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CHARGE I: Violation of the UCMJ, Article 120b

Specification 1: In that TECHNICAL SERGEANT DAVID L. HELM, United States Air Force,
375th Aeromedical Evacuation Squadron, Scott Air Force Base, Illinois, did, at or near
LaFollette, Tennessee, on or about 18 May 2014, commit a sexual act upon [Victim 1], a child who had
not attained the age of 16 years, to wit: penetrating her vulva with his penis, by using force against her, to
wit: using physical strength sufficient to overcome her.
Specification 2: In that TECHNICAL SERGEANT DAVID L. HELM, United States Air Force,
375th Aeromedical Evacuation Squadron, Scott Air Force Base, Illinois, did, at or near
Gatlinburg, Tennessee, between on or about 1 March 2014 and on or about 31 March 2014, commit a
sexual act upon [Victim 1], a child who had attained the age of 12 years, but had not attained the age of
16 years, to wit: penetrating her vulva with his finger, with the intent to gratify his sexual desire.
Specification 3: In that TECHNICAL SERGEANT DAVID L. HELM, United States Air Force,
375th Aeromedical Evacuation Squadron, Scott Air Force Base, Illinois, did, at or near Scott Air Force
Base, Illinois, between on or about 20 November 2013 and on or about 1 December 2013, commit a
sexual act upon [Victim 1], a child who had attained the age of 12 years, but had not attained the age of
16 years, to wit: penetrating her vulva with his finger, with the intent to gratify his sexual desire.
Specification 4: In that TECHNICAL SERGEANT DAVID L. HELM, United States Air Force,
375th Aeromedical Evacuation Squadron, Scott Air Force Base, Illinois, did, at or near Scott Air Force
Base, Illinois, between on or about 20 November 2013 and on or about 1 December 2013, commit lewd
acts upon [Victim 1], a child who had not attained the age of 16 years, to wit: touching her chest and
thighs with his hand, and kissing her neck with his mouth, with the intent to gratify his sexual desire.
CHARGE II: Violation of the UCMJ, Article 120c
Specification 1: In that TECHNICAL SERGEANT DAVID L. HELM, United States Air Force,
375th Aeromedical Evacuation Squadron, Scott Air Force Base, Illinois, did, at or near Scott Air Force
Base, Illinois, between on or about 14 July 2013 and on or about 23 July 2013, wrongfully and knowingly
broadcast a photograph the accused knew or reasonably should have known was of the private area of
[Victim 2], was recorded without her consent, and was recorded under circumstances in which [Victim 2]
had a reasonable expectation of privacy.
Specification 2: In that TECHNICAL SERGEANT DAVID L. HELM, United States Air Force,
375th Aeromedical Evacuation Squadron, Scott Air Force Base, Illinois, did, at or near Scott Air Force
Base, Illinois, between on or about 14 July 2013 and on or about 23 July 2013, wrongfully and knowingly
film the private area of [Victim 2], without her consent, and under circumstances in which [Victim 2] had
a reasonable expectation of privacy.

ADDITIONAL CHARGE I: Violation of the UCMJ, Article 120b


Specification 1: In that TECHNICAL SERGEANT DAVID L. HELM, United States Air Force,
375th Aeromedical Evacuation Squadron, Scott Air Force Base, Illinois, did, at or near Dayton, Ohio,
between on or about 1 January 2013 and on or about 1 May 2013, commit a sexual act upon
[Victim 2], to wit: penetrating the vulva of [Victim 2] with his finger, by causing bodily harm to her, to
wit: penetrating the vulva of [Victim 2] with his finger without her consent.
Specification 2: In that TECHNICAL SERGEANT DAVID L. HELM, United States Air Force,
375th Aeromedical Evacuation Squadron, Scott Air Force Base, Illinois, did, at or near Dayton, Ohio,
between on or about 1 March 2013 and on or about 1 November 2013, commit a sexual act upon
[Victim 2], to wit: penetrating the vulva of [Victim 2] with his finger, by causing bodily harm to her, to
wit: penetrating the vulva of [Victim 2] with his finger without her consent.
ADDITIONAL CHARGE II: Violation of the UCMJ, Article 128
Specification: In that TECHNICAL SERGEANT DAVID L. HELM, United States Air Force,
375th Aeromedical Evacuation Squadron, Scott Air Force Base, Illinois, did, at or near Dayton, Ohio,
between on or about 1 March 2013 and on or about 1 January 2012 and on or about 1 July 2012,
unlawfully place a capsule into [Victim 2]'s mouth, with his hand, without her consent.

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