Federal Grand Jury Indicts Two for Child Exploitation Offenses as a Result of Undercover Law Enforcement Operation in Owensboro

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BOWLING GREEN, KY – A federal grand jury in Bowling Green returned two indictments on November 10, 2021, charging a Utica, Kentucky man and a Georgetown, Indiana man with federal child exploitation offenses.  The charges were announced by Michael A. Bennett, Acting United States Attorney, Western District of Kentucky, Kentucky Attorney General Daniel Cameron, and United States Secret Service Special Agent in Charge Robert Holman of the Louisville Field Office.

The charges were the result of a joint federal, state, and local operation called Operation Angel, aimed at making federal arrests of individuals who prey upon children in the Owensboro area.  The operation was headed by the United States Secret Service and included the United States Attorney’s Office for the Western District of Kentucky, the Kentucky Office of the Attorney General, the Kentucky State Police, and the Owensboro Police Department.    

According to court documents, 41-year-old Timothy Richard Simone, of Utica, is charged with attempted enticement of a minor and attempted transfer of obscene material to a minor.  He faces not less than 10 years’ imprisonment for the enticement charge, and not more than 10 years’ imprisonment for the obscenity charge.  The maximum penalty Simone faces is life imprisonment.       

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Bradley Linderman, 34, of Georgetown, Indiana, is also charged with travelling across state lines with intent to engage in illicit sexual conduct with a minor, attempted enticement of a minor, and attempted transfer of obscene material to a minor.  He faces not less than 10 years’ imprisonment for the enticement charge, not more than 30 years’ imprisonment for the charge of interstate travel to engage in illicit sexual conduct with a minor, and not more than 10 years’ imprisonment for the obscenity charge.  The maximum penalty Linderman faces is life imprisonment. 

If convicted, a federal district court judge will determine any sentence imposed upon Simone and Linderman after considering the U.S. Sentencing Guidelines and other statutory factors.

Simone and Linderman are scheduled to be arraigned in Owensboro on November 23, 2021, before U.S. Magistrate Judge H. Brent Brennenstuhl of the U.S. District Court for the Western District of Kentucky.  

The United States Secret Service, Kentucky Office of the Attorney General, Kentucky State Police, and the Owensboro Police Department are investigating the cases.

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Assistant U.S. Attorney A. Spencer McKiness is prosecuting the cases.

An indictment is merely an allegation and all defendants are presumed innocent until proven guilty beyond a reasonable doubt in a court of law.


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This case was brought as part of Project Safe Childhood, a nationwide initiative launched in May 2006 by the Department of Justice to combat the growing epidemic of child sexual exploitation and abuse. Led by the United States Attorneys’ Offices and the Criminal Division’s Child Exploitation and Obscenity Section, Project Safe Childhood marshals federal, state, and local resources to locate, apprehend, and prosecute individuals who sexually exploit children, and to identify and rescue victims.

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