UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 1 errc. UNITED STATES OF AMERICA v. FILED UNDER SEAL WILLIE DISHON MATTHEW OBADIAH, Defendant. CRIMINAL COMPLAINT COVER SHEET 1 . Did this matter originate from a matter pending in the Northern Region of the United States Attorney?s Of?ce prior to October 14, 2003? Yes No 2. Did this matter originate from a matter pending in the Central Region of the United States Attorney?s Of?ce prior to September 1, 2007? Yes No ReSpectfully submitted, ARIANA FAJ ORSHAN TED ST TTORNEY m/lb/zom By; (- 6) 10-06% ssa Sinwannes ssistant United States Attorney Court ID No. A5501644 99 NE. 4th Street, 8th Floor Miami, Florida 33132?21 1 1 Tel: (305) 961-9023 Fax: (305) 536?4699 VanessaS .J ohannes@usdoj . gov Case Document 1 Filed 04/22/19 Page 1 of 12 A0 9l (Rev. 08/09) Criminal Complaint UNITED STATES DISTRICT COURT for the Southern District of Florida United States of America v. WILLIE DISHON MATTHEW OBADIAH Case No. 1 1 0&575 gec?m? Defendant(s) CRIMINAL COMPLAINT l, the complainant in this case, state that the following is true to the best of my knowledge and belief. On or about the date(s) of February 28 - March a 2019 in the county of in the SOUTHERN District of FLORIDA the Code Section O?ense Description Defendant did knowingly, in and affecting interstate commerce, recruit, TITLE 18, UNITED STATES entice, harbor, transport, provide, obtain. advertise. and maintain by any CODE, SECTIONS 1591 means a person, that is, the Minor Victim, knowing. and in reckless disregard 1591(b)(2) and 1591(b)(1). of the fact, and having had a reasonable opportunity to observe the Minor Victim, that the Minor Victim had not attained the age of 18 years and would be caused to engage in a commercial sex act. Further the offense was effected by means of force, threats of force, or coercion. This criminal complaint is based on these facts: SEE ATTACHED AFFIDAVIT OF FBI SPECIAL AGENT GEORGE B. NAU. if Continued on the attached sheet. r/Jham Complainant" signature FBI SPECIAL AGENT Prr? edna andtr?tle Sworn to before me and signed in my presence. Date: Ji??geWe Ct: ?1ff3r1lf; Dr? in 3?0 City and state: up} rip? If gi?n GCC- u. BLE JACQUELINE BECERRA i :Iger: NOE-ID (Jerky Printedname andtii?le ii 0- DistriciC Southern? Distric of Ft Ji' I Case 3:19-mj-00132 DSC Page 2 of 12 Date FILED UNDER SEAL AFFIDAVIT IN SUPPORT OF A CRIMINAL COMPLAINT 1, George B. Nau, having first been duly sworn, hereby depose and state as follows: BACKGROUND 1. I am a Special Agent with the Federal Bureau of Investigation and have been so employed since April 1998. Thus, I am an investigative or law enforcement officer of the United States within the meaning of Section 2510(7) of Title 18, United States Code. That is, I am an of?cer of the United States who is empowered by law to conduct investigations of, and make arrests for, violations of federal law, including the offenses enumerated in Title 18, United States Code, Sections 1591, 2422, and 2423, et seq. 2. I currently serve as part of the Crimes Against Children Squad and the FBI Child Exploitation Task Force in the Miami Field Office. My duties include the investigation of crimes involving the sexual exploitation of minors, including the sex trafficking and commercial trafficking of minors and the possession and production of child pornography. I have received training on the proper investigative techniques for these violations, including the use of surveillance techniques, undercover activities, and the application and execution of arrest and search warrants. I have conducted and assisted in child exploitation investigations, and have executed search warrants that have led to seizures of child pornography and undercover operations to recover juvenile victims of sex traf?cking. PURPOSE OF THE AFFIDAVIT 3. This affidavit is submitted in support of a criminal complaint charging that WILLIE DISHON MATTHEW OBADIAH, from on or about February 28, 2019 through on or about March 2, 2019, in Miami-Dade County and elsewhere, did knowingly, in and affecting Case Document 1 Filed 04/22/19 Page 3 of 12 interstate and foreign commerce, recruit, entice, harbor, transport, provide, obtain, advertise, and maintain by any means a person, that is, the Minor Victim, knowing, and in reckless disregard of the fact, and having had a reasonable opportunity to observe the Minor Victim, that the Minor Victim had not attained the age of 18 years and would be caused to engage in a commercial sex act, which carries a minimum mandatory term of 10 years? imprisonment, in violation of Title 18, United States Code, Section 1591(a)(1) and It is further alleged that the offense was effected by means of force, threats of force, or coercion, which carries a minimum mandatory sentence of 15 years of imprisonment and up to life imprisonment, in violation of Title 18, United States Code, Section 1591(a)(1) and 4. The statements contained in this af?davit are based upon my own personal knowledge, as well as information provided by other individuals, including other law enforcement of?cials, and my review of records obtained during the course of this investigation. I have not included in this af?davit each and every fact and circumstance known to me, but only the facts and circumstances suf?cient to establish probable cause. PROBABLE CAUSE - Recovering and Interviewing the Minor Victim 5. On March 4, 2019, a 17-year-old minor female?s (hereinafter referred to as ?Minor Victim?) relative called law enforcement to report that Minor Victim was an alleged victim of human traf?cking. Law enforcement reSponded to an address in Miami Gardens, Florida, where the Minor Victim was recovered. 6. On March 5, 2019, Minor Victim was interviewed by law enforcement. In part, she provided the following information. On or about February 24, 2019, the Minor Victim ran Case Document 1 Filed 04/22/19 Page 4 of 12 away from her foster home in Greensboro, North Carolina. A friend of Minor Victim?s took her to a friend?s house in Columbus, North Carolina, where she stayed until approximately February 28, 2019, whereon Minor Victim was picked up by OBADIAH. 7. The Minor Victim met OBADIAH through acebook. Speci?cally, OBADIAH had been in contact with the Minor Victim via Facebook for approximately two weeks prior to picking her up. acebook pro?le is ?Tonie Ahora Tocaa.? OBADIAH utilized the name ?Torrie? when he spoke to Minor Victim. OBADIAH attempted to initiate contact with Minor Victim on Facebook Messenger. Initially, the Minor Victim ignored repeated attempts for approximately one week prior to accepting messenger contact with him. 8. During their contact on messenger, Minor Victim incorrectly advised OBADIAH that she was 18 years old. OBADIAH told Minor Victim that she looked young and requested proof of her age. Minor Victim sent OBADIAH a picture of her actual identi?cation card, showing OBADIAH that she was in fact 17 years old. Minor Victim also advised OBADIAH that she was a runaway. Knowing Minor Victim?s age and that she was a runaway, OBADIAH requested her address and picked her up. At the time, it was Minor Victim?s understanding that she was getting picked up to go on a road trip to Miami, where she would just smoke and walk on the beach. 9. After picking up Minor Victim on or about February 28, 2019, OBADIAH drove Minor Victim and another female known as to a hotel in Charlotte, North Carolina. After arriving at the hotel, OBADIAH had a conversation with Minor Victim, wherein he explained that he would be posting ads of her online for prostitution services. OBADIAH told Minor Victim that she was now a part of his family. Minor Victim feared for her safety upon hearing this. 10. Minor Victim was then taken to room 117 of the hotel, wherein she had three Case Document 1 Filed 04/22/19 Page 5 of 12 different prostitution ?in-calls.? Each ?in?call? consisted of penile/vaginal intercourse. An ?in? call? is when the customer seeking prostitution services travels to meet the prostitute (versus an ?out-call,? where the prostitute travels to meet the customer). OBADIAH instructed the Minor Victim to text the number ?1 to him when the customer arrived at the hotel room, and to text the number to him when the customer left. OBADIAH also sent Minor Victim the following, via text: This meant $60 for a quick Visit and $100 for half?of?an-hour OBADLAH utilized the term ?bOp? for customers. The Minor Victim made approximately $500 for sexual services with three ?bops.? 1. Minor Victim was instructed by OBADIAH to have the ?bops? place the money on t0p of the microwave inside of the hotel room. Minor Victim was instructed not to touch the money until the ?bOp? pulled his pants down and showed her his penis. She was told by OBADIAH that law enforcement officers do not expose themselves. Minor Victim was also instructed to never do anything that would not please the ?bop.? Minor Victim asked OBADIAH for the money from the sex acts but was told by OBADIAH that she could not get her money. He said he would hold onto it. 12. On or about March 1, 2019, OBADIAH, and Minor Victim left for Miami, Florida. Before leaving Charlotte for Miami, they were joined by the following females: ?June,? ?Day ?Justice,? and ?Kimmie?. On the trip to Miami, OBADMH forced Minor Victim to use cocaine. OBADIAH had Minor Victim discard her identification card on the way down to Miami and stated that he would get her a new identi?cation card later. During the drive south, Minor Victim heard OBADIAH threatening to harm a female, via a telephone call. She believed he was Speaking to another prostitute. Based upon comments to this unknown female, Case Document 1 Filed 04/22/19 Page 6 of 12 Minor Victim was afraid of Minor Victim stated that she never saw ?Tonie,? as she still knew him, carrying a gun, but she saw him carrying a bag and did not know what was in it. 13. The group Speci?ed above arrived in Miami on or about March 2, 2019. After spending a short period of time at a motel in Hialeah, Florida, they proceeded to another hotel in Miami. At some point after arriving in the Miami area, OBADIAH reposted Minor Victim?s ?services? online, and arranged four ?in-calls? for her. Minor Victim had penile/vaginal intercourse with all four ?bops.? Each ?bOp? paid her $200. After having sex with the ?rst ?bop,? OBADIAH had Minor Victim take four different pills. Minor Victim knew that one was a Percocet and another was a Xanax bar. The other two pills were unknown to Minor Victim. 14. After the four ?hops? left, Minor Victim attempted to contact OBADIAH but he did not respond. Minor Victim was awoken later that evening by OBADIAH and forced to perform oral sex on him. When OBADIAH ejaculated into Minor Victim?s mouth, she spit it out. OBADIAH raised his hand to punch Minor Victim for doing this, and Minor Victim stuck her hand out to block the blow. OBADIAH told Minor Victim to never touch a pimp and attempted to further sexually assault her. Minor Victim was able to get out of the hotel room and was eventually caught by OBADIAH. OBADIAH took Minor Victim to South Beach and left her with the other adult females that had come to Miami with them. 15. When Minor Victim was alone with Day 1 and Justice, she told them about her age and that she had been sexually assaulted by OBADIAH. Upon hearing this, they drove Minor Victim to a relative?s home in the Miami area and le? her there. 16. Minor Victim was shown a photograph of a Facebook page assOciated with ?Tonie Ahora Tocca.? Minor Victim signed and dated the picture indicating the person on this Facebook Case Document 1 Filed 04/22/19 Page 7 of 12 pro?le was the individual she knew as ?Tonic,? that is, OBADIAH. - Subsequent Investigation by Law Enforcement 17. Further investigation by law enforcement revealed that the ?url? for the Facebook pro?le of ?Tonie Ahora Tocca? contained the name ?Dishon.Willie.18.? A query of the name Willie Dishon was conducted in North Carolina?s Driver?s License database. This query provided a photograph of OBADIAH, which is consistent with the individual depicted in the Facebook pro?le for ?Tonie Ahora Tocca.? 18. During the interview of Minor Victim, she stated that the group drove to Miami in two white vehicles, possibly a Toyota or Nissan. Minor Victim also stated they stayed in rooms 225 and 207 at the motel in Hialeah. Minor Victim remembered staying in room 420 at the other hotel in Miami, and that the person that rented the hotel room was named (Note: the motel and hotel names, as well as ?rst name were provided by Minor Victim and are known to law enforcement.) l9. Investigation at the motel in Hialeah revealed that room 225 was rented to a person with the initials from a known address in Charlotte, North Carolina. (Note: full name is known to law enforcement, but not revealed herein due to privacy concerns.) drives a white Nissan registered in North Carolina. Room 207 was rented in Minor Victim?s presence by Justice, using the name ?Nichole.? A review of-the rental for room 207 revealed it was rented by a person with the initials (Note: the full name is known by law enforcement, but again, for privacy, is not revealed herein.) The Minor Victim had previously identi?ed Justice?s Facebook page, which had a user identi?cation name that matched the identi?cation of Additionally, the Minor Victim can be seen on video surveillance at the motel in Hialeah on the date in question Case Document 1 Filed 04/22/19 Page 8 of 12 with a group of black females utilizing a white car. 20. Investigation at the other hotel in Miami revealed that room 420 was rented by a person with the initials and whose last name is the same as which was provided by the Minor Victim and referenced above. A review of the video surveillance from the hotel in Miami shows that the Minor Victim can be seen at the hotel on the dates she stated she was prostituted from that location. CONCLUSION 21. Based on my training and experience, and as further supported by the facts in this af?davit, I respectfully submit that there is probable cause to believe that WILLIE DISHON MATTHEW OBADIAH, from on or about February 28, 2019 through on or about March 2, . 2019, did knowingly, in and affecting interstate and foreign commerce, recruit, entice, harbor, transport, provide, obtain, advertise, and maintain by any means a person, that is, the Minor Victim, knowing, and in reckless disregard of the fact, and having had a reasonable opportunity to observe the Minor Victim, that the Minor Victim had not attained the age of 18 years and would be caused to engage in a commercial sex act, which carries a minimum mandatory term of 10 years? imprisonment, in violation of Title 18, United States Code, Section 1591(a)(1) and his portion was intentionally left blank. Case Document 1 Filed 04/22/19 Page 9 of 12 It is further alleged that the offense was effected by means of force, threats of force, or coercion, which carries a minimum mandatory sentence of 15 years of imprisonment and up to life imprisonment, in violation of Title 18, United States Code, Section 15 and FURTHER YOUR AF IANT SAYETH NAUGHT. WW 5 George B. l