UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

CRIMINAL COVER SHEET

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

Attorney's Office prior to August 8, 2014 (Mag. Judge Shaniek Maynard)? 

2. Did this matter originate from a matter pending in the Northern 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 

Tel:

Email:

Gregory Schiller

0648477

500 South Australian Avenue, Suite 400

West Palm Beach, Florida 33401

561-820-8711

gregory.schiller@usdoj.gov

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Assistant United States Attorney

FL Bar No.

No

By:

UNITED STATES ATTORNEY

Gregory Schiller

 CASE NO. PM510WM 

UNITED STATES OF AMERICA 

v. 

WILLIAM MICHAEL SPEARMAN,

Case 9:22-mj-08510-WM Document 1 Entered on FLSD Docket 11/02/2022 Page 1 of 10
AO 91 (Rev. 08/09) Criminal Complaint

UNITED STATES DISTRICT COURT

for the

__________ District of __________

)

)

)

)

)

)

Case No.

Defendant(s)

CRIMINAL COMPLAINT

I, the complainant in this case, state that the following is true to the best of my knowledge and belief.

in the county of in the

, the defendant(s) violated:

u Continued on the attached sheet.

Complainant’s signature

Printed name and title

6XEVFULEHGDQGVZRUQWREHIRUHPHLQDFFRUGDQFHZLWKWKHUHTXLUHPHQWVRI)HG5&ULP3E\WHOHSKRQH)DFH7LPH

Date:

City and state:

Printed name and title

 Southern District of Florida

United States of America

v.

WILLIAM MICHAEL SPEARMAN

22-mj-8510-WM

On or about the date(s) of March 2018 through November 2022 Palm Beach

Southern District of

Code Section

18 U.S.C. § 2252A(g)

18 U.S.C. § 2251(d) and (e)

Offense Description

Engaging in a child exploitation enterprise

Conspiracy to advertise child pornography

This criminal complaint is based on these facts: 

See attached Affidavit.

✔

FBI Special Agent David J. Backlund

West Palm Beach, Florida

Judge’s signature

U.S. Magistrate Judge William Matthewman

Complainant’s signature

Florida and elsewhere

November 2, 2022

KJZ Nov 2, 2022 West Palm Beach

Case 9:22-mj-08510-WM Document 1 Entered on FLSD Docket 11/02/2022 Page 2 of 10
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AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT AND ARREST WARRANT

I, David J. Backlund, a Special Agent with the Federal Bureau of Investigation (“FBI”) 

being duly sworn, depose and state as follows: 

1. I have been employed as a Special Agent of the FBI since September 2008, and am

currently assigned to the FBI’s Child Exploitation Operational Unit within the Criminal 

Investigative Division. As part of my duties as a Special Agent, I am assigned to investigate 

violations of federal law, including the online exploitation of children. This includes violations 

pertaining to the illegal trafficking, production, transmission, possession, and receipt of material 

depicting the sexual exploitation of minors. 

2. I am submitting this affidavit in support of a criminal complaint and arrest warrant

for WILLIAM MICHAEL SPEARMAN, year of birth: 1966, social security number: XXX-XX5417. I submit there is probable cause to believe that beginning at least in or about 2018, and 

continuing through in or about November 2022, in the Southern District of Florida and elsewhere, 

SPEARMAN engaged in a child exploitation enterprise in violation 18 U.S.C. § 2252A(g) and 

conspired with others to advertise child pornography in violation of 18 U.S.C. § 2251(d) and (e). 

The term “child pornography,” as used in this affidavit, refers to the definition set forth in 18 

U.S.C. § 2256(8)(A). 

3. Title 18 U.S.C. § 2252A(g) provides that a person engages in a child exploitation

enterprise if a person violates Chapter 110 of the United States Code (among other portions of 

Title 18), as part of a series of felony violations constituting three or more separate incidents and 

involving more than one victim, and commits those offenses in concert with three or more other 

persons. As further set forth below, there is probable cause to believe that SPEARMAN violated 

various provisions of Chapter 110 of the United States Code in such a manner, including the 

Case 9:22-mj-08510-WM Document 1 Entered on FLSD Docket 11/02/2022 Page 3 of 10
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advertisement of child pornography and conspiracy to advertise child pornography in violation of 

18 U.S.C. § 2251(d) and (e), and the distribution of child pornography and conspiracy to distribute 

child pornography in violation of 18 U.S.C. § 2252A(a)(2) and (b)(1). Each of the aforementioned 

is a felony offense. Here, I submit there is probable cause to believe that SPEARMAN violated 

18 U.S.C. § 2252A(g) because, as described more fully below, on three or more occasions, 

SPEARMAN shared numerous URL links via a website with a group of 10 or more other 

individuals, which links, when accessed, redirected to web pages displaying child pornography 

files. 

4. Title 18 U.S.C. § 2251(d) and (e) prohibit any person from conspiring to knowingly

make, print, or publish, or cause to be made, printed or published, any notice or advertisement 

seeking or offering to receive, exchange, buy, produce, display, distribute, or reproduce, any visual 

depiction, if the production of such visual depiction involves the use of a minor engaging in 

sexually explicit conduct and such visual depiction is of such conduct, when such person knows 

or has reason to know that such notice or advertisement will be transported using any means or 

facility of interstate or foreign commerce or in or affecting interstate or foreign commerce by any 

means including by computer, or when such notice or advertisement was transported using any 

means or facility of interstate or foreign commerce or in or affecting interstate commerce by any 

means including computer. Here, I submit that there is probable cause that SPEARMAN violated 

18 U.S.C. § 2251(d) and (e) because, as described more fully below, he was a member and 

facilitator of a website that was dedicated to the advertisement, distribution, and exchange of child 

pornography, and on which, in accordance with the rules of the website, users advertised and 

distributed child pornography via notices and advertisements in the form of URL links and 

descriptive text.

Case 9:22-mj-08510-WM Document 1 Entered on FLSD Docket 11/02/2022 Page 4 of 10
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5. The statements contained in this affidavit are based in part on information provided

by FBI Special Agents; written reports about this and other investigations that I have received, 

directly or indirectly, from other law enforcement agents; information gathered from the service 

of administrative subpoenas; the results of physical and electronic surveillance conducted by law 

enforcement agents; independent investigation and analysis by FBI agents and computer forensic 

professionals; and my experience, training and background as a Special Agent with the FBI. Since 

this affidavit is being submitted for the purpose of securing a Criminal Complaint and arrest 

warrant, I have not included each and every fact known to me concerning this investigation. I have 

set forth only the facts that I believe are necessary to establish probable cause to believe 

SPEARMAN has violated 18 U.S.C. §§ 2252A(g) and 2251(d) and (e). 

6. The FBI is investigating a website (hereinafter referred to as the “TARGET

WEBSITE”) that allows users to engage in online communications with other users. Users of the 

TARGET WEBSITE traffic in child pornography images and videos via the posting of web links 

within messages. These links allow a user to navigate to another website, such as a file-hosting 

website, where images and/or videos were stored in order to download these images and videos. 

When posting the links, users of the TARGET WEBSITE also generally include descriptive text 

that provides information about the sexual acts and age and gender of the child victim depicted in 

the linked-to child pornography files. The TARGET WEBSITE provides rules that instruct users 

to share child pornography in this manner. The TARGET WEBSITE consists of at least 100 

registered members. Registered members of the TARGET WEBSITE, and any user with a higher 

status than registered member, all have their usernames reserved for their exclusive use and must 

access their account through a password chosen by the user. Usernames that are taken by 

registered members or users of higher status cannot be used by any other website user. Until 

Case 9:22-mj-08510-WM Document 1 Entered on FLSD Docket 11/02/2022 Page 5 of 10
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approximately June 2022, a high-ranking administrator of the TARGET WEBSITE resided in 

Palm Beach County, Florida, within the Southern District of Florida, and advertised child 

pornography and took acts to help manage the website from his home. 

7. FBI investigation has further revealed that another particular user of the TARGET

WEBSITE, acting under a particular online alias and referred to here as the “SUBJECT USER,” 

acted as a high-ranking administrator of the website. According to communications made over 

the TARGET WEBSITE, the SUBJECT USER has recommended other users for promotion, 

welcomed users to the website, provided guidance to users, and recruited other users to serve in 

positions on the TARGET WEBSITE such as room moderators. The SUBJECT USER has been 

at least a registered member, or a user of greater status, since this time. 

8. The FBI’s investigation further revealed that the SUBJECT USER has, on more

than three occasions, shared thousands of URL links to child pornography via the TARGET 

WEBSITE that were accessible to more than 10 other TARGET WEBSITE users. Below are 

examples of some of the links shared by the SUBJECT USER. Each of these three examples is 

from a separate message sent by the SUBJECT USER on separate occasions between July and 

August 2022: 

a. The SUBJECT USER shared a collection of links, including one link with

descriptive text suggesting indicating that the linked-to child pornography files

depicted a young girl being sexually abused by an older woman. That link in fact

redirected to another website that contained an image depicting an adult female

holding a female toddler, estimated to be between one to two years of age, upside

down by her feet. The toddler’s legs are spread and the adult female has her tongue

touching the toddler’s vagina, which is exposed for the camera.

Case 9:22-mj-08510-WM Document 1 Entered on FLSD Docket 11/02/2022 Page 6 of 10
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b. On another occasion, the SUBJECT USER shared a collection of links, including 

one link with descriptive text suggesting indicating that the linked-to child 

pornography files depicted one or more girls performing oral sex. That link in fact 

redirected to another website that contained an album containing 21 images of 

females performing oral sex on erect penises. All of these images appear to depict 

minor girls, including girls who are visibly prepubescent, some estimated to be 

under the age of five.

c. On yet another occasion, the SUBJECT USER shared a collection of links, 

including one link with descriptive text suggesting indicating that the linked-to 

child pornography files depicted a preteen girl displaying her genitals and 

performing oral sex. That link in fact redirected to another website that contained 

79 images of a known female victim who was estimated to be between the ages of 

seven and nine at the time of the abuse. The girl exposes her anus and vagina for 

the camera in many of the images. There are also multiple images where the girl is 

performing oral sex on her adult abuser’s erect penis.

IDENTIFICATION OF WILLIAM SPEARMAN AS THE SUBJECT USER

9. On or about November 2, 2022, the FBI executed a search warrant authorized by 

the U.S. District Court for the Northern District of Alabama at SPEARMAN’s residence in 

Madison, Alabama. During the execution of the search warrant, after being advised of his rights, 

SPEARMAN admitted to FBI agents that he was the SUBJECT USER on the TARGET 

WEBSITE. He stated that he had been on the TARGET WEBSITE since approximately 2018, 

had shared child pornography over the site, and had taken steps to manage the site. He also stated 

that he maintained child pornography on devices in his residence. 

Case 9:22-mj-08510-WM Document 1 Entered on FLSD Docket 11/02/2022 Page 7 of 10
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10. During the execution of the search warrant at SPEARMAN’s residence, FBI agents 

also discovered evidence of SPEARMAN’s involvement with the TARGET WEBSITE. For 

example, FBI agents encountered SPEARMAN in his garage near a desk with a laptop on it. The 

screen of the laptop was frozen but had evidence on it of him accessing the TARGET WEBSITE 

and another website related to the TARGET WEBSITE that is also dedicated to child sexual 

exploitation. In addition, agents found a thumb drive in a box in the garage where they encountered 

SPEARMAN. A forensic preview of that thumb drive revealed a large volume of child 

pornography, including the following files: 

a. A photo of a prepubescent girl who appears to be approximately five to seven years 

old based on her young facial and bodily features and lack of pubic hair or breast 

development. The photo depicts an adult male inserting his penis into the girl’s 

vagina and the girl inserting a phallic sex toy into her mouth. 

b. A photo of a prepubescent girl who appears to be approximately eight to nine years 

old based on her young facial and bodily features and lack of pubic hair or breast 

development. The girl is depicted nude with her vagina and anus exposed and a 

sex toy inserted in her anus. An adult male is depicted standing over the girl and 

appears to be masturbating close to the girl’s face. 

c. A photo of a prepubescent girl who appears to be approximately six to seven years 

old based on her young facial and bodily features and lack of pubic hair or breast 

development. The photo depicts the girl exposing her naked vagina and anus and 

she appears to be rubbing a phallic sex toy against her vagina. 

Case 9:22-mj-08510-WM Document 1 Entered on FLSD Docket 11/02/2022 Page 8 of 10
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CONCLUSION 

11. For these reasons, your Affiant respectfully submits that there is probable cause to 

believe that SPEARMAN violated 18 U.S.C. § 2252A(g) within the Southern District of Florida 

and elsewhere by violating Chapter 110—including 18 U.S.C. §§ 2251(d) and (e) and 2252A(a)(2) 

and (b )(1 )—as part of a series of felony violations involving three or more separate incidents and 

more than one victim, and committed those offenses with three or more other persons. Your Affiant 

further respectfully submits that there is probable cause to believe that SPEARMAN violated 18 

U.S.C. § 2251(d) and (e) within the Southern District of Florida and elsewhere by conspiring with 

others to advertise child pornography. I therefore respectfully request that the Court authorize a 

criminal complaint for SPEARMAN. 

Respectfully submitted, 

David J. Backlund 

Special Agent 

Federal Bureau of Investigation 

Subscribed and sworn to me by applicant by 

telephone (Facetime) per the requirements of 

Fed. R. Crim. P. 4(d) and 4.1 on this 2nd day 

of November, 2022. 

_____________________________________ 

HON. WILLIAM MATTHEWMAN 

UNITED STATES MAGISTRATE JUDGE 

Case 9:22-mj-08510-WM Document 1 Entered on FLSD Docket 11/02/2022 Page 9 of 10
*Refers only to possible term of incarceration, supervised release and fines. It does not include

restitution, special assessments, parole terms, or forfeitures that may be applicable.

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

 U.S.C. § 2A(g)

* Max. Term of Imprisonment: Life

* Mandatory Min. Term of Imprisonment (if applicable): 20\HDUV

* Max. Supervised Release: Life (mandatory minimum term of years)

* Max. Fine: $ILnHDQGDVSHFLDODVVHVVPHQW

PENALTY SHEET

Defendant's Name: WILLIAM MICHAEL SPEARMAN 

Case No:

PM510-WM

Count #1: 

Engaging in a child exploitation enterprise

Count #2:

Conspiracy to advertise child pornography

18 U.S.C. § 2251(d) and (e)

* Max. Term of Imprisonment: 30 years

* Mandatory Min. Term of Imprisonment (if applicable): 15 years

* Max. Supervised Release: Life (mandatory minimum term of 5 years)

* Max. Fine: $250,000 fine and a $5,000 special assessment

Case 9:22-mj-08510-WM Document 1 Entered on FLSD Docket 11/02/2022 Page 10 of 10