AO 91

(Rev. 11/11) Criminal Complaint

AUSA Sarah Streicker 312 353-1415

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

RECEIVED
NOV O1 2016

UNITED STATES OF AMERICA
CASE NUMBER:
UNDER SEAL

v.

THOMAS G. BRUTON
CLERK, U.S. DISTRICT COURT

WILLIAM WHITLEY,
also known as "Will" and "Willie"

CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best of my knowledge
and belief:

COUNT ONE
From on or about June 1, 2015 to on or about September 17, 2015, at Chicago, in the
Northern District of Illinois, Eastern Division, and elsewhere, the defendant violated:
Code Section

Offense Description

Title 18, United States Code, Section
· 159l(a)

in and affecting interstate commerce, did
knowingly patronize, solicit, recruit, entice,
harbor, transport, provide, obtain, and maintain
by any means a person, namely, Minor A,
knowing and in reckless disregard of the fact that
Minor A had not attained the age of 18 years and
would be caused to engage in a commercial sex
act.

COUNTTWO
In or about July 2015, at Chicago, in the Northern District of Illinois, Eastern Division, and
elsewhere, the defendant violated:
Code Section

Offense Description

Title 18, United States Code, Section
2251(a)

did knowingly use, persuade, induce, and entice a
minor, namely, Minor A, to engage in sexually
explicit conduct, namely, lascivious exhibition of
Minor A's genitals, for the purpose of producing a
visual depiction of such conduct, which visual
depiction defendant knew and had reason to
know would be transported and transmitted
using a means and facility of interstate commerce

 and in and affecting interstate commerce, and
which visual depiction was actually transported
and transmitted using a ·means and facility of
interstate commerce and in and affecting
interstate commerce.

This criminal complaint is based upon these facts:

_x_ Continued on the attached sheet.
HELENDUNN
Special Agent, Federal Bureau of Investigation
(FBI)
Sworn to before me and signed in my presence.
Date: November 1 2016

City and state: Chicago, Illinois

MARIA VALDEZ, U.S. Magistrate Judge
Printed name and Title

 UNITED STATES DISTRICT COURT
ss
NORTHERN DISTRICT OF ILLINOIS

AFFIDAVIT
I, HELEN DUNN, being duly sworn, state as follows:
1.

I am a Special Agent with the Federal Bureau of Investigation, and have

been so employed for 14 years. My current responsibilities include the investigation
of sex trafficking crimes and crimes against children.
2.

This affidavit is submitted in support of a criminal complaint alleging

that WILLIAM WHITLEY, also known as "Will" and "Willie," has violated Title 18,
United States Code, Sections 159l(a) and 2251(a). Because this affidavit is being
submitted for the limited purpose of establishing probable cause in support of a
criminal complaint charging WHITLEY with sex trafficking of a minor and
production of child pornography, I have not included each and every fact known to
me concerning this investigation. I have set forth only the facts that I believe are
necessary to establish probable cause to believe that WHITLEY committed the
offenses alleged in the complaint.
3..

This affidavit is based on my personal knowledge, information provided

to me by other law enforcement personnel, interviews of witnesses, cellular phone
records, my experience and training, and the experience of other agents.
4.

As set forth in more detail below, there is evidence establishing probable

cause that WHITLEY, a Chicago Police Officer, engaged in commercial sex acts with

 Minor A on multiple occasions in 2015, and took sexually explicit photographs of
Minor A and distributed those photographs to Minor A via text message ..

Recovery of Minor A
5.

In 2015, the FBI was investigating allegations that a minor-aged female,

Minor A (date of birth xx/xx/2000), was the victim of sex trafficking in Chicago and
the surrounding area.
6.

In early September 2015, law enforcement located and reviewed several

advertisements for commercial sex acts with Minor A on Backpage.com, which
I

according to the advertisements, were posted on or about September 1, 2015,
September 9, 2015, September 11, 2015, and September 14, 2015.

In these

advertisements, Minor A is identified by the same nickname, Nickname A.
7.

The September 1, 2015, September 9, 2015, September 11, 2015, and

September 14, 2015 Backpage.com advertisements each stated that Minor A could be
reached at telephone number 773-xxx-0641 ("Minor A Phone").1
8.

On or about September 12, 2015, a law enforcement officer acting in an

undercover capacity (the "UC") and purporting to be a "john" seeking commercial sex
services in response to the Backpage.com advertisements called Minor A at the Minor

As described in this affidavit, law enforcement has identified Minor A as the user of the
Minor A Phone based in part upon the following: (1) the phone number was listed for Minor
A in the Backpage.com advertisements containing photographs of Minor A and identifying
Minor A by the nickname Nickname A; (2) the UC and Minor A communicated over Minor A
Phone and agreed to meet at a place and time on or about September 18, 2015, and Minor A
appeared at that place and time; (3) when Minor A was taken into custody on or about
September 18, 2015, she.had in her possession the Minor A Phone and consented to the search
of that phone; and (4) WHITLEY had the Minor A Phone saved in his contacts on his Galaxy
tablet under the contact name of Nickname A.
1

2

 A Phone. The UC had approximately two phone calls with Minor A on or about
September 12, 2015, and both of these communications occurred over Minor A Phone.
These telephone conversations were not recorded and the descriptions of those
conversations contained in this affidavit are based upon reporting from the UC.
During the communications between the UC and Minor A on September 12, 2015,
they discussed meeting and engaging in commercial sex services. Minor A and the
,

UC also negotiated the price of commercial sex services to be provided by Minor A.
Specifically, Minor A and the UC negotiated sex services for the price of $160.
9.

During one conversation, Minor A and the UC discussed where to meet

for the sex services. Minor A told the UC words to the effect of her "driver is not
available," and therefore Minor A would have to take public transportation. The UC
and Minor A decided· to meet at a train stop in the South Loop of Chicago in the
afternoon on September 12, 2015. Officers went to that location at the appointed
time, but Minor A did not show up.
10.

Between on or about September 16, 2015 and September 17, 2015, the

UC exchanged several text messages with Minor A, who was using the Minor A
Phone, in order to schedule a meeting. The UC also called the Minor A Phone, but no
one answered. A meeting was not scheduled.
11.

On or about September 18, 2015, the UC contacted Minor A at the Minor

A Phone via text messaging and phone calls. These telephone conversations were not
recorded and the descriptions of those co.nversations contained in this affidavit are
based upon reporting from the UC. During these communications, the UC and Minor

3

 A again discussed meeting and engaging in commercial sex services, and negotiated
commercial sex services for the price of approximat~ly $160. The UC and Minor A
arranged to meet on Friday, September 18, 2015, at approximately 4:30 p.m. at a
'',._

location on West 15th Street in Chicago.
12.

The UC and other law enforcement officers traveled to the meeting

location at approximately 4:30 p.m. on September 18, 2015. At that time, the UC
observed a black Mercedes four-door sedan stop in front of the agreed upon meeting
location on West 15th Street. The UC observed Minor A exit the back passenger's side
door. The UC also observed a female, who was later identified as Individual A, seated
at the front passenger's side, and a male, who was later identified as Individual B, in
the driver's seat. The UC informed law enforcenient officers of the description of the
vehicle and its passengers, and the law enforcement officers followed the vehicle.
13.

The UC then met with Minor A in the agreed upon location in Chicago.

The UC identified himself as a police officer and Minor A was then taken into custody
due to two outstanding warrants out of Cook County, Illinois, relating to charges of
retail theft and aggravated battery. As described below, Minor A agreed to speak
with law enforcement, and was kept in juvenile custody after her arrest as a result of
, her two outstanding warrants.
14.

Law enforcement officers performed a traffic stop on the black Mercedes

four-door sedan on Canalport and Halsted Street in Chicago. Law enforcement
subsequently ran the license plate number of the Mercedes sedan through a law
enforcement database which confirmed that the Mercedes was registered to

4

 Individual B. Individual A and Individual B were taken into custody and identified
as Individual A and Individual B. They w_ere later released without charges.

WHITLEY Paid Minor A for Sex and Sent Sexually Explicit
Photographs of Minor A to Minor A
15.

Upon her arrest on September 18, 2015, Minor A agreed to cooperate

with law enforcement. Minor A was not made any promises in exchange for her
cooperation nor was she paid in exchange for her cooperation.

The information

provided by Minor A to law enforcement has to date proven to be reliable and truthful.
Certain of the information Minor A provided has been corroborated by records related
to the Minor A Phone including contact lists, text messages, call records, and
photographs. Minor A has approximately 6 juvenile arrests, including one for
obstructing identification. Minor A has one juvenile adjudication for retail theft.
16.

Law enforcement ,officers interviewed Minor A on or about the evening

of September 18, 2015, as well as on subsequent dates. During these interviews,
Minor A had metal braces on her teeth. Minor A stated that she got the braces put
on her teeth in approximately June 2014.

17.

During these interviews with law enforcement, Minor A provided,

among other information, the following information about WHITLEY:
a.

Minor A stated that she had been engaging in commercial sex

services for the last several months. She stated that she saved the phone numbers of
her "johns," or commercial sex customers, in her phone with a dollar sign($) before
their names. Minor A stated that one of the individuals who she had sex with in

5

 exchange for money was a person she knew as "Will" and who law enforcement later
identified as WILLIAM WHITLEY, as described below.
b.

Minor A stated that WHITLEY's phone number was saved in her

phone under the contact name "$Will." As set forth below, a subsequent conse_nt
search of the Minor A Phone revealed that she had the contact name "$Will" saved in
her phone with the phone number 773-x:xx-5882 (the "Whitley Phone"),2
c.
June 2015.

According to Minor A, Minor A met WHITLEY in approximately

Minor A was introduced to WHITLEY through Minor A's friend,

Individual A.
d.

Minor A stated that Individual A introduced Minor A to

WHITLEY by taking Minor A to WHITLEY's apartment building in Chicago. Once
there, Individual A told Minor A which apartment was WHITLEY's and stated words
to the effect of WHITLEY would be able to pay, which Minor A understood to mean
that WHITLEY had money to pay her for engaging in sex acts. Minor A then went
up to WHITLEY's apartment by herself and met WHITLEY, who paid Minor A for
sex.3

As set forth in this affidavit, law enforcement identified WHITLEY as the user of the
Whitley Phone based in part upon the following: (1), subscriber information indicated that
the Whitley Phone is subscribed to by WILLIAM WHITLEY at his home address in Chicago,
Illinois; (2) Minor A had the Whitley Phone saved in her contacts as "$Will"; and (3) on or
about October 8,-2015, WHITLEY acknowledged to law enforcement that he was the user of
the Whitley Phone.
2

Minor A was shown a photograph of WILLIAM WHITLEY and identified that photograph
as depicting the individual she knew as "Will" who paid her for sex. Minor A also identified
the location ofWHITLEY's apartment in Chicago, Illinois.·

3

6

 e.

Minor A stated that she engaged in commercial sex services with

WHITLEY on approximately five occasions, each time at his apartment. Minor A
recalled that the most recent occasion occurred approximately one or two days prior
to Minor A's arrest on September 18, 2015. As set forth below, a subsequent search
of the Minor A Phone revealed text messages and call records indicating that Minor
A was with WHITLEY on September 17, 2015 .
. f.

Minor A stated that, on each occasion, WHITLEY paid Minor A

to have sex with him. Minor A stated that WHITLEY paid her between $60 and $150
for sex. During the most recent occasion that WHITLEY paid Minor A for sex, he
paid Minor A approximately $100. Minor A stated that the money she had on her
when she was arrested (approximately $46) was money left over from the $100 that
WHITLEY had paid her.
g.

Minor A stated that she and WHITLEY engaged in both oral sex

and vaginal sex each time she met him at his apartment in Chicago. WHITLEY used
a condom when they had sex, and Minor A recalled the condoms were Magnum
condoms in a gold wrapper. Minor A stated that the condoms belonged to WHITLEY
and that he kept the condoms near his bed.
h.

Minor A stated that she and WHITLEY did not have a regular

date on which they met. Minor A explained that WHITLEY would text Minor A at
Minor A Phone when he wanted to have sex with her. Minor A explained that, once
she.would receive a text message from WHITLEY, Minor A would then typically take
public transportation or call a cab or friend to drive her to WHITLEY's apartment,

7

 where she would engage in commercial sex with WHITLEY. On the most recent
occasion, she stated that WHITLEY wanted her to come over before he left for work
that day.
1.

Minor A stated that she did not tell WHITLEY her true name.

Minor A stated that she told WHITLEY that she was 23 years old. Minor A did not
tell WHITLEY her true age, which was 14 years old at the time. Minor A stated that
WHITLEY did not ask her anything about her background and did not ask her for
identification. Throughout the time that Minor A was with WHITLEY, Minor A had
metal braces on her teeth.
J.

Minor A stated that she observed Chicago Police Department

uniforms hanging on WHITLEY'S bedroom door. Minor A stated that WHITLEY kept
a handgun under the pillow of his bed, including while Minor A and WHITLEY
engaged in sex acts on the bed·. Minor A stated that, initially, WHITLEY did not tell
her that he was a police officer. Eventually, however, WHITLEY told Minor A that
he was a police officer, and bragged about being a police officer. In addition, Minor A
stated that WHITLEY often wore a gold chain around his neck that had gold
medallion with a Chicago Police Department logo on it.
k.

Minor A stated that WHITLEY took naked photographs of her on

his Galaxy cellular phone while they were inside of his apartment. Minor A also
recalled that WHITLEY had a Galaxy tablet in his apartment. Minor A stated that
WHITLEY sent her via text message some of the naked photographs he took of her.
In some of the photographs, Minor A stated that she is posing naked with another

8

 person. Minor A stated that she had some of the naked photos that WHITLEY took
of her saved in the "downloads" section of her phone (the Minor A Phone).

As

described below, a subsequent search of photographs downloaded on the Minor A
Phone includ~d photographs of a female, who Minor A identified as herself, without
any clothes on posing in sexual positions, including with her genitalia exposed, in
WHITLEY's apartment.

1.

Minor A stated that she knows several other females who have

sex with WHITLEY in exchange for money, including Minor B, who Minor A knew by
the nickname Nickname B and law enforcement identified as Minor B, as described
below. Minor A stated that Minor B was approximately 16 years old, which she knew
because Minor B told Minor A her age.

Search of the Minor A Phone
18.

At the time of her arrest on September 18, 2015, Minor A had on her

person the Minor A Phone, and Minor A consented in writing to the search of the
phone. Law enforcement subsequently searched the Minor A Phone, which revealed
evidence of communications with WHITLEY as recently as September 17, 2015, that
indicate that Minor A saw WHITLEY that day.
19.

More specifically, Minor A had WHITLEY's phone number, 773-xxx-

5882, saved in her contacts under the name "$Will." Law enforcement subsequently
obtained subscriber information for phone number 773-xxx-5882, which showed that
this phone number was registered to WHITLEY at his apartment in Chicago.

9

 20.

According to the record of text messages on the Minor A Phone, on

September 17, 2015, between approximately 11:30 a.m. and 12:46 p.m., WHITLEY,
.

~

using the Whitley Phone, initiated a series of text messages with Minor A, who was
using the Minor A Phone. Furthermore, the call log on the Minor A Phone reflect
that Minor A called WHITLEY multiple times on September 17, 2015.
a.

More specifically, according to the text messages found on the

Minor A Phone, at approximately 11:30 a.m. on September 17, 2015, WHITLEY,
using the Whitley Phone, sent a text message to Minor A at the Minor A Phone that
stated, "Wyd [what you doing]."4 In response, at approximately 11:39 a.m., Minor A,
using the Minor A Phone, placed an outgoing call to WHITLEY at the Whitley Phone
that lasted approximately seven seconds. Approximately two minutes later, at 11:41
a.m., WHITLEY, using the Whitley Phone, sent a text message to Minor A at the
Minor A Phone that stated, "Stop playing with phone. Either talk. Or say stop texting
you. But don't play on phone." At approximately 12:07 p.m., Minor A responded with
a text that stated, "I'm just being cautious because lk ppl like to play on your phone."
At approximately 12:10 p.m., WHITLEY, using the Whitley Phone, responded, "Not
me. To [sic] grown for that."

The transcripts of text messages described in this affidavit remain in draft form; to the
extent quotations from the conversations are included, they are preliminary, not final. The
interpretations of certain text messages are set forth herein in brackets. My understanding
and interpretation of the messages is based upon the contents of the messages, and my
knowledge derived from this investigation, and my experience and familiarity, and the
experience and familiarity of other law enforcement agents, with sex trafficking.
4

10

 b.

Approximately one minute later~ Minor A, using Minor A Phone,

sent a text to WHITLEY at the Whitley Phone, that stated, "Awww ok wassup then."
In response, WHITLEY sent two text messages stating, "You already know" and "B4
I gotta work," respectively. At approximately 12:12 p.m., the Minor A responded by
asking, "What time yo:u gotta go [to work] cause im bout to jump in shower now."
WHITLEY, using the Whitley Phone, texted back, "2:00p." Minor A then texted back,
"Ok in shower now call you when leaving out house."
c.

Approximately thirty minutes later, at approximately 12:45 p.m.,

WHITLEY, who was using the Whitley Phone, sent a text to Minor A, who was using
the Minor A Phone, that stated, "Wya [where you at]." At approximately 12:46 p.m.,
the Minor A responded with a text that stated, "Leaving out now."
d.

According to the call log records on the Minor A Phone, between

approximately 12:55 p.m. and 1:20 p.m. on September 17, 2015, the Minor A Phone
called the Whitley Phone approximately four times. The call records further reflect
that these calls each were less than 60 seconds in duration.
21.

In addition, law enforcement's review of the Minor A Phone indicated

that Minor A had the telephone number of Individual A saved in the contacts of the
Minor A Phone under Individual A's first name.
22.

Law enforcement subsequently obtained toll records from the service

provider for the Minor A Phone. According to these toll records, the Minor A Phone
and the Whitley Phone were in contact hundreds of times between on or about July
24, 2015 and September 17, 2015, including the communications on September 17,

11

 2015 described above. For example, the toll records for the Minor A Phone reflect
that, on or about July 24, 2015, the Minor A Phone and the Whitley Phone exchanged
more than approximately 50 text messages. In addition, for example, the toll records
show that, on or about August 7, 2015, the Minor A Phone and the Whitley Phone
exchanged more than approximately 50 text messages and that the Minor A Phone
placed two calls to the Whitley Phone (each were less than one minute in duration)
and the Whitley Phone placed one call to the Minor A Phone, which was
approximately 1 minute and 10 seconds in duration.
23.

Furthermore, law enforcement's review of the Minor A Phone reyealed

that it contained approximately six photographs depicting either one or two females,
both whom were naked and on top of a bed in sexual poses. The faces of the females
do not appear to be visible in the photographs. Upon showing these photographs to
Minor A, Minor A identified herself in at least some of these photographs.

For

example, one of the photographs shows Minor A and the other female next to each
other on the bed from behind on their hands and knees with their buttocks and
genitalia exposed. Another photograph shows Minor A lying on the bed with her legs
spread apart and genitalia exposed. Minor A further told law enforcement that these
photographs were taken by WHITLEY in WHITLEY's bedroom in his apartment.
24.

The information obtained from the forensic download of the Minor A

Phone indicates that these approximately six photographs were saved on or about
July 24, 2015, though the source of these photographs is not reflected on the
download.· The photographs were saved in the "/Internalstorage/GOSMS/download"

12

 section of the Minor A Phone. As set forth above, toll records show that more than
approximately 50 text messages where exchanged between the Minor A Phone and
the Whitley Phone on or about July 24, 2015.
25.

Law enforcement's review of the six photographs described above

indicates that the items visible in the background of these photographs are consistent
with items found in WHITLEY's apartment during the search of his apartment on or
about October 8, 2015 (described in more detail below).

For example, in one

photograph, leopard print bedding which has several different leopard print patterns
on it is visible on the left side of the photograph. During the search of WHITLEY's
apartment, law enforcement found leopard print bedding that appears to be the same
as that in the photograph. In addition, in two of the photographs, a tan, beige, and
black bedspread is visible on the right hand side of the photographs.

Law

enforcement found what appears to be the same tan, beige, and black bedspread in
WHITLEY's apartment.

WHITLEY Paid Minor B for Sex
26.

Following the interviews of Minor A, law enforcement identified as

Minor B (DOB: xx/xx/1997) the person who Minor A referred to as Nickname B, a 16year-old who WHITLEY paid for sex.

In or about early 2016, law enforcement

interviewed Minor B, who agreed to cooperate with the investigation and was
subsequently interviewed on multiple occasions. Minor B was not made any promises

13

 in exchange for her cooperation nor was she paid in exchange for her cooperation. 5
Minor B provided, among other information, the following information about
WHITLEY:
a.

Minor B stated that she ran away from home when she was

approximately 15 years old. According to Minor B, when Minor B was approximately
16 years old, she met Individual A. Minor B went to parties at Individual A's house,
which were attended by older men. Minor B stated that other young runaways also
were at these parties. Minor B stated that the young runaways, including herself,
had sex with the older men in exchange for money.
b.

Minor B identified a photograph of WHITLEY as one of the men

who she saw at the parties at Individual Ns house and who later paid Minor B for
sex, as described below. Minor B could not recall WHITLEY's name.
c.

Minor B further stated that Minor "B saw WHITLEY on an

occasion when she was walking in the Englewood neighborhood of Chicago with a
friend. According to Minor B, WHITLEY pulled up next to Minor B and her friend in
a car and asked if they wanted to take a ride with him and "his partner." Minor B
and her friend agreed and got into WHITLEY's car. Based on the way the man spoke
and referred to a "partner," Minor B believed that WHITLEY might be a police officer.
d.

Minor B explained that WHITLEY was in the driver's seat of the

car and WHITLEY's partner was sitting in the passenger seat. While they were

As an adult, Minor B has no convictions and has been arrested approximately twice, once
for assault and once for theft. Minor B has one juvenile adjudication, which was for theft.
Minor B has multiple juvenile arrests for theft and violent offenses.
5

14

 riding around in the car, WHITLEY paid Minor B approximately $65 in exchange for
giving him oral sex.
e.

Minor B stated that, after this first meeting, WHITLEY became

one of her primary commercial sex customers.

Minor B recalled that she and

WHITLEY met on approximately five occasions, and on each occasion, WHITLEY
paid her approximately $60 to $65 to give him oral sex .. Minor B explained that she
told WHITLEY that her name was Nickname B.
f.

Minor B stated that, during the time she was engaging 1n

commercial sex acts with WHITLEY, she was approximately 16 years old and was
·approximately two months away from turning 17 years old. Based upon Minor B's
date of birth, this would mean that the contact between Minor B and WHITLEY
occurred in approximately 2014. Minor B stated that, as to WHITLEY's age, she
believed WHITLEY to be in his 50s. Minor B stated that she did not talk about her
age with WHITLEY, but that she believed WHITLEY knew she was young. Minor B
explained that WHITLEY likely knew she was young because he saw her at
Individual A's house, and that most of the girls at Individual A's house were young
runaways. Minor B further stated that, at the time she was engaging in commercial
sex acts with WHITLEY, she was inexperienced with commercial sex acts, having
only just started engaging in them. Minor B further explained that, the first time
WHITLEY paid her for oral sex, he had to guide her during oral sex.
g.

Minor B recalled communicating with WHITLEY over a social

media website. Minor B further stated that, after she had been with WHITLEY for

15

 a while, she gave WHITLEY's phone number to her friends so that they could have
sex with him for money too.

Interview of WHITLEY and Search of WHITLEY's Apartment and
Electronics
27.

On or about October 7, 2015, a federal magistrate judge issued a warrant

to search WHITLEY's apartment in Chicago, Illinois, as well as the Whitley Phone.
The search warrant for WHITLEY's apartment was executed on or about October 8,
2015, and WHITLEY voluntarily agreed to be interviewed by law enforcement on that
same day.
28.

During the interview with law enforcement, WHITLEY identified 773-

xxx-5882 (the Whitley Phone) as his cellular phone number. WHITLEY stated that
he had recently obtained a new phone, but that it had the same phone number as the
Whitley Phone.
29.

In addition, WHITLEY acknowledged knowing Minor A (who he

referred to as Nickname A) and Individual A. WHITLEY stated that he met Minor A
through Individual A.

WHITLEY stated that he did not know Minor A's age.

WHITLEY recalled that Minor A had braces on her teeth. WHITLEY stated that he
had sex with Minor A on one occasion in approximately July or August 2015 and gave
her some money after !hey had sex. WHITLEY also stated that he took photographs
of Minor A on his cellular phone (a previous cellular phone with the same phone
number as the Whitley Phone) while Minor A was wearing a bra and panties.
WHITLEY stated that he sent these photographs to Minor Ns cellular phone.
30.

Whitley denied knowing a person by the name of Nickname B.

16

 31.

Law enforcement subsequently searched the Whitley Phone as well as

Samsung Galaxy tablet WHITLEY had in his apartment (the Whitley Tablet). A
review of the Whitley Tablet revealed that WHITLEY had the Minor A Phone saved
in his contacts (law enforcement did not find the Minor A Phone number saved in the
contacts of the Whitley Phone). More specifically, the Minor A Phone number was
saved in the Whitley Tablet under the name of Nickname A with the letters "Fre"
before it.

A search of the Whitley Phone and the Whitley Tablet revealed that

WHITLEY had multiple phone numbers saved in his phone with the letters "Fre"
either before or after the name. For example, saved in the contacts of the Whitley
Phone were phone numbers for contact names including, but not limited to, "fre
Bunny," "Fre Brittany Aka Mocha," "Fre Jasmine," and "Fre Star." Based upon law
enforcement's review of text messages exchanged between the Whitley Phone and his
various contacts with "Fre" in the contact name, the text messages exchanged
between WHITLEY and the "Fre" phone numbers are consistent with prostitution,
including discussions of price and meeting times.
32.

During the search of WHITLEY's apartment on or about October 8,

2015, in addition to the Whitley Tablet, law enforcement found condoms, empty
condom wrappers including a Magnum Trojan brand condom wrapper that was gold
in color, and used condoms. Law enforcement also found hanging on a hanger a shortsleeve, blue Chicago Police Department uniform shirt with a name tag on it that said
WHITLEY. Furthermore, law enforcement found bedding including leopard print
bedding that contained multiple leopard print patterns on it, which appeared to be

17

 the same leopard print bedding visible in certain of the sexually explicit photographs
found on the Minor A Phone described. above. Law enforcement also found a tan,
black, and beige colored bedspread, which appeared to be the same bedspread visible
in certain of the sexually explicit photographs found on the Minor A Phone described
above.

Interstate Commerce
33.

As described above, WHITLEY's conduct affected interstate commerce

in that he used a cellular phone in furtherance of the sex trafficking of Minor A and
the production and distribution of sexually explicit images of Minor A. In addition,
according to Minor A, WHITLEY used Trojan condoms during commercial sex acts
with Minor A. According to a representative of the company that produces Trojan
Magnum brand condoms, such condoms are manufactured outside of the state of
Illinois.

18

 Conclusion
34.

Based upon the foregoing, there is probable cause to believe that

WHITLEY engaged in the sex trafficking of Minor A, and produced and distributed
sexually explicit photographs of Minor A, in violation of Title 18, United States Code,
Sections 1591(a) and 2251.

FURTHER AFFIANT SAYETH NOT.

HELEN DUNN
Special
Agent,
Investigation

19

Federal

Bureau

of