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Taleek Brooks Production Complaint Final Final

Taleek Brooks Production Complaint Final Final

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Published by: huffpost on Feb 07, 2012
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07/10/2013

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EMK:RTPF# 2012R00028UNITED STATES DISTRICT COURTEASTERN DISTRICT OF NEW YORK- - - - - - - - - - - - - - - - -XUNITED STATES OF AMERICA- against -TALEEK BROOKS,Defendant.- - - - - - - - - - - - - - - - -XC O M P L A I N TM. No. _____________(T. 18, U.S.C., §§2251(a) and2252(a)(4)(B))EASTERN DISTRICT OF NEW YORK, SS.: THOMAS THOMPSON, being duly sworn, deposes and saysthat he is a Special Agent with the Federal Bureau ofInvestigation (“FBI”), duly appointed according to law and actingas such.In or about and between January 2008 and January 2011,both dates being approximate and inclusive, within the EasternDistrict of New York and elsewhere, the defendant TALEEK BROOKSdid knowingly and intentionally employ, use, persuade, induce,entice, and coerce one or minors to engage in sexually explicitconduct for the purpose of producing visual depictions of suchconduct, which visual depictions were produced using materialsthat had been mailed, shipped and transported in and affectinginterstate and foreign commerce.(Title 18, United States Code, Section 2251(a))On or about January 13, 2012, within the EasternDistrict of New York, the defendant TALEEK BROOKS did knowinglyand intentionally possess matters containing one or more visual
 
depictions, which visual depictions had been mailed, shipped andtransported using a means and facility of interstate and foreigncommerce, and which were in and affecting interstate and foreigncommerce, and which were produced using materials which had beenmailed, shipped and transported in interstate and foreigncommerce by any means, including by computer, the production ofsuch visual depictions having involved the use of one or moreminors engaging in sexually explicit conduct and such visualdepictions were of such conduct.(Title 18, United States Code, Section 2252(a)(4)(B))The source of my information and the grounds for mybelief are as follows:
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1.I have been a Special Agent with the FBI sinceDecember 2004, and am currently assigned to the New York Office.I have been assigned to the Internet Crimes Against Childrensquad. I have been assigned to investigate violations ofcriminal law relating to the sexual exploitation of children. Ihave gained expertise in this area through training in classesand daily work related to conducting these types ofinvestigations. As part of my responsibilities, I have beeninvolved in the investigation of numerous child pornography casesand have reviewed thousands of photographs depicting children(less than eighteen years of age) being sexually exploited by 
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Because the purpose of this complaint is merely toestablish probable cause to arrest, I have not set forth all of thefacts and circumstances concerning this investigation of which I amaware.
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adults. Through my experience in these investigations, I havebecome familiar with methods of determining whether a child is aminor. I am also a member of the Eastern District of New YorkProject Safe Childhood Task Force.2.I am familiar with the information contained inthis affidavit based on my own personal participation in theinvestigation, my review of documents, my training andexperience, and discussions I have had with other law enforcementpersonnel concerning the creation, distribution, andproliferation of child pornography. Additionally, statementsattributable to individuals herein are set forth in sum andsubstance and in relevant part.3.On January 10, 2012, the Honorable Ramon E. Reyes,Jr. signed a search warrant authorizing the search of a residencelocated on Lafayette Avenue in Brooklyn, New York (the “SUBJECTPREMISES”). In my Affidavit in Support of an Application for aSearch Warrant of the SUBJECT PREMISES, I stated that on or aboutDecember 29, 2011, an undercover FBI special agent had signedinto a peer-to-peer (P2P) file sharing program and downloadednine (9) images and two (2) video files depicting childpornography from the shared directories of a user with theusername “T.S.” Records obtained from Verizon Internet Servicesshowed that the IP address utilized by T.S. was subscribed to“TALEEK BROOKS” and that the address associated with the IPaddress was the SUBJECT PREMISES.4.On January 13, 2012, I and other law enforcement
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