/I
AO
91
(Rev, 08/09)
Criminal Complaint
II
I,
UNITED
STATES
DISTRICT
COURT
,2013
for
the Western District
of
Texas United States
of
America
)
Case No.
£P.'
/
3
1
3
/
-
m,rCi)
DEION LOCKHART
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
August, 2012
to
October, 2012 in the
county
of
Western District
of
Texas
,
the defendant(s) violated:
El
Paso
in
the Code
Section Offense
Description
Title
18
U.S.C.
§ 1591
Knowing,
or
in
reckless disregard
of
the
fact,
that
force,
threats
of
force, fraud,
or coercion
will
be
used
to
cause
sex
trafficking of
children
and/or
a
person
to
engage
in
a
commercial
sex
act. This
criminal complaint
is
based
on these
facts:
See
attached
affidavit.
(
Continued on
the attached sheet.
ók
4A'
Complainant's signature
Clinton
J.
Smith,
FBI
Special Agent
Printed
name
and
title
Sworn
to
before me and signed
in my
presence.
Date:
ZOI
Judge
s
signature
City and
state:
El
Paso, Texas
Miguel
A.
Torres,
U.S.
Magistrate
Judge
Printed
name
and
title
Case 3:13-mj-03331-MAT Document 1 Filed 07/19/13 Page 1 of 4
Affidavit in
Support of
an
Arrest
Warrant
1.
I,
Clinton
J.
Smith,
hereinafter referred to
as
Complainant, am
a
Special Agent (SA)
of
the Federal Bureau
of
Investigation
(FBI), and conduct investigations
of
violations
of
Federal Criminal
Law, including Human Trafficking.
2.
From approximately August, 2012 to
October,
2012,
Deion LOCKHART, also known
as
MEMPHIS, forced
juvenile
victim
AG
to prostitute
in El Paso, Texas,
which
is
in
the Western District
of
Texas.
3.
The victim,
henceforth identified
as AG, has conveyed to Complainant
through interviews
some
of
the facts contained in this affidavit.
4.
In approximately August 2012,
AG was
invited by
a
friend she knew from high school
to a motel
room
to make
some money . AG was
16
at the time.
When
AG
arrived
at the
motel room,
at
COMFORT INN
at 900
North Yarbrough
Drive, El Paso, 79915, there
were four
to five
black
males in
the room smoking marijuana.
One
of
the males was
a tall,
light
complexioned
black
male with several tattoos that went by the moniker MEMPHIS .
Also
present were two
other girls
that
AG did not know. AG was
told that
she was
just
going to
sit
in
a
motel room and answer the
door,
and when men came
in,
LOCKHART would
rob them.
After
some time, AG went to
the bathroom. When
she
returned, the friend
she
arrived with
was
gone.
LOCKHART told
AG
that her friend would return
later.
5.
LOCKHART
and
the other
men
had two adjoining
rooms at the COMFORT
INN.
LOCKHART told
AG to come
to
the adjoining room. LOCKHART then
told
AG she had
to
take pictures for the website, and when
she
asked what website and what kind
of
pictures, he ignored
her.
LOCKHART
told AG to
take
off
her shirt and pants and then all the males except
for
LOCKHART's
cousin came
in to
the
room.
The men instructed her how to pose
for the pictures. When AG
told the men that
she did
not want to take pictures, they
responded
by
continuing to pressure her to pose for pictures;
AG
then followed
their
instructions.
The men
spoke openly about posting but
she
did not know what that meant. After taking
the pictures,
AG was
allowed
to get
dressed and the men
gave her more marijuana.
Approximately
10
minutes later, a man
AG
did not know came
to
the door
of
the motel room that
AG was
in.
AG was
then instructed
by
LOCKHART to have
sex
with the
man. AG
told LOCKHART that
she
did not want
to
have
sex
with
the
man but he continued to pressure
her.
He further instructed her to put
the money
under the
door to
the adjoining
room.
As
she went to
the motel room door and
let
the man
in,
LOCKHART closed the door to the adjoining room. AG
let
the
man in and did everything LOCKHART instructed her to
do
to include having
sex
with the man
for money.
That
night AG
had
sex
with
two
men.
The two men paid her by handing her the money or leaving
the
money on
Case 3:13-mj-03331-MAT Document 1 Filed 07/19/13 Page 2 of 4
the dresser.
She
did not leave the motel because LOCKHART
was big and he scared her.
LOCKHART took
all
of
the money that
she
made through prostitution that
night.
6.
In the following days
LOCKIHIART
continued to give
AG
marijuana and forced her
to
have
sex
with five to
six men
a day every day
of
the
week. AG was never
given
a
day
off,
but
there were some days that
she
did not have to work
as
much and only had
sex
with
a
couple
of
men
at night. The
men would pay AG
$100 for
30
minutes
or $180
for
an hour
for sex
with
customers. However,
if
she
spent more than
15
minutes with
a
customer, LOCKHART would yell
at
her and accuse her
of
enjoying
it.
This cycle
continued until approximately
late September or early October 2012.
7.
The first customer that
AG
had
sex
with failed
to tell her that the condom
broke
during
sex.
AG
did not know
if
she
had any sexually transmitted
diseases (STDs) or
if
she
was pregnant. After the first night, LOCKHART took AG to
his
brother's
house. AG was kept at
his
brother's
house and
at various hotels during the
time she
was
with MEMPHIS.
8.
AG was not allowed
to have
a
phone and
was not
permitted to
keep any
of
the money she earned through prostitution. AG slept on
a
couch
in
MEMPHIS
's brother's
house and
was given food
(usually fast
food)
only once a
day. AG
was given toiletries
and
clothes
by
the other
girls
present
at
the house and by LOCKHART. The
men would mistreat the girls, often assaulting them
and
calling them names such
as
bitch , whore and ho . LOCKHART was considered a
pimp
by
the
girls
and the
men.
9.
LOCKHART continually intimidated
AG.
If
she was
not making money,
prostituting LOCKHART would yell
at AG and tell her
that
he
did not
have her there
for
no
reason.
If
LOCKHART thought that
AG
wasn't
paying attention
to him,
he would grab
her arms
and yell at
her.
LOCKHART forced
AG to have sex
with him four
to five times,
even
though
she did not want
to.
When
she resisted,
LOCKHART pulled her in closer and forced
her.
While at motels, AG was
not
allowed to leave the
room.
LOCKHART intimidated her and whenever
she
asked to
leave, she
was told
no.
LOCK}IART would tell
AG
that
she
could
not leave
because
money was
calling .
10.
LOCKHART
did
not beat
AG,
but
AG saw other
men hit their
girls.
At one
point
one
of
the men beat
his girl
because
she
took too
long with
a
customer and was
paid
in one
dollar
bills.
When the
girl
came into the room after being
with the
customer, the man asked her why
she
took
so
long with
the
customer and asked
if
she
had been dancing
for
the
one dollar bills.
When the
girl went to take
a
shower in
the hotel
room,
the man went
into
the bathroom and began yelling
at her and hitting her. He
threw her
out
of
the bathroom and continued
to hit
and kick her in the
back,
Case 3:13-mj-03331-MAT Document 1 Filed 07/19/13 Page 3 of 4
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