1

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF INDIANA 

HAMMOND DIVISION 

 

UNITED STATES OF AMERICA ) 

 ) Case No. 2:13 CR 00036 RL-APR 

 v. ) 

 ) 

CHRISTOPHER M. BOUR ) 

MOTION FOR VICTIM RESTITUTION

Comes now the United States of America through Assistant United 

States Attorney Jill Koster to request that the Court enter an order requiring 

Defendant Christopher M. Bour (hereafter “Defendant”) to pay victim 

restitution of $37,500 to each of Jane Doe and Jane Doe 2 pursuant to 18 

U.S.C. § 2259 and Paroline v. United States, 134 S. Ct. 1710, 1722 (2014), and 

in support thereof states as follows: 

1. On June 5, 2013, a superseding indictment was returned by a 

grand jury in this judicial district charging Defendant with 

purchasing Jane Doe, an infant child, knowing that, as a 

consequence of the purchase, she would be portrayed in a visual 

depiction assisting him to engage in sexually explicit conduct in 

violation of 18 U.S.C. § 2251A(b) (Count 2), producing child 

pornography featuring Jane Doe (Counts 3 and 4) and Jane Doe 2 

USDC IN/ND case 2:13-cr-00036-DRL-APR document 95 filed 07/25/14 page 1 of 10
2

(Count 5) in violation of 18 U.S.C. § 2251(a), and possession of 

child pornography in violation of 18 U.S.C. § 2252(a)(4) (Count 8). 

DE # 32. A forfeiture allegation included in the superseding 

indictment specifically identified the residence where Defendant 

lived at the time of his arrest: 5190 Indiana Place in Gary, 

Indiana. Id., p. 9. Due to the government’s filing of a lis 

pendens on that property, the parties subsequently entered into 

an agreement that allowed for the sale of the property so long as 

the net proceeds – which totaled $8,803.64 – were maintained in 

U.S. Marshal custody pending the outcome of this prosecution. 

2. On January 23, 2014, Defendant filed notice of his intent to plead 

guilty to all of the charges against him without the benefit of a 

plea agreement with the government. DE # 47. A change of plea 

hearing was then held and, on January 30, 2014, the Court 

accepted Defendant’s guilty plea as to all counts. DE # 50. 

3. Defendant was sentenced on May 15, 2014. DE # 67. At the 

hearing, the government informed the Court that Defendant, 

through counsel, had agreed to pay most of the net proceeds 

USDC IN/ND case 2:13-cr-00036-DRL-APR document 95 filed 07/25/14 page 2 of 10
3

($8,803.641) from the sale of his Gary, Indiana house to victims 

Jane Doe and Jane Doe 2 in restitution. See DE # 66, p. 18. 

Although the government intended to seek more than that amount 

on the victims’ behalf, it notified the Court, pursuant to 18 U.S.C. 

§ 3664(d)(5), that the victims’ losses were not yet ascertainable 

and asked the Court to set a deadline 90 days after sentencing to 

award restitution. See DE # 67. At that time, the government 

was working to have a Guardian Ad Litem appointed who could 

establish a bank account for the victims’ benefit into which future 

restitution payments could be made. See DE # 66, p. 18. The 

Court set a restitution deadline of August 5, 2014. DE # 67. 

4. On May 21, 2014, the Superior Court of Lake County entered an 

order appointing attorney Geoffrey Giorgi as Guardian Ad Litem 

for the Estate of Minor Children Jane Doe and Jane Doe 2. 

Thereafter, attorney Giorgi worked with Horizon Bank to 

establish bank accounts for the benefit of each minor victim. On 

June 19, 2014, the undersigned received confirmation that said 

bank accounts had been established. 

 1 Defendant’s agreement to contribute these funds was contingent upon $500 being 

subtracted from the total amount ($8,803.64) held by the U.S. Marshal to pay for the $100 

special assessment per count that Defendant also owes.

USDC IN/ND case 2:13-cr-00036-DRL-APR document 95 filed 07/25/14 page 3 of 10
4

5. Between June 23, 2014 and July 18, 2014, the undersigned 

participated in settlement negotiations with counsel for 

Defendant as well as counsel for co-Defendant, Natisha Hillard 

(hereafter “Hillard”). Hillard agreed to pay restitution totaling 

$12,500 to each of Jane Doe and Jane Doe 2 in this case (a joint 

motion seeking to include said restitution in Hillard’s judgment 

will be filed shortly). On July 18, 2014, the undersigned was 

informed by counsel for Defendant that he would not agree to pay 

any additional amount of restitution. Thus, the government 

hereby asks the Court to order Defendant to pay restitution to the 

victims in the instant case. 

6. That Defendant sexually abused Jane Doe on videotape and took 

sexually explicit photographs of Jane Doe 2 is undisputed. See DE 

# 50 (change of plea hearing), #93 (transcript of change of plea 

hearing). Indeed, because Defendant documented the abuse and 

exploitation, this Court has already witnessed it first-hand. See 

DE # 62, 89. 

7. Federal law characterizes orders of restitution as “mandatory” for 

all offenses falling within Chapter 110 of the United States Code, 

USDC IN/ND case 2:13-cr-00036-DRL-APR document 95 filed 07/25/14 page 4 of 10
5

which includes Defendant’s offenses of conviction. 18 U.S.C. § 

2259(a). Subsection (b)(1) of Section 2259 states that said 

restitution orders “shall direct the defendant to pay the victim 

(through the appropriate court mechanism) the full amount of the 

victim’s losses as determined by the [C]ourt.” Those losses can 

include costs incurred by the victim for “medical services relating 

to physical, psychiatric, or psychological care,” among others. 18 

U.S.C. § 2259(b)(3)(1). 

8. Reasonable estimates of likely future costs to a victim are properly 

included in restitution awards. See Paroline v. United States, 134 

S. Ct. 1710, 1722 (2014); United States v. Danser, 270 F.3d 451, 

455 (7th Cir. 2001) (upholding a restitution award that included 

estimated costs for future counseling); United States v. Laney, 189 

F.3d 954, 966 (9th Cir. 1999) (“Section 2259 is phrased in generous 

terms, in order to compensate the victims of sexual abuse for the 

care required to address the long term affects of their abuse.”); 

United States v. Pearson, 570 F.3d 480, 487 (2nd Cir. 2009) (“[A] 

restitution order pursuant to 18 U.S.C. § 2259 may include 

restitution for estimated future medical expenses.”). 

USDC IN/ND case 2:13-cr-00036-DRL-APR document 95 filed 07/25/14 page 5 of 10
6

9. Victims need not provide sworn testimony or otherwise participate 

in restitution proceedings. See 18 U.S.C. § 3664(g)(1). Under 

Section 2259, the term “victim” means any individual harmed as a 

result of a commission of a crime” and includes, in the case of 

minor victims, their legal guardian or a representative of their 

estate. See 18 U.S.C. § 2259(c). 

10. In this case the government is asking the Court to order 

Defendant to pay $37,500 in restitution to each of Jane Doe and 

Jane Doe 2. According to the report submitted by Licensed 

Clinical Psychologist Myra D. West, each victim in this case is 

likely to need “a minimum of 5-10 years of counseling, once a 

week” at an average cost of $125 per session. See Exhibit 1, filed 

herewith. Five years of weekly therapy sessions at that rate adds 

up to $32,500 (5x52x125=$32,500). Ten years of weekly therapy 

sessions at that rate adds up to $65,000 (10x52x125=$65,000). 

Even according to Dr. West those estimates are conservative. See 

Exhibit 1, p. 2 (asking the reader to keep in mind that the victims 

may suffer “significant, potentially lifelong” effects from their 

sexual abuse and trauma and that her estimated treatment range 

USDC IN/ND case 2:13-cr-00036-DRL-APR document 95 filed 07/25/14 page 6 of 10
7

of 5 to 10 years “could, in fact, be much longer”). Further, those 

estimates do not include in-patient psychological treatment nor 

costs associated with outpatient treatment such as prescription 

drugs. The figures also do not account for inflation. 

Nonetheless, the government believes it is reasonable to conclude, 

based upon Dr. West’s report, that each victim in this case will 

spend a minimum of $50,000 on future psychological treatment as 

a result of her abuse and exploitation in this case. 

11. When more than one defendant has contributed to a victim’s 

losses, 18 U.S.C. § 3664(h) gives the Court the option of holding 

them both jointly and severally liable for the full amount or 

“apportion[ing] liability among the defendants to reflect the [each 

person’s] level of contribution to the victim’s loss”. Because a 

settlement has been reached with Hillard, the government urges 

the Court to apportion the harm caused to the victims in this case 

and, for the following reasons, believes it is appropriate for 

Defendant to be held responsible for 75% of said harm: 

a. Bour proposed that he sexually abuse the victims and 

attempted to put Hillard at ease by claiming to have had a 

similar arrangement in the past with a woman from Illinois; 

USDC IN/ND case 2:13-cr-00036-DRL-APR document 95 filed 07/25/14 page 7 of 10
8

b. Bour induced Hillard, a single unemployed mother with few 

reliable sources of financial support, to consent to the abuse 

by offering to pay her cash in exchange for each abuse 

session; 

c. Bour alone sexually abused Jane Doe and took the sexually 

explicit photographs of Jane Doe 22; 

d. Bour threatened Hillard that if she did not allow the abuse 

to continue, he would report her to Child Protective Services 

and she could lose custody of her children; 

e. Bour initiated most of the approximately eight abuse 

sessions that took place; and 

f. According to a psychologist who examined Hillard, she has 

an IQ of 75 and due to her background and circumstances 

was particularly susceptible to Bour’s manipulation. 

12. If the Court agrees that $50,000 is a reasonable estimate of 

each victim’s likely future losses and that 75% of that harm should 

be apportioned to Defendant, the government respectfully 

requests that the Court enter an Order requiring Defendant to pay 

$37,500 in restitution to each of Jane Doe and Jane Doe 2. As 

explained above, Hillard has agreed to pay each victim the 

remaining $12,500. 

WHEREFORE, the government respectfully requests that the Court 

 

2 Although Hillard was present in the room and held the videocamera during at 

least one session, she did not directly participate in the abuse. 

USDC IN/ND case 2:13-cr-00036-DRL-APR document 95 filed 07/25/14 page 8 of 10
9

enter an Order that includes the following or similar language setting forth a 

requirement that Defendant pay each victim in this case $37,500 in restitution 

pursuant to 18 U.S.C. § 2259: 

The Court hereby Orders Defendant to pay, forthwith, a total of 

$75,000 in victim restitution to the Clerk of the Court in this 

judicial district. As Defendant has already agreed to pay toward 

this debt $8,303.64 which is currently being held by the U.S. 

Marshal, the Court Orders the U.S. Marshal to surrender those 

funds to the Clerk of the Court immediately. The Clerk of the 

Court is ordered, in turn, to disburse those and any future funds 

received from Defendant (or on his behalf) to Jane Doe and Jane 

Doe 2 c/o attorney Geoffrey Giorgi at 9205 Broadway, Suite B, 

Merrillville, IN 46410 (Telephone: 219-738-1133). Pursuant to 

his appointment by the Lake County Superior Court, attorney 

Geoffrey Giorgi is, in turn, directed to equally divide any and all 

restitution funds received in this case and to deposit those funds 

into Horizon Bank Account # 2627313 and/or Horizon Bank 

Account # 2627326, which accounts are to be maintained for the 

sole benefit of Jane Doe and Jane Doe 2 until this restitution 

obligation has been met in full and all funds collected have been 

disbursed to Jane Doe and Jane Doe 2, or, in the case of their early 

passing, to their heirs. 

 

 Respectfully submitted, 

DAVID CAPP 

United States Attorney 

By: / S / Jill Rochelle Koster 

JILL ROCHELLE KOSTER 

Assistant United States Attorney 

5400 Federal Plaza, Suite 1500 

Hammond, Indiana 46320 

(219) 937-5500 

 

USDC IN/ND case 2:13-cr-00036-DRL-APR document 95 filed 07/25/14 page 9 of 10
10

CERTIFICATE OF SERVICE 

I hereby certify that on July 25, 2014, I electronically filed the foregoing 

with the Clerk of the Court using the CM/ECF system which sent notification 

of such filing to defense counsel of record. 

By: / S / Jill Rochelle Koster 

JILL ROCHELLE KOSTER 

Assistant United States Attorney 

5400 Federal Plaza, Suite 1500 

Hammond, Indiana 46320 

(219) 937-5500 

USDC IN/ND case 2:13-cr-00036-DRL-APR document 95 filed 07/25/14 page 10 of 10