a. All property used or intended to be used to commit or to promote the
commission of the aforementioned violation in Count Seven of this Second
Superseding Indictment, including but not limited to the following:

i. One Apple i-Phone 6s Plus, model A1634, serial number
F2MQIJSLMGR.

In violation of 18 U.S.C. §§ 2428(a)(1) and (b)(1)(A).

A TRUE BILL.

s/ Foreperson
FOREPERSON

BENJAMIN C. GLASSMAN

UNITED STATES ATTORNEY bib).

|ATHER A. HILL (IL 6291633) S. COURTER SHIMEALL (0090514)
Assistant United States Attorney Assistant United States Attorney

14


producing and attempting to produce any visual depiction of such conduct, to wit: one or more
digital images depicting Jane Doe engaged in sexually explicit conduct, including oral and anal
sexual intercourse, bestiality, masturbation and the lascivious display of the genitalia; the
production of such visual depictions using materials that had been mailed, shipped and
transported in and affecting interstate and foreign commerce by any means, specifically a cellular
phone that was manufactured in whole or in part outside of the state of Ohio.

In violation of 18 U.S.C. §§ 2251(a) & (e).

COUNT FOUR

Between on or about January 9, 2018, and on or about January 17, 2018, in the Southern
District of Ohio, Defendant WILLIAM G. WEEKLEY did knowingly use a means and facility
of interstate and foreign commerce, that is, a cellular phone and Internet-based communication
platforms, to attempt to persuade, induce, entice, and coerce an individual who had not attained
the age of 18 years, specifically an individual the defendant believed to be an approximately 10-
year-old female, to engage in sexual activity for which any person could be charged with a
criminal offense, to wit, Ohio Revised Code § 2907.05, Gross Sexual Imposition, and 18 U.S.C.
§ 2251(a), Production of Child Pornography.

In violation of 18 U.S.C. § 2422(b).

COUNT FIVE
Between on or about January 9, 2018, and on or about January 17, 2018, in the Southern
District of Ohio, Defendant WILLIAM G. WEEKLEY did knowingly distribute one or more
visual depictions using any means and facility of interstate and foreign commerce, including a
cellular phone, the production of such visual depictions having involved the use of a minor

engaged in sexually explicit conduct, as defined in 18 U.S.C. § 2256(2)(A), and such depictions
5


FORFEITURE COUNT A
The allegations contained in Counts One through Three, Five, Six, Ten and Eleven of this
Second Superseding Indictment are hereby re-alleged and incorporated by reference for the
purpose of alleging forfeitures to the United States of America, pursuant to 18 U.S.C. § 2253.
As a result of the offenses alleged in Counts One through Three, Five, Six, Ten and
Eleven of this Second Superseding Indictment, and upon conviction thereof, Defendant
WILLIAM G. WEEKLEY shall forfeit to the United States:
a. All matter containing any visual depiction described in the allegations
contained in Counts One through Three, Five, Six, Ten and Eleven of this
Second Superseding Indictment; and
b, All property used or intended to be used to commit and to promote the
commission of the aforementioned violations in Counts One through Three,
Five, Six, Ten and Eleven of this Second Superseding Indictment, including
but not limited to the following:
i. Miscellaneous sexual paraphernalia; and

ii. One ZTE cellular phone, model N9519, MEID #
256691570301071363.

In violation of 18 U.S.C. §§ 2253(a)(1) and (3).

FORFEITURE COUNT B
The allegations contained in Count Four of this Second Superseding Indictment are
hereby re-alleged and incorporated by reference for the purpose of alleging forfeitures to the

United States of America, pursuant to 18 U.S.C. § 2428.

10


sexual activity for which any person could be charged with a criminal offense, to wit, Ohio
Revised Code § 2907.05, Gross Sexual Imposition.

In violation of 18 U.S.C. § 2422(b).

COUNT EIGHT
Between on or about December 13, 2017, and on or about January 8, 2018, in the

Southern District of Ohio, Defendant BRIAN S. PERKINS, did use a means and facility of
interstate and foreign commerce, that is, a cellular phone and Internet-based communication
platforms, to attempt to persuade, induce, entice, or coerce an individual who had not attained
the age of 18 years, specifically, Jane Doe, an individual who was, and whom the defendant
believed to be, an 11-year-old female, to engage in sexual activity for which any person could be
charged with a criminal offense, to wit, Ohio Revised Code § 2907.05, Gross Sexual Imposition.

In violation of 18 U.S.C. § 2422(b).

COUNT NINE
Between on or about December 13, 2017, and on or about January 8, 2018, in the

Southern District of Ohio, Defendant BRIAN S. PERKINS did knowingly make and publish,
and cause to be made and published, notices and advertisements seeking and offering to receive
visual depictions, the production of such visual depictions involving the use of a minor,
specifically, Jane Doe, an approximately 11-year-old female, engaged in sexually explicit
conduct, as defined in 18 U.S.C. § 2256(2)(A), and such visual depictions being of such conduct;
and such notices and advertisements were transported using any means and facility of interstate
and foreign commerce, by any means, including via cellular phones.

In violation of 18 U.S.C. §§ 2251(d)(1)(A), (2)(A), and (e).


being of such conduct, to wit: digital image files depicting Jane Doe, an approximately 10 to 11-
year-old female, engaged in oral sexual activity, bestiality, and the lascivious display of the
genitalia.

In violation of 18 U.S.C. §§ 2252(a)(2) and (b)(1).

COUNT SIX

On or about January 17, 2018, in the Southem District of Ohio, Defendant WILLIAM
G. WEEKLEY knowingly possessed matter, that is, digital files stored on a cellular phone that
contained one or more visual depictions; and such visual depictions were produced using
materials that had been shipped and transported in interstate and foreign commerce, the
production of such visual depictions having involved the use of minors engaging in sexually
explicit conduct, as defined in 18 U.S.C. § 2256(2)(A), and such visual depictions being of such
conduct, to wit: digital images files depicting Jane Doe, an approximately 10- to 11-year-old
female, engaged in oral and anal sexual intercourse, bestiality, and the lascivious display of the
genitalia,

In violation of 18 U.S.C. § 2252(a)(4)(B) and (b)(2).

COUNT SEVEN
Between on or about September 25, 2017, and on or about January 8, 2018, in the
Southern District of Ohio, Defendant FRANKLIN EUGENE PERRY, did use a means and
facility of interstate and foreign commerce, including a cellular phone and the Internet, to
persuade, induce, entice, and coerce, and to attempt to persuade, induce, entice and coerce, an
individual who had not attained the age of 18 years, specifically Jane Doe, an individual who

was, and whom the defendant believed to be, an approximately 10-year-old female, to engage in


visual depictions, the production of such visual depictions involving the use of a minor,
specifically, Jane Doe, an approximately 11-year-old female, engaged in sexually explicit
conduct, as defined in 18 U.S.C. § 2256(2)(A), and such visual depictions being of such conduct;
and such notices and advertisements were transported using any means and facility of interstate
and foreign commerce, by any means, including via cellular phones.

In violation of 18 U.S.C. §§ 2251(d)(1)(A), (2)(A), and (e).

COUNT THIRTEEN

Between on or about January 17, 2018, and on or about January 29, 2018, in the Southern
District of Ohio, Defendant TIMOTHY F. SULLIVAN, did use a means and facility of
interstate and foreign commerce, that is, a cellular phone and Internet-based communication
platforms, to attempt to persuade, induce, entice, and coerce an individual who had not attained
the age of 18 years, specifically Jane Doe, an individual who was, and whom the defendant
believed to be, an 11-year-old female, to engage in sexual activity for which any person could be
charged with a criminal offense, to wit, Ohio Revised Code § 2907.05, Gross Sexual Imposition,
and 18 U.S.C. § 2251(a), Production of Child Pornography.

In violation of 18 U.S.C. § 2422(b).


IN THE UNITED STATES DISTRICT COURT =

FOR THE SOUTHERN DISTRICT OF OHIO -_
EASTERN DIVISION THGAUG 23 PK 3:55

UNITED STATES OF AMERICA
v.

WILLIAM G. WEEKLEY(1)
Counts 1 through 6, 10 & 11

TIMOTHY F. SULLIVAN(2),
Counts 11 through 13

FRANKLIN EUGENE PERRY(3),
Count 7
and

BRIAN S. PERKINS(4)
Counts 8-10

THE GRAND JURY CHARGES:

Case No: 2:18- 7
CHIEF JUDGE SARGUS
18 U.S.C. § 2

18 U.S.C. §§ 2251(a) & (e)

18 U.S.C. §§ 2251(d) & (e)

18 U.S.C. §§ 2252(a)(2) & (b)(1)

18 U.S.C. §§ 2252(a)(4)(B) & (b)(2)
18 U.S.C. §§ 2253(a)(1) & (3)

18 U.S.C. § 2422(b)

18 U.S.C. §§ 2428(a)(1) &

(by)

SECOND SUPERSEDING INDICTMENT

GENERAL ALLEGATIONS

At all times relevant to this Second Superseding Indictment:

Jane Doe was a minor female, born in 2006, and resided in the Southern District of Ohio.

WILLIAM G. WEEKLEY was an adult male who resided in the Southern District of

Ohio and utilized various online usernames and accounts, including, funforfun83 and

williamweekley1212@gmail.com. WEEKLEY also utilized a ZTE cellular phone, which had

the capability to send and receive text (SMS) and picture (MMS) messages and to access the

Internet, and which was assigned the phone number 740-644-6520.


FORFEITURE COUNT D

The allegations contained in Count Thirteen of this Second Superseding Indictment are
hereby re-alleged and incorporated by reference for the purpose of alleging forfeitures to the
United States of America, pursuant to 18 U.S.C. § 2428.

As a result of the offense alleged in Count Thirteen of this Second Superseding
Indictment, and upon conviction thereof, Defendant TIMOTHY F. SULLIVAN shall forfeit to
the United States:

a. All property used or intended to be used to commit or to promote the
commission of the aforementioned violation in Count Thirteen of this Second
Superseding Indictment, including but not limited to the following:

i. One Apple i-Phone, model MG6A2LL/A, serial number
DNQP29FEGSMP.

In violation of 18 U.S.C. §§ 2428(a)(1) and (b)(1)(A).

FORFEITURE COUNT E
The allegations contained in Counts Nine and Ten of this Second Superseding Indictment
are hereby re-alleged and incorporated by reference for the purpose of alleging forfeitures to the
United States of America, pursuant to 18 U.S.C. § 2253.

As a result of the offenses alleged in Counts Nine and Ten of this Second Superseding
Indictment, and upon conviction thereof, Defendant BRIAN S. PERKINS shall forfeit to the
United States:

a. All matter containing any visual depiction described in the allegations

contained in Counts Nine and Ten of this Second Superseding Indictment; and

12


As a result of the offense alleged in Count Four of this Second Superseding Indictment,
and upon conviction thereof, Defendant WILLIAM G. WEEKLEY shall forfeit to the United
States:

a. All property used or intended to be used to commit or to promote the
commission of the aforementioned violation in Count Four of this Second
Superseding Indictment, including but not limited to the following:

i. One ZTE cellular phone, model N9519, MEID #
256691570301071363.

In violation of 18 U.S.C. §§ 2428(a)(1) and (b)(1)(A).

FORFEITURE COUNT C

The allegations contained in Counts Eleven and Twelve of this Second Superseding
Indictment are hereby re-alleged and incorporated by reference for the purpose of alleging
forfeitures to the United States of America, pursuant to 18 U.S.C. § 2253.

As a result of the offenses alleged in Counts Eleven and Twelve of this Second
Superseding Indictment, and upon conviction thereof, Defendant TIMOTHY F. SULLIVAN
shall forfeit to the United States:

a. All matter containing any visual depiction described in the allegations
contained in Counts Eleven and Twelve of this Second Superseding Indictment; and

b. All property used or intended to be used to commit and to promote the
commission of the aforementioned violations in Counts Eleven and Twelve of this

Second Superseding Indictment, including but not limited to the following:

i. One Apple i-Phone, model MG6A2LL/A, serial number
DNQP29FEGSMP.

In violation of 18 U.S.C. §§ 2253(a)(1) and (3).

ll


COUNT TEN

On or about January 8, 2018, in the Southern District of Ohio, Defendant WILLIAM G.
WEEKLEY did knowingly distribute, and Defendant BRIAN S. PERKINS did knowingly
receive, one or more visual depictions using any means and facility of interstate and foreign
commerce, including cellular phones, the production of such visual depictions having involved
the use of a minor engaged in sexually explicit conduct, as defined in 18 U.S.C. § 2256(2)(A),
and such depictions being of such conduct, to wit: digital image files depicting Jane Doe, an
approximately 11-year-old female, engaged in sexually explicit conduct, including oral and anal
sexual intercourse, and the lascivious display of the genitalia.

In violation of 18 U.S.C. §§ 2252(a)(2) and (b)(1), and 18 U.S.C. § 2.

COUNT ELEVEN

On or about January 17, 2018, in the Southern District of Ohio, Defendant WILLIAM
G. WEEKLEY did knowingly distribute, and Defendant TIMOTHY F. SULLIVAN did
knowingly receive, one or more visual depictions using any means and facility of interstate and
foreign commerce, including cellular phones, the production of such visual depictions having
involved the use of a minor engaged in sexually explicit conduct, as defined in 18 U.S.C.
§ 2256(2)(A), and such depictions being of such conduct, to wit: digital image files depicting
Jane Doe, an approximately 11-year-old female, nude and lasciviously displaying her genitalia.

In violation of 18 U.S.C. §§ 2252(a)(2) and (b)(1), and 18 U.S.C. § 2.

COUNT TWELVE
Between on or about January 17, 2018, and on or about January 29, 2018, in the Southern
District of Ohio, Defendant TIMOTHY F. SULLIVAN did knowingly make and publish, and

cause to be made and published, notices and advertisements seeking and offering to receive
8


Doe engaged in sexually explicit conduct, including oral sexual intercourse, masturbation and the
lascivious display of the genitalia; the production of such visual depictions using materials that
had been mailed, shipped and transported in and affecting interstate and foreign commerce by
any means, specifically a cellular phone that was manufactured in whole or in part outside of the
state of Ohio.

In violation of 18 U.S.C. §§ 2251(a) & ().

COUNT TWO

On or about November 11, 2017, in the Southern District of Ohio, Defendant WILLIAM
G. WEEKLEY did employ, use, persuade, induce, entice, and coerce a minor, specifically Jane
Doe, an approximately 10-year-old female, to engage in sexually explicit conduct as defined in
18 U.S.C. § 2256(2)(A), for the purpose of producing and attempting to produce any visual
depiction of such conduct, to wit: one or more digital image and/or video files depicting Jane
Doe engaged in sexually explicit conduct, including anal sexual intercourse, masturbation and
the lascivious display of the genitalia; the production of such visual depictions using materials
that had been mailed, shipped and transported in and affecting interstate and foreign commerce
by any means, specifically a cellular phone that was manufactured in whole or in part outside of
the state of Ohio.

In violation of 18 U.S.C.. §§ 2251(a) & (e).

COUNT THREE
Between on or about December 13, 2017, and on or about December 16, 2017, in the
Southern District of Ohio, Defendant WILLIAM G. WEEKLEY did employ, use, persuade,
induce, entice, and coerce a minor, specifically Jane Doe, an approximately 11-year-old female,

to engage in sexually explicit conduct as defined in 18 U.S.C. § 2256(2)(A), for the purpose of
4


that he engaged in various sex acts with Jane Doe. During his sexual activities with Jane Doe,
WEEKLEY used his ZTE cellular phone to create numerous sexually explicit images and.
videos of Jane Doe. WEEKLEY then sent the sexually explicit images of Jane Doe, via online
platforms and picture (MMS) messages, to individuals, including SULLIVAN and PERKINS,
whom he had met through his Craigslist activities described above.

SULLIVAN engaged in e-mail, text message and picture message communications with
WEEKLEY. During these text and picture message conversations, SULLIVAN requested
sexually explicit photographs of Jane Doe.

PERRY communicated with WEEKLEY via e-mail, phone calls, text messages, and
chats on the mobile application Wickr. During these communications, PERRY and
WEEKLEY discussed sexually abusing Jane Doe together, and made plans for PERRY to join
WEEKLEY in the sexual abuse of Jane Doe.

PERKINS communicated with WEEKLEY via e-mail. During the e-mail
conversations, PERKINS and WEEKLEY discussed WEEKLEY’s sexual abuse of Jane Doe,
and PERKINS requested sexually explicit photographs of Jane Doe and that WEEKLEY bring

Jane Doe to meet PERKINS for the purpose of PERKINS engaging in sex acts with Jane Doe.

COUNT ONE

On or about October 28, 2017, in the Southern District of Ohio, Defendant WILLIAM
G. WEEKLEY did employ, use, persuade, induce, entice, and coerce a minor, specifically Jane
Doe, an approximately 10-year-old female, to engage in sexually explicit conduct as defined in
18 U.S.C. § 2256(2)(A), for the purpose of producing and attempting to produce any visual

depiction of such conduct, to wit: one or more digital image and/or video files depicting Jane

3


TIMOTHY F. SULLIVAN was an adult male who resided in the Southern District of
Ohio and utilized various online usernames and accounts, including, timsull2006@hotmail.com.
SULLIVAN also utilized an Apple i-Phone, which had the capability to send and receive text
(SMS) and picture (MMS) messages and to access the Internet, and which was assigned the
phone number 614-271-5729.

FRANKLIN EUGENE PERRY was an adult male who resided in the Southern District
of Ohio and utilized various online usernames and accounts, including,
lucky772017@gmail.com and lucky72017. PERRY also utilized an Apple i-Phone, which had
the capability to send and receive text (SMS) and picture (MMS) messages and to access the
Internet, and which was assigned phone number 303-817-5112.

BRIAN S. PERKINS was an adult male who resided in the Southern District of Ohio
and utilized various online usernames and accounts, including,
justanormalguy2015@yahoo.com. PERKINS also utilized an Apple i-Phone, which had the
capability to access Internet-based communication platforms.

WEEKLEY, SULLIVAN, PERRY and PERKINS (hereinafter “the defendants”)
utilized the online classified advertisement website Craigslist to post and respond to
advertisements in the personals section of the website that sought partners for various sexual
activities and communications. Through their Craigslist activities, the defendants made online
contact with each other and others who shared, or whom they believed would share, their sexual
interest in minors, incest and child pornography. After making initial contact through the
Craigslist system, the defendants engaged in ongoing communications regarding these interests
via text (SMS) message and various online platforms and applications.

WEEKLEY had regular access to Jane Doe, and informed others with whom he

communicated online and via text message, including SULLIVAN, PERRY and PERKINS,
2


b. All property used or intended to be used to commit and to promote the
comunission of the aforementioned violations in Counts Nine and Ten of this Second
Superseding Indictment, including but not limited to the following:

i. One Apple i-Phone, model A1688, serial number DNPQX3DKGRYC.

In violation of 18 U.S.C. §§ 2253(a)(1) and (3).

FORFEITURE COUNT F
The allegations contained in Count Eight of this Second Superseding Indictment are
hereby re-alleged and incorporated by reference for the purpose of alleging forfeitures to the
United States of America, pursuant to 18 U.S.C. § 2428.
As a result of the offense alleged in Count Eight of this Second Superseding Indictment,
and upon conviction thereof, Defendant BRIAN S. PERKINS shall forfeit to the United States:
a. All property used or intended to be used to commit or to promote the
commission of the aforementioned violation in Count Eight of this Second
Superseding Indictment, including but not limited to the following:
i. One Apple i-Phone, model A1688, serial number DNPQX3DKGRYC.

In violation of 18 U.S.C. §§ 2428(a)(1) and (b)(1)(A).

FORFEITURE COUNT G
The allegations contained in Count Seven of this Second Superseding Indictment are
hereby re-alleged and incorporated by reference for the purpose of alleging forfeitures to the
United States of America, pursuant to 18 U.S.C. § 2428.
As a result of the offense alleged in Count Seven of this Second Superseding Indictment,
and upon conviction thereof, Defendant FRANKLIN EUGENE PERRY shall forfeit to the

United States:
13