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REDACTED COPY
REDACTED
FILED
MAY 2 6
^CLERK, U.S. DISTRICT
COURT
AFFIDAVIT IN SUPPORT OF APPLICATION
NORFOLK,
va
FOR ISSUANCE
OF
A CRIMINAL COMPLAINT
2, l#M\Ulr
I, Kristin B. Joseph, being
first
duly swornstate:
I
am
a
Special Agent
of
the Department
of
Homeland Security, Immigration and Customs
Enforcement (ICE).
Homeland
Security Investigations (HSI), currently assigned to the Office of
the
Assistant
Special Agent inCharge (ASAC), Norfolk,
Virginia.
I have
been
so
employed
since August 2005.
As
part
ofmy
daily
duties as an
HSI
agent, I investigate criminal violations
relating to child exploitation
and
child
pornography1
including violations pertaining to the illegal
production,
distribution,
receipt,
and possession ofchild pornography, in
violation
of 8U.S.C.
§§ 2251, 2252
and 2252A. I
have received
training
in
the
area
of
child
pornography and child
exploitation,
and
have
had
the
opportunity
to observe
and
review numerous examples ofchild
pornography
(as
defined in 18 U.S.C. § 2256(8)) in all forms ofmedia including computer
media.
2. Your affiant hasassisted in the investigation of theoffenses described in thisaffidavit. Asa
result ofyour affiant's
participation in
this
investigation
and a
review
of reports made
by other law
enforcement officers, your affiant is familiar with the circumstances of this
on-going
investigation.
I have
not
included each
and
every fact known tome in this affidavit, butonly the
facts
I believe are
necessary
to
establish
probable
cause
to
believe DAVID
ALLISTER
CAMPBELL
has
engaged
in
the crimes ofdistribution, receipt,
and
possession of child pornography, in violation of 18
U.S.C.
§§
2252(a)(2) and (a)(4)(B).
L EGAL
AUTHOR I T Y
3. 18 U.S.C. § 2252(a)(2) provides that anypersonwhoknowingly receives,or distributes,
any visual depiction using any means or facility of interstate or foreign commerceor that has
been mailed, or has been shipped or transported in or affecting interstate or foreign commerce, or
which contains materials which have been mailed or so shipped or transported, by any means
including by computer, or knowingly reproduces any visual depiction for distribution using any
means or facility of interstate or foreign commerce or in or affecting interstate or foreign
commerce or through the mails, if (A) the producing of such visual depiction involves the use of
a minor engaging in sexually explicit conduct; and (B) such visual depiction isof such conduct,
shall be punished.
4. 18 U.S.C. § 2252(a) (4) (B) prohibits a person from knowingly possessing, or knowingly
accessing with intent to view, one or more books, magazines, periodicals, films, or other
Child
Pornography means any visual depiction, including any photograph, film, video, picture, or
computer
or
computer-generated image or picture, whether made or produced by electronic, mechanical, or other means, of
sexually explicit conduct, where - (A) the production of such visual depiction involves the use of a minor engaging
in sexually explicit conduct; . . . [or] (C) such visual depiction has been created, adapted, or modified to appear that
an identifiable minor is engaging in sexually explicit conduct. For conduct occurring after April 30, 2003. the
definition also includes (B) such visual depiction is a digital image, computer image, or computer-generated image
that is, or is indistinguishable from, that of a minor engaging in sexually explicit conduct. 18U.S.C. § 2256(8).
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materials
which contain
visual
depictions ofminors
engaged
in
sexually explicit conduct
that
have been mailed, shipped or transported using any means or
facility
ofinterstate or foreign
commerce or in or
affecting
interstate or foreign commerce, or
which
was produced using
materials which
have been
mailed,
shipped or transported, by any
means including
by
computer.
PRO LE
C USE
TO
RREST D VID C MP ELL
5. Onor about November 19,2014,the
National
Center forMissing andExploited Children
(NCMEC)
received
information from
the Microsoft Corporation in which Microsoft
reported
that the
account | ^H^ | msn com
had,
on
several
occasions
on
November 10,
2014,
uploaded
numerous images
of
child pornography
to
the
Internet. Microsoft also included
the Internet
Protocol
Address (IP)
from
where theactivity occurred. The IP address was
subsequently
traced
to the residence ofDavid
CAMPBELL
at ^ ^ ^ | H | ^ ^ ^ H ^ ^ |
IB Virginia Beach, Virginia,
^ ^^ The
information was forwarded to the Southern
Virginia
Internet
Crimes Against
Children
Task
Force (SOVAICAC)
at the Virginia Beach
Police
Department (VBPD).
6. Onor aboutMarch23,2015, NCMEC received information froma concerned citizenthat
someone was
posting comments
on an
online
Tumblr2
account
in which the individual claimed to
travel toHarrisonburg,
Virginia,
to
engage
in
sex
with underage boys. The reporting
party
provided
the URL as
http://|H^^^H.com
as the account making the comments.
A
VBPD
Detective reviewed theTumblrpage andobserved the page was titled Boys Arethe
Best ,TheDetective also observedthe posting Boysare to be loved and appreciated. Findme
on Skype and
Hotmail
as
^^H
and on Yahoo and
as
^^^^^^H-
7. On or about December 6, 2015, NCMEC received information from another concerned
citizen that someone had posteda cartoondepicting children being sexuallyabusedon the
Tumblr
account http://^^H|^HH-com '
The
reporting party
also
stated
the user posted
comments that he regularly had sexualcontactwithunderage boysas youngas 10yearsold. The
sameVBPDDetective reviewed the Tumblr page and observed it to be the same webpage from
theprevious NCMEC report. Further, the userof theTumblr pageprovided a Yahoo e-mail
address for people that wanted to contact him.
8. As part of the investigation, the Virginia Beach Detective subpoenaed Yahoo Inc.
(Yahoo ) for subscriber and IP information for the email account provided by the Tumblr user.
Yahoo responded the subscriber for
the
account
was
listed as
David
CAMPBELL at^|
|Virginia
Beach,
Virginia, |^|
2Tumblr isa social
networking
site that
allows members
to post pictures stories and other activities
2
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9. On February 25,2016,
VBPD
Detectives and agents from the HSI Norfolk executed a
state search
warrant at CAMPBELL'S
residence located
at
^^H^^HI^^^^^^^HI
Virginia Beach,
Virginia,H
Present
at
the residence
was
CAMPBELL.
CAMPBELL was
informed the investigators had
a
search
warrant
for
the
premises and made entry and secured the
location. During the
execution of
the search, CAMPBELL
was
read his Miranda Rights and
he
agreed
to
speak with
the investigating
agents. During the
interview
CAMPBELL
admitted
to
accidentally uploading
child pornography
from
his B^^^^^Hi@msn'com ema
account. CAMPBELL statedshortly afterhedid that, MSN
locked
outhis
account.
CAMPBELL also admitted to the activity that had been reported regarding the Tumblraccount
and his associatedTwitter account. CAMPBELL stated that he traded child pornography via
Twitter in
the
private direct messaging, but
not
onhis public Twitter
page.
He
stated that at the
time hedidn't think the direct messages were
monitored
byTwitter butthat he
now
he thinks itis
because his Twitter account was closed. CAMPBELL further stated that he had been involved
with child pornography for at
least 25
years and would
consider
himselfa
pedophile.
CAMPBELL stated that
when
he
saw
a child he would envision the child naked and fantasize
about engaging in sexual acts with the child. CAMPBELL
stated that
hehad never followed
through with
his
fantasies
andthe
comments that
were
made
onthe
Tumblr account
was just
fantasy talk.
10. The search was conducted and the following devices were seized: Acer CPU- S/N:
DTSRQAA00841083B913000, IBM CPU
-
S/N: 81893HULKYD5NT, EMachines CPU
-
S/N:
PTNADOX002909009A09000, LenovoLaptop -
S/N:
CB06308917, Two Rosewill External
HardDrives, Hitachihard Drive, two MaxtorHard Drives,Western Digital Hard Drive,PHR-
10)A External Hard Drive,
Seagate External
Hard Drive,
Western Digital External hard drive,
Eight thumb drives, Three SD cards, For CD-R's, Two DVD's.
11.
On
April
21,2016, a Federal search warrant wasobtained forHSIto conduct
forensic
examinations on
the
items
seized
from
CAMPBELL S residence. The
forensic examinations are
notcomplete yet, but to date the resultshave revealed approximately 5,287 images andvideos of
child pornographyon multiple computers or storage devices seized from CAMPBELL'S
residence. An example of some of the files are as follows:
a. A video entitled 07.mp4 was created on the Acer desktop computer on
December8,2015 and depicts a prepubescent male engaged in oral-genital sexual intercourse
with
an
adult male.
b. A video entitled 03.avi was created on the Lenovo laptop computer on
December
9,2015
and depicts a prepubescent male engaged in oral-genital sexual intercourse
w it h a n
adu l t male .
c. A video entitled 2015-09-25 19.22.36.mp4 was created on the Acer desktop
computer on November 11,2015 and depicts a prepubescent male engaged in anal penetration
using a foreign object.
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d. A video entitled 02.mp4
was created
on the Lenovo laptop onDecember 8,
2015 and
depicts
two prepubescent males
engaged
inoral-genital sexual
intercourse.
e. A video entitled al009.avi was created on the Acer desktop computer on
January 26,2016 and
depicts
a prepubescent male
engaged
in
oral-genital sexual intercourse
with an adu lt male.
12. Basedon the informationand evidenceset forth above,your affiant respectfullysubmits
that there
is
probable cause
to
believe
thatDAVID ALLISTER CAMPBELL has committed the
following offenses:
Count
One: Onor about November 10, 2014, in
Virginia
Beach, in the
Eastern
District ofVirginia,
DAVID ALLISTER
CAMPBELL
knowingly
distributed
visual
depictions ofminors
engaging
in
sexually explicit
conduct, using a means or
facility
of
interstate
or
foreign commerce
orthathas
been mailed, shipped
or
transported
inor
affecting interstate
or
foreign commerce,
or
which contains materials which
have been
mailed, shipped
or
transported,
by
any means
including
by
computer,
in
violation
of
Title 18,
United
States Code, Section
2252(a)(2); and
Count Two:
Onor
about February
24,2016, inVirginia Beach, intheEastern
District
of
Virginia,
DAVID ALLISTER CAMPBELL
knowingly
possessed
material
which
contained visual depictions
of
minorsengagedin sexually explicitconduct that havebeen
mailed, shipped or transported using anymeans or facility of interstateor foreign commerce or in
or affecting interstate or foreign commerce, or whichwasproducedusing materials whichhave
beenmailed, shipped or transported, by any
means
including by computer, in violation of Title
18, United States Code, Section 2252(a)(4)(B).
13. Accordingly, I request that a warrant be issued authorizing the arrest
of
DAVID
ALLISTER
CAMPBELL.
Kristin B. Joseph
Special Agent
Department ofHomeland Security
Homeland Security Investigations
Norfolk,
VA
Sworn to before me this day
of
May, 2016.
United States Magistrate Judge
Eastern District ofVirginia
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