IN THE UNITED STATES DISTRICT COURT FOR THE
WESTERN DISTRICT OF MISSOURI
WESTERN DIVISION
UNITED STATES OF AMERICA,
Case No. __________________________
Plaintiff,
v.
MARIO AMBROSE ANTOINE, also known
as “Mario Sixstring,” “Mario Ferrari,” “Mario
Danger,” “Chris Campbell,” “Dalton Wayne,”
“Ryan Bollman,” “Reyna Dash,” “Carmen
Resben,” “KindaGuitarded,” and “Nikki,”
[DOB: 12/21/1982]
Defendant.

COUNTS ONE through TWELVE:
Wire Fraud
18 U.S.C. § 1343
NMT: Twenty Years Imprisonment
NMT: $250,000 Fine
Supervised Release: NMT Three Years
Class B Felony
COUNT THIRTEEN and FOURTEEN:
Cyberstalking
18 U.S.C. § 2261A(2)
NMT: Five Years Imprisonment
NMT: $250,000 Fine
Supervised Release: NMT Three Years
Class D Felony
COUNTS FIFTEEN and SIXTEEN:
Online Enticement
18 U.S.C. § 2422(a)
NMT: Twenty Years Imprisonment
NMT: $250,000 Fine
Supervised Release: NLT Five Years
Class C Felony
COUNTS SEVENTEEN and EIGHTEEN:
False Statements to Federal Law
Enforcement
18 U.S.C. § 1001(a)(2)
NMT: Five Years Imprisonment
NMT: $250,000 Fine
Supervised Release: NMT Three Years
Class D Felony
COUNT NINETEEN:
Obstruction of the Due Administration of
Justice
18 U.S.C. § 1503
NMT: Ten Years Imprisonment
NMT: $250,000 Fine

Case 4:16-cr-00320-BP Document 4 Filed 10/12/16 Page 1 of 24

 Supervised Release:
Class C Felony

NMT Three Years

COUNT TWENTY:
Extortion
18 U.S.C. § 875(d)
NMT: Two Years Imprisonment
NMT: $250,000 Fine
Supervised Release: NMT One Year
Class E Felony
COUNT TWENTY-ONE:
False Registration of a Domain Name
18 U.S.C. § 3559(g)(1)
NMT: Seven Years Imprisonment
NMT: $250,000 Fine
Supervised Release: NMT Three Years
Class D Felony
$100 Special Assessment for Each Count
INDICTMENT
THE GRAND JURY CHARGES THAT:
1.

At times relevant to this Indictment:
a. MARIO AMBROSE ANTOINE (“ANTOINE”), also known as “Mario
Sixstring,” “Mario Ferrari,” “Mario Danger,” “Chris Campbell,” “Dalton
Wayne,” “Ryan Bollman,” “Reyna Dash,” “Carmen Resben,”
“KindaGuitarded,” and “Nikki,” resided at various addresses in Kansas City
and Raymore, Missouri, which are within the Western District of Missouri, and
worked as a wedding photographer while doing business as Short Dog Digital
Corp., Imagine Photo KC, Moon Rocket Photo, MoonRocketMediaKC, and
MoonRocketPhotoKC.
b. ANTOINE created a succession of various online aliases, posing as a talent
manager, photographer, and videographer for fictitious companies such as
“Playboy Worldwide,” “Playboy Asia,” “Dash Agency,” and others companies
that were purportedly involved in managing and hosting private overseas
pornography websites. Using these various aliases and showing purported
documentation demonstrating the legitimacy of this enterprise, ANTOINE
would “audition” dozens of victims throughout the greater Kansas City,
Missouri area as models for prospective employment with these fictitious
entities.

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 c. ANTOINE induced these victims with false and fraudulent pretenses,
representations, and promises of payment of tens of thousands of dollars for
entering into contracts for these modeling shoots and engaging in this sexual
activity, which entailed auditions whereby the victims would perform various
sexual activities with ANTOINE, which he would record.
d. As an inducement and enticement to engage in this activity, ANTOINE
presented these female victims with forged and false documents to add an
appearance of legitimacy to this scheme and enterprise, including but not
limited to falsified and forged checks issued to other purported “models,”
Internal Revenue Service Form 1099-MISC, Department of Homeland Security
Form I-9, and various other documents.
e. After many of these victims complained to ANTOINE that they had not been
paid as promised, ANTOINE forwarded images of this sexual activity with
these victims to the employers and significant others of the victims.
COUNTS ONE through TWELVE
Wire Fraud
2.

The Grand Jury re-alleges and incorporates by reference Paragraph 1 of this

Indictment.
A.

Purpose of the Scheme and Artifice
3.

Beginning on or about August 28, 2011, and continuing to on or about the date of

this Indictment, in the Western District of Missouri and elsewhere, the defendant, MARIO
AMBROSE ANTOINE (“ANTOINE”), devised and intended to devise a scheme to defraud
numerous victims, specifically, VICTIMS 1 through 6, and others both known and unknown to
the Grand Jury, and to obtain money and property, that is, the publicity rights, likenesses, and
produced images and videos, by means of false and fraudulent pretenses, representations, and
promises to VICTIMS 1 through 6, including but not limited to the representations and promises
of immediate and future payment for entering into such contracts.

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 B.

Manner and Means
4.

It was part of the scheme and artifice to defraud that ANTOINE assumed numerous

aliases and identities, posing as a company owner, recruiter, talent manager, photographer, and
videographer for multiple fictitious companies and private modeling websites, including but not
limited to “Playboy Worldwide,” “Playboy Asia,” and “Dash Agency,” and falsely registered
domain names purporting to be associated with Playboy Enterprises, Inc., in an attempt to induce
numerous female victims to engage in sexual and pornographic activity with ANTOINE with the
promises of immediate and prospective payment for such activity.
5.

It was further part of the scheme and artifice to defraud that ANTOINE made false

and fraudulent pretenses, representations, and promises in an effort to obtain money and property,
that is, the property of the victims’ likenesses, rights of publicity, and the produced images and
videos, and prepared and entered into contracts and modeling release forms with each prospective
victim to convey the victims’ property rights in their likenesses and the produced images and
videos to ANTOINE.
6.

It was further part of the scheme and artifice to defraud that ANTOINE prepared

forged and fraudulent payment checks, Internal Revenue Service (“IRS”) tax forms, and
Department of Homeland Security employment forms to demonstrate the authenticity of this
enterprise and assure the prospective victims that they would be paid thousands of dollars promised
to them by these fictitious entities for their auditioning and modeling activity.
7.

It was further part of the scheme and artifice to defraud that ANTOINE sent these

produced images of the victims to the victims’ employers and significant others.

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 C.

Overt Acts
8.

On or about August 28, 2011, ANTOINE knowingly falsely registered the domain

name williammorristalent.com, opting for private registration of this domain name, which he used
in the course of these offenses.
9.

On or about September 29, 2011, ANTOINE knowingly falsely registered the

domain name playboy-worldwide.com, opting for private registration of this domain name, which
he used in the course of these offenses.
10.

On or about October 17, 2012, ANTOINE created the “Nikki” Facebook profile,

which was one of the Facebook aliases ANTOINE employed over the course of this scheme to
defraud.
11.

On or about December 8, 2014, ANTOINE knowingly falsely registered the

domain name playboy-asia.com, opting for private registration of this domain name, which he used
in the course of these offenses.
12.

On or about December 8, 2014, ANTOINE created the email account

casting@playboy-asia.com.
13.

On or about November 12, 2015, ANTOINE conducted Google searches for “rape

by deception,” “rape by deception kansas,” and “illegal to trick girls into sleeping with you,” and
viewed websites and law journals regarding the criminality of committing rape by fraud or
deception.
ANTOINE’s Overt Acts with VICTIM 1
14.

Beginning on or about October 2011, VICTIM 1 was contacted by a woman named

“Hannah” who asked VICTIM 1 if she would be interested in modeling in adult photographs and
videos, who in turn directed VICTIM 1 to contact ANTOINE.

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 15.

On multiple occasions in late 2011 and early 2012, with the understanding that

ANTOINE would be paying $1,000 per “shoot,” ANTOINE and VICTIM 1 produced numerous
images and videos of their sexual activity. VICTIM 1 never received any sort of payment from
ANTOINE.
16.

Beginning on or about April 2015, VICTIM 1 began receiving emails from an

individual identifying themselves as ANTOINE’s attorney, which informed VICTIM 1 she
needed to re-contact ANTOINE to resolve their issues or he was going to post her images on the
Internet.
17.

On or about April 2015, VICTIM 1 contacted ANTOINE, who informed her that,

in exchange for not selling or distributing the previously produced images and videos of their
sexual activity, VICTIM 1 could either pay him $9,000 or she could come to ANTOINE’s house
and have sex with him.
18.

On or about April 7, 2015, VICTIM 1 drove to ANTOINE’s then-residence in

Raymore, Missouri, to have sex with him in lieu of the payment of $9,000 to avoid the distribution
of the pornographic images and videos.
19.

On or about April 7, 2015, ANTOINE directed VICTIM 1 to enter into an

“Assignment of Rights to Digital Media” agreement with VICTIM 1, in which VICTIM 1 signed
over to ANTOINE any and all digital media produced by ANTOINE as part of ANTOINE’s
assurance and agreement that he was destroying all of his pornographic images and videos of his
sexual activity with VICTIM 1.
20.

On or about April 7, 2015, ANTOINE provided to VICTIM 1 a false Department

of Homeland Security (“DHS”) Form I-9, which is used to verify the identity and employment
authorization of individuals hired in the United States. This false DHS Form I-9 presented by

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 ANTOINE to VICTIM 1 represented that the employer was “Reyna Dash” of “Dash Agency –
New York,” with an address in New York City, New York. On or about this date, ANTOINE
directed VICTIM 1 to fill out her information on this form so that she could be paid, which she
did.
21.

On or about May 25, 2015, ANTOINE sent to VICTIM 1 a photographic image of

a forged check made from “Dash Agency” in the amount of $575.00 and made out to VICTIM 1
as payment for the sexual activity. These materials included a notation that VICTIM 1 was paid
$500 for a “portfolio fee.”
22.

On or about April 7, 2015, ANTOINE surreptitiously video recorded VICTIM 1

signing and executing these documents. ANTOINE told VICTIM 1, “Trust me I don’t have
hidden cameras,” then looks and points at the hidden camera which is recording this encounter and
tells VICTIM 1, “that doesn’t have a webcam” and assured VICTIM 1 there are no cameras
recording in the room. VICTIM 1 asked ANTOINE, “Why is this what you want?” to which he
responded, “why not…unless you want to buy me a new Lexus.” VICTIM 1 confirmed with
ANTOINE that “we’re gonna delete all the stuff,” and ANTOINE responded, “I’m gonna wipe
everything clean.” VICTIM 1 asks how much money ANTOINE was going to make if he
released it, and ANTOINE responded, “they were gonna buy everything for $13,000, but that’s
not just your stuff that’s everybody’s stuff.” ANTOINE and VICTIM 1 engaged in oral and
vaginal sex, which was surreptitiously recorded. Following this sexual activity, ANTOINE
accessed his computer and told VICTIM 1, “there are all your files…When you’re ready for me to
delete them, tell me.” ANTOINE explained his process for deleting all of the image and video
files. ANTOINE further handed the clipboard and one of the aforementioned forms to VICTIM
1 and told her to write her email on it so he could email her a copy of it. ANTOINE then told

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 VICTIM 1, “I’m so mad at you…like, why did you have to go off and get a boyfriend? Why
couldn’t we just finish the shoot and be friends?” Later ANTOINE assured VICTIM 1, “I’ll
make sure I delete all of it…which sucks, I was gonna make a shitload of money…you owe me a
car.” ANTOINE signed the form in front of VICTIM 1, and told VICTIM 1 that he had “fried”
the hard drive.
23.

On or about May 1, 2015, ANTOINE, as “Reyna Dash,” sent an email to VICTIM

1, writing that “Since you decided you wanted to quit shooting, we will not be paying the $500
portfolio fee.”
ANTOINE’s Overt Acts with VICTIM 2
24.

Between or about March 10, 2015, and November 24, 2015, ANTOINE, as

“Nikki,” sent a series of messages via Facebook to VICTIM 2, which contained numerous false
and fraudulent pretenses, representations, and promises as to the legitimacy of this pornographic
enterprise and the prospect of payment to VICTIM 2.
25.

On or about March 10, 2015, ANTOINE, as “Nikki,” sent an unsolicited message

to VICTIM 2, inquiring whether she had ever thought about modeling.
26.

On or about March 11, 2015, ANTOINE, as “Nikki,” sent a series of messages via

Facebook to VICTIM 2, writing, “the money jobs are probably a little out of your comfort
zone…the stuff I do pays $8k-$15k PER shoot…[t]he good part is, none of it is available in the
US…i actually do shoots with a male producer…$8k for a bj, $15k if we have sex…i’ve bought a
house…a new jeep…i’ve been to Miami, Mexico, LA this year…i haven’t looked at a price tag
when i’ve been shopping in like months haha…I know i got it in the bank (sic).” ANTOINE
offers to share examples of previous shoots, and in response VICTIM 2 provides her email address.
27.

On or about March 11, 2015, ANTOINE sends an email to VICTIM 2 containing

approximately 15 images of VICTIM 1 performing oral sex on ANTOINE.
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 28.

On or about March 11, 2015, ANTOINE, as “Nikki,” sent a series of messages via

Facebook to VICTIM 2, writing, “sent…there are like 15 photos so it may take a sec.” In
response, VICTIM 2 wrote, “they pay you 8k to do that?!” and ANTOINE replied, “yep…EACH
shoot…those are 3 different shoots…$24,000…that’s what most people make in a year, i made in
three 30 minute shoots…and it all goes overseas so nobody here even knows about it…the
producer is a local guy named Chris…you can email…to me or the company…playboy-asia.”
29.

On or about May 17, 2015, ANTOINE, as “Nikki,” sent a series of messages via

Facebook to VICTIM 2, writing, “i’m mad they quit doing cash, we have to do paychecks
now…stupid IRS…it’s foreign, and you’re 1099 status, so it’s up to you if you want to claim it.”
30.

On or about June 23, 2015, ANTOINE, as “Nikki,” sent a series of messages via

Facebook to VICTIM 2, writing, that her payment “would be within 3 days,” and it would be
guaranteed by contract. When VICTIM 2 asked what sort of compensation, ANTOINE further
wrote, “$2k audition, $8k and up per shoot,” and sent an image of a large stack of $100 bills to
VICTIM 2, with the accompanying message, “[t]his just in the console of my car lol.”
ANTOINE further directed VICTIM 2 to send her information to casting@playboy-asia.com.
After VICTIM 2 asked ANTOINE for reassurance that it was “for sure 3 days for payment,”
ANTOINE replied, “[l]ately its been 2…[b]ut 3 to be safe…FedEx a check or direct deposit.”
31.

On or about June 24, 2015, ANTOINE, as “Nikki,” sent a series of messages via

Facebook to VICTIM 2, writing that VICTIM 2 would be going to “Raymore.” After VICTIM 2
wrote to ANTOINE for reassurance that “in about 3 days I’ll have $2k?” ANTOINE replied,
“[p]robably sooner.”

ANTOINE again directed VICTIM 2 to send her information to

casting@playboy-asia.com. After VICTIM 2 asked ANTOINE what the producer looked like,
ANTOINE sent to VICTIM 2 a picture of himself.

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 32.

On or about July 1, 2015, ANTOINE, as “Nikki,” sent a series of messages via

Facebook to VICTIM 2, reassuring VICTIM 2 that she would be paid within days. ANTOINE
further wrote messages advising VICTIM 2 what sort of sexual activities “Chris” preferred and
the “audition is easy…because he really doesn’t take many pics.”
33.

On or about July 1, 2015, at ANTOINE’s direction, VICTIM 2 entered into a

“Model Release and Grant of Rights” contract with ANTOINE (identified in the contract as “Chris
C.”) which conveyed the use of her rights of publicity in exchange for the false and fraudulent
pretense, representation, and promise that the producer, ANTOINE, would pay $2,000 to VICTIM
2 for her audition.
34.

After signing this contract, VICTIM 2 engaged in sexual activity with ANTOINE,

which ANTOINE recorded by taking photographs and making a video recording. ANTOINE
told VICTIM 2 she would be mailed a check.
ANTOINE’s Overt Acts with VICTIM 3
35.

Between on or about October 5, 2014, and August 20, 2015, ANTOINE, as both

“Nikki” and “Mario Sixstring,” sent a series of messages via Facebook to VICTIM 3, which
contained numerous false and fraudulent pretenses, representations, and promises as to the
legitimacy of this pornographic enterprise and the prospect of payment to VICTIM 3.
36.

Beginning on or about October 5, 2014, ANTOINE, as “Nikki,” sent a series of

messages via Facebook to VICTIM 3, writing “Now another company is gonna buy your shoot,”
and providing the domain to a revenge porn website where homemade images and videos of former
girlfriends are posted. ANTOINE further sent VICTIM 3 additional messages via Facebook,
writing, “You signed the release already…they’ll pay you once it goes live…it’s a US site...so they
use your real name…he was gonna put it on a site that even says your Facebook profile etc.”

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 ANTOINE then sent to VICTIM 3 a nude image of VICTIM 3 covered in semen. VICTIM 3
responds, “I don’t want that,” and ANTOINE wrote back, “if anyone ever googles your name,
they could probably find it…like job interviews in the future…or they’ll come to [VICTIM 3’s
employer]…are you going to risk this shit getting out?...What happens in 5 years when you want
a big girl job?...I’m telling you…Reshoot.” After VICTIM 3 responded to ANTOINE that she
did not want to reshoot, ANTOINE replied, “well your shit is going to be all over the web…when
you lose your job…then what…how are you going to pay for shit when you have NO job…like
you’re gonna end up fucking up your whole life over 30 mins of your time.” VICTIM 3 responds
to ANTOINE that she will not engage in a reshoot, to which he replied, “well have it your
way…You won’t be able to get a job, [VICTIM 3’s employer] will fire you…everyone in KC will
know you as the ‘porn girl with braces’…I don’t get it, why would you fuck up your future like
that?”
37.

On or about May 21, 2015, ANTOINE, as “Mario Sixstring,” sent a series of

messages via Facebook to VICTIM 3, writing “Are you gonna pick up your check anytime soon.”
Less than a minute later, ANTOINE, as “Nikki,” sent a message via Facebook to VICTIM 3,
writing “Hey…You know you have a paycheck that’s been here for awhile right.” ANTOINE
directed VICTIM 3 to email “Carmen” at “casting@playboy-asia.com,” and further wrote to
VICTIM 3 that “Carmen said your check is for like $18k.” ANTOINE arranged for another photo
shoot for VICTIM 3, further writing to her that the photo shoot will be with “Mario…the same
guy you’ve been shooting with, he’s doing the photos.”
38.

In or about May 2015, ANTOINE sent VICTIM 3 a photograph of a forged check

purported to have been issued to VICTIM 3 from “PBA Enterprises” in New York City for
“Audition and Production” in the amount of $18,590.93.

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 39.

On or about May 30, 2015, at ANTOINE’s direction, VICTIM 3 entered into a

“Model Release and Grant of Rights” contract with ANTOINE (identified in the contract as
“Mario Sixstring”) which conveyed the use of her rights of publicity in exchange for the false and
fraudulent pretense, representation, and promise that the producer, ANTOINE, would pay
VICTIM 3 the “base compensation of $33,550.”
40.

After signing this contract, VICTIM 3 engaged in sexual activity with ANTOINE,

which ANTOINE recorded by taking photographs and making a video recording.
41.

On or about August 2015, after VICTIM 3 complained to ANTOINE that he she

had never received the payment for this modeling activity, ANTOINE, sent some of these nude
images of VICTIM 3 taken during the recorded sexual activity to managers with her thenemployer, who was based in Kansas.
42.

On or about August 17, 2015, VICTIM 3 sent a message to ANTOINE’s “Mario

Sixstring” Facebook profile, writing, “you guys are using my pics against me…[t]hreatening my
job when I have a kid.”
43.

On or about August 20, 2015, VICTIM 3 sent a message to ANTOINE’s “Mario

Sixstring” Facebook profile, writing, “My job is gone now…[a]nd so is my bf.” ANTOINE (as
“Mario Sixstring”) replies, “Awesome so blame me,” and VICTIM 3 responded, “[y]ou’re the one
with the videos and pictures.” ANTOINE replied, “The majority yah…there a ton of people
offering to buy them, give me money for them.” VICTIM 3 responded to ANTOINE, writing,
“Cause you’re making me loose (sic) my job and house,” to which ANTOINE replied, “I think
your job is already toast…Nikki has been messaging your GM.” VICTIM 3 responded, writing,
“Cyber bullying makes people kill their selves,” to which ANTOINE replied, “Are you gonna kill
yourself [VICTIM 3]?”

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 ANTOINE’s Overt Acts with VICTIM 4
44.

Between March 22, 2015, and August 16, 2015, ANTOINE, as “Nikki,” sent a

series of messages via Facebook to VICTIM 4, which contained numerous false and fraudulent
pretenses, representations, and promises as to the legitimacy of this pornographic enterprise and
the prospect of payment to VICTIM 4.
45.

On or about March 22, 2015, VICTIM 4 received an unsolicited Facebook friend

request from ANTOINE posing as “Nikki.” On or about this same date, ANTOINE, as “Nikki,”
sent a series of messages via Facebook to VICTIM 4 that there was a lot of money to be made by
doing adult modeling for private websites.

ANTOINE wrote that her boss is “Chris…he

produces the modeling stuff i get paid for…if you’re ever looking for good money hit him up.”
ANTOINE further wrote, “a BJ starts at like $8k…a full shoot can be 10-15k…you ge paid for
the audition too (sic).”
46.

On or about April 23, 2015, ANTOINE, as “Nikki” sent a series of messages via

Facebook to VICTIM 4, writing, “the shoots start around $8k and go up from there…$2k for the
auction and $8k for an oral shoot and $12k+ for an intercourse (sic).”
47.

On or about April 24, 2015, ANTOINE, as “Nikki” sent a series of messages via

Facebook to VICTIM 4, writing “you’d make $2k for the audition…blow job shots are around
$8k…if you do full sex they can be between $10k-$15k…you could have a jeep in like 2 months
if you wanted…are you just going to do head again.” When VICTIM 4 asked ANTOINE where
the pictures would end up, ANTOINE answered, “Overseas, Thailand, South Korea, Japan,
Vietnam, Cambodia, Laos…they love american girls just like guys here love Asians.”
ANTOINE further wrote, “i could set something up with Chris before he leaves for Nashville
today (sic).”

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 48.

On or about April 24, 2015, at ANTOINE’s direction, VICTIM 4 entered into a

“Model Release and Grant of Rights” contract with ANTOINE (holding himself out as “Chris
Campbell”) which conveyed and contracted the use of her rights of publicity and likeness in
exchange for the false and fraudulent pretenses, representations, and promises that the “base
compensation” of $8,000 and a “special compensation” of $2,000 for “Audition” would be paid to
VICTIM 4.
49.

On or about April 24, 2015, ANTOINE produced and retained images and video

recordings of his sexual activity with VICTIM 4.
50.

Between April and July 2015, VICTIM 4 contacted ANTOINE numerous times to

receive payment, which never occurred.
51.

Beginning on or about late June of 2015, ANTOINE (as “Nikki”) engaged in

flirtatious communications with VICTIM 4’s ex-boyfriend and informed him that VICTIM 4 and
ANTOINE (“Mario”) were now in a relationship.
52.

On or about July 8, 2015, ANTOINE, as a newly-created Facebook alias “Dalton

Wayne,” sent a message via Facebook to VICTIM 4 writing “Hey, heard you’re a pornstar and
stripper. Are you working tonight?...[VICTIM 5] was saying you were. I was just wondering.”
53.

On or about August 5, 2015, ANTOINE, as “Dalton Wayne,” sent a message via

Facebook to VICTIM 4, writing “just FYI, someone is about to leak a bunch of naked pics of you
and a bunch of other [VICTIM 4’s employer] girls.”
54.

On or about August 16, 2015, ANTOINE, as “Dalton Wayne,” sent a message via

Facebook to VICTIM 4, which contained a nude image of VICTIM 4 with semen on her back.
ANTOINE further wrote, “so how do you know Mario…Nikki said that I could get photos of you
from him.”

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 ANTOINE’s Overt Acts with VICTIM 5
55.

Between or about May 21, 2015, and October 30, 2015, ANTOINE, as both

“Nikki” and “Mario Sixstring,” sent a series of messages via Facebook to VICTIM 5, which
contained numerous false and fraudulent pretenses, representations, and promises as to the
legitimacy of this pornographic enterprise and the prospect of payment to VICTIM 5.
56.

On or about May 21, 2015, ANTOINE, as “Nikki,” sent a series of messages via

Facebook to VICTIM 5, a resident of Kansas, inquiring whether VICTIM 5 was interested in
modeling. ANTOINE sent messages to VICTIM 5, writing “I do some adult stuff on the
side…pays amazing…it goes to countries where nobody here will ever know it exists or ever see
it.”
57.

On or about May 25, 2015, ANTOINE, as “Nikki,” sent a series of messages via

Facebook to VICTIM 5, identifying the photographer as “Mario Sixstring…he just added you on
Facebook.” Minutes later, ANTOINE, as “Mario Sixstring,” sent a series of messages via
Facebook to VICTIM 5, writing “Hey Nicole said to message ya.”
58.

On or about May 26, 2015, ANTOINE, as “Mario Sixstring,” sent a series of

messages via Facebook to VICTIM 5, writing “I work with an Agency…you should fill out an
app,” and directing her to a purported website for “Dash Agency.” ANTOINE sent additional
messages, writing that “(Nikki) does those shoots, and they go overseas…so nobody here can see
them…she makes a killer living at it…like $140k a year…I mean, I dont judge, $10k-15k for 25
mins of work…I’d do it if i was a girl haha.”
59.

On or about May 26, 2015, ANTOINE, again as “Nikki,” reassured VICTIM 5 that

“there is NO way anyone could find out.” When VICTIM 5 asked ANTOINE “How do you
know?” ANTOINE responded, “because you have 5 friends who’ve done it…and over 58 girls

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 in KC from the last 3 years have done them…not ONE has ever been found out…EVER.”
ANTOINE informed VICTIM 5 she could make “$4k for handjob…$8k for head…or $12k and
up for intercourse…you can make $12k in 30 mins fucking.” ANTOINE reassures VICTIM 5
the hosting website is overseas and private and “there is ZERO chance anyone will ever find
out…unless you tell them.” ANTOINE sent VICTIM 5 a picture of dollar bills valued in the
thousands spread out over a car seat, writing “thats just what i keep in my safe at home ;)…i have
about another $55k in the bank,” and that she had made $140,000 for ten photo shoots last year.
ANTOINE asked VICTIM 5 “wanna see what I made last year?” and sent a picture of a forged
IRS Form 1099-MISC purportedly issued by “Playboy Asia” to “Nikki” indicating that she had
received $142,093 in income. VICTIM 5 asked ANTOINE, “you have sex with the guy or
producer for the audition?” and ANTOINE responds “yah.” VICTIM 5 provided ANTOINE
with her full name, date of birth, and address in Kansas so he could prepare the contract in advance.
60.

On or about May 26, 2015, VICTIM 5 traveled from Kansas to ANTOINE’s

residence in Raymore, Missouri for the sexual activity.
61.

On or about May 26, 2015, at ANTOINE’s direction, VICTIM 5 entered into a

“Model Release and Grant of Rights” contract with ANTOINE (as “Chris Campbell”) which
conveyed and contracted the use of her rights of publicity and likeness in exchange for the false
and fraudulent pretenses, representations, and promises that the producer would pay to VICTIM 5
the “base compensation” of $2,000 and an additional $12,000 for upon the scheduling of the shoot.
On or about this same date, at ANTOINE’s direction, VICTIM 5 signed a “Confidentiality
Agreement” between her and “Playboy Asia.”
62.

On or about May 26, 2015, ANTOINE produced and retained images and video

recordings of his sexual activity with VICTIM 5.

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 63.

On or about October 30, 2015, ANTOINE, as “Nikki,” sent a series of messages

via Facebook to the then-boyfriend of VICTIM 5, who resided in Kansas. ANTOINE informed
VICTIM 5’s boyfriend “she does porn” and suggesting that was how she was able to pay for her
car.
64.

On or about October 30, 2015, ANTOINE, as “Nikki,” sent images of VICTIM 5

engaged in sexual activity with ANTOINE to VICTIM 5’s boyfriend in Kansas. When VICTIM
5’s boyfriend responded to ANTOINE that “you are distributing unwanted pornographic material
to me” and it “takes consent to send pictures like that,” ANTOINE replied, “lol, not when she
signs a release, i could post them on the front page of the KC Star if i wanted.” ANTOINE further
wrote, “All you’re gonna be known is as the dude who has a porn star girlfriend.”
ANTOINE’s Overt Acts with VICTIM 6
65.

Between on or about June 15, 2015, and June 18, 2015, ANTOINE, as both “Nikki”

and “Mario Sixstring,” sent a series of messages via Facebook to VICTIM 6, which contained
numerous false and fraudulent pretenses, representations, and promises as to the legitimacy of this
pornographic enterprise and the prospect of payment to VICTIM 6.
66.

Beginning on or about June 15 2015, ANTOINE, as “Mario Sixstring,” sent a

series of messages via Facebook to VICTIM 6, and persuaded her to contact “Nikki” via Facebook,
writing that “shes gotten tons of my friends work.”
67.

On or about June 15, 2015, ANTOINE, now as “Nikki,” sent a series of messages

via Facebook to VICTIM 6, including images of VICTIM 1 performing oral sex on ANTOINE,
but with ANTOINE (as “Nikki”) claiming to be the female depicted in the images.
68.

On or about June 15, 2015, ANTOINE, as “Nikki,” sent a series of messages via

Facebook to VICTIM 6, informing VICTIM 6 that “she” received “$8k for a full blowjob

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 shoot…$12k for sex,” and that an overseas website licenses the images to “parts of Japan, south
Korea, china etc.”
69.

On or about June 15, 2015, ANTOINE, as “Nikki,” sends to VICTIM 6 via

Facebook messenger an image of a forged IRS Form 1099-MISC purportedly issued by “Playboy
Asia” to “Nikki” demonstrating that she was paid $142,093 “last year.” ANTOINE further wrote
to VICTIM 6 that “Mario” would be the on-site photographer. VICTIM 6 asked “How soon do
you get paid after,” and ANTOINE responds, “Next day usually.”
70.

On or about June 15, 2015, ANTOINE, as “Mario Sixstring,” sent a series of

messages via Facebook to VICTIM 6 reassuring her that “there is a huuuge confidentiality
agreement and contract,” and VICTIM 6 invites ANTOINE to bring the proposed contract to her
home in Kansas.
71.

On or about June 18, 2015, VICTIM 6 traveled from Kansas to ANTOINE’s

residence in Raymore, Missouri for the arranged photo and video shoot.
72.

On or about June 18, 2015, ANTOINE provided to and made VICTIM 6 fill out

and execute a “Record Keeping Compliance Form Pursuant to 18 U.S.C. 2257,” which VICTIM
6 filled out using her address in Kansas.
73.

On or about June 18, 2015, at ANTOINE’s direction, VICTIM 6 entered into a

“Model Release and Grant of Rights” which conveyed and contracted the use of her rights of
publicity and likeness in exchange for the false and fraudulent pretenses, representations, and
promises that the “base compensation” of $2,000 for “oral audition” and a “special compensation”
of $8,000 for “additional productions” would be paid to VICTIM 6.
74.

On or about June 18, 2015, ANTOINE produced and retained images and video

recordings of his sexual activity with VICTIM 6.

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 D.

Wire Communications
75.

On or about each of the dates set forth below, in the Western District of Missouri

and elsewhere, the defendant, MARIO AMBROSE ANTOINE, for the purpose of executing and
attempting to execute the scheme and artifice to defraud, transmitted, or caused to transmit by
means of wire, radio, or television communication in interstate or foreign commerce the following
writings, signs, signals, pictures or sounds for the purpose of executing this scheme or artifice,
each wire communication being a separate count of this Indictment:
COUNT
DATE
1
December 8,
2014
2
3
4

May 1, 2015
March 11, 2015
March 11, 2015

5
6
7
8
9

May 17, 2015
June 23, 2015
June 24, 2015
October 5, 2014
May 21, 2015

10
11

April 24, 2015
May 26, 2015

12

June 15, 2015

WIRE COMMUNICATION
ANTOINE’s reservation of the Playboy-Asia.com website and
associated casting@playboy-asia.com email account with
GoDaddy.com, LLC
Email from ANTOINE (as “Reyna Dash”) to VICTIM 1
Facebook messages from ANTOINE (as “Nikki”) to VICTIM 2
Email from ANTOINE to VICTIM 2 containing pornographic
images of VICTIM 1
Facebook messages from ANTOINE (as “Nikki”) to VICTIM 2
Facebook messages from ANTOINE (as “Nikki”) to VICTIM 2
Facebook messages from ANTOINE (as “Nikki”) to VICTIM 2
Facebook messages from ANTOINE (as “Nikki”) to VICTIM 3
Facebook messages from ANTOINE (as both “Mario Sixstring”
and “Nikki”) that they had a check for VICTIM 3
Facebook messages from ANTOINE (as “Nikki”) to VICTIM 4
Facebook messages from ANTOINE (as both “Mario Sixstring”
and “Nikki”) to VICTIM 5
Facebook messages from ANTOINE (as “Nikki”) to VICTIM 6

All in violation of Title 18, United States Code, Section 1343.
COUNT THIRTEEN
Cyberstalking
76.

The Grand Jury re-alleges and incorporates by reference each and every allegation

contained in Paragraphs 1 and 35 through 43 of this Indictment as if fully set forth in this Count.
77.

Beginning on or about October 5, 2014, and through August 20, 2015, said dates

being approximate, in the Western District of Missouri and elsewhere, the defendant, MARIO
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 AMBROSE ANTOINE, with the intent to injure, harass, intimidate, and cause substantial
emotional distress to VICTIM 3, used any interactive computer service or communication service
or electronic communication system of interstate commerce, or any other facility of interstate or
foreign commerce, that is: electronic mail, Internet websites, and Facebook messages, to engage
in a course of conduct that caused substantial emotional distress to VICTIM 3, all in violation of
Title 18, United States Code, Section 2261A.
COUNT FOURTEEN
Cyberstalking
78.

The Grand Jury re-alleges and incorporates by reference each and every allegation

contained in Paragraphs 1, 62, and 63 of this Indictment as if fully set forth in this Count.
79.

Beginning on or about June 1, 2015, and through October 30, 2015, said dates being

approximate, in the Western District of Missouri and elsewhere, the defendant, MARIO
AMBROSE ANTOINE, with the intent to injure, harass, intimidate, and cause substantial
emotional distress to VICTIM 5, used any interactive computer service or communication service
or electronic communication system of interstate commerce, or any other facility of interstate or
foreign commerce, that is: electronic mail, Internet websites, and Facebook messages, to engage
in a course of conduct that caused substantial emotional distress to VICTIM 5 and a spouse or
intimate partner of VICTIM 5, all in violation of Title 18, United States Code, Section 2261A.
COUNT FIFTEEN
Online Enticement
80.

The Grand Jury re-alleges and incorporates by reference each and every allegation

contained in Paragraphs 1 and 55 through 59 of this Indictment as if fully set forth in this Count.
81.

Between on or about May 21, 2015, and May 26, 2015, in the Western District of

Missouri and elsewhere, the defendant, MARIO AMBROSE ANTOINE, using a facility and

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 means of interstate and foreign commerce, knowingly attempted to persuade, induce, entice, and
coerce an individual, VICTIM 5, a resident of the state of Kansas, to travel in interstate or foreign
commerce, to engage in prostitution or in any sexual activity for which any person can be charged
with a criminal offense, that is, the following felonies proscribed by the State of Missouri, such as,
but not limited to: rape in the second degree (MO. REV. STAT. § 566.031), sodomy in the second
degree (MO. REV. STAT. § 566.061), and promoting obscenity (MO. REV. STAT. § 573.020(1)), all
in violation of Title 18, United States Code, Section 2422(a).
COUNT SIXTEEN
Online Enticement
82.

The Grand Jury re-alleges and incorporates by reference each and every allegation

contained in Paragraphs 1 and 65 through 73 of this Indictment as if fully set forth in this Count.
83.

Between on or about June 15 and June 18, 2015, in the Western District of Missouri

and elsewhere, the defendant, MARIO AMBROSE ANTOINE, using a facility and means of
interstate and foreign commerce, knowingly attempted to persuade, induce, entice, and coerce an
individual, VICTIM 6, a resident of the state of Kansas, to travel in interstate or foreign commerce,
to engage in prostitution or in any sexual activity for which any person can be charged with a
criminal offense, that is, the following felonies proscribed by the State of Missouri, such as, but
not limited to: rape in the second degree (MO. REV. STAT. § 566.031), sodomy in the second degree
(MO. REV. STAT. § 566.061), and promoting obscenity (MO. REV. STAT. § 573.020(1)), all in
violation of Title 18, United States Code, Section 2422(a).
COUNT SEVENTEEN
False Statement and Representation Made to a Department of the United States
84.

The Grand Jury re-alleges and incorporates by reference each and every allegation

contained in Paragraph 1 of this Indictment as if fully set forth in this Count.

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 85.

On or about April 1, 2016, in the Western District of Missouri and elsewhere, the

defendant, MARIO AMBROSE ANTOINE, did willfully and knowingly make a materially
false, fictitious, and fraudulent statement and representation in a matter within the jurisdiction of
the executive branch of the Government of the United States, by denying that he promised money
and offered payment to these victims, and these materially false, fictitious, and fraudulent
statements and representations were made to a special agent with the Federal Bureau of
Investigation in Kansas City, Missouri, which is within the Western District of Missouri. The
statements and representations were false because, as ANTOINE then and there knew, that he
had, in fact, promised money and offered payment to these victims, all in violation of Title 18,
United States Code, Section 1001(a)(2).
COUNT EIGHTEEN
False Statement and Representation Made to a Department of the United States
86.

The Grand Jury re-alleges and incorporates by reference each and every allegation

contained in Paragraph 1 of this Indictment as if fully set forth in this Count.
87.

On or about April 1, 2016, in the Western District of Missouri and elsewhere, the

defendant, MARIO AMBROSE ANTOINE, did willfully and knowingly make a materially
false, fictitious, and fraudulent statement and representation in a matter within the jurisdiction of
the executive branch of the Government of the United States, by denying that he created or used
the alias of “Nikki” in his communications with these victims, and this materially false, fictitious,
and fraudulent statement and representation was made to a special agent with the Federal Bureau
of Investigation in Kansas City, Missouri, which is within the Western District of Missouri. The
statement and representation was false because, as ANTOINE then and there knew, that he had,
in fact, created and used the alias of “Nikki” in his communications with these victims, all in
violation of Title 18, United States Code, Section 1001(a)(2).
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 COUNT NINETEEN
Obstruction of Due Administration of Justice
88.

The Grand Jury re-alleges and incorporates by reference each and every allegation

contained in Paragraphs 1, 85, and 87 of this Indictment as if fully set forth in this Count.
89.

Between on or about September 10, 2016, and October 7, 2016, in the Western

District of Missouri and elsewhere, the defendant, MARIO AMBROSE ANTOINE, did
corruptly influence, obstruct and impede or endeavor to influence, obstruct, and impede the due
administration of justice regarding a federal Grand Jury in the Western District of Missouri, by
making false material statements to federal and state agents investigating his crimes that the
Federal Bureau of Investigation was no longer pursuing this investigation, and that his attorney
had cast doubt on the procedural sufficiency of the search warrants, when in fact the Federal
Bureau of Investigation was continuing its investigation and said attorney had not been consulting
with ANTOINE, in violation of Title 18, United States Code, Section 1503.
COUNT TWENTY
Extortion
90.

The Grand Jury re-alleges and incorporates by reference each and every allegation

contained in Paragraphs 1 and 14 through 23 of this Indictment as if fully set forth in this Count.
91.

Between on or about March 1, 2015, and on or about April 7, 2015, said dates being

approximate, in the Western District of Missouri and elsewhere, MARIO AMBROSE
ANTOINE, defendant herein, knowingly and with intent to extort a thing of value from VICTIM
1, did transmit in interstate and foreign commerce a communication containing a threat to injure
the property and reputation of VICTIM 1, all in violation of Title 18, United States Code, Section
875(d).

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 COUNT TWENTY-ONE
False Registration of a Domain Name
92.

The Grand Jury re-alleges and incorporates by reference each and every allegation

contained in Paragraphs 1 through 12, 28, 30, 31, 37, 59, 61, 69, and 75 of this Indictment as if
fully set forth in this Count.
93.

Between on or about December 8, 2014, and on or about the date of this Indictment,

said dates being approximate, in the Western District of Missouri and elsewhere, MARIO
AMBROSE ANTOINE, defendant herein, did knowingly and intentionally falsely register and
caused to be registered the playboy-asia.com website domain name, and used a service to obscure
the registration of this website from public viewing, and knowingly and intentionally used this
domain name and an email account he created with this domain name in the course of the
commission of the felony offenses alleged in this Indictment, all in violation of Title 18, United
States Code, Section 3559(g)(1).

A TRUE BILL.

____/s/ Megan M. DeLeo_____________
FOREPERSON OF THE GRAND JURY
___/s/ Patrick D. Daly___________
Patrick D. Daly
Assistant United States Attorney
Dated: ___10/12/16___________
Kansas City, Missouri

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