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Case 1:14-Mj-00991-JO Document 19 Filed 12/11/14 Page 1 of 59 Pageid CaseCase 1:14-cr-00650-JBW 1:14-mj-00991-JO Document Document 58-4 19 Filed Filed 12/11/14 07/30/15 Page Page 1 1 of of 59 59 PageID PageID #: #: 81 313 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 1 - - I CaseCase 1:14-cr-00650-JBW 1:14-mj-00991-JO Document Document 58-4 19 Filed Filed 12/11/14 07/30/15 Page Page 2 2 of of 59 59 PageID PageID #: #: 82 314 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 2 CaseCase 1:14-cr-00650-JBW 1:14-mj-00991-JO Document Document 58-4 19 Filed Filed 12/11/14 07/30/15 Page Page 3 3 of of 59 59 PageID PageID #: #: 83 315 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 3 CaseCase 1:14-cr-00650-JBW 1:14-mj-00991-JO Document Document 58-4 19 Filed Filed 12/11/14 07/30/15 Page Page 4 4 of of 59 59 PageID PageID #: #: 84 316 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 . 4 - l _ [ CaseCase 1:14-cr-00650-JBW 1:14-mj-00991-JO Document Document 58-4 19 Filed Filed 12/11/14 07/30/15 Page Page 5 5 of of 59 59 PageID PageID #: #: 85 317 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 5 CaseCase 1:14-cr-00650-JBW 1:14-mj-00991-JO Document Document 58-4 19 Filed Filed 12/11/14 07/30/15 Page Page 6 6 of of 59 59 PageID PageID #: #: 86 318 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 6 .I CaseCase 1:14-cr-00650-JBW 1:14-mj-00991-JO Document Document 58-4 19 Filed Filed 12/11/14 07/30/15 Page Page 7 7 of of 59 59 PageID PageID #: #: 87 319 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:
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