Superceding Indictment
THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
UNITED STATES OF AMERICA )
No. 07 CR 530 v. DANIEL RAPPE
Violations: Title 18, United
States Code, Sections 1519,
2232,2250,371, and 2
SUPERSEDING INDICTMENT
COUNT ONE
The SPECIAL JUNE 2007 GRAND JURY CHARGES:
Beginning on or about March 16, 2007, and continuing through on or about March 19, 2007, in DuPage County, in the Northern District of Illinois, Eastern Division, DANIEL RAPPE, defendant herein, did conspire with Individual A and with others known and unknown to the United States to commit offenses against the United States, namely, to:
(a) knowingly alter, destroy, mutilate, and conceal a record, document, or tangible object, namely, data on certain computers, with the intent to impede, obstruct, and influence the investigation and proper administration of a matter within the jurisdiction of a department or agency of the United States, namely, the U.S. Marshal’s Service and the Bureau of Immigration and Customs Enforcement, and in relation to and in contemplation of such a matter; in violation of Title 18, United States Code, Sections 1519 and 2; and
(b) before a search for and seizure of property, namely, data on certain computers, by a person authorized to make such search or seizure, to knowingly destroy, damage, waste, dispose of, transfer, and otherwise take any action for the purpose of preventing and impairing the Government’s lawful authority to take such property into its custody and control; in violation of Title 18, United States Code, Sections 2232 and 2;
In furtherance of the conspiracy, and to effect the unlawful objects of the conspiracy, defendant DANIEL RAPPE committed the following overt acts in the Northern District of Illinois:
(a) On or about March 18, 2007, the defendant met with Individual A and instructed Individual A to destroy the data on certain computers in the residence that the defendant and Individual A shared, through the use means that included Individual A’s use of computer wiping software;
(b) On or about March 19,2007, the defendant called Individual A several times and, believing that certain computers in the residence that the defendant shared with Individual A would be the subject of a federal search warrant, instructed Individual A in coded language to destroy data on those computers;
(c) On or about :March 19, 2007, the defendant caused Individual A to destroy the data on certain computers in the residence that the defendant shared with Individual A-data that the defendant believed would be the subject of a federal search warrant-through means that included Individual A’s use of computer wiping software; and
(d) On or about March 19, 2007, the defendant caused Individual A to remove a computer hard drive that the defendant believed would be the subject of a federal search warrant from the residence that the defendant shared with Individual A;
In violation of Title 18, United States Code, Section 371.
2 COUNT TWO
The SPECIAL JUNE 2007 GRAND further charges:
On or about March 19, 2007, in DuPage County, in the Northern District of Illinois, Eastern Division, DANIEL RAPPE, defendant herein, did knowingly alter, destroy, mutilate, and conceal a record, document, or tangible object, namely, data on certain computers; with intent to impede, obstruct, and influence the investigation and proper administration of a matter within the jurisdiction of a department or agency of the United States, namely, the U.S. Marshal’s Service and the Bureau of Immigration and Customs Enforcement, and in relation to and contemplation of such a matter;
In violation of Title 18, United States Code, Sections 1519 and 2.
3 COUNT THREE
The SPECIAL JUNE 2007 GRAND WRY further charges:
On or about March 19, 2007, in DuPage County, in the Northern District of Illinois,
Eastern Division,
DANIEL RAPPE
defendant herein, before a search for and seizure of property by a person authorized to make
such search or seizure, did knowingly destroy, damage, and otherwise take any action, and
knowingly attempt to destroy, damage or otherwise take any action, for the purpose of
preventing and impairing the Government’s lawful authority to take such property into its
custody or control;
In violation of Title 18, United States Code, Sections 2232 and 2.
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COUNT FOUR
From on or about March 6, 2007 through on or about March 18, 2007, in the Northern
District of Illinois, Eastern Division, and elsewhere,
DANIEL RAPPE,
defendant herein, an individual required to register as a sex offender under the Sex Offender
Registration and Notification Act, Title 42 United States Code, Sections 16911 and 16913, after
receiving a conviction in Illinois for Criminal Sexual Assault and another conviction in Illinois
for Aggravated Criminal Sexual Abuse, did knowingly fail to register and update a registration,
after traveling in interstate commerce by leaving the Northern District ofIllinois and traveling
to Indiana on or about February 27,2007;
In violation of Title 18, United States Code, Section 2250.
A TRUE BILL:
FOREPERSON
UNITED STATES ATTORNEY
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