Indictment — United States v. Solomon (Dkt. 1, D. Minn.)

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An indictment returned by a grand jury in United States v. Douglas Dan Solomon, No. 0:22-cr-00113-PJS-BRT, in the U.S. District Court for the District of Minnesota, filed June 8, 2022 as Doc. 1. Count 1 charges that on or about May 15, 2019 the defendant, previously convicted of possession of child pornography on or about December 13, 2004, knowingly possessed visual depictions of a minor engaging in sexually explicit conduct, under 18 U.S.C. § 2252(a)(4)(B) and 18 U.S.C. § 2252(b)(2). The forfeiture allegations seek forfeiture under Section 2253(a) of listed devices, including thumb drives, a tablet and a desktop computer, and of substitute property under Section 853(p). The four-page indictment is marked a true bill.

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CASE 0:22-cr-00113-PJS-BRT Doc.1 Filed 06/08/22 Page 1 of 4

                 UNITED STATES DISTRICT COURT
                      DISTRICT OF MINNESOTA                           _
                     .                            Ch ALX-NS P35 /6€1

UNITED STATES OF AMERICA,                INDICTMENT

                 Plaintiff,              18 U.S.C. § 2252(a)(4)(B)
                                         18 U.S.C. § 2252(b)(2)
      V.                                 18 U.S.C. § 2253(a)
                                         18 U.S.C. § 2253(b)
DOUGLAS DAN SOLOMON,                     21 U.S.C. § 853(p)

                 Defendant.

     THE UNITED STATES GRAND JURY CHARGES THAT:

                              COUNT 1
                  (Possession of Child Pornography)

     On or about May 15, 2019, in the State and District of Minnesota, the

defendant,                                                      |

                      DOUGLAS DAN SOLOMON,

having been previously convicted under Chapter 110 of Title 18 of the United

States Code for possession of child pornography, namely a conviction on or

about December 13, 2004, in United States District Court for the District of

Minnesota, knowingly possessed one or more matters which contained visual

depictions that has been shipped and transported using any means or facility

of interstate or foreign commerce and in or affecting interstate or foreign

commerce, and which were produced using materials which have been mailed,

shipped, and transported using a means and facility of interstate or foreign

commerce, by any means, including by computer, where the production of such
                                                                   S G A N N E »)

                                                                    JUN 08 202 /,

                                                                 U.S. DISTRICT COURT MPL

CASE 0:22-cr-00113-PJS-BRT Doc.1 Filed 06/08/22 Page 2 of 4

United States v. Douglas Dan Solomon

visual depictions involved the use of a minor engaging in sexually explicit
conduct and such visual depictions were of such conduct, including, but not

limited to, the following images described below:

Filename Description

[REDACTED]Mfdp.mp4 | Video file approximately one minute and one
second long depicting an adult hand digitally
penetrating the genitalia of a prepubescent girl
who is naked from the waist down.

[REDACTED]al.mp4 Video file approximately 12 minutes long
depicting a prepubescent girl performing oral sex
on an adult male. The video then shows the adult
male anally penetrating the girl with his penis.

[REDACTED]MSB.mp4 | Video file approximately five minutes and 50
seconds long depicting a prepubescent girl
performing oral sex on an adult male. The girl
later digitally penetrates her anus with her
finger while holding a foreign object against her
genitalia. The end of the video shows the male
above the girl while masturbating and
ejaculating on her body.

[REDACTED]D63.jpg An image file depicting a naked prepubescent girl
lying down. She is blindfolded and her hands are
tied together over her head. There is a dog licking
the girl’s genitals.

[REDACTED)ot.avi Video file approximately two minutes and one
second long depicting an adult male masturbating
and ejaculating on the face of a prepubescent girl.

all in violation of Title 18, United States Code, Sections 2252(a)(4)(B) and

2.252(b)(2)..

CASE 0:22-cr-00113-PJS-BRT Doc. 1 Filed 06/08/22 Page 3 of 4

United States v. Douglas Dan Solomon

FORFEITURE ALLEGATIONS

Upon conviction of Count 1 of the Indictment, the defendant shall forfeit
to the United States pursuant to Title 18, United States Code, Section 2253(a):

(1) any visual depiction described in section 2251, 2251A, 2252, 2252A,
2252B, or 2260 of Chapter 110, United States Code, or any book, magazine,
periodical, film, videotape, or other matter which contains any such visual
depiction, which was produced, transported, mailed, shipped or received in
violation of Chapter 110;

(2) any property, real or personal, constituting or traceable to gross
profits or other proceeds obtained from such offense; and

(3) any property, real or personal, used or intended to be used to commit
or to promote the commission of such offense or any property traceable to such
property.

The property subject to forfeiture includes, but is not limited to, the
following:

(a) Sandisc Cruzer Thumb Drive;

(b) Seagate Free Agent, Serial Number 9QG5JPRP;

(c) ASUS Verizon Tablet, IMEI: 357185082448935;

(d) Dell desktop computer, Serial Number 5Y1XVL1;

(e) HP desktop computer, Serial Number 2UA22910GY;

(f) Black unmarked desktop tower; and

CASE 0:22-cr-00113-PJS-BRT Doc.1 Filed 06/08/22 Page 4 of 4

United States v. Douglas Dan Solomon

(g) Blue thumb drive labeled “Online Training Academy”

If any of the above-described forfeitable property is unavailable for
forfeiture, the United States intends to seek the forfeiture of substitute
property as provided for in Title 21, United States Code, Section 853(p), as

incorporated by Title 18, United States Code, Section 2253(b).

A TRUE BILL

UNITED STATES ATTORNEY FOREPERSON

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