FILED SEALED OCT 10 2019 CLERK US DISTRICICOURT SOUTHERN DISTRICTOF CALIFORNIA BY DEPUTY UNITED STATES DISTRICT COURT SOUTHERN DISTRICTOF CALIFORNIA UNITED STATES OF AMERICA Case No.: 1 Plaintiff COMPLAINTFOR VIOLATION OF: Title 18, . S. C ., Section 1591( a ) and (b)(1) MICHAEL JAMES PRATT ( 1) Sex Trafficking by Force, Fraud, or MATTHEW ISAACWOLFE ( 2 ), Coercion ; Title 18, U . S. C . , Section 1594 ( ) RUBEN ANDREGARCIA (3) , Conspiracy to Commit Sex Trafficking by VALORIE MOSER ( 4 ), Force , Fraud , or Coercion ; and Title 18 , U . S . C ., Section 1594( d ) Criminal Defendants. Forfeiture The undersigned Complainant, being duly sworn , states: Count 1 (18 U .S . C . ) In or aboutMay 2015 , within the Southern District of California and elsewhere, defendants MICHAEL JAMES PRATT,MATTHEW WOLFE, and RUBEN ANDRE GARCIA , in and affecting interstate commerce, knowingly did recruit, entice, harbor, transport , provide, obtain, advertise,maintain, patronize, and solicit, by any means a person, to wit, Adult Female 1( AF 1”), knowing and in reckless disregard ofthe fact Complaint 1 means of force , threats of force, fraud, coercion, and any combination of such means, willbe usedto cause the person to engage in a commercial sex act; in violation || Title 18 United States Code, Section 1591 a ) and(b)( 1). Count 2 (18 U . S . C . 1591) or about October 2013, within the Southern District of California and 7 elsewhere, defendants MICHAEL JAMES PRATT, MATTHEW WOLFE, and RUBEN ANDRE GARCIA , in and affecting interstate commerce, knowingly did recruit, entice, harbor, transport, provide, obtain , advertise, maintain , patronize, and solicit by any means a person, to wit, Adult Female 2 (“ AF-2 ,knowingand in reckless disregard of the fact thatmeans of force, threats of force, fraud, coercion, and any combination of such means,will be used to cause the person to engage in a commercial act in violation of Title 18, United States Code, Section 1591(a ) and (b)(1). Count 3 (18 U .S .C . 1591) In or about and between January 2015 and February 2015, within the Southern District of California and elsewhere , defendants MICHAEL JAMES PRATT, MATTHEW WOLFE , and RUBEN ANDRE GARCIA , in and affecting interstate commerce , knowingly did recruit, entice, harbor, transport,provide obtain , advertise, maintain , patronize, and solicit by any means a person , to wit Adult Female 3 ( 2 knowing and in reckless disregard of the fact thatmeans of force , threats of force , fraud, coercion , and any combination of such means, will be used to cause the person to engagein a commercialsex act; in violation of Title 18 United States Code, Section 241591a) and (b)(1). Complaint Count 4 (18 U . S .C . ) Beginning on an unknown date,but no later than approximately October 2013 , 4 | and continuing through the present, within the Southern District of California and 5 elsewhere , defendants MICHAEL JAMES PRATT,MATTHEW WOLFE , RUBEN 6 GARCIA , and VALORIE MOSER , did combine, conspire, and agree with 7 other to, in and affecting interstate commerce, knowingly recruit, entice , harbor, 8 transport, provide , obtain , advertise ,maintain, patronize , and solicit by any means a 9 to wit , AF -1, AF -2,AF-3, Adult Female 4 ( -4 ”),and Adult Female 5 (“AF 105 knowing and in reckless disregard of the fact thatmeans of force ,threats of force, 11 fraud, coercion , and any combination of such means,will be used to cause these persons engage in a commercial sex act, in violation ofTitle 18 United States Code, Section 1591(a )and (b )(1). All in violation of Title 18 United States Code, Section 1594(c ). FORFEITURE ALLEGATIONS . The allegationscontained in Counts 1through 4 above arereallegedherein 17 incorporated as a part hereof for purposes of seeking forfeiture of property of 18 defendants MICHAEL JAMES PRATT, MATTHEW WOLFE, RUBEN ANDRE 19 GARCIA, and VALORIE MOSER to the United States pursuantto Title 18 United States Code, Sections 1594(d) and (e). 21 Upon conviction of the offenses in Counts 1 through 4 , which involve violations Title 18 United States Code, Sections 1591 and 1594, defendants 23 | MICHAEL JAMES PRATT, MATTHEW WOLFE, RUBEN ANDRE GARCIA, and VALORIE MOSER shall forfeit, pursuant to Title 18 United States Code, Section 1594(d ) and (e), allright, title, and interest in ( 1) any property, real or personal,used or intended to be used to commit or to facilitate the commission of the offense ; (2 ) any 27 property , realor personal, constituting or derived from , any proceeds obtained , directly 28 Complaint 1 or indirectly, as a resultof theoffense. The property to be forfeited includes, but is not limited to, (a) any personal property that was used or intended to be used to commit or 3 | facilitate the commission of the offense; and (b ) any property, real or personal, 4 constituting or derived from proceeds obtained directly or indirectly as a result of such 5 . any of the property described above , as a result of any act or omission 7 of defendants MICHAEL JAMES PRATT,MATTHEW WOLFE , RUBEN ANDRE 8 GARCIA , and VALORIE MOSER, cannot be located upon the exercise of due diligence; has been transferred or sold to, or deposited with, a third party; has been placed beyond the jurisdiction ofthe court; has been substantially diminished in value; or has been commingled with other property which cannot be divided without difficulty , the United States shallbe entitled to forfeiture of substitute property up to the value of 13 property described above, pursuant to Title 18 United States Code, Section 1594 (d ) || (e) This complaint is based on the attached Statement of Facts incorporated herein 17 by reference . Ilana Sabata SpecialAgent Federal Bureau of Investigation Sworn to me and subscribed in my presence this of October 2019 . HONJLINDA LOPEZ U . S. Magistrate Judge Complaint AFFIDAVIT 2 Lana K . Sabata, being duly sworn , states: I am a special agent with the Federal Bureau of Investigation (FBI) and have been so employed since May 2008 . In October 2008, the FBIassigned meto the 5 Violent Crime and Major Offender Program in Northwest Indiana. Duties under this 6 program focus on federal violent crime investigations including kidnapping , extortion , 7 | interstate transportation of stolen property , bank robberies , criminal gang activity and 8 drug trafficking . Additionally , I was assigned as the Crimes Against Children (CAC ) coordinator and worked child -related violations that included parental kidnapping, enticement, prostitution and child pornography. In January 2013, I transferred to the FBI's San Diego Division . I currently work on investigating crimes involving child 12 | exploitation and human trafficking. Prior to my employment with the FBI,Iwas a local 13 enforcement officer in Lincoln , Nebraska for approximately seven years , with 14 experience in general investigations , as well as an undercover narcotics investigator . I 15 served in the United States Armed Forces, Air National Guard , Security Forces. 16 This training and experience , together with my consultation and experience working 17 colleagues , task force officers and subject matter experts, form the basis for the 18 opinions I express below . Statementof Probable Cause A Overview of the Conspiracy 2. From at least 2013 through and including the present, defendants 22 ||MICHAEL JAMES PRATT, MATTHEW WOLFE , RUBEN ANDRE GARCIA , and VALORIE MOSER , and others participated in a conspiracy to recruit young adult women to engage in commercial sex acts by fraud and coercion. Via the internet, members ofthe conspiracy recruited young women from around thecountry who were || interested in modeling. Once the young women responded to online ads posted by the conspiracy , conspirators would advise the women that the jobs were in fact for 28 Complaint 1 pornographic videos, notmodeling gigs, and participants, or“ models,” would receive approximately $ 3 ,000 to $ 5 ,000 for a one- day video shoot. When presented with this 3 revised offer, many of the women initially refused , often for fear that the videos would 4 be published on the internet and damage their personal, educational and/or professional || lives in various ways. 3 convince women to appear in the adult videos, members of the 7 conspiracy assured the women that the videos would not be posted on the internet and 8 would only be distributed outside the United States on DVD or to supposed private 9 | collectors overseas. Members ofthe conspiracy assured the women that their friends 10 and families would never learn that the women had appeared in the videos. To help 11 convince them , PRATT paid other young women working at his direction, including 12 | MOSER, to act as references or provide false assurances to the women that, if they 13 filmed a video, the video would not be posted online. 4 . Ifa woman agreed to make a video ,members of the conspiracy paid to fly 15 the woman to San Diego. MOSER sduties included driving these women to and from 16 the airport and San Diego -area hotels. GARCIA met with thewomen at the hotel along 17 with a videographer. WOLFE initially served as the conspiracy ' s videographer , before Uncharged Co -Conspirator # 1(UCC-1) took on that role. When questioned in-person , 19 GARCIA, MOSER , WOLFE, and UCC- 1falsely assured thewomen theirvideoswould 20 be posted on the internet. GARCIA , whose job duties included having sex with the women on camera, frequently offered the young women marijuana or alcohol in the 22 hotel room before presenting them with a document that he and the videographer 23 refused to let the young women keep . After presenting the women with thedocument, to shooting the videos , at least some of the women signed a “Model/ Release” which stated that the producer of the video , identified as Clockwork Productions Inc. on behalf of BLL Media Inc., could use and/ or publish the video for any purposes whatsoever . The release does not reference internet publication and there is no reference to girlsdoporn .com , pornhub .com or any other website .