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IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA




UNITED STATES OF AMERICA : CRIMINAL NO.

v. : DATE FILED

CHRISTINE YODER

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VIOLATIONS:

18 U.S.C. ' 2251(a) (employing a
child to produce images of the child
engaging in sexually explicit conduct
B 2 counts);
18 U.S.C. ' 2252(a)(1) (distributing
material involving the sexual
exploitation of children B2 counts)

Notice of forfeiture

INDICTMENT

COUNT ONE

THE GRAND JURY CHARGES THAT:

BACKGROUND

At all times material to this indictment,

1. Defendant CHRISTINE YODER lived in Philadelphia, in the Eastern District of
Pennsylvania, having custody and control of her two minor female children under the age of 18:
Minor #1, known to the grand jury, was approximately six years old; and Minor #2, known to the
grand jury, was approximately 16 months old.
2. A confidential source (CS) who was cooperating with the Federal Bureau of
Investigation (FBI) lived in Michigan where he corresponded via the Internet with defendant
CHRISTINE YODER.

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3. An undercover special agent (UC) with the FBI worked in Detroit, Michigan,
where, while posing as the CS, he corresponded via the Internet with defendant CHRISTINE
YODER.
THE CHILD EXPLOITATION ACTIVITY
4. From as early as in or around March 2014 through on or about May 23, 2014,
defendant CHRISTINE YODER used her Motorola Droid Ultra cellular telephone to take
numerous photographs of Minor #1 that depicted Minor #1 engaging in sexually explicit conduct,
as that term is defined in Title 18, United States Code, Section 2256. Defendant YODER took
these photographs, at least in part, to send to men via the Internet.
5. On or about May 21, 2014, defendant CHRISTINE YODER began engaging in
chat sessions with the CS via Internet social networking services, Mocospace.com and Kik
Messenger. Defendant YODER used the screen name sexygirl32 on Mocospace.com, and
freakygirl82 on Kik Messenger. Defendant YODER used these social networking services to
offer her daughter, Minor #1, to the CS for sexual activity.
6. On or about May 21, 2014, via Kik Messenger, defendant CHRISTINE YODER
sent the CS a photograph that defendant YODER had produced of Minor #1 that depicted Minor
#1 engaging in sexually explicit conduct.
7. On or about May 21, 2014, after sending the CS the pornographic photograph of
Minor #1, defendant CHRISTINE YODER offered to fly Minor #1 to Detroit, Michigan for sexual
activity with the CS. Defendant YODER told the CS that she would give Minor #1 to the CS for
a sexual relationship and that the CS would have her til u [the CS] die. Defendant YODER
said that she was very serious about sending her daughter to Michigan and described the size
clothes that the CS would need to buy for Minor #1. Defendant YODER asked the CS if he had a

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double bed for them to sleep in together and said that she hoped that the CS would get Minor #1
pregnant one day so that defendant YODER could be a grandmother.
8. Later on May 21, 2014, the UC took over the CSs account on Kik Messenger and,
while posing as the CS, continued the correspondence with defendant CHRISTINE YODER.
9. On or about May 21, 2014, defendant CHRISTINE YODER, via Kik Messenger,
sent the UC a photograph that defendant YODER had produced of Minor #1 that depicted Minor
#1 engaging in sexually explicit conduct. The image was a close up that depicted Minor #1s
vagina being spread open by an adult hand. The UC asked defendant YODER if the adult hand was
defendant YODERs hand, and defendant YODER said that it was. The UC and defendant
YODER then continued the conversation on Kik Messenger about sending Minor #1 to Michigan
to be sexually assaulted.
10. On or about May 22, 2014, via Kik Messenger, defendant CHRISTINE YODER
gave the UC information that he needed to purchase an airplane ticket for Minor #1 to travel to
Michigan, including the full name and birth date of Minor #1.
11. On May 23, 2014, via Kik Messenger, defendant CHRISTINE YODER provided
her mobile telephone number, as that information was also required for the purchase of an airplane
ticket for Minor #1. Defendant YODER then reiterated that she was very serious about sending
her daughter to Michigan.
12. On or about May 23, 2014, defendant CHRISTINE YODER, via Kik Messenger,
sent the UC explicit messages about the UC engaging in sexual activity with Minor #1: she loves
u, Yea she wants ur dick in her, Yea are u going to eat her pussy, Mmm and fuck her all the
time. Defendant YODER then told the UC, I dont want any contact after u take her. After

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having sent the UC non-pornographic photographs of Minor #1, defendant YODER told the UC,
Thats my 6 yr old Urs now.
13. From as early as in or around March 2014 through on or about May 23, 2014, in the
Eastern District of Pennsylvania, defendant
CHRISTINE YODER

employed, used, persuaded, induced, enticed, and coerced Minor #1 to engage in sexually explicit
conduct for the purpose of producing visual depictions of such conduct. Those visual depictions
were produced using materials that had been mailed, shipped, and transported in and affecting
interstate and foreign commerce, and those visual depictions were actually transported and
transmitted using a means and facility of interstate and foreign commerce, that is, the Internet.
In violation of Title 18, United States Code, Section 2251(a).


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COUNT TWO
THE GRAND JURY FURTHER CHARGES:
1. Paragraph 1 of Count One is incorporated here.
2. From as early as in or around March 2014 through on or about May 23, 2014, in the
Eastern District of Pennsylvania, defendant
CHRISTINE YODER

employed, used, persuaded, induced, enticed, and coerced Minor #2 to engage in sexually explicit
conduct for the purpose of producing visual depictions of such conduct. Those visual depictions
were produced using materials that had been mailed, shipped, and transported in and affecting
interstate and foreign commerce.
In violation of Title 18, United States Code, Section 2251(a).

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COUNT THREE
THE GRAND JURY FURTHER CHARGES:
1. Paragraphs 1 through 12 of Count One are incorporated here.
2. On or about May 21, 2014, in Philadelphia, in the Eastern District of Pennsylvania,
defendant
CHRISTINE YODER
knowingly transported and shipped using a means and facility of interstate and foreign commerce,
that is, the Internet, and in and affecting interstate and foreign commerce, a visual depiction of
Minor #1, described in Paragraph 6 of Count One, by sending, via an Internet social networking
site, the visual depiction to an online confidential source (CS). The producing of this image
involved the use of Minor #1 engaging in sexually explicit conduct, and the visual depiction was of
such conduct.
In violation of Title 18, United States Code, Section 2252(a)(1).



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COUNT FOUR
THE GRAND JURY FURTHER CHARGES:
1. Paragraphs 1 through 12 of Count One are incorporated here.
2. On or about May 21, 2014, in Philadelphia, in the Eastern District of Pennsylvania,
defendant
CHRISTINE YODER
knowingly transported and shipped using a means and facility of interstate and foreign commerce,
that is, the Internet, and in and affecting interstate and foreign commerce, a visual depiction of
Minor #1, described in Paragraph 9 of Count One, by sending, via an Internet social networking
site, the visual depiction to an undercover FBI agent (UC). The producing of this image involved
the use of Minor #1 engaging in sexually explicit conduct, and the visual depiction was of such
conduct.
In violation of Title 18, United States Code, Section 2252(a)(1).


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NOTICE OF FORFEITURE
THE GRAND JURY FURTHER CHARGES THAT:
1. As a result of the violations of Title 18, United States Code, Sections 2251 and
2252, defendant
CHRISTINE YODER

shall forfeit to the United States of America any property used or intended to be used, in any
manner or part, to commit, or to facilitate the commission of, such offenses, including, but not
limited to: One Motorola Droid Ultra cellular telephone, IMSI #311480088610102.
2. If any of the property subject to forfeiture, as a result of any act or
omission of the defendant:
(a) cannot be located upon the exercise of due diligence;
(b) has been 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;

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it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p), to
seek forfeiture of any other property of the defendant up to the value of the property subject to
forfeiture.
All pursuant to Title 18, United States Code, Section 2253.

A TRUE BILL:



GRAND JURY FOREPERSON




ZANE DAVID MEMEGER
UNITED STATES ATTORNEY

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