Professional Documents
Culture Documents
USA V. Walker
USA V. Walker
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No. .J j.g
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UN ITE D STA TE S O F AM ER ICA
V S.
ED W AR D W A LK ER ,
D efendant.
/
CW M INA L CO V ER SH EET
D id this m atter originate from a m atter pending in the Central Region of the
United States Attorney's Office prior to August 9,2013 (M ag.Judge Alicia
Valle)? Yes X No
2. D id this m atter originate from a m atter pending in the N orthern Region of the
United States Attorney's Office priorto August8,2014 (M ag.Judge Shaniek
M aynard)? Yes X No
/
BY :
AlejandraL. 'pe
Florida BarN o.37
A ssistantU nited StatesA ttorney
Southern D istrictofFlorida
99 N E 4th Street
M iam i,Florida 33132
Te1:(305)961-9241
Email:Alejandra.Lopez@usdoj.gov
Case 1:20-cr-20087-AHS Document 1 Entered on FLSD Docket 01/31/2020 Page 2 of 15
AO 91(Rev.08/09) CfiminalComplaint
United StatesofAmerica
V.
V Continuedontheattachedsheet. V
(.NOmpI6ll'tt6ltlt'JsigltoJld/-e
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ey.G=Loff,SnecialAnent,F:I
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1,Alex G.Loff,aSpecialAgentwiththeFederalBureauofInvestigation(tCFBl''),having
been duly sw orn,hereby depose and state:
BA CK G R O U N D
2510(7)ofTitle18oftheUnited StatesCode.
1 currently sel've aspartof the Crim es AgainstChildren group and the FBlChild
Exploitation and Hum an Trafficking Task Force in the FBI's M iamiField Office. M y duties
trafticking and com mercialtrafficking of minors and the possession and production of child
including the use of sttrveillance techniques,undercover activities, and the application and
investigations,includingundercoveroperationstorecoverjuvenilevictimsofsextrafticking,and
have executed search wanuntsthathave led to seizuresofchild pornography.
advertise,m aintain and solicit by any m eans a m inor,that is,the M inor V ictim ,to engage in
Case 1:20-cr-20087-AHS Document 1 Entered on FLSD Docket 01/31/2020 Page 4 of 15
StatesCode,Section 1591(a)(1)and(b)(1),andknowing,andinrecklessdisregardofthefact,and
having had a reasonable opportunity to observe the M inorV ictim ,thatthe M inorV ictim had not
attained the age of l8 years and w ould be caused to engage in a com m ercialsex act,in violation
ofTitle18,UnitedStatesCode,Section 1591(a)(1)and(b)(2).
The statem ents eontained in this A ftidavit are based upon m y ow n personal
officials,and m y review ofrecords obtained during the course of this investigation. l have not
included in this A ffidavit each and every fact and circum stance know n to m e,butonly the facts
PR O BA BLE C A USE
on January 25,2020 atapproxim ately 11:27 p.m .on awebsite çiw ww.skipthegames.com ''thatis
know n to contain advertisem entsforcom m ercialsex acts.The advertisem ent,entitled Cûl-leyy new
and m ore
Slim beautif'ulexotic w ith sweetpersonality m y goalisto please u and m ake sure we have
a good night
labsolutely lovewhitem en
Please no m en under40
M atureonly pleaseany questionsask callcan facetime ifu haveduo to speak and see im
Seven2o5one927six5.''
6. Based on their training and experience, 1aw enforcem ent knew that
Other law enforcem entofficers then knocked on the doorand w ere allow ed into the room by the
with herfriendsw ho she believed w ere at South Beach, identified as tw o fem ales and one m ale.
V ictim 1 w as then taken to M iam i-D ade Police D epartm ent's Special V ictim Bureau to be
rOOm .
Case 1:20-cr-20087-AHS Document 1 Entered on FLSD Docket 01/31/2020 Page 6 of 15
hotel. A sthe M inorV ictim approached R oom 206 she w astaken into custody.A shorttim e later,
Fem ale 1 and W A LK ER were also taken into custody as they approached Room 206.The M inor
Victim ,Fem ale 1,and W A LK ER w ere then a11taken to M iam i-D ade Police D epartm ent to be
interdew ed.
lnterview ofVictim 1
through January 29,2020. In the interview ,V ictim l stated she w as from Connecticut,and that
she knew the M inorV ictim as û$Red.''She further stated she m etthe M inor V ictim on a cellular
W A LKER.
10. V ictim 1 further stated that the M inor V ictim , Fem ale 1, and W A LK ER w ere
plalm ing on m oving to A rizona,butdecided to com e dow n to M iam iforvacation beforethe m ove.
W A LKER told V ictim 1 thatthere would be a 1otof people in M iam ibecause ofthe Superbow l
anditwouldbealotoffun.Asaresult,Victim 1decidedtojointheMinorVictim,Female1,and
W A LKER in their trip to M iam i.V ictim 1 stated thatW A LKER drove the three fem ales down
from Connecticutto M iam iin hiscar.They stopped and spentanightin D aytona before continuing
the drive to M iam i,where they anived on oraboutJanuary 24,2020. V ictim 1 furtherstated that
A fler arriving in M iam i,V ictim 1 stated that W A LK ER told the three fem ales to
dressnicely because he w as taking them som ew here fun. W hen they w entoutlaterthatevening,
W ALKER took the three w om en to a strip club.V ictim 1 stated she assum ed they w ere atstrip
club to getdrugs and,in fact,she saw W A LK ER iido a transaction''and purchase plastic bagsof
w as happening in the strip club.During their tim e in the strip elub,V idim 1 saw W A LK ER
speaking alone w ith the m anager. She later found outthatW A LK ER had spoken to the m anager
12. Afterthey wentto strip club,W ALKER took thethree fem alesto M arshall'sstore
and boughtthe M inorV ictim and Fem ale 1 som e high-heeled shoes. V ictim 1 stated she stayed
in the car and did notgo into the M arshall's w ith the w om en and W A LK ER because she did not
running low on m oney.Asaresult,W ALKER took thethree wom en to Ocean Drive,in M iam i
used to describe aprostitutewalking around soliciting people forcomm ercialsex acts. V ictim 1
which began to bleed.W A LK ER then boughthydrogen peroxide and bandages, gave them to the
M inorVictim ,and told the M inorV ictim to clean up and puthershoesback to continue walking.
Because businesses on Ocean Drive generally close at 5:00 a.m .,W A LK ER did not allow the
w om en back into the hotel room until 6:00 a.m .w hen W A LKER w ould be sure that a1l the
Case 1:20-cr-20087-AHS Document 1 Entered on FLSD Docket 01/31/2020 Page 8 of 15
D rive at8:00 a.m .to continue w alking and trying to m ake m oney.W A LK ER then told the girls
thatnoonewasgoingtopaythemjusttohangoutwiththem andthat,eventually,theyhadtohave
to have sex w ith the m en they m et.
V ictim 1 also stated that, at som e point subsequent to their arrival in M iam i,
W A LKER told herhe alw aysw anted to do çûout-calls''because he didn'tw antanyone to eom ing
into theirplace.1know from m y training and experience thatan ûûin-call''is a tenn used for when
the custom er travels to the girlforthe prostitution actand an tûout-call''is a telnn used forw hen
the girltravelsto the custom er forthe prostitution act.V ictim 1furtherstated thatW A LKER told
thewom enthattheyw erenotto chargeany sex actunder$500 and wereto charge anywherefrom
$500-$1,000.Vidim 1alsostatedthatatonepointW ALKER boughtthewom en abox ofcondoms
atthe CV S Phanuacy located nearO cean D rive.
16. Afterbeing driven to Ocean Drive by W ALKER and walking fora while on his
orders,the wom en did notm akeany m oney.C onsequently,W ALKER becam e upsetatthe wom en
online fo< eom m ercial sex aets attûw w w .skipthegam es.com ''using their phone num bers on the
advertisem ents as the contactphone num ber.V ictim l further stated that W A LK ER dem anded
photographsfrom the three w om en ofthem selves. Victim 1 stated that,since she did notwantto
give W A LK ER any photos of herself,she gave W ALKER photos she found on the internetthat
resem bled her.Shortly thereafter,V ictim 1 stated she began to receive phone callsfrom unknow n
Case 1:20-cr-20087-AHS Document 1 Entered on FLSD Docket 01/31/2020 Page 9 of 15
numbers,but ignored them because she did notwantto do any kldates.'' ln m y training and
experience,Iknow thata çsdate''is a term used to describe a prostitute engaging in a com m ercial
sex actw ith a person in exchange forsom ething ofa m onetary value.
18. On or about January 27,2020, Victim 1 further stated that W A LKER took the
wom en to Ocean Drive and orderedthe wom en back tom akem oney by prostituting them selves.
However,Vidim 1 told W ALKER she was feeling sick so she could stay in the car, w hich
W A LK ER allowed herto do foran hour. V idim 1 stated she told W A LK ER she w as notfeeling
wellbecauseshedid notwanttoprostituteherself.
19. W hile V ictim l waslaying in the car,Fem ale 1 called herand told herthatshe and
the M inorV id im m ettw o m en w ho had a yacht. The w om en w anted V id im 1to com e w ith them
to the yachtbecause them en had agreed to pay thewom en $300 each for sex acts,which wasa
partoffollowing directionsfrom W ALKER to makem oney by prostituting themselves.
told W A LKER thatshe w anted to go hom e. W ALK ER had responded thatV ictim 1 could catch
told him she would geta train ride home.W ALKER had told heritwould take abouttwo to
tim e ofa return trip by train,V ictim 1agreed to go w ith the otherw om en on the yachtin orderto
1up. They then alldroveto the yacht.Afterarriving attheyacht, the M inorV ictim im m ediately
Case 1:20-cr-20087-AHS Document 1 Entered on FLSD Docket 01/31/2020 Page 10 of 15
on him .H ow ever,M ale 2 w as drunk and could notachieve an eredion. Fem ale 1 tried to dance
forhim to help him achieve an erection,butitdid notw ork. Therefore,they a11agreed to try to
to Fem ale 1 while V ictim 1w as getting dressed,even though they did nothave sexualintercourse.
Victim 1 stated she then saw Fem ale l give the m oney to the M inorV ictim . Once they returned
from the yachtand m etup w ith W A LKER,Victim 1 stated the M inorV ictim gave W A LKER the
Fem ale 1,and tried to convince V ictim 1 to shave herhead asw ell,butshe did notlethim . V idim
1 also stated thatshe saw W ALK ER thzeaten the M inorV ictim by telling the M inor V ictim that
m essages to her sister on Facebook M essenger stating her desire to go back hom e. Law
enforcem entthen requested V ictim 1 give eonsentto search herphone,which she gave. A review
ofV ictim 1's cellphone revealed a m essage on Facebook M essenger from on or aboutJanuary
24,2020 at approxim ately 7:34 p.m .ln the m essage,V ictim 1's sister asks her, ûûYou okay''to
which Victim 1replied,ç$A 1i1butim only hereto makem oney onceim akem y m ark im beback
butim begsiclsendingmoneythroughwestel'
n union.''A furtherreview ofthemessagerevealed
8
Case 1:20-cr-20087-AHS Document 1 Entered on FLSD Docket 01/31/2020 Page 11 of 15
thaton oraboutJanuary 26,2020 atapproxim ately 12:38 a.m .,V id im 1 senther sistera series of
hom e ''
1's cellular phone revealed a contactsaved underthe nam e ûilkedd,''whose the cellulartelephone
further review ofV ictim 1's cellulartelephone revealed the follow ing textconversation betw een
25. A furtherreview of Victim 1's eellular phone revealed a contact saved underthe
nam e tlW orth.''The cellular telephone num ber listed for ûûW orth''w as the sam e cellular num ber
Case 1:20-cr-20087-AHS Document 1 Entered on FLSD Docket 01/31/2020 Page 12 of 15
W ALKER provided to 1aw enforcem entas his own. Law enforcem ent also found Victim 1's
cellularphone contained severalmessages from klW orth''to Victim 1 which supported the fact
1 stating,ûsGm orning...again apologiesforthatm ix up. M y intentions w ere to link w ith you and
letyou know thefollowing. W eareleaving,m oving from CT, 1sthitting the superbowlin M iam i
9,2020 EiW orth''senta few textm essagesto V ictim 1 the stating, tûljustwantedtoextendanoffer
ofleaving with m eto you.Fresh startsom etraveland folx you knowi''tdW e willbehere ti1the
23rd,1'd loveto see you and kick itbeforew ego',''and ûûFurther 1w anna take you w ith m e, let's
via textmessage to come away with him by stating. ddGmorning...how are thingslet'skick it, w e
arebetterthan thisand you needto makethism ovewith m e, getoutofbpt,ctand the north east.''
friends and her uncle,who she identitied as W ALKER . The M inorVictim furtherstated that
,
whilein M iam i,W ALKER broughtthem to South Beach andthatthethreew om en also wenton
to Texasin thepast. Finally,theM inorVictim stated thatshehad posted two online prostitution
10
Case 1:20-cr-20087-AHS Document 1 Entered on FLSD Docket 01/31/2020 Page 13 of 15
27. O n oraboutJanuary 28,2020,1aw enforcem entalso interviewed Fem ale l. Fem ale
1stated shem etthe M inorVictim and W ALKER on the app M eetM e and, eventually,moved in
with W ALKER forafew years.Fem ale 1also stated thatshehad neverhad sex form oney before
m eeting W ALKER and the M inorVidim and wasûdadded in''to whatW ALKER and the M inor
to M iam itogether forvacation.W hile in M iam i, she stated thatthey allw entoutatnightin South
Beach and were told by W ALKER to go up and down the streetm eeting people and going on
engaging in acomm ereialsex actwith a person in exchange forsom ething ofam onetary value.
Atone point,Fem ale 1 adm itted thatthe three w om en w entouton a boatwith tw o guys who they
Interview ofW A LK ER
audio and video recorded.In hisposL-M iranda statem ent, W ALK ER stated thathe cam e to M iam i
stated thathe metthe M inorVictim approximately one and ahalfyears ago when she ran away
stated thatthe M inor V ictim and Fem ale 1 lived w ith him at his house, and that they w ere al1
30. Law enforcem enthad observed thatthe loek screenlofW ALKER'S cellphone
depicted a selfiez photograph ofhim selfand the M inor Victim . W hen asked why he had this
photograph on hisloek screen,W ALKER stated they were close friends. W A LKER denied that
31. W ALKER adm itted to law enforcementthathe had taken a vacation to Texasin
the past w ith the M inor Victim and Fem ale 1. W hen asked about the online prostitution
advertisem ents ofthe M inorVictim ,W ALKER positively identified the M inor Victim as the
person advertised, but denied know ing anything about the prostitution advertisem ents.
Florida.
asked W ALKER ifshe could have som etim e alone in the hotelroom with a friend. Because of
this,W A LKER and the otherw om en w entto his vehicle to take a nap. Afteran hour,the M inor
Vidim wentto eheck on V id im 1,atwhieh tim e the group eneountered 1aw enforcem ent.
1A lock screen isthe visualdepiction thatappears on the screen of a cellphone w hen the phone
isnotin use and locked. To getpastthe lock screen, the user w ould have to enter a passcode,
passw ord,orprovide biom etric data,such as a tingem rint.
2A seltie is a photograph in which one ofthe people in the photograph is also the person taking
the photograph.
Case 1:20-cr-20087-AHS Document 1 Entered on FLSD Docket 01/31/2020 Page 15 of 15
C O N C LU SIO N
33. Based on m y training and experience,and assupported by the factsin thisA ftidavit,
Irespectfully subm itthatthere isprobable cause to believe thatW A LKER,did know ingly,in and
and solicitby any m eans a m inor,thatis,the M inorV ictim ,to engage in com m ercialsex acts by
1591(a)(1) and (b)(1),and knowing,and in reckless disregard ofthe fact,and having had a
reasonable opportunity to observe the M inorV ictim ,that the M inor V ictim had not attained the
age of 18 years and w ould be caused to engage in a com m ercialsex act,in violation of Title 18,
UnitedStatesCode,Section l591(a)(l)and(b)(2).