Case 1:07-cr-01363-WJ Document 20 Filed 06/29/2007 Page^r.lh.F 1 of 19 ,R" I-INITEDSTATES DISTRICT COURT JUN2 g 2ss7
FOR THE DISTRICTOF NEW MEX]CO MATTHEWJ.DYKMAN CLEFK UNITED STATESOF AMERICA, ) ) Plaintiff, )
vs. cr.No.ot-ck-1363PT
DEVON LYNN TOWNSEND,
Defendant.
PLEAAGREEMENT
Pursuantto Rule I I, Fed.R. Crim.P., the parties notify the court of the following
agleementbetween the United StatesAttomey for the District of New Mexico, the
Defendant,DEVON LYNN TOWNSEND,andthe Defendant's counsel, RAYMOND
TWOHIG,ESQUIRE:
REPRESENTATIONBY COUNSEL
L The Defendantunderstands the Defendant'sright to be representedby an
attomeyand is so represented.The Defendanthas thoroughly reviewed all aspectsofthis
casewith the Defendant'sattorney and is fully satisfredwith that attorney'slegal
representation.
RIGHTS OF THE DEFENDANT
2. TheDefendant further understands the Defendant's rights:
to be charged and prosecuted by indictnent;
t. Case 1:07-cr-01363-WJ Document 20 Filed 06/29/2007 Page 2 of 19
b. to plead not guilty, or having alreadyso pleaded,to persistin that plea;
to have a trial by jury; and
d. at a trial:
1) to confrontand cross-examine adverse witnesses,
2) to be protectedfrom compelledself-incrimination,
3) to testifu andpresent evidence on the Defendant'sown behalf, and
4) to compelthe attendanceofwitnesses for the defense.
WAIVER OF RIGHTS AND PLEA OF GUILTY
3. TheDefendant agrees to waivethese rights and to pleadguilty to Counts1 through3 of the Informationfiled in this matter.In Count1, the Defendantis charged with Stalking,in violationof 18U.S.C. $ 2261A(2XA).In Count2, the Defendantis chargedwith Unlawfulaccess to Storedcommunications, in violationof l8 U.S.C.$
270l(a)(l) and(2) and(bX1XA). In Count3, theDefendant is chargedwith
Unauthorizedfixation of andtrafficking in soundrecordings and music videosof live musicalperformances, in violationof 2319,4..Pursuant to the Forfeitureallegation in the
Information,as set forth in further detail below, the Defendantfurther agreesto forfeit to the United Statesany and all interestshe may havein any and all unauthorizedaudio and visualrecordings of live musicalperformances obtained without consent of the performersinvolved. Case 1:07-cr-01363-WJ Document 20 Filed 06/29/2007 Page 3 of 19
SENTENCING
4. The Defendantunderstands that the maximumpenalty the Court can impose for each count of the Information is:
For the Defendant'sviolation of I 8 U.S.C.5 2261A, the Stalking statute:
l) a termof imprisonmentof not morethan 5 (five) years;
2) a fine not to exceed$250,000.00;
3) a term of supervisedrelease of not more than 3 (three)years that must follow any term of imprisonment. (If the Defendant servesa termof imprisonment,is thenreleased on supervised release,and violates the conditions of supervisedrelease, the Defendant'ssupervised release could be revoked-- evenon the last day of the term -- and the Defendantcould then be retumedto anotherperiod of incarcerationand a new term of supervisedrelease.);
4) a mandatoryspecial penalty assessment of $100.00;and
5) restitutionas may be orderedby the Courtpursuant to law, 18 U.S.C.$ 36634,and paragraphT of this agreement.
b. In thecase of theDefendant's violation of l8 U.S.C.$ 2701(aXl) and(2) and(b)(l)(A), the Unlawfulaccess to storedcommunications statute:
l) a term of imprisonmentof not more than 5 (five) years;
2) a fine not to exceed$250,000.00;
3) a term of supervisedrelease of not more than 3 (three)years that must follow any term of imprisonment. (If the Defendant servesa termof imprisonment,is thenreleased on supervised release,and violates the conditionsof supervisedrelease, the Defendant'ssupervised release could be revoked-- evenon Case 1:07-cr-01363-WJ Document 20 Filed 06/29/2007 Page 4 of 19
the last day of the term -- andthe Defendantcould then be retumedto anotherperiod of incarcerationand a new term of supervisedrelease.);
4) a mandatoryspecial penalty assessment of $100.00; and
5) restitutionas may be orderedby the Court pursuantto law, 18 U.S.C.$ 36634,andparagaphT of thisagreement.
c. For theDefendant's violation of 18U.S.C. $ 2319A,the Unauthorizedfixation of and trafficking in soundrecordings statute:
1) a termof imprisonmentof not morethan 5 (five) years;
2) a finenotto exceed$250,000.00;
3) a termof supervisedrelease ofnot morethan 3 (three)years that must follow any term of imprisonment. (If the Defendant sewesa termof imprisonment,is thenreleased on supervised release,and violates the conditions of supervisedrelease, the Defendant'ssupervised release could be revoked-' evenon the last day of the term -- andthe Defendantcould then be retumedto anotherperiod of incarcerationand a new term of supervisedrelease.);
4) a mandatoryspecial penalty assessment of $100.00;and
5) restitutionas may be orderedby the Court pursuantto law, 18 U.S.C.$ 3663A,and paragaph7 of this agreement'
5. Theparties recognize that the federalsentencing guidelines are advisory, but that the Court is requiredto considerthern in determiningthe sentenceit imposes.
6. The United Statesreserves the right to makeknown to the United States
ProbationOffice, for inclusionin thepresentence leport to be preparedunder Rule 32,
Fed.R. Crim.P., anyinformation the United States believes may be helpfulto theCourt,
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includingbut not limitedto informationabout any relevant conduct under u.S.S.G.
$ 181.3.
7. The Defendantagtees and acknowledges that the Court is not limited to orderingrestitution only to the amountof the particularoffenses to which the Defendant is enteringa plea of guilty, but may orderrestitution to include all amountsresulting from all of theDefendant's criminal conduct related to this case.
DEFENDAI{T'S ADMISSION OF FACTS
8. TheDefendant admits to the following facts:
a. By my signatureon this plea agreement,I am acknowledgingthat I am pleadingguilty becauseI am, in fact, guilty of the offensesto which I am pleading guilty. I recognizeand acceptresponsibility for my criminal conduct. Moreover,in pleadingguilty, I acknowledgethat ifl choseto go to trial insteadof enteringthis guilty plea,the United States could prove facts sufficient to establishmy guilt to all of the chargesto which I am pleadingguilty beyonda reasonabledoubt. I specifically admit the followingfacts related to the chargesagainst me, and declare under penalty ofpefury that all ofthesefacts are true andcorrect:
(l). Fromon or aboutJanuary 1, 2006through on or about
November16,2006, in BernalilloCounty in the Stateand District of New Mexico,and elsewhere,I usedan interactivecomputer service, and a facility of interstatecofilmerce' to engagein a courseof conduct,described in further detail in paragraphs2 through 19
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below,that caused substantial emotional dishess to a personin anotherState, that is, Mr. andMrs. chesterand Talinda Bennington in california. when I engagedin the courseof conductdescribed below, I wasacting with the intentto harass,with the intentto place undersurveillance with the intent to harass,and with the intent to causeboth of the
Benningtonssubstantial emotional dishess.
(2). During the time frame of the eventsdescribed in the
Information,from approximatelyJanuary l, 2006 throughapproximately November 16,
2006,I wasliving in Albuquerque,New Mexicoand working as an employeeat the
SandiaNational Laboratories(SNL) facility in Albuquerque. I worked as a tradesperson at SNL in the Technologyand Manufacturinggroup. In thatjob, I often worked in a securepart of the facility andhad accessto a terminal servernetwork which was connectedto theInternet. I alsohad a personalcomputer at homethat was connected to the Intemet.
(3). I havebeen a fan of the altemativeor nu metal band Linkin
Park. ChesterBennington is the lead singerfor Linkin Park. Talinda Benningtonis
ChesterBennington's wife. Chesterand Talinda Bennington live in the Stateof
California. I spenta lot of time on the Intemet learningabout Chester and Talinda
Bennington.
(4). I foundout ChesterBennington's personal e-mail address from a masse-mail that one of Mr. Bennington'sfriends sent out informingthe recipients Case 1:07-cr-01363-WJ Document 20 Filed 06/29/2007 Page 7 of 19
about an upcoming concert in which Mr. Bennington was going to perform. After I found out ChesterBennington's e-mail address,I useda computerlocated in New Mexico with interactiveaccess to the lnternet, and without authorization,gained access to a servef locatedin the Stateof California at yahoo.com,an Internet Serviceprovider. Once I was coffiected to yahoo.com,I was successfullyable to changethe passwordto Mr.
Bennington'sprivate e-mail account. Once I resetthe password,I was able to review and downloadall of Mr. Bennington's private e-mail colrespondencein his accountat yahoo.com. I was also able to find out about Talinda Benninglon's e-mail addressfrom accessingher husband'saccount.
(5). Over the courseof severalmonths, I was able to accessall sorts of private information about the Benningtons from their private e-mail accounts, including:
(a). family pictures of the Benningtons and their minor children;
(b). correspondencebetween Wamer Brothers Recordsand the business attomey for Linkin Park, including a copy ofa checkmade payable to ChesterBennington from the record companyas well as a copy of the recording contract between Wamer Brothers Records and the membersof Linkin Park;
(c). information about a new home purchase by the Benningtons which included such documents as a home inspectionreport, imagesof the home's interior, and other real estate documents;
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(d). information about the Benningtons' travel plans including flight information and the name of motels and hotels where the Benningtons had reservations;
(e). a copy ofa dentalbill for Talinda Bennington;
(0. information about the time and location of Mrs. Bennington'schildbirth classes;
(e). e-mail correspondenceconceming the whereabouts and after school activities of the Benningtons' child;
(h). information about purchasesthe Benningtons made for their newborn child;
(il. information aboutthe scheduleand itinerary ofthe membersof Linkin Park,including their itinerary for the Grammyawards show in20O6.
(6). By secretlymonitoring the Benningtons'private e-mail correspondence,I was also able to leamprivate passwords assigned to theBenningtons which allowedme to accessother restricted information on the Intemet. For example, usingthe Benningtons' assigrred password, I wasable to accessand download copies of theBenningtons' wedding pictures from the Benningtons'wedding photographer's website.
(7). By usingthe Bennington's private information, without the
Benningtons'knowledge, I alsoactivated the Bennington'sonline billing accountwith theBennington's telephone company, Verizon Wireless' By activatingthe accountover the Internet,I wasthen able to obtainonline access to theBenningtons' telephone bills.
For example,as charged in Count2 of the Information,on or aboutMarch 30, 2006,I Case 1:07-cr-01363-WJ Document 20 Filed 06/29/2007 Page 9 of 19
intentionally accessedwithout authorizationthe Verizon Wirelesscomputer system. I did this by falsely representingthat I was ChesterBennington and by inputting Mr.
Bennington'sinformation to activateMr. Benninglon'sonline billing accountat Verizon
Wirelesswithout Mr. Bennington'sknowledge or authorization.I wasthen able to access and downloadthe entire contentsof one of the Benningtons'monthly Verizon Wireless telephonebills, which were storedin an electronicformat on the Verizon Wireless computersystem. I understandthat Verizon Wirelessdoes business in interstate corrmerceand that the companyuses the Internet,which is connectedto interstatewires, to sendbills in an electronicformat in interstatecornmerce to its customers.I obtained copiesof theBenningtons' telephone bills to furthermy stalkingactivities.
(8). By reviewingthe Benningtons' telephone bills, I wasable to leamthe telephonenumbers of their friends,acquaintances, and business associates. By settingup the onlineVerizon account, I wasalso able to listento all of theBenninglons' voicemail messagesleft on theirtelephone answering service.
(9). With accessto theBenningtons' private accounts with entities suchas Verizon Wireless, I wasalso able to changethe computerpasswords assigned to theBenningtons with thesecompanies. On at leastone occasion, I changedthe password for oneof their computeraccounts to somethingto the effect of "Who is doing this to you?" Case 1:07-cr-01363-WJ Document 20 Filed 06/29/2007 Page 10 of 19
(10). On at leastone occasion, knowing that Chester Bennington was in Arizona, I traveledto Aizona solely for the purposeof trying to seehim. while I wasthere, I monitoredChester Bennington's voice mails as a meansof trying to locate wherehe might be eatingdinner or lunch.
(l l). On at leastone other occasion, while I wasin Los Angeleson a family vacation,I drovepast the Benningtons' residence.
(12). I alsocreated two new e-mailaccounts,
"[email protected]"and "[email protected]," and used thoseaccounts to sendmessages to bothTalinda Bennington, and friends of the
Benningtons.For example,using the "inside [email protected]"address, I wrote a tauntinge-mail to a friend of the Benningtonsthreatening to divulge personal informationabout the Benningtons.I endedmy e-maildescribing myself as "somebody who knowsa little too much. . ."
(13). Usingthe "inside [email protected]" address, I next wrote anothere-mail to anotherBennington friend relatedto the sameprivate information,referring to the situationas "my little bombshellthat's about to explode...... "In the samee-mail, I alsostated:
The answerwill revealitself shortlv. This is too fun.
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( 14). Usingthe "[email protected]"address, I then senta copy of anothere-mail to the samefriend of the Benningtons,which included the following statements:
I'm havingfun. Are you? **:f
I wonderhow the fanswould react to this??
(15). Thenext taunting e-mail that I sentto the samefriend of the
Benningtonsfrom the samee-mail address, ended with me stating,"Enjoy therest of your nightand maybe just maybeyou'll havesweet dreams too."
(16). I alsocommunicated directly with TalindaBennington by e- mail usingthe e-mailaddress [email protected]. In these e-mail messages, I suggestedthat the Benningtonssend an undercoverinvestigator to monitor the activities of a personassociated with the Benningtons.Using this samee-mail address, I latersent anothere-mail to TalindaBennington's e-mail address. The text portionof the e-mailto
Talinda Benningtonthat I sentcontained a hyperlink to a website. The hyperlink was to an article aboutcyberstalking.
(17). On anotheroccasion I usedan e-mailaccount registered to
ChesterBennington to sendan e-mailmessage posing as Talinda Bennington in an effort to gatherinformation about an e-mailaccount of a personclosely associated with the
Benninstons.
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(18). In or aboutAugus t 2006,I contactedTalinda Bennington on thetelephone. I did not identi$ myselfduring the course of multipletelephone calls.
(19). On or aboutSeptember 26,2006,I placedtwo telephoneca1ls to Talinda Benningtonand spoketo Talinda Benningtonon the telephone. I againfailed to identifymyself.
(20). With respectto Count3 of the Information,I alsoadmit that, on or aboutNovember l, 2006,without the cons€ntof theperformers involved, that is, the membersof the band Linkin Park,I knowingly and for purposesof my own financial gain,did offer to distributeand did traffic in, copiesand phonorecords of unauthorized fixations of the soundsand images of the soundsand images of a live musical performanceby the membersof the bandLinkin Park,that is, a performancethat I advertisedas occurring on March4,2004, in Sunrise,Florida, at the Office DepotCenter.
More specifically,I wasactively engaged in tradingunauthorized recordings of live concertperformances by a numberof differentbands, including a varietyof different performancesby Linkin Park,with other individuals ovef the Interneton the website, etree.org.In fact,I informedpotential traders on thewebsite that I hadover 833 bootleg recordingsavailable for tradefrom a variety of different performers,including a March 4,
2004Linkin Parkperformance in Sunrise,Florida recorded onto a DVD. AlthoughI did not offer to sell thebootleg recordings for money,I did possessthe unauthorized recordingsof the live concertperformances with the intent to transferthem to othersin
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exchangedfor the expectedreceipt of somethingofvalue, that is, I offered to trade or exchangethem in the expectationthat the personto whom I transferredthe bootleg recolding would also transfera recording ofa live musical performancethat I did not yet have in my collection back to me.
g. By signing this agreement,I admit all the foregoing facts and admit that there is a factual basis for each element of the crimes to which I am pleading guilty. I agree that the Court may rely on any of these facts, as well as any undisputed facts in the presentencereport, to determine my sentsnce,including, but not limited to, the advisory guideline offenselevel.
STIPULATIONS
10. To assistthe Court in determiningthe advisory sentencingguideline range, the United States and the Defendant stipulate as follows:
a. As of the date of this agreement,the Defendanthas clearly demonstrateda recognition and affirmative acceptanceofpersonal responsibility for the
Defendant'scriminal conduct. Consequently,pursuant to U.S.S.G. $ 3E1.1, so long as the
Defendant continues to accept responsibility for the Defendant's criminal conduct, the
Defendantis entitled to a tfuee-levelreduction from her baseoffense level as calculated under the sentencingguidelines. This reductiondepends on the Defendantpersonally providing to the United StatesProbation Officer who prepares the presentencer€port in this case an appropriate written statementin which the Defendant clearly establishesthe
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Defendant'sentitlement to this reduction. Further,the United Statesis free to withdraw this stipulationif the Defendantengages in any conductthat is inconsistentwith acceptanceof responsibilitybetween the dateof this agreementand the sentencing hearing.
b. The Defendantstipulates and agreesthat the applicableadvisory guidelinefor Defendant'scrime of Stalkingpursuant to 18U.S.C. $ 2261A(2XA)is
U.S.S.G.5 2A6.2,which carries a baseoffense level of 18.
c. TheDefendant recognizes that her extensiveaccessing of private information aboutthe Benningtons,their family members,and their friends and associates,was unlawful and caused the Benningtons substantial emotional distress. As a term and condition of this plea agreement,without prior Court authorizationand written agreementof the United States,the Defendanttherefore promises and agreesnot to make any further disclosureor disseminationof any information,photographs, documents or imagesthat the Defendantobtained, or leamedabout without proper authorization,or throughunlawful means. This provision specificallyincludes any information that the
Defendantobtained without authorizationby accessingthe Benningtons'private e-mail accounts,the Benningtons'Verizon Wireless billing account,the Benningtons'wedding photographer'swebsite, or any other accountsor websitesassociated with either the
Benninstons'or their friendsand associates.
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d. The partiesare free to argueeither for, or against,the applicationof any specific offensecharacteristics or other adjustmentsto the advisoryguideline sentencesthat are otherwisenot addressedby way of stipulationherein'
e. This agreementdoes not precludethe Defendantfrom seekinga downwarddeparture or variancefrom the applicableadvisory sentencing guideline range as determinedby the Court after resolutionofany objectionsby either party to the presentencereport to be preparedin this case. Ifthe Defendantshould seek a downward departureor variance,the United Statesretains its right to opposesuch downward departureor variance.
f. The Defendantfurther agteesto forfeit to the United Statesthe more than800 recordings, DVD's, CD's andVHS tapesof musicalperformances and concerts that havepreviously been disclosed to the Defendantas documentsnumbered 7l through
86,as well asall of the computersand associated items listed in parts2 through5 of the
ForfeitureAllegation containedin the Information.
g. As part of this plea agreement,the Defendantagrees to fully cooperatewith anymental testing, evaluation, treatnent and counselingas the Court may direct.
h. During the period ofany Court-orderedincarceration and/or supervisedrelease, the Defendantagrees that sheshall not attemptto watch,keep under surveillancein anyfashion (including elecnonically), harass, or haveany contact, directly
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or indirectly, with ChesterBennington, Talinda Benningtonand/or their family and householdmembers (as further defined in paragraph11 of the December1l' 2006
RestrainingOrder enteredagainst the Defendantin Benningtonv' Townsend,in the superiorcourt ofcalifornia, county oforange, No. 06HL05071).This provision shall includeno physicalcontact or contactby way of telephonemessages, mail, e-mail,instant messaging,or other tlpe of electroniccommunication. The Defendantfurther agreesthat shewill stayaway from the individualsreferenced above and will not appearat any concertor otherpublic or private eventor activity whereany of the aboveindividuals are present,including any hotel wherethey may be staying.
11. The Defendantunderstands that the abovestipulations are not binding on the Court andthat whetherthe Court acceptsthese stipulations is a matter solely within the discretionofthe Court after it hasreviewed the presentencereport' Further,the
Defendantunderstands that the Court may chooseto deviatefrom the advisoryguideline sentence.The Defendantunderstands that if the Court doesnot acceptany one or more of the abovestipulations and reaches an advisoryguideline sentence different than expected by theDefendant, or if the Courtdeviates from the advisoryguideline range, the
Defendantwill not seekto withdraw the plea of guilty. In other words,regardless of any stipulationsthe partiesmay enterinto, insofar as is otherwisepermitted by law, the
Defendant'sfinal sentenceis solelywithin thediscretion of the Court.
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DEFENDANT'S ADDITIONAL OBLIGATIONS
12. TheDefendant understands the Defendant's obligation to providethe
United StatesProbation Office with truthful, accurate,and completeinformation. The
Defendantrepresents that the Defendanthas complied with and will continueto comply with this obligation.
13. If requestedto do soby theUnited States Attorney's Office, the Defendant will provideall documents,records, writings, tangible objects, or materialsof anykind thatare in theDefendant's possession, custody, or controland that relate directly or indirectly to arryarea of inquiry or investigationin this proceeding.
WAIVER OF APPEAL RIGHTS
14. The Defendantis awarethat federallaw affords a Defendantthe right to appealthe sentenceimposed. Acknowledging that, the Defendant knowingly waives the right to appealany sentencewithin the statutoryrange applicable to the statute(s)of conviction.
GOVERNMENT'S AGREEMENT
15. Providedthat the Defendant fulfrlls theDefendant's obligations as set out above,the United Statesagrees that the United Stateswill not bring additionalcriminal chargesagainst the Defendantarising out of the Defendant'sconduct now known to the
UnitedStates Attorney's Office for theDistrict of New Mexico. The Defendant understandsthat this agreementis limitedsolely to the UnitedStates Attomey's Oflice for
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the Districtof New Mexicoand does not bind anyother federal, state, or local agenciesor prosecutingauthorities, including the Tax Divisionof theu.s. Departmentof Justice.
VOLUNTARYPLEA
16. TheDefendant agrees and represents that this pleaof guilty is freelyand voluntarily madeand is not the result of force, threats,or promises(other than the promisesset forth in this agreement).There have been no representationsor promises from anyoneas to what sentencethe Court will impose. The Defendantrepresents that the Defendantis pleadingguilty becausethe Defendantis in fact guilty, andfor no other reason.
VIOLATION OF PLEA AGREEMENT
17. TheDefendant agrees that ifthe Defendantviolates any provision ofthis agreement,the United Statesmay declarethis agreementnull and void, andthe Defendant will thereafterbe subjectto prosecutionfor any criminal violation, including but not limited to any crime(s)or offense(s)contained in or relatedto the chargesin this case,as well aspe{ury, false statement,obstruction ofjustice, and any other crime committedby the Defendantduring this prosecution.
SPECIAL ASSESSMENT
18. At thetime of sentencing,the Defendantwill tenderto theUnited States
DistrictCourt, District of New Mexico,333 Lomas Blvd. NW, Suite270, Albuquerque,
New Mexico 87102,a moneyorder or certifiedcheck payable to the orderof the United
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StatesDistrict Court in the amountof $300.00in paynentof the specialpenalty assessmentdescribed above.
ENTIRETY OF AGREEMENT
19. This documentis a completestatement of the agreementin this caseand maynot be alteredunless done so in writing andsigned by all parties.
-:Z f AGREEDTO AND SIGNED1yti" z lhav of f ,,,,t a
CI United StatesAttomey PostOffice Box 607 Albuquerque,New Mexico 87102 (s0s)346-7274
I haveread this agreementand carefully reviewedevery part of it with my attorney. I understandthe agreementand voluntarily sign it.
DEVON LYNN TOWNSEND Defendant
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