Case 1:10-mj-00042-HKS

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FILED

United States District

for the Western District of New York United States of America v. MICHAEL LESINSKI
Defendant

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Case No.

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CRIMINAL COMPLAINT I, the complainant in this case, state that the following is true to the best of my knowledge and belief. From On or about the date of April 18, 2005, continuing to on or about April 24, 2005, in the Western District of New York, and elsewhere, the defendant violated.l.L U.S.c. 371 (Conspiracy) ,an offense described as follows: the defendant, MICHAEL LESINSKI, did knowingly, willfully and unlawfully combine, conspire and agree together with others, including Ronald Tills, to commit an offense against the United States, that is, to knowingly transport women in interstate and foreign commerce, with the intent that said women engage in prostitution, in violation of Title 18, United States Code, Section 2421; and that at least one overt act was committed in furtherance of the conspiracy, in that the defendant, MICHAEL LESINSKI, on April 18, 2005, did rent limousines in order to transport said women from the Buffalo airport to Niagara Falls Ontario, Canada, with the intent that the women engage in prostitution;

This criminal complaint is based on these facts:

'}t

Continued on the attached sheet.

Complainant's signature

Jennifer Allio, Special Agent, Federal Bureau of Investigation

Printed name and title

Sworn to before me and signed in my presence.

1!ittPl?\f4-t
Judge's signature

City and State:

Buffalo, New York

H. KENNETH SCHROEDER Jr.

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A F F I D A V I T

State of New York County of Erie City of Buffalo

ss:

I, JENNIFER AMO, being duly sworn, hereby states:

1.

am

Special

Agent

with

the

Federal

Bureau

of I am

Investigation have been currently

assigned

to the Buffalo, New York Field Office. of the FBI for eleven Western District
("HTTFIf),

a Special assigned

Agent to the

years. York

of

New

Human

Trafficking Task Force and Alliance work Human Trafficking Among the members of of

and I am assigned to

investigations and Civil Rights violations. the HTTF are special agents and from the

Department Enforcement Office.

Homeland

Security,

Immigration

CUstoms

("ICE") and deputies

from the Erie County Sheriff's with

I have been involved in a number of investigations

the HTTF relating to human trafficking, including investigations of sex trafficking.

2.

I make this affidavit in support of a Criminal Complaint

charging MICHAEL LESINSKI, with conspiracy to violate the Mann Act (Title 18, United States Code, Section 2421), in violation of Title 18, United States Code, Section 371.

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3.

This affidavit is based on information I received during of an organization known as the Royal Order of

my investigation Jesters,

as well as information

obtained by other investigators.

I have not included each and every fact known to me concerning this investigation, and have set forth those facts that are necessary to establish probable cause to believe that MICHAEL LESINSKI did

knowingly conspire with other individuals to violate the Mann Act.

THE CRIMINAL STATUTE

4.

The investigation of MICHAEL LESINSKI and others involves

a conspiracy to violate the Mann Act, Title 18, United States Code, Section 2421, which provides in pertinent part:

Whoever knowingly transports any individual in interstate or foreign commerce, , with intent that such individual engage in prostitution .

THE ROYAL ORDER OF JESTERS

5.

The

Royal

Order

of

Jesters

("ROJII) is

a world

wide

fraternal organization

whose membership

is limited to individuals

invited to join by other members.

The motto of the ROJ is "mirth On occasion, a

is king.1I The ROJ has local chapters or "courts." local court or group of local courts in the

same geographical

location sponsor social gatherings known as \\booksof the play" or

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"books."

The sponsoring

courts organize

the "books" and arrange Jesters from The ROJ also of a national "book" was held

for food, lodging, and entertainment at the "book." allover sponsors the country may attend the local "books". a yearly national "book," the equivalent

convention.

In April, 2005, the Jester's national

in Niagara Falls, Ontario, Canada.

6.

As set forth below, a typical feature of a "book of the ("Jester Girls") who engage in Arrangements for the

play" is the presence of prostitutes

commercial sex acts with members of the ROJ.

prostitutes are generally made by the organizer of the "books", or the region hosting the national "book." On occasion, individual

Jesters may make arrangements

to transport prostitutes to "books."

THE INVESTIGATION

6.

Beginning

in

January,

2008,

in

conjunction

with

an

investigation of the

of the Buffalo Chapter of the ROJ, several members were interviewed by As myself set and other below, agents those

chapter the

conducting

investigation.

forth

individuals eventually pled guilty to Mann Act violations resulting from their transport, in interstate commerce, of prostitutes to ROJ functions with the intent that the prostitutes engage in commercial sex acts with members of the ROJ.

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7.

In January and February 2008, John Trowbridge, a retired and member

captain with the Lockport, New York, Police Department of the ROJ, told investigators, Jester "books" throughout

including myself, about a number of States and Canada he had

the United

attended.

He stated that prostitutes

were present at the "books"

and were available to perform commercial sex acts with members of the ROJ. Buffalo Supreme He described a number of occasions where members of the Court, Court including Judge, Ronald Tills, then a New York State made

and his

law clerk,

Michael

Stebick,

arrangements

for Jester Girls to attend "books" intending that the sex acts with members of ROJ1

Jester Girls engage in commercial

8.

Trowbridge

further

stated that Tills was in charge of "book" which 2005 took place in

transportation Niagara This Falls,

for the 2005 national Ontario, was Canada,

in April

(April 20 - 24). "Jester Girls"

transportation

for ROJ members

and the

(prostitutes).

Trowbridge

related that Tills delegated that duty

to MICHAEL LESINSKI, a member of the ROJ and then an active deputy sheriff with the Erie County (NY) Sheriff's Department. Trowbridge

On March 20, 2009, Trowbridge pled guilty in the Western District of New York to a violation of the Mann Act. In the plea agreement, Trowbridge admitted transporting women from western New York to out of state Jester "books" intending that the women engage in commercial sex acts at those functions. Tills and Stebick, were referenced in the plea agreement by their job titles, as being complicit in that criminal activity with Trowbridge.
1

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informed me that LESINSKI rented a limousine to transport the women who were to perform commercial sex acts at the national "book" from the Buffalo/Niagara Airport in Cheektowaga, New York, to the hotel Trowbridge believed that 12 to

in Niagara Falls, Ontario, Canada.

14 women attended the conference, all from out of New York State. Trowbridge identified LESINSKI as a member of the ROJ who traveled to other "books" and who utilized the services of prostitutes.

9. that

In February 2008, I interviewed a local female who stated Trowbridge, and Stebick had recruited her to be a four ROJ

Tills,

Jester Girl at ROJ events.

She attended

approximately

events at their behest where she engaged in sex acts in exchange for money with several members of the ROJ.

10. described

In March 2008, I interviewed Michael his association with the ROJ,

Stebick. began

Stebick in 1998.

which

Stebick related that at ROJ "books" (at a hotel) there is typically a hospitality room where a list of women found. to (and room numbers) can be

The ROJ members can then visit the rooms and pay. the women in sexual acts. Stebick described specific Jester

engage

"books" where this activity occurred, including an occasion where he drove Kentucky his motor in October home, 2005. at Tills' request, to a ROJ event in those on the motor and a woman.

Stebick identified

home trip as Tills,

Trowbridge,

other ROJ members,

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The woman, who was recruited by Tills, engaged

in commercial

sex

acts in the motor home on the way to the event and at the event2

11. in Niagara

Stebick stated that he did not attend the national "book" Falls, Ontario, Canada. Stebick mistakenly believed

that the Niagara Falls national than in 2005.

"book" took place in 2006, rather

Stebick stated that he was aware that LESINSKI had (in 2006)

rented a limousine to transport "girls" from the airport but did not know the details of that incident.

12. the

In April 2008, Trowbridge provided the investigation with addresses, and phone numbers of 13 women he knew

names,

traveled through the Buffalo airport to the Niagara Falls, Ontario, Canada, national "book" in April 2005, to engage in commercial sex Trowbridge had spoken to each of the on their way to the

acts with members of the ROJ.

women while they were at the Buffalo Airport national "book" in Canada. prostitutes in attendance spoken.

Trowbridge stated there were additional at the national "book" with whom he had

not personally

On August 7, 2008, Stebick pled guilty in the Western District of New York, to conspiracy to violate the Mann Act. The plea was in connection with the trip to Kentucky in October 2005.
2

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13. described

In

June

2008,

interviewed

Ronald

Tills.

Tills Tills

his lengthy resume of activities

with the ROJ.

described how women were recruited to provide sex in exchange for money at ROJ events. a national He stated that are usually about 30 women at who had the

"book". He described a network of members

ability to supply such women.

He described instances in which he

contacted women for that purpose.

14. District

On September of New York

4, 2009, Tills pled guilty in the Western to a Mann Act violation for his role in

transporting Kentucky.

the prostitute

to the October 2005, Jester "book" in

In the plea agreement, Tills also acknowledged his role women to work as prostitutes national "book" at the Niagara of the Falls, is

in procuring Ontario,

Canada, stated

(the date

event

erroneously

as Spring,

2006, when,

in fact, the national

"book" took place April 20-24, 2005) For purposes of relevant conduct, the parties further agree that in or about Spring, 2006, the defendant arranged for the transportation of women from the Buffalo airport to the organization's national meeting then being held in Niagara Falls, Ontario, Canada. The women came from various parts of the United States to the national meeting in order to have sex with members of the organization in exchange for money. The defendant agreed with representatives of the national organization that he would see to it that members of the Buffalo chapter of the organization would women from the Buffalo airport to the hotel in Niagara Falls, Ontario, Canada where the meeting was being held. The women did attend the meeting and were in fact transported from, and back to, the
7

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Buffalo airport by persons whom the defendant had given this responsibility. While at organization's national meeting in Niagara Falls, Ontario, Canada, the women did engage in various sex acts, including sexual intercourse, with members of the organization in exchange for money.

15.

During the course of the June, 2008, interview of Tills,

Tills identified MICHAEL LESINSKI as one of the individuals who he assigned the duty to transport the women who engaged in commercial sex acts to and from the Buffalo Ontario, Canada, hotel. airport and the Niagara Falls,

16.

During the course of the investigation I obtained records Limousine. There was a receipt/invoice signed by

of Lakeview

MICHAEL LESINSKI, dated April 18, 2005, reflecting two limousines 2005. for dates of service of April

that he rented 24,

20, 2005/April

One was to driven by LESINSKI, the other by a person noted The receipt also noted that "pick-up" would be at the Airport" and "to: Falls View Canada drop off." (See

as "AL." "Buffalo

attached exhibit A) .

17.

I also reviewed United States Border crossing records for 20-24, 2005, which matched the plates of the The border crossing records reflect

the period of April

limousines rented by LESINSKI.

that the limousines rented by LESINSKI crossed the Rainbow Bridge inbound to the United States as follows:

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Limousine 1 4/19/05 4/20/05 4/20/05 4/20/05 4/24/05 4/24/05 4/24/05 Limousine 2 4/20/05 4/20/05 4/20/05 4/24/05 2:02 pm 3:57 pm 6:08 pm 1:13 pm. 9:56 9:46 11:52 3:02 pm am am pm

5:49 am 7:27 am 9:43 am

CONCLUSION

Whereforet based on the foregoingt I respectfully probable

2005t

submit that
t

cause exists to believe that from on or about April 18

20053t

continuing up to on or about April 24t of New York and elsewheret the

in the Western MICHAEL

District

defendant {

LESINSKIt did knowinglYt willfully and unlawfully combinet conspire and agree together with otherst including Ronald Tillst to commit an offense against the United
St.a t.e , s

that

.i s ,

to

knowingly

transport women in interstate and foreign comme rce , with the intent that said women engage in prbstitutiont in violation of Title 18
t

On April 5t 2010t the defendantt MICHAEL LESINSKI { and his attorneYt Rodney o. Personiust executed a Tolling Agreement in which LESINSKI agreedt inter alia, to not to assert the statute of limitations as a defense to the conduct described in this affidavit related to the events of April, 2005.
3

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United States Code, Section 2421; and that at least one overt act was committed in furtherance of the conspiracy, in that the

defendant, MICHAEL LESINSKI, on April 18, 2005, did rent limousines in order Niagara to Falls transport Ontario, said women from the the Buffalo that airport to

Canada,

with

intent

the women

engage in prostitution; Code, Section 371.

all in violation of Title 18, United States I request that a criminal complaint in the

form annexed be issued.

before me of June,

10

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"/1+ .Sub~al C.0 oc,r7J----Non-Refundable Deposit

$ -=-......---==----=-~cL-/\?() OJ OJ .$ t.; 0 _

, Date of Service $ damage to the vehicle done

Sign and keep Pink copy. rerum Whie & Yellowcopy with deposit. Gratuity nor included. Not responsible for lost or stolen articles,