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  1. United States District Court for the Eastern District of Michican
  2. Unived States of America
  3. v.
  4. THADDEUS LEWIS MCMICHAEL
  5.  
  6. Case: 2: 12-mj-20147
  7. Judge:  Unassigned
  8. Filed:  02-29-2012 At 10: 04 AM
  9. USA V. MCMICHAEL (CMP)(MRM)
  10.  
  11. Criminal Complaint
  12. I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
  13.  
  14. On or about the sate(s) of July 1, 2013 - February 17 2012 in the county of Oakland in the Eastern District of Michigan, the defendant(s) violated:
  15.  
  16. Code Section                                      Offense Description
  17. Title 18, United States Code, Section 2252A(a)(2) Receipt of Child Pornography
  18. Title 18, United States Code, Section 2252A(a)(5) Possession of Child Pornography
  19.  
  20. The criminal complaint is based on these facts:
  21. See attached addidavit.
  22. Continued on the attached sheet.
  23.  
  24. Sworn to before me and signed in my presence.
  25. Date:  February 29, 2011
  26. City and state:  Detroit, Michigan
  27.  
  28. Ryan E. Blanton, Special Agent, FBI
  29. Complainant
  30. Mark A. Randon, United States Magistrate Judge
  31. Judge
  32.  
  33.  
  34.  
  35. I, Ryan E. Blanton, a Special Agent (SA) with the Federal Bureau of Investigation (FBI), Detroit
  36. Division, being duly sworn, depose and state as follows:
  37.  
  38. 1. I have been employed as a Special Agent of the FBI since August 2009, and am currently
  39. assigned to the Detroit Division Cyber Crime Squad. While employed by the FBI, I have
  40. investigated federal criminal violations related to Internet fraud, computer intrusions, and the
  41. FBI's Innocent Images National Initiative, which investigates matters involving the online
  42. sexual exploitation of children. I have gained experience through training at the FBI
  43. Academy, post Academy training, and everyday work related to conducting these types of
  44. investigations.
  45.  
  46. 2. As a federal agent, I am authorized to investigate violations of laws of the United States and
  47. to execute warrants issued under the authority of the United States.
  48.  
  49. 3. On February 17, 2012, federal search warrants were executed at XXXXX Franklin River
  50. Drive, Apt 307, Southfielt, Michigan 48034 and XXXXX Kilbirnie Avenue, Lathryn Village,
  51. Michigan 48076 in furtherance of an investigation involving the receipt and possession of
  52. child pornography.
  53.  
  54. 4. I am submitting this affidavit in support of a complaint and arrest warrant authorizng the
  55. arrest of THADDEUS LEWIS MCMICHAEL for violations of Title 18, United States Code,
  56. Section 2252(a)(2) and 2252A(a)(5)(B), the receipt and possession of child pornography.
  57.  
  58. 5. The statements in this affidavit are based on the investigation of this matter by Affiant and
  59. other FBI personnel. Since this affidavit is being submitted for the limited purpose of
  60. securing a complaint and arrest warrant, I have not included each and every fact known to
  61. me concerning this investigation. I have set forth only the facts that I believe are necessary
  62. to establish probably cause to believe that THADDEUS LEWIS MCMICHAEL received and
  63. possessed child pornography.
  64.  
  65. 6. On June 24, 2011, the Detroit, MI,division of the FBI was contacted by the Loiusville, KY,
  66. division of the FBI concerning an individual on the social networking website
  67. www.facebook.com (Facebook), who was actively discussing child pornography and
  68. methods for downloading child pornography from the Internet. The Facebook user ID
  69. provided was MADTHAD08.
  70.  
  71. 7. On the following dates the Facebook profile MADTHAD08 was viewed by Addiant or other
  72. FBI personnel:
  73. : a. July 1, 2011
  74. : b. July 5, 2011
  75. : c. August 12, 2011
  76. : d. October 12, 2011
  77. : e. January 5, 2012
  78. : f. January 8, 2012
  79. Comments posted by the user ID MADTHAD08 included statements regarding methods to
  80. obtain child pornography on the Internet, methods of encrypting child pornography stored on
  81. a computer, and having recently masturbated while viewing child pornography.
  82.  
  83. 8. Facebook, Inc. was issued two subpoenas for subscriber information and access logs.
  84. Results obtained from Facebook, Inc., included access logs, with accompanying IP
  85. addresses and access times, as well as subscriber information as THAD MCMICHAEL.
  86.  
  87. 9. A search of the American Registry for Internet Numbers (ARIN) online database indicated
  88. that IP addresses provided by Facebook, Inc., were registered to the Internet Service
  89. Provider Comcast Cable Communications, Inc. Per their website, ARIN is a nonprofit
  90. organization responsible for managing the Internet numbering resources for North America,
  91. and a portion of the Caribbean.
  92.  
  93. 10. Results from administrative subpoenas sent to Comcast Cable Communications, Inc., for IP
  94. addresses and corresponding times of access provided by Facebook, Inc., revealed that, at
  95. those dates and times, the IP addresses were assigned to accounts registered to
  96. KIMBERLY BALLENGER, XXXXX Kilbirnie Avenue, Lathrup Village, Michigan 48076,
  97. THADDEUS MCMICHAEL, XXXXX Franklin River Drive, Apt 307, Southfield, Michigan
  98. 48034, and SPECS HOWARD SCHOOL, 19900 West 89 Mile Road, Southfield, Michigan
  99. 48075.
  100.  
  101. 11. On February 17, 2012, federal search warrants were executed at XXXXX Franklin River
  102. Drive, Apt 307, Southfield, Michigan 48034 and XXXXX Kilbirnie Avenue, Lathrup Village,
  103. Michigan 48076. A search of the Southfield residence resulted in the seizure of two laptop
  104. computers, one hard drive, two external hard drives, one flash drive, one mini SD flash card,
  105. 135 optical disks, two MP3 players, one Microsoft Xbox gming console, one Nintendo Wii
  106. gaming console, one Nintendo memory card, one cable modem, and one network router.
  107. No evidence was seized from the Lathrup Village residence.
  108.  
  109. 12. THADDEUS LEWIS MCMICHAEL (MCMICHAEL) was interviewed during the execution of
  110. the search warrand in Southfield. During the interview MCMICHAEL was shown a printout of
  111. the Facebook profile page for the user ID MADTHAD08 and confirmed the account and profile
  112. belonged to him. MCMICHAEL was then shown a series of printed screen shots containing
  113. statements he posted on his Facebook page and was asked to explain the posts. The
  114. following are the statements from the printed screen shots accompanied with
  115. MCMICHAEL'S responses:
  116.  
  117. : a. On 10/03/2011 in response to the statement "Stop downloading all that cee pee
  118. : Thad, you're just asking for it" being posted by another user on MCMICHAEL'S
  119. : Facebook page, MCMICHAEL wrote "WELL TELL 7 YEAR OLD GIRLS TO
  120. : STOP SUCKING DICK SO SEXY." MCMICHAEL claimed this post was a joke.
  121.  
  122. : b. On 11/02/2011, MCMICHAEL wrote "that feel after you fap to cp. It's a feel like
  123. : none other. It's like your floating on cloud 9 or something. fapping to some 40
  124. : year old woman with fake tits makes your cum smell rotten. But fapping to a 9
  125. : year old girl attempt to please some guy with a hairy stomach makes your cum
  126. : squirt out with such pure intensity that you feel like your floating on air. and the
  127. : way your dick feel, OH GPD YOUR DICK will feel so fuzzy and warm. You
  128. : moralfags need to at least try to fap to some cp at least once before you die.
  129. : Because there is no other feel like it." MCMICHAEL claimed this post was a
  130. : joke.
  131.  
  132. : c. On 11/27/11, MCMICHAEL wrote "all cp isn't rape, Sometimes the kids want it,
  133. : Most of the time they NEED it." MCMICHAEL claimed this post was a joke.
  134.  
  135. : d. On 12/01/2011, MCMICHAEL wrote "I gotta plan ahead, can't have all my
  136. : classmates knowing I walk around with 6 gigs of cp...on my keychain."
  137. : MCMICHAEL claimed this post was a joke.
  138.  
  139. : e. On 12/06/2011 in response to the question "How can you even be a pedo?"
  140. : being posted by another user on MCMICHAEL'S Facebook page, MCMIAHERL
  141. : wrote "anything younger than 16 is fine for me...thy have some 13 and younger
  142. : stuff in here." MCMICHAEL claimed these posts were a joke.
  143.  
  144. : f. On 12/06/2011, MCMICHAEL wrote "I can fap to the came cp video for weeks,
  145. : because it's sooo fucking hot!" MCMICHAEL claimed this post was a joke.
  146.  
  147. : g. On 12/08/2011, MCMICHAEL wrote "WHOS THE GIRL THAT WANTED TO SEE
  148. : THE RETARD GUT GET BEAT OFF BE A NURSE? WELL HERE IT IS IF
  149. : YOU STILL WNAT TO SEE IT [link to video] For disabled people, sexuality is
  150. : necessary...also it's CP...it's a nurse jacking off a 10 year old boy! not just any
  151. : 10 year old boy, a retard 10 year old boy!" MCMICHAEL claimed ot have
  152. : originally come across the video on 4Chan.org in the /b/ conversation thread.
  153. : MCMICHAEL guessed the age of the male in the video to be eight to twelve
  154. : years old. MCMICHAEL claimed the post was made as a joke.
  155.  
  156. : h. On 12/09/11, MCMICHAEL wrote "Yea, I carry around a 8 gb drive full of CP."
  157. : MCMICHAEL'S response to being asked about this post was "I plead the fifth."
  158.  
  159. : i. On 12/11/2011, MCMICHAEL wrote "I got my cp on truecrypt." MCMICHAEL
  160. : claimed this was a joke and that he did not have Truecrypt encryption software.
  161.  
  162. : j. On 12/17/2011, MCMICHAEL wrote "I'm not renting a damn laptop. I need to
  163. : keep at least 4 gigs of cp on my shit and I not dealing with takeing if off when I'm
  164. : done." MCMICHAEL claimed this post was a joke.
  165.  
  166. : k. On 12/20/2011, MCMICHAEL wrote "using the dsi XL web browser, no computer,
  167. : $70 to see if they can fix it, no refunds, not sure if CP is on it or not..."
  168. : MCMICHAEL claimed this post was a joke.
  169.  
  170. : l. On 01/04/2014, MCMICHAEL wrote "I JUST GOT THE GREATEST IDEA! what
  171. : if i adot a little girl? I'm sure she wouldn't mind becoming my sex slave if i take
  172. : her away from the orphenage. WHY DIDN'T I THINK OF THIS BEFORE? IT'S
  173. : FOIL PROOF! Once she become sef awear that i'm cumming inside of her
  174. : nighty, i'll ask her if she'd rather go back to the orphenage or come back to bed.
  175. : yes it's perfect! Theres no way she'd would turn me down. Now i just gotts
  176. : to locate the michigan adoption agency tomorrow and my plan will be put into
  177. : moation. Soon i'll have my very own loli and she'll have no where to run. BWAH
  178. : HAHAHAHA BWAH HAHAHAHAAA." MCMICHAEL claimed that this post was a
  179. : joke and that he couldn't possibly actually adopt a little girl anyway.
  180.  
  181. : m. On 01/20/2012, MCMICHAEL wrote "megaporn was the first place I ever got
  182. : fappable CP. I twas 2 girls fucking each other. So hot I still fap to it to this day.
  183. : RIP MAGAPORN. Gone too soon..." MCMICHAEL state that he had located
  184. : and downloaded the described video about two or three years prior to the
  185. : interview.
  186.  
  187. : n. On 01/20/2012, MCMICHAEL wrote "wake up, brother at school, mom at work
  188. : i'm gonna finish what i started, go to the computer, internet is off because of
  189. : unpaid bill, forgot my cp usb at home, doesn't have cinamax on demand THIS
  190. : HOUSE IF FUCKING SHIT!" MCMICHAEL stated that he had actually forgotten
  191. : his USB drive but that he was joking about it containing child pornography.
  192.  
  193. : o. On 02/01/2012, MCMICHAEL wrote "HOLY FUCK! I went to the liberby today to
  194. : send some resamays out and left my usb drive pluged in a computer with all my
  195. : cp, my resamay along with my name and address on if for about 30 mins. I can
  196. : only thank kami-sama that nobody looked through it." MCMICHAEL stated that
  197. : he had been at the library but he did not leave a USB drive behind.
  198.  
  199. : p. On 02/01/2012, in response to the post "All your CP fits on one flash drive? I
  200. : expected better from you" being written by another user on MCMICHAEL'S
  201. : Facebook page, MCMICHAEL wrote "it's 20 gigs." MCMICHAEL stated that he
  202. : did not own a twenty-gigabyte flash drive.
  203.  
  204. 13. On February 17, 2012, and February 28, 2012, Affiant previewed the eight gigaybe usb
  205. flash drive belonging to MCMICHAEL. During the Affiant's review, numerous images and
  206. videos of real children engaged in sexually explicit conduct including, but not limited to, the
  207. lascivious display of the genitals and pubic area of any person, were located in the following
  208. directories:
  209. : a. \things\don't click
  210. : b. \things\don't click\teens
  211. : c. \things\don't click\cp
  212. : d. \things\don't click\cp\cp
  213.  
  214.  
  215. 14. As of this date, Affiant found approximately 300 to 350 images and videos of child
  216. pornography among MCMICHAEL's electronic media seized during the execution of the
  217. Southfield search warrant.
  218.  
  219. 15. Material found in the directory "\things\don't click\cp\cp" included images of tee-shirt designs
  220. featuring images of child pornography. The images showed an internet address of
  221. shirtmockup.com. The website shirtmockup.com allows users to upload images to design
  222. their own tee-shirts and download the resulting image for free.
  223.  
  224. 16. Also located onthe usb flash drive was a copy of MCMICHAEL'S resume.
  225.  
  226. 17. Based on Affiant's review of the materials found in the directory "\things\don't click\cp\cp" on
  227. the usb flash drive belonging to MCMICHAEL, MCMICHAEL's statements, and Affiant's
  228. training and experience, Affiant believes that MCMICHAEL used the Internet, a means and
  229. facility of interstate or foreign commerce, to further his conduct related to his receipt and
  230. possession of child pornography.
  231.  
  232. 18. Affiant concluded that THADDEUS LEWIS MCMICHAEL was the only individual who had
  233. received and possessed child pornography at the residence, XXXXX Franklin Rive Drive,
  234. Apt 307, Southfield, Michigan 48034 or XXXXX Kilbirnie Aveneu, Lathrup Village, Michigan
  235. 48076.
  236.  
  237. 19. Based on the aforementioned factual information, your affiant respectfully submits that there
  238. is probable cause to believe that THADDEUS LEWIS MCMICHAEL received and possessed
  239. child pornography, using the Internet, a facility of interstate and foreign commerce, while
  240. within the Eastern District of Michigan.
  241.  
  242. 20. Your affiant, therefore, respectfully requests that this Honorable Court issue a complaint and
  243. arrest warrant for THADDEUS LEWIS MCMICHAEL, for violations of Title 18, United States
  244. Code, Section 2252A(a)(2) and 2252A(a)(5)(B), the receipt and possession of child
  245. pornography.
  246.  
  247. Ryan E. Blanton
  248. Special Agent
  249. Federal Bureau of Investigation
  250.  
  251. Sworn and subscribed before me this 29th day of February, 2012.
  252.  
  253. MARK A. RANDON
  254. UNITED STATES MAGISTRATE JUDGE
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