Case 4:20-mj-70795-MAG Document 1 Filed 06/17/20 Page 1 of 26 FILED 1 DAVID L. ANDERSON (CABN 149604) United States Attorney 2 HALLIE HOFFMAN (CABN 210020) 3 Chief, Criminal Division 4 Jun 17 2020 ANDREW J. BRIGGS (CABN 294224) Special Assistant United States Attorney SUSANY. SOONG CLERK, U.S. DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA OAKLAND 5 1301 Clay Street, Suite 340S Oakland, California 94612 Telephone: (510) 637-3697 FAX: (510) 637-3724 andrew. briggs@usdoj.gov 6 7 8 9 Attorneys for United States of America 10 UNITED STATES DISTRICT COURT 11 NORTHERN DISTRICT OF CALIFORNIA 12 OAKLAND DIVISION 13 ) CASENO. UNITED STATES OF AMERICA, 4:20-mj-70795-MAG ) Plaintiff, ) ) ) ) 16 WILHANMARTONO, ) ) 17 ________________ 14 15 V. Defendant. NOTICE OF PROCEEDINGS ON OUT-OFDISTRICT CRIMINAL CHARGES PURSUANT TO RULES 5(c)(2) AND (3) OF THE FEDERAL RULES OF CRIMINAL PROCEDURE ) ) 18 19 Please take notice pursuant to Rules 5(c)(2) and (3) of the Federal Rules of Criminal Procedure 20 that on June 17 2020, the above-named defendant was arrested pursuant to an arrest warrant (copy 21 attached) issued upon an 22 • Indictment 23 D Information 24 D Criminal Complaint 25 D Other (describe) _ _ _ _ _ _ _ __ 26 pending in the Northern District of Texas, Dallas Division, Case Number 3-20CR0274-N . In that case (copy of indictment attached), the defendant is charged with a violation(s) ofTitle(s) 27 28 United States Code, Section(s): RULES 1 Case 4:20-mj-70795-MAG Document 1 Filed 06/17/20 Page 2 of 26 1 COUNT ONE: 18 U.S.C. § 2421A- Promotion and Facilitation of Prostitution and Reckless Disregard 2 of Sec Trafficking. 3 COUNT TWO: 18 U.S.C. §§ 371 , 1952(a)(3)(A) - Conspiracy To Engage in Interstate and Foreign 4 Travel and Transportation In Aid of Racketeering Enterprises-Facilitating Prostitution. 5 COUNTS THREE-ELEVEN: 18 U.S.C. §1952(a)(3)(A) - Interstate and Foreign Travel and 6 Transportation In Aid of Racketeering Enterprises-Facilitating Prostitution. 7 COUNTS TWELVE-TWENTY-EIGHT: 18 U.S.C. §1956(a)(l)(B(i) - Laundering of Monetary 8 Instruments. The maximum penalties are as follows: 9 10 COUNT ONE: Imprisonment not to exceed 10 years, or not to exceed 25 years for an aggravated 11 12 violation; fine not to exceed $250,000 ; a term of supervised release of not more than 5 years; 13 mandatory restitution; mandatory special assessment of $100.00; and forfeiture of property. 14 COUNTTWO: 15 Imprisonment not to exceed 5 years; fine not to exceed $250,000 ; a term of supervised 16 release of not more than 3 years; potential restitution; mandatory special assessment of $100; 17 and forfeiture of property. 18 COUNTS THREE-ELEVEN: Imprisonment not to exceed 5 years; fine not to exceed $250,000; a term of supervised 19 20 release of not more than 3 years; potential restitution; mandatory special assessment of $100; 21 and forfeiture of property. 22 Ill 23 Ill 24 Ill 25 26 27 28 RULES 2 Case 4:20-mj-70795-MAG Document 1 Filed 06/17/20 Page 3 of 26 1 COUNTS TWELVE-TWENTY-EIGHT: 2 Imprisonment not to exceed 20 years; fine not to exceed $500,000, or twice the value of 3 the property involved in the transaction, whichever is greater; a term of supervised release of not 4 more than 3 years; potential restitution; mandatory special assessment of $100; and forfeiture of 5 property. 6 Respectfully Submitted, 7 DAVID L. ANDERSON 8 9 Date: June 17, 2020 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 RULES 3 Case 4:20-mj-70795-MAG Document 1 Filed 06/17/20 Page 4 of 26 United States District Court Northern District of Texas Dallas Division UNITED STATES OF AMERICA WARRANT FOR ARREST V. Wilhan Martono CASE NUMBER: 3:20-cr-274-N To: The United States Marshal and any Authorized United States Officer MAG. CASE NUMBER: YOU ARE HEREBY COMMANDED to arrest Wilhan Martono and bring him or her forthwith to the nearest magistrate judge to answer a(n) Sealed Indictment Information Complaint Order of court Violation Notice Probation Violation Petition charging him or her with: Promotion and Facilitation of Prostitution and Reckless Disregard of Sex Trafficking; Conspiracy to Engage in Interstate and Foreign Travel and Transportation in Aid of Racketeering Enterprises- Facilitating Prostitution; Interstate and Foreign Travel and Transportation in Aid of Racketeering Enterprises-Facilitating Prostitution; Laundering of Monetary Instruments in violation of Title 18 United States Code, Section(s) 2421A; 371(18:1952(a)(3)(A); 1952(a)(3)(A); 1956(a)(1)(B)(i) Karen Mitchell, U.S. District Court Clerk Name and Title of Issuing Officer Signature of Issuing Officer U.S. Magistrate Judge Rebecca Rutherford 6/3/2020 Judge Date Dallas, TX Location s/C. Fisher (By) Deputy Clerk RETURN This warrant was received and executed with the arrest of the above-named defendant at DATE RECEIVED DATE OF ARREST NAME AND TITLE OF ARRESTING OFFICER SIGNATURE OF ARRESTING OFFICER pag?eb?Of?? We. ?rnmw - DISTRICT COURT -. .. .. - NORTHERN DISTRICT OF TEXAS . FILED IINQITITEHEUNIITED STATES DISTRICT COURT JUN "30 ORTHERN DISTRICT or TEXAS DALLAS DIVISION U. S. COURT . STATES OF AMERICA I No.3 i V. . INDICTMENT I The Grand Jury chargesall times material to this indictment: . . 1. The website cityxguide.com (?CityXGuide?) is a leading source of I prostitution advertisements in the Northern District of Texas and elsewhere. CityXGuide is part of a network of interconnected websites that includes cityxguide.com, cityxguidenet, cityxguideco, bodyrubshop.com, capleasures.com, and backpage.co (hereinafter, the ?Illicit Websites?). The Illicit Websites share the same login pages, backend servers, contact information, Privacy Policy, and Terms of Use. Together, the Illicit Websites have posted hundreds of thousands of proStitution advertisements and generated tens of millions of dollars in prostitution-related revenue. 2. The defendant, Wilhan Martono (?Martono?), is the creator, owner, manager, and operator of the Illicit Websites. Indictment-?Page 1 Case Documentl Filed 06/17/20 Illicit Websites 3-. The Illicit Websites allow promoters prostitutes, pimps, and brothels) to post and pay for prostitution advertisements. These advertisements generally include photographs of the person, usually a female, being advertised (often featuring fill] or partial nudity), along with a physical description, contact information, and a list of sexual services being offered. The Illicit Websites allow customers to view these advertisements, ?lter results by geography and category, and obtain contact information for the listed promoters. 4. From the homepage of each of the Illicit Websites, customers are able to I select the desired continent, country, state, or city from a list of hundreds of locations. The list of geographic regions includes the United States; Africa; Asia, Paci?c Middle East; Australia Oceania; Canada; Europe; and Latin America Caribbean. A list of ?Favorite Cities? at the bottom of the homepage includes Dallas, as well as San Jose, San Francisco, 'Los Angeles, Las Vegas, Boston, Chicago, Atlanta, Miami, Sacramento, San Diego, Orlando, Austin, and Salt Lake City. - I 5. After selecting a speci?c country or city from the homepage, customers are given the option to?lter advertisements by the following categories: (1) Adult Jobs; (2) Bedy Rubs (which links directly tolbodyrubshopcom); (3) Domination Fetish; - (4) Female Escorts; (5) Male Escorts; (6) Web Sex; (7) Phone Sex; (8) Shippers; and TransseXual. . . 6. After Selecting one or more of these categories, customers are able to view a ?ltered list of advertisements displayed in reverse chronological order. Indictment?Page 2 Of 26 Advertisements generally include photographs of the femalelbeing, advertised, along with a physical description of her anatomy (including a description of ?Breasts,? ?Breasts Type,? and ?Grooming Down Under?). Advertisements further specify who the female ?see[s]? men, women, and/or couples), whether she is available for or what her ?Work Hours? are, and what ?Method of Payments? are accepted. Advertisements also provide a name, age, location, and contact information for the female being advertised. 7. Under the ?Intimate Activities? category, advertisements specify the sexual services provided. The Illicit Websites provide a menu of ?Intimate Activities? to choose from, allowing promoters to select the services to be listed in a-particular advertisement by clicking a check box. Customers can then ?lter advertisements based on the services listed. The menu of ?Intimate Activities? includes the following: - ?Breast relief Russian,? ?Deep Throat,? ?Domination 4 mild ?Domination severe,? ?Face sitting,? ?Fantasy out?ts (onlrequest),? ?Girlfriend experience,? ?Intercourse Anal (Greek),? ?Intercourse Oral,? ?Intercourse Vaginal (F ?Kissing closed lips,? ?Kissing deep ?Lunch dinner dates,? ?Massage senSual,? ?Massage therapeutic,? ?Multiple sessions within date time . ?Oral ?Oral receiving ?Oral without condom I ?Pomstar experienCe ?Prostate Massage,? ?Rimming receiving,? ?Role- playing,? ?Service by two providers,? ?Striptease,? ?Submission,? ?Toy show,? ?Travel i extended dates,? ?Water sports giving,?,?Water Sports receiving,? ?Will entertain . couples,? and ?Will entertain women.? Indictment?Page 3 Case 4:20-mj-70795-MAG Document 1 Filed 06/17/20 Page 8 of 26 Case 3:20-cr-00274-N *SEALED* Document 1 *SEALED* Filed 06/02/20 Page 4 of 22 PageID 4 . "wr? Case Document 1 Filed 06/17/20 Page 9 of 26 advertisement will be posted simultaneously on cityxguide.com and backpage.co. Promoters can also post an advertisement without payment, but such an advertisement will be displayed only on cityxguide.net and not on any of the other Illicit Websites. 13. There are multiple types of advertisement upgrades available on the Illicit. - Websites. Option 1, entitled ?Move Ads to Top of Listings,? allows a promoter to display an advertisement in the ?Top Ad? section of the website at a cost of $5.00 an hour. Option 2, entitled ?Auto Repost Ad to TOP of Listings,? allows a promoter to I automatically display a previous advertisement in. the ?Top Ad? section four times a day at a cost of $20.00. Option 3, entitled ?Auto Repost Ad,? allows a promoter to display an advertisement at the top of the listings, but-below the ?Top Ad? section, ?at a set time of day at a cost of $8.00 for four days. Option 4, entitled ?Sponsor Ad for CityXGuide.Com,? allows a promoter to display an advertisement on the right side of the website in every page for the selected city at a cost of $4.00 per week. Wilhan Martono l4. Manono purchased the domain names for the Illicit Websites from GoDaddy, a business that sells domain names. _He purchased the domain for cityxguide.com on September 21, 2004. 15. On April 6, 2018, the Federal Bureau of Investigation (FBI) seized backpage.com, a website that was then the leading source of prostitution advertisements in the United States and elsewhere. On April 7, 2018, Martono registered the domain names lbackpage.com, cityxguides.c0m, cityxguide.co, cityxguide.0rg, cityxguide.xyz, cityxguide.online, and cityxguidelive. On May 11, 2018, Martono registered Indictment?Page 5 Page 10 of 26 newbackpage.co. He later registered bo?dyrubshopcom on October 6, 2018, and - capleasures.corn on April 12, 2019. i I I 16. Martono also purchased and maintained the servers that host the Illicit Websites. In order to manage and operate the Illicit Websites, Martono leased server space, purchased server equipment, and purchased blocks of Internet ProtOcol addresses, including more than 95 unique IP addresses. 17. Martono took numerous steps to obfuscate the true location of the servers hosting the Illicit Websites. Among other things, Martono purchased services that prevented any Domain Information GrOper query from identifying the IP address of the origin server hosting the Illicit Websites. Martono also purchased a . proxy service to route website traf?c through an IP address in Europe before it reached . the origin server. Websites. Among other things, Martono used CardCash, a third-party gift card reseller, to exchange batches of gi? cards uploaded to the Illicit Websites for US. currency. I Martono often used a Virtual Private Network to mask his true IP address while conducting these transactions. He would then funnel the money obtained from his transactions with CardCash through a netvvork of bank accounts to be used for personal expenses and to maintain the Illicit Websites; Since 2018, Martono has earned more than $21,000,000.00 in proceeds from the Illicit Websites. Indictment?Page 6 18. Martono also took steps to conceal the proceeds he derived ?om the Illicit Terms of Use 19. The Illicit WebSites share the same contact-information, Privacy Policy, and Terms of Use. I 20. The ?Noti?cation of In?'ingement? and ?Contact Us? sections of the . A Terms of Use purport to identify contact information for the Illicit Websites. But the physical address listed (115 Repulse Bay Road, Apartment 755, Repulse Bay, Hong Kong) is associated with a residential unit in a Hong Kong apartment building. The phone number listed (+852 is associated with aproperty management ?rm in Hong Kong. The faxnumber listed is the same as the phone number. 21., The ?User Conduct? section of the Terms of Use lists certain requirements that customers and promoters agree to follow. Section 4(a) of the Terms of Use purports to prohibit ?[p]osting adult content or explicit adult material unless: such material is speci?cally permitted in designated adult categories and permitted under applicable federal, state, and local law; and (ii) you are at least 18 years of age or I older and not considered to be a minor in your state of residence.? But the Illicit Websites openly advertise commercial sex acts inhundreds of jurisdictions where prostitution is illegal. For example, the CityXGuide homepage lists a total of 14? ?Favorite Cities,? including Dallas, Texas. Prostitution is illegal in Texas and in all 14 of the ?Favorite Cities? listed. 22. Section 4(b) of the Terms of Use purports to prohibit ?obscene or lewd and lascivious graphics or photographs which depict genitalia or actual or simulated sex acts?. But the majority of advertisements on the Illicit Websites include photographs Indictment?Page 7 that depict full or partial nudity and obscene, lewd, and lascivious depictions of female genitalia. - I 23. Section 4(e) of the Terms of Use purports to prohibit ?[p]osting any solicitation directly or in ?coded? fashion for any illegal service exchanging sexual favors for money or other valuable consideration.? But the menu of ?Intimate :Activities? provided by the Illicit?Websites includes dozens of sex acts described with . i code words and without them. 24. Sections 4(d) and 4(e) of the Terms of Use purport to prohibit ?[p]osting any material . . . that exploits minors in any way? or ?constitutes or assists in human I 1 But numerous victims of child sex traf?cking have been identi?ed in i I CityXGuide advertisements, including a 13-year?old Jane Doe who was identi?ed based on a CityXGuide advertisement and recovered in the Northern Districtof Texas in November 2019. '25. Martono frequently corresponded with promoters who complained about the placement of their advertisements or other. technical issues on the Illicit Websites. That correspondence often included the URL address of a speci?c advertisement or screenshots from one of the Illicit Websites. For example, in a May 5, 2019 email . exchange, Martono sent the promoter a screenshot of a list of CityXGuide including one with the title, AM READY FOR In an email exchange with Martono on January 22, 2019, another promoter described CityXGuide I as ?[t]aking over from where Backpage left off.? Indictment?Page 8 Lase Document 1 Filed 06/17/20 Page 13 0t 26 26. Martono also received numerous emails from federal, state, and local law enforcement of?cers across the cduntry, informing him that CityXGuide was being used to facilitate sex traf?ckingvand child exploitation. ?Martono also received numerous subpoenas for subscriber information, IP addresses; and other records related to these investigations. Indictment?Page 9 Case Document 1 06f17/20 Page I4 0t 26 Count One I Promotion and Facilitation of Prostitution and Reckless Disregard of Sex Traf?cking (Violation of 18 U.S.C. 2421A) 27. The factual allegations in Paragaphs 1?26 are incorporated by reference and re-alleged as though fully set forth herein. 28. From on or about April 1.1, 2018, and continuing through the present, in the Northern District'of Texas and elsewhere, the defendant, Wilhan Martono, with the intent to promote and facilitate the prostitution of another person, and using a facility and means of interstate and foreign commerce and in and affecting interstate and foreign commerce, did own, manage, and operate an interactive computer service, as that term is de?ned in 47 U.S.C. 230(t), and did promote and facilitate the prostitution of ?ve or more persons, and did so in reckless disregard of the fact that such conduct contributed to in violation of 18 U.S.C. 1591(a). In violation of 18 U.S.C. 2421A. Indictment?Page 10 - - i 753W . Count Two . Conspiracy To Engage in Interstate and Foreign Travel and Transportation In Aid of Racketeering Enterprises?Facilitating Prostitution (Violation of 18 U.S.C. 371 (18 U.S.C. 1952(a)(3)(A)) 29. . The factual allegations in Paragraphs 1?28 are incorporated by reference and re-alleged as though fully set forth herein. I 30. Beginning in or around 2010, the exact date being unknown to the Grand Jury, and continuing through the present, in the Northern District of Texas and elsewhere, the defendant, Wilhan Martono, did knowingly and willfully combine, conspire, confederate, and agree with other persons known and unknown to the Grand Jury, to commit an offense against the United States, to wit: Interstate and Foreign .- Travel and Transportation in Aid of Racketeering Enterprises?Facilitating Prostitution, in violation of 18 Obiect of the ConspiracY 31. The object of the conspiracy was to obtain money from the promotion and facilitation of prostitution. - Manner and 'Means of the Conspiracv 32. The manner and means of the conspiracy are described in Paragraphs 26 above, incorporated by reference and re-alleged as though fully set forth herein.? . Indictment?Page ll Documentl I?Iled 06/17/20 Wage 16 of 26 Overt Acts 33. Overt acts were committed in ?irtherence of the conspiracy, including but not limited to those described in Paragraphs 144?18, incorporated by reference and re- alleged as though fully set forth herein. I In violation of 18 use. 371 (13 U.S.C. Indictment?Page 12 . Counts ThreevEleven Interstate and Foreign Travel and Transportation in Aid of i Racketeering Enterprisestacilitating Prostitution (Violation of 18 U.S.C. 1952(a)(3)(A)) 34. The factual allegations in Paragraphs 1?33 are incorporated by reference I and re-alleged as though set forth herein. 35. On or about the dates set forth below, each instance constituting a separate count of this indictment in the Northern District of Texas and elsewhere, the defendant, Wilhan Martono, and other persons known and unknown to the Grand Jury, did use the mail and any facility in interstate and foreign commerce with intent to otherwise promote, manage, establish, carry on, and facilitate the promotion, management, establishment, and carrying on of an unlawful activity, to wit: prostitution offenses 1n violation of the laws of the State' in which they are committed and of the United States, including but not limited to Texas Penal Code 43.02, and therea?er performed and attempted to perform an act that did promote, manage, establish, carry on, and facilitate the promotion, management, establishment, and carrying on of the unlawful activity, on or about the listed dates, as follows: Count Date Description Three November 4, 2019 Publish advertisement entitled, BUNNY 1 . READY TO HOP . Four March 4, 2020 Publish advertisement entitled, ?SeXy a YoUr New AddIctTiO Five March 4, 2020 Publish advertisement entitled, NIB YOUR FRESH - FABULOUSLY WET, FETISH Indictment?Page 13 Document 1' "Fife?d 06/17/20 Page'18' of 26 Count Date Description Six March 4, 2020 Publish advertisement entitled, true - EVERYTHING IS BIGGER IN TEXAS LETS . Seven March 4, 2020 Publish advertisement entitled, DOUBLESTACK THICK CARAMEL I - BIG OL BOOTY HEAVENLY I Eight March 4, 2020 Publish advertisement entitled, ?Dallas Odessa 3 INCALLS Greek AVAILABLE (NO BARE) Kinky Sex and All FetiShes Nine I March 11, 2020 4 Publish advertisement entitled, ?Sensual Perfection? - VIP EXperience with a Charming model? Ten March 11, 2020 Publish advertisement entitled, ?Asian Beautiful 1 Sexy girls REAL PICS BBJ GEL GFE 69 ASIAN NEW FACE BIG SURPRISE call Eleven March 11, 2020 Publish advertisement entitled, NOTCH 100% . REAL MUST SEE ST HAVE MUST i In violation of 18 use. Indictment?Page 14 Reckless Disregard of Sex Traf?cking in violation 'of 18 U.S.C. 2421A, and Interstate Prostitution in violation of 18 U.S.C. l952(a)(3)(A), knowing that the transaction was Case??f?nn??el 795m Counts Twelve?Twentv?Eight Laundering of Monetary Instruments - (Violation of 18 U.S.C. . 36. i The factual allegations in Paragraphs 1?35 are incorporated by reference and re?alleged as though fully set forth herein?. '37. On or about the dates set forth below, each instance constituting a separate count of this indictment, in the Northern District of Texas and elsewhere, the defendant, Wilhan Martono, knowing that the property involved in a ?nancial transaction represented the proceeds of some form of unlawful activity, did conduct and attempt to conduct such a ?nancial transaction which in fact involved the proceeds of a speci?ed unlaw?ll activity, to wit: Promotion and Facilitation .of Prostitution and and Foreign Travel and Transportation in Aid of Racketeering Enterprises?Facilitating designed in whole or in part to conceal and disguise the nature, location, source, ownership, and control of the proceeds of such speci?ed unlaw?rl activity, as follows: Count -Date - - Financial Transaction Twelve November 25, 2018 Transfer of approximately 200 Target gift cards totaling $6,965.00 to CardCash in exchange for $5,808.60 in U.S. currency. Thirteen November 25, 2018 Transfer of approximately 200 Target gift cards totaling $5,165.00 to CardCash in exchange for $4,338.60 in U.S. currency. Indictment?Page 15 Case 1?1-LiI?ed 06/17/20 Page 20 Of 2b Count Date Financial Transaction Fourteen November 25, 2018 Transfer of approximately 200 Target gift cards totaling $5,225.00 to CardCash in exchange for $4,389.00 in US. currency. Fi?een November 25, 2018 Transfer of approximately 200 Target gift cards totaling 295. 00 to CardCash in exchange for $5287. 80 U. S. currency. Sixteen November 25, 2018 Transfer of approximately 200 Target gift cards totaling $7,070.00 to CardCash in exchange for $5,770.80 in US. currency._ Seventeen November 2-5, 2018 Transfer of approximately 200 Target gift cards totaling $6,450.00 to CardCash in exchange for $5,418.00 in US. currency. Eighteen November 27, 2018 Transfer of approximately 200 Target gi?: cards? totaling $6,260.00 to CardCash in exchange for $5,423.16 in US. emrency. Nineteen November 27, 2018 Transfer of approximately 200 Target gift cards totaling $6,760.00 to CardCash in exchange for $5,678.40 in US. currency. Twenty November 27, 2018 Transfer of approximately 200 Target gift cards totaling $7,585.00 to CardCash in exchange for $6,371.40 in US. currency. Twenty- One November 27 2018 Transfer of approximately 200 Target gift cards totaling $5,280.00 to CardCash in exchange for $4,435.20 in US. currency. Twenty- . Two November 27, 2018 Transfer of approximately 200 Target gift cards totaling $4,940.00 to CardCash in exchange for $4,149.60 in 1.1.5. currency. Twenty- Three November 27, 2018 Transfer of approximately 200 Target gift cards totaling $4,300.00 to CardCash in exchange for $3,612.00 in?U.S. currency. Indictment?Page 16 Count Date Financial Transaction Twenty? January 28, 2019 Transfer of approximately 152 Walrnart gift cards Four - to CardCash in exchange for $6,364.56 in UHS currency. Twenty- February 4, 2019 Transfer of approximately 196 Walmart gift cards Five totaling $10,439.84 to CardCash in exchange for $9,554.06 in US. currency. Twenty- March 18, 2019 Transfer of approximately 222 Walmart gm cards Six totaling $11,246.92 to CardCash in exchange for $10,144.84 in U.S.?currency. Twenty- April 1, 2019 Transfer of approximately 219 Walmart gift cards Seven totaling $12,599.58 to CardCash in exchange for $10,933.81 in US. currency. Twenty: May 20, 2019 Transfer of approximately 328 Walmart gift cards Eight totaling $17,705.93 to CardCash in exchange for $16,038.17 in US. currency. In'violation Indictment?'Page 17 Case "Documen?tmlm?led 06/17/20 Pager?rof?26-?mmfm?W __Case 4220-mj- lU Document 1 I-lled 06/17/20 Page 22 OT 26 ?Criminal Forfeiture (18 U.S.C. 2428(a); 18 U.S.C. 981(a)(1)(C) and 28 U.S.C. 2461(c); and 18 U.S.C. I I Upon conviction for the offense alleged in Count One of the indictment, the defendant, Wilhan Martono, shall forfeit to the United States, pursuant to 18-U.S.C. 2428(a), anyproperty, real or personal, used, or intended to be used, to commit or to facilitate the commission of the violation; and any property, real or personal, . constituting or derived ?'om any proceeds obtained, directly or indirectly, as a result of the violation. Upon conviction for any of the offenses alleged in Counts Two through Eleven of the indictment, the defendant, Wilhan Martono, shall forfeit to the United States, pursuant to 18 U.S.C. 981(a)(1)(C) and 28 U.S.C. 2461(0), any property, real or personal, which constitutes or is. derived from proceeds traceable to the respective violation(s). Upon conviction for any of the offenses alleged in Counts Twelve through Twenty-Eight of the indictment, the defendant, Wilhan Martono, shall forfeit to the United States, pursuant to 18 U.S.C. 982(a)(1), any property, real and personal, involved in, or traceable to property involved in, the respective violation(s). The property subject to forfeiture includes, but'is not limited to, the following: a. All funds contained in checking account in the name of Wilhan'Martono at Bank of America. b. All funds contained in checking account in the name of Host Online LLC at Bank of America. c. . All funds contained in checking account in the name of Wilhan Martono at Wells Fargo Bank. Indictment?Page 18 case Document 1 I?Ileo 0b/17/20 Page 23 0t 26 d. All funds contained in checking account 1n the name of Wilhan Martono dba Gamers and Gifts at Union Bank. e. All funds contained 1n checking account in the name of Wilhan Martono at UniOn Bank. f. All ?mds contained in account in'the name of wnhan Martono at TD Arneritrade. g. All ?inds contained 1n savings account 1n the name of Wilhan Martono at Barclays Bank Delaware. h. All ?mds contained in savings account 1n the name of Wilhan Martono at Goldman Sachs. i. All funds contained in checking account 1n the name of Wilhan Martono and Chenny Atmadja at JPMorgan Chase Bank. j. All funds contained in checking account in the name of Wilhan Martono dba Gamers and Gi?s at IPMorgan Chase Bank. k. All funds contained in checking account in the name of Wilhan MartOno at HSBC Bank. 1. All funds contained in savings account in the name of Wilhan Martono at HSBC Bank. - Hi. All things of value, including precious metals and bullion, purchased in 2018 and 2019 by, for, or on behalf of Wilhan Martono from Silver Bullion Pte LTD (UEN 200907537M) in Singapore. n. All things of value, including precious metals and bullion, purchased in 2018 and 2019 by, for, or on behalf of Wilhan .Martono from Silver Bullion Pte LTD (UEN 20090753 7M) in Singapore and stored, maintained, or housed at Safe House SG Pte (UEN 2013-26241Z) in Singapore. If any of the above-describedforfeitable property, as a result of any act or omission of the defendant, cannot be located upon the existence of due diligence; has been transferred or sold to, or deposited with, a third party; (0) has been placed beyond the jurisdiction of the court; has been substantially diminished in value; 0r . has been commingled with other property Which cannot be divided without dif?culty, the United States intends, pursuant to 21 U.S.C. 853(p), to seek the Indictment?Page 19 Case Documentl Filed 06/17/20 Page 2?rof26 forfeiture of other property from the defendant up to the value of the forfeitable property described in this forfeiture notice; FOREPERU ERIN NEALY COX UNITED TE ATTORNEY Siddharth Texas Bar . 2407-27 91 Rebekah etts . Texas Bar No. 24074883 John de la Garza Texas Bar No. 00796455 Assistant United States Attorneys 1100 Commerce Street, Third Floor Dallas, Texas 75242-1699 Telephone: 214-659-8744- Facsimile: 214-659-8800 Email: siddharth.mody@usdoj.gov Indietment?Page 20 a . IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION THE UNITED STATES OF AIVIERICA WILHAN MARTONO INDICTIVIENT 18 U.S.C. 2421A Promotion and Facilitation of Prostitution and Reckless Disregard of Sex Traf?cking I (Count 1) 18 U.S.C. 371 (18 U.S.C. 1952(a)(3)(A) Conspiracy to Engage in Interstate and Foreign Travel and Transportation In Aid of Racketeering Enterprisestacilitating Prostitution (Count 2) (18 U.S.C. 1952(a)(3)(A) i Interstate and Foreign Travel and Transportation in Aid of i Racketeering Enterprises?Facilitating Prostitution (Counts 3 through 11) 18 U.S.C. 1956(a)(1)(B)(i) .1 Laundering of Monetary Instruments (Counts 12 through 28) I - 18 U.S.C. ?2428(a); 18 U.S.C. and 28 U.S.C. 2461(c); and 18 U.S.C. 982(a)(1) Forfeiture Notice 28 Counts i [remainder of page left intentionally blank] 3 ?h - 136117720 '0 Q. (C (T. 3% A true bill rendered Filed in open court this Li day of June, 2020. mm JUDGE N0 Criminal Matte nding Warrant to be Issued