‘COMMONWEALTH OF POLICE CRIMINAL COMPLAINT PENNSYLVANIA COMMONWEALTH OF PENNSYLVANIA COUNTY OF: Northampton vs. ‘Magisterial District Number: 03-1-04 MOJ: Hon, Vivian |, Zumas, Esq, DEFENDANT: (NAME and ADDRESS): ‘Addross: 248 Brodhead RG, Suite 2 Cosias Ni Li Aes Bethlohom, PA 18017 iat Mc: aE Nase Taal Ree Telephone: (610) 681-2364 2718 CRESMONT AVE i EASTON PA tB045 18106657000), e ses pee NCIC Extraction Code Tyne (0s as i it Fabory Ful TSFelny Pend. TICAtsdemeanor Surouncng States D2-Fetony Lid, D6-Fetony Pend, Extracition Determ, [J D-Mtledemeanor No Extradition Di3+otony Sunouncing States] A-Nledemeanr Fl TIEAedemeaner Penng DieFelony No ie Ebttsdeowor unt [F-wsceneanr Pacing Exton Data. TGR DEFENDANT IDENTIFICATION INEORIIATION Tae Dats Fed ‘OTWAIveScan Number] ~ Complaint equea Lab Sorvicest ‘osrot2024 losysags| 24000080 2024.010018 Oves BNO GENDER | pos 1081-07-07 OB. ‘Aas DOB ni ‘CoDefendantle) LO 5 hat Fist None Wo Nana LastName ‘cen OFemate AKA RACE wa Tiss is aa me Hiner — Aisa cai Pee be Thee aa HAIR COLOR. Dorr Gry) C) Re ¢rewimubn.) ~— Eso (Sancy)-(CyaLtygetuay CIPLEPurpie) BI BRO Yerown) Thexxeniny Chons oreagey —Clwiiwate) — CsaR(Unesoaw), Lari (Green) IPR i) Dien gence Sranbery) i atic Deco ene) BaKO ion) Trawnrcreeny Tory ieen, Cheaz ere ruse varceny EL ent) Emu ticle) C1200 Unown) Dives HINO [ puatosation NU Wamber SEFENDANT VEHIOLE FORMATION SII Registration ‘Commit Veh. p4] Schoo! sticnercamanyy ——/ id oh. Your] take adh ‘Sie ‘Office of the allorney for the Commonwealth fy Approved (3 Disapproved because; {The allomey forthe Gonmonweath may require that Ihe complain, aveat warrant atfdavk, oF bol be approved bythe Barney Tore Gommonnealih por fofng, S89 PaR.Cren?, 807). Approved by SDDA Matthew Falk ‘Wass oe toy Tre Caney ‘Gials lieaaay arha Commarea) oan |, AL Michao Luzio & Det. Emly Falko 95786 6.908 / 4276216 429 ‘Wam ofthe Affari) ‘TPSPIMPOETC “Resigned Affant ID Number & Badge #) Of the Gly of Bethichem Police Department PA0469300, {deny Depariment or Agancy Represented and Polical Sibalison) —(Palce Aganey ORI Number) do hereby state: (check appropriate box) 1. accuse the above named defendant wtio lives at the address set forth above | accuse the defendant whose name is unknown to me but who is described as 1 | accuse the defendant whose name and popular designation or nickname are unknown fo me and whom [have therefore designated as John Doe or Jane Doe with violating the penal laws of the Commonwealth of Pennsylvania at [301 Bethiehern fettidarcer PEE ros sis —— Eas ils Mido School (2008 Chester Rd, BétNshorn, PA) apd other locations In Nowthamsion CUM in_Northampton County [_48_] on of about_Maich ond Apt 2026 (County Coa) FOrlerse Dale) “ROPE 412A ~ Rev. 12/21 Page 107 2aa POLICE CRIMINAL COMPLAINT Date Filed: | OTWiLiveScan Number Complaint “7 Tneldont # esv01/2024 2esocdes 2026016018 First Wide: Costes Nek Alostas 2. 1 ask that a warrant of arrest or a summons be issued and that the defendant be required to-answer the charges | have made. 3. L verify thatthe facts sel forth in this complaint are true and correct o the best of my knowledge or information and belief. ‘This verification is made subject to the penailies of Section 4904 of the Crimes Code (18 Pa.C.S. § 4904) relating to ‘unsworn falsification to authorities, 4. This complaint consists of the preceding page(s) numbered _L through ®. 5. ! cently that this fling complies with the provisions of the Case Records Public Access Polley of the Unified Judicial System of Pennsylvania that require fling confidential information and documents differently than non-confidential information arid documents. ‘The acts committed by the accused, as listed and hereafter, were against the peace and dignity of the Commonwealth ‘of Pennsylvania and were contrary to the Aci(s) of the Assembly, or In violation of the statutes cited, {Before a warrant of arrest can be issued, an affidavit of probable cause must be completed, sworn to before the issuing authority, and attached.) AND NOW, on this dat: 5-18-24 | certly that the complaint has been property epmpleted and verified. An affidavit of probable cause must be completed befora a warrant can be Issued. O2-_\- 6 fr ‘Wgistorial Dishict Cour Numb=r) Tssulag AURA) Temporary Assignment by court orderaah POLICE CRIMINAL COMPLAINT Docket Number: Date Filed: | OTNiLiveScen Number ‘Complaint # Tneldent osama 2A-oooees 2024018018 | First: Nido: Last Contes Nok sta ‘The acts committed by the accused are described below with each Act of Assembly or statute allegedly violated, if appropriate. When there is more than one offense, each offense should be numbered chronologically, (Got orth abriaf summary ofthe acts eulficlnt to ales tha defendant of th nstur of tho offense) charged, A citation tothe statutes) allegedly vid without more ental ine aommary cas, you run ce he apei actions)an ubuaton(} fhe ta) or cancte) Inefioate [TI Attempt EF Sotenation Ti Gonepiracy Inefioats | TT Aten a ‘Genee Number of Victims Age 60 or Older. 31224 ©) beara 8 1 FA as ERS —oa— gan OO RTE: Gents | Cleat ze | Wate Slatute Description (include the name of slalute of ordinance); 3122,1(0) Statutory Sexual Assault ‘als of the accused associated with this Offense: EE ‘person commits a feoiyof the fit dagroe when tht person engages in sexielInfercourse with a complainant under the 6ge of 16 yeats and that person, |e 14 or more years older than the complainant andthe Complainant end the person are not marta to each othe. The defendent, being 43 years. ol, took his rect bare penis and made contact withthe 14 year old victim's vulvar ves6buse, whichis located past te vaginalis. The defendant and vi are not ‘mario i e6ch ote, Ci Fonagiooy Number of Vitis Age 69 or Oe x Bley. Z 8 1 FS Fate SS — tase — He ome | ae estate Tisateyzone [Cher zone Statute Description (include the name of slaiuts oF ordinance): 8124.2(6.2) Institutional sexual assault ‘Aas of the accused associated with this Offense: [person who has dct contact wih a siudent ala schoo commits a felony ofthe hu degree when he engages in sexual intercourse, deviate sexval Infercourse or indecent contact with a student of he school. Th defendant, was assignod as a SRO at EHMS snd eégoged in sexual ntorcourse, deviate servi nlercouree, end indecent contact with a student ofthe school ot inside the Schoo! and aud the schos!. Or Seaton Senapieey Nunbor of Vietng Age 80 or Ofer oe) See 1 DF Bed ee eS a eS Ci Interstate D Safely Zone Dl Work Zone “Statute Description (include the name of salute or ordinance) 3126(a\'8) Agaravated Indecent Assault ‘Acts of the accused associated with this Offense: ‘A prson who engagns in panetralon, however sight of tho genitals or arus of a compleinant iy apart of the person's body for any purpose other than 004 feth medical, hygene or aw enforcement procodures commits aggravated Indecontassaul ifthe complainants loss than 16 years of age and the Pereén i four or more years olior han tho complainant and the complainant andthe parson are not mariod to each cher. The defendant (43 yews old). Inserted his pont, tongue, and fingors ilo tho vagina ofthe vcim (14 yoare ot). The dofendont and vier are not marced to eaeh ober ROPC 412A Rev. 12/24 : Page Sof 8Eg POLICE CRIMINAL COMPLAINT Docket Number: Date Filed: | OTNiLiveScan Number Coniplaint # Tneldent # 50112024 24000886 2024018018, ist dae: Last: Costas ok Alosias ‘The acts committed by the accused are described below with each Act of Assembly or statute allegedly violated, I appropriate, When there is more then one-offense, each offense should be numbered chronologically. {Godt a bioraummary a the tat surtet to aes the detondont of the nature the eons) charg. A clation one state(s) soggy Sad wat or not ler na summary cat, you most ts sani sciat) auburn he sa) or oan) Beg Inchoate’ | C7 Attempt Ti Soficitation TH Conspirac Offense. 1B00FA 18.902. 10008 ie Number of Viotiens Ago 60 or Older. ofa 3123 (ant?) 18 1 FA tn PAS EY A ea ee CHineotte | ChSatey zoe | Cawork Zone ‘Stalute Description (include the name of statute or ordinance): |. 2122t\(7) Involuntary Deviate Sexualinieroourse ‘Acts of the accused associated with this. Offense: ‘A person commits felony of he fst agree when the parson engages in doviate ces ntarcouree with a complainant whois less than 16 years of eg andthe person i four or more yoars older than the complnant and the complainant and poreon ee net maid o aachethar, The defendant (43 years old) inserod Ns penis, tongue, end fingers into tho vagina ofthe vctn ($4 year 6d). The defendant and vicim are not marred te each other, Tachoate ‘Attempt TiSolicitation Ti Conspiracy inchoate [CI Aterpt on Conspiracy uber of Viting Age 6D or Ofder ots] | @ —al a aaa oa ies TT — Gael ~— aOR Tae j c ae 1D tnerstate Di safety Zone C1 Work Zone ‘Statute Description (include the nama of statue oF ordnance): 7512(a) Criminal Use of ¢ Communications Facility ‘Acts of the accused associated with this Offense: ‘A porson cornmis a felony of the tha degre if tha pereon uses corsmuniaton facty to comvmt, cas or fcltate tho commssion ortho alompt ‘hereof of any crine which consis a felory undor tis the. The defendant used a collar hone ard an lteret basad messaging application to facto the statutory Sovual assault, nstiltonelsoxual assault, aggravated Indecent assaul and Involuntary deviate sexual intercoure offences agalna tho 14 year oid vletim. The four efenses Inte ae el felones, Usain ET conapiacy Number of Vitis Age 60 or Older 12) foam] te 1 we sec ia aa eR Oa TSAR D interstate Safety Zone OD Work Zone Salute Description (clude the narme Of lalate or OrInanosy 7507.4(a\(2\ Invasion of privacy ‘Acts of the accused associated with this Offense: “The detendant a, fo the purpose of arousing or gafyng the sexual daske of any person, knowingly dogs photographs, videotapes, electonialy donee, ‘ins o otherwise record oF parson views the ntiate pate, whathar of aol covered by cating of another parson withoul thal parsons Krowledge ard ‘censant and which Intimate pats thet parson does not ntad lobe visible by normal plc observation. The defendant took an “upekit'video ofthe 11 year ‘ld vizim witout her knowiodge or conse, videotaping her led vagal and butlocks eran, ‘ROPE 443A —Rev. 12/24 Page 4 of 8ah POLICE CRIMINAL COMPLAINT Bocket Number; | Date Filed: | OTN/LiveScan Number Complaint # Incidont # 05/01/2024 24-000886 —_2024.916018 Ol Fret: Midler Tast : Costes Nek Alestas AFFIDAVIT of PROBABLE CAUSE Your AFFIANT in this matter is Detective Lieutenant Diluzio. He is a duly sworn officer for the Commonwealth and is currently employed by the City of Bethlehem Police Department. He is a certified law enforcement officer by the Pennsylvania Municipal Police Officers Education and Training Commission, certification number 35786. Your AFFIANT is a FSI Task Force Officer (IFO) on the PBI Child Exploitation and Hunan ‘Trafficking Task Force. (CRUTTP) He is also a sworn detective in Lehigh County as a member of the Lehigh County Computer Crimes Task Force (L3CTE) and a member of Internet Crimes Against Children (ICAC) Taskforce. #is current assignment ie Lieutenant of the Criminal Investigations Division, which includes detectives, forensics, vice and evidence. Your CO-AFFIANT in this matter is Detective Falko. She is a duly sworn officer for the Commonwealth and is currently employed for the City of Bethlehem Police Department. she is @ certified law enforcement officer law enforcement officer by the Pennsylvania Municipal Police Officers’ Rducation and Training Commission, certification number 42782. Your CO~AFFIANT is currently assigned to the Criminal Division as a Special Victims Detective. Your CO-AFFIANT is a member of the Northampton and Lehigh County Drug Task Force, a member of the Pennsylvania Internet Crimes Against Children Task Force, and a member of the Northampton County Major Crimes Task Force. (CONTINUED NEXT PAGE) 1, H. Méhael Dizi & Det. Emly Feko, BEING DULY SWORN ACCORDING TO THE LAW, DEPOSE AND SAY THAT THE FACTS SET FORTH IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF. A. CERTIFY THAT THIS FILING COMPLIES WITH THE PROVISIONS OF THE CASE RECORDS PUBLIC ACCESS POLICY OF THE UNIFIED JUDICIAL SYSTEM OF PENNSYLVANIA THAT REQUIRE FILING CONFIDENTIAL INFORMATION AND DOCUMENTS DIFFERENTLY THAN NON-CONFID! SSworno me and subscribed before me this |S74_dayor Date My commission expires first Monday of January, “oo 53 Temporary fssignment by courtorder ‘AOPC 411#88 POLICE CRIMINAL COMPLAINT AFFIDAVIT CONTINUATION PAGE Date Filed: ‘OTNiLiveScan Number ‘Complaint: Incident-# osot2024 24-000666 _2opkareote a TR a a aa on is AFFIDAVIT of PROBABLE GAUSE CONTINUATION she has received numerous trainings from the National Children’ s Advocacy Center in forensic interviewing of children as well as training for multi~disctplinary responses to enild victims. She has xeceived further training in forensic interviewing of children through ChildFiret Zero Abuse Project. and is also a member of The American Professional Society on the Abuse of Children. She received her Master's Degree from DeSales University in digital forensics. ‘The DEFENDANT in this matter is 43-year-old COSTAS ALESTAS, BOB 1/7/1981. At the time of these offenses, the DEFENDANT was employed Sy the City of Bethlehem Police Departitent as a School Resource Officer (SRO). He was assigied to East Hille Middle school (EHMS), located at 2005 Chester. Rd, Bethlehem, PA 19017 (Northampton County). The DEFENDANT was also employed by the Bethlehem Area School District (BASD).as a coach for the BHNS co-ed soccer team, One victim in this matter is a 14-year-old female who will be referred vo as VICTIML, A second victim in this matter is an 11-year-old female who will be referred to ae VICTIMZ. on 5/1/2024, the City of Bethlehem Police Department was notified by BASD personnel of an allegation of an inappropriate relationship between a female student at EMS and the DEFENDANT. Inmediately sfter receiving the notification of the allegation, the DEFENDANT was ordered to leave EHMS and report to police headquarters where he was placed on * adninistrative leave. The Defendant voluntarily surrendered his cellular phone (an Apple iPhone) and it was placed into police evidence. Investigation revealed the identity of VICTIM. Detective Falko interviewed VICTINI and learned details regarding her relationship with the DEFENDANT. VICTIM stated she initially net the DEFENDAN? while she Was a student at BHNS. The DEFENDANT told her that he didnt "Look at students’ the way he looked at her and that he found her attractive and that attvajgo talk about, engaging da sexual acts, familiarizing her with this informatg@ngely pee eing the behavior. he, had strong romantic feelings for her. They, ‘AOPC 414C ~ Rev. 12/24tah POLICE CRIMINAL COMPLAINT AFFIDAVIT CONTINUATION PAGE Docket Namber Date Filed: “OTNiLiveScan Number Complaint# |) ‘Incident losiove0ze 24000086 2024-01608 Tse ay Fist: Wider Tast: fone cates Nek estos AFFIDAVIT of PROBABLE CAUSE CONTINUATION Due to the fact that VICTINI didn't have social media, the DEFENDANT provided her with nis personal cell phone number 610-972-2964 to continue their communication outéide of school. Te shonld be noted the phone number 610-972-2964 is the cellular phone number the DEFENDANT hao on file with our police department. In February of 2024, the VICTIML's mother monitored her cellphone and discovered text messages. between her and the DEFENDANT. VICTIM1 was aware that her mother saw the messages and told the DEFENDANT of the discovery. The DEFENDANT blocked VICTIMI's phone number and told hex he would think of another way to communicate with her, In March of 2024, the DEFENDANT began communicating with VICTIM, using the ‘TextNow number 484-299-1161, which she stored in her phone as ‘Isabella’. Secret meetings and conversations in the DEFENDANT'S office continued. The DEFENDANT and VICRIMI would kiss in his office and he would touch VICTIMI's buttocks and breasts above her clothing, This behavior evolved to her undressing in the DEFENDANT's office where he would view her entire naked body. In Mazch of 2024, the DEFENDANT told VICTIMI that 8 school administrator was not going to be at a scheduled echool dance and that he was going to find a concealed place for them to have @ sexval encounter. The DEFENDANT instructed VICTIM to follow him to the boy's locker xoom at ERMS, while he was being employed to patrol the dance. During this time, the DEFENDANT kissed VICTIMI, groped her buttocks with his hands, and rubbed her vagina with his hands over hex clothing, The DEFENDANT proceeded to take his erect. bare penis and force contact with VICTIMI's vulvar vestibule, which is located paét VICTIMI's vaginal lips. The DEFENDANT was in full police uniform while committing this sexual offense. City of Bethlehem Police scheduling records indicate that the DEFENDANT worked 3 hours of overtine fat the school dance at ERNS on 3/15/24. A video was also obtained of the school dance where the DEFENDANT and VICTIMI can be observed speaking with one another in the background. The DEFENDANT also told VICTIM. to leave her home and mest him in secluded areas to be picked up in his zed Jeep Cherokee or his silver Nissan STR. PennDot records indicate the DEFENDANT owns a zed deep SUV beagifig,PA registration, BSK3346, and a silver Nissan Gra NEXT PAGE) {signature SkaMiont) ‘OPC a116— Rev. 12/28 “Page 7 of ©1a POLICE CRIMINAL COMPLAINT AFFIDAVIT CONTINUATION PAGE Docket Numbarr | ~Date Filed ‘GTRULveSean Number Complaint# |) Incident josorre 24-0006 _20as-owore Fret iar Ta I cov [ene Asn AFFIDAVIT of PROBABLE CAUSE CONTINUATION VICTIM, stated the DEFENDANY would routinely pick her up after soccer practice due to his wife having a '360 app' and knowing where he was. After their secret mectings, he would drop her off in the area of her home so she would not be seen. Search warrants for the DBFEDNAN?'s phone and his TextNow account recovered location data. The recovered location data also shows the DEFENDANT's phone in VICTIMi's neighborhood on the evenings of 4/23/2024 and 4/25/2024 and the morning of 4/26/2024. VICTIM further indicated that the DEFENDANT picked her up in his Jeep and drove her to the Green Pond Country Club parking lot (3604 Farmersville Rd, Bethlehem, 2A). VICTIMI stated the DEFENDANT placed his tongue and mouth on her bare vagina and inserted his fingers into her vaginal opening. Location data recovered from the DEFENDANT’s phone and was compared with the records from TextNow. Those records show that on 4/11/2023, the following occurs: #08PM through 5:57PM - The DEFENDANT and VICFIML are coordinating meeting. The DEFENDANT indicates he is driving his Jeep. ~6:05PM ~ location data from the DEFENDANT's phone shows it was in the Green Pond Country Club parking lot 6:21PM through 6:23PM - The DEFENDANT texts VICTIM ‘Dann’ followed by unknown emojis. VICTEML then states her ‘legs are shaking! and she ‘can't walk nozmally'. They talk about her going back ingide her house and it ends with the DEFENDANT stating 'OK, delete everything and I'11 talk to you tomorrow". On aitother occasion, the DEFENDANT picked up VICTSML in his Nissan GTR and drove her to the William Ponn Park and Ride (5715 William Penn Huy, Easton, PA 18045). She stated she masturbated his bare penis with her hand. The DEFENDANT also kissed her breast and sucked fon it to the degree he caused a bruise or ‘hickey'. (CONTINUED NEXT PAGE) “ope a14¢ = Rev. 12/2148% POLICE CRIMINAL COMPLAINT AFFIDAVIT CONTINUATION PAGE Docket Number: Date Filed: ‘OTNiLiveSean Number ‘Complaint # Tneident # josiow2024 24000886 —_2024-018018" Tre ae: Tat a i ae AFFIDAVIT of PROBABLE CAUSE CONTINUATION On multiple o¢easions, the DEFENDANT would instruct VICTIML to come to his office. fle. would tell VICTIMI to lie about their relationship and if ever questioned to ‘act suxprised' as Af Lt wis hex ‘first time nearing this.' fle told her that although it was ‘erazy’ thoy: were doing this, they were ‘in love with each other.! On 5/6/2024, tdeutenant Dituzio was granted sealed search warrants to search the DEFENDANT'S iPhone and to obtain, content and subscriber information from TextNow. on 5/8/2024, Textiiow provided the subscriber information for 484~-299-i161 as well as message content and call logs. The TextNow account was created on 3/26/2024 using email address guesswho44d@myyahoo.com and was active until 5/3/2024. Data recovered from the DEPENDANT's phone links the Textiow account with said email address to his phone. With the ToxtNow number, approximately 4980 messages vere exchanged between VICTINI and the DEFENDANT, and 49 phone calls totaling over @ hours since 3/26/2024. One video recovered from the DEFENDANT's phone was taken on 3/15/2024, The video was taken inside Bast Hille Middle School and is an 'upskirt' type video of VICTIM2. The video was token with the DSFENDANT's phone and his voice can he heard towards the end of the video. ‘The DEFENDANT strategically turns the phone upwards to record up her skizt to focus in on hex vaginal and buttocks axea. VICTIN2's parents positively identified her in the video based on her clothing she was wearing on the date the video was taken. Due to the above-stated facts, your AFFIANTS request that an arrest warrant be granted for the DEPENDANT COSTAS ALESTAS, / Tu dlrlay ‘AOPG 411¢~ Rev. 12/24 Page 8 of 3