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. - S .D I S T R I C T U R i . O 1 , , { l G I P 0 RC 0 i . t N l L CRIMINAL No. 3:$CR/O (rrPS VIOLATIONS: l8 U.S.C. 1001[False Statements] $ INDICTMENT

The GrandJury Charges at all times relevantto this lndicftnent: that COLTNT ONE FalseStatements the Government to 18U.S.C. 1001 $ l. 2. Defendant NOUEL ALBA resided the Stateof New York. in ALBA hascontrolovera Facebook account underthe screen nameVictorian

GlamFairys(*VGF") andis the ownerof a PayPal account underthe e-mailaddress of nouelalba45 3@gmail.com. 3. On December 14,2012,Adam Laruashotandkilled 26 individuals, including20

childrenagessix or seven, Sandy at Hook Elementary SchoolinNewtowU Connecticut. 4. On or aboutDecember 14,2012at approximately l:30 p.m.,ALBA posted on

anotherFacebook user'spagefalsely claiming to be the aunt of a child who attended Sandy Hook ElementarySchoolandto haveprovidedpicturesto law enforcement officersto help identi$ victims. 5. page"My Also on or aboutDecember 14,2012,ALBA posted her Facebook on

heartis entirelydestroyed knowingmy little manis gone." At thattime, ALBA hadposted on

includingthe pagepicturesof childrenkilled in the Newtownschoolshooting, her Facebook child ALBA falselyclaimedwasher nephew. 6. on the I5,20|2,ALBA posted followingfalseinformation On or aboutDecember

page: her Facebook We've setup a funeralfund for my brotherandfamilies. Anyone wilting to makea donationcanmakeoneeitherthroughpaypal@ or by REDACTED com DirectDeposit JPMorgan @ Account Bank NA & JPMCRoutingNumber0REDACTED 9 Chase for We Number REDACTED 99. like to Thankeveryone your just pray for us but for to prayers.We askthat you continue not todayaswell as the familieswho havelost their kids andparents this nightmare.Thatneedour for all thosekids who experienced supportright now. Yesterdayhasbeena completenightmarefor manyof us. Many of us hadhopethat our lovedoneswhereelse where safe. Reality set in whenthey askedfor photosand if our loved oneshad any markson their body that they could have identiS. A part of me regretshaving to be the oneto identi$ my body. I don't think I could everfully recoverfrom what I nephews sawandhis lifelessbodyjust layrngthere. I couldn't helpbut to hold my nephewin my armsandthan give my brotherand sisterin law the badnews.. . . 7. of with VICTIM DONOR#1, a resident the ALBA alsospokeon the telephone

Stateof New York, and falsely claimedto havegoneinto SandyHook ElementarySchoolto identiff her nephew'sbody. 8. to ALBA alsowrotethe following in text messages VICTIM DONOR#1:
a. the grooup an fb" b.

"Im stayingstrong. Justfinishedthe funeralarrangement.I postedit in

at Purportingto be in attendance a prayetserviceheld at NewtownHigh

hearingthe rabbising [at] Newtownhigh for the service School: "I just died and went.toheaven presis heremet with mostthe families."
ln responseto VICTIM DONOR #1's question about whether ALBA was

spoke: "No im sittingin my car. BarakObama still at the prayerservicewhenPresident


EmotionallyI cantdeal.withit right now..tomonow ill see[ALBA's purported nephew] a in casket that will be hardenough handle. GoodGod.Im surehell give a goodspeech. and He to met with us hugged evencryd with us. Hes.Reallydownto earth" us d. In response VICTIM DONOR#l's inquiryasto ALBA's emotional to

nephew] well-being: o'Ima mess. Not lookingforwardto seethat casket and [ALBA's purported in it. Scaryfeelingcause that is what will kill us all today. 11 gun shotin his little bodyor take thosebullets. The guilt we havejust keeps building up. I can't barethe pain the fearhe went to through. We alwayspromised protecthim andthe ltime we needed be therewe weren't to thereto protecthim" e. my hearing but "It's hardhavinhto leaveyour babyat a cemetery harder

kids to sisterin law keepsayinghow sheis suppose live withouther baby. Harderfor her hese i alreadylost a brotherthey can't losetheir mother. Me cause can't think as [ALBA's purported is peoplein her stateof mind andthe outcome nevera good nephew's]auntanymore. I've seen one. Which is why ima stick anround." g. postings text messages, individuals, and Basedon ALBA's falseFacebook

December between account moneyto ALBA's PayPal includingVICTIM DONOR #1, donated 18, 15,2012andDecember 2012. 10. in 21,2012,ALBA voluntarilyparticipated a telephone On or aboutDecember

("FBI"). Bureauof Investigation interviewwith SpecialAgentsof the Federal 11. amongotherthings: to It wasmaterialto the FBI's investigation determine, a. pageandwasresponsible whetherALBA hadcontrolover her Facebook

with the Newtownschool connection her concerning personal for postingmisrepresentations for shooting for postingsolicitations donations; and


b. donors;and c.

whether ALBA hadusedothermeans solicit donations to from victim-

whether ALBA hadcontrolover her PavPal account. which victimto

donorshadsenttheir donations.
12. On or about December 21,2012, within the District of Connecticut and

elsewhere,defendantNOUEL ALBA, in a matter within the jurisdiction of the FederalBureau of Investigation, an agency of the executive branch of the Government of the United States,did knowingly and willfully make a false, fraudulent, and fictitious material statement and representation, that: in a. ALBA falsely statedto the FBI SpecialAgents that she was not involved

in any postings on her Facebookpage regarding her personalconnection to Newtown school shooting; in truth and in fact, as ALBA well knew, ALBA had used her Facebookpageto misrepresent that she was the aunt of a Newtown school shooting victim and was collecting donationsfor her nephew's funeral fund, inducing victim-donors, including VICTIM DONOR#1, to sendmoney to ALBA's PayPal account; b. ALBA falsely statedto the FBI SpecialAgents that she did not have any

phone contact with any person about posts on her Facebook page regarding the Newtown school shooting; in truft and in fact, as ALBA well knew, ALBA had repeated, confirmed and expanded on the misrepresentations posted on her Facebook page-including that she was the aunt of a

Newtown school shooting victim and was collecting donationsfor her nephew's funeral fundin text messages and telephonecalls with victim-donors, including with VICTIM DONOR #1, inducing them to sendmoney to ALBA's PayPal account;



ALBA falselystated the FBI Special to Agentsthat,whenher PayPal

account informationwasposted her Facebook to pageon Decemberl5,20l2,ALBA's paypal account wasinactiveandthat did not evenknow the password because hadnot usedit for so she long; in truth andin fact,asALBA well knew,ALBA hadloggedinto her PayPal account on December 14,2012. All in violationof Title 18,UnitedStates Code,Section 1001(a). A TRUE BILL