Full text
Case 2:24-cr-00383-HCN Document 1 Filed 11/20/24 PageID.1 Page 1 of 4
TRINA A. HIGGINS, United States Attorney (#7349)
CAROL A. DAIN, Assistant United States Attorney (#10065)
Attorneys for the United States of America
Office of the United States Attorney
111 South Main Street, Suite 1800
FILED US District Cout"t -UT
Salt Lake City, Utah 84111-2176
NOV 20 '24 PMOl:23
Telephone: (801) 524-5682
IN THE UNITED STATES DISTRICT COURT
DISTRICT OF UTAH
UNITED STATES OF AMERICA, INDICTMENT
Plaintiff, VIOLATIONS:
vs. Count 1: 18 U.S.C. § 2251(a) and (e),
Production of Child Pornography;
BRENT RICHARD JOHNSON,
Count 2: 18 U.S.C. § 2252A(a)(5)(B),
Defendant. Possession of Child Pornography.
Case: 2:24-cr-00383
Assigned To : Nielson, Howard C., Jr
Assign. Date: 11/20/2024
The Grand Jury Charges:
COUNT 1
18 U.S.C. § 2251(a) and (e)
(Production of Child Pornography)
Between on or about August 4, 2013, and on or about November 5, 2013, in the
District of Utah,
BRENT RICHARD JOHNSON,
Case 2:24-cr-00383-HCN Document 1 Filed 11/20/24 PageID.2 Page 2 of 4
defendant herein, did employ, use, persuade, induce, entice and coerce Minor A, to
engage in sexually explicit conduct for the purpose of producing any visual depictions of
such conduct, knowing and having reason to know that such visual depiction would be
transported and transmitted using any means and facility of interstate and foreign
commerce and in and affecting interstate and foreign commerce; using materials that
have been mailed, shipped, and transported in and affecting interstate and foreign
commerce by any means, including by computer; and the visual depiction was
transported and transmitted using any means and facility of interstate and foreign
commerce and in and affecting interstate and foreign commerce, and attempted to do so;
all in violation of 18 U.S.C. § 2251(a) and (e).
COUNT2
18 U.S.C. § 2252A(a)(5)(B)
(Possession of Child Pornography)
Beginning on or about August 4, 2013, and continuing until on or about April 25,
2024, in the District of Utah,
BRENT RICHARD JOHNSON,
defendant herein, did knowingly possess, and knowingly access with intent to view, any
material that contains an image of child pornography, as defined in 18 U.S.C. § 2256(8),
that had been mailed, shipped, and transported using any means and facility of interstate
and foreign commerce and in and affecting interstate and foreign commerce by any
means, including by computer, and that was produced using materials that have been
2
Case 2:24-cr-00383-HCN Document 1 Filed 11/20/24 PageID.3 Page 3 of 4
mailed, shipped, and transported in and affecting interstate and foreign commerce by any
means, including by computer and attempted to do so; all in violation of 18 U.S.C. §
2252A(a)(5)(B).
Pursuant to 18 U.S.C. § 2252A(b)(2), notice is given that at least one image of
child pornography possessed by defendant JOHNSON involved a prepubescent minor
and a minor who had not attained 12 years of age.
NOTICE OF INTENT TO SEEK FORFEITURE
Pursuant to 18 U.S.C. § 2253, upon conviction of any offense violating 18 U.S.C.
§ 2251, the defendant(s) shall forfeit to the United States of America: (i) any visual
depiction described in 2251, 2251A, or 2252, 2252A, 2252B, or 2260 ofthis chapter, or
any book, magazine, periodical, film, videotape, or other matter which contains any such
1
visual depiction, which was produced, transported, mailed, shipped, or received in
violation of this chapter; (ii) any property, real or personal, constituting or traceable to
gross profits or other proceeds obtained from such offense; and (iii) 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 to be forfeited includes,
but is not limited to:
■ HP Tower serial number: 3CR334004V
■ HP computer serial number: 8CC93 71 VJ9
■ ASUS Laptop serial number: 12ML8N0LP02S87935B
■ Toshiba Hard Drive serial number: X2QJFSXWSSX3
3
Case 2:24-cr-00383-HCN Document 1 Filed 11/20/24 PageID.4 Page 4 of 4
■ Go Pro s/ SD card
■ Various Thumb Drives
■ Substitute property as allowed by 21 U.S.C. § 853(p) and 18 U.S.C. § 2253(b).
A TRUE BILL:
FOREPERSON OF~
IL ND JURY
TRINA A. HIGGINS
United States Attorney
Assistant United States Attorney
4