8:19-cr-00214-LSC-MDN Doc # 1 Filed: 06/19/19 Page 1 of 2 - Page ID # 1

SEALED
IN THE UNITED STATES DISTRICT COURT
FILED
FOR THE DISTRICT OF NEBRASKA U.S. DIST ICT COUHT
01STRI CT OF EEP1\SK A
UNITED ST ATES OF AMERICA,
19 JUN I 9 PM 2: 32
Plaintiff, 8:19 C ') .\ ~ ,. . -- ,
1f"rvB l1 11 1 · •· 11i.-
vs. INDICTMENT
18 U.S.C. 2241(a) & 1153
BENJAMIN CHASE LOVEJOY, 18 U.S.C. 2242(2) & 1153

Defendant.

The Grand Jury charges that

COUNT!

On or about April 13, 20 19, in the District of Nebraska, within in Indian Country, the

defendant, BENJAMIN CHASE LOVEJOY, an Indian male, did knowingly cause or attempt to

cause, K.B ., an Indian female, to engage in a sexual act, to wit: contact between the penis and the

vulva, with K.B. by the use of force against K.B. , in that the defendant, BE JAMIN CHASE

LOVEJOY, got on top of K.B. while she was in the front passenger seat of a vehicle and used his

body weight to restrain K.B. and manipulated her arms to prevent movement and resistance.

In violation of Title 18, United States Code, Sections 2241(a) and 1153.

COUNT II

On or about April 13, 2019, in the District of Nebraska, within Indian Country, the

defendant, BENJAMIN CHASE LOVEJOY, an Indian male, did knowingly cause or attempt to

cause, K.B., an Indian female, to engage in a sexual act, to wit: digital penetration of the vulva, of

K.B. who was, as the defendant well knew, incapable of appraising the nature of the conduct or

physically incapable of declining paJ.iicipation in the aforementioned sexual act.

In violation of Title 18, United States Code, Sections 2242(2) and 1153.

1
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8:19-cr-00214-LSC-MDN Doc # 1 Filed: 06/19/19 Page 2 of 2 - Page
,' ID # 2

A TRUE BILL.

FOREPERSON I

The United States of America requests that trial ofthis case be held in Omaha, Nebraska,
pursuant to the rules of this Court.

By: ---l,;~--"'---"'-=- --""'--'--=-=...:....,,.t--'-A--1''---------'---- -

I.:ECIA E. WRJGHT, #2
Assistant U.S. Attorney