AFFIDAVIT IN SUPPORT OF 

AN APPLICATION FOR A SEARCH WARRANT 

I, Kenneth Jay Hurst, a Special Agent with the Federal Bureau of Investigation, being . . . . 

duly sworn, depose and state as follows: 

Introduction 

1. I have been employed as a Special Agent of the Federal Bureau of lrivestigation 

("FBI") since 2016, and aii1 currently assigned to the Cincinnati Division. I entered on duty as a 

Special Agent in 2016 and am currently assigned to the Complex Financial Crimes Squad of the 

Cincinnati Division. In this capacity, I investigate matters involving criminal enterprises, white 

collar crimes, civil rights violations, bank robberies and the online exploitation of children. Prior 

to my current assignment, I was assigned to a Counterintelligence Squad, where I investigated a 

wide array of natfonal security matters. Since 2016, I have received training and investigative 

experience in interviewing and interrogation techniques, arrest procedures, search and seizure, 

search warrant applications, and various other crimes and investigative techniques including 

Title IU investigations. 

2. Prior to my employment as a Special Agent with the FBI, I was a Captain in the 

United States Army in a reconnaissance and surveillance organization. In that capacity, I 

conducted numerous interviews and interrogations while deployed to Afgh~nistan in 2014. Prior 

to my career in the United Stat~s Army, I was a fu,11 time student. I graduated from the 

University of Kentucky in 2012 with a Bachelor's Degree in :1nternational Studies. 

3. As a federal agent, I am authorized to investigate violations of United States laws 

and to execute warrants issued under the. authority of the United States. 

4. I am investigating the activities involving the sexual abuse of a minor an,d the 

corresponding production of images memorializing the sexual abuse that occurred at 10651 

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South State Route 48, Loveland, Ohio 45140. As will be shown below, .there is probable cause 

to believe .that evidence involving the sexual abuse of a minor and corresponding production of 

images memorializing the sexual abuse will be located at 1065 l South State Route 48, Loveland, 

Ohio 45140. I submit.this application and affidavit in support of a sea~ch warrant authorizing the 

search of the above residence ("Premise"), as further described in Attachment A-1, as well as 

mobile telephones provided to the Hamilton Township Police Department ("HTPD"), via 

Consent to Search Forms ("Subject iPhone" and "Witness iPhone"), as further described in 

Attachments A-2 and A-3. Located within the Premises, Subject iPhone and Witness iPhone fo 

be searched, I seek to seize evidence, fyuits, and instrumentalities of the forgoing criminal · 

violations, which relate to the knowing production and possession of child pornography, more 

particularly described in Attachment B. I request authority to search the entire premises, 

including the residential dwelling, outbuildings, and vehicles on the premises, and any computer 

and computer media located therein, as well as the Subject iPhone and Witness iPhone, where 

the items specified in Attachment B may be found, and to seize all items listed in Attachment B 

as instrumentalities, fmits, and evidence of a crime. 

5. The statements in this affidavit are based in part on information provided by 

HTPD and on my own investigations of this matter, including my ·experience and training as a 

Special Agent of the FBI. Since this affidavit is being submitted for_ the limited purpose of 

securing a s~arch 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 that evidence, fruits, and instrumentalities of the violation of§§ 2251, 2252 and 

· 2252A, are presently located at the premises. 

STATUTORY AUTHORITY 

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6. This investigation concerns alleged violations of 18 U.S.C. §§ 2251, 2252 and 

2252A, relating to material involving the sexual exploitation of minors. 

a. 18 U.S.C. § 2251(a) prohibits knowingly producing a visual 

depiction of a minor engaged in sexually explicit conduct, using materials that 

affect interstate commerce. 

b. ·18 U.S.C. § 2252(a)(l) prohibits knowingly transporting or 

shipping in interstate or foreign commerce, by computer or mail, any visual 

depiction of minors engaging in sexually explicit conduct. 

c. 18 U:S.C. § 2252(a)(2) prohibits knowingly receiving or 

distributing, by computer or mail, any visual depiction of minors engaging in 

sexually explicit conduct that has been mailed, shipped, or transported in 

interstate or foreign commerce. That section also prohibits knowingly 

reproducing any visual depiction of minors engaging in sexually explicit conduct 

for distribution in interstate or foreign commerce by any means, including by 

computer or the mail. 

d. 18 U.S.C. § 2252(a)(4) prohibits possessing one or more books, 

magazines, periodicals, films, or other materials which contain visual depictions 

of minors engaged in sexually explicit conduct that have been transported in 

interstate or foreign commerce, or that were produced using materials that had 

traveled in interstate or foreign commerce. 

e. 18 U.S.C. § 2252A(a)(l) prohibits knowingly mailing, 

transporting, or shipping child pornography in interstate or foreign commerce by 

any means, including by computer. 

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f. 18 U.S.C. § 2252A(a)(2) prohibits knowingly receiving or 

distributing any child pornography that has been mailed or shipped or transp01ted 

in interstate or foreign ·commerce by any means, including by computer. 

g. 18 U.S.C. § 2252A(a)(3)(A) prohibits a person from lrnowingly 

reproducing child pornography for distribution through the mail or in interstate or 

foreign commerce by any means, including by computer. 

. . 

h. 18 U.S.C. § 2252A(a)(3)(B) prohibits lmowingly advertising, 

promoting, presenting, distributing, or soliciting thiough the mail, or using any 

means or facility of interstate or foreign commerce, or in or affecting interstate or 

foreign commerce by any means any material in a manner that reflects the belief 

or is intended to cause another to believe that the material is or contains a visual 

depiction of an act1:1al minor engaging in sexually explicit conduct, or an obscene 

visual depiction of a minor engaging in sexually explicit conduct. 

i. · 18 U.S.C. § 2252A(a)(5)(B) prohibits a perso~ from knowingly 

possessing any book, magazine, periodical, film, videotape, comp-μter disk, or 

other material that contains an image of child pornography that has been mailed, 

shipped, or transported in interstate or foreign commerce by any means, including 

by computer, or that was produced using materials that have been mailed; 

shipped, or transported in interstate or foreign commerce by any means, including 

by computer. 

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DEFINITIONS 

7. The following definitions apply to this Affidavit and Attachment B: 

a. "Child Erotica" means mate1ials or items that are sexually 

arousing to persons having a sexual interest in minors but that are not 

necessarily, in and of themselves, obscene or that do not necessarily depict 

minors in sexually. explicit poses or positions. 

· b. "Child Pornography'' includes any visual depiction of sexually 

explicit conduct where (a) the production of the visual depiction involved the 

use of a minor engaged in sexually explicit conduct; (b) the visual depiction 

was a digital image, computer image, or computer-generated image that is, or 

is indistinguishable from, that of a minor engaged in sexually explicit conduct; 

or ( c) the visual depiction has been created, adapted, or modified to appear 

that an identifiable minor is engaged in sexually explicit conduct. See 18 

u.s.c. § 2256(8). 

c. "Computer" refers to "an electronic, magnetic, ,optical, 

electrochemical, or other high speed data processing device performing 

logical or storage functions, and includes any data storage facility or 

communications facility directly related to or operating in conjunction with 

such device." See 18 U.S.C. § 1030(e)(l). 

d. "Computer .hardware" consists of all equipment that can receive, 

capture, collect, analyze, create, display, convert, store, conceal, or transmit 

electronic, magnetic, or similar computer impulses or data. Computer 

hardware includes any data-processing devices (including, but not limited to, 

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central processing units, internal and peripheral storage devices such as fixed 

disks, external hard drives, floppy disk drives and diskettes, and other memory 

storage devices); peripheral input/output devices (including, but not Fmited tO, 

keyboards, printers, video display monitors, and related communications 

devices such as cables and connections); as well as any devices", mechanisms, 

or parts that can be used to restrict access to computer hardware (including, 

but not limited to, physical keys and locks). 

e. . "Computer passwords and data security devices" consist of 

information or items designed to restrict access to or hide computer software, 

' 

docmnentation, or data. Data security devices may consist of hardware, 

software, or other programming code. A password (a string of alpha-numeric 

characters) usually·operates what i:night be termed a digital key to "unlock" 

particular data security devices. Data security hardware may include 

encryption devices, chips, and circuit boards. D~ta security software of digital 

code may include programming code that creates "test" keys or "hot" keys, 

which perform certain pre-set security functions when touched. Data security 

software or code may also encrypt, compress, hide, or "booby-trap" protected I . 

data to make it inaccessible or unusable, as well as reverse the progress to 

restore it. 

f. "Computer-related docmnentation" consists of written, recorded, 

printed, or electronically stored material that explains or illustrates how to 

configure or use computer hardware, computer software, or other related 

items. 

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g. "Computer software" is digital information that can be interpreted 

by a computer and any of its related components to direct the way it works. 

Computer software is stored in electronic, magnetic, or other digital form. It 

commonl)' includes programs to run operating systems, applications, and 

utilities. 

h. "Internet Protocol address" or "IP address" refers to a ':1nique 

numbei- used by a computer to access the Internet. IP addresses can be 

dynamic, meaning th~t the Internet Service Provider (ISP) assigns a different 

unique number to a computer every time it accesses the Internet. IP addresses 

might also be static, if an ISP assigns a.user's computer a particular IP address 

that is used each time the computer accesses the Internet. 

i. "Minor" means any person under the age of 18 years. See 18 

U.S.C. § 2256(1). 

j. "Peer-to-peer file-sharing" ("P2P") is a method of communication 

available to Internet users through the use of special software. Computers 

linked together through the Internet using this software form a network that 

allows for the sharing of digital files between users on the network. A user 

first obtains the P2P software, which can be downloaded from the Internet. In 

general, P2P software allows the user to set up files on a computer to be 

shared with others running compatible P2P software. A user obtains files by 

opening the P2P software on the user's computer, and conducting searches for 

files that are currently being shared on another user's computer. 

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k. "Sexually explicit conduct" applies to visual depictions that 

involve the use of a minor, see 18 U.S.C. § 2256(8)(A), or that have been 

created, adapted, or modified to ~ppear to depict ar:i identifiable minor, see 18 

U.S.C. § 2256(8)(C). In those contexts, the term refers to actual or simulated 

(a) sexual intercourse (including genital-genital, oral-genital, or oral-anal), 

whether between persons of the same or opposite sex; (b) bestiality; (c) 

masturbation; ( d) sadistic or masochistic abuse; or ( e) lascivious exhibition of 

the genitals or pubic areas of any person. See 18 U .S.C. § 2256(2)(A). 

1. "Visual depictions" include undeveloped film and videotape, and 

data stored on computer disk or by electronic means, which is capable of 

conversion into.a visual image. See 18 U.S.C. § 2256(5). · 

m. The terms "records," "documents," and "materials" include all 

information recorded in any form, visual or aural, and by any means, whether 

in handffiade form (inclu~ing, but not limited to, writings, drawings, painting), 

photographic form (including, but not limited to, microfilm, microfiche, 

pri.D.ts, slides, negatives, videotapes, motion pictures, photocopies); 

mechanical form (including, but not limited to, phonograph records, printing, 

typing); or electrical, electronic or magnetic form (including, but not limited 

to, tape recordings, cassettes, compact discs, electronic or magnetic storage 

devices such as floppy diskettes, hard disks, CD-RQMs, digital video disks 

("DVDs"), Personal Digital Assistants ("PDAs"), Multi Media Cards 

("MMCs"), memory sticks, optical disks, printer buffers, smart cards, memory 

calculators, electronic dialers, Bernoulli drives, or electronic noteJmoks, as 

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well as digital data files and printouts or readouts from any magnetic, 

electrical or electronic storage device). 

BACKGROUND ON COMPUTERS AND CHILD PORNOGRAPHY 

8. Based on my knowledge, training, and experience ip child exploitation and child 

pornography investigations, and the experience and training of other law enforcement officers 

with whom I have had discussions, computers, computer technology, and the Internet have 

revolutionized the manner in which child pornography is produced, distributed and stored. 

9. Computers and cellphones basically serve five functions in connection with child 

pornography: production, communication, distribution, storage, and social networking. The 

term computer is this affidavit should be read to include cellphones. 

10. With digital cameras, images of child pornography can be transferred directly 

onto a computer. A modem allows any computer to connect to another computer through the use 

of telephone, cable, or wireless connection. Through the hlternet, electronic contact can be made 

to literally millions_ of computers and. cellphones around the world. 1ndeed, modem day 

cellphones have many of the same capabilities as co.r:nputers. Many cellphones now have digital 

cameras as well. 

11. The computer and cellphones ability to store images in digital form make them 

ideal repositones for child pornography. The size of the electronic storage media: (commonly 

referred to as the hard drive) used in home computers and cellphones has grown tremendously 

within the last several years. These drives can store thousands of images at very high resolution. 

12. The Internet affords individuals several different venues for meeting each other, 

obtaining, viewing and trading child pornography in a relatively secure and anonymous fashion. 

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13. Individuals also use online resources to retrieve and store child pornography, 

including servic~s offered by Internet Portals such as Apple, Google, Yahoo! and Hotmail, 

among others. The online services allow a user to set up an account with a remote computing 

service that provides e-mail services as well as electronic storage of computer files in any variety 

of formats. A user can set up an online storage account from any c.omputer with access to the 

Internet. Evidence of such online storage of child pornography is often found on the user's 

computer. Even· in cases where online storage is used,, however, evidence of child pornography 

can be found on the user's computer in most cases. 

I 

14. As with most digital technology, communications made from a computer are 

often saved or stored on that computer. Storing this information can be intentional, for example, 

by saving an e-mail as· a file on the computer or saving the location of one's favorite websites in 

"boolanarked" files. Digital information can also be retained unintentionally. Traces of the path 

of an electronic communication may be automatically stored in many places, such as temporary 

files or ISP client software, among others. In addition to electronic communications, a computer 

user's Internet activities generally leave traces in a computer's web cache and Internet history . . 

files. A forensic examiner often can recover evidence that ~hows whether a computer contains 

peer-to-peer and instant messaging software, when the computer was sharing files, and some of 

the files that were uploaded or downloaded. Computer files or remnants of such files can be 

recovered n:ionths or even years after they have been downloaded onto a hard drive, deleted, or 

viewed via the Internet. Electronic files downloaded to a hard drive can be stored for years at 

little or no cost. Even wh~n such files have been deleted, they can be recovered months or years 

. . later using readily available forensic tools. When a person "deletes" a file on a home computer, 

the data contained in the ·file does not actually disappear; rather, that data remains on the hard 

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drive until it i~ overwritten by new data. Therefore, deleted files, or remnants of deleted files, 

may reside.in free space or slack space -- that is, in space on, the hard drive tl~at is not allocated to 

an active file or that is unused after a file has been allocated to a set block of storage space -.- for 

long periods of time before they are overwritten. · In addition, a computer's operating system 

may also keep a record of deleted data in a "swap" or "recovery" file. Similarly, files that have 

been viewed via the Internet are automatically d~wnloaded into a temporary Internet directory or 

"cache . " The browser typically maintains a fixed amount of hard drive space devoted to these 

files, and the files are· only overwritten as they are replaced with more recently viewed Internet 

pages. Thus, the ability to retrieve residue of an electronic file from a hard drive depends less on 

I 

when the file was downloaded or viewed than on a particular user's operating system, storage 

capacity, and computer habits. · 

SPECIFICS OF SEARCH AND SEIZURE OF COMPUTER SYSTEMS 

15. s.earches a,nd seizures of evidence from computers commonly require agents to 

download or copy information from the computers and their components, or seize most or all 

computer items (computer hardware, computer software, and computer related documentation) to 

be processed later by a qualified computer expe1t in a laboratory or other controlled 

environment. This is almost always true because of the following two reasons: 

a. Computer storage devices (like hard disks, diskettes, tapes, laser disks, 

magneto opticals, and others) can store the equivalent of thousands of pages of 

information. Especially when the user wants to conceal criminal.evidence, he or she 

often stores it in random order with deceptive file names. This requires searching 

authorities to examine all the stored data that is available in order to deterin.ine 

whether it is included in the warrant that authorizes the search. This sorting process 

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. can take days or weeks, depending on the volume of data stored, and is generally 

difficult to accomplish fully on-site. 

b. Searching computer systems for criminal evide~ce is a highly technical 

process requiring expert skill and a properly controlled environment, The vast array 

of computer hardware and software available requires even computer experts to 

specialize in some systems and applications; so.it is difficult to know before a search 

which expert should analyze the system and its data. The se;lrch of a computer 

system is an exacting scientific procedure that is designed to protect the integrity of 

the evidence and to recover even hidden, erased, compressed, password-protected, or. 

encrypted files. Since computer evidence is extremely.vulnerable to tampering or 

' ' destruction (which may be caused by malicious code or normal activities of an 

operating system), the controlled environment of a laboratory is essential to its 

complete and accurate analysis. 

16. In order to fully retrieve data from a computer system, the analyst needs all 

magnetic storage devices as well as the central processing unit ("CPU"). In cases involving child 

pornography where the evidence.consists partly of graphics files, the monitor(s) may be essential 

for a thorough and efficient search due to software and hardw.are configuration issues. In 

addition, the· analyst needs all the system software (operating systems or interfaces, and hardware 

drivers) and any applications software which may have been used to create the data (whether 

stored on hard drives or on external media). 

17. Furthermore, because there is probable cause to believe that the computer and its 

stor~ge devices a:re all instrumentalities of crimes, within the meaning of 18 U.S.C. §§ 2251 

through 2256, they should all be seized as such. 

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BACKGROUND OF THE INVESTIGATION 

18. Your Affiarit states that on November 20, 2017, the Hamilton Township Police 

Department (HTPD) received a witness report stating JAKE MICHAEL DAMRON had taken 

pornographic pictures of a five year old minor victim (hereinafter referred to as "MINOR 

VICTIM"). MINOR VICTIM is the daughter of DAMRON'S girlfriend, (hereinafter referred to 

as "GIRLFRIEND") with whom he resides. The witness reported DAMRON was trading the 

images of MINOR VICTIM for other child pornography via the cell phone application "KJK."1 

23. On November 21, 2017 a Detective with HTPD and a Warren County Children's 

Service Case Worker responded to DAMRON'S address, 10651 South State Route 48, Loveland, 

I 

Ohio 45140 in an attempt to locate MINOR VICTIM and.GIRLFRIEND. The detective found 

the residence to be unoccupied and contacted GIRLFRIEND via telephone. Arrangements were 

·made to meet with GIRLFRIEND at the Warren County Child Advocacy Center. On November 

· 21, 2017 at approximately 1420 hoU.r.s, the detective interviewed GIRLFRIEND at the Advocacy 

center. 

24. GIRLFRIEND advised on October 28, 2017, she became suspicious of 

DAMRON and searched his cell phone (Subject iPhone) while he was sleeping. GIRLFRIEND 

observed conversations in DAMRON'S cell phone between DAMRON and other individuals, 

which included several pictures of young female children including MINOR VICTIM. 

GIRLFRIEND used her personal cell phone (Witness iPhone) to take pictures of the images and 

conversations displayed on DAMRON'S cell phone and confronted DAMRON with the pictures. 

GIRLFRIEND advised she initially kicked DAMRON out of the house upon discovering the 

images. and conversations, but allowed DAMRON to move back into the house approximately 

1• Kile is an internet based messaging and communication application which is usable on cellphones and other 

internet capable devices. 

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one week later, after DAMRON agreed to attend therapy. Sergeant Short subsequently requested 

that GIRLFRIEND respond to the Hamilton Township Police Department headquarters· for 

further interviewing. 

25. GIRLFRIEND immediately responded to HTPD where she voluntarily turned 

her cell phone over and provided her passcode. GIRLFRIEND also signed a property release 

form and a consent to search form. GJRLFRIEND then completed a three page voluntary written 

statement. In the statement, GIRLFRIEND advised she felt suspicious of DAMRON and 

searched his cell ~hone. During the search she found sex applications and chatrooms including 

the application "KI!(." In "KlK," GIRLFRIEND found many conversations between DAMRON 

and other "KlK" users exchanging videos and images. The images in the conversations included 

pictures of GIRLFRIEND and MINOR VICTIM. Additionally, DAMRON had sent and received 

sexually explicit pictures of other children. GIRLFRIEND confronted DAl\1RON with the 

images and DAMRON apologized to GIRLFRIEND and told her that he knew what he had done 

was wrong. GIRLFRIEND then kicked DAMRON out of the house but continued to feed him 

and allow him to enter with permission. GIRLFRIEND advised she confided in friends and 

asked them for advice and also told MINOR VICTIM'S psychofogist about the incident. 

26. On November 21, 2017, at approximately 1640 hours, Sergeant Short conducted 

a non-custodial interview of DAMRON at the HTPD .. On November 28, 2017, Your Affiant 

reviewed a video recording of the interview. The interview lasted approximately twenty-eight 

minutes and DAMRON provided the following information: 

• DAMRON stated that he had "nude pictures of kids" on his phone and responded in 

the affirmative when asked by Sergeant Short if he had been sending and receiving 

them. 

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• DAMRON also advised he had taken inappropriate pictures of MINO~ VICTIM. 

• DAMRON had deleted all of the pictures off of his phone but possessed the cell 

phone. 

• · DAMRON identified his "KJK" usemame as "HITEMYOUNGIN" associated with 

the email address "cincityracer@yahoo.com". 

• DAMRON deleted the account from his phone after b.eing confronted by 

GIRLFRIEND but confirmed his account was still aCtive. 

• When asked by Sergeant Short if DAMRON had been trading child pornography on 

"K.IK", DAMRON responded in the affirmative. 

27. DAMRON consented to turning his iPhone 6s2 cell phone over to Sergeant Short 

and agreed to provide his cell phone passcode. S~rgeant Short advised DAMRON he would be . 

analyzing the cell phone and would present the results to a Grand Jury. DAMRON again agreed 

to tum the phone over to Sergeant Short, he then signed a property release form and signed a 

consent to ·search form. DAMRON explained MINOR VICTIM was the only minor he had taken 

photographs of and stated he had "probably" taken them due to easy access. DAMRON also 

· stated he is registered as a sex offender with the State of Ohio 

28. On November 27, 2017 Your Affiant received the HTPD case file, interview 

notes, and DAMRON'S cell phone as well.as GIRLFRIEND'S cell phone. Upon receiving 

GIRLFRJEND'S cell phone, a pink iPhone 6s, Your Affiant reviewed GIRLFRIEND'S signed 

and dated consent to search form. Upon verification of GIRLFRIEND'S consent to search, at 

approximately 1610 hours, Your Affiant turned GIRLFRIEND'S cell phone on, placed the 

device into airplane mode and reviewed GIRLFRIEND'S camera roll. Your Affiant identified 

2• From experience, I know iPhone cellphones are typically ma~ufactured outside the United States. 

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multiple photographs taken on October 28, 2017, of a cell phone matching the description of 

DA1v,1RON'S with conversations and images depicting what appeared to be shared photographs 

including the following: 

• A prepubescent female straddling what appeared to be an erect male penis 

• What appeared to be a prepubescent female naked spreading her legs. 

• Photographs of what appeared to be an adult male.hand pulling back underwear 

to expose the genitalia of what appeared to. be an unidentifiable prepubescent 

female. 

29. At approximately 1635 hours, Your Affiant concluded the review of the cell 

phone and powered the device off. 

30. Public database records checks and Ohio Bureau of Motor Vehicles identified 

that DAMRON, date· of birth XX-XX-1992, Social Security Account Number ;x:xx-XX-3187, 

resides at 10651 South State Route 48, Loveland, Ohio 45140. 

31. During his interview with Sergeant Short, DAMRON provided 10651 ·South State 

Route 48, Loveland, Ohio 45140, as his residential address. 

CHARACTERISTICS COMMON TO INDIVIDUALS INVOLVED IN THE 

DISTRIBUTION, TRANSPORTATION, RECEIPT, OR POSSESSION AND 

ATTEMPTED DISTRIBUTION, TRANSPORTATION, RECEIPT. OR 

POSSESSION OF CIDLD PORNOGRAPHY 

32. As set forth above,. probable cause exists to believe that DAMRON has produced, 

distributed, ·and possessed child pornography. Based upon my knowledge, experience, and 

training, and the training. and experience of other law enforcement officers with whom I have had 

discussions, I know that there are certain characteristics common to individuals involved in such 

crimes: 

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a. Those who distribute, transport, i:eceive, or possess child pornography, or 

who attempt to commit these crimes may receive sexual gratification, stimulation, and 

satisfaction from contact with children; or from fantasies _they may have viewing children 

engaged. in sexual activity or in sexually suggestive poses, such as in person, m 

photographs, or other visual media; or'"from literature describing such activity. 

b. Those who disttibute, transport, receive, or possess child pornography, or 

who attempt to commit these crimes may collect sexually explicit or suggestive materials,_ 

in a yariety of media, including photographs, magazines, motion pictures, videotapes, 

books, slides and/or drawings or other visual media. Such individuals oftentimes use 

these materials for their _own sexual arousal and gratification. Further, they may use these 

mate1ials to lower the inhibitions of children they are attempting to seduce, to arouse the 

selected child partner, or to demonstrate the desired sexual acts. 

c. Those who distribute, transport, receive, or possess child pornography, or 

who attempt to commit these crimes often possess and maintain ·copies of childpomography material, that is, their pictures, films, video tapes, magazines, negatives, 

photographs, correspondence; mailing lists, books, tape recordings, etc., in the privacy 

and security of their home or some other secure location. These individuals typically 

retain pictures, films, photographs, negatives, magazines, correspondence, books, tape 

recordings, mailing lists, child erotica, and videotapes for many years. 

d. Likewise, . those · who distribute, transport, receive, or possess child 

pornography, or who attempt to commit these crimes often maintain their collections that 

are in a digital or electronic format in a safe, secure and private environment, such as a 

computer and surrounding area. These collections are often maintained for several years 

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and are kept close by, usually at the individual's residence, to enable the collector to view 

the collection, which is valued highly. 

e. Those who distribute, transport; receive, or possess child pornography,. or 

who attempt to commit these crimes also may correspond with and/or meet others to 

share information and materials; rarely destroy correspondence from other child 

I 

pornography distributors/collectors; conceal such correspondence as they do their 

sexually explicit material; and often maintain lists of names, addresses, and telephone 

numbers of individuals with whom they have been in contact and who share the same 

interests in child pornography. 

f. Those who distribute, transport, receive, or possess child pornography, or 

who attempt to commit these crimes prefer not to be without their child pornography for 

any prolonged time period. This behavior has been documented by law enforcement 

officers involved in the investigation of child pornography throughout the world. 

33. DAMRON, residing. at 10651 South State Route 48, Loveland, Ohio 45140, 

exhibits the common characteristics described above in ii 27 of someone involved in the 

· distribution, transportation, receipt, and possession of child pornography, or the attempt to 

. ' distribute, transport, receive, or possess child pornography, is evidenced by the facts that are set 

forth in this affidavit,. including: 

a. The fact that sexually explicit images of MINOR VICTIM were produced 

to document the abuse and preserve the abuse for later review and sexual 

gratification; 

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b. The sexually explicit images of MINOR VICTIM were produced using a 

mobile device, allowing for the contents to be kept in digital format, and 

easily transported, distributed, and stored. 

c. DAMRON's own statements of producing, distributing, receiving; and 

possessing child pornography. 

CONCLUSION 

-34. Based on the aforementioned factual information, Your Affiant respectfully 

submits that there is probable cause to believe that evidence of the above described sexual abuse, 

in violation of 18 U.S.C. §§ 2251, 2252 and 2252A, will be located at the residence associated 

with DAMRON, as well as both the Subject iPhone and Witness iPhone. Additionally, the 

evidence listed_ to be seized, listed in Attachment B to this affidavit, which is incorporated herein 

by reference, is contraband, the fruits of crime, or things otherwise criminally possessed, or 

property which is or has been used as the means of committing the foregoing offenses. 

35. Your Affiant, therefore, respectfully requests that the attached warrants be issued 

authorizing the search and seizure of the items listed in Attachment B. 

Sworn and subscribed before nie this d cJ day of November, 2017. 

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ATTACHMENT A-2 

DESCRIPTION OF THE SUBJECTIPHONE TO BE SEARCHED 

An Apple iPhone 6S, silver in color, Model Ai688, FCC ID: BCG-E2946A IC: 579CE2946A. The iPhone was turned over to HTPD by DAMRON with consent to search and is 

being stored at the FBI Cincinnati Field Office, 2012 Ronald Reagan Drive, Cincinnati, Ohio 

45236. 

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ATTACHMENTB 

PROPERTY AND PARTICULAR ITEMS TO BE SEARCHED AND SEIZED 

Agents are authorized to photograph or video the interior and exterior of the 

building. Additionally, all items contained in the premises described in Attachment A-1, A-2, 

and A-3 that relate to violations of_ 18 U.S.C. §§ 2251, 2252 and 2252A, relating to the 

production, distribution, transportation, receipt, and possession of child pornography: 

1. Child pornography or child erotica in _any format or medium; 

2. Girl's clothing, including underwear and similar clothing items; 

3. Sexual toys and items used for sexual arousal or sexuat"acts; 

4. Any computer or storage medium, including but not limited to, computers, computer . ' 

servers, cellular telephones, personal data assistants, tablets, electronic storage devices, thumb 

drives, flash drives or cards, and smart cellular telephones; 

5. Any images of Minor Victini; · 

6. Any information, communications, images, videos, messages, or qata associated with Kik 

messenger; 

7. Records and information relating to the identity or location of the suspects, or others who 

may have communicated with for the purpose of exchanging and/or trading images of minors; 

8. Computers or storage media used as a means to commit the violations of 18 U.S.C. §§ 

2251, 2252 and 2252A; 

9. For any computer or storage medium whose seizure is otherwise authorized by 

this warrant, and any computer or storage medium that contains or in which is stored records or 

information that is otherwise called for by this warrant (hereinafter, "COMPUTER"): 

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a. evidence of who used, owned, or controlled the COMPUTER at the time the 

things described in this warrant were created, edited, or deleted, such as logs, 

registry entries, configuration files, saved usemames and passwords, documents, 

browsing history, user profiles, email, email contacts, "chat," instant messaging 

logs, photographs, and correspondence; 

b. evidence of software that would allow others to control the COMPUTER, such as 

viruses, Trojan horses, and other forms of malicious software, as well as evidence 

of the presence or absence of security software designed to detect malicious 

·software; 

· c. evidence of the lack of such malicious software; 

d. evidence of the ·attachment to the COMPUTER of other storage devices or similar 

. containers for electronic evidence; 

e. evidence of counter-forensic programs (and associated data) that are designed to . 

eliminate data from the COMPUTER; 

f. evidence of the times the COMPUTER was used; 

g. passwords, encryption keys, and other access devices that may be necessary to 

access the COMPUTER; 

h. documentation and manuals that may be necessary to access the COMPUTER or 

to conduct a forensic examination of the COMPUTER; 

i. records of or information ~bout Internet Protocol addresses used by the 

COMPUTER; 

j. records of or information about the COMPUTER's Internet activity, including 

firewall logs, caches, browser history and cookies, "bookmarked" or "favorite" 

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10. 

11. 

12. 

. 13. 

14. 

k. 

web pages, search terms that the user entered into any Internet search engine, and 

records of user-typed web addresses; 

contextual information necessa1y to understand the evidence described in this 

attachment. 

Routers, modems, and network equipment used to connect computers to the 

Internet. -

All visual depictions in any form, including still images, videos, films or other 

recordings of child pornography or minors engaged in sexually explicit conduct and any 

mechanism used for the receipt, storage, or production of the same. 

Any and all computer passwords and other data security devices designed to 

restrict access to or hide computer software, data, or documentation. Data security 

. devices may consist of hardware, software, or other programming code. 

Any and all" documents, records, e-mail, and internet history (in electronic form) 

pertaining to the sexual exploitation of children whether transmitted or received. 

Any and all electronic records, documents, invoic.es, notes, and materials that 

pertain to accounts ~ith any Internet Service Provider, as well as any and all"records 

relating to the ownership or use of computer equipment found at that property. 

15. Electronic or paper documents and records regarding the lease and/or possession 

16. 

or ownership of the property described in Attachment A-1, A-2, or A-3 or of any 

computer or electronic storage device found at that property. 

Evidence of.user attribution showing who used or owned any of the items seized 

under this warrant, including evidence of when those items were created, edited, or 

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deleted, such as logs, phonebooks, saved usernames and passwords, documents, and 

browsing history. 

17. Records evidencing the use ofthe Internet, to include Internet Protocol addresses· 

including: 

a. records of Internet Protocol addresses used; 

b. records of Internet activity, including firewall logs, caches, browser histo1y and 

cookies, "bookrnarked11 or "favorite" web pages, search te1ms that the user entered 

into any Internet search engine, and records of user-typed web addresses. 

18. As used above, the terms "records" and "information" includes all forms of 

creation or storage, including any form of computer or electronic storage (such as hard 

disks or other media that can store data); any handmade form (such as writing); any 

mechanical_ form (such as printing or typing); and any photographic form (such as 

microfilm, microfiche, prints, slides, negatives, videotapes, motion pictures, or 

photocopies). 

19. The te1m "computer" includes· all types of electronic, magnetic, optical, 

electrochemical, or other high speed data processing devices performing logical, 

arithmetic, or storage functions, including desktop computers, notebook computers, 

mobile phones, tablets, server computers, and network hardware. 

20. The term "storage medium" includes any physical object upon which computer 

21. 

22. 

data can be recorded. Examples include hard disks, RAM, floppy disks, flash meinory, 

CD-ROMs, and other magnetic or optical media. 

Any images or videos that depict Minor Victim. 

Any communications with or about Minor Victim. 

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23. Any text, email,. or other communi~ation concerning the sexual exploitation of 

children. 

24. Any hotel records and receipts, travel records and receipts, vehicle records, 

financial records, and telephone bills. 

25. Any record, receipt, or advertisement pertaining to sexual exploitation of minors. 

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