Case 3:23-mj-00213-MDM Document 1 Filed 02/27/23 Page 1 of 1

AO 91 (Rev. 11111) Criminal Complaint

UNITED STATES DISTRICT COURT

for the
District of Puerto Rico

United States of America )

v. )
) Case No.
VICTOR J. PIZARRO SANTIAGO ) 23-
)
)
)
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 September,2022-February 27,2023 in the county of San Juan in the
District of P_u_e_rt_o_R_i_co , the defendant(s) violated:

Code Section Offense Description

18 U.S.C. § 2252A(a)(2) Distribution/Receipt of Child Pornography

18 U.S.C. § 2252A(a)(5)(8)
Possession of Child Pornography, including images of prepubescent minors

This criminal complaint is based on these facts:

See attachment

The United States request defendants' detention pending trial.

o Continued on the attached sheet.

Reviewed by: AUSA Jenifer Hernandez Vega

Compl;;~

Alilison Hirsch
Prinled name and lille

Sworn in accordance with the requirements of Fed. R. Crim.

P. 4.1 by telephone at on

Date:
Judge's signature

City and state: San Juan, Puerto Rico US MAGISTRATE JUDGE MARSHAL D. MORGAN
Printed name and title
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AFFIDA VIT IN SUPPORT OF CRIMINAL COMPLAINT

I, Allison Hirsch, hereinafter referred to as your affiant, a Special Agent of the Federal
Bureau ofInvestigation (FBI), being duly sworn, state and depose as follows:

BACKGROUND

1. I am a Special Agent with the Federal Bureau ofInvestigation (FBI) and have been
so since 2009. I am currently assigned to the FBI's San Juan Division, Crimes Against Children
Squad. As an FBI Special Agent, I have received extensive training in a variety of investigative
and legal matters of violations of federal and state law. Your affiant is "an investigative or law
enforcement officer of the United States" within the meaning of Section 2510(7) of Title 18, United
States Code. Your affiant is therefore, an officer of the United States who is empowered by law to
conduct investigations of, and to make arrests for, the offenses enumerated in Title 18, United
States Code. During my employment with the FBI, I have participated in various violent crime
investigations along with other FBI Special Agents (SAs) and other Task Force Officers (TFOs).
2. The information contained in this affidavit was obtained from the investigation
conducted by your affiant in addition to information provided to your affiant by other local and
federal law enforcement agents. Because this affidavit is made for the limited purpose of
establishing probable cause for the arrest warrant and filing of a criminal complaint, your affiant
has not recited every fact known to your affiant as a result of this investigation.

RELEVANT FACTUAL ALLEGATIONS

3. On or about February 24, 2023, the Honorable Giselle Lopez-Soler, U.S. Magistrate
Judge for the District of Puerto Rico, authorized a search warrant for the residence of Victor J.
Pizarro-Santiago (Case No. 23-206 (M». The residence was located at Calle Ruiz Belvis in San
Juan, PR 00917 (Target Residence).
4. On or about February 27, 2023, in the morning hours, FBI Special Agents (SAs)
arrived at the residence of Victor J. Pizarro-Santiago. Once Pizarro-Santiago was outside of his
residence, FBI SAs approached him and asked to speak. Pizarro-Santiago agreed to speak with
the FBI SAs in an FBI vehicle. Pizarro-Santiago was advised he was not under arrest and was free
to leave any time. Pizarro-Santiago stated, and FBI SAs confirmed that Pizarro-Santiago was the
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only individual at his residence at the time. Pizarro-Santiago, although not under arrest at that
time, was advised and provided with his Miranda rights via the FBI's Advice of Rights form.

Pizarro-Santiago read his rights aloud and signed the Advice of Rights form indicating he

understood his rights.

5. FBI SA's conducted an interview and Pizarro-Santiago stated the following, in part

and in summary: He has been interested in child sexual assault material (CSAM), also known as

child pornography, when he began communicating with individuals via the application MeetMe in
2019. He admitted to using a MeetMe account tied to email addressmaverikprit3@yahoo.com
6. MeetMe is a website and application used for social networking; it is designed to
introduce users to new individuals. MeetMe reported maverikprit3@yahoo.com (MeetMe
Screenname "T") chats to the National Center for Missing and Exploited Children (NCMEC) via
a Cybertip in October of 2019. The Cybertip indicated that on or about 09/24/2019, Suspect
maverikprit3@yahoo.com (MeetMe Screenname "T") stated in a chat he molested his baby and

sent an image to another chat participant of a female prepubescent minor with her legs spread and

a red rash covering her genital and buttocks area.

7. During the interview, Pizarro-Santiago said he sent this image using his MeetMe
account (Screenname "T"), and he had obtained the image he sent from Google. He said he
received, sent, and possessed child pornography of infants and toddlers, because he was interested
in writing a story about adults that had sexual relations with children and wanted to understand the
thinking of adults who had sex with infants and toddlers, and as such he pretended to be someone
molesting a baby on multiple occasions. Pizarro-Santiago initiated these conversations about

molesting infants with other members of MeetMe.

8. Pizarro-Santiago indicated he primarily used MeetMe to receive and send child
pornography. Pizarro-Santiago had many accounts on MeetMe, because MeetMe would detect
that his chats contained child pornography and close his accounts, at which time Pizarro-Santiago
would start a new account. Pizarro-Santiago could not remember the names or email addresses

for all the MeetMe accounts he used to send and receive child pornography; Pizarro-Santiago made

up random emails and names to create the MeetMe accounts.

9. The FBI investigation revealed that the MeetMe account "Nins" was used from
approximately September 9,2022 to December 7,2022. MeetMe reported "Nins" to NCMEC via
a Cybertip. The Cybertip contained a chat log of approximately 436 pages dedicated to discussing

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the sexual abuse of infants, toddlers, and minors and contains child pornography sent from "Nins"
to another chat participant and child pornography received by "Nins" from another chat
participant.
1O. Pizarro-Santiago admitted using the "Nins" account from September, 2022 to
December 7, 2022. Pizarro-Santiago used email titiputa36@gmail.com to create his "Nins"
MeetMe account. The Google account titiputa36@gmail.com was associated with telephone
number 787-319-0677.
II. Pizarro-Santiago was shown several identified child pornography files from his
"Nins" chat with "Jo"; Pizarro-Santiago identified one file which depicted an infant with an adult
male finger inserted into the infant's anus as being sent to him by someone else. Pizarro-Santiago
identified multiple child pornography files depicting infant genitalia as being sent by him to other
individuals.
12. FBI SAs executed the search warrant while the interview was being conducted. An
FBI SA observed a telephone plugged in and sitting on the table. The telephone was seized. The
telephone had telephone number 787-717-7223 and is a Samsung Galaxy.

13. Records obtained as part of the investigation revealed that an IP address assigned
to telephone number 787-717-7223 was used to login to Google account titiputa36@gmail.com,
the Google account which was used to create the MeetMe account "Nins" on or about September
9,2022.
14. Pizarro-Santiago described the locations of two telephones in his residence to FBI
SAs; he described the telephones as in his bedroom closet. FBI SAs obtained the telephones, a
TeL 30 Z and a Motorola Moto E. Pizarro-Santiago provided the passcodes to the telephones.
One telephone had MSISDN (telephone number) 787-319-0677; the same telephone number
associated with Pizarro-Santiago's titiputa36@gmail.com account.
15. The telephone with MSISDN 787-319-0677 contained child pornography from
Telegram, WhatsApp, and MeetMe. An initial review of the telephone indicated approximately
600 image files and 100 video files; an initial review by your Affiant of the image files and video
files indicated dozens of the files were sexually explicit images of minors, most of prepubescent
female minors.
16. The second telephone obtained by FBI SAs from the location Pizarro-Santiago
described, and accessed with the passcode Pizarro-Santiago provided, had lMEI

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016053000503392 and no telephone number; however, the device did have a file sharing

application and various other applications. I know from my training and experience that such a

device is typically used when connected to WiFi; it cannot make calls or send texts but it may use
other applications to communicate and file share. A physical review of this device indicated it
contained child pornography files of prepubescent female minors.
17. Pizarro-Santiago's device with telephone number 787-319-0677 was associated
with email account Tculi978@gmail.com; email accountTculi978@gmail.comis associated with an

NCMEC Cybertip report that on or about November 19,2021, MeetMe user "Nini" was involved
in a chat about molesting his/her five-year old daughter; ''Nini'' stated he/she prepared a bottle for
the daughter with a lot of sperm. The Cybertip 107860803 noted that there was one or more
apparent child pornography files associated with the Cybertip.
18. During the search warrant execution, additional devices were seized from the
residence, including a computer, tablet, and external hard drive; which will be examined by the
FBI.

CONCLUSION
19. Based on the information above, your affiant submits that there is probable cause
to believe that Victor J. Pizarro-Santiago violated the following federal offenses: Title 18, United
States Code, Sections 2252A(a)(2) (Distribution/Receipt of Child Pornography), and
2252A(a)(5)(B) (Possession of Child Pornography).

I hereby declare, under penalty of perjury, that the foregoing is true and correct to the
best of my knowledge.

Allison Hirsch
Special Agent
Federal Bureau of Investigation

Sworn in accordance with the requirements of Fed. R. Crim. P. 4.1 by telephone at on

February 27, 2023

Marshal D. Morgan
United States Magistrate Judge
District of Puerto Rico