

  ****************************************************************************
                  >C O M P U T E R   U N D E R G R O U N D<
                                >D I G E S T<
               ***  Volume 1, Issue #1.15 (June 16, 1990)   **
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MODERATORS:   Jim Thomas / Gordon Meyer
REPLY TO:     TK0JUT2@NIU.bitnet

COMPUTER UNDERGROUND DIGEST is an open forum dedicated to sharing
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diverse views.
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          *** SPECIAL ISSUE: June Indictment of Craig Neidorf ***

--------------------------------------------------------------------
The new indictment drops some charges and introduces others.  The logic
required to connect the acts to the charges requires considerable
prosecutorial intellectual aerobics.  We invite comments from all
perspectives. We again encourage law enforcement agents or sympathizers to
join the dialogue, because we believe that productive discussion is in the
interests of all in the computer world.

Moderators Note:  This is a verbatim copy of the indictment, transcribed
from a third generation Fax/Photcopy of the original. As of this writing we
have been unable to obtain a copy from the US Government.  While in the
past we were able to have materials mailed to us, upon inquiry this time we
were told by the that a copy would have to be picked up in person at the
Federal Building in downtown Chicago.

Special thanks go out to the CuD reader who supplied us with this copy,
saving us the trip downtown.
=====================================================================





                         UNITED STATES DISTRICT COURT
                       NORTHERN DISTRICT OF ILLINOIS
                              EASTERN DIVISION


UNITED STATES OF AMERICA    )
                            )
        v.                  )   No. 90 CR 70
                            )   Violations : Title 18, United
ROBERT J. RIGGS, also known )   States Code, Sections
as Robert Johnson, also     )   1343 and 2314
known as Prophet, and       )
CRAIG NEIDORF, also known   )
as Knight Lightning         )

                           _Count One_

     The SPECIAL APRIL 1990 GRAND JURY charges:

                         _Introduction_

     1.   At all times relevant herein, Enhanced 911 (E911) was the
national computerized telephone service program for handling
emergency calls to the police, fire, ambulance and emergency
services in most municipalities in the United States.  Dialing 911
provided the public immediate access to a municipality's Public
Safety Answering Point (PSAP) through the use of computerized call
routine. The E911 system also automatically provided the recipient
of an emergency call at the PSAP with the telephone number and
location identification of the emergency caller.

     2.   At all times relevant herein, the Bell South Telephone
Company and its subsidiaries (Bell South) provided telephone
services in the nine state area including Alabama, Mississippi,
Georgia, Tennessee, Kentucky, Louisiana, North Carolina, South
Carolina and Florida.

                       [end of page one]

               _DEFINITION OF TERMS_

     3.   _The E911 Test File_ - At all times relevant herein, the
E911 system of Bell South was described in the computerized text
file known as the Bell South Standard Practice 660-225-104SV
Control Office Administration of Enhanced 911 Services for Special
and Major Account Centers, dated March 1988 (E911 text file). The
E911 text file was a highly proprietary and closely held
computerized text file belonging to the Bell South Telephone
Company and stored on the company's AIMS-X computer in Atlanta,
Georgia.  The E911 text file described the computerized control,
maintenance and service of the E911 system and carried warning
notices that it was not to be disclosed outside Bell South or any
of its subsidiaries except under written agreement.

     4.   _Text File_ - As used here, a "file" is a collection of
related data records treated as a unit by a computer and stored in
a computer's memory on a disk or other permanent storage device.
A "text file" is a collection of stored data, which, when recovered
from a disk or other storage device, presents typed English
characters displayed on a computer monitor, a printer or in any
other display medium compatible with the computer storing the data.

     5.   _Computer Hackers_ - As used here, computer hackers are
individuals involved with the unauthorized access of computer
systems by various means.  Computer hackers commonly identify
themselves by aliases or "hacker handles" when communicating with
other hackers.

                          [page] 2

     6.   _Legion of Doom_ - As used here the Legion of Doom (LOD)
was a closely knit group of computer hackers involved in:

        a.   Disrupting telecommunications by entering
             computerized telephone switches and changing the
             routing on the circuits of the computerized
             switches.

        b.  Stealing proprietary computerized information from
            companies and individuals.

        c.  Stealing and modifying credit information on individuals
            maintained in credit bureau computers.

        d.  Fraudulently obtaining money and property from
            companies by altering the computerized information
            used by the companies.

        e.  Sharing information with respect to their methods
            of attacking computers with other computer hackers
            in an effort to avoid law enforcement agencies and
            telecommunication experts from focusing on them, alone.

     7.   _Bulletin Board System_ -  At all times relevant herein, a
bulletin board system (BBS) was a computer, or portion thereof,
operated as a medium of communication between computer users at
different locations.  Users accessed or got on the BBS through
telephone line link ups from the user's computer to the BBS
computer, which could be in the same building or around the world.
BBS's could be used to exchange messages (electronic mail) or store

                          [page] 3

information.  BBS's were public commercial services or privately
operated.

        8.        _JOLNET BBS_ - At all times relevant herein, a public access
computer bulletin board system was located in Lockport, Illinois,
which provided computer storage space and electronic mail service
to its users.  The Lockport BBS was called "Jolnet".  The Jolnet
BBS was also used by computer hackers as a location for
exchanging and developing software tools for computer intrusion,
and for receiving and distributing hacker tutorials and other
computer access information.

        9.        _E-Mail_ - At all time relevant herein, electronic mail
(e-mail) was a computerized method for sending communications and
computer files between computers on various computer networks.
Persons who sent or received e-mail were identified by an e-mail
address, similar to a postal address.  Although a person may have
more than one e-mail address, each e-mail address identified a person
uniquely.  The message header of an e-mail message identified both
the sender and recipient of the e-mail message and the date the
message was sent.

                       _DEFENDANTS_

        10.        At all times relevant herein ROBERT J. RIGGS, defendant
herein, was a member of the LOD.

        11.        At all time relevant herein, CRAIG NEIDORF, defendant herein,
was a publisher and editor of a computer hacker newsletter known as
"PHRACK".  He disseminated this newsletter by sending it so those
individuals on the mailing list.

                     [page] 4

        12.        Beginning in or about February, 1988 and continuing until the
return date of this indictment, at Lockport, In the Northern
District of Illinois, Eastern Division, and elsewhere,

                                        ROBERT J. RIGGS, also known
                                        as Robert Johnson, also
                                        known as Prophet, and
                                        CRAIG NEIDORF, also known
                                        as Knight Lightning,

defendants herein, together with others known and unknown to the
Grand Jury, devised and intended to devise and participated in a
scheme and artifice to obtain property by means of false and
fraudulent pretenses and representations, well knowing at the time
that such pretenses and representations were false and fraudulent when
made.

                                   _OBJECT OF FRAUD SCHEME_

        13.        The object of the defendants' scheme was to fraudulently
obtain and steal private property in the form of computerized files
by gaining unauthorized access to other individuals' and corporations'
computers, copying the sensitive computerized files in those
computers, and then publishing the information from the computerized
files in a hacker publication for dissemination to other computer
hackers.

                                   _OPERATION OF THE FRAUD SCHEME_

        14.        It was part of the fraud scheme that the defendant NEIDORF
would and did solicit information about how to illegally access
computers and telecommunications systems from computer hackers,
including the defendant RIGGS.

                                     [page]  5

        15.        It was further part of the scheme that between about
February, 1988 and Novemeber, 1988 the defendant RIGGS would and did
fraudulently obtain sensitive proprietary Bell South information
files including the E911 text file by gaining remote unauthorized
access to computers of the Bell South.

        16.        It was further part of the scheme that the defendant RIGGS
would and did disguise and conceal and did attempt to disguise
and conceal the theft of the E911 text file from Bell South by
removing all indications of his unauthorized access into Bell
South computers and by using account codes of legitimate Bell
South users to disguise his unauthorized use of the Bell South
computer.

        17.        It was further part of the scheme that between about
February, 1988 and November 23, 1988  [transcribers note: copy
illegible at this point, year could be 1989], RIGGS would and did
transfer in interstate commerce the fraudulently obtained E911 text
file from Decatur, Georgia to Lockport, Illinois through the use of
an interstate computer data network.

        18.        It was further part of the scheme that defendant RIGGS would
and did store the stolen E911 text file on a computer bulletin board
system in Lockport, Illinois under the name Robert Johnson, as alias
he used to conceal his true identity.

        19.        It was further part of the scheme that between about October,
1988 and January 23, 1989 defendant NEIDORF, utilizing a computer at
the University of Missouri in Columbia, Missouri would and did
receive a copy of the stolen E911 text file from defendant RIGGS
through the lockport computer bulletin board system through the use
of an interstate computer network.

                                        [page] 6

        20.        It was further part of the scheme that defendant NEIDORF
would and did edit and retype the E911 text file at the request of
the defendant RIGGS in an attempt to conceal the fact that Bell
South's computer system had been entered by RIGGS without authority
and that RIGGS had fraudulently obtained the E911 text file in order
to convert Bell South's private and proprietary text file and the
information it contained therein to the defendants' own use and the
use of others and to prepare it for dissemination and disclosure in
the computer newsletter, "Phrack".

        21.        It was further part of the scheme that on or about January
23, 1989, defendant NEIDORF would and did transfer an edited version
of the stolen E911 test file through the use of an interstate
computer data network from his computer at the University of Missouri
to the computer bulletin board system used by defendant RIGGS in
Lockport, Illinois.

        22.        It was further part of the scheme that on or about February
24, 1989 defendant NEIDORF disseminated the disguised E911 text file
in issue 24 of "PHRACK" newsletter.

        23.        It was further part of the scheme that the defendant NEIDORF
would disseminate and disclose this information to others for their
own use, including to other computer hackers who could use it to
illegally manipulate the emergency 911 computer systems in the United
States and thereby disrupt or halt 911 service in portions of the
United States.

        24.        It was further part of the scheme that the defendants used
aliases, coded language and other means to avoid detection and

                                        [page] 7

apprehension by law enforcement authorities and to otherwise provide
security to the members of the fraud scheme.

        25.        It was further a part of the scheme that the defendants would
and did misrepresent, conceal, and hide, and cause to be
misrepresented, concealed and hidden the purposes of the acts done in
furtherance of the fraud scheme.

        26.        Between in or about February, 1988 and Novemeber, 1988,
at Lockport, in the Northern District of Illinois, Eastern Division,
and elsewhere,

                                ROBERT J. RIGGS, also known
                                as Robert Johnson, also
                                known as Prophet,

defendant herein, for the purpose of executing the aforesaid scheme,
did knowingly transmit and cause to be transmitted by means of a wire
and radio communication in interstate commerce from Decatur, Georgia
to Lockport, Illinois, certain signs, signals and sounds, namely:  a
data transfer of Bell South E911 Standard Practice test file dated
March, 1988  (as further defined in paragraph 3 of this Count of this
Indictment).

        In violation of Title 18, United States Code, Section 1343.



                               [page] 8


                         _COUNT TWO_

        The SPECIAL APRIL 1990 GRAND JURY further charges:

        1.        The Grand Jury realleges and incorporates by reference the
allegations of paragraphs 1 through 25 of Count One of this
Indictment as fully set forth herein.

        2.        On or about July 23, [transcribers note: date illegible in
copy] 1988, at Lockport, in the Northern District of Illinois,
Eastern Division and elsewhere,

                                CRAIG NEIDORF, also known
                                as Knight Lightning,

defendant herein, for the purposes of executing the aforesaid scheme
did knowingly transmit and cause to be transmitted by means of a wire
and radio communication in interstate commerce from Columbia,
Missouri to Lockport, Illinois certain signs, signals and sounds,
namely:  a data transfer of Phrack World News announcing the
beginning of the "Phoenix Project";

        In violation of Title 18, United States code [sic] , Section 1343









                         [page] 9


                         _COUNT THREE_

    The SPECIAL APRIL 1990 GRAND JURY further charges:

    1.  The Grand Jury realleges and incorporates by reference the
allegations of paragraphs 1 through 25 of Count One of this
Indictment as fully set forth herein.

    2.  On or about September 19, 1988, at Lockport, in the Northern
District of Illinois, Eastern Division and elsewhere,

                CRAIG NEIDORF, also known
                as Knight Lightning,

defendant herein, for the purposes of executing the aforesaid scheme
did knowingly transmit and cause to be transmitted by means of a wire
and radio communication in interstate commerce from Columbia,
Missouri to Lockport, Illinois certain signs, signals and sounds,
namely:  a data transfer of E-mail from defendant NEIDORF to
defendant RIGGS and "Scott C."

    In violation of Title 18, United States code [sic] , Section 1343





                         [page] 10


                         _COUNT FOUR_

    The SPECIAL APRIL 1990 GRAND JURY further charges:

    1.  The Grand Jury realleges and incorporates by reference the
allegations of paragraphs 1 through 25 of Count One of this
Indictment as fully set forth herein.

    2.  On or about September 29, 1988, at Lockport, in the Northern
District of Illinois, Eastern Division and elsewhere,

                ROBERT J. RIGGS, also known
                as Robert Johnson, also
                known as Prophet, and
                                CRAIG NEIDORF, also known
                as Knight Lightning,

defendants herein, for the purposes of executing the aforesaid scheme
did knowingly transmit and cause to be transmitted by means of a wire
and radio communication in interstate commerce from Lockport,
Illinois to Columbia, Missouri certain signs, signals and sounds,
namely:  a data transfer of E-mail from the defendant RIGGS to the
defendant NEIDORF;

    In violation of Title 18, United States Code , Section 1343




                                        [page] 11


                         _COUNT FIVE_

    The SPECIAL APRIL 1990 GRAND JURY further charges:

    1.  The Grand Jury realleges and incorporates by reference the
allegations of paragraphs 1 through 25 of Count One of this
Indictment as fully set forth herein.

    2.  Between in or about October, 1988 and January 23, 1989 at
Lockport, in the Northern District of Illinois, Eastern Division and
elsewhere,

                                ROBERT J. RIGGS, also known
                                as Robert Johnson, also
                                known as Prophet, and
                CRAIG NEIDORF, also known
                as Knight Lightning,

defendants herein, for the purposes of executing the aforesaid scheme
did knowingly transmit and cause to be transmitted by means of a wire
and radio communication in interstate commerce [sic] Lockport,
Illinois to Columbia, Missouri certain signs, signals and sounds,
namely:  a data transfer of Bell South's E911 Practice text file
dated March, 1988 (as further defined in paragraph 3 of Count One of
this Indictment) from defendant RIGGS to defendant NEIDORF;


    In violation of Title 18, United States Code , Section 1343



                                                [page] 12


                         _COUNT SIX_

    The SPECIAL APRIL 1990 GRAND JURY further charges:

    1.  The Grand Jury realleges and incorporates by reference the
allegations of paragraphs 1 through 25 of Count One of this
Indictment as fully set forth herein.

    2.  Between in or about October, 1988 and January 23, 1989 at
Lockport, in the Northern District of Illinois, Eastern Division and
elsewhere,
                                ROBERT J. RIGGS, also known
                                as Robert Johnson, also
                                known as Prophet, and
                CRAIG NEIDORF, also known
                as Knight Lightning,

defendants herein, for the purposes of executing the aforesaid scheme
did knowingly transmit and cause to be transmitted by means of a wire
and radio communication in interstate commerce from Lockport, Illinois
to Columbia, Missouri a computerized text file with a value of $5,000
or more, namely:

        A Bell South Standard Practice (BSP) 660-225-104SV- Control
        Office Administration of Enhanced 911 Services for Special
        Services and Major Account Centers dated March, 1988, valued at
        approximately $23,900.00;

the defendants then and there knowing the same to have been stolen,
converted, and taken by fraud;

    In violation of Title 18, United States code [sic] , Section 2314



                                        [page] 13


                         _COUNT SEVEN_

    The SPECIAL APRIL 1990 GRAND JURY further charges:

    1.  The Grand Jury realleges and incorporates by reference the
allegations of paragraphs 1 through 25 of Count One of this
Indictment as fully set forth herein.

    2.  Between in or about December 23 1988, at Lockport, in the
Northern District of Illinois, Eastern Division and elsewhere,

                CRAIG NEIDORF, also known
                as Knight Lightning,

defendant herein, for the purposes of executing the aforesaid scheme
did knowingly transmit and cause to be transmitted by means of a wire
and radio communication in interstate commerce from Columbia,
Missouri to Lockport, Illinois certain signs, signals and sounds,
namely:  a data transfer of Phrack Newsletter, Issue 22, Files 1, 4,
5 and 6;

    In violation of Title 18, United States Code  , Section 1343


                           [page] 14


                         _COUNT EIGHT_

    The SPECIAL APRIL 1990 GRAND JURY further charges:

    1.  The Grand Jury realleges and incorporates by reference the
allegations of paragraphs 1 through 25 of Count One of this
Indictment as fully set forth herein.

    2.         Between in or about January 23, 1988 at Lockport, in the
Northern District of Illinois, Eastern Division and elsewhere,

                                ROBERT J. RIGGS, also known
                                as Robert Johnson, also
                                known as Prophet, and
                CRAIG NEIDORF, also known
                as Knight Lightning,

defendants herein, for the purposes of executing the aforesaid scheme
did knowingly transmit and cause to be transmitted by means of a wire
and radio communication in interstate commerce from Columbia,
Missouri to Lockport, Illinois certain signs, signals and sounds,
namely:  a data transfer of an edited Bell South E911 Standard
Practice text file dated March, 1988 (as further defined in paragraph
3 of Count One of this Indictment);

    In violation of Title 18, United States Code , Section 1343



                                        [page] 15


                         _COUNT NINE_

    The SPECIAL APRIL 1990 GRAND JURY further charges:

    1.  The Grand Jury realleges and incorporates by reference the
allegations of paragraphs 1 through 25 of Count One of this
Indictment as fully set forth herein.

    2.  On or about July 23, 1988, at Lockport, in the Northern
District of Illinois, Eastern Division and elsewhere,

                                ROBERT J. RIGGS, also known
                                as Robert Johnson, also
                                known as Prophet, and
                CRAIG NEIDORF, also known
                as Knight Lightning,

defendants herein, did transmit and cause to be transmitted by means
of a wire and radio communication in interstate commerce from
Columbia, Missouri to Lockport, Illinois, a computerized text file
with a value of $5,000 or more, namely:

        An edited Bell South Standard Practice (BSP) 660-225-104SV-
        Control Office Administration of Enhanced 911 Services for
        Special Services and Major Account Centers dated March, 1988,
        valued at approximately $23,900.00;

the defendants, then and there knowing the same to have been stolen,
converted, and taken by fraud;

    In violation of Title 18, United States Code , Section 2314.



                          [page] 16

                        _COUNT TEN_

    The SPECIAL APRIL 1990 GRAND JURY further charges:

    1.  The Grand Jury realleges and incorporates by reference the
allegations of paragraphs 1 through 25 of Count One of this
Indictment as fully set forth herein.

    2.  On or about February 23, 1988, at Lockport, in the Northern
District of Illinois, Eastern Division and elsewhere,

                CRAIG NEIDORF, also known
                as Knight Lightning,

defendant herein, for the purposes of executing the aforesaid scheme
did knowingly transmit and cause to be transmitted by means of a wire
and radio communication in interstate commerce from Columbia,
Missouri to Lockport, Illinois certain signs, signals and sounds,
namely:  a data transfer of Phrack Newsletter, Issue 24, including an
edited Bell South Standard Practice (BSP) 660-225-104SV- Control
Office Administration of Enhanced 911 Services for Special Services
and Major Account Centers dated March, 1988;

    In violation of Title 18, United States Code  , Section 1343







                       [page] 17


                         _COUNT ELEVEN_

    The SPECIAL APRIL 1990 GRAND JURY further charges:

    1.  The Grand Jury realleges and incorporates by reference the
allegations of paragraphs 1 through 25 of Count One of this
Indictment as though fully set forth herein.

    2.  On or about February 24, 1989, at Lockport, in the Northern
District of Illinois, Eastern Division and elsewhere,

                                ROBERT J. RIGGS, also known
                                as Robert Johnson, also
                                known as Prophet, and
                CRAIG NEIDORF, also known
                as Knight Lightning,

defendants herein, did transport and cause to be transported in
interstate commerce from Columbia, Missouri to Lockport, Illinois, a
computerized text file with a value of $5,000 or more namely:

    A Bell South Standard Practice (BSP) 660-225-104SV- Control Office
    Administration of Enhanced 911 Services for Special Services and
    Major Account Centers dated March, 1988, valued at approximately
    $23,900.00;

the defendants, then and there knowing the same to have been stolen,
converted, and taken by fraud;

    In violation of Title 18, United States code [sic] , Section 2314


                                                                        A TRUE BILL:


                                                                   _________________________________
                                                                        F O R E P E R S O N




___________________________________
UNITED STATES ATTORNEY



                      [page] 18



[transcribed from FAXed copy 6/14/90.  GRM]

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