AUSA: Abraham Telephone: 

AO 91 (Rev. 08/09) Criminal Complaint 

Special Agent : Jones Telephone: 

UNITED STATES DISTRICT COURT 

for the 

Eastern District of Michigan 

United States of America, 

Plaintiff, 

v. 

Herbert T. Felton, Jr. 

Defendant(s). 

Case: 4:14-mj-30265 

A

Ass!gned To : Hluchaniuk, Michael J 

ss19n. Date: 6/5/2014 . 

Description: CMP USA v HERBERT 

T. FELTON, JR. (TH) 

CRIMINAL COMPLAINT 

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 .May 7, 2014 to May 9, 2014 , in the county of_,,G..,,,e"-'n=es=e=e _______ _ 

in the Eastern District of-'-'M~ic=h~ig.,_a=n-'-------' the defendant(s) violated: 

Code Section 

Title 18, United States Code, Section 2423{a) 

This criminal complaint is based on these facts: 

Continued on the attached sheet. 

Sworn to before me and signed in my presence. 

City and state: Flint, Michigan 

Offense Description 

Transportation of minors with intent to engage in criminal sexual 

activity 

India Rochelle Jones 

Printed name and title 

Judge's signature 

Printed name and title 

Case 4:14-cr-20529-TGB-MJH ECF No. 1, PageID.1 Filed 06/05/14 Page 1 of 3
AFFIDAVIT OF INDIA JONES IN SUPPORT OF 

CRIMINAL COMPLAINT - U.S. v. Felton 

I, India Jones, being sworn, depose and state the following: 

1. I am employed as a Special Agent (SA) with the Federal 

Bureau of Investigation. I have been so employed since April 2011. I am 

currently working with local law enforcement officers on the investigation of 

Herbert T. Felton, Jr., for, among other things, violations of 18 U.S.C. § 

2423(a). 

2. On May 7, 2014, PW, a 14 year old living in Tilton, Illinois was 

reported missing. PW was seen earlier in the day walking to school 

however he did not actually enter the school building. Video from the 

Dansville, Illinois bus station shows that PW boarded a bus sometime after 

11 :45 am. 

3. PW's father obtained PW's cellular phone records and noted an 

unfamiliar number with an out-of-state 810 area code. PW's father 

travelled to Michigan and met with Det. Mark Holland on May 8, 2014. Det. 

Holland was able to trace the telephone number to Felton. Officers also 

learned that Felton was using the address 313 Page Street, Flint, Michigan. 

Sometime on or around midnight officers went to 313 Page Street and 

found PW and Felton at the residence. At the time that officers arrived, PW 

was visibly intoxicated. 

4. Felton was arrested and advised of his Miranda rights. He 

waived his rights and consented to an interview with officers of the 

Genesee County Sheriff's Department. Felton said he met PW over the 

internet approximately one year ago. Since that time they had 

communicated via internet social media and cell phone. Felton said that 

communication between he and PW included transmitting sexually explicit 

pictures to each other. Recovered off Felton's cell phone were several 

images of PW naked. 

5. Felton further stated that he travelled to Illinois to meet PW on 

or around May 7, 2014. PW and Felton travelled via bus from Dansville to 

Case 4:14-cr-20529-TGB-MJH ECF No. 1, PageID.2 Filed 06/05/14 Page 2 of 3
Champagne, Illinois. In Champagne PW and Felton boarded the Amtrack 

Train and continued to Flint, Michigan. Det. Holland has confirmed via 

video surveillance at the various bus and train stations the information 

provided by defendant regarding the travel to Michigan. Also recovered 

from defendant's bedroom were the Amtrack train tickets purchased by 

Felton. 

6. Felton stated that while in Michigan he and PW engaged in 

sexual intercourse. Felton first indicated that he believed PW was over 18 

years of age but ultimately indicated that he knew he was under 16 years 

old. On Felton's cell phone was a photo image of PW's school 

identification with his date of birth showing his age as 14 years old. 

7. Based on discussions with Det. Holland and other law 

enforcement officers involved in this investigation it would appear that PW 

and Felton had had an intimate relationship for a significant period of time. 

By way of example, Felton indicated that he and PW were to get married, 

Felton engaged in "grooming" techniques including sharing of sexually 

explicit photos with PW, and the chat rooms PW and Felton communicated 

in were rooms associated with sexual encounters, i.e. 

"naughtymeetings. com". 

8. I have reviewed the Michigan laws and after discussions with 

the Genesee County Prosecutor's Office, the sexual activity between 

Felton and PW is a criminal offense under MCLA §§750.520b and 

750.520d. 

rnfQ·a~ ndia RochelleJon 

Complainant 

Sworn to before me and signed in my presence. 

Date: {q-S: .... JoL<( 

Michael Hluchaniuk 

United States Magistrate Judge 

Case 4:14-cr-20529-TGB-MJH ECF No. 1, PageID.3 Filed 06/05/14 Page 3 of 3