(COMMONWEALTH OF MASSACHUSETTS, SUFFOLK, Ss SUPERIOR COURT DEPARTMENT DOCKEY NO. 1864CRO0252 ‘COMMONWEALTH es BRYON HEFNER COMMONWEALTH’S STATEMENT OF THE CASE Now comes the Commonwealth and, for the courts edification only, respectfully files this Statement ofthe Case, The defendant, Bryon Hefner, is charged with five counts of indecent assault and battery, one count of open and gross lewdness, and four counts of | Uunlawflly disseminating a secretly obtained image of a nude or partially nude person. ‘The alleged vitims and witnesses mentioned below are identitied by numbers and letters to protect their identities On June 18, 2015, the defendant and Person 1 met far drinks in bar in Boston and went from there to the defendant's condo on Beacon Hill, As they sat on the couch inthe living room the defendant reached over, put his hand between Person I's leg, and grabbed Person I's ‘genitals through his clothes without his consent. Person 1 pushed the defendant's hand away. {he defendant repeated this action several more times and atone point unzipped Person 1°s Pants. Fach time Person 1 again pushed the defendant's hand aside, Person | escaped this situation by going to the bathroom and staying there until a mutual fiiend ofhis and the defendant arrived, at which point Person I quickly left the apartment. (On Apri 19, 2016, Person 1 traveled withthe defendant and two other people from one politcal =vent to another event in Boston, Person 1 was in the backseat of «car with the defendant. The defendant reached over, put his hand between Person 1's legs, and touched his ‘genitals over Person 1's clothes. As he had done the previous spring, Person 1 pushed the Ths Stet ofthe Cs summary of he eis nthe. hs ot intend be complete sateen ofthe for evidence that the Commonwealth wil ey upon t Wal oe disposton, =D 7 APRdefendant's hand away. The defendant grabbed Person 1's genitals again, and Person 1 pushed him away again and told the defendant, “Screw off” The defendant did not touch Person I again inthe a, but they ended up seated next to each other at dinner at the Boston event. The ‘defendant grabbed Person 1's genitals through his clothes under the table, again without his ‘consent. Person 1 got up to take a phone call and stayed away from the table as long ashe could. (Gn August 21, 2016, Person 2 and his wife joined a small group to celebrate a fiend’s birthday in Boston. ‘The gathering moved from brunch ata restaurant tothe roof deck of an apartnert building, where the defendant joined the group later in the aflemoon. Person 2 had ‘met the defendant once before but they were nt friends, On the roof deck the defendant made ‘unsolicited comments referring to Person 2 as “hot.” As the group left the building in early evening, the defendant suddenly pulled Person 2 close and kissed him aggressively on the lips ‘Without His consent, Person 3 first met the defendant in June 2014 and they became elose friends, In the fll (of 2014 at the defendant's condo in Boston, the defendant undid Person 3°s belt and pants and ‘tie to stick his hands inside Person 3°s underwear. The defendant was able to touch Person 3° enitas though his underwear before Person 3 pushed him away and retreated into the bathroom. Person 3 was angry at the defendant but maintained the friendship for a period of time, during ‘which the defendant assaulted him inthis manner several more times without his consent. InJune 2016, Person 3 planned to goto a party hosted by Person 1, the first victim. ‘identified above. The defendant trie to invite himself along but Person | said the defendant was not welcame. Instead Person 3 took the defendant to Person 3's own apartment in Boston Person 3 wanted to rest for 2 while and told the defendant to wait inthe living room. The defendant repeatedly eame into Person 3°s room and tried o climb into bed with him. Person 3 became irreasingly uneasy and pushed the defendant away each time, When the defendant ‘entered the bedroom the final time he dropped his own pants to his ankles and exposed his penis and buttocks to Person 3, who did not invite this behavior and was shocked and alarmed by it Person 3 again ordered the defendant out of the bedroom, and soon after found thatthe front door was wide open and the defendant was gone Person 4 intially met the defendant in 2011. In December 2013, Person 4 and the defendant attended a conference that spanned several days. Person 4 recalled consuming a large amount ofalcohol one night at the conference and being ina hotel suite wit the defendant,‘When Person 4 awoke the next moming, he was naked and alone in his own hotel room bed, with no memory of how he got there. Several years later, Person 4 leamed tha the defendant ‘was in possession of naked photographs of him. Person 4 never consented to have the defendant ‘ake nude or partially nude images of him in December 2013 or at any other time, and never consented fo the display of such images to any other person. Boston and State Police located four individuals who reported thal at various separate ‘mes in Boston from December 2013 through 2015, the defendant shoved them images on his, cellphone that depicted Person 4 with his genitals and/or buttocks exposed. The defendant did so ina casual and boastful manner and identified the subject as Person 4 while showing the images to Persors A, B and C. Person D knew Person 4 and recognized him asthe person depicted April 24,2018 Respectfully submitted For the Commonwealth, AURA HEALEY. ATTORNEY GENERAL ‘Assistant Attomey General One Ashburton Place, 19* Door Boston, MA 02108 (617) 727-2200 BOF 661427 Tan Polumbauim Special Assistant Attormey General ‘One Bulfinch Place Boston MA 02114 (617) 619-4000 BBO# 566597Mr. Hefier Rosenberg has pled not gully to the charges and looks forward to defending hhimselfin a court of law where accusers cannot remain anonymous and must face 05s- examination. Unfortunately, he has already been pilloried inthe press for political purposes, having never had a tal/8 €4CR 06 ASR INDICTMENT #02! indecent Assault & Battery SUCROUI8- ‘on Person Fourteen or Over Gil6. 265, § 138 Commonwealth oS Massachusetts SUFFOLK, ss. A the SUPERIOR COURT, begun and holden at the CITY OF BOSTON, within and forthe County of SUFFOLK on the last Thursday of March inthe year two thousand and eighteen. ‘THE JURORS for the COMMONWEALTH OF MASSACHUSETTS on their oath present that BRYON HEFNER on or about June 18, 2015, in a residential building in the County of Suffolk, did commit an indecent assault and battery on Person I, a person who had attained age fourteen, said indecent assault ard battery occurring in violation of G.L.¢. 265, §13H, ‘Against the peace ofthe Commonwealth, and contrary to the form of the statute in such case made and provided. : A Tne Bill, vant Ktforney General Supesior Court Deparment - Criminal Business AR @ 2 2018 March Siting, 2018 ‘Returned into said Superior Court by the Statewide Grand Jurors and ordered to be filed. Premen L. Morn ce q”J€ €4 CR OF AGA INDICTMENT ODL Indecent Assault & Battery SUCR2O8- ‘on Person Fourteen or Over GL. 6.265, § 13H Commentwealth of Maisachusetts SUFFOLK, ss. At the SUPERIOR COURT, begun and holden at the CITY OF BOSTON, within and for the County of SUFFOLK on the last Thursday of March i the year two thousand and eighteen, ‘THE JURORS for the COMMONWEALTH OF MASSACHUSETTS on their oath present that BRYON HEFNER ‘on orabout April 19,2016, ina car located in or near the County of Suffolk, did commit an indecent assault and battery on Person 1, @ person who had attained age fourteen, said indecent assault and battery oscurring in violation of G.L ¢. 265, § 13H, ‘Against tie peace ofthe Commonwealth, and contrary to the form of the statue in such ease made and provided, A True Bill, ieapd Jury Poreperson Supevior Court Department - Criminal Business MAR 2 9 2G Merch Sitting, 2018, ‘Returned into said Superior Court by the Statewide Grand Jurors and ordered to be file.JECYCR 003G2 INDICTMENT {0% Indecent Assault & Battery SUCR2OIB- dn Person Fourteen oF Over Give. 265, § 130 Commonwealth of Masachusetts SUFFOLK, ss A: the SUPERIOR COURT, begun and holden at che CITY OF BOSTON, within and for the County of SUFFOLK on the last Thursday of March inthe year two thousand and eighteen. ‘THE JURORS for the COMMONWEALTH OF MASSACHUSETTS on their oath present chat BRYON HEFNER ‘on or about April 19, 2016, ina restaurant inthe County of Suffolk did commit an indecent assault and battery on Person 1, person who had attained age fourteen, said indecent assault and battery ‘occurring in violation of G.L. , 265, § 13H. Against the peace ofthe Commonwealth, and contrary to the form ofthe statute in such case made and provided. A Tre Bill Gang JuqForepetson Superior Court Department Criminal Business MAR 2 $ 2018 March sitting, 2018 Returned into std Superior Court by the Statewide oa Jurors and ondered to be filed asc UPesson Mensa] GaramINDICTMENT. ‘#00. Indecent Assault & Battery SUCRIO8- ‘on Person Fourteen or Over GL. 6.265, § 13H % emmonwwealth of Mabsachuselts SUFFOLK, ss, At the SUPERIOR COURT, begun and holden at the CITY OF BOSTON, within and forthe County of SUFFOLK on the last Thursday of March inthe year two thousand and eighteen. ‘THE JURORS for the COMMONWEALTH OF MASSACHUSETTS on their oath present that BRYON HEFNER om or abeut August 21, 2016, ata residential building in the County of Suffolk, did commit an ‘indecent assault and battery on Person 2, a person who had attained age fourteen, said indecent assault and battery occurring in violation of GL. c, 265, § 13H. ‘Aaninst the peace of the Commonwealth, and contrary to the form of the statute in such ease made and provised. A Tre Bill Grand Jur Forghersén Superior Court Department - Criminal Business MAR 29 2098 March Sitting, 2018 Returned into said Superior Court by the Statewide Grand Jurors and ordered tobe file. ‘reno A. Menage Clerk of Court