Va ..
- mu: mime-we
- Beth ?Augeux?uain
- The max Threats 5mm aatnewg'e'n-s'mr @be-manopm;
- "The; is variously Such an smaclim organiza?un
- em: Reply
- .man 5mm?
- mum
- x. mm 9 )mn? W?u'
- {wee .. .rzbiw?yu?? m:
- Aww?apvw.? .1), M.
- mm . ..
- ?mama ??awleer mm ..
- immil-h-mI-rm-mWJ-?HK mm.
- him Remy m:
- Emvmn Fm?? yrhu taunt:
- Like Re?lls *i
- Justin *5me mm:
- Mik? {Wink
- ?an-mat} i?rui? W?he? em aas?mle?
- Ri?pl?y 5 ii
- Justm shaker Darrun Pruitt That is a pa-as?ebal?tir He ?anged mom
- from dalng any tanner damage in my 6m? . -
- mm Reply 5h?"
- ?11,861?
- new: 149! Fron I (gm-ms; i
- like: Rl?zi?g
- dimlin ?5?an Eurruli Pruiztmear?r?, he war; the ana intelmsannu. ?Fl-last
- leave-2 other to "gamer ewdence My wave mums new
- nno la? week So that goon,
- ?in Weary 3 we
- Justus: saunter ?He knows what he cud? Barre? Pr
- :4 new; i215
- ?animal Where have I haan mm shims?: Oh yea! The
- Reply
- Jumm 3mm, Thaw we: beanie new
- mi:
- Lzunh?tw Cruz
- 3
- Justin ahaf?r
- 2 a i
- Get an Umbe- switch to Demzlx. Ell'adlay DDS. R?rmu' dull
- ?Anya; E?g
- Affidavit - Page 12
- Case 3:17-mj-00257-BF Document 1 Filed 03/31/17 Page 14 of 20 PageID 14
- 19. On or about March 21, 2017, JUSTIN SHAFER sent a Facebook message to SA
- Hopp?s wife, using the application Facebook Messenger. A screen capture was obtained
- and the contents of the message states:
- Facebook Comment
- Pro?le
- Justin Shafer How ya doin? 59
- Justin Shafer Tell Nathan I said howdy.
- Justin Shafer Tell him I want my videos of my kids you should just use
- your real last name on facebook.
- Justin Shafer
- A copy of the screen capture is included below:
- 21-2: v:
- saw
- 1 i, 3914
- mm Refer
- ?Saiwamlien ?ows this? i=2 Writ-{amorous
- nus/>2:
- ?4 wsxawagiwidlwme maxim-m
- V, I
- Tell Em . want my meets of my (in: bark?, and- gnu moxith use 361 mi
- ammonites-back
- (foj?F??
- S4: mange. he said
- Mite ms
- ?ex; ?In The: utter-e; f?
- Affidavit Page 13
- Case 3:17-mj-00257-BF Document 1 Filed 03/31/17 Page 15 of 20 PageID 15
- 20. On March 29, 2017, Shafer sent SA Hopp two additional emails, one at 5:55am
- and the second at 5:57am. A screen shot of the emails are below:
- Wad 3:2957751? Ali/Ii:
- Eust?o Skater {gustEmsbaier?2?tna?ig_
- {3 sou-{mam this message on assets}? 3:13 AM
- Welcome to the Federal Government?
- On Wed, Ma: 29: 201? at 5:55 AM. Justin Simfcr?iius?inshafez?mn?eom? wrote:
- "Fuck the police?"
- f?3??502484 5 2,2 liS a??ra9620McGowan 000} rigs:
- i submitted this SEITU to OCR on march 3111.. .What is the hold up?
- Over 500 patients inthe sign-in-sheet folders." No SSN on this ftp.
- Why has this taken so long for the FTP server to go down?
- Justin Shafez
- Onsite Dental Systems
- 3?04 Sagebrush CL 5?
- North Riddand Hills. TX. 76182
- (817) 909-4332
- 21. SA Hopp and his spouse advised Af?ant that JUSTIN conduct, his
- obsession with SA Hopp, his sending messages to SA Hopp and his spouse, his posting
- personal identifying information of SA Hopp, his spouse, and other family members on
- Twitter and on Facebook, and the derogatory and in?ammatory statements made about
- Affidavit - Page 14
- Case 3:17-mj-00257-BF Document 1 Filed 03/31/17 Page 16 of 20 PageID 16
- SA Hopp since the execution of the NDTX Search Warrant in May 2016, have caused
- substantial emotional distress to SA Hopp and his spouse.
- CONCLUSION
- 22. JUSTIN communication using Twitter and Facebook intended to
- intimidate, harass, and cause harm to SA Hopp and to his family and were alarming in
- nature.
- 23. Based on the forgoing, I have probable cause to believe that from in or about May
- 2016, through and including March 21, 2017, defendant JUSTIN SHAFER, knowingly
- and with the intent to harass and intimidate and place under surveillance with intent to
- harass and intimidate a person, namely Nathan Hopp and his spouse, did knowingly and
- intentionally use an interactive computer service and an electronic communication
- service to engage in a course of conduct that caused, attempted to cause, and would be 3' .
- reasonably expected to cause substantial emotional distress to that person; in that
- JUSTIN SHAFER used his Twitter and his Facebook accounts to post derogatory and
- in?ammatory statements about Hopp and personal identifying information of Hopp and
- his immediate family and his wife online, in violation of 18 U.S.C.
- I request that a warrant be issued for the arrest of JUSTIN SHAFER. I further request
- that this complaint, af?davits, and warrant be sealed, except to the extent necessary to
- effectuate the arrest and arraignment of the defendant.
- 24. I understand that on January 5, 2017, Chief Judge Barbara M.G. of the
- United States District Court of Northern District of Texas issued Special Order No. 19-1
- requiring in section 1, that ?the clerk of court will ensure that there is no public access . . .
- Affidavit - Page 15
- Case 3:17-mj-00257-BF Document 1 Filed 03/31/17 Page 17 of 20 PageID 17
- to criminal complaints, supporting af?davits, and related papers, until each named
- defendant has been arrested or has made an appearance in federal court.?
- 1:??tu submitted,
- Ryonnie C5. Buentello, Special Agent
- Federal Bureau of Investigation
- Subscribed . - 0 before me on March 2017
- UNITED STATES MAGISTRATE JUDGE
- Affidavit - Page 16
- Case 3:17-mj-00257-BF Document 1 Filed 03/31/17 Page 18 of 20 PageID 18
- MW
- Property to Be Searched
- The warrant applies to information associated with the email account
- and ustin.Shafer.79, that is stored at premises
- owned, maintained, controlled, or operated by acebook Inc., a company headquartered
- in Menlo Park, CA.
- Case 3:17-mj-00257-BF Document 1 Filed 03/31/17 Page 19 of 20 PageID 19
- Attachment
- Particular Things to be Seized
- 1. Information to be disclosed by Facebook Inc.
- To the extent that the information described in Attachment A is within the
- possession, custody, or control of Facebook including any
- messages, records, ?les, logs, or information that have been deleted but are still
- available to Facebook, or have been preserved pursuant to a request made
- under 18 U.S.C. 2703(f), Facebook. is required to disclose the following
- information to the government for each account or identi?er listed in
- Attachment A:
- a.
- All contact and personal identifying information, including full name, user
- identi?cation number, birth date, gender, contact e-mail addresses,
- Facebook passwords, Facebook security questions and answers, physical
- address (include city, state, and zip code), telephone numbers, screen
- names, websites and other personal identi?ers.
- All activity logs for the account and all other documents showing the user?s
- posts and other Facebook activities;
- All photos and videos uploaded by that username and all photos and Videos
- uploaded by any user that have that user tagged in them;
- All photos and associated data through which Facebook has used facial
- recognition to identify the user through additional posts.
- . All pro?le information; News Feed information; status updates; links to
- Videos, photographs, articles, and other items; Notes; Wall postings; friend
- lists, including the friend? Facebook usernames/identi?cation numbers;
- groups and networks of which the user is a member, including the groups?
- Facebook group identi?cation numbers; future and past event postings;
- rejected ?Friend? requests; comments; gifts; pokes; tags; and information
- about the user?s access and use of Facebook applications;
- All other records of communication and messages made or received by the
- user, including all private messages, chat history, video calling history, and
- pending ?friend? requests;
- All ?check ins? and other location information;
- All IP logs including all records of all the IP addresses that loges into the
- account;
- Case 3:17-mj-00257-BF Document 1 Filed 03/31/17 Page 20 of 20 PageID 20
- i. All records of the account?s usage of the ?like? feature, including all
- Facebook posts and all non-Facebook webpages and content that the user
- has ?liked?;
- All information about the Facebook pages that the account is or was a ?fan?
- of;
- All past and present lists of friends created by the account;
- All records of Facebook searches performed by the account;
- . All information about the user?s access and use of Facebook Marketplace;
- The types of service utilized by the user;
- The length of service (including start date) and the means and source of any
- payments associated with the service (including any credit card or bank
- account number);
- p. A11 privacy settings and other account settings, including privacy settings
- for individuals Facebook posts and activities, and all records showings
- which Facebook users have been blocked by the account;
- q. All records pertaining to communications between Facebook and any
- person regarding the user or the user?s Facebook account, including
- contacts with support services and records actions taken.
- 3
- g-
- 11. Information to be seized by the government
- All information described above in Section I that constitutes fruits, evidence, and
- instrumentalities of violations 18 U.S.C. 119 and involving Justin
- Shafer, using since account inception including, for
- each username identi?ed on Attachment A, information pertaining to the following
- matters:
- a. Files, databases, and database records stored by Facebook related to
- criminal activity by the user
- b. The identity of the person(s) who created or used the username, including
- records that help reveal the whereabouts of such person(s).
- 0. The identity of the person(s) who communicated with the username about
- matters relating to criminal activity.
- (1. Subscriber information related to the accounts established in Attachment A
- to include:
- i. Names, physical addresses, telephone numbers and other identi?ers,
- email address and business information;
- ii. Length of service (including start date), types of service utilized,
- means of source payment for services (including credit card or bank
- account number), and billing and payment information.
Add Comment
Please, Sign In to add comment