Case 8:16-cr-00246-PWG Document 16 Filed 05/18/16 Page 1 of 6

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND

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UNITED STATES OF AMERICA

* * * * *

v. CALEB ANDREW BAILEY,

* Defendant

*

*

* * *

* * * *

*

(Unlawful Transport of Explosive Materials by a Non-Licensee, 18 U.S.c. ~~ 842(a)(3)(A), 844(a)(I); Illegal Possession of a Machine Gun, 18 U.S.c. ~~ 922(0), 924(a)(2); Production and Attempted Production of Child Pornography, 18 U.S.C. ~ 2251(a) and (c); Possession of Child Pornography, 18 U.S.c. ~ 2252A(a)(5)(B); Forfeiture, 18 U.S.c. ~~ 924(d)(I), 2253, 28 U.S.c. ~ 2461(c), 21 U.S.c. ~ 853)

*

******* INDICTMENT COUNT ONE The Grand Jury for the District of Maryland charges that: On or about February 18, 2016, in the District of Maryland, the defendant, CALEB ANDREW BAILEY, not being a licensee and permittee as defined in Title 18, United States Code, Section 841, knowingly transported explosive materials, to wit. 119 rounds ofreloaded

.50 caliber eartridges

with M48A 1 incendiary projectiles and 200 rounds of 14.5mm M 183A I spotting projeetiles that contain an explosive charge, to another person who was not a licensee and permittee as defined in Title 18, United States Code, Section 841.

18 U.S.c.

99

842(a)(3)(A), 844(a)(I)

Case 8:16-cr-00246-PWG Document 16 Filed 05/18/16 Page 2 of 6

COUNT TWO The Grand Jury for the District of Maryland further charges that: On or about May 5, 2016, in the District of Maryland, the defendant, CALEB ANDREW BAILEY, knowingly possessed a machine gun, that is, a Spikes Tactical Model ST-15, bearing serial number RM-I 0815, as defined by Title 26, United States Code, Section 5845(b).

18 U.S.C.

SS 922(0),

924(a)(2)

2

Case 8:16-cr-00246-PWG Document 16 Filed 05/18/16 Page 3 of 6

COUNT THREE The Grand Jury for the District of Maryland further charges that: Between in or about March 2015 and in or about January 2016, in the District of Maryland, the defendant, CALEB ANDREW BAILEY, knowingly attempted to and did employ, use, persuade, induce, entice, and coerce a minor to engage in any sexually explicit conduct as defined in Title 18, United States Code, Section 2256(2), for the purpose of producing a visual depiction of such conduct, and the visual depiction had been produced using materials that had been mailed, shipped, and transported in interstate and foreign commerce by any means, including by computer.

18 U.S.C.

9 2251(a)

and (e)

3

Case 8:16-cr-00246-PWG Document 16 Filed 05/18/16 Page 4 of 6

COUNT FOUR The Grand Jury for the District of Maryland further charges that: On or about May 9, 2016, in the District of Maryland, the defendant, CALEB ANDREW BAILEY, knowingly possessed any material that contained an image of child pornography, as defined in Title 18, United States Code, Section 2256(8), which image had been shipped and transported using any means or facility of interstate and foreign commerce and in or affecting interstate and foreign commerce by any means, including by computer, and that was produced using materials that have been mailed, shipped, and transported in and affecting interstate and foreign commerce by any means, including by computer.

18 U.S.C.

S 2252A(a)(5)(B)

4

Case 8:16-cr-00246-PWG Document 16 Filed 05/18/16 Page 5 of 6

FORFEITURE ALLEGATION The Grand Jury for the District of Maryland further finds that: Explosives and Machine Guns Forfeiture 1.

Pursuant to Title 18, United States Code, Section 924( d) and Title 28, United

States Code, Section 2461 (c), upon conviction of the offenses set forth in Counts One and Two of this Indictment. the defendant. CALEB ANDREW BAILEY, shall forfeit to the United States any explosive or machinegun involved or used in such offenses. Child Pornographv Forfeiture 2.

Pursuant to Title 18, United States Code. Section 2253, upon conviction of the

offenses set forth in Counts Three and Four of this Indictment, the defendant, shall forfeit to the United States of America: a.

Any visual depiction described in Title 18, United States Code, Sections

2251 and 2252A, or any book, magazine, periodical, tilm, videotape, or other matter which contains any such visual depiction, which was produced, transported, mailed, shipped or received in violation of Title 18. United States Code, Chapter liD; b.

Any property. real or personal. constituting or traceable to gross profits or

other proceeds obtained from the offenses; and c.

Any property, real or personal, used or intended to be used to commit or to

promote the commission of the ofTenses.

5

Case 8:16-cr-00246-PWG Document 16 Filed 05/18/16 Page 6 of 6

Substitute Assets 3.

Ifany of the property described above, as a result of any act or omission of the

defendant a.

cannot be located upon the exercise of due diligence;

b.

has bcen transferred or sold to, or deposited with, a third party;

c.

has been placed beyond the jurisdiction of the court;

d.

has been substantially diminished in value; or

e.

has been commingled with other property which cannot be divided without difficulty,

the United States of America shall be entitled to forfeiture of substitute property pursuant to Title 21, United States Code, Section 853(p), as incorporated by Title 18, United States Code, Section 2253(b).

18 U.S.C. 28 U.S.c. 18 U.S.C. 21 U.S.c.

SS 924(d) S 2461(c) S 2253 S

853

f:;c£:f. ~

od J. Rosenstem United States Attorney

A TRUE BILL:

SIGNATURE REDACTED

Date: May 18, 2016

6

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