I declare under penalty of perjury that the statements above are true and correct to the best of my
knowledge and belief.

rell’ submitted, _

William Heppler

Sergeant — SFPD ICAC/

Task Force Officer

Homeland Security Investigations

Subscribed and _s) to before me on November 2 ry » 2016.

HONORABLECTAUREL BEELER
UNITED STATES MAGISTRATE JUDGE


c. Advanced Peace Officer Standards and Training Certificate

d. Robert Presley Institute of Criminal Investigation, 80-hour Basic Investigations
Training

e. Northern California HIDTA — Search Warrants “A Through Z” 2012
f. Undercover and Plainclothes Operations Course.

g. ICI Detective Symposium 2010-14 (CA POST)

h. Detecting Danger Course (NCHIDTA)

i. 40 hour Interview and Interrogation Course (BATI)

I have also received on the job training from seasoned inspectors regarding the investigation of
cases involving child pornography and sexual enticement of children on-line.

5. The statements set forth in this affidavit are based on my own investigation,
knowledge obtained from other HSI Task Force Officers, other law enforcement personnel;
search warrants executed on the Subject’s electronic accounts; my review of documents and
computer records related to this investigation; oral and written communications with others who
have personal knowledge of the events and circumstances described herein; review of public
source information, including information available on the Internet; interviews with a Victim
related to this investigation; and records received via legal process.

APPLICABLE LAW

6. Title 18 U.S.C. § 2251(a) prohibits any person who employs, uses, persuades,
induces, entices, or coerces any minor to engage in any sexually explicit conduct for the purpose
of producing any explicit depiction of such conduct or for the purpose of transmitting a live
depiction of such conduct.

7. Title 18 U.S.C. § 875(d) prohibits any person who, with intent to extort from any
person, any money or anything of value, transmits in interstate or foreign commerce any
communication containing any threat to injure the property or reputation of the addressee or of
another.

8. Title 18 U.S.C. § 2252(a)(2) prohibits any person from knowingly receiving or
distributing any visual depiction using any means or facility of interstate or foreign commerce or
that has been mailed, or has been shipped or transported in or affecting interstate or foreign
commerce, or which contains materials which have been mailed or so shipped or transported, by
any means including by computer, or knowingly reproduces any visual depiction for distribution
using any means or facility of interstate or foreign commerce or in or affecting interstate or
foreign commerce or through the mails, if the producing of such visual depiction involves the use
of a minor engaging in sexually explicit conduct, and such visual depiction is of such conduct.

2


Example 1: Located in “Lots of Stuff” folder, Digital Video -
3e092048-62c4-467a-94ce-d921 bb80cc2e 2.mp4. An
approximately 0-18 month old infant is lying face down when an
adult male inserts his finger into the infant child anus. The adult
male proceeds to insert his erect adult male penis into the infant’s
anus.

Example 2: Located in “Lots of Stuff” folder, Digital Video -
1cda40b8-34ad-4f55-b21 0-£96836343e12.mp4. A juvenile male
between the approximate ages of 4 and 7 years old is orally
copulating an adult male erect penis.

Example 3: Located in “Lots of Stuff” folder, Digital Video -
shootl2yo.mpg. A juvenile male between the approximate ages of
10 and14 years old is laying on a bed. The juvenile’s hands are
bound with a brown rope. An adult male removes the juvenile’s
underwear and begins to manipulate the juvenile’s penis. The
adult male proceeds to digitally penetrate the juvenile with his
finger and sodomize the juvenile with his erect penis.

Example 4: Located in “Shared” folder, Digital Video - 5.mp4. A
juvenile male between the approximate ages of 6 and 9 is bound
with rope, his hands are tied behind his back. The juvenile boy
proceeds to orally copulate the erect penis of an adult male. The
adult male proceeds to insert his erect penis into the anus of the
juvenile boy and sodomize the boy. The adult male additionally
digitally penetrates the buys anus with his finger. The juvenile
boy’s hands remain tied behind his back during the entire incident.

Example 5: Located in “Shared” folder, Digital Image -
tumblr_n6zoeqobk71tdqvtqol_1280,jpg. The image depicts two
juvenile males approximately between the approximate ages of 9
and 13 years old completely nude laying head to toe. The juvenile
boys are engaging in oral copulation of each other.

25. San Francisco police officers obtained a search warrant for the person and
property of VIRAMONTES. They located him, took custody of his smart phone, and
transported him to the SFPD Hall of Justice. There, VIRAMONTES was advised of his Miranda
rights. He waived his rights and spoke with me and another officer.

26. VIRAMONTES statements included verification of his name, email address,
Dropbox account, and last residential address. He admitted to possessing child pornography,
including video of children as young as five years of age engaging in sexual acts. He further
stated that he has been downloading and distributing child pornography for approximately one
and a half years, often through the use of his Apple iPhone. VIRAMONTES was then placed

7


or modified to appear that an identifiable minor is engaging in sexually explicit
conduct.

The term “child erotica,” as used herein, means materials or items that are
sexually arousing to persons having a sexual interest in minors but that are not
necessarily obscene or do not necessarily depict minors in sexually explicit poses
or positions.

The “Internet” is a global network of computers and other electronic devices that
communicate with each other. Due to the structure of the Internet, connections
between devices on the Internet often cross state and international borders, even
when the devices communicating with each other are in the same state.

“Internet Service Providers” (“ISPs”), as used herein, are commercial
organizations that are in business to provide individuals and businesses access to
the Internet. ISPs provide a range of functions for their customers including
access to the Internet, web hosting, e-mail, remote storage, and co-location of
computers and other communications equipment. ISPs can offer a range of
options in providing access to the Internet including telephone based dial-up,
broadband based access via digital subscriber line (“DSL”) or cable television,
dedicated circuits, or satellite based subscription. ISPs typically charge a fee
based upon the type of connection and volume of data, called bandwidth, which
the connection supports. Many ISPs assign each subscriber an account name — a
user name or screen name, an "e-mail address," an e-mail mailbox, and a personal
password selected by the subscriber. By using a computer equipped with a
modem, the subscriber can establish communication with an Internet Service
Provider (“ISP”) over a telephone line, through a cable system or via satellite, and
can access the Internet by using his or her account name and personal password.

“Internet Protocol address” or “IP address” refers to a unique number used by a
computer to access the Internet. IP addresses can be “dynamic,” meaning that the
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 which is used each time the computer accesses the Internet.
IP addresses are also used by computer servers, including web servers, to
communicate with other computers.

“URL” is an abbreviation for Uniform Resource Locator and is another name for
a web address. URLs are made of letters, numbers, and other symbols ina
standard form. People use them on computers by clicking a pre-prepared link or
typing or copying and pasting one into a web browser to make the computer fetch
and show some specific resource (usually a web page) from another computer
(web server) on the Internet.

“Website” consists of textual pages of information and associated graphic images.
The textual information is stored in a specific format known as Hyper-Text Mark-

4


9.

Title 18 U.S.C. § 2252(a)(4)(B) prohibits any person from knowingly possessing

or accessing with the intent to view, or attempting or conspiring to possess or access with the
intent to view, 1 or more books, magazines, periodicals, films, video tapes, or other matter which
contain any visual depiction that has been mailed, or has been shipped or transported using any
means or facility of interstate or foreign commerce or in or affecting interstate or foreign
commerce, or which was produced using materials which have been mailed or so shipped or
transported, by any means including by computer, if the producing of such visual depiction
involves the use of a minor engaging in sexually explicit conduct and such visual depiction is of

such conduct.

10.

DEFINITIONS

The following definitions apply to this Affidavit:

. The term “minor,” as defined in 18 U.S.C. § 2256(1), refers to any person under

the age of eighteen years.

. The term “sexually explicit conduct,” 18 U.S.C. § 2256(2)(A), is defined as actual

or simulated (i) sexual intercourse, including genital-genital, oral-genital, anal-
genital, or oral-anal, whether between persons of the same or opposite sex; (ii)
bestiality; (iii) masturbation; (iv) sadistic or masochistic abuse; or (v) lascivious
exhibition of the genitals or pubic areas of any person.

. The term “visual depiction,” as defined in 18 U.S.C. § 2256(5), includes

undeveloped film and videotape, data stored on computer disc or other electronic
means which is capable of conversion into a visual image, and data which is
capable of conversion into a visual image that has been transmitted by any means,
whether or not stored in a permanent format.

. The term “computer,” as defined in 18 U.S.C. §1030(e)(1), means an electronic,

magnetic, optical, electrochemical, or other high speed data processing device
performing logical, arithmetic, or storage functions, and includes any data storage
facility or communications facility directly related to or operating in conjunction
with such device.

. The term “child pornography,” as defined in 18 U.S.C. § 2256(8), means any

visual depiction, including any photograph, film, video, picture, or computer-
generated image or picture, whether made or produced by electronic, mechanical,
or other means, of sexually explicit conduct, where (A) the production of such
visual depiction involves the use of a minor engaging in sexually explicit conduct;
(B) such visual depiction is a digital image, computer image, or computer-
generated image that is, or is indistinguishable from, that of a minor engaging in
sexually explicit conduct; or (C) such visual depiction has been created, adapted,


16. I reviewed the (7) digital files of upload logs provided by Dropbox for the above
described Dropbox user. The upload files date back to August of 2013. While reviewing the
titles of the videos uploaded to the above mentioned Drobox user’s account, I immediately
recognized numerous title of videos consistent with title of child pornography videos, starting on
08/19/2013 with a video titled: /Private/BIBCAM suce_11 yo with 14yo.avi.

17. Additionally, an IP log for the above described Dropbox user was provided for
dates and times the user uploaded videos to Dropbox. Of the IP addresses that were provided,
one IP address was used in a greater frequency that any of the others provided. A check of
publicly available records located online by an organization known as the American Registry of
Internet Numbers, determined that the IP address is assigned to Comcast Cable Communications,
LLC.

18. Based on my training and experience, I know that Internet Service Providers
maintain, log, and store account information for subscribers which can include but not be limited
to service address, e-mail accounts, IP history related to session dates and times, online digital
storage, etc.

19. I completed a law enforcement database query of Krishna VIRAMONTES and
obtained a date of birth, California Driver’s License number, Social Security Number, and
address.

20. | Comcast Cable Communications, LLC confirmed the physical address to which
the IP address was assigned. This address is the same address as the one identified for
VIRAMONTES in the law enforcement database query.

21. Dropbox later provided additional digital media for the above described Dropbox
user. The digital media was separated into seven electronic file folders, entitled “Apps”;
“Camera Uploads”; “Jack”; “Lots of Stuff’; “Personal”; “Shared”; and “Theater Movies.”

22. I completed a preview of the above mentioned digital media files located in the
seven electronic file folders within Dropbox account. I located approximately, 287 child
pornography videos and 392 child pornography images located in the Folder and associated
subfolders entitled “Lots of Stuff.” I located approximately, 21 child pornography videos and
one child pornography image located in the Folder and associated subfolders entitled “Camera
Uploads.” I located approximately 27 child pornography videos and one child pornography
image located in the Folder and associated subfolders entitled “Personal.” I located
approximately, 128 child pornography videos and 159 child pornography images located in the
Folder and associated subfolders entitled “Shared.”

23. In total, from my training and experience I identified approximately 463 digital
videos of child pornography and 553 digital images of child pornography within the Dropbox
account belonging to Krishna VIRAMONTES, approximately 21 GB of child pornography.

24. Below are Examples of child pornography located within VIRAMONTES’
Drobox Account:


AO 257 (Rev. 6/78)

DEFENDANT INFORMATION RELATIVE TO A CRIMINAL ACTION - IN U.S. DISTRI COURT

comptaint [CJ inrormation [1] inpictMENT Name of District Court, or esl bali
UO surerseDInG NORTHERN DISTRIC FOP SORNA
SAN FRANCISCOPBIVISION 2,

7>———— OFFENSE CHARGED

18 U.S.C. Section 2251(a) - Production of Visual Depictions of oO Petty
Minors Engaging in Sexually Explicit Conduct

oO Minor DEFENDANT - U.S
18 U.S.C. Section 875(d) - Extortion Through Interstate Misde-
Commerce C1 meanor | |p KRISHNA VIRAMONTES
Felony

PENALTY: Predaction -Maiaim Preon'Tam ora Moa DISTRICT COURT NUMBER M
roduction - Minimum Prison Term of 15 years and Maximum
Prison Term of 30 years; Extortion - Max. Prison Term of 20 years; 8 1 6 % 1 5 4 3 Aq
Maximum Fine of § 250,000; = 2G 8
Maximum Term of Supervised Release of 3 years;

Mandatory Special Assessment of $100 per count.

DEFENDANT

PROCEEDING
Name of Complaintant Agency, or Person (& Title, if an

HSI summons was served on above charges

oO person is awaiting trial in another Federal o1
give name of court

2) [J Isa Fugitive

3) [] |s on Bail or Release from (show District)

oO this person/proceeding is transferred from another district

per (circle one) FRCrp 20, 21, or 40. Show District
IS INCUSTODY

4) (J On this charge

this is a reprosecution of

charges previously dismissed 5) [J On another conviction
OO which were dismissed on motion SHOW } [1] Federal [J State
of: DOCKET NO.
6) Awaiting trial on other charges
U.S. ATTORNEY DEFENSE
O Oo If answer to (6) is "Yes", show name of institution
San Francisco County
this prosecution relates to a "Yes"
pending case involving this same Has detainer [] Yes ele
defendant MAGISTRATE been filed? [J No filed
CASE NO. Month/Day/¥.
prior proceedings or appearance(s) DATE OF > lonth/Day/Year
(J before U.S. Magistrate regarding this ARREST 9/29/16
defendant were recorded under Or... if Arresting Agency & Warrant were not
Name and Office of Person DATE TRANSFERRED Month/Day/Year
Furnishing Information on this form BRIAN STRETCH TO U.S. CUSTODY
U.S. Attorney [] Other U.S. Agency
Name of Assistant U.S. (F This report amends AO 257 previously submitted
Attorney (if assigned) Maffei and Kreuzkamp

ADDITIONAL INFORMATION OR COMMENTS

PROCESS:
(J SUMMONS (J No PROCESS*

If Summons, complete following:
[J Arraignment [_] Initial Appearance

WARRANT Bail Amount: No Bail

* Where defendant previously apprehended on complaint, no new summons or
warrant needed, since Magistrate has scheduled arraignment
Defendant Address:

Date/Time: Before Judge:

Comments:

G2



You’re going to get mail every day of the week
I hope your parents like the video footage they see

I have your parents email and Facebook
I’m sending them some files of things you do
You don’t wanna answer me

Wait until 10minutes
10minutes I will start sending files

One every hour
Yea you fucking other guys

Minor One:
please don’t
It’s not funny

32. Instagram owns and operates a free-access social-networking website of the
same name that can be accessed at http://www.instagram.com. Users can access Instagram
through the Instagram website or by using a special electronic application created by the
company that allows users to access the service through a mobile device. Instagram allows
users to send interstate and foreign communications to other users using connections to the
Internet, an international network of interconnected computers.

FACTS ESTABLISHING PROBABLE CAUSE AS TO LAMON

33. Information that I have collected over the course of this investigation establishes
probable cause to believe that Harrison Drake LAMON violated the following federal laws:
Title 18, United States Code, Section 2252(a)(2) (Receipt of Distribution of Child Pornography)
and 2252(a)(4)(B) (Possession of Child Pornography).

34. | The SFPD ICAC Unit review of VIRAMONTES’ iPhone also discovered
message communications between VIRAMONTES and an individual identified as “Harrison”
from at least June 26, 2016. I conducted a records check and found that the telephone number
associated with “Harrison” in VIRAMONTES’ iPhone was associated with Harrison D.
LAMON. Further records check and search warrants issued to telephone service providers
confirmed the telephone number VIRAMONTES associated with “Harrison” is used by Harrison
D. LAMON.

35. | VIRAMONTES and LAMON exchanged child pornography. On July 7, 11, 12,
and 13, 2016, VIRAMONTES sent LAMON nine (9) child pornography videos. One of the
videos depicts a prepubescent boy, approximately seven (7) years old, having oral and anal intercourse
with an approximately twelve (12) year old boy in a field.

9


under arrest and booked into San Francisco County Jail for California Penal Code charges for the
Possession and Distribution of child pornography.

27. SFPD ICAC Unit reviewed VIRAMONTES’ iPhone and discovered he had
engaged in a sexual relationship with a 15-year old boy (Minor One) from May of 2016 through
September of 2016. SFPD ICAC Unit was able to locate Minor One.

28. The Minor One confirmed the sexual relationship with VIRAMONTES and
indicated that VIRAMONTES had filmed some of their sexual encounters.

29. While examining VIRAMONTES’ iPhone, the SFPD ICAC Unit discovered that
VIRAMONTES had produced sexually explicit videos of having anal and oral sex with Minor
One, whom he had tied to the bed using a scarf or rope, and had distributed those videos of
Minor One to various other persons with whom he was actively trading child pornography. For
example, on or about June 24, 2016, VIRAMONTES sent one such person a child pornography
video of Minor One with the message “That was in my room.” VIRAMONTES sent this person
five more child pornography videos before sending him a video of VIRAMONTES performing
oral copulation on Minor One. VIRAMONTES and this person then continue to text about all
the sexual things they would want to do to Minor One.

30. | Minor One told me that he sought to end the sexual relationship with
VIRAMONTES in or around July 2016, but continued the sexual relationship because
VIRAMONTES threatened to reveal the child pornography videos of Minor One to Minor One’s
Parents.

31. For example, on or about September 9, 2016, Minor One received the following
series of Instagram messages from VIRAMONTES:

VIRAMONTES:

DON’T IGNORE ME (Minor One)

You could’ve had an orgy with you being the center
But go ahead meet some else

They’re going to abuse you

Don’t play with me
You will be the one to get fucked in the end kid

I have every message you’ve ever sent to me there is nothing you can say or
manipulate to make you sound good. I have the real you. Every time you come
over you’re on camera.

You can’t refute digital evidence

Please try me

Please you’ll be scared to walk out your front door
Sleep well


up Language (“HTML”) and is transmitted from web servers to various web
clients via Hyper-Text Transport Protocol (“HTTP”).

FACTS ESTABLISHING PROBABLE CAUSE AS TO VIRAMONTES

11. Information that I have collected over the course of this investigation establishes
probable cause to believe that VIRAMONTES violated the following federal laws: Title 18,
United States Code, Sections 2251(a) (Production of Visual Depictions of Minors Engaging in
Sexually Explicit Conduct) and 875(d) (Extortion Through Interstate Communications).

12, On July 26, 2016, I was assigned to investigate a San Francisco Police
Department (SFPD) Case that was generated from a Cybertipline Report made by the National
Center for Missing and Exploited Children (NCMEC) and provided to the SFPD Internet Crimes
Against Children (ICAC) Unit via the Silicon Valley ICAC Task Force.

13. The Cybertipline Report related to possible criminal activity submitted to
NCMEC by Dropbox Inc. (“Dropbox”). Dropbox allows users to create a special folder on their
computers, which Dropbox then synchronizes so that it appears to be the same folder (with the
same contents) regardless of which device is used to view it. Files placed in this folder are also
accessible via the Dropbox website and mobile apps. Dropbox uses afreemium business model,
wherein users are offered a free account with a set storage size and paid subscriptions for
accounts with more capacity.

14. Dropbox reported that a Dropbox user, who has the email address
Krishna. VIRAMONTES@gmail.com; Screen/User name: Krishna; and User ID ending in 5790,
had uploaded digital files including of child pornography, on May 24, 2016. The uploaded files
included 10 videos of child pornography and 7 logs of uploads from the Dropbox user for a total
of 17 digital files of suspected child pornography.

15. I reviewed the 10 digital files of submitted by Dropbox and confirmed the files
are child pornography. Two examples of the files are detailed below:

Example 1: file name - be60Scf8-a844-488a-9099-30fa3b262894 -
is a digital video that depicts an approximately 9-12 year old
juvenile male completely nude laying on a bed, blindfolded, with a
testicle clamp around his scrotum, and his hands and feet bound.
A nude male adult with an erect penis ties the juvenile boys bound
hands to a bed frame. The adult male begins to perform oral sex on
the juvenile by while manually manipulating his own erect penis.

Example 2: file name - bed0850e-c412-447a-894a-60974c] b832c-
is a digital video that depicts a nude prepubescent juvenile male
genitalia, anus and legs. From the size of the development, the
juvenile male is approximately 2-5 years of age. A nude adult
male with an erect penis is shown sodomizing the juvenile boy.


AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT AND ARREST WARRANT

I, William Heppler, Sergeant with the San Francisco Police Department and Task Force Officer
with the United States Department of Homeland Security (HSI), being duly sworn, hereby
depose and state as follows:

INTRODUCTION

1. I make this affidavit in support of a criminal Complaint against Krishna
VIRAMONTES for violation of Title 18, United States Code, Sections 2251(a) (Production of
Visual Depictions of Minors Engaging in Sexually Explicit Conduct) and 875(d) (Extortion
Through Interstate Communications) and Harrison Drake LAMON for violation of Title 18,
United States Code, Section 2252(a)(2) (Receipt or Distribution of Child Pornography) and
2252(a)(4)(B) (Possession of Child Pornography).

2. The facts set forth in this affidavit are based on my own personal knowledge,
knowledge obtained from other individuals during my participation in this investigation,
including other law enforcement officers, my review of documents and computer records related
to this investigation, communications with others who have personal knowledge of the events
and the circumstances described herein, and information gained through my training and
experience. Because this affidavit is submitted for the limited purpose of establishing probable
cause in support of a Complaint, it does not set forth each and every fact that I, or others, have
learned during the course of the investigation.

AGENT BACKGROUND

3. I, Sgt. William Heppler #1726, am a San Francisco police officer. I am employed
by the City and County of San Francisco and have been so employed for over ten years. Iam
currently assigned to the Investigations Bureau as an Inspector in the Special Victims Unit. In
my current assignment, my primary responsibility is to investigate allegations of domestic
violence, sexual assault, child physical and sexual abuse, and internet crimes against children. In
connection with my duties and responsibilities as a law enforcement officer, I have also testified
in judicial proceedings. I am also a Task Force Officer with the Department of Homeland
Security, Homeland Security Investigations.

4. During my career, I have investigated and or have been involved in the
investigation of hundreds of domestic violence and child abuse cases. I have conducted
interviews of victims and witnesses of domestic violence, sexual assault and child abuse. I have
received formal training at the San Francisco Police Academy in, and am familiar with, the
investigation, processing of evidence, and identification techniques associated with domestic
violence, sexual assault, and child physical and sexual abuse. In addition to the San Francisco
Police Academy, I have completed the following:

a. 16 hour Search Warrant Preparation course (NCHIDTA)

b. Bachelor of Science. California Polytechnic State University, San Luis Obispo
1


AO 91 (Rev. LI/I1) Criminal Complaint ‘a
UNITED STATES DISTRICT COURT . fa Ep

for the 2, A
Northern District of California

United States of America
Vv.

KRISHNA VIRAMONTES and HARRISON DRAKE
LAMON

Defendant(s)

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 5/24/16 through 9/14/16 in the county of San Francisco in the
Northern District of California , the defendant(s) violated:
Code Section Offense Description
18 U.S.C. § 2251(a) Production of Visual Depictions of Minors Engaging in Sexually Explicit
Conduct
18 U.S.C. § 875(d) Extortion Through Interstate Commerce
18 U.S.C. § 2252(a)(2) Receipt or Distribution of Child Pornography
18 U.S.C. § 2252(a)(4)(B) Possession of Child Pornography

This criminal complaint is based on these facts:

As set forth in the attached Affidavit of William Heppler, Sergeant with the San Francisco Police Department and Task
Force Officer wtih the U.S. Department of Homeland Security

@ Continued on the attached sheet. yj

Approved as to form: Q li

= ‘Complainant's signature
VOX yee oe.

illi I FPD q fi
AUSA Karen Kreuzkamp William Heppler, SI Sgt., HSI Task Force Officer

Printed name and title

Sworn to before me and signed in my presence. P
Date: 4 pk 2P) b a |

Judge's signature }

City and state: San Francisco, California Hon. Laurel Beeler, U.S. Magistrate Judge
Printed name and title



AO 257 (Rev. 6/78)

DEFENDANT INFORMATION RELATIVE TO A CRIMINAL ACTION - IN U.S. DISTRICT COURT

COMPLAINT C0 inrorMATION Oo INDICTMENT

PENALTY: Receipt - Minimum Prison Term of 5 years and Maximum
Term of 20 years; Possession - Max. Prison Term of 20 years;
Maximum Fine of $ 250,000;
Maximum Term of Supervised Release of 3 years;
Mandatory Special Assessment of $100 per count.

CI suPERSEDING

istrate Location

Name of District Court, Pry rope idgaf
IERN DIS

OFFENSE CHARGED
18 U.S.C. Section 2252(a)(2) - Receipt or Distribution of Child () Petty
Pornography
C1 Minor
18 U.S.C. Section 2252(a)(4)(B) - Possession of Child Bedi
Pornography | isde~

NOR ORNIA
yore DIVISION
\ 4 ay 7F D

DISTRICT COURT NUMBER

16 71543

DEFENDANT

PROCEEDING
Name of Complaintant Agency, or Person (& Title, if any)

HSI

person is awaiting trial in another Federal or State Court,
Oo give name of court

this person/proceeding is transferred from another district
Oo per (circle one) FRCrp 20, 21, or 40. Show District

this is a reprosecution of
oO charges previously dismissed

which were dismissed on motion SHOW
of DOCKET NO.
([] U.S. ATTORNEY = [[] DEFENSE }
this prosecution relates to a
(J pending case involving this same
defendant MAGISTRATE

CASE NO.
prior proceedings or appearance(s)

(before U.S. Magistrate regarding this
defendant were recorded under

Name and Office of Person
Furnishing Information on this form BRIAN STRETCH

[JU.S. Attorney [] Other U.S. Agency

Name of Assistant U.S.
Attorney (if assigned)

PROCESS:
[] sumMONS [J] NO PROCESS*

If Summons, complete following:
(Arraignment [J Initial Appearance

Defendant Address:

WARRANT

IS NOTIN CUSTODY
Has not been arrested, pending outcome this proceeding.
) [J Ifnot detained give date any prior
summons was served on above charges

2) [J |s a Fugitive

3) oO Is on Bail or Release from (show District)

IS INCUSTODY
4) [] On this charge

5) [-] On another conviction

} (Federal [] State
6) [J Awaiting trial on other charges
If answer to (6) is "Yes", show name of institution

If "Yes"
} give date

Has detainer L] Yes

been filed? [I] No filed
DATE OF > Month/Day/Year
ARREST

On... if Arresting Agency & Warrant were not

DATE TRANSFERRED Month/Day/Year
TO U.S. CUSTODY

Maffei and Kreuzkamp
ADDITIONAL INFORMATION OR COMMENTS

Date/Time:

(J This report amends AO 257 previously submitted

Bail Amount: No Bail

* Where defendant previously apprehended on complaint, no new summons or
warrant needed, since Magistrate has scheduled arraignment

Before Judge:

Comments:



36. | VIRAMONTES sent LAMON additional child pornography videos depicting
prepubescent children engaged in sexual acts on or about August 27, 2016 and September 6,
2016.

37. Onor about July 16, 2016 LAMON sent VIRAMONTES two (2) child
pornography images. One of the images depicts two approximately nine (9) to ten (10) year old
juvenile boys. One of the boys has his penis exposed and the other child is grasping it with his
hand, masturbating the other child.

38. | Onor about September 4, 2016, LAMON sent VIRAMONTES child erotica
images. The images depict prepubescent juvenile boys in various stages of undress and posing in
sexually provocative poses.

39. | Onor about September 7, 2016, LAMON sent VIRAMONTES several child
pornography and child erotica images. The child pornography images depict prepubescent
juvenile boys engaging in sexual acts, and the child erotica depict prepubescent juvenile boys in
various stages of undress and posing in sexually provocative poses. LAMON sent
VIRAMONTES additional child pornography and child erotica images on or about September 8,
11, 13, and 14, 2016.

CONCLUSION

40. Based on the above mentioned investigation and arrest of VIRAMONTES on
California State Penal Code Charges and images contained in VIRAMONTES above mentioned
Dropbox Account, on his iPhone and in his various Social Media Account (Facebook, Instagram,
KIK) I believe that VIRAMONTES obtained and possessed child pornography. Based upon the
forensic analysis of the Chats that VIRAMONTES had on his iPhone and through his social
media account, as well as Minor One’s statement, I believe that VIRAMONTES produced,
distributed and received child pornography.

41. Based on my training and experience and the facts set forth in this Affidavit, there
is probable cause to believe that VIRAMONTES produced one or more visual depictions of a
minor engaging in sexually explicit conduct and of child pornography, in violation of 18 U.S.C.
§ 2251(a), and, with the intent to extort, transmitted in interstate commerce, communication of a
threat to another person, in violation of 18 U.S.C. § 875(d).

42. Based on my training and experience and the facts set forth in this Affidavit, there
is probable cause to believe that LAMON knowingly received or distributed child pornography,
in violation of 18 U.S.C. § 2252(a)(2) and knowingly possessed child pornography, in violation
of 18 U.S.C. § 2252(a)(4)(B).

MW
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