FILED
IN OPEN COURT
IN THE UNITED STATES DISTRICT COURT FO I TF E
INDICTMENT
Count 1
County, Virginia, within the Eastern District of Virginia, the defendant, MIKE DOUGLAS
LATHAM, did unlawfully and knowingly attempt to distribute and distribute, via the Internet,
visual depictions of minors engaging in sexually explicit conduct, to wit: motion picture files and
still image files depicting prepubescent children engaging in sexually explicit conduct including
fellatio, actual and simulated vaginal and anal intercourse and the lascivious exhibition of the
genitals and pubic area, using any means or facility of interstate or foreign commerce or that has
been mailed and shipped and transported in or affecting interstate and foreign commerce and
which contains materials which have been mailed and so shipped and transported, by any means
including by computer, if (i) the producing of such visual depiction involves the use of a minor
Case 1:11-cr-00215-JCC Document 6 Filed 05/12/11 Page 2 of 4
(In violation of Title 18, United States Code, §§ 2252(a)(2), 2252(b)(1) and 2256(8)(A).)
Case 1:11-cr-00215-JCC Document 6 Filed 05/12/11 Page 3 of 4
Count 2
Between on or about May 12, 2010 and on or about October 14, 2010, in Fairfax County,
Virginia, within the Eastern District of Virginia, the defendant, MIKE DOUGLAS LATHAM,
did unlawfully and knowingly receive and attempt to receive, via the Internet, visual depictions
of minors engaging in sexually explicit conduct, to wit: motion picture files and still image files
depicting prepubescent children engaging in sexually explicit conduct including fellatio, actual
and simulated vaginal and anal intercourse and the lascivious exhibition of the genitals and pubic
area, using any means or facility of interstate or foreign commerce or that has been mailed and
shipped and transported in or affecting interstate and foreign commerce and which contains
materials which have been mailed and so shipped and transported, by any means including by
computer, if (i) the producing of such visual depiction involves the use of a minor engaging in
sexually explicit conduct and (ii) such visual depiction is of such conduct.
(In violation of Title 18, United States Code, Sections 2252(a)(2), 2252(b)(1) and 2256(8)(A).)
Case 1:11-cr-00215-JCC Document 6 Filed 05/12/11 Page 4 of 4
Forfeiture Count
DOUGLAS LATHAM shall forfeit to the United States any and all matter which contains visual
violation of Chapter 110; any property constituting or derived from any proceeds the defendant
obtained directly or indirectly as a result of the said violation; and any and all property used or
intended to be used in any manner or part to commit and to promote the commission of the
(2) One Seagate hard disk drive, model ST3500630AS, s/n 5QG22E42.
A TRUE BILL:
NEIL H. MACBRIDE
UNITED STATES ATTORNEY