'The Real Housewives of Orange County' season 11 news: Vicki Gunvalson's topless photo triggers FBI investigation

"The Real Housewives of Orange County" ("RHOC") star Vicki Gunvalson is reportedly being investigated by the FBI because of a topless photo that ended up on the Twitter account of a 15-year-old.

The snap of Gunvalson with her breasts exposed was taken while the "RHOC" cast was filming a retreat in Dublin, Ireland. TMZ says that Gunvalson's "RHOC" castmate Tamra Judge, with whom she has an ongoing feud, allegedly sent the photo around. Production sources claim that Judge took the racy photo and sent it to the reality show's producers and cast members with some nasty comments.

The FBI complaint is said to have been filed by a woman who saw the photo after it was tweeted by a 15-year-old girl. "[Judge] asked [the girl] to distribute it online in an effort to harass and humiliate one Vicki Gunvalson," the complaint reads.

Manhattan defense attorney Lance Fletcher told Fox News that he expects the case will reach a dead end as the nature of the complaint is difficult to prove.

"There are a number of federal laws designed to protect children from sexually explicit material through the internet," Fletcher says. "It is illegal... to knowingly use computer services to make obscene material available to a minor under 18 years old," he continues.

"There is merit to claim but this type of thing happens on the Internet so often that enforcement is somewhat rare," he adds.

TMZ says that the reason Gunvalson was topless in the snap is that her "RHOC" castmate Heather Dubrow was, at the time, FaceTiming her husband, plastic surgeon Terry Dubrow. Gunvalson is said to have exposed her breasts so that Dubrow could examine her nipples, "which she felt were uneven."

Fox News reports that the FBI declined to comment on, confirm or deny the investigation. Bravo also declined to comment, as did Gunvalson's and Judge's representatives.

The three-part reunion special of "The Real Housewives of Orange County" season 11 airs over three consecutive Mondays, beginning Nov. 7, at 10 p.m. EDT on Bravo.