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| May-14-99 03:20 PM FBI WFO MEDIA OFFICE | |
| Sent by: FBI 7037823446 | |
| IN THE UNITED STATES DISTRICT COURT FOR THE | |
| EASTERN DISTRICT OF VIRGINIA | |
| Alexandria Division | |
| UNITED STATES OF AMERICA ) | |
| ) | |
| v. ) Criminal No. | |
| ) | |
| ) Counts 1-3: Computer Intrusion | |
| ERIC BURNS ) (18 U.S.C. $ 1030(a)(5) | |
| also known as "Zyklon" ) | |
| ) | |
| Defendant. ) | |
| INDICTMENT | |
| May 1999 Term - At Alexandria, Virginia | |
| COUNT 1 | |
| THE GRAND JURY CHARGES THAT: | |
| From on or about August 25, 1998, through on or about | |
| January 22, 1998, in the Eastern District of Virginia and | |
| elsewhere, ERIC BRUNS, also known as "Zyklon," defendant herein, | |
| knowingly and intentionally cuased transmissions from a computer | |
| in Shoreline, Washington, of progress, information, codes, and | |
| commands, and as a result of such conduct, intentionally caused | |
| damage without authorization to a computer of Electric Press, | |
| Kerndon, Virginia, which was a protected computer used by and for | |
| the United States Information Agency, and agency of the United | |
| States Government, and the conduct affected the use of the | |
| computer by and for the government and caused loss aggregating at | |
| least $5,000 to at least one individual between August 25, 1998 | |
| and March 1, 1999. | |
| (In violation of Title 18, United States Code, Section | |
| 1030(a)(5)(A).) | |
| COUNT 2 | |
| THE GRAND JURY CHARGES THAT: | |
| From on or about December 28, 1998, through on or about | |
| December 31, 1998, in the Eastern District of Virginia and | |
| elsewhere, ERIC BURNS, also know as "Zyklon," the defendant | |
| herein, knowingly and intentionally caused transmissions from a computer | |
| in Shoreline, Washington, of programs, information, | |
| codes, and commands, and as a result of such conduct, | |
| intentionally caused damage without authorization to a computer | |
| of Computer Tech Services, doing business as LaserNet, in | |
| Fairfax, Virginia, which was a protected computer used in interstate | |
| commerce and communication, and caused loss | |
| aggragating at least $5,000 to at least one individual between | |
| December 28, 1998, and March 1, 1999. | |
| (In violation of Title 18, United States Code, Section | |
| 1030(a)(5)(A).) | |
| COUNT 3 | |
| THE GRAND JURY CHARGES THAT: | |
| From on or about December 28, 1998, through on or about | |
| January 11, 1999, in the Eastern District of Virginia and | |
| elsewhere, ERIC BURNS, also known as "Zyklon," defendant herein, | |
| knowingly and intentionally caused the transmission from a | |
| computer in Shoreline, Washington, of programs, information, | |
| codes, and commands, and as a result of such conduct, | |
| intentionally caused damage without authorization to computers | |
| operated by Issue Dynamics, Inc. in Alexandria, Virginia, and | |
| Washington, D.C., which were protected computers used in | |
| interstate commerce and communications, and caused loss | |
| aggragating at least $5,000 to at least one individual between | |
| December 28, 1998, and March 1, 1999. | |
| (In violation of Title 18, United States Code, Section | |
| 1030(a)(5)(A).) | |
| A TRUE BILL: | |
| __________________________ | |
| FOREPERSON | |
| UNITED STATES GRAND JURY | |
| (signed) | |
| ______________________ | |
| Helen F. Fahey | |
| United States Attorney | |
| (signed) | |
| ______________________ | |
| Justin W. Williams | |
| Assistant United States Attorney | |
| Chief, Criminal Division | |
| (signed) | |
| ______________________ | |
| Jack Henly | |
| Assistant United States Attorney | |