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In violation of Title 18, United States Code, Sections 2261A(2) and 2261(b).
COUNT 8

Between on or about January 24, 2017 and March 1, 2017, in the District of
Arizona, the defendant, MELISSA ANN SANTANA, with the intent to harass or
intimidate D.S., used facilities of interstate and foreign commerce, to-wit, interactive
computer services, electronic communication systems of interstate commerce or any
other facility of interstate or foreign commerce to engage in a course of conduct that
caused, attempted to cause or would reasonably have been expected to cause substantial
emotional distress to D.S. and members of D.S.’s immediate family.

In violation of Title 18, United States Code, Sections 2261A(2) and 2261(b).

A TRUE BILL

KYA
FOREPERSON OF THE GRAND JURY
Date: November 14, 2017

ELIZABETH A. STRANGE
Acting United States Attorney
District of Arizona

s/
CAMILLE D. BIBLES
Assistant U.S. Attorney



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REDACTED FOR
PUBLIC DISSUISURE

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF ARIZONA

United States of America, CR-17-08284-PCT-GMS(DKD)

Plaintiff,
INDICTMENT

VIO: 18U.S.C. § 1001(a)(2)
. (Makes any materially false, fictitious,
Melissa Ann Santana, or fraudulent statement or

representation)
Defendant. Counts 1 - 3

Vs.

18 U.S.C. §§ 2261A(2) & 2261(b)
(Stalking)
Counts 4 - 8

THE GRAND JURY CHARGES:

Atall times material to this indictment, within the District of Arizona and elsewhere:

COUNT 1

On or about September 9, 2016, in Coconino County, in the District of Arizona,
the defendant, MELISSA ANN SANTANA, in a matter within the jurisdiction of the
executive branch of the Government of the United States, did knowingly and willfully
make a materially false statement and representation, in that MELISSA ANN
SANTANA, did falsely represent to three federal officials of the United States Forest
Service, W.K., A.P. and G.O., all Flagstaff Hotshot Crew supervisors, that she had a
teenage daughter who was sexually assaulted by Arizona based federal firefighters
while fighting a fire in Wyoming, when in fact she created a false e-mail identity, does
not live in Wyoming, does not have a daughter and no such assault took place.

In violation of Title 18, United States Code, Section 1001(a)(2).



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COUNT 2
On or about September 29, 2016, in Coconino County, in the District of Arizona,
the defendant, MELISSA ANN SANTANA, in a matter within the jurisdiction of the
executive branch of the Government of the United States, did knowingly and willfully
make a materially false statement and representation, in that MELISSA ANN
SANTANA, did falsely represent to a federal official of the United States Forest
Service, Globe Hotshot Crew Superintendent D.W., that she was a woman who a
firefighter had impregnated and that he wasn’t returning her calls, when in fact she
created a false identity and had no relationship with the firefighter.
In violation of Title 18, United States Code, Section 1001(a)(2).
COUNT 3
On or about September 29, 2016, in Coconino County, in the District of Arizona,
the defendant, MELISSA ANN SANTANA, in a matter within the jurisdiction of the
executive branch of the Government of the United States, did knowingly and willfully
make a materially false statement and representation, in that MELISSA ANN
SANTANA, did falsely represent to a federal official of the United States Forest
Service, Flagstaff Hotshot Crew Superintendent W.K., that she was a woman who a
firefighter had impregnated and that he wasn’t returning her calls, when in fact she
created a false identity and had no relationship with the firefighter.
In violation of Title 18, United States Code, Section 1001(a)(2).
COUNT 4
Between on or about February 1, 2015 and February 8, 2017, in the District of
Arizona, the defendant, MELISSA ANN SANTANA, with the intent to harass or
intimidate M.G., used facilities of interstate and foreign commerce, to-wit, interactive
computer services, electronic communication systems of interstate commerce or any
other facility of interstate or foreign commerce to engage in a course of conduct that
caused, attempted to cause or would reasonably have been expected to cause substantial

emotional distress to M.G.



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In violation of Title 18, United States Code, Sections 2261A(2) and 2261(b).
COUNT 5
Between on or about June 30, 2016 and August 1, 2017, in the District of
Arizona, the defendant, MELISSA ANN SANTANA, with the intent to harass,
intimidate or place under surveillance with the intent to harass or intimidate N.L., used
facilities of interstate and foreign commerce, to-wit, interactive computer services,
electronic communication systems of interstate commerce or any other facility of
interstate or foreign commerce to engage in a course of conduct that caused, attempted
to cause or would reasonably have been expected to cause substantial emotional distress
to N.L.
In violation of Title 18, United States Code, Sections 2261A(2) and 2261(b).
COUNT 6
Between on or about August 31, 2016 and September 22, 2017, in the District
of Arizona, the defendant, MELISSA ANN SANTANA with the intent to harass or
intimidate K.T., used facilities of interstate and foreign commerce, to-wit, interactive
computer services, electronic communication systems of interstate commerce or any
other facility of interstate or foreign commerce to engage in a course of conduct that
caused, attempted to cause or would reasonably have been expected to cause substantial
emotional distress to K.T.
In violation of Title 18, United States Code, Sections 2261A(2) and 2261(b).
COUNT 7
Between on or about September 8, 2016 and May 26, 2017, in the District of
Arizona, the defendant, MELISSA ANN SANTANA, with the intent to harass or
intimidate E.T., used facilities of interstate and foreign commerce, to-wit, interactive
computer services, electronic communication systems of interstate commerce or any
other facility of interstate or foreign commerce to engage in a course of conduct that
caused, attempted to cause or would reasonably have been expected to cause substantial

emotional distress to E.T.