Case 3:i2-cr-00317-L Document 19 Filed 10/03/12 Page 1 of 11 PagelD 46 U.S. DISTRICT COURT

NORTHERN DISTRICT OF TEXAS FILED

IN THE UNITED STATES D STRICT COUR T ~" FOR THE NORTHERN DIS1RICT O 7 TjÇ?CA§

D A L L A S DIVIS ION C L E R K , U.S. DISTRICT COURT

UNITED STATES OF A M E R I C A § v1

Deputy

VS. § CRIMINAL NO.

B A R R E T T L A N C A S T E R B R O W N ( l ) § 8. " 1 2CB - 3 1 ? * I l

INDICTMENT

The Grand Jury charges:

INTRODUCTION

At ail times material to this indictment, or as otherwise specified,

1. Barrett Lancaster Brown created Project P M in approximately 2010. Project P M

was a IRC/wiki-based blogger network created to allow Brown and those he associated

with to share information and achieve or pursue certain goals. Barrett Lancaster Brown

used the website wiki.echelon2.org to operate Project P M .

2. On September 4, 2012, Barrett Lancaster Brown used his Twitter.com account

BarrettBrownLOL, and posted the following comments:

a. "Don't be a pussy. Call up every facist and tell them you're watching. http://www.youtube.com/watch?v=4gcptY8nel4 ... #ProjectPM."

b. "Have you doxed a pig today? Be ready for the dévolution - have a list informationliberation.com/?id=40815 #Anonymous."

c. "Don't know how to shoot? You've got five years to learn. Maybe less.http://www.youtube.com/watch?v=wkqSIZaBhUY&list=UUv 1F lZ4TdveCyva7okPRmSA&index=l&feature=plcp ... #Anonymous #ProjectPM #blackbloc."

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d. "#DHS stocking up on ammo. Are you? http://www.youtube.com/watch?v=wkqSIZaBhUY&list=UUvlFlZ4 TdveCyva7okPRmSA&index=l&feature=plcp ... Don't wait. Retaliate."

e. "Have a plan to kill every government you meet. #ProjectPM tinychat.com/BarrettBrown #Anonymous Echelon2.org."

3. On September 7, 2012, Barrett Lancaster Brown used his Twitter.com account

BarrettBrownLOL, and posted the following comments:

a. "Kids! Overthrow the US government loi https://www.youtube.com/watch?v=pHCdS70248g ..."

b. "@Badger32d I've experienced other end of the gun, watching mom detained by U.S. armed thugs. See you on the streets!"

c. "#ProjectPM - Everyone in #Anonymous with balls is either with us or awaiting trial. Don't wait. Retaliate."

4. On September 7, 2012, Barrett Lancaster Brown used his Twitter.com account

BarrettBrownLOL, and posted a message saying "Organize. Choose your pig. Make your

move. Pastebin.com/HFxBIHv #ProjectPM #Anonymous #blackbloc dévolution."

5. On September 8, 2012, Barrett Lancaster Brown used his Twitter.com account

BarrettBrownLOL, and posted the following comments:

a. "Democrats do not fear Republicans who fear no Democrat, but both will learn to fear anarchists now that net gives us revenge #ProjectPM."

b. "So now if I don't take my opiates I guess I get to feel 2 years of betrayal by country, loss of best kids in West to feds. Fuck you."

c. "Last outlet that ran my work, Guardian, no longer responding. Nothing restrains me now from finishing my real work #ProjectPM."

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d. "Journalists allow the guilty to escape. #ProjectPM ensures the guilty will be known to their children as they are, forever."

e. "Help #ProjectPM plan, exécute further attacks #PantherModerns tinychat.com/barrettbrown #Anonymous #Wikileaks http://cryptome.org/2012/09/frey-chat-brown-02.htm .. ."

f. "@_Dantalion No. I'd shoot you w/ my shotgun if you came near my home in Texas, where even I can legally kill ppl https://www.youtube.com/watch?v=wkqSIZaBhUY&list=UUvlFlZ4 TdveCyva7okPRmSA&index=2&feature=plcp . . ."

g. "Not mad at you, mad at #FBI @AaronBarr which I've got taken care of now anyway loi e-mail hacks pastebin.com/12crnMjP."

6. On September 10, 2012, Barrett Lancaster Brown used his Twitter.com account

BarrettBrownLOL and posted the following comments:

a. "#FBI Now you know I know. I get call from Agent [RS]1 in 24 hrs, my laptops on plane to Dallas or I release in 25 #Anonymous."

7. On September 10, 2012, Barrett Lancaster Brown used his Twitter.com account

BarrettBrownLOL, and re-posted the message " A dead man can't leak stuff... Illegally

shoot the son of a bitch."

8. On September 11, 2012, Barrett Lancaster Brown used his Twitter.com account

BarrettBrownLOL, and posted the following comments:

a. "0 uploading now, dropping in 30 minutes #Anonymous #Wikileaks #ProjectPM #PantherModerns #FBI #Agent[RS]."

b. "-1 youtube.com/watch?v=klvPlX... #Anonymous #ProjectPM #Wikileaks #FBI #PantherModerns #Agent[RS] #OffThePigs #Blackbloc."

Per local practice, the victim's name has been redacted from the Indictment. The rédaction will appear as [RS].

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c. "@AsheraResearch My mother is being threatened with charges by #FBI due in part to your lies. Mention her again and see what happens."

d. "If what #HBGary did to me was légal, it will be just as légal when I do some of it to #Agent[RS]."

e. "#ProjectPM backs up its claims, threats. Don't wait. Retaliate. #OpClydeTolson #Anonymous #Wikileaks http://www.youtube.com/watch?v=:klvPlXx60H4&feature::=youtu.be .. ."

f. "As I'il explain further tomorrow, I will regard any further armed raids as potential #Zeta assassination attempts and respond accordingly."

g. "#Agent[RS] claimed my warrants weren't public due to #Zeta threat. He knows it's serious and won't mind if I shoot any suspects."

h. "Threat to put my mom in prison last mistake #Agent[RS] will ever fucking make http://www.youtube.com/watch7vHdvP 1 Xx60H4&feature=autoplay&list= UUvlFlZ4TdveCyva7okPRmSA&playnext=l ... #OpClydeTolson."

9. On September 11, 2012, Barrett Lancaster Brown published a self made video

on YouTube.com, entitled Why FBI Agent [RS] Has Two Weeks To Send my Property

Back, Part 1/3.

10. On September 11, 2012, Barrett Lancaster Brown published a self made video

on YouTube.com, entitled FBI Ultimatum Pt 2. In the video, Brown stated:

a. "[T]his is part two of a two part séries of why I'm fucking angry."

b. "From now on I am a bad guy, and I'm going to prove that in the coming months, using the court System, using the média, using my group ProjectPM, which has always been secretly to some extent created for the purpose of wiping out this fucking government and certain média institutions, and through other means at my disposai, some of which are known, some of which are known to a few, and some of which are still secret.... I want everyone to know the

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demand I am making to the FBI today, which is that I will have my stuff returned to me in two weeks."

c. "They have two weeks to get send it ail back, and twenty-four hours from now I will receive a call from [RS] himself, apologizing for what happened."

11. On September 11, 2012, after Barrett Lancaster Brown published the two videos

on YouTube.com, he used his Twitter.com account BarrettBrownLOL, and stated "[d]one

for the day, see part 3 of #OpClydeTolson tomorrow. Send me info on #Agent[RS] - use

@AaronBarr ethics re: family members."

12. On September 12, 2012, Barrett Lancaster Brown published a self made video

on YouTube.com, entitled Why I'm Going to Destroy FBI Agent [RS] Part Three:

Revenge of the Lithe. In the video:

a. Brown called FBI Spécial Agent [RS] a "fucking chicken shit little faggot cocksucker" and indicated that "we are investigating [him] now."

b. Brown called FBI Spécial Agent [RS] "a criminal, who is involved in a criminal conspiracy."

c. Brown stated "[fjhat's why [RS]'s life is over, but when I say his life is over, I don't say F m going to kill him, but I am going to ruin his life and look into his fucking kids."

d. Brown stated "[a]ny armed officiais of the US government, particularly the FBI, will be regarded as potential Zeta assassin squads, and as the FBI and DPD know . . . I'm armed, that I corne from a military family, that I was taught to shoot by a Vietnam vet and by my father a master hunter . . . I will shoot ail of them and kill them if they corne."

e. Brown stated "[a]nd frankly, you know, it was pretty obvious I was

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going to be dead before I was forty or so, so, I wouldn't mind going out with two FBI sidearms like a fucking Egyptian Pharaoh. Adios"

13. When Barrett Lancaster Brown published the video Why I'm Going to Destroy

FBI Agent [RS] Part Three: Revenge of the Lithe on September 12, 2012, he inserted a

comment on YouTube.com requesting other persons to "[s]end ail info on Agent [RS] to

barriticus@gmail.com so FBI can watch me look up his kids."

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Case 3:12-cr-00317-L Document 19 Filed 10/03/12 Page 7 of 11 PagelD 52

COUNT ONE Internet Threats

18U.S.C. § 875(c)

The Grand Jury hereby adopts, realleges, and incorporâtes by référence ail of the

allégations in the Introduction of this Indictment.

From on or after March 6, 2012, through and including on or about September 12,

2012, in the Dallas Division of the Northern District of Texas, the défendant Barrett

Lancaster Brown, knowingly and willfully did transmit in interstate and foreign

commerce communications containing threats to injure the person of another, that being,

Barrett Lancaster Brown transmitted messages through the Internet on his Twitter.com

account and his YouTube.com account, threatening to shoot and injure agents of the

Fédéral Bureau of Investigation, and specifically focusing on Fédéral Bureau of

Investigation Spécial Agent [RS].

In violation of 18 U.S.C. § 875(c).

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Case 3:12-cr-00317-L Document 19 Filed 10/03/12 Page 8 of 11 PagelD 53

COUNT TWO Conspiracy to Make Publically Available

Restricted Personal Information of an Employée of the United States 18U.S.C. §371 (18U.S.C. § 119)

The Grand Jury hereby adopts, realleges, and incorporâtes by référence ail of the

allégations in the Introduction of this Indictment.

Between on or about March 5, 2012 through on or about September 12, 2012, in

the Dallas Division of the Northern District of Texas, the défendant Barrett Lancaster

Brown, knowingly and willfully did combine, conspire, confederate, and agrée with other

persons known and unknown to the grand jury, to commit an offense against the United

States, to wit: to make restricted personal information about Fédéral Bureau of

Investigation Spécial Agent [RS] and his immédiate family publically available with the

intent to threaten and intimidate the Spécial Agent and to incite the commission of a

crime of violence against the Spécial Agent in violation of 18 U.S.C. § 119, in that in

September 2012 in the Northern District of Texas, Barrett Lancaster Brown requested

another person known to the grand jury to assist him find on the Internet restricted

information about Fédéral Bureau of Investigation Spécial Agent [RS] and [RS]'s family,

and that other person agreed to do so, and furthermore, the other person did conduct a

search on the Internet for the restricted information.

In violation of 18 U.S.C. § 371 (18 U.S.C. § 119).

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COUNT THREE Retaliation Against a Fédéral Law Enforcement Officer

(18 U.S.C. §§115(a)(l)(B) and (b)(4))

The Grand Jury hereby adopts, realleges and incorporâtes by référence ail of the

allégations in the Introduction of this Indictment.

Between on or about March 5, 2012 through on or about September 12, 2012, in

the Dallas Division of the Northern District of Texas, the défendant Barrett Lancaster

Brown, did knowingly and willfully threaten to assault a Fédéral Law enforcement

officer, with the intent to impede, intimidate, and interfère with such Fédéral Law

enforcement officer while engaged in the performance of officiai duties, and with the

intent to retaliate against such Fédéral Law enforcement officer on account of the

performance of officiai duties.

In violation of 18 U.S.C. §§ 115(a)(l)(B) and (b)(4).

CANDINA S. H E A T H Assistant United States Attorney State of Texas Bar No. 09347450 1100 Commerce Street, 3rd Floor Dallas, Texas 75242 Téléphone: 214.659.8600 candina.heath@usdoj .gov

A TRUE BILL:

S A R A H R. S A L D A N A UNITED STATES ATTORNEY

Indictment - Page 9

Case 3:12-cr-00317-L Document 19 Filed 10/03/12 Page 10 of 11 P*agelD 55

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS

D A L L A S DIVISION

THE UNITED STATES OF A M E R I C A

v.

BARRETT L A N C A S T E R B R O W N

INDICTMENT

18 U.S.C. § 875(c) Internet Threats

18 U.S.C. §371 (18 U.S.C. § 119) Conspiracy to Make Publically Available Restricted Personal Information of an Employée

of the United States

18 U.S.C. §§115(a)(l)(B) and (b)(4) Retaliation Against a Fédéral Law Enforcement Officer

3 Counts

A true bill rendered

D A L L A S FOREPERSON

Filed in open court this day of October 2012

Clerk Défendant already in Fédéral Custody since 9/13/12 at Mansfield

UNITED STATES D f ô ^ ^ T / M A G I S T R A T E JUDGE y ^ ^ ^ ^ ^ ^ Magistrate Case pending 3:12-MJ-405 / < y / 3 / < ±

Case 3:12-cr-00413-B Document 1 Filed 12/04/12 Page 1 of 6 PagelD 1

CLF/X US DISTRICT COURT ; -RTHERN DIST.OF TX

IN THE UNITED STATES DISTRICT COURT flLED Q^\G\H FOR THE NORTHERN DISTRICT OF TEXAS D A L L A S DIVISION 2 » ' 2 D K ^ ™ . l ' 5 °

DEPUTY CLERK.

UNITED STATES OF A M E R I C A § §

VS. § NO. §

BARRETT L A N C A S T E R BROWN (1) § J[ # 1 2CR " 41 3 " B

The Grand Jury charges:

INDICTMENT

Count One Traffic in Stolen Authentication Features

(18 U.S.C. §§ 1028(a)(2), (b)(l)(B), and (c)(3)(A)) Aid and Abet

(18 U.S.C. §2)

On or about December 25, 2011, in the Dallas Division of the Northern District of

Texas and elsewhere, défendant Barrett Lancaster Brown, aided and abetted by persons

known and unknown to the Grand Jury, in and affecting interstate commerce, did

knowingly traffic in more than five authentication features knowing that such features

were stolen and produced without lawful authority, in that Brown transferred the

hyperlink "http://wikisend.com/download/597646/stratfor_full_b.txt.gz" from the Internet

Relay Chat (IRC) channel called "#Anonops" to an IRC channel under Brown's control

called "#ProjectPM," said hyperlink provided access to data stolen from the company

Stratfor Global Intelligence, to include in excess of 5,000 crédit card account numbers,

Indictment - Page 1

Case 3:12-cr-00413-B Document 1 Filed 12/04/12 Page 2 of 6 PageID 2

the card holders' identification information, and the authentication features for the crédit

cards known as the Card Vérification Values (CVV), and by transferring and posting the

hyperlink, Brown caused the data to be made available to other persons online without

the knowledge and authorization of Stratfor Global Intelligence and the card holders.

In violation of 18 U.S.C. §§ 2 and 1028(a)(2), (b)(l)(B), and (c)(3)(A).

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Case 3:12-cr-00413-B Document 1 Filed 12/04/12 Page 3 of 6 PageID 3

Count Two Access Device Fraud

(18 U.S.C. §§ 1029(a)(3) and (c)(l)(A)(i)) Aid and Abet

(18 U.S.C. §2)

From on or about December 25, 2011, through at least on or about March 6, 2012,

in the Dallas Division of the Northern District of Texas and elsewhere, défendant Barrett

Lancaster Brown, aided and abetted by persons known and unknown to the Grand Jury,

with intent to defraud did possess at least fifteen and more devices unauthorized access

devices in and affecting interstate and foreign commerce, in that Brown possessed stolen

crédit card account numbers and the authentication features for the crédit cards known as

the Card Vérification Values (CVV) without the knowledge and authorization of the card

holders.

In violation of 18 U.S.C. §§ 2 and 1029(a)(3), and (c)(l)(A)(i).

Indictment - Page 3

Case 3:12-cr-00413-B Document 1 Filed 12/04/12 Page 4 of 6 PageID 4

Counts Two Through Twelve Aggravated Identity Theft

(18 U.S.C. §§ 1028A(a)(l)) Aid and Abet

(18 U.S.C. § 2)

From on or about December 25, 2011 through at least on or about March 6, 2012,

in the Dallas Division of the Northern District of Texas and elsewhere, défendant Barrett

Lancaster Brown, aided and abetted by persons known and unknown to the Grand Jury,

during and in relation to a felony violation of 18 U.S.C. § 1028(a)(2), knowingly

transferred and possessed without lawful authority the means of identification of the

persons below referenced, said means of identification consisting of the crédit card

account numbers; the corresponding authentication features for the crédit cards known as

the Card Vérification Values (CVV); the card holders' names and usernames for online

account access; and the card holders' physical addresses, phone numbers, and email

addresses.

COUNT C A R D HOLDER

CITY, STATE A M E R I C A N EXPRESS CC # (last four digits)

CC C V V (redacted)

3 B M Houston, TX 5003 4*87

4 CD Dallas, TX 4011 9*71

5 B H Spicewood, TX 1007 4*28

6 B L Galveston,TX 2004 4*20

7 BS Dallas, TX 1009 8*55

8 BC Dallas, TX 3009 4*10

Indictment - Page 4

Case 3:12-cr-00413-B Document 1 Filed 12/04/12 Page 5 of 6 PagelD 5

9 B W Dallas, TX 2732 7*16

10 M T Coco Beach, FL

4007 9*98

COUNT C A R D HOLDER

CITY, STATE MASTER C A R D CC # (last four digits)

CC C V V (redacted)

11 K R Tucson, A Z 6394 4*8

12 BJ Richardson, T X

6444 4*3

In violation of 18 U.S.C. §§ 2 and 1028A(a)(l).

A TRUE BILL:

S A R A H R. S A L D A N A UNITED STATES ATTORNEY

Assistant United States Attorney Northern District of Texas State of Texas Bar No. 09347450 1100 Commerce Street, 3rd Floor Dallas, Texas 75242 office: 214.659.8600 fax: 214.659.8805 candina.heath@usdoj .gov

Indictment - Page 5

Case 3:12-cr-00413-B Document 1 Filed 12/04/12 Page 6 of 6 PagelD 6

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS

D A L L A S DIVISION

THE UNITED STATES OF A M E R I C A

v.

BARRETT L A N C A S T E R BROWN (1)

INDICTMENT

18 U.S.C. §§ 1028(a)(2), (b)(l)(B), and (c)(3)(A); 18 U.S.C. § 2 Traffic in Stolen Authentication Features; and Aid and Abet

18 U.S.C. §§ 1029(a)(3) and (c)(l)(A)(i); and 18 U.S.C. § 2 Access Device Fraud; and Aid and Abet

18 U.S.C. §§ 1028A(a)(l); and 18 U.S.C. § 2 Aggravated Identity Theft; and Aid and Abet

12 Counts

A true bill rendered

D A L L A S FOREEERSON

Filed in open court this day of December, 2012

Clerk Défendant already in Fédéral

UNITED STATES DiSTR4G

Cust since^JM2/af#ïansfit

[GfsTRATE JUDG'E Magistrate Case pending 3:12-MJ-405

Case 3:13-cr-00030-B ' Document 1 Filed 01/23/13 Page 1 of 4 PagelD 1

0 ^

' U S DISTRICT COURT N O R T H E R N DISTRICT OF T E X A S

FILED IN THE UNITED STATES DISTRICT COURT p~ FOR THE NORTHERN DISTRICT OF 1 E X A S

D A L L A S DIVISION

UNITED STATES OF A M E R I C A

VS.

JAN 2 3 2013

C L E R K , U.S.. DISTRICT C O U R T

B y . Deputy

§ NO. BARRETT L A N C A S T E R BROWN (1) § 3 - 1 3 C RO 0 3 0 " B

The Grand Jury charges:

INDICTMENT

Count One Obstruction: Concealment of Evidence

(18 U.S.C. § 1519) Aid and Abet

(18 U.S.C. §2)

On or about March 6, 2012, in the Dallas Division of the Northern District of

Texas, the défendant Barrett Lancaster Brown, aided and abetted by K M , did

knowingly conceal tangible objects, namely two laptop computers containing records,

documents, and digital data, with the intent to impede, obstruct, and influence the

investigation and proper administration of any matter within the jurisdiction of any

départaient and agency of the United States, and in relation to and in contemplation of

any such matter, in that Barrett Lancaster Brown and K M concealed two laptop

computers in K M ' s résidence in the Northern District of Texas prior to the exécution of a

search warrant at K M ' s résidence, said search warrant having been issued by a United

States Magistrate Judge in the Dallas Division of the Northern District of Texas, and the

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Case 3:13-cr-00030-B Document 1 Filed 01/23/13 Page 2 of 4 PageID 2

exécution of the search warrant was in relation to an investigation conducted by the

Dallas Division of the Fédéral Bureau of Investigation, an agency of the United States

Department of Justice.

In violation of 18 U.S.C. § 1519 and 18 U.S.C. §2 .

Indictment - Page 2

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Case 3:13-cr-00030-B Document 1 Filed 01/23/13 Page 3 of 4 PageID 3

Count Two Obstruction: Corruptly Concealing Evidence

(18 U.S.C. § 1512(c)(l)) Aid and Abet

(18 U.S.C. §2)

On or about March 6, 2012, in the Dallas Division of the Northern District of

Texas, the défendant Barrett Lancaster Brown aided and abetted by K M , did knowingly

and corruptly conceal and attempt to conceal records, documents, and digital data

contained on two laptop computers, with the intent to impair the integrity and availability

of the records, documents, and digital data contained on the laptop computers for use in

an officiai proceeding, that being: (1) a proceeding before a fédéral Grand Jury in the

Northern District of Texas; and (2) a proceeding before a United States Magistrate Judge

in the Northern District of Texas specifically related to search warrants issued on

March 5, 2012.

In violation of 18 U.S.C. § 1512(c)(l) and 18 U.S.C. § 2.

Assistant United States Attorney Northern District of Texas State of Texas Bar No. 09347450 1100 Commerce Street, 3rd Floor Dallas, Texas 75242 office: 214.659.8600 fax: 214.659.8805 candina.heath@usdoj .gov

Indictment - Page 3

Case 3:13-cr-00030-B Document 1 Filed 01/23/13 Page 4 of 4 PageID 4

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS

D A L L A S DIVISION

THE UNITED STATES OF A M E R I C A

v.

BARRETT L A N C A S T E R B R O W N (1)

INDICTMENT

18 U.S.C. § 1519; 18 U.S.C. § 2 Obstruction: Concealment of Evidence; A id and Abet

18 U.S.C. § 1512(c)(l); 18 U.S.C. § 2 Obstruction: Corruptly Concealing Evidence; A id and Abet

2 Counts

A true bill rendered

D A L L A S FOREPERSON

Filed in open court this_j____ day of January, 2013

Défendant Barrett Lancaster Brown in Fédéral Cust

UNITED STATES DISTRICT/MAGISTRATE JUDG No Criminal matter pending