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TM:MPR
UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK ------X FILED UNDER SEAL UNITED STATES OF AMERICA AFFIDAVIT IN SUPPORT OF - against - ARREST WARRANT AND COMPLAINT TATIANA DANIEL, also known as "Kimora" and M.No. ------"Kimora Solange," (T. 18, U.S.C., §§ 1594(a) and 1594(b)) SHANDALE FRANKLIN, also known as "Shandale Rebelious Franklin" and "Shandale Kayla Franklin," and
BRIAN ADAMS, also known as "Bryan Adams,"
Defendants. ------X
EASTERN DISTRICT OF NEW YORK, SS.:
STACY SHAHRANI, being duly sworn, deposes and states that she 1s a
Special Agent with the Federal Bureau oflnvestigation ("FBI"), duly appointed according to
law and acting as such.
On or about and between January 11, 2014 to June 19, 2014, both dates being
approximate and inclusive, within the Eastern District of New York and elsewhere, the
defendants TATIANA DANIEL; also known as "Kimora" and "Kimora Solange,"
SHANDALE FRANKLIN, also known as "Shandale Rebelious Franklin" and "Shandale
Kayla Franklin," and BRIAN ADAMS, also known as "Bryan Adams," and others known
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and unknown, willfully and knowingly, in and affecting interstate commerce, did attempt and
conspire to recruit, entice, harbor, transport, provide, obtain and maintain by any means one
or more persons, knowing and in reckless disregard of the fact that the person had not
attained the age of 18 years and would be caused to engage in a commercial sex act.
(Title 18, United States Code, Sections 1594(a) and (b))
The source of your deponent' s information belief and the grounds for her
belief are as follows:
1. I am a Special Agent with the FBI currently assigned to the FBI's New
York Field Office. I have been a Special Agent with the FBI for over five years. During my
tenure with the FBI, I have participated in numerous criminal investigations, including those
involving international organized crime. Since July 2013, I have been assigned to the Crimes
Against Children squad. I am currently conducting an investigation together with the New
York City Police Department ("NYPD") and the Kings County District Attorney's Office
into this matter. I am familiar with the information contained in this affidavit based on my
own personal participation in the investigation, my review of documents, my training and
experience, and discussions I have had with other law enforcement personnel. Additionally,
statements attributable to individuals herein are set forth in substance and in relevant part.
2. As set forth in the paragraphs below, there is probable cause to believe
that the defendants TATIANA DANIEL, SHANDALE FRANKLIN, and BRIAN ADAMS,
together with others, are involved in the commercial sex trafficking of minor victims. In
particular, the defendants have solicited females between the ages of 12 and 15 to engage in
sexual conduct with adults on various dates and at various locations in exchange for money,
including at a "sex party" planned for January 2014 in Brooklyn, New York, where multiple
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minor victims were to be paid to engage in sexual conduct with adults. Because I submit this
affidavit for the limited purpose of establishing probable cause to arrest the defendants, I
have not set forth all facts known to me about this investigation and case.
I. TATIANA DANIEL
3. On or about April 15, 2014, "Individual I" was arrested on a complaint
charging him with engaging in child sex trafficking in violation of 18 U.S.C. §1591.
Specifically, the complaint alleged, in or about December 2013 , Individual 1, who was 31
years old at the time, engaged in sexual conduct with two minor females, "Victim I," age 12,
and "Victim 2," age 13. The complaint further alleged that Individual I had arranged and
attempted to arrange meetings between Victim I and Victim 2 and other adult individuals,
for the purpose of having Victim I and Victim 2 engage in sexual conduct with the adult
individuals in exchange for money. Victim I and Victim 2 provided detailed accounts to FBI
agents and NYPD officers of their sexual encounters with Individual I and his efforts to
prostitute them. Their accounts were corroborated by Victim l's Facebook messages with
Individual 1, which were obtained pursuant to a state search warrant of Individual l's
Facebook account. In those Facebook messages, Individual 1 discussed meeting with Victim
1 and Victim 2, engaging in sexual conduct with Victim 1, and prostituting Victim 1 and
Victim 2.
4. On March 27, 2014, Victim 2 met with an FBI agent and NYPD
detectives at the NYPD's 69th Precinct in Brooklyn, New York. During that meeting,
Victim 2 stated that a friend of hers, "Victim 3," approximately 14 years old, was introduced
to Individual I through a Facebook user named "Kimora Solange" who, as discussed below,
was later determined to be the defendant TATIANA DANIEL, age 20. Victim 2 further
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stated that she communicated with DANIEL on Facebook and that DANIEL offered Victim
2 money to work at a club. In approximately mid-March 2014, DANIEL again offered
Victim 2 money to work at a club. DANIEL told Victim 2 that she could earn $800 per night
and that the club had multiple rooms in addition to the room where the pole dancing took
place. More particularly, DANIEL told Victim 2 that she would get paid throughout the
night to have sex and to perform oral sex. DANIEL also told Victim 2 that the parties are
during the day so the girls would have to skip school in order to dance at the parties. During
this interview, Victim 2 also confirmed her Facebook usemame.
5. On March 27, 2014, Victim 1 met with an FBI agent and NYPD
detectives at the NYPD's 69th Precinct in Brooklyn, New York. During that meeting,
Victim 1 confirmed her Facebook usemame.
6. Individual 1 has indicated to law enforcement that he knows DANIEL
as "Tatiana" and that she uses the Facebook usemame "Kimora Solange." Individual 1 has
further stated that he has met DANIEL in person on multiple occasions. In addition, shortly
after his arrest, Individual 1 stated, in sum and substance, that DANIEL continues to promote
parties for a club in Brooklyn at which minor females engage in prostitution.
7. On April 24, 2014, DANIEL, using the Facebook usemame Kimora
Solange, exchanged private messages with Individual 1 via Facebook. During that
conversation, DANIEL provided her telephone number as 347-841-5725. This conversation
was monitored in real time by law enforcement with Individual 1 's consent. Records
received from Metro PCS for telephone number 347-841-5725 indicate that the subscriber
has been "Tatiana Daniels" since September 7, 2013 .
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8. On April 22, 2014, a state search warrant was issued for Victim 1 's
Facebook account. The subsequent search revealed numerous messages sent between
DANIEL and Victim 1 on Facebook.
a. On or about January 12, 2014, the following conversation took
place between Victim 1 and DANIEL on Facebook:
DANIEL: [Victim 3] told u?
Victim 1: She Didn't Tell Me The Full Thig Only Piece by Piece Can
Yhu Tell Me?
DANIEL: Y eahh
Victim 1: Yeahh What?
DANIEL: Imma explain just a sec
Victim 1: Okaee
DANIEL: light well its basically a gentlemen party something my uncle
throws 4 Times a year
DANIEL: It's a party where girls your age , .younger or older come out to
make money
DANIEL: the payers are gonna be lawyers doctors teachers or whatever
Victim 1: Okay nd when nd where is this going to ake place
DANIEL: Its like a hotel he rented out
DANIEL: Jan 20th at 9
Victim 1: nine in the morning
DANIEL: Your not the only girl im bringing like 7 otherfemales with
mw
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DANIEL: 9pm
Victim 1: yhea yhea ov course i knew that already nd 9 pm or am
DANIEL: My uncle bringing girls and stuff
DANIEL: 9Pm
DANIEL: Drinks weed and foodwill be provided
Victim 1: so do we buy our own cloths or do the provide that to?
DANIEL: just where something cute
DANIEL: Wear
Victim 1: like nice panties and bra's
DANIEL: Yeah and clothes
b. Later in the conversation, on or about January 16 and 17, 2014,
the following exchange took place between Victim 1 and DANIEL:
Victim 1: are yhu going to take me to the party or nahh
DANIEL: yeaaa 1 am
Victim 1: where do we meet at nd i am going to be dancing in my bra nd
panties
DANIEL: in whatever they ask
DANIEL: Wanna meet up tomorrow sou can get to know me?
Victim 1: where at thoee
DANIEL: My house
Victim 1: where at
DANIEL: The ville
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Victim 1: kimora i cnt come sorry i have cheerleading practice what about
friday??
DANIEL: Okay
Victim 1: alright
DANIEL: Yeooo?
Victim 1: yhea
DANIEL: cometo my house in the morning
Victim 1: tmm morning nd i wanted to know if there is any other day for
that men party!
DANIEL: nah the 20th is the only day
Victim 1: but yhu sed 4 times a year
DANIEL: yeah its maddddd far from now
DANIEL: but come to my house tomorrow you can make some money
DANIEL: 2 other girls are coming too
Victim 1: what time nd where
DANIEL: my house and like 9
Victim 1: what is the address
DANIEL: be here on time
DANIEL: [address]
DANIEL: [cross streets]
Victim 1: can i bring a friend
DANIEL: yeah u sould she gonna be with it ? cause she just cant be taking
up space no offense
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Victim 1: lmao okayy nd how am i going to be making this money
DANIEL: in many different ways
Victim 1: can yhu tell me!
DANIEL: lol , dancing , sex , anything u gonna walk away with at least
800
Victim 1: yhu dead ass
DANIEL: YEAHWHAT?
Victim 1: Ooo .. if my friend not with it to come with me i am not coming
at all
DANIEL: iight
DANIEL: shit littt tho
Victim 1: who going to be there
DANIEL: me my uncle and the girls
DANIEL: and whoever pying for whatever it is
Victim 1: Ooo ... okay?!
Victim 1: what about after school
DANIEL: what time after school ?
Victim 1: I get out ov school like a 3:50?
DANIEL: where ur school?
Victim 1: Next to Tilden
Samuel J. Tilden High School is located m Brooklyn, New York. Meyer Levin, or
Intermediate School 285, is a middle school located across the street from it.
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9. On April 22, 2014, a state search warrant was also issued for the Victim
2's Facebook account. The subsequent search revealed numerous private messages sent
between DANIEL and Victim 2 on Facebook.
a. On or about January 12, 2014, the following conversation took
place between DANIEL and Victim 2 on Facebook:
DANIEL: [Victim 3] told you?
Victim 2: Yea
DANIEL: You with it
Victim 2: Yea
Victim 2: Come meet me by Tilden high skl tomorrow at 2:45
DANIEL: thats where you go?
Victim 2: No Meyer Levin
DANIEL: Ohh iight
b. The conversation between DANIEL and Victim 2 continued on
or about January 13, 2014, when DANIEL, in sum and substance, asked Victim 2 if she has
any friends that are "interested" and "how many." Victim 2 responded, in sum and
substance, that she has one friend that's interested. DANIEL then instructed Victim 2 that
she and her friend should meet DANIEL the next day. The following exchange then took
place:
Victim 2: How many of us going
DANIEL: Tomorrow its u & your friend
DANIEL: But the day of the party is madddd girlss
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c. DANIEL continued the conversation with Victim 2 over the
next four days. Initially, on January 13, 2014, DANIEL told Victim 2 "U will make 500 +".
But, on or about January 17, 2014, DANIEL told Victim 2, regarding she and her friend,
"They gonna pay yall 800$ each."
d. On or about January 21, 2014, Victim 2 told DANIEL, "We
coming at 12: where to meet u." DANIEL instructed Victim 2, in sum and substance, to
meet at her house and then to "meet me at new lotts." DANIEL instructed Victim 2 to "Just
look decent" and "Don't flopppp." Victim 2 then sent DANIEL a photograph of herself
taken in a mirror. DANIEL responded, "Yeah thats good ; put ur hair in a bun".
10. The searches of Victim 1 's and Victim 2's Facebook accounts also
recovered private messages sent on Facebook between Victim 1 and Victim 2. On or about
January 17, 2014, the following conversation took place between Victim 1 and Victim 2:
Victim 1: inbox kimora nd tell her that yhu with it not only that yhur
going to come with me to her house
Victim 2: Ok after school
Victim 1: noo i think we gotta skip
Victim 2: No
Victim 1: w.e
Victim 1: she sed that we can make money in different ways
Victim 2: Yea
Victim 1: yhupp in her house
Victim 2: But after ski
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Victim 1: lol , dancing, sex, anything u gonna walk away with at least
800 that is just what she send to me yhu would be walking away
from a big offer
11. On June 27, 2014, a state search warrant was issued for Victim 3's
Facebook account. The subsequent search revealed numerous private messages sent between
DANIEL and Victim 3 on Facebook.
a. On or about May 15, 2014, DANIEL asked Victim 3 "wya,"
which is a common slang term meaning "where you at?" Victim 3 responded by sending a
picture that depicts Manhattan and then followed up by sending a photo of herself on a plane.
In sum and substance, Victim 3 then told DANIEL that she is only in New York for the
summer.
b. On or about June 19, 2014, DANIEL and Victim 3 had the
following conversation:
DANIEL: You tryna make money
DANIEL: Over 1000
Victim 3: When you Tryna do this
DANIEL: Tomrrow
DANIEL: It's litttt son
DANIEL: Nfs [No Funny Shit]
Victim 3: Tell me what to do
DANIEL: Regular shit
DANIEL: These neggas pay BREADDDDDS
DANIEL: Lawyers
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DANIEL: Doctors
Victim 3: What about them
DANIEL: They pay you
Victim 3: So what I do
DANIEL: What Eva u want
DANIEL: And if you got girls
DANIEL: Bring them
DANIEL: I'm telling you
DANIEL: We going to the marriott hotel
Victim 3: Wait so there no other way?
Victim 3: IfI get someone to do it I still get payed
DANIEL: Yeah but not as muchh as them
Victim 3: How much they getting payed
DANIEL: 1000+
DANIEL: Depending on what they do
DANIEL: You can come to
Victim 3: So wait you doing it to
DANIEL: Nahhhh
DANIEL: Im just getting all the girls ready
Victim 3: I need MOENY but not like that
DANIEL: My Business partner gonna pick me and the girls up and i
collecr the money
DANIEL: U Dnt gotta do shit
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DANIEL: U can do what I'm doing
Victim 3: Help out the girls together
Victim 3: I try that before but they be playing
DANIEL: I put this On my life its littt
DANIEL: I guarantee u walking out with more than 2000
DANIEL: We going to the marriott right downtown
DANIEL: All we doing is getting the girls sending them to work and we
get paid then we pay them
Victim 3: So I just try and get some girls together then
DANIEL: lght
DANIEL: We need thern for tomrrow
12. On June 27, 2014, a state search warrant was issued for the DANIEL's
Facebook account. The subsequent search revealed numerous private messages sent between
DANIEL and "Victim 4," who is 16. On or about and between January 11 and 12, 2014, the
following conversation took place between DANJEL and Victim 4 on Facebook:
DANIEL: Yeooo?
Victim 4: Yo .
DANIEL: Wassup you tryna make money? my bro [Individual 1] said you
with it
Victim 4: Facts.
DANIEL: light , its called a gentleman affair . It will be held jan 20th Its
basically like a sex party or do whatevee for money but you get
paid 200+, per person.
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Victim 4: . sex for money? I'm not doing that ..
DANIEL: My uncle is in charge
DANIEL: Nah no age limit Shit legit, sometimes u dont even gotta have
sex They might want you to dance or whatever but u getting
paid Its madddd other girls your age thats gonna be there even
older females Doctors , lawyers and maybe teachers will be
there Drinks , weed and food will be there
Victim 4: Aight .. where this place at
DANIEL: Its a lowkey place if u wanna meet tomorrow like the other
girls we can
Victim 4: Aight
DANIEL: My uncle will explain everything
Victim 4: Okay
DANIEL: Wassup?
DANIEL: And don't think im lining you or anything its easy money imma
be there also that' s why i want you to meet me before the party
Based on a Facebook conversation between DANIEL and the defendant BRIAN ADAMS
discussed further below, the individual DANIEL refers to as her "uncle" in her Facebook
conversations with Victim 1 and Victim 4 appears to be the defendant ADAMS.
II. SHANDALE FRANKLIN AND BRIAN ADAMS
13. The search of DANIEL's Facebook account also recovered private
numerous messages between DANIEL and the Facebook username "Shandale Rebelious
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Franklin," who, as discussed further below, was later determined to be the defendant
SHANDALE FRANKLIN.
a. On or about and between January 11 and 19, 2014, the
following conversation took place between DANIEL and FRANKLIN on Facebook:
DANIEL: This is the one girl, shes good?
[DANIEL sends FRANKLIN one photograph containing
three different images of what appears to be a minor
female, who has not yet been identified by law
enforcement. This photograph is attached as Exhibit 1.]
FRANKLIN: Yeah
DANIEL: Okay shes with it
FRANKLIN: Okays cool
DANIEL: Imma get like 3 more
FRANKLIN: Okay cool an ill meet with of them
DANIEL: Tomorrow good?
FRANKLIN: Yups
DANIEL: She good?
[DANIEL sends FRANKLIN one photograph containing
two images of Victim 4. This photograph is attached as
Exhibit 2.]
FRANKLIN: Yeah shes good too
DANIEL: light
DANIEL: Y all got something fot tonight
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FRANKLIN: Wat u mean a gurl to work
DANIEL: Man
FRANKLIN: U lost me
DANIEL: Nvm lol
FRANKLIN: No i don't got no man for the nite amma heading to work
i was asking if had someone that wannted to make cash
thats y i that
DANIEL: Yeaaa a girl
FRANKLIN: Oh okays I didnt book nothing for tonight causs am not
gonna be there ill can try . . . but of not tomorrow
DANIEL: Ok
FRANKLIN: K I'll let u knw
FRANKLIN: Send me a image of the gurl who wanted to work
FRANKLIN: Tonight
DANIEL: light hold on
FRANKLIN: Ok
DANIEL: They said tomorroe
FRANKLIN: Ok
DANIEL: What time the party starts ?
FRANKLIN: The party is on the 20 nit start @9
DANIEL: light i got like 6 girls so far
FRANKLIN: Okays cool thats wats up
DANIEL: Imma get one today whats ur husband fb
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FRANKLIN: Bryan adams
DANIEL: I cant find him lol
FRANKLIN: Look on my page
DANIEL: Tell him check his inbox
DANIEL: I got 2 customers tomorrow & 1 tonight
FRANKLIN: Okays
DANIEL: I have a girl at the house
FRANKLIN: I knw I saw here
FRANKLIN: Her
DANIEL: Iighy
DANIEL: lighy
DANIEL: Kaylaaa
FRANKLIN: Kimoraaaa
DANIEL: Yeahhh
FRANKLIN: Nothing wyd i just saw ur text that saif kayla
FRANKLIN: Said
DANIEL: yeahhh lol , i was writing you for that girl
FRANKLIN: Ohhhh okays
DANIEL: yeah 2 of the girls said they gonna be at my house by 4
pm
FRANKLIN: Okays cool no problem ill be over there tomorrow
DANIEL: iight
FRANKLIN: B said hit me wen that girl get here
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DANIEL: iight im waiti'fig on them
FRANKLIN: Okays
FRANKLIN: Did they show up
FRANKLIN: He said
FRANKLIN: Kimora call me 347314 7089 call me now
According to immigration records related to the defendant FRANKLIN, she used the middle
name "Kayla" on her 2002 application for a B2 visa.
b. On or about January 20, 2014, the following conversation took
place between DANIEL and FRANKLIN on Facebook:
DANIEL: Heyyy
FRANKLIN: Wats up
DANIEL: Wasssup the party not today?
FRANKLIN: He said it not enough gurls an he knw how the rest of the
gurls look in person so he doing it the end of this month
so everything is alk together with no mishaps
DANIEL: Ohhhhokk
DANIEL: Ppl wanna just work
FRANKLIN: They can work too but if the huge no body gonna take
em thats y I have to meet with them in the person
DANIEL: okay how much i get from them?
FRANKLIN: The price starts 60 n up depends on how much they do u
get half cause u gave them work
DANIEL: Okay so the other half goes to you
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FRANKLIN: No it goes to them ..
DANIEL: The girls?
DANIEL: The one from last time
FRANKLIN: Yups
DANIEL: She really wanna come
FRANKLIN: The one from last time she kinda big so am trying to find
a client that like gurls her size
FRANKLIN: She can come. I just gotta find ppl for her but she can
dance
DANIEL: Ohhh ok
DANIEL: Cause i need money today lol
FRANKLIN: Am still working on her
DANIEL: light
FRANKLIN: Let u knw ... an the break down
DANIEL: Okay
c. On or about and between January 21 and 24, 2014, the
following conversation took place between DANIEL and FRANKLIN on Facebook:
· DANIEL: Kayla i got 2 girls corning to you today
FRANKLIN: Wat time
DANIEL: 12
FRANKLIN: Okays text u when i come back from the doctors
DANIEL: Alrightt
FRANKLIN: Kk
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FRANKLIN: just got back from the er am gonna have to reschedule
with them two do u have pies of them
DANIEL: Kayla?
FRANKLIN: Hey wats up
DANIEL: You guys looking for me?
FRANKLIN: Yea yesterday. I had a client but i had one of the other.
Girls go do the call
DANIEL: Y all let me kno last min
FRANKLIN: It was bryan ... he was just hanging out and he thought u
was at t so he took the guy down there
DANIEL: No i dnt stay in 24/7 lol
FRANKLIN: Oh okays srry next time one come up ill hit cause i didnt
even knw he was coming
DANIEL: light thanks
FRANKLIN: no problem anytime
DANIEL: Ifu have any today tell me
FRANKLIN: okays i will
d. On or about and between February 24 and 25, 2014, the
following conversation took place between DANIEL and FRANKLIN on Facebook:
FRANKLIN: Kimora I need a couple of gurls I have a client he just
came from London and need two to 3 gurls to choose
from hit me back with pies
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DANIEL: Alright
DANIEL: Ill see what i can do
FRANKLIN: Okay thanks
DANIEL: I got 2
FRANKLIN: U got pies
FRANKLIN: Amma be over there Friday .... wat happen to the pies
DANIEL: The girls dnt wanna do it
DANIEL: I wont be here friday going by ceecee school
FRANKLIN: . Ok. .. u huv anyone else
DANIEL: Not now
FRANKLIN: Okays let me knw if u find anything n can u get in
contact with that gurl that had came by the house tell her
to write me on fb i have something for her
DANIEL: Alright.
FRANKLIN: Thnks
DANIEL: Welcome
14. The search of DANIEL's Facebook account also recovered numerous
private messages between DANIEL and the Facebook usemame "Bryan Adams," who, as
discussed further below, was later determined to be the defendant BRIAN ADAMS.
a. On or about and between January 12 and 13, 2014, the
following conversation took place between DANIEL and ADAMS on Facebook:
DANIEL: Heyyy
ADAMS: Yooo
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DANIEL: Yeaaa
ADAMS: So u have something???????
DANIEL: Y eaaa , i got about 7 girls tryna get more
DANIEL: 2 Of them wanna meet up tomorrow and work
DANIEL: ["Victim 5"]; Age 17
[DANIEL sends ADAMS one photograph containing
three images of Victim 5, a female who has yet to be
identified by law enforcement, but appears to be a
minor based on her photographs on Facebook.
According to Victim 2, who is friends with Victim 5,
Victim 5 was approximately 15 years old at the time this
photograph was sent. This photograph is attached as
Exhibit 3.]
DANIEL: [Victim 2] 17
[DANIELS sends ADAMS a photograph of Victim 2.
This photograph is attached as Exhibit 4.]
DANIEL: Those 2 wanna work tomorrow & the party
ADAMS: [Victim 2] only the other one to big
ADAMS: Where we me your place or mine???
DANIEL: It dont matter
DANIEL: [Victim 1] same size as [Victim 2]
[DANIEL sends ADAMS a close up photograph of
Victim 1 ' s face. DANIEL then sends ADAMS the same
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image that DANIEL sent to FRANKLIN, which is
attached as Exhibit 1. These photographs are
attached as Exhibit 5.]
DANIEL: I have 2 more girls & i should have more tomorrow
ADAMS: I Willie home at 11 am being [Victim 1] too I will be by u
at 12 noon in the morning the to girls will be working
come 3 pm
DANIEL: They got school & [Victim 1] only wanna do the party
the first 2 girls the only ones that wanna wrk
ADAMS: OK so tomorrow I will message u and come over have
the girl meet u at your house in the morning [Victim 2]
ADAMS: The other we will let do the party
ADAMS: Remember sneakers & jeans no costumes
ADAMS: Send a friends request form your page
DANIEL: They said after school
ADAMS: What time
DANIEL: One of them get out at 145 other .245
ADAMS: OK hit me when one gets there
DANIEL: light
DANIEL: Be on fb
ADAMS: Ok
DANIEL: Only the [Victim 5] girl wanna come
DANIEL: She here
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DANIEL: Wya ·
ADAMS: Come to me
DANIEL: I can't come I'm sending her
ADAMS: Ok
DANIEL: She walking to the 15 now
ADAMS: Ok
DANIEL: She's not big
DANIEL: lol
ADAMS: OK ha ha
DANIEL: Lol she coming now
ADAMS: Ok
DANIEL: Like in 5 mins she gonna be there
DANIEL: She on van siclen
ADAMS: Ok
DANIEL: She there
DANIEL: She next to the sneaker store
DANIEL: I told her ur my uncle
ADAMS: Ok
DANIEL: She wearing a blue adidas jacket
ADAMS: How long?????
DANIEL: She said tomorrow her and her friend gonna come
DANIEL: She just told me
ADAMS: Ok 24 CaseCase 1:14-cr-00650-JBW 1:14-mj-00991-JO DocumentDocument 58-419 Filed Filed 12/11/14 07/30/15 Page Page 25 25 of of 59 59 PageID PageID #: #: 105 337
DANIEL: Yeaa , that girl good?
ADAMS: She good for the party. But she kinda Big Kayla gonna
start her
DANIEL: light , she working today? cause i need to pay my bill lol
DANIEL: And buy some soap etc for the house
ADAMS: Kayla is make calls now ... to see by tonite
ADAMS: If they take we pay ....
DANIEL: light
15. On October 24, 2014, a state search warrant was issued for
FRANKLIN's Facebook account. The subsequent search revealed numerous private
messages sent between FRANKLIN and the Facebook account for "Individual 2."
a. On or about and between January 11 and 12, 2014, the
following conversation took place between FRANKLIN and Individual 2 on Facebook:
FRANKLIN: Syd am having a five season party and i need niggas that
got money anything goes type of party but they better got
cash
FRANKLIN: No bullshyters
Individual 2: Ok I know a few when and where
Individual 2: btw did Bryan talk to mommy about the car
FRANKLIN: The 20th still picking the spot most likely monroe cause
I have rooms or how much that guy want for that club I
went with u to .... yea I did she gotta calk her landlord
Individual 2: I thought it was her car but ok do it on Monroe
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DMV records show that the address 349 Monroe Street, Brooklyn, New York 11221
("Monroe Address") is associated with the defendant ADAMS's New York state
identification. Con Edison records show that from September 2006 to the present there was a
shared account for the Monroe Address with "Brian Adams" and another individual. A
review of information received from the New York Administration of Children Services
("ACS") indicates that the defendants FRANKLIN and ADAMS previously resided together
at the Monroe Address.
b. On or about and between February 22, 2014, the following
conversation took place between FRANKLIN and Individual 2 on Facebook:
Individual 2: Cuzo can you have Bryan call me
FRANKLIN: Okay ill tell him
Individual 2: light
Individual 2: I really wanna hurt sumone
FRANKLIN: Ywathappen
Individual 2: A lot I wanna get a nigga and 2bitchs
FRANKLIN: Wat they did to y dnt u walk around the comer
Individual 2: I don't live ova there I moved 8months ago
Individual 2: Niggas tryed to line me
FRANKLIN: Oh okays .... , about wat ....
Individual 2: Molly's and my stripper bitch
FRANKLIN: Oh wow smfh over ur shyt
Individual 2: I need a clip for a Luger 9mm
Individual 2: Niggas came to my job last night 26 CaseCase 1:14-cr-00650-JBW 1:14-mj-00991-JO DocumentDocument 58-419 Filed Filed 12/11/14 07/30/15 Page Page 27 27 of of 59 59 PageID PageID #: #: 107 339
FRANKLIN: Amma call b an c if he can get his hands on one for u
..... smfh for wat
FRANKLIN: Niggga bugs
Individual 2: Imma get dis nigga and his bitch
FRANKLIN: I called he saidd he dnt have one of those
Individual 2: I got the joint I just need the clip
FRANKLIN: I knw he dnt have the clip for it
Individual 2: Damnok
On June 8, 2012, ADAMS was arrested for possessing a large capacity ammunition feeding
device (rifle magazine), which was loaded with twenty-one rounds of .223 caliber
ammunition. He was charged with violating New York Penal Law 265.02(8) (criminal
possession of a weapon in the third degree - ammunition feeding device). On July 25, 2012,
he pleaded guilty to disorderly conduct in violation ofN.Y Penal Law 240.20.
c. The search of FRANKLIN's Facebook account also revealed
numerous private messages sent between FRANKLIN and the Facebook account of "Victim
6," a female who has yet to be identified by law enforcement, but who appears based on her
photographs on Facebook to be a minor. On or about and between January 11 and 18, 2014,
the following conversation took place between FRANKLIN and Victim 6 on Facebook:
FRANKLIN: Hey can u meet with me on Wednesday
Victim 6: Hey ,sure wya
FRANKLIN: Am in east ny the last stop on the 3 train new lots an
hegamen
Victim 6: Oh ok cool , its about dancing rite ?
27 CaseCase 1:14-cr-00650-JBW 1:14-mj-00991-JO DocumentDocument 58-419 Filed Filed 12/11/14 07/30/15 Page Page 28 28 of of 59 59 PageID PageID #: #: 108 340
FRANKLIN: Yea am throwing. A party n i need dancer sp am gonna
try u out an c how u do
Victim 6: Canu call me
FRANKLIN: Wat happen to u meeting me
Victim 6: Oh shit i totally forgot :(
FRANKLIN: I figure wen can we meet
Victim 6: Tomar afterschool
FRANKLIN: Time
FRANKLIN: Wat time
Victim 6: 2 45
FRANKLIN: That's great
Victim 6: But i dnt think ima dance tomar night
FRANKLIN: U dont have to dance its just some things i gotta go over
with u on wat u need and stuff ... wat about ur sister
Victim 6: Hey wyd
FRANKLIN: Nothing with my daughter wats going on wat happen
today
Victim 6: Alot
FRANKLIN: Like wanna talk about it
Victim 6: Yea a lil
FRANKLIN: Okays so talk to me wat going on
Victim 6: Life,
FRANKLIN: Wat abour it wats on ur mind
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Victim 6: Im almost done school , i have no job & i wanna dance
but im nervous
FRANKLIN: Danceing is gonna make u some money but a not a lot of
money danceing is easy Espically wineing ... an wat u
wanna do after school besides dancing
Victim 6: College
FRANKLIN: Okays thats good wat collage u plan on going to
Victim 6: Idk yet
FRANKLIN: Okays ..just thats bothering u
Victim 6: Yea
FRANKLIN: U sure
Victim 6: Yea
FRANKLIN: Okays hun
Victim 6: Yea u still going ya arty ?
FRANKLIN: Yeah at the end of this month wen i finalize it ill inbox u
with everything
Victim 6: okboo
d. The search of FRANKLIN's Facebook account also revealed
numerous private messages sent between FRANKLIN and the Facebook account of
"Individual 3," a female who has yet to be identified by law enforcement, but who appears
based on her photographs on Facebook to be an adult. On or about and between January 11,
2014, the following conversation took place between FRANKLIN and Individual 3 on
Facebook:
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FRANKLIN: Baby mama bryan need u to dance for his five season
party hes throwing n he said no excuses
Individual 3: no problem i have period though
Individual 3: and when
FRANKLIN: The 20th
16. On October 24, 2014, a state search warrant was issued for the
defendant ADAM's Facebook account. The subsequent search revealed hundreds of images
of child erotica, which depict clothed or partially-clothed females aged approximately six to
fourteen years old in erotic positions.
17. On June 21, 2014, the defendant FRANKLIN received numerous
messages on Face book wishing her happy birthday. A review of information received from
ACS indicates that the defendant FRANKLIN's date of birth is June 21, 1990. The
defendant FRANKLIN' s 2002 application for a B2 visa also states that her date of birth is
that date.
18. On January 27, 2014, the defendant ADAMS received numerous
messages on Face book wishing him happy birthday. A review of information received from
ACS indicates that the defendant's date of birth is January 27, 1980. A review of NYPD
records also shows that date listed as the defendant ADAMS's birthday on his New York
state identification.
19. A review of records received from Facebook show that the telephone
number 347-653-0125 ("Telephone Number 1") was associated with the defendant
FRANKLIN's Facebook account as of December 19, 2013 . .· A review of NYPD records
shows that the defendant ADAMS provided Telephone Number 1 as his telephone number
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on June 17, 2013, when he filed a domestic violence complaint against another individual. A
review of NYPD records also shows that Telephone Number 1 is associated with the
defendant ADAMS's New York State identification. A review of records received from
T-Mobile shows that the subscriber for Telephone Number 1 from July 31, 2011 to
December 9, 2012 was "Shandale Franklin." The date of birth for Shandale Franklin is listed
as June 21, 1990, which is the defendant FRANKLIN' s date of birth. A review of records
received from Sprint show that the subscriber for Telephone Number 1, which is a "Sprint
Boost Mobile" number, from December 26, 2012 to September 25, 2013 was "Shandale
Boost" and the subscriber address was P.O. Box 54988, Irvine, CA 92618.
20. A review of photographs currently posted to the defendant ADAMS's
publicly-available Facebook profile, including his "profile" photograph, shows several
photographs of a man in his early 30s with dreadlocks. (A screenshot of one of these
photographs is attached hereto as Exhibit 6). I have compared these photographs to the
defendant ADAMS's DMV photograph, and they appear to be the same person. (A copy of
the defendant's DMV photograph is attached hereto as Exhibit 7.)
21. ADAMS is seen in several of the photographs posted to his publicly-
available Facebook profile with a woman. (A screenshot of one photograph containing
multiple images is attached hereto as Exhibit 8.) I have compared photographs of this
woman to photographs currently posted on the defendant FRANKLIN's publicly-available
Facebook profile, including her "profile" photograph, and they appear to be the same person.
(A screenshot of one of these photographs is attached hereto as Exhibit 9.)
22. A review of information received from ACS indicates that FRANKLIN
and ADAMS have a female child in common ("Child 1"), who is approximately eighteen
31 - -- I CaseCase 1:14-cr-00650-JBW 1:14-mj-00991-JO DocumentDocument 58-419 Filed Filed 12/11/14 07/30/15 Page Page 32 32 of of 59 59 PageID PageID #: #: 112 344
months old. Based on my review of publicly-available information and images posted to
ADAMS's and FRANKLIN's Facebook profiles, as well as the messages recovered during
the search of their Facebook accounts, ADAMS and FRANKLIN also appear to have a male
child in common ("Child 2"), who is less than one year old.
23. ADAMS and FRANKLIN are seen together with the children in several
photographs posted to their publicly-available Facebook profiles, including photographs in
which they are holding a baby together. See Ex. 8. One photograph posted to FRANKLIN's
account contains separate images of each child. (A screenshot of this photograph is attached
hereto as Exhibit 10.) The name of Child 1 is written across the bottom of one of the images.
The name of Child 2 is written across the other image.
24. A review of the defendant FRANKLIN'S change of address form
received from the United States Postal Service, which is dated October 14, 2014, shows that
ADAMS, FRANKLIN, Child 1, and Child 2 currently reside together at 1250 East 95th
Street, Apt. #1, Brooklyn, New York ("95th Street Address"). (A photocopy of the change of
address form is attached hereto ax Exhibit 11.)
25. A review of records received from Con Edison shows that "Brian
Adams" has a shared account for the 95th Street Address with another individual. The
account for the 95th Street Address has been active since October 2014.
26. A review of NYPD records shows that, on October 25, 2014,
"Victim 7 ," who is the defendant ADAM'_s sixteen-year-old half-sister, filed a police report
related to an incident that occurred on July 4, 2014. At the time of the report, Victim 7 stated
that she resided with ADAMS at the Brooklyn Address. The police report indicates that, on
July 4, 2014, ADAMS punched Victim 7 in the face and broke her jaw while they were at a
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family barbeque. Victim 7 reported ADAMS's Facebook username as "Bryan Adams."
The report contains the following statement from Victim 7: "Bryan adams has also been sex
trafficing under age girl and i feel discusted everyday living in the same house with such
history and going back to live there will put me back where I was at with thoughts of killing
people alone my self."
27. On November 20, 2014, based on the complaint of Victim 7, the NYPD
arrested ADAMS and charged him with violating New York Penal Law§ 120.05 (assault in
the second degree). ·ADAMS is currently in state custody.
28. Based on the foregoing evidence, I submit that there is probable cause
to believe that the defendants TATIANA DANIEL, SHANDALE FRANKLIN, and BRIAN
ADAMS have willfully and knowingly conspired and attempted to recruit, entice, harbor,
transport, provide, obtain and maintain by any means one or more persons, knowing and in
reckless disregard of the fact that the person had not attained the age of 18 years and would
be caused to engage in a commercial sex act. In particular, the foregoing Facebook chats
between DANIEL, Victim 1, Victim 2, Victim 3, and Victim 4 show, among other things,
that DANIEL knowingly recruited minor females to attend a "sex party" in January 2014.
Indeed, these chats show that DANIEL was aware that Victim 1 and Victim 2 attended the
middle school Meyer Levin and thus were minor females. The foregoing Facebook chats
between DANIEL, FRANKLIN, and ADAMS show that DANIEL recruited the minor
females for the "sex party" on behalf of FRANKLIN and ADAMS, who agreed to pay
DANIEL a portion of the money that the minor females received for performing sexual acts
with adult males at the "sex party.'' These chats also show that DANIEL sent FRANKLIN
photographs of Victim 4 and what appears to be another minor female to show her who she
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had recruited to work at the party. These chats further show that DANIEL sent photographs
of Victim 1, Victim 2, and Victim 5 to ADAMS to show him who she had recruited for the
party, and she identified each girl as a minor female. The chats between FRANKLIN and
Individual 2 show that FRANKLIN recruited clients for the sex party, while the chats
between FRANKLIN and Victim 6 also show that she recruited an individual who appears to
be a minor female for the sex party.
WHEREFORE, your deponent respectfully requests that arrest warrants be
issued for the defendants TATIANA DANIEL, also known as "Kimora" and "Kimora
Solange," SHANDALE FRANKLIN, also known as ''Shandale Rebelious Franklin" and
"Shandale Kayla Franklin," and BRIAN ADAMS, also known as "Bryan Adams," so that
they may be dealt with according to law.
34 I . CaseCase 1:14-cr-00650-JBW 1:14-mj-00991-JO DocumentDocument 58-419 Filed Filed 12/11/14 07/30/15 Page Page 35 35 of of 59 59 PageID PageID #: #: 115 347
I further request that the Court order that this application, including the
affidavit and arrest warrant, be sealed until further order of the Court. These documents
discuss an ongoing criminal investigation. Disclosure of this application and these orders
would seriously jeopardize the ongoing investigation, as such disclosure would give the
targets of the investigation an opportunity to destroy evidence, harm or threaten victims or
other witnesses, change patterns of behavior, notify confederates, and flee from or evade
prosecution. Additionally, I request that Exhibits 1-5, which are photographs of the minor
victims, be sealed pursuant to 18 U.S.C. § 3509(d)(2) (requiring that information related to
minor victims be filed under seal).
st~ Special Agent Federal Bureau of Investigation
Sworn to before me this 21st day of November, 2014 0:Jk- THE HONORABLE JAMES ORENSTEIN UNITED STATES MAGISTRATE WDGE EASTERN DISTRICT OF NEW YORK
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