Case 2:23-mj-00332 Document 1 Filed 02/17/23 Page 1 of 13

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RYAN LACON


Defendant(s)

CRIMINAL COMPLAINT
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Code Section Offense Description
18 U.S.C. 2251(a) did knowingly attempt to employ, use, persuade, induce, entice, or coerce
MINOR #1, a person under the age of 18 years, to engage in sexually explicit
conduct for the purpose of producing a visual depiction of such conduct, and in
his attempt to produce the visual depiction he used materials that have been
mailed, shipped, or transported in or affecting interstate or foreign commerce.

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PLEASE REFER TO $77$&+('$)),'$9,7$1'ATTACHMENT "A".

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s/ Leslie Trawick
Complainant’s signature

LESLIE TRAWICK, SPECIAL AGENT FBI

Printed name and title

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Elizabet Digitally signed by
Elizabeth T. Hey
Date: 2023.02.17
'DWH 02/17/2023
h T. Hey 11:58:47 -05'00'
Judge’s signature

&LW\DQGVWDWH Philadelphia, Pennsylvania Elizabeth T. Hey, Chief Magistrate Judge

Printed name and title
 Case 2:23-mj-00332 Document 1 Filed 02/17/23 Page 2 of 13

23-MJ-332
AFFIDAVIT IN SUPPORT OF ARREST WARRANT

I, Leslie C. Trawick, a Special Agent (SA) with the Federal Bureau of Investigation

(FBI), Philadelphia Division, being duly sworn, depose and state as follows:

1. I have been a Special Agent with the FBI since September 2021. During

my employment with the FBI, I have gained experience through training at the FBI Academy

and have participated in investigations pertaining to child pornography, human trafficking and

kidnapping. I am currently assigned to the Philadelphia Division’s Crimes Against Children

Squad and have observed and reviewed numerous examples of child pornography (as defined in

18 U.S.C. § 2256).

2. I am assisted in this investigation by Special Agent James J. Zajac, who

has been an FBI Special Agent since 2006 and has 16 years of experience in investigating child

exploitation and computer crimes cases. Special Agent Zajac is currently assigned to FBI-

Philadelphia’s Crimes Against Children Squad. In this affidavit of probable cause, I am relying,

in part, on the expertise and experience of Special Agent James J. Zajac, who has conducted

numerous investigations involving child pornography and has been an affiant on numerous

search warrant affidavits and participated in the execution of many search and seizure warrants.

3. As a federal agent, I am authorized to investigate violations of laws of the

United States and to execute warrants issued under the authority of the United States.

4. The statements in this Affidavit are based in part on my investigation of this

matter and on information provided by other law enforcement officers. Because this affidavit is

being submitted for the limited purpose of securing an arrest warrant, I have not included each and

every fact known to me concerning this investigation. I have set forth only those facts that I believe

are necessary to establish probable cause to believe that RYAN LACON, date of birth April 13,

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1992, committed violations of Title 18 U.S.C. § 2251 which makes it a crime to employ, use,

persuade, induce, entice, or coerce any minor to engage in any sexually explicit conduct for the

purpose of producing any visual depiction of such conduct, or attempts to do so.

LEGAL AUTHORITY

5. Title 18 U.S.C. § 2251(a) and (e) prohibits a person from employing, using,

persuading, inducing, enticing, or coercing any minor, that is, a person under the age of 18 years,

to engage in any sexually explicit conduct for the purpose of producing any visual depiction of

such conduct, using materials that have been mailed, shipped, or transported in or affecting

interstate or foreign commerce by any means, including by computer, or attempting to do so.

FACTS SUPPORTING PROBABLE CAUSE

6. On July 22, 2022, a father of a 14-year-old girl, hereafter “MINOR 1,”

reported to a Massachusetts law enforcement agency 1 that he discovered MINOR 1 was sending

naked pictures of herself to an individual with the username of CAIROSHOCK#7128 over

Discord in exchange for Amazon gift cards. Discord is an online chat communication platform

which allows users to chat over voice, video, and text. Her father provided consent for law

enforcement to review MINOR 1’s cell phone.

7. On July 22, 2022, the Massachusetts law enforcement agency sent an

administrative subpoena to Discord for subscriber information associated with the username

CAIROSHOCK#7128. On August 8, 2022, Discord provided the following subscriber

information. Discord provided a username change spreadsheet, which indicated the username

changed from CAIROSHOCK to CAROSHOCK.

1
I am aware of and have been in communication with this Massachusetts law enforcement
agency. The name of the agency is being withheld to protect the identity of the minor victim.

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a. User ID: 350794541508329472

b. Username: CAROSHOCK#7484

c. Email: ryan.lacon@gmail.com

d. Email verified: Yes

e. Phone number: +16105515899

f. Registration IP: Not found

g. Registration Time (UTC): 2017-08-26 00:12:16

8. In August 2022, MINOR 1 stated that she met CAIROSHOCK on Discord. MINOR

1 told CAIROSHOCK she was underage. MINOR 1 stated that CAIROSHOCK would ask

MINOR 1 for pictures of her masturbating and would give her money in return via CashApp or

Amazon gift cards. MINOR 1 could not estimate the number of pictures and videos she sent but

knew it was a lot. MINOR 1 stated that she took videos of herself using sex toys that

CAIROSHOCK paid for via Amazon gift cards. MINOR 1 stated that CAIROSHOCK had given

her a total of $700 via CashApp and $500 via Amazon gift cards.

9. MINOR 1 had once received a picture of CAIROSHOCK through Discord, and

described him as white, with blonde or light brown hair, in his mid-20s, with glasses. MINOR 1

stated that CAIROSHOCK called her on the phone once and talked about how much he loved her.

MINOR 1 stated that CAIROSHOCK talked about meeting in person and told her, “We should

meet up and we should have sex.” MINOR 1 stated that she said she did not want to, but maybe

when she was out of high school.

10. On MINOR 1’s cell phone, law enforcement located numerous videos and images

of MINOR 1 to include nudity and performing sex acts on herself. The device showed numerous

screenshots of conversations over Discord between MINOR 1 and CAROSHOCK and

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CAIROSHOCK, who the investigation has shown are the same user. MINOR 1’s cell phone

showed a CashApp screenshot of transactions showing MINOR 1 receiving money in different

amounts for various items identified as: “outfits,” “stuffff,” “pics,” “vids,” and “vidz.” The user

named “Ryan” with username $cairoshock was sending the money to MINOR 1.

11. Pursuant to a Massachusetts search warrant issued on September 21, 2022,

Massachusetts law enforcement reviewed account information associated with Discord user:

RYAN.LACON@GMAIL.COM, username CAROSHOCK #7484, and User ID

350794541508329472, in search of evidence of violations of Massachusetts General Law Chapter

272 Sec. 29(A) (Posing or Exhibiting Child in State of Nudity or Sexual Conduct), and

Massachusetts General Law Chapter 272 Sec. 29(C) (Possession of Child Pornography). I

reviewed the results of the search warrant and determined that there were two chat threads with at

least 1,470 messages between CAROSHOCK#7484 and MINOR 1. These messages consisted of

text messages and exchanged images and videos from April 25, 2022 to June 15, 2022.

12. The chat messages between CAROSHOCK#7484 and MINOR 1 indicate that he

was aware she is a minor. CAROSHOCK#7484 asks MINOR 1 on multiple occasions if her

parents are home or checking in on her. CAROSHOCK#7484 tells MINOR 1 that he wants to meet

up with her, marry her, and have kids with her. MINOR 1 talked about her individualized

education program and summer school in the chats. The following is a list of the chat messages

indicating CAROSHOCK#7484 was aware MINOR 1 was a minor:

a. April 25, 2022, 23:27 (UTC)

i. MINOR 1: I’m 16

b. April 25, 2022, 23:31 (UTC)

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i. MINOR 1: I would like to get toys but if my parents found them I’d be dead

lol

c. May 3, 2022 23:58 (UTC)

i. CAROSHOCK#7484: We are probably gonna have a generational gap

about things if u don't mind that lmao

d. May 4, 2022 18:29 (UTC)

i. CAROSHOCK#7484: Are you in school?

ii. MINOR 1: Yea

iii. CAROSHOCK#7484: Niceee which class?

iv. MINOR 1: History

v. CAROSHOCK#7484: Hmmm wanna do some pics and vids when you’re

back?

vi. MINOR 1: I’ll take pics but maybe not vids

vii. MINOR 1: I’m worried I’ll get caught lol

viii. CAROSHOCK#7484: Haha do u have a door on your room?

ix. MINOR 1: Yea

x. CAROSHOCK#7484: Gotcha do your parents still check on u if it’s closed?

xi. MINOR 1: Yea

e. May 18, 2022, 23:09 (UTC)

i. MINOR 1: But I do have summer school […]

13. To view the files sent within each chat thread, Discord provided a folder of

attachments with the associated file names. In my opinion, there are at least 33 files of child

pornography as defined in 18 U.S.C. § 2256, depicting MINOR 1 engaged in masturbation and/or

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the lascivious display of the genitals as well as child erotica. A review of the chats from April 25,

2022 through June 15, 2022, indicate that MINOR 1 was producing a majority of the images and

videos of child pornography in direct response to CAROSHOCK#7484’s specific requests.

a. On May 16, 2022, CAROSHOCK #7484 solicited the child to produce numerous

videos of the child engaged in sex acts, including the following on May 16, 2022

at 20:00 (UTC):

1. CAROSHOCK#7484: Can you let me see you holding the vibe

against your clit

2. CAROSHOCK#7484: With your legs spread from the front

3. CAROSHOCK#7484: And let me see your pretty face so I can see

how much u love it lol

4. MINOR 1: Sorry I'm so silent my parents are home

5. MINOR 1 sent IMG_8024.mov – a 47-second video of MINOR 1

from the front, spreading her legs and holding a pink vibrator against

her exposed vagina. MINOR 1’s face is visible throughout the video.

b. CAROSHOCK#7484 tells MINOR 1 that he would like to meet up with her to have

sex. CAROSHOCK#7484 tells MINOR 1 that he loves her, wants to get her

pregnant, and marry her. Samples of this type of chat are described below:

1. May 3, 2022 23:58 (UTC)

a. CAROSHOCK#7484: Where do you live again?

b. MINOR 1: Massachusetts

c. CAROSHOCK#7484: Right lol that’s a totally doable

distance honestly

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d. CAROSHOCK#7484: I’d love to meet you sometime

e. MINOR 1: That would be nice

f. CAROSHOCK#7484: Did you want to wait a bit for that or

would you not care when it was? Probably over the summer

when you’re on vacation haha

2. May 10, 2022, 23:32 (UTC)

a. CAROSHOCK#7484: I want to get you pregnant so

baddddd

14. In addition to the chat threads described above, there were chat threads between

CAROSHOCK#7484 and other Discord users. Below are some of the records which identify the

user of Discord account CAROSHOCK#7484 as RYAN LACON:

a. CAROSHOCK#7484 sent an image of his Pennsylvania Driver’s License, with

date of birth April, 13, 1992, date of issue February 28, 2021 and expiration date of

April 14, 2025. The remaining details, including name and face, were blacked out.

Since the email address RYAN.LACON@GMAIL.COM was used to register the

Discord account, I completed a PennDOT record check for the name RYAN

LACON. PennDOT records returned the same date of birth, date of issue, and date

of expiration on his Driver’s License.

b. CAROSHOCK#7484 sent multiple self-taken images with and without eyeglasses

on. Based on my review, the person in these images match the picture of RYAN

LACON on his Pennsylvania Driver’s License.

c. CAROSHOCK#7484 stated in one of the chat threads, “I made an Instagram for

my puppy. it’s rusty_the_corg” and sent an image and video of a Welsh Corgi dog.

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Open-source research identified this Instagram account, RUSTY_THE_CORG,

containing a location pin with “Fishtown, Philadelphia” and date of birth as April

11, 2022, in the profile bio. A Welsh Corgi dog was observed sitting in the window

during surveillance at 19 East Oxford Street, Philadelphia PA 19125.

d. CAROSHOCK#7484 stated in one of the chats, “I live in Philadelphia”.

e. CAROSHOCK#7484 sent two images of the outside of his residence. This matches

the residence of RYAN LACON at 19 East Oxford Street, Philadelphia PA 19125.

CAROSHOCK#7484 stated in one of his chats, “I’m sweeping the front rly quick.

I noticed it was rly dirty and my parents just bought all the houses next door so I’m

gonna clean it really quick.” Record checks indicate that in April 2022, LACON

LIVING TRUST purchased 21, 23, and 25 East Oxford Street, Philadelphia, PA

19125.

f. CAROSHOCK#7484 states in one of his chats, “My name is Ryan btw if u forgot

lol”.

15. Discord also provided IP connection history for logins to the CAROSHOCK#7484

account. From April 25, 2022 – June 15, 2022, there were 1,623 logins from IP Address

72.78.245.119. On December 9, 2022, Your Affiant issued an administrative subpoena to Verizon

for subscriber information associated with IP Address 72.78.245.119 on June 15, 2022 at 14:50:06

UTC. Verizon provided the following results:

c. IP Address: 72.78.245.119

d. Start time: 2020-09-11 06:57:16 UTC

e. Stop Time: 2022-07-13 04:16:42 UTC

f. Account Creation Date: 02/13/2018

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g. Customer Name: Mike Lacon

h. Account Address: 19 E OXFORD ST, PHILADELPHIA, PA 19125

i. Email Address: RYAN.LACON@GMAIL.COM

j. Status #: Active

a. Call log history with a phone call via the Discord application from CAIROSHOCK

on April 26, 2022 at 15:33 (UTC) with a duration of 32 minutes.

16. On August 30, 2022, an administrative subpoena was served to Block Inc.

(CashApp) for records associated with the user $CAIROSHOCK. Block Inc. provided the

following results:

a. Identity Verification Name: Ryan Lacon

b. Date of Birth: 1992-04-13

c. Street: 1733 Supplee Rd

d. City: Lansdale

e. Alias History: cairoshock, ryan.lacon@gmail.com, 6105515899, C_gewkrqyp2

17. On February 10, 2023, federal search warrant 23-MJ-272 was authorized by United

States Magistrate Judge Pamela A. Carlos, for the residence of 19 East Oxford Street, Philadelphia,

PA 19125 and for the person of RYAN LACON.

18. On February 17, 2023, these federal search warrants were executed at 19 East

Oxford Street, Philadelphia, PA 19125 and on the person of RYAN LACON and law enforcement

observed the following:

a. RYAN LACON was the only person found at the residence. A Welsch corgi dog

was also on scene.

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b. RYAN LACON appeared to the be the same person listed in the PennDot record

described in paragraph 14(a) and the same person who sent out images of

themselves using Discord username CAROSHOCK#7484 as described in

paragraph 14(b).

c. Based on previous surveillance of LACON and the residence, as well as the fact

that there was only one bedroom observed to be setup inside the residence, it

appeared LACON was the only person living in the residence. LACON also

confirmed that he was the only resident.

d. Law enforcement seized a total of two cell phone devices, two laptops, and one

desktop computer from LACON and the residence. An on-site forensic review of

these electronic devices showed the following:

i. Law enforcement observed the email account of

RYAN.LACON@GMAIL.COM on a device.

ii. Law enforcement recovered a video taken of LACON’s computer screen

while LACON was communicating with another over Discord. The

computer screen showed LACON using the Discord account of

CAROSHOCK and also showed a live feed of LACON while he was

accessing the account.

CONCLUSION

19. Based upon the information above, I respectfully submit that there is probable cause

to believe that RYAN LACON, date of birth April, 13, 1992, did attempt to employ, use, persuade,

induce, entice, or coerce a minor to engage in sexually explicit conduct for the purpose of

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producing any visual depiction of such conduct, in violation of 18 U.S.C. § 2251(a), as more fully

set forth in Attachment A.

20. Therefore, I respectfully request that the attached arrest warrant be issued

authorizing the arrest of RYAN LACON.

V/HVOLH&7UDZLFN
_______________________________________
LESLIE C. TRAWICK
Special Agent
Federal Bureau of Investigation

SWORN TO AND SUBSCRIBED

BEFORE ME THIS DAY
OF FEBRUARY, 2023.
Digitally signed by
Elizabeth
_______________________________________
Elizabeth T. Hey
HONORABLE ELIZABETH T.2023.02.17
Date: HEY
T. Hey
United States Magistrate Judge
11:58:12 -05'00'

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ATTACHMENT A

Count One – Attempted Manufacture of Child Pornography – 18 U.S.C. § 2251(a)

On or about May 16, 2022, in the Eastern District of Pennsylvania, defendant RYAN LACON
did knowingly attempt to employ, use, persuade, induce, entice, or coerce MINOR #1, a person
under the age of 18 years, to engage in sexually explicit conduct for the purpose of producing a
visual depiction of such conduct, and in his attempt to produce the visual depiction he used
materials that have been mailed, shipped, or transported in or affecting interstate or foreign
commerce.

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