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Case 1:16-cr-00313-GBL Document 54 Filed 01/06/17 Page 1 of 13 PageID# 161

IN THE UNITED STATES DISTRICT COURT FOR THE
EASTERN DISTRICT OF VIRGINIA

Alexandria Division
UNITED STATES OF AMERICA
V.

No. ]:16-CR=.3i3.
FILFD

IN OPEN COURT

JUSTIN GRAY LIVERMAN,

(a/k/a "D3F4ULT")

JAN

D

Defendant
CLERK, U.S. DISTRICT COURT
ALEXANDRIA. VIRGINIA

STATEMENT OF FACTS

The United States and the defendant, JUSTIN GRAY LIVERMAN, a/k/a "D3F4ULT,"

agree that the following facts are true and correct, and that had this matterproceeded to trial, the
United States would have proven them beyond a reasonable doubt with admissible and credible
evidence:

1.

From at least in or around November 2015 to in or around February 2016,

defendant agreed andconspired with others to, among otherthings, obtain unauthorized access to
U.S. government officials' online accounts and government computer databases, andconduct
harassing telephone campaigns of victims who were senior U.S. government employees.
Defendant's co-conspirators labeled themselves with the group moniker"Crackas with Attitude,"
or CWA.

2.

During the conspiracy, defendant used several pseudonymous online accounts -

which he created and controlled - to communicate with co-conspirators and publicly harass

victims, among other things, including: (a) Twitteraccounts @_D3F4ULT, @BASHTIEN_, and

@SH1N0D4; (b) Jabber messaging account d3f4ult@jabber.lqdn.fr; and (c) Facebook and online
accounts under the alias "Joseph Markowicz." In their communications, defendant and his co-

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