Indictment — United States v. Alex Scott Roberts (C.D. Cal., Dkt. 1, November 6, 2020)

Summary

An Indictment filed November 6, 2020 (Document 1) by the October 2020 Grand Jury in United States v. Alex Scott Roberts, CR 2:20-cr-00554-AB, in the U.S. District Court for the Central District of California. Count One and Count Two each charge stalking under 18 U.S.C. §§ 2261A(2)(A)–(B) and 2261(b)(5), naming Victim 1 and Victim 2 respectively, from on or about July 29, 2020 to at least on or about August 18, 2020. The counts allege a course of conduct that includes a fake classifieds listing and anonymous text messages, which the indictment quotes. Count Six charges a threat by interstate communication under 18 U.S.C. § 875(c) based on text messages alleged to have been sent to Victim 2 on or about August 16, 2020. The document is marked A TRUE BILL and lists United States Attorney Nicola T. Hanna.

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       Case 2:20-cr-00554-AB Document 1 Filed 11/06/20 Page 1 of 14 Page ID #:1



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                                                                    11/6/2020
                                                                         JB
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 8                           UNITED STATES DISTRICT COURT

 9                     FOR THE CENTRAL DISTRICT OF CALIFORNIA

10                              October 2020 Grand Jury

11   UNITED STATES OF AMERICA,                CR       2:20-cr-00554-AB
12             Plaintiff,                     I N D I C T M E N T

13             v.                             [18 U.S.C. §§ 2261A(2)(A)–(B),
                                              2261(b)(5): Stalking; 18 U.S.C.
14   ALEX SCOTT ROBERTS,                      § 875(c): Threat by Interstate
                                              Communication]
15             Defendant.

16

17        The Grand Jury charges:
18                                      COUNT ONE
19                  [18 U.S.C. §§ 2261A(2)(A)–(B), 2261(b)(5)]
20        1.    Beginning on or about July 29, 2020, and continuing to at
21   least on or about August 18, 2020, in Los Angeles County, within the
22   Central District of California, and elsewhere, defendant ALEX SCOTT
23   ROBERTS (“ROBERTS”), with the intent to harass and intimidate Victim
24   1, used an interactive computer service, an electronic communication
25   service, an electronic communication system of interstate commerce,
26   and other facilities of interstate and foreign commerce, namely,
27   cellular telephone networks, interstate wires, and the Internet, to
28   engage in a course of conduct, described in paragraph 2 below, that
       Case 2:20-cr-00554-AB Document 1 Filed 11/06/20 Page 2 of 14 Page ID #:2



 1   placed Victim 1 in reasonable fear of death and serious bodily injury

 2   to Victim 1 and immediate family members of Victim 1, and that

 3   caused, attempted to cause, and would reasonably be expected to cause

 4   substantial emotional distress to Victim 1 and immediate family

 5   members of Victim 1.

 6        2.    Defendant ROBERTS’s course of conduct included, among other

 7   things, the following:

 8              a.    On or about July 31, 2020, after being told by Victim

 9   1 and her family that Victim 1 did not wish to communicate with him,

10   defendant ROBERTS created a fake listing on the classifieds website

11   Craiglist.com advertising a room for rent at Victim 1’s home.                The

12   listing included Victim 1’s name, home address, and included the

13   following: “Room for Rent . . . Will explain upon visit [¶] Stop by

14   anytime home is open.”

15              b.    On or about August 2, 2020, defendant ROBERTS sent

16   anonymous text messages to a friend of Victim 1, demanding Victim 1’s

17   telephone number, threatening to send nude photographs of Victim 1,

18   and threatening to send someone to rape Victim 1.          The messages

19   included the following:

20
           Fuck it then I will post her pictures [¶] Not kidding .
21         . . U ignore me and all her naked pictures get posted
           [¶] So either give me her number or I post these . . .
22         And ur silent [¶] Like a little bitch [¶] Do u want me
           to have someone rape her . . . If u don’t respond I
23         will send someone over to rape her . . . U have 1
           minute to respond before I send.
24

25              c.    Between on or about August 11, 2020 and on or about

26   August 18, 2020, defendant ROBERTS sent numerous anonymous text

27   messages, from multiple telephone numbers, to Victim 1’s sister

28

                                             2
       Case 2:20-cr-00554-AB Document 1 Filed 11/06/20 Page 3 of 14 Page ID #:3



 1   (Victim 2), who lives with Victim 1.        The text messages that

 2   defendant ROBERTS sent included the following:

 3                    i.    On or about August 11 and 12, 2020, text messages

 4   that included the following:

 5
           Since u think this is a game let’s change your mind on
 6         that . . . Alright lets see what happens tomorrow then
           . . . Let’s have some fun with your cars right now [¶]
 7         Until u respond [¶] Be there soon. . . Who’s window is
           open [¶] Outside [¶] By [Victim 1’s] car [¶] Which
 8         tire.
 9                    ii.   On or about August 12, 2020, text messages that
10   included the following:
11
           [S]o I’m outside . . . I see you guys [¶] look out
12         towards topanga . . . [Victim 1] gets what she
           deserves. . . retribution is upon her and her life will
13         depend on it. . . payback is a bitch and she gets what
           she deserves [¶] hope you all survive there will be
14
           blood . . .you wanted this so let’s show u how serious
15         I am.

16                    iii. On or about August 12, 2020, text messages that

17   included the following:

18         I’m outside [¶] too scared to talk [¶] is [Victim 1] or
           [Victim 2] too scared [¶] poor babies . . . what
19
           happens if someone throws something over your wall [¶]
20         and it blows the house up . . . payback is a bitch for
           what [Victim 1] has done [¶] and she will pay [¶] and
21         so will u [Victim 2] . . . lucky for me I was able to
           hack your WiFi so thanks for the shower videos of the
22         both of you . . . let’s post these videos of the both
           of u in the shower . . . worst thing to do is ignore
23         [¶] that’s how people end up dead . . . be careful with
24         the brake lines [¶] I cut them last night . . . cops
           tell u not to respond pretty stupid when I’m right here
25         . . . so if u think ignoring me and not responding to
           me is smart it’s pretty stupid[]. . . I know where u
26         drive [¶] what time u guys leave [¶] I know your every
           move. . . one of you will be dead by the end of the day
27         pick who it shall be.
28

                                             3
       Case 2:20-cr-00554-AB Document 1 Filed 11/06/20 Page 4 of 14 Page ID #:4



 1                    iv.   On or about August 12, 2020, text messages

 2   that included the following:

 3
           [P]eople will be there soon glad u wanted this . . .
 4         have either of u been raped I guess u will experience
           that soon [¶] I have someone following both u and
 5         [Victim 1] [¶] hope you and [Victim 1] enjoy being
           raped . . . told the guys to bring guns too this should
 6         be interesting they will be there soon . . . [Victim 1]
           gets what she deserves [¶] pain . . . they will be
 7         there in 10 minutes [¶] are u ready [¶] u may be sore
 8         after . . . think I’m joking watch u will see [¶] but
           then again u won’t be alive to see [¶] I have a sniper
 9         at the window shall I shoot . . . respond or I shoot.

10                    v.    On or about August 16, 2020, text messages that

11   included the following:

12         So hacking consists of breaking into a certain system
           or systems which allows the hacker to then break his
13         way into your device. Are you following along or to
           stupid to understand. I will continue due to your
14
           inconsistent stupidity. Once the hacker is in the
15         device he can access whatever he wants, . . . Payback
           is a bitch [Victim 2] and both you and [Victim 1] will
16         pay [¶] I’ll see on Tuesday.

17                    vi.   On or about August 16, 2020, text messages
18   that included the question, “What else do I need to bring for
19   Tuesday,” and included a photograph of the window to Victim 1’s
20   bedroom, which appeared to have been taken from outside the
21   house of Victim 1 and Victim 2.
22                    vii. On or about August 16, 2020, text messages
23   that included the following:
24
           I see you [¶] Time to kill you or [Victim 1] [¶] I see
25         your car [¶] Who will die tonight or on Tuesday during
           clinic . . . U either respond or I start shooting
26         whoever is in the room at the window adjacent to
           Topanga [¶] 1 minute [¶] 45 seconds until I start
27         shooting [¶] Want to see how serious I am [¶] I have a
           gun aimed right at both your mom and dad . . . If u
28
           don[’]t respond someone will die.
                                       4
       Case 2:20-cr-00554-AB Document 1 Filed 11/06/20 Page 5 of 14 Page ID #:5



 1                    viii.        On or about August 17, 2020, a text

 2   message that included the following: “[L]et’s see will I kill

 3   [Victim 1] today or tomorrow at practice [¶] since u don’t care

 4   and don’t want to respond why worry.”

 5                    ix.     On or about August 18, 2020, text messages

 6   that included the following: “I will see the both of you today

 7   who will die [¶]    Since u don’t care [¶] You won’t even know

 8   who I am.”

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       Case 2:20-cr-00554-AB Document 1 Filed 11/06/20 Page 6 of 14 Page ID #:6



 1                                      COUNT TWO

 2                     [18 U.S.C. §§ 2261A(2)(A)–(B), 2261(b)(5)]

 3        1.      Beginning on or about July 29, 2020, and continuing to at

 4   least on or about August 18, 2020, in Los Angeles County, within the

 5   Central District of California, and elsewhere, defendant ALEX SCOTT

 6   ROBERTS (“ROBERTS”), with the intent to harass and intimidate Victim

 7   2, used an interactive computer service, an electronic communication

 8   service, an electronic communication system of interstate commerce,

 9   and other facilities of interstate and foreign commerce, namely,

10   cellular telephone networks, interstate wires, and the Internet, to

11   engage in a course of conduct, described in paragraph 2 below, that

12   placed Victim 2 in reasonable fear of death and serious bodily injury

13   to Victim 2 and immediate family members of Victim 2, and that

14   caused, attempted to cause, and would reasonably be expected to cause

15   substantial emotional distress to Victim 2 and immediate family

16   members of Victim 2.

17        2.      Defendant ROBERTS’s course of conduct included, among other

18   things, the following:

19                a.    Between on or about August 11, 2020 and on or about

20   August 18, 2020, defendant ROBERTS sent numerous anonymous text

21   messages, from multiple telephone numbers, to Victim 2 (Victim 1’s

22   sister).   The text messages that defendant ROBERTS sent included the

23   following:

24                      i.   On or about August 11 and 12, 2020, text messages

25   that included the following:

26
           Since u think this is a game let’s change your mind on
27         that . . . Alright lets see what happens tomorrow then
           . . . Let’s have some fun with your cars right now [¶]
28         Until u respond [¶] Be there soon. . . Who’s window is

                                             6
       Case 2:20-cr-00554-AB Document 1 Filed 11/06/20 Page 7 of 14 Page ID #:7



 1         open [¶] Outside [¶] By [Victim 1’s] car [¶] Which
           tire.
 2

 3                    ii.   On or about August 12, 2020, text messages that

 4   included the following:

 5
           [S]o I’m outside . . . I see you guys [¶] look out
 6         towards topanga . . . [Victim 1] gets what she
           deserves. . . retribution is upon her and her life will
 7         depend on it. . . payback is a bitch and she gets what
           she deserves [¶] hope you all survive there will be
 8         blood . . .you wanted this so let’s show u how serious
 9         I am.

10                    iii. On or about August 12, 2020, text messages that

11   included the following:

12
           I’m outside [¶] too scared to talk [¶] is [Victim 1] or
13         [Victim 2] too scared [¶] poor babies . . . what
           happens if someone throws something over your wall [¶]
14         and it blows the house up . . . payback is a bitch for
           what [Victim 1] has done [¶] and she will pay [¶] and
15         so will u [Victim 2] . . . lucky for me I was able to
16         hack your WiFi so thanks for the shower videos of the
           both of you . . . let’s post these videos of the both
17         of u in the shower . . . worst thing to do is ignore
           [¶] that’s how people end up dead . . . be careful with
18         the brake lines [¶] I cut them last night . . . cops
           tell u not to respond pretty stupid when I’m right here
19         . . . so if u think ignoring me and not responding to
           me is smart it’s pretty stupid[]. . . I know where u
20
           drive [¶] what time u guys leave [¶] I know your every
21         move. . . one of you will be dead by the end of the day
           pick who it shall be.
22

23                    iv.   On or about August 12, 2020, text messages

24   that included the following:

25
           [P]eople will be there soon glad u wanted this . . .
26         have either of u been raped I guess u will experience
           that soon [¶] I have someone following both u and
27         [Victim 1] [¶] hope you and [Victim 1] enjoy being
           raped . . . told the guys to bring guns too this should
28         be interesting they will be there soon . . . [Victim 1]
                                             7
       Case 2:20-cr-00554-AB Document 1 Filed 11/06/20 Page 8 of 14 Page ID #:8



 1         gets what she deserves [¶] pain . . . they will be
           there in 10 minutes [¶] are u ready [¶] u may be sore
 2         after . . . think I’m joking watch u will see [¶] but
           then again u won’t be alive to see [¶] I have a sniper
 3
           at the window shall I shoot . . . respond or I shoot.
 4

 5                    v.      On or about August 16, 2020, text messages that

 6   included the following:

 7
           So hacking consists of breaking into a certain system
 8         or systems which allows the hacker to then break his
           way into your device. Are you following along or to
 9         stupid to understand. I will continue due to your
           inconsistent stupidity. Once the hacker is in the
10         device he can access whatever he wants, . . . Payback
11         is a bitch [Victim 2] and both you and [Victim 1] will
           pay [¶] I’ll see on Tuesday.
12

13                    vi.     On or about August 16, 2020, text messages

14   that included the question, “What else do I need to bring for

15   Tuesday,” and included a photograph of the window to Victim 1’s

16   bedroom, which appeared to have been taken from outside the

17   house of Victim 1 and Victim 2.

18                    vii. On or about August 16, 2020, text messages

19   that included the following:

20
           I see you [¶] Time to kill you or [Victim 1] [¶] I see
21         your car [¶] Who will die tonight or on Tuesday during
           clinic . . . U either respond or I start shooting
22         whoever is in the room at the window adjacent to
           Topanga [¶] 1 minute [¶] 45 seconds until I start
23         shooting [¶] Want to see how serious I am [¶] I have a
24         gun aimed right at both your mom and dad . . . If u
           don[’]t respond someone will die.
25

26                    viii.        On or about August 17, 2020, a text

27   message that included the following: “[L]et’s see will I kill

28

                                             8
       Case 2:20-cr-00554-AB Document 1 Filed 11/06/20 Page 9 of 14 Page ID #:9



 1   [Victim 1] today or tomorrow at practice [¶] since u don’t care

 2   and don’t want to respond why worry.”

 3                    ix.   On or about August 18, 2020, text messages that

 4   included the following: “I will see the both of you today who will

 5   die [¶]   Since u don’t care [¶] You won’t even know who I am.”

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      Case 2:20-cr-00554-AB Document 1 Filed 11/06/20 Page 10 of 14 Page ID #:10



 1                                     COUNT THREE

 2                               [18 U.S.C. § 875(c)]

 3        On or about August 12, 2020, in Los Angeles County, within the

 4   Central District of California, and elsewhere, defendant ALEX SCOTT

 5   ROBERTS, with intent to issue a threat and with knowledge that it

 6   would be viewed as a threat, knowingly transmitted in interstate and

 7   foreign commerce a communication containing a true threat to injure

 8   the person of another, that is, text messages to Victim 2 that

 9   included the following:

10         [S]o I’m outside . . . I see you guys [¶] look out
           towards topanga . . . [Victim 1] gets what she deserves
11         . . . retribution is upon her and her life will depend
           on it . . . payback is a bitch and she gets what she
12
           deserves [¶] hope you all survive there will be blood .
13         . . you wanted this so let’s show u how serious I am.

14

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                                            10
      Case 2:20-cr-00554-AB Document 1 Filed 11/06/20 Page 11 of 14 Page ID #:11



 1                                     COUNT FOUR

 2                               [18 U.S.C. § 875(c)]

 3        On or about August 12, 2020, in Los Angeles County, within the

 4   Central District of California, and elsewhere, defendant ALEX SCOTT

 5   ROBERTS, with intent to issue a threat and with knowledge that it

 6   would be viewed as a threat, knowingly transmitted in interstate and

 7   foreign commerce a communication containing a true threat to injure

 8   the person of another, that is, text messages to Victim 2 that

 9   included the following:

10         I’m outside [¶] too scared to talk [¶] is [Victim 1] or
           [Victim 2] too scared [¶] poor babies . . . what happens
11         if someone throws something over your wall [¶] and it
           blows the house up . . . payback is a bitch for what
12
           [Victim 1] has done [¶] and she will pay [¶] and so will
13         u [Victim 2] . . . lucky for me I was able to hack your
           WiFi so thanks for the shower videos of the both of you
14         . . . let’s post these videos of the both of u in the
           shower . . . worst thing to do is ignore [¶] that’s how
15         people end up dead . . . be careful with the brake lines
           [¶] I cut them last night . . . cops tell u not to
16
           respond pretty stupid when I’m right here . . . so if u
17         think ignoring me and not responding to me is smart it’s
           pretty stupid[]. . . I know where u drive [¶] what time
18         u guys leave [¶] I know your every move . . . one of you
           will be dead by the end of the day pick who it shall be.
19

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                                            11
      Case 2:20-cr-00554-AB Document 1 Filed 11/06/20 Page 12 of 14 Page ID #:12



 1                                     COUNT FIVE

 2                               [18 U.S.C. § 875(c)]

 3        On or about August 12, 2020, in Los Angeles County, within the

 4   Central District of California, and elsewhere, defendant ALEX SCOTT

 5   ROBERTS, with intent to issue a threat and with knowledge that it

 6   would be viewed as a threat, knowingly transmitted in interstate and

 7   foreign commerce a communication containing a true threat to injure

 8   the person of another, that is, text messages to Victim 2 that

 9   included the following:

10         [P]eople will be there soon glad u wanted this . . .
           have either of u been raped I guess u will experience
11         that soon [¶] I have someone following both u and
           [Victim 1] [¶] hope you and [Victim 1] enjoy being raped
12
           . . . told the guys to bring guns too this should be
13         interesting they will be there soon . . . [Victim 1]
           gets what she deserves [¶] pain . . . they will be there
14         in 10 minutes [¶] are u ready [¶] u may be sore after .
           . . think I’m joking watch u will see [¶] but then again
15         u won’t be alive to see [¶] I have a sniper at the
           window shall I shoot . . . respond or I shoot.
16

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                                            12
      Case 2:20-cr-00554-AB Document 1 Filed 11/06/20 Page 13 of 14 Page ID #:13



 1                                      COUNT SIX

 2                               [18 U.S.C. § 875(c)]

 3        On or about August 16, 2020, in Los Angeles County, within the

 4   Central District of California, and elsewhere, defendant ALEX SCOTT

 5   ROBERTS, with intent to issue a threat and with knowledge that it

 6   would be viewed as a threat, knowingly transmitted in interstate and

 7   foreign commerce a communication containing a true threat to injure

 8   the person of another, that is, text messages to Victim 2 that

 9   included the following:

10         I see you [¶] Time to kill you or [Victim 1] [¶] I see
           your car [¶] Who will die tonight or on Tuesday during
11         clinic . . . U either respond or I start shooting whoever
           is in the room at the window adjacent to Topanga [¶] 1
12
           minute [¶] 45 seconds until I start shooting [¶] Want to
13

14   //

15   //

16   //

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      Case 2:20-cr-00554-AB Document 1 Filed 11/06/20 Page 14 of 14 Page ID #:14



 1         see how serious I am [¶] I have a gun aimed right at both
           your mom and dad . . . If u don[’]t respond someone will
 2         die.
 3

 4                                            A TRUE BILL

 5

 6                                                     /S/
                                              Foreperson
 7

 8   NICOLA T. HANNA
     United States Attorney
 9

10

11   CHRISOPHER D. GRIGG
     Assistant United States Attorney
12   Chief, National Security Division

13   CAMERON L. SCHROEDER
     Assistant United States Attorney
14   Chief, Cyber & Intellectual
      Property Crimes Section
15
     ANIL J. ANTONY
16   Assistant United States Attorney
     Deputy Chief, Cyber &
17    Intellectual Property Crimes
      Section
18
     LAUREN RESTREPO
19   Assistant United States Attorney
     Cyber & Intellectual Property
20    Crimes Section

21

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                                            14


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