Case 1:19-mj-00315-PJG ECF No. 1-1 filed 09/12/19 PageID.

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Continuation of Complaint

I, Kurt Fiegel, being duly sworn, hereby state the following:

Introduction

1. I am a Special Agent with the U.S. Department of Homeland Security

Investigations (HSI). I am assigned to the Office of the Resident Agent in Charge in

Grand Rapids, Michigan. I began my career with HSI in September 2007 and prior

to joining HSI, served as a probation and parole officer for the Michigan

Department of Corrections for approximately six years. As an HSI Special Agent, I

have received training in the production, receipt, and possession of child

pornography. I am responsible for criminal investigations of these violations, as well

as both criminal and administrative violations of the customs and immigration laws

of the United States.

2. Because this continuation is for the limited purpose of establishing

probable cause to support the criminal complaint, it contains only a summary of

relevant facts. I have not included each and every fact known to me concerning the

entities, individuals, and events described in the continuation. This continuation is

made for the purpose of establishing probable cause that Joseph Francis BRISSON

II committed the crime of sexual exploitation and attempted sexual exploitation of a

child, in violation of 18 U.S.C. § 2251(a) and (e).

3. The statements in this continuation are based on: (a) my personal

participation in this investigation; (b) information provided by other federal law

enforcement officers; (c) a review of the contents of BRISSON’s cellphone; and (d)

my training and experience and the training and experience of other officers.

Case 1:19-mj-00315-PJG ECF No. 1-1 filed 09/12/19 PageID.3 Page 2 of 4

Probable Cause

4. Today, September 12, 2019, Joseph F. BRISSON was interviewed in

his pursuit of a position as a Customs and Border Protection (CBP) officer. As part

of the hiring process, he was going to be subjected to a polygraph examination. The

interview occurred in the Eastern District of Michigan.

5. During the pre-polygraph interview, he admitted that he had explicit

photographs of a minor on his cellphone. At that point, the interviewers on behalf of

CBP contacted HSI special agents in the Eastern District of Michigan who arrived

to interview BRISSON.

6. BRISSON, his girlfriend, and Minor Victim 1,1 all reside together at a

house on Hancock Street in Manistee, Michigan. Minor Victim 1 is not BRISSON’s

child but is his girlfriend’s daughter. BRISSON’s girlfriend has two adult children

who also reside there.

7. BRISSON told CBP interviewers and HSI special agents that he had

set up a hidden camera in a bathroom of the residence in approximately May 2019.

8. BRISSON admitted he used the camera surreptitiously to record

Minor Victim 1 getting into and out of the shower. BRISSON said he downloaded

1The identity of Minor Victim 1 is known to law enforcement but is not included
herein to protect her privacy.
the videos from the camera onto his home desktop computer. He also took stills

from parts of the videos and saved those.

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9. BRISSON also admitted that he used his Apple iPhone 6 to take

photographs of the computer screen when the naked stills were displayed.

BRISSON did this so that he could have copies of the images on his iPhone. He

stored those images in a portion of a Snapchat account labeled “My Eyes Only.” “My

Eyes Only” is a setting in Snapchat that allows a user to password protect any

“Snaps” (i.e. videos or images) that a user does not want other people to see.

10. Special Agent Chad Cable of HSI is a computer forensic agent who has

reviewed BRISSON’s iPhone 6. BRISSON gave HSI agents consent to review his

phone and provided all necessary unlock codes, account passwords, etc.

11. SA Cable relayed to me that six images of Minor Victim 1 unclothed

appear in the “My Eyes Only” tab of the Snapchat account on BRISSON’s iPhone 6.

Two of these appear to meet the federal definition of child pornography; these two

images depict Minor Victim 1 fully nude. She is framed from about her chin through

her thighs and is clearly a pubescent teenager. Her naked breasts and pubic area

are exposed in the photographs. The setting of the images is clearly a bathroom and

the viewer can tell that Minor Victim 1 is stepping into or out of a shower. These

images appear to be still shots of a video that were cropped by BRISSON. Minor

Victim 1’s head and her feet are not visible.

 12. BRISSON further admitted that he used the images and videos for his

sexual gratification. BRISSON masturbated using the depictions about twice a

week, beginning in May.

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13. BRISSON gave investigators his consent to search his home and

retrieve the desktop computer on which he saved the videos. That search is ongoing

and additional investigation continues.

Conclusion

14. Based on the foregoing information, I believe there is probable cause

to charge Joseph Francis BRISSON II with sexual exploitation and attempted

sexual exploitation of a minor beginning in or about May 2019 and continuing

through September 2019.