IN THE UNITED STATEiS DISTRICT COURT FOR THE

EASTERN DISTRICT OF VIRGINIA

"

. i [i
APS 19 2018

Alexandria Division

'

i
UNITED STATES OF AMEIUCA

Case No.: 1:18-MJ-196
UNDER SEAL

GEORGE AREF NADER,
Defendant.

AFFIDAVIT IN SUPPORT OF A CRIMINAL COMPLAINT

I, Special Agent Ted P. Delacourt ofthe Federal Bureau ofInvestigation(FBI), being
duly sworn under oath, do hereby depose and state:
INTRODUCTION

1.

I have been employed by the FBI since September of 2004, and as a Special

Agent since September 2005. Since 2005,1 have received training and experience in
interviewing and interrogation techniques, and arrest and search procedures. I was assigned as a
Special Agent in the Jacksonville Division in January 2006, where I worked counterterrorism
and intelligence-gathering operations for approximately three years. In May 2009,1 was
assigned to the Washington Field Office and charged with investigating international

corruption, specifically violations ofthe Foreign Corrupt Practices Act(FCPA)and antitrust

violations. In January 2009,1 was promoted to Supervisory Special Agent and assigned to the
Counterterrorism Division ofFBI Headquarters, specifically to the National Joint Terrorism
Task Force. In August 2012,1 transferred within the Counterterrorism Division to the

International Operations Section I, Continental US Unit V,where I program managed

 International Terrorism investigations in the Phoenix Division. I am currently assigned to the
Washington Field Office, Northern Virginia Resident Agency, Child Exploitation Task Force.
Since joining the FBI,I have investigated violations offederal law.

2.

As a federal agent, I am authorized to investigate violation oflaws ofthe United

States and as a law enforcement officer I am authorized to execute warrants issued under the

authority ofthe United States. Since September 2014,1 have been assigned to investigate

violations oflaw concerning the sexual exploitation ofchildren, including child pornography

and child sex trafficking. I have gained experience through both formal and on-the-job training
in conducting these types ofinvestigations.

3.

I am submitting this affidavit in support ofa criminal complaint and arrest

warrant charging the defendant GEORGE AREF NADER with Transportation of Visual
Depictions of Minors,in violation of Title 18, United States Code, Section 2252(a)(1) and
(b)(1).

4.

The statements contained in this Affidavit are based on my experience and

background as a criminal investigator, on information provided to me by other members ofthe
Federal Bureau ofInvestigation and other law enforcement officers, court records and

documents, business records, interviews, publicly available information and my review of
physical and documentary evidence. I have personally participated in the investigation ofthe

offense set forth below and, as a result of my participation and review ofevidence gathered in
the case, I am familiar with the facts and circumstances ofthis investigation. Since this

Affidavit is being submitted for the limited purpose of supporting a criminal complaint, I have
not included every fact resulting from the investigation. I have set forth only the facts that I

 believe are necessary to establish probable cause to believe the above-named defendant has
violated Title 18, United States Code,2252(a)(1) and (b)(1), as set forth herein.

RELEVANT FEDERAL CRIMINAL STATUTES

5.

Title 18, United States Code, Section 2252(a)(1) and (b)(1) prohibits the knowing

transportation ofany visual depiction of minors engaging in sexually explicit conduct using any
means or facility of interstate or foreign commerce or in or affecting interstate commerce by any

means, including by computer,ifthe producing ofsuch visual depiction involves the use of a
minor engaging in sexually explicit conduct and such visual depiction is ofsuch conduct.
6.

Under Title 18, United States Code, Section 2256(2)(A),"sexually explicit

conduct" means "actual or simulated — (i) sexual intercourse, including genital-genital, oralgenital, anal-genital, or oral-anal, whether between persons ofthe same or opposite sex;(ii)
bestiality;(iii) masturbation;(iv) sadistic or masochistic abuse; or(v)lascivious exhibition ofthe
genitals or pubic area of any person."
STATEMENT OF PROBABLE CAUSE

7.

GEORGE AREF NADER,hereinafter *TS1ADER," is a citizen ofthe United States

and Lebanon. On February 27,1991, NADER was indicted in the Eastern District of Virginia
for violations oftransporting child pornography. Title 18, United States Code, Section
2252(a)(1), by a federal grand jiu*y. The indictment resulted fi-om a seizure ofchild pornography

at the Washington-Dulles International Airport on July 26,1990 oftwo reels of video tape

concealed in candy tins. On May 6,1991,NADER pled guilty to a single violation of Section
2252(a)(1).
8.

On January 16, 2018, Search Warrant 1:18-SW-30 was sworn out in the United

States District Court for the Eastern District of Virginia and signed by U.S. Magistrate Judge

 Ivan D. Davis. The search warrant pertained to a matter unrelated to child pornography. The
attachments to the search warrant specified the items to be searched as "the person of George

Nader" and "Any baggage associated with George Nader...including but not limited to any
check baggage associated with George Nader on flight EF 231 as well as any carry-on baggage,
including but not limited to any briefcase, satchel, or duffel bag." The items to be seized
included "Any electronic devices capable of storing, transmitting, or receiving information,
including but not limited to: Cellular telephone. Tablet, Laptop..."

9.

On January 17, 2018,NADER departed Dubai, United Arab Emirates on a direct

flight aboard Emirates Airlines Flight 231 and arrived the same day at Washington-Dulles
International Airport in Dulles, Virginia. Washington-Dulles International Airport is located in
the Eastern District of Virginia.

10.

Upon arrival at Washington-Dulles International Airport, NADER declared to an

agent firom the United States Customs and Border Protection he was in possession ofthree
iPhones. NADER was later voluntarily interviewed by FBI agents regarding a matter unrelated
to child pornography. At the conclusion ofthe interview, NADER was informed ofthe existence
ofthe search warrant issued by this Court(1:18-SW-30)and the three iPhones were subsequently
seized. The iPhones seized from NADER were later specifically identified as:
a) iPhone 5 with serial number F2NJQ55RDTTN;
b) iPhone 6 with serial number FKlQLB5PGRYD;and

c) iPhone 7 with serial number F2LSD2XFHFY4.
11.

On January 17, 2018, Search Warrant 1:18-SC-00114 was sworn out in the United

States District Court for the District of Columbia and signed by Chief U.S. District Court Judge
Beryl A. Howell. The attachments to the search warrant specified the property to be searched as

 "iPhone 5 with serial number F2NJQ55RDTTN,iPhone 6 with serial number
FK1QLB5PGRYD,iPhone 6+ with serial number F2LSD2XFHFY4."

12.

On January 18, 2018, an order was filed with the United States District Court for

the District of Columbia to correct the identification ofthe iPhone with serial number

F2LSD2XFHFY4 to properly reflect it as an iPhone 7.
13.

The three iPhones seized from NADER were then forensically processed pursuant

to the search warrant for a matter not involving child pornography. At the completion ofthe

forensic processing, the digital forensic files derived from iPhone 7 with serial number
F2LSD2XFHFY4("IPHONE 7 FILES") were made available to the case agent in that other

matter for review using a forensic software package specifically designed to allow investigators
to review material without risk ofchanging or altering the evidence.

14.

On February 12,2018,the case agent for that other matter conducted an initial

review ofthe IPHONE 7 FILES for evidence unrelated to child pornography. During that

review,the case agent in that other matter uncovered multiple files which appeared to contain

child pornography. The potential child pomography matter was subsequently referred to my
office, and the case was assigned to your affiant.
15.

On March 5,2018,the IPHONE 7 FILES were saved to a Seagate Hard Drive

Model ST3750640AS with serial Number 5QD502SH. On March 16,2018, Search Warrant
1:18-SW-154 was sworn out in the United States District Court for the Eastern District of

Virginia and signed by US Magistrate Judge John F. Anderson. The attachments to the search
warrant specified the property to be searched as "digital forensic files derived from the iPhone 7
with serial number F2LSD2XFHFY4 seized from George Aref Nader on January 17,2018
currently located on a Seagate Hard Drive Model ST3750640AS with serial Number 5QD502SH

 that is in the custody ofthe Federal Bureau ofInvestigation in its Northern Virginia Resident
Office, 9325 Discovery Boulevard, Manassas, Virginia 20109." The items to be seized included,
but were not limited to, fhiits, evidence, and instrumentalities of"child pomography and child
erotica."

16.

Pursuant to the search warrant, your affiant conducted a review ofthe IPHONE 7

FILES located on a Seagate Hard Drive Model ST3750640AS with serial Number 5QD502SH.

During that review, your affiant located a number offiles that appear to be visual depictions of
minors engaged in sexually explicit conduct,including:

a)

Video #1: The video starts with two adult females and then cuts to a

prepubescent boy, approximately 7 years old, who is wearing a thawb (an ankle-length
Arab garment, usually with long sleeves, similar to a robe, kaftan, or tunic). The boy lifts

up the thawb exposing his penis. The boy then grabs his penis and shakes it. The boy is
laughing as he does this and then drops the thawb over his privates. The video then cuts
to an older male. The video has Arabic conversation from the adult females, child, and

adult male. The video is 12 seconds in length.

b)

Video #2: The video starts with a young boy, approximately three years

old, sitting on the floor with a small mechanical toy bunny that appears to knobbing up
and down up against the boy's penis. An adult removes the toy and exposes the boy's
penis. The boy reacts angrily and cries. The video is 4 seconds in length.
c)

Video #3: The video is an extended and reedited version of Video #2.

The video starts with a boy, approximately three years old, sitting on the floor with a
small mechanical toy bunny that appears to knobbing up and down up against the boy's
penis. An adult removes the toy and exposes the boy's penis. The child reacts angrily

 and cries. The portion of the video when the adult removes the toy, exposing the boy's
penis causing him to react angrily and cry is repeated twice over. The video is
approximately 13 seconds in length.

d)

Video #4: The video centers on a boy approximately thirteen(13)to

fourteen(14) years old seated on a wood plank floor naked from the waist down. A goat

is lying before him with all four legs tied. The boy appears to penetrate the goat from
behind with his penis. The goat reacts and makes noise each time the boy thrusts. The
boy looks at the camera and smiles. The video is 30 seconds in length.

e)

Video #5: The video centers on a boy approximately three(3)to four(4)

years old in a farmyard naked from the waist down. Baby goats surround him. The boy
looks at the camera before moving a few steps away. The baby goats follow. A hand

from off screen reaches into frame and lifts the boy's shirt. The baby goats move in and
suck on his penis. The boy looks at the camera. Laughing is heard. The video is 32
seconds in length.

f)

Video #6: The video centers on a boy approximately four(4)to six(6)

years old seated in a classroom with other children. The boy has the front of his pants
pulled down and is masturbating. A voice calls to the boy, who turns to the camera

before letting go of his penis and pulling up his pants. The video is 3 seconds in length.
g)

Video #7: The video centers on three boys between the ages of six(6)and

eight(8) years ofage standing naked on a stage. Music plays throughout the video.
Individual children approach the boys, touching the genitals ofeach in turn, make a

gesture, and then walk away. The video is 30 seconds in length.

 h)

Video #8: The video centers on a boy approximately three(3)to four(4)

years old in a chicken coop naked from the waist down. The boy holds a bucket on his
head while chickens surround him. After a few seconds one ofthe chickens pecks at the

boy's penis. He cries out in pain and is let out ofthe chicken coop by the camera
operator. The camera follows the boy. The camera operator speaks to the boy in a
language other than English and films his tears. The video is 30 seconds in length.

i)

Video #9: The video centers on a boy approximately three(3) years old.

The boy is seated, wearing a shirt but no pants. The boy holds a pair ofpliers pointed at
his genitals. Voices are heard speaking in a language other than English. The boy snaps

the pliers closed on his own genitals and cries out in pain. The voices laugh. The video
is 6 seconds in length.

j)

Video #10: The video centers on the nude buttocks ofa boy

approximately two(2)to three(3) years old. The boy is lying down on his chest. What
appears to be a number pad and buttons are drawn in black ink on the boy's buttocks. A
voice speaks in a language other than English and a finger presses the numbers and
buttons as ifthe boy were an Automated Teller Machine. The boy spreads his legs and
currency is removed from under the boy's penis. A child's face appears, laughing. The
video is 9 seconds in length.

k)

Video #11: The video centers on a boy approximately three(3)to four(4)

years old seated on a couch sharing a meal on a low table with older people. The boy

reaches for something from the table and is quickly pushed onto his back on the couch.
The crotch ofthe boy's pants splits open revealing his penis. The child begins to cry and

 urinates all over the food on the table. The older people react. The video is 6 seconds in
length.

k)

Video #12: The video is an extended and reedited version of Video #11.

The video centers on a boy approximately three(3)to four(4) years old seated on a

couch sharing a meal on a low table with older people. The boy reaches for something
from the table and is quickly pushed onto his back on the couch. The crotch ofthe boy's
pants splits open revealing his penis. The child begins to cry and urinates all over the
food on the table. The older people react. The video changes to black and white and

proceeds in slow motion with singing in a language other than English. The reedited
portion ofthe video when the boy's pants split revealing his penis, he cries, and urinates
all over the food on the table plays twice. The video is 16 seconds in length.
CONCLUSION

17.

Based on the foregoing, and on my training, experience, and participation in this

and other investigations, I submit there is probable cause to believe that on or about January 17,
2018,in the Eastern District of Virginia, GEORGE AREF NADER transported visual depictions
of minors engaged in sexually explicit conduct, in violation of Title 18, United States Code,
2252(a)(1) and (b)(1).

Ted P. Delacourt

Special Agent
Federal Bureau of Investigation
Sworn to before me this 19th day
of April, 2018
./S/.
John F. Anderson

United States Magistrate Judge
Alexandria, Virginia