ORIGINAL 

IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

FORT WORTH DIVISION 

UNITED STATES OF AMERICA 

V. No. Ll: 22--CR., D(d..o-D 

CLOIS GLENN RABORN (01) 

FACTUAL RESUME 

INFORMATION: 

PLEA: 

Count One: Sexual Exploitation of a Child, in violation of 18 U.S.C. 

§§ 225l(a) and (e) 

Guilty Plea to Count One 

PENALTY: 

The minimum and maximum penalties the Court can impose include: 

a. a term of imprisonment for not less than fifteen ( 15) years and not more than 

thirty (30) years; 

b. a fine up to the amount of $250,000, or twice the pecuniary gain or twice the 

pecunia1y loss to the victim; , 

c. a term of supervised release of any term of years or life but not less than five 

(5) years, which is mandatmy under the law and will follow any tenn of 

imprisonment. Revocation of the term of supervised release could result in an 

additional period of confinement. If the defendant violates any condition of 

the term of supervised release, the Court may revoke such release te1m and 

require that the defendant serve an additional period of confinement; 

d. a mandatory special assessment of $100; 

e. unless the Court finds the defendant to be indigent, an additional mandatory 

special assessment of $5,000 must also be imposed pursuant to 18 U.S.C. 

§ 3014 for offenses occurring on or after May 29, 2015; 

f. an assessment ofup to $50,000 pursuant to 18 U.S.C. § 2259A; 

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g. restitution to the victim or to the community, which may be mandatory under 

the law; 

h. registration as a sex offender under the Sex Offender Registration and 

Notification Act; 

1. costs of incarceration and supervision; and 

J. forfeiture of property. 

ELEMENTS OF THE OFFENSE: 

In order to establish the offense alleged in Count One of the Information, charging a 

violation of 18 U.S.C. §§ 225 l(a) and (e), the government must prove the following 

elements beyond a reasonable doubt: 1 

Second: 

Third: 

That the defendant used, persuaded, induced, enticed, or coerced a minor to 

engage in sexually explicit conduct; 

That the defendant acted with the purpose of producing a visual depiction 

of such conduct; and 

That the visual depiction was produced using materials that have been 

mailed, shipped, or transported in or affecting interstate or foreign 

commerce by any means, including a computer. 

STIPULATION OF FACTS: 

1. Defendant Clois Glenn Raborn admits and agrees that between on or about June I, 

2016, through on or about Februa1y 28, 2019, in the Northern District of Texas, he did 

use a minor, Minor Victim 1, to engage in sexually explicit conduct for the purpose of 

producing any visual depiction of such conduct, and the visual depiction was produced 

using materials that had been mailed, shipped and transported in and affecting 

interstate and foreign commerce by any means, including by computer. Specifically, 

Raborn used an Apple iPhone 6s IMEI unknown, a silver HP Laptop computer serial 

number 5CH1411BW3, and a Silver MultiCard 16GB USB serial number 

0XECC3800678047 to produce the following visual depiction of a prepubescent 

minor engaged in sexually explicit conduct: 

l Fifth Circuit Pattern Jury Instruction 2.84 (S'h Cir. 2019). 

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File Name File Description 

7e0bd000742d0f0 l .bmp An image with Raborn's fingers moving MVl 's 

underwear to the side, exposing her genitals. 

Raborn's penis is visible on top of MVl 's leg. 

2. The image in paragraph was taken at Raborn's residence, which is within the Fort 

Wmth Division of the Northern District of Texas. 

3. Raborn knew that the image depicted a real minor. Raborn admits that he used Minor 

Victim 1 to produce sexually explicit visual depictions of Minor Victim I, while 

Raborn was in the Northern District ofTexas. Raborn stipulates that the Apple iPhone 

6s IMEi unknown, silver HP Laptop computer serial number 5CH1411BW3 with 

Lite-On LA-512M3S-ZI 512GB SSD serial number 002241118539, and a Silver 

MultiCard 16GB USB serial number 0XECC3800678047 were manufactured and/or 

assembled outside of Texas and therefore the charged depiction was produced using 

materials that had been mailed, shipped, or transpo1ted in or affecting interstate or 

foreign commerce by any means, including by computer. 

i~~--fL-----1---

CL 

Defendant 

Factual Resume - Page 3 

A TTICUS GILL 

Attorney for Defendant 

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