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tlewis

tlewis

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05/05/2012

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AO
9l
(Rev.
08/09)
Criminal Complaint
UNTTBn
STRTBS
DTsrrucT
CoURT
for
the
Southern
District
ofAlabama
United
States
of America
v.JERRY L. CANNON
Code Section
1
8
u.s.c.
$2252A(a)(2)(A)
This criminal complaint
is
based on these facts:
See attached Affidavit,incorporated hereinbyreference.
d
Continued ontheattached
sheet.
Sworn
to
before me
and
signed
in my
presence.Date:
caseNo,
M5
tl-
OOf2-
C
Defendant(s)
CRIMINAL
COMPLAINT
I,
the
complainant
in this
case, state
that the
following
is true to
the
best of
my
knowledge
and
belief.
On or
about the date(s)
of
0112512011
&021021201'l
in
the
county
of
Southern
District
ofAlabama
,
the defendant(s)violated:
Mobile
in
the
Marya Wilkerson,Special
Agent,
FBIPrinted
name
and
title
Offense
Description
Certain Activities relating to Materialinvolving the Sexual Exploitation
of
MinorsWilliamE. Cassadv,UnitedStates MaoistrateJudoe
ity
and
state:
02t14t2011Mobile.Alabama
Printed
name
and
title
Case 1:11-mj-00052-C Document 1 Filed 02/16/11 Page 1 of 14
 
IN
THE
LINITED
STATES
DISTRICT
COURT
FOR
THE
SOUTHERNDISTRICT
OF
ALABAMA
United
States
of America
V.
JERRY
L.CANNON
Court
No.
AFFIDAVITIN
SUPPORT
OF
CRIMINAL
COMPLAINT
I,
Marya
Wilkerson,
Special
Agent
of
the Federal
Bureau
of
Investigation,
being
first
duly
sworn, hereby
depose
and
state
as
follows:
INTRODUCTION
AND
AGENT BACKGROUND
1.
I
make
this
affidavit in
support
of
an
application
for
a
Criminal
Complaint
and
ArrestWarrant
for
Jerry
L.
Cannon
for violations of
Title
18
U.S. Code
Section
92252A(a)(2XA),Certain
Activities
relating
to Material
involving
the
Sexual
Exploitation of
Minors
.
2.
I
arn
a
Special
Agent
with
the
Federal
Bureau
ofInvestigation(FBD
and
havebeensince
April
13,
2008.
I
am
currently
assigned
to the
Mobile,
Alabama,
Division.
I
am
authorizedto
investigate
violationsof
Federal
Law,including
Title
18
U.S.
Code,Sections
92252(a)(5)(B)and52252A(a)(2XA),certain
activitiesrelating
to the
mateial
constituting or containing
childpornography.
Priorto
my
employment
with
the
FBI,
I
was
a
Prosecutor
for
the
Knox
County
DistrictAttorney's
Office
in
Knoxville,
Tennessee,
for
approximately
four
and
ahalf
years.
With
the
FBI, I
have
obtained
kaining
related
to
investigating
crimes
against
children
and
internetcrimes inparticular.
3.
The
facts
inthis
affidavit
come
frommy
personal
observations,
my training
and
experience, and
information
obtained
from
other
agents and
wifiresses. Thisaffidavit
is
intended
to
show
merely that
there
is
sufficient
probable
cause
for
the requested
warrant
and
does
not
set
forth
all
of my
knowledge
about
this
matter.
4.
Basedon
my training
and experience
and
the
facts
as
set
forth in this affidavit,
there is
probable
cause
to believe that
violations of
Title
18,
U.S.Code,Section52252A(a)(2XA)
has
been
committed
by
Jerry
L.
Cannon
throughthe
use
of
the
multiple
false Facebook accounts.
Case 1:11-mj-00052-C Document 1 Filed 02/16/11 Page 2 of 14
 
USE
OF COMPUTERS
WITH CHILD
PORNOGRAPHY
5.
As
a
result
of my training
andexperience,
I
know
that computers
are used
byindividuals who exploit children(which
includes collectors
of
child
pornography)
to:
a)
correspond
with
like-mindedindividuals via
e-mail,
chat,
bulletin
boards,newsgroups,instant
messages,
file
transfers
and othermeans;
b)
store
identifying
information
concerning
child victims,
as
well
as
identifying information
about other
individualswho
share
the
same
interests; c) locate,
view,
download,
collect,
and
organize
images
of child
pornographyfound throughthe
Internet.
Computers
also
afford individuals
adegree
of
anonymity.
6.
Collectors
and
distributors
of
childpornography
also use
online
resources
toretrieve
and store
child
pornography,
including
services
offered
by
Internet Portals
such
as
Yahoo!
and
Hotmail,
among
others.
The online
services
allow
a
user
to
set
up
an
account
with
a
remote
computing
service
e
that
providese-mail
services
as
well
as
electronic
storage
of
computer
files in
any
variety
offormats. A
user can
set
up
an
online
storage
account
from
any computer
with
access
to
the
Internet.
These
online
storageaccounts
are
often
free
but
can
involve
a
charge.
Payment
is almost always
made
via
credit
card,
debit card, or other
similar
payment
service,
7.
A
subscriber assigned
a
free online
storage account
frequently
can
setup
such
accounts
by
providinglimitedidentifying information. Any
information
provided
is
frequently
fictitious in
anattempt
to
preserve
the
anonymity of
the
user.
Consequently,
even
if
it
is
known
that
a
collector
or
distributorof child
pornographyis
a
subscriber
of
a
free
online
storage
service, the
service
provider
frequently
will
have no records
in
that
subscriber's
name.
Instead,the
online
service
will
only
be able
to
identify
fields,
including child
pornography,that
are
associated
with
aoologin,"
or unique,
user-created
identity
the subscriber
uses
to
"1og
on"
to the online
service.
8.
Such
an
online
storage account is
particularly
useful
to
a
collector
or
distributor
of
child
pornography.
Such
a
subscriber
can
collect,
store,
view
and
distributeelectronic
images,
including child
pornography,
directlyfrom
the
online service.
Consequently,
the
illegal files
have
minimal
contact
with
the subscriber's home
computer,
The
subscriber
can also
manipulate the
files
on
an
online
storage
service
from
anycomputer
connected
to
the
Internet.
Case 1:11-mj-00052-C Document 1 Filed 02/16/11 Page 3 of 14

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