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Indictment — United States v. Daniel Nathan West, No. 4:20-cr-00032

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An Indictment, Document 2, filed 02/06/20, in United States of America v. Daniel Nathan West, Case 4:20-cr-00032-GKF, Northern District of Oklahoma. Under the heading THE GRAND JURY CHARGES, COUNT ONE (Distribution and Receipt of Child Pornography) charges that from on or about May 17, 2019, to on or about December 17, 2019, the defendant knowingly distributed and received visual depictions of a minor engaging in sexually explicit conduct. COUNT TWO (Possession of Child Pornography) charges knowing possession and access with intent to view such depictions. A Forfeiture Allegation lists a ZTE cellular phone and an ARCA Tablet. The signature block names R. Trent Shores, United States Attorney, and Christopher J. Nassar, Assistant United States Attorney.

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Case 4:20-cr-00032-GKF Document 2 Filed in USDC ND/OK on 02/06/20 jBeor TE 4

IN THE UNITED STATES DISTRICT COURT

FEB - 6 2020

Mark C. McCartt, Clerk
.S. DISTRICT COURT

FOR THE NORTHERN DISTRICT OF OKLAHOMA

UNITED STATES OF AMERICA,
Plaintiff,

Vv.

DANIEL NATHAN WEST,

Defendant.

THE GRAND JURY CHARGES:

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Case No. —26-€R O35 ar
2 GKF

INDICTMENT

[COUNT 1: 18 U.S.C. §§ 2252(a)(2)
and (b)(1): Distribution and Receipt
of Child Pornography;

COUNT 2: 18 U.S.C. §§ 2252(a)(4)(B)
and 2252(b)(2) — Possession of Child
Pornography;

Forfeiture Allegation: 18 U.S.C. §
2253(a) — Child Pornography
Forfeiture]

COUNT ONE

[18 U.S.C. §§ 2252(a)(2) and (b)(1)]

From on or about May 17, 2019, to on or about December 17, 2019, in the Northern

District of Oklahoma and elsewhere, the defendant, DANIEL NATHAN WEST, did

knowingly distribute and receive visual depictions of a minor engaging in sexually explicit

conduct, using any means and facility of interstate and foreign commerce, and that had been

shipped and transported in and affecting interstate and foreign commerce,

and which

contained materials that had been so shipped and transported, by any means including by

computer. The production of such visual depictions involved the use of a minor engaging in

sexually explicit conduct and the visual depictions were of such conduct.

All in violation of Title 18, United States Code, Sections 2252(a)(2) and 2252(b)(1).
Case 4:20-cr-00032-GKF Document 2 Filed in USDC ND/OK on 02/06/20 Page 2 of 3

COUNT TWO
[18 U.S.C. §§ 2252(a)(4)(B) and 2252(b)(2)]

From on or about May 17, 2019, to on or about December 17, 2019, in the Northern
District of Oklahoma and elsewhere, the defendant, DANIEL NATHAN WEST,
knowingly possessed and knowingly accessed with intent to view visual depictions of a
minor engaging in sexually explicit conduct in one or more graphic image files and video
files. The production of the visual depictions involved the use of at least one prepubescent
minor and a minor who had not attained 12 years of age engaging in sexually explicit
conduct. The visual depictions had been mailed, and had been shipped and transported in
and affecting interstate and foreign commerce, and had been shipped and transported using
means and facilities of interstate and foreign commerce, and were produced using materials
which had been so mailed and shipped and transported by any means including by
computer.

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

2252(b)(2).
Case 4:20-cr-00032-GKF Document 2 Filed in USDC ND/OK on 02/06/20 Page 3 of 3

FORFEITURE ALLEGATION
[18 U.S.C. § 2253(a)]

The allegations contained in this Indictment are hereby realleged and incorporated
by reference for the purpose of alleging forfeitures pursuant to Title 18, United States Code,
Section 2253(a).

Upon conviction of either of the offenses alleged in this Indictment, as a part of his
sentence, the defendant, DANIEL NATHAN WEST, shall forfeit to the United States,
any property constituting, or derived from, or traceable to, the proceeds obtained, directly
or indirectly, as a result of such violations, and any property, real or personal, that was used
or intended to be used to commit or to facilitate the violation of federal law. The property
to be forfeited includes any computers, laptops, cellular phones, and all peripheral
equipment, but is not limited to:

ELECTRONICS

1. A ZTE cellular phone, Model Z557BL, serial number 320286640278; and

2. ARCA Tablet, unknown identifiers, recovered during the execution of a search
warrant at 701 North Sioux Avenue on December 17, 2019.

All pursuant to Title 18, United States Code, Section 2253(a).

R. TRENT SHORES A TRUE BILL
UNITED STATES ATTORNEY

LE. ___ /s/ Grand Jury Foreperson

CHRISTOPHER J. NASSAR Grand Jury Foreperson
Assistant United States Attorney


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