UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

CASE NO. __ 1_:2_2_-m ____ j-_0_28_0_6_-L_o_u_is ___ _ 

UNITED STATES OF AMERICA 

vs. 

ALAN LI, a/k/a "Michael Chen," 

Defemlant. 

----------__,c....,R""I"""IV'""'u,..,.N...-'.I.AL covER SHEET 

1. Did this matter originate from a matter pending in the Northern Region of the United States 

Attorney's Office prior to August 8, 2014 (Mag. Judge Shaniek Maynard)? No 

2. Did this matter originate from a matter pending in the Central Region of the United States 

Attorney's Office prior to October 3, 2019 (Mag. Judge Jared Strauss)? No 

Respectfully submitted, 

JUAN ANTONIO GONZALEZ 

UNITED STATES ATTORNEY 

BY: ls/Katherine W. Guthrie 

Katherine W. Guthrie 

Assistant United States Attorney 

Court ID No. A5502786 

99 Northeast 4th Street 

Miami, Florida 33132-2111 

Tel: 786-390-8262 

Email: Katherine.Guthrie@usdoj.gov 

Case 1:22-cr-20224-BB Document 3 Entered on FLSD Docket 05/12/2022 Page 1 of 13
AO 91 (Rev. 08/09) Criminal Complaint 

UNITED STATES DISTRICT COURT 

United States of America 

V. 

ALAN LI, 

a/k/a "Michael Chen," 

Defendant(s) 

for the 

Southern District of Florida 

) 

) 

) 

) 

) 

) 

Case No. 1 :22-mj-02806-Louis 

CRIMINAL COMPLAINT BY TELEPHONE OR OTHER RELIABLE ELECTRONIC MEANS 

I, 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 March 12, 2022 - May 10, 2022 in the county of Miami-Dade 

-~S~o~ut=h=e~rn~_ District of --~F~lo=n=·d=a~--, the defendant(s) violated: 

Code Section 

18 U.S.C. § 1594(a) 

18 U.S.C. § 2422(b) 

Offense Description 

Attempted Sex Trafficking of a Minor 

Attempted Coercion or Enticement of a Minor 

This criminal complaint is based on these facts: 

SEE ATTACHED AFFIDAVIT. 

~ Continued on the attached sheet. 

Kimberly Jennette, FBI Special Agent 

Printed name and title 

in the 

Attested :ri~. 4) b Face Time to by the Applicant in accordance with the requirements ofFed.R.~y __________ _ 

Date: May 12 2022 

Judge 's signature 

City and state: Miami Florida Hon. Lauren F. Louis, U.S. Magistrate Judge 

Printed name and title 

Case 1:22-cr-20224-BB Document 3 Entered on FLSD Docket 05/12/2022 Page 2 of 13
AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT & ARREST 

I, Kimberly Jennette, being first duly sworn, hereby depose and state as follows: 

INTRODUCTION AND AGENT BACKGROUND 

1. I have been a Special Agent with the Federal Bureau of Investigation ("FBI") since 

March 2018. I am an investigative or law enforcement officer of the United States within the 

meaning of Title 18, United States Code, Section 2510(7). That is, I am an officer of the United 

States 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, 2423, 

2251, and 2252. 

2. I currently serve as part of the Crimes Against Children group and the FBI Child 

Exploitation Task Force in the FBI's Miami Field Office. My duties include investigating crimes 

involving the sexual exploitation of minors, including sex trafficking, child pornography, and 

enticement violations. 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 several child 

exploitation investigations. I have also executed search warrants that have led to seizures of child 

pornography and undercover operations to recover juvenile victims of sex trafficking. 

3. I submit this Affidavit in support of a criminal complaint charging ALAN LI, a/k/a 

"Michael Chen" ("LI"), a 26-year-old Asian male with date of birth July 7, 1995, a social security 

number ending in 5248, who currently resides at 600 15th Street, Apt. 6, Miami Beach, Florida 

33139, with the following offenses: (1) Attempted Sex Trafficking of a Minor Less Than 14 Years 

of Age, in violation of Title 18, United States Code, Section 1594(a); and (2) Attempted Coercion 

and Enticement of a Minor, in violation of Title 18, United States Code, Section 2422(b ). 

Case 1:22-cr-20224-BB Document 3 Entered on FLSD Docket 05/12/2022 Page 3 of 13
4. The facts and information in this Affidavit come from my own personal 

observations, my training and experience, and information obtained from other law enforcement 

personnel, investigators, witnesses, and documents. This Affidavit does not include every fact and 

circumstance known to me, but only the facts and circumstances sufficient to establish probable 

cause. 

PROBABLE CAUSE 

5. On or about March 12, 2022, the FBI received a National Hotline Tip from a female 

in Columbus, Ohio. The complainant ("S.M.") stated an acquaintance, LI, had reached out via 

Snapchat and asked her to help his friend MICHAEL CHEN ("CHEN") find young girls in the 

Miami, FL area. The following is a portion of Snapchat conversations between LI, username 

@alanli771995, and S.M. that occurred on or about March 12, 2022, provided by S.M.: 

LI You said you were trafficked right? 

LI My friend wants to meet young girls and he is willing to 

pay, can you help him out? 

S.M. Well, put him in touch with f mle here on Snapchat. 

. .. LI Ok lemme see if he has Snap 

LI One sec 

LI Ok I had him make an account 

LI He's gonna add you 

LI His name is Michael btw 

7. Later that day, S.M. received messages from CHEN, utilizing Snapchat username 

Mikey_ chen124. A portion of those conversations are below: 

CHEN Hi I'm mike, alan gave me your contact 

... CHEN But I also like younger girls 

CHEN If you know what I mean 

S.M. What age 

CHEN Ideally 8-15 

... S.M. Do you have some pictures of yourself? Do you also 

have any experience with this before? 

Case 1:22-cr-20224-BB Document 3 Entered on FLSD Docket 05/12/2022 Page 4 of 13
CHEN 

8. S.M. stated she had met LI approximately a year ago in Columbus, Ohio through a 

dating/escort site. The two got together for a night and spoke about her having been trafficked 

when she was a minor. S.M. and LI lost contact for about a year until he reached out online on or 

about March 12, 2022. S.M. identified LI as ALAN LI, and told law enforcement that she knew, 

through social media, LI was working at Mount Sinai Hospital in Miami Beach. S.M. said she and 

LI followed each other on Instagram. S.M. told law enforcement she believed LI and CHEN were 

the same person based on the nature of the conversations, LI acting as an intermediary, and the 

short amount of time between LI's request and CHEN's first message. After further investigation, 

S.M. reviewed the photo of LI from the website of Mount Sinai Medical Center in Miami Beach, 

FL. S.M. confirmed that the LI in the photo from Mount Sinai's website is the same LI that she 

has met and communicated with via Snapchat. 

9. Additionally, on March 16, 2022, law enforcement learned that S.M. had also 

contacted Mount Sinai to report the conversations that she had with LI. J.P., Director of Security 

for Mount Sinai Medical Center, contacted the FBI to report his conversation with S.M. J.P. 

provided LI's information, which was recorded as: Alan Li, DOB: 7/7/1995, telephone number 

614-537-6514, residential address 600 15th Street, Miami Beach, FL 33139. J.P. also provided Li's 

Instagram username as alan_li1995. The next week, J.P also gave law enforcement a copy ofLI's 

personnel file, which included his schedule, network activity on Mount Sinai's computers, and a 

personal email address of alanli_ oh7@yahoo.com. 

10. On March 22, 2022, S.M. consented to allow an FBI Online Covert Employee 

("OCE") to take over her Snapchat account "PrivateSavvy2.0" to continue talking to CHEN and 

LI. When the OCE opened S.M. 's Snapchat account on March 22, 2022, Snapchat data showed 

Case 1:22-cr-20224-BB Document 3 Entered on FLSD Docket 05/12/2022 Page 5 of 13
CHEN had not reached out to S.M. in four days, but LI had made contact asking for updates on or 

about March 21, 2022. On March 22, 2022, the OCE messaged LI via S.M. 's Snapchat and 

provided LI with a "trafficker's" telephone number. The "trafficker," the same OCE utilizing 

another telephone number, received a text message from LI shortly thereafter. LI used a telephone 

number, 305-239-8165, whose registered provider is Bandwidth, Inc. ("Bandwidth"), a 

telecommunications company. Portions of the conversation are below: 

LI I heard you can set me up with some girls? 

OCE Perhaps. What exactly you looking for? 

LI 10-14 in the Miami area 

OCE fS.M.l said this was for your buddy? 

OCE Mike? 

LI Yessir 

OCE I'll speak with him directly then ifhe 's interested. I don't 

mess with middlemen 

11. Within a few minutes, CHEN initiated contact with the OCE via another Bandwidth 

registered telephone number, 786-408-6520: 

CHEN What do you have available? 

OCE Girl or boy? 

CHEN Girl 

OCE Got a 9, 12, and 15 depending on what kind of service 

you want 

CHEN Full service bareback available? 

OCE For the 9 and 12. Gotta wrap up for the 15 

OCE No anal with the 9 

CHEN Ok let's do the 12 

... 

CHEN So what do I need to do in order to make this happen? 

12. CHEN and the OCE then discussed payment and rates. CHEN asked to spend "1 

hour" with the 12-year-old girl. The OCE told CHEN he would need to pay half up front and that 

it would be "$500 total for bareback sex with 12-year-old. Down payment of $250 ... "to be paid 

through CashApp. As they discussed payment, CHEN asked ifhe could pay with cash or Bitcoin. 

Case 1:22-cr-20224-BB Document 3 Entered on FLSD Docket 05/12/2022 Page 6 of 13
CHEN explained CashApp would not allow him to send money without providing his social 

security number. He asked if he could have someone else pay for him, and the OCE said they 

would work it out later: 

OCE ... we will figure something out [regarding payment]. 

What kind of long term set up vou looking for? 

Cl:IEN Ok no problem 

CHEN And like a live in situation 

OCE You ever had that? 

CHEN Ya once before 

CHEN Do you do that? 

OCE Yes but I keep that very private. What was your previous 

setup? 

CHEN I just had her live with me and I provided everything 

OCE Fuck her? 

CHEN Of course 

OCE How old was that one? This 12 I got will do anything but 

had her a while now 

CHEN 13 

... 

OCE . . . . Who's kid was it? 

CHEN Just someone I knew in Ohio who set it up for me 

13. The OCE and CHEN then discussed the possibility of CHEN purchasing a minor 

to live with him. CHEN asked whether he should pay in monthly payments or a lump sum. The 

OCE then asked CHEN how he would keep the 12-year-old "quiet and unseen": 

CHEN Ya she will stay in the house 

OCE And not get out while your gone 

CHEN Ya I mean I'll keep everything locked up but she is well 

behaved I assume? 

OCE Under my control she is 

CHEN Gotcha 

.CHEN Well l'll make sure everything is safe 

OCE How? 

CHEN I keep mv place prettv safe and locked up 

... 

CHEN And what's your monthly rate? 

Case 1:22-cr-20224-BB Document 3 Entered on FLSD Docket 05/12/2022 Page 7 of 13
OCE I've only ever sold one girl for permanent use and that 

was a one time payment. Once I sell her she may yours 

so idk if I want monthlv oavments linking me to vou 

CHEN Gotcha 

CHEN How much did vou sell for? 

OCE $20K 

CHEN Ok that's reasonable. Just need to see the girl first 

obviously lol 

FOLLOW-UP INVESTIGATION 

14. On March 23, 2022, law enforcement served a subpoena on Bandwidth for the 

subscriber information associated with telephone numbers 305-239-8165 and 786-408-6520, as 

used by LI and CHEN in the above conversations. Bandwidth's records showed both telephone 

numbers belong to Ad Hoc Labs, Inc (dba Burner). Burner, a mobile app, advertises itself as a 

"simple and effective way to get extra phone numbers for [a user's] phone, keeping their primary 

phone number private." Burner says you can "[ c ]reate as many simultaneous local numbers as you 

need, in any U.S. or Canadian area code." 

15. Law enforcement subpoenaed Snapchat for records associated with the accounts of 

LI (username @alanli771995) and CHEN (username @Mikey _chen124). Snapchat returns 

showed CHEN's account was created from IP address 207.244.181.239 ("IP ADDRESS") on 

March 12, 2022, the same date LI reached out to S.M. about finding young girls. The Snapchat 

returns also showed CHEN's account was created with telephone number 305-239-8165, the same 

telephone number LI used to contact the OCE. 

16. On March 30, 2022, law enforcement found a Telegram Mobile account with 

display name "Michael Chen," which was associated with Li's known telephone number, 614-

537-6514. 

17. Additionally, IP activity showed that, on several occasions, alanli771995 logged 

out of Snap chat and within a few seconds Mikey_ chenl 24 logged into Snapchat or vice versa from 

Case 1:22-cr-20224-BB Document 3 Entered on FLSD Docket 05/12/2022 Page 8 of 13
the same IP address. For example, Mikey_chen124 logged out ofSnapchat, on March 12, 2022, at 

22:26:21 UTC, and alanli771995 logged into Snapchat at 22:26:25 UTC, both from the IP 

ADDRESS. 

18. On April 4, 2022, CHEN texted the OCE using a new Bandwidth telephone number 

305-239-8515: 

CHEN Ok I'll get the cash aoo sent to vou 

CHEN Can vou send the receiving address again? 

OCE Mike? 

CHEN Ya what's up 

CHEN Sorry I had to get a new burner phone my old one ran out 

lol 

19. During the conversation, the OCE and CHEN again discussed payment for the 12-

year-old girl that CHEN had requested previously. The OCE provided a CashApp ID. 

20. On April 7, 2022, the OCE told CHEN that due to the CashApp issues, they could 

just meet in person. A portion of the conversation is below: 

OCE Hey man, if the cashapp is going to be a huge issue. We 

can just meet and talk first to make sure your cool. 

You've been vouched for so I'm not super worried 

CHEN Ya I'm having a hard time foruring it out 

CHEN And va I'm down to iust meet up 

OCE Aight. We are in Atlanta but should be back late Sunday 

night. Once she gets some sleep and maintenance should 

be good for Monday or Tuesday 

CHEN Cool I'm down for that 

... 

OCE She should be available for you after the weekend. Can 

do an hour and go from there. What you into so I can prep 

her 

CHEN I just want to go raw with cum inside 

OCE Aight that's easy. Nothing rough. No scars or bruises. 

Obvious but have to say it 

CHEN Yup that's not a problem I'm not rough like that 

OCE Cool. We are going to come back there Sunday night. I 

gotta pick a spot to work next week. What's close to you? 

CHEN I'm near south beach 

Case 1:22-cr-20224-BB Document 3 Entered on FLSD Docket 05/12/2022 Page 9 of 13
21. In the same conversation, CHEN asked the OCE about how their meeting would 

work and where the OCE was based: 

CHEN Where do vou usually do this out of? 

CHEN Hotel! 

CHEN ? 

... CHEN You're based in Miami tho? 

OCE Yea Miami / Ft Laudy but mostly Miami. Come up to 

Atlanta a lot to 

CHEN Perfect 

CHEN Excited to meet up 

22. CHEN scheduled to meet the OCE and the 12-year-old girl on April 12. But on the 

evening of April 12, CHEN cancelled, saying he had to work late. 1 CHEN asked, "Can we schedule 

for tomorrow? It just works so much better for my schedule." 

23. The following day, April 13, 2022, LI-not CHEN-reached back out to S.M. via 

Snapchat. At this point, the OCE had relinquished control of S.M. 's Snapchat account. When S.M. 

replied on April 16, LI asked about the trafficker she had put him in touch with: 

LI Was mainly wondering about this dude you 

recommended for me and mv friend Michael in So FL 

LI He's trustworthy ri!!ht? 

., .. LI . . . I'm not trying to be sketch but I'm trying to be careful 

since I don't know him. 

S.M. I get it 

LI So I should hit him up then? 

24. From on or about April 16, 2022, to April 28, 2022, CHEN and the OCE did not 

communicate. On April 29, 2022, CHEN and the OCE resumed messaging when the OCE told 

CHEN, "Got some high-end girls in town working the beach this weekend and next for Fl. If you 

1 During this time, law enforcement were surveilling LI who had already left work that day. 

Case 1:22-cr-20224-BB Document 3 Entered on FLSD Docket 05/12/2022 Page 10 of 13
know any players send them my way." From on or about April 29, 2022, through May 1, 2022, 

CHEN and the OCE messaged intermittently, texting about what girls were available, what ages, 

and pricing. 

25. On May 2, 2022, CHEN asked the OCE if any girls were available: 

CHEN Anvone availabletonight? 

OCE 12and 15 m 

CHEN Anvoics? Ans where vou at? 

... 

OCE You seen the 12 I'll get vou 15 in a min 

CHEN Ok nice. lemme know 

26. After CHEN and the OCE discussed the rates for the 15-year-old girl, CHEN 

messaged, "Ya let's do it." He told the OCE he would let him know when he was on his way. The 

OCE told CHEN, "You waste my time again we are done. I have a business to run." 

27. After the OCE sent that text to CHEN, LI 2 sent S.M. a message on Snapchat. By 

this point, S.M. had returned control of her Snapchat account back to the OCE, who pretending to 

be S.M., stated the following: 

LI I'm worried about this dude T vou recommended haha 

S .. M. What about him and whv? 

LI Idk haha he iust gets suoer aQ"m-essive sometimes 

S.M. Why what happened now? 

LI Nothing haha just was gonna meet him tonight and got 

spooked 

28. Based on my investigation, there is probable cause to believe that LI and CHEN 

are the same person, engaged in the attempted sex trafficking of a minor and the attempted coercion 

and enticement of a minor, for the following reasons: CHEN's Snapchat account was created from 

2 The OCE (when pretending to be the trafficker) has not received any further messages from a 

person identifying himself as "Alan" since on or about March 23, 2022. Alan LI, however, has 

continued to communicate with both S.M. and the OCE pretending to be S.M. 

Case 1:22-cr-20224-BB Document 3 Entered on FLSD Docket 05/12/2022 Page 11 of 13
the same phone number that LI used to contact the OCE trafficker; IP activity shows that several 

times alanli771995 logged out of Snapchat and, within a few seconds, Mikey_ chen124 logged into 

Snapchat or vice versa from the same IP address, including the IP ADDRESS registered to LI's 

known residence; LI's known telephone number, 614-537-6514, is associated with CHEN's 

Telegram Mobile account; LI initiated contact with the OCE trafficker and said, "I heard you can 

set me up with some girls?" ( emphasis added) and only referenced CHEN when prompted by the 

OCE; LI's work as a middleman for CHEN; the overlap in their biographical information, 

including that they both previously lived in Ohio and now live near South Beach; and Li's reaching 

out to S.M. via Snapchat on at least two separate occasions to inquire about the tmstworthiness of 

the OCE trafficker whose information she provided following meetings CHEN, not LI, had 

scheduled with the OCE trafficker. 

[This Space Intentionally Left Blank] 

Case 1:22-cr-20224-BB Document 3 Entered on FLSD Docket 05/12/2022 Page 12 of 13
CONCLUSION 

29. Based on the foregoing, your Affiant respectfully submits that there is probable 

cause to believe that, beginning on or about March 12, 2022, ALAN LI a/k/a "Michael Chen" 

engaged in the attempted sex trafficking of a minor, in violation of Title 18, United States Code, 

Section 1594(a), and the attempted coercion and enticement of a minor, in violation of Title 18, 

United States Code, Section 2422(b ). 

FURTHER YOURAFFIANT SAYETH NAUGHT 

KIMBE~ JENNETTE, SPECIAL AGENT 

FEDERAL BUREAU OF INVESTIGATION 

Attested to by the applicant in accordance with the requirements of Fed.R.Crim.P. 4.1 

by Face Time thzof May 2022, in Miami, Florida. 

HONORABLE LAUREN F. LOUIS 

UNITED STATES MAGISTRATE JUDGE 

Case 1:22-cr-20224-BB Document 3 Entered on FLSD Docket 05/12/2022 Page 13 of 13