Case Document 4 Filed 04/02/19 Page 1 of 3

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF NEW YORK

 

UNITED STATES OF AMERICA Criminal No. 136 


V. Indictment



MAHKYA SEARLES, Violations: 18 U.S.C. 
and 

Defendant. [Receipt of Child
Pornography]

18 U.S.C. 
and 
[Possession of Child
Pornography]



2 Counts and Forfeiture Allegation

County of Offense: Tioga
THE GRAND JURY CHARGES:
COUNT 1

[Receipt of Child Pornography]

From in or about April of 2013, through on or about March 10, 2019, in Tioga County, in
the Northern District of New York, defendant MAHKYA SEARLES did knowingly receive child
pornography using a means and facility of interstate and foreign commerce, shipped and
transported in and affecting such commerce by any means, including by computer, in that the
defendant received, by way of the Internet, image files depicting one or more minors engaged in
sexually explicit conducr.

In Violation of Title 18, United States Code, Sections and



Case Document 4 Filed 04/02/19 Page 2 of 3


[Possession of Child Pornography]

On or about March 20, 2019, in Tioga County, in the Northern District of New York,
defendant MAHKYA SEARLES did knowingly possess material that contained one or more
images of child pornography that had been shipped and transported using a means and facility of
interstate and foreign commerce, and in and affecting such commerce by any means, including by
computer, and that were produced using materials which had been shipped and transported in and
affecting such commerce by any means, including by computer, that is an Apple iPhone SE cellular
telephone, serial number DX3W2GU2HTVK, which contained images of one or more minors
engaged in sexually explicit conduct, in violation of Title 18, United States Code, Sections
and 

This violation involved digital images of child pornography involving prepubescent minors
and minors who had not attained 12 years of age, in violation of Title 18, United States Code,
Section 2252A(b)(2).

FORFEITURE ALLEGATION

l. The allegations contained in Counts 1 85 2 of this Indictment are hereby realleged
and incorporated by reference for the purpose of alleging forfeiture pursuant to Title 18, United
States Code, Section 2253,

2. Pursuant to Title 18, United States Code, Section 2253, upon conviction of one or
more offenses in violation of Title 18, United States Code, Section 2252A, the defendant,
MAHKYA SEARLES, shall forfeit to the United States of America any property, real and
personal, used and intended to be used to commit and to promote the commission of the offenses.
The property to be forfeited includes, but is not limited to, the following:

a. Apple iPhone SE cellular telephone, serial number: DX3W2GU2HTVK,

ls.)

Case Document 4 Filed 04/02/19 Page the property described above, as a result of any act or omission of the
defendant:
a. cannot be located upon the exercise of due diligence;
b. has been transferred or sold to, or deposited with, a third party;
c. has been placed beyond the jurisdiction of the court;
d. has been substantially diminished in value; or
e. has been commingled with other property which cannot be divided without
dif?culty,

the United States of America shall be entitled to forfeiture of substitute property pursuant to Title
21, United States Code, Section 853(p), as incorporated by Title 18, United States Code, Section

2253(b) and by Title 28, United States Code, Section 2461(c).

Dated: April 2, 2019
A TRUE BILL, 

Grand Jury Foreperson!

GRANT C. AQUITH
United States Attorney

By: 
Kristen Grabo?wski

Assistant United States Attorney
Bar Roll No. 700658

LA.)