I

I
I]NITED SIATES DISTRICT COT'RI FOR TTIE iIE lailzl i
!
SOUTTIERN DTSTRICT OF YSEST VIRGINIA
CTIARLESTON GRAND iII'RY 2O2L
DECEMBER 14, 202]- SESSTON

T NITED STATES OF AI'{ERICA

v CRIMINAI NO. 2:2]--cr-00235

18 u. s. c. S 2251(a)
18 u. s. c. S 2251(e)
TODD CHRISTOPHER ROATSEY 18 u. s.c. S 2252A(a) (2)
18 u. s. c. S 2252A(a) (s) (B)
18 u. s. c. s 22s2A (b) (1)
18 u. s. c. s 22s2A(b) (2t
18 u. s. c. s 2422lb'
18 u. s. c. s 2427
gsSgBgEqIrg
II9IgEUEIT
The Grand Jury Charqes:

COT'NT OIIE

From on or about February B, 2020 through on or about February

L6, 2020, dt or near Erkview, Kanawha county, west virginia, and

within the Southern District of Vfest Virginia, defendant TODD

cHRrsroPHER ROATSEY did emproy, use, persuade, induce, entice, and

coerce a minor, Minor Femal-e l, and attempt to employ, use,

persuade, induce, enti-ce, and coerce a minor, Mlnor Female L, to
engage in sexually explicit conduct for the purpose of producing
visual depictions of such conduct, and the visual depictions were
transmitted using any means and facility of interstate and foreign
commerce and in and affecting interstate and foreign conrmerce.

In violation of Title 18, United States Code, Sections 2251 (a)

and (e) .
 cotNT Two
on or about January 25, 2020, dt or near Elkview, Kanawha

county, west virginia, and within the Southern District of west

virginia, defendant roDD cHRrsropHER ROATSEy did employ, use,
persuade, induce, entice, and coerce a minor, Minor Female 2, and

attempt to emproy, use, persuade, induce, entice, and coerce a

mj-nor, Minor Female 2, to engage in sexually explicit conduct for

the purpose of producing visual depictions of such conduct, and the
visual- depictions were transmj-tted using any means and facility of
interstate and foreign cornmerce and in and affecting interstate and

foreign commerce.

In violation of Title 18, United States Code, Sections 2251 (a)

and (e) .
 COT'NT THREE

From on or about January 25, 2020, through on or about Eebruary

15, 2020, dt or near Elkview, Kanawha County, West Virginia, and

within the Southern District of West Virginia, defendant TODD

CHRISTOPHER ROATSEY, using a facility and means of interstate

commerce, that is, the fnternet and cel-lular network, did knowingly
persuade, induce, entice, and coerce an individual, Minor Female t,
who had not attained the age of 18 years, to engage in sexual
activity for which any person could have been charged with a

criminal offense, and attempted to do so.

fn violation of Title 18, United States Code, Sections 2422(b)
and 242'7 .
 COI'NT EOT'R

From on or about January 4, 2020, through on or about January

25, 2020, dt or near Elkview, Kanawha County, West Virginia, and
within the Southern District of West Virginia, defendant TODD

CHRISTOPHER ROATSEY, using a facility and means of interstate

commerce, that is, the Internet and cellular networks, did knowingly
persuade, induce, entJ-ce, and coerce an individual, Minor Female 2,
who had not attained the age of 1B years, to engage in sexual
activity for which any person could have been charged with a

criminal offense, and attempted to do so.

In violation of Title 18, United States Code, Sections 2422(b)
and 2421.
 COT'NT FTVE

On or about January 25, 2020, ?t or near Elkview, Kanawha

County, Virginia, and within the Southern District of West Virginia,

defendant CHRISTOPHER TODD ROATSEY did knowingly receive and attempt
to recej-ve child pornography, as defined in 18 U.S.C. S 2256(B) (A) ,

that had been shipped and transported in and affect.ing interstate

and foreign coflrmerce by any means, including by cerr phone and

computer, and by using a means and facility of interstate and

foreign commerce.

fn violation of Title 18, United States Code, Sections

2252A(a) (2) and 2252A(b) (1) .
 COI'NT SIX

On or about February 76, 2020, dt or near Elkview, Kanawha

County, Virginia, and within the Southern District of West Virginia,

defendant CHRISTOPHER TODD ROATSEY did knowingly receive and attempt
to recej-ve child pornography, as defined in 18 U.S.C. S 2256(B) (A) ,
that had been shipped and transported in and affecting interstate
and forej-gn conmerce by any means, including by cell phone and

computer, and by using a means and facility of interstate and

foreign commerce.

fn violatj-on of Title 18, United States Code, Sections

2252A(a) (2) and 2252A(b) (1) .
 COI'NT SEVEN

On or about July 16, 202L, aL or near Elkview, Kanawha County,

virginia, and within the southern District of tlflest virginia,

defendant CHRISTOPHER TODD ROATSEY did knowlngly distribute and

attempt to distribute child pornography, as defined in 18 u.s.c. s

2256(B) (A), that had been shipped and transported in and affecting

interstate and foreign commerce by any means, including by cefl

phone and computer, and by using a means and facility of interstate
and foreign commerce.
rn vioration of Title 18, united States Code, Sections
2252A(a) (2) and 2252A(b) (1) .
 COT]NT EIGHT

On or about AprLL 29, 202I, at or near Elkview, Kanawha County,

West Virginia, and within the Southern District of West Virginia,

defendant TODD CHRISTOPHER ROATSEY did knowingly access with intent
to view material, that is, computer graphic image files, containing
images and vldeos of child pornography, as defined in 18 U.S.C. S

2256 (B) (A), that involved prepubescent minors and which had been

shipped and transported in and affecting interstate and foreign

commerce by any means/ includinq by computer.
fn violation of Title 18, Unit.ed States Code, Sections
2252A (a) (s) (B) and 22s2A (b) (2) .
 COI'NT NINE

on or about october 28, 202r, dt or near Elkview, Kanawha

county, west virginia, and within the southern District of west

Vlrginia, defendant TODD CHRfSTOPHER ROATSEY did knowingly possess
material, that is, computer graphic image fires, containing images
and videos of child pornography, as defined in 1B u. s.c. s
2256 (B) (A), that involved prepubescent minors and which had been
shipped and transported in and affecting interstate and foreign
commerce by any means, including by computer.
rn viofation of Title 18, united States code, secti_ons
2252A (a ) ( s ) (B ) and 22s2A (b ) (2) .
 TOREEITT'RE

In accordance with 18 U.S.C. SS 981(a) (1) (C), 2428 and,2253 (a),

28 U.S.C. S 2467, and Rule 32.2(a) of the Federal Rules of Criminal

Procedure, and premised on the conviction of defendant roDD

cHRrsroPHER ROATSEY of a vioration of 18 u.s.c. SS 225t et seq. or

1B u.s.c. ss 2421 et see., as set forth in this superseding
indictment, the defendant shall forfeit to the United States any
visual- depictions and any books, magazines, periodicals, films,
videotapes, and other matter which contains such visual depictions,
which were produced, transported, mailed, shipped, or recej-ved in
connection with the violations set forth in this superseding
indlctment, any real and personal property constituting or traceable
to gross profits or other proceeds obtained from the violations set
forth in this superseding i-ndictment, and any rear and personal
property used or intended to be used to commit or to promot.e the
commission of the violations set forth in this superseding
indictment, including, but not l-imited to, digital media, cel-l-
phone(s), tabret(s), and computer equipment seized on october 28,
2021,.

W]LLIAM S. THOMPSON
United States Attorney

By: ,l

JE FE RADA HERRALD
As ta United States Attorney
F-----'r,

PUBLIC INFORMATION RELEASE

UNITED STATES OF AMERICA

Criminal No. 2:21-cr-00235

TODD CHRISTOPHER ROATSEY

An indictment was returned today by the Grand Jury for the United states
District court for the southern District of west Virginia meeting at charleston
charging the above defendant with violation of federal law in connection with
'l! U (Production of Chitd pornography) (2 counts);
! 9 $ 2251 (Enticementof
1!M S2251 aMinor) 1zcountij;'
and Distribution of Chird po,nography) (3 counts);
]t !] ! 9 9????\(a)(2) (Receipt
18 U'S'C. $ 2u.!2A(a)(s)(a) (Possession of and Access with lnten"t
to v]"ti, pr"prr6."ent Child
Pornography) (2 counts)
Pertinent information concerning the defendant is set forth berow:

DEFENDANT'S NAME: Todd Christopher Roatsey AGE: 42

MARRIED Unknown EMpLOyER (tf known):
INVESTIGATING AGENCY: HSI
CHARGES: 1€ u.s.c. g 2251.(produ.ction of child pornography) (2 counts); 18 u.s.c.
(Enticemenr of a Minor) (2 counts); iS U.S.C. ZZiZAlayZl s 2251
S
Distribution of Chitd pornography) (3 counts); ie u.s.c.
lieceipt anJ
$'zzbza1, j1slia j
(Possession of and Access with rntent to View prepubesient cniro po'rirJgraphy)

POSSIBLE PENALTY: life in prison; $2,250,000 fine; 5 years to life supervised

release

WILLIAM S. THOMPSON
UNITED STATES ATTORNEY
SOUTHERN DISTRICT OF WEST VIRGINIA

PLEASE NorE: The Fifth Amendment and appricabre Federar raw gives a criminal
defendant a
personal right of lndictment by grand jury for Federal crimes punishable
by more than one year
imprisonment. And rndictment is a formal, written accusation by a grand jury. An
rndictment is
not proof of guilt, and the defendant is presumed innocent until and unless the
defendant is
found guilty.