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AFFIDAVIT
I, Monica Abend, being duly sworn, do hereby depose and state:
I. INTRODUCTION
1. I am a Special Agent (“SA”) with the Department of Homeland Security (“DHS”),Homeland Security Investigations (“HSI”), currently assigned to Office of the Assistant SpecialAgent in Charge, Orange County, California (“HSI Orange County”) and have been so employedsince January 2002. I have conducted, participated in and/or received training in numerousinvestigations of criminal activity, including, but not limited to, the investigation of narcotics,money laundering, fraud, child pornography, alien smuggling, human trafficking, and Title IIIwire communication interception investigations. During investigation of these matters, I haveexecuted, and participated in the execution of, search warrants, and have seized evidence inviolation of the United States Code. As part of my daily duties as an HSI agent, I investigatecriminal violations relating to child exploitation and human trafficking. I have received trainingin the area of child pornography, child exploitation and human trafficking.
II. PURPOSE OF AFFIDAVIT
2. This affidavit is made in support of a criminal complaint against Samuel MartinezGONZALEZ (“GONZALEZ”), for a violation of Title 18, United States Code, Section 2423(a):Transportation of Minors with Intent to Engage in Criminal Sexual Activity. The statementscontained in this affidavit are based upon my training and experience, information provided tome by other investigators, other law enforcement officers, and witnesses as part of thisinvestigation. This affidavit is intended to show that there is sufficient probable cause for therequested criminal complaint and does not purport to set forth all my knowledge of, or
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investigation into, this matter.
III. PROBABLE CAUSEBackground Information and Identification of Gonzalez
3.
On August 12, 2011, at approximately 2:12 p.m., an email was forwarded to mefrom Human Trafficking Group Supervisor (“GS”) Rebecca Peters of Homeland SecurityInvestigations, Office of the Special Agent in Charge Dallas, Texas. Three minor femaleshereinafter referred to “VR”, “ST” and “JT,” who left residences in Irving, Texas were possiblybeing drugged and forced into prostitution in Orange County, California. I communicated withGS Peters via phone and email. GS Peters provided me with a copy of The National Center forMissing and Exploited Children (“NCMEC”) Intake Report, Case number: 1177707 which Ireviewed and learned the following:a. On August 12, 2011, at approximately 11:23 a.m., a call was takenregarding an endangered runaway. The report’s narrative reads, “The 15 year-old child is listedin NCIC as Missing Person Juvenile. The child was temporarily staying with her aunt when sheran away, because the caller had to spend a week incarcerated due to traffic tickets. On themissing date, the child ran away with the companions. The mother of two of the companions, JTand ST, said an unknown man had promised to get them jobs if they provided him with theirsocial security numbers. The caller's relatives found an advertisement on backpage.com, in theOrange County, California, section, advertising the companion, ‘Asia,’ for prostitution. The adwas titled ‘100% real all night specials.’" On August 9, 2011, during the night, the child (VR)called her grandmother. She said she and the companions had driven to California. The childremembered seeing a sign for Orange County. She said they were staying in a hotel. The child
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sounded very disoriented and she did not seem to know what day of the week it was. The callerdid not know if the child took clothing or belongings with her. The child did not have access tomoney.b. The “Child Information” on the NCMEC Intake Report reflects the nameas VR; a date of birth reflecting that she is currently 15 years old; Country of Birth: UnitedStates; Missing Date/Time: August 6, 2011; Missing Location: Home – Single Story; MissingCity: Irving; Missing County: Dallas; State: TX; Missing Country: United States; MissingLocation Detail: Aunt’s house – March Street; Suspected Prostitution: August 12, 2011.c. The section titled “Companion, Suspect, Abductor, Witness or Other”provided four possible minor companions, ST, JT, PR, and “Asia.”4.
On August 12, 2011, I communicated with GS Peters and Irving PoliceDepartment Investigator Rodney Bergeron (Inv. Bergeron) telephonically and via email andlearned the following:a.
A relative of VR reported that on August 6, 2011, VR left her residence inIrving, Texas with two other female juveniles (ST and JT). VR’s relative found an advertisementon backpage.com in the Orange County, California section advertising the companion, “Asia,”for prostitution. The ad was titled, “100% real all night specials.”b.
On August 9, 2011, VR called her grandmother from phone number (714)322-XXXX. The grandmother stated that VR told her that she and her companions had driven toCalifornia and that VR remembered seeing a sign for Orange County. VR also said she wasstaying in a hotel. The grandmother stated that VR sounded disoriented and she did not seem toknow what day of the week it was.
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