Case 3:12-cr-30172-GPM Document 1

Filed 06/20/12 Page 1 of 2 Page ID #1

IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF ILLINOIS

UNITED STATES OF AMERICA,
Plaintiff,
vs.

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CRIMINAL NO. JSi' 3#/7& ' (sfrA

Title 18, United States Code, Sections 1470,2252(a)(1) and 2422(b).

JACK C. BALDWIN, JR.,

Defendant.

INDICTMENT

THE GRAND JURY CHARGES:

COUNT 1

Enticement of a Minor

From on or about December 10, 2011, until on or about December 13, 2011, in St. Clair

County, within the Southern District of Illinois,

JACK C. BALDWIN, JR.,

defendant herein, did use any facility and means of interstate and foreign commerce to knowingly
employ, use, persuade, induce, entice, and coerce an individual whom he believed to be 11 years old
to engage in sexual activity for which any person could be charged with a criminal offense, that is,

the production and attempted production ofchild pornography in violation ofTitle 18, United States

Code, Section 2251(a); all in violation of Title 18, United States Code, Section 2422(b).
COUNT 2

Transfer of Obscene Matter to a Minor

On or about December 10,2011, in St. ClairCounty,within the Southern District ofIllinois,

JACK C. BALDWIN, JR.,

Case 3:12-cr-30172-GPM Document 1

Filed 06/20/12 Page 2 of 2 Page ID #2

defendant herein, did, by means of interstate commerce, knowingly transfer obscene matter to
another individual who had not attained the age of 16 years, knowing that the other individual had

not attained the age of 16 years, by sending a close-up picture of his erect nude penis to a girl he
knew to be 11 years old; all in violation of Title 18, United States Code, Section 1470.
COUNT 3

Transportation of Child Pornography

On or about December 13,2011, in St. Clair County, within the Southern District ofIllinois,
JACK C. BALDWIN, JR.,

defendant herein, did knowingly transport and attempt to transport any visual depictions using any
means or facility ofinterstate or foreign commerce, or in or affecting interstate or foreign commerce, by any means including by computer, and the production of such visual depiction involved the use

ofa minor engaging in sexually explicit conduct and the visual depiction is of such conduct, all in
violation of Title 18, United States Code, Section 2252(a)(1).
A TRUE BILL

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ANGELA SCOTT

Assistant United States Attorney

^^-STEPHB^I R. WIGGINfBN^
United States Attorney
Recommended Bond: Detention