O91 Rev. ML) Cini Corplaine fume. ‘ATROANOKE, VA UNITED STATES DISTRICT COURT ~ PILED ieee FEB 16 2017 ‘Wester District of Virginia UAC cueRK United States of America sey. a wena 1] MT 1ST SHANNON BOBROSKY CRIMINAL COMPLAINT 1, the complainant in this case, state that the following is true fo the best of my knowledge and belief. the county of ROANOKE inthe ‘On or about the date(s) of Unknown, betwee 9/2015 to 2/2017 WESTERN _ Districtof __VIRGINIA __, the defendant(s) violated: Code Section Offense Description 18 USC 225%(a) ‘Sexual Explottation of Chileren This er inal complaint is based on these facts: SEE ATTACHMENT ® Continued on the attached sheet omplainan's igrahre Jerre &. Harvard Ill SPECIAL AGENT Printed name and tle ‘Swom to before me and signed in my presence. Date: o2ne2017_ City and state: ROANOKE, VIRGINIA, HON. ROBERTS. BALLOU Prinied name and ile Case 7:17-mj-00015-RSB Document 1 Filed 02/16/17 Page 1of6 Pageid#: 1‘THE UNITED STATES DISTRICT COURT FOR THE ‘WESTERN DISTRICT OF VIRGINIA IN THE MATTER OF A CRIMINAL COMPLAINT / ARREST WARRANT FOR: caseno._ 7/7 Mg IS SHANNON M. BOBROSKY ARFIDAVIT IN SUPPORT OF A CRIMINAL COMPLAINT AND ARREST WARRANT I, Jerre E. Harvard DI, being first duly swom, depose and state the following: L_INTRODUCTION 1, Lam a Special Agent with the U.S. Department of Homeland Security (DHS), Office of Homeland Security Investigations (HSN), currently assigned to the Office of the Special Agent in Charge in Washington D.C. I have been awarded academic degroes of Bachelor of Science and Master of Science in Environmental Economies. I have been employed as a Special Agent with HSI since March, 2008. I am a graduate of the Federal Law Enforcement Training Center Criminal Investigator Training Program and Immigration and Customs Enforcement Special Agent Training academy, 1 am an “investigative or law enforcement officer” as defined in 18 U.S.C, § 2510(7), which grants the authority for such officers to conduct investigations and make arrests for offenses enumerated in Title 18 of the United States Code. 2. Imake this affidavit in support of a criminal complaint authorizing the issuance of an arrest warrant for Shannon M. Bobrosky (hereinafter referred to as “Bobrosky”), On February 15, 2017, Bobrosky admitted to producing images of child pomography in violation of Title 18 United States Code 2251(2), which makes it a crime for any person who employs, uses, persuades, induces, entices, or cocrees any minor to engage in, or who has a minor assist any other person to engage in, or who transports ‘any minor in or affecting interstate or foreign commerce, or in any Territory or Possession of the United States, with the intent that sueh minor engage in, any sexually explicit conduct for the purpose of producing any visual depiction of such conduct or for the purpose of transmitting a live visual depiction of such conduct, shall be punished as provided under subsection (e), if such person knows or has reason to know that such visual depiction will be transported or transmitted using any means or facility of interstate or foreign cormmerve or in or affecting interstate or foreign commerce or mailed, if that visual depiction was produced or transmitted using materials that have been mailed, shipped, or transported in or affecting interstate or foreign commerce by any means, including by computer, or if such visual depiction has actually been transported or transmitted using any means or oo Case 7:17-m)-00015-RSB Document 1 Filed 02/6/17 Page 2of6 Pageiat: 2,,{ ifacility of interstate or foreign commerce or in or affecting interstate or foreign commerce or mailed, 3. Imake this affidavit from personal knowledge based on my participation in this investigation, as well as from the factual information supplied to me orally and in ‘written form by other Special Agents, Officers, and law enforcement officials of HSI, Roanoke City Police Department (RCPD), the Federal Bureau of Investigation (FB, and the Pitsylvania County SheriffS Office. Since this Affidavit is being submitted for the limited purpose of obtaining an arrest warrant, I have not set forth every fact resulting from the investigation. 4, The following definitions, provided in 18 USC 2256, apply to this AfTidavi Case I, DEFINITIONS "Minor" means any person under the age of eighteen years; "Sexually explicit conduct” means 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; bestiality; . masturbation; sadistic or masochistic abuse; or v. lascivious exhibition of the genitals or pubic atea of any person; ¢. "Producing" means producing, directing, manufacturing, issuing, publishing, or advertising: 4. "Visual depiction” includes undeveloped film and videotape, data stored ‘on computer disk or by 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 @ permanent format; ©. "Child pomography" means any visual depiction, including any photograph, film, video, picture, or computer or computer-generated image or picture, whether made or produced by electronic, mechanical, or ‘other means, of sexually explicit conduct, where- i, the production of such visual depiction involves the use ofa minor engaging in sexually explicit conduct; ii, 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 : x? wo 7-mj-00015-RSB Document 1 Filed 02/16/17 Page 3of6 Pageide: BYIL_THE INVESTIGATION 5. Bobrosky has access cf eae eRe IME VICTIM 1 6, Based on information provided by law enforcement in Newark, New Jersey, on February 15, 2017, Roanoke City Police Department Officer Ryan Brady swore out a state of Virginia search warrant for a search of Bobrosky’ The search authorized the seizure and search of all computers and other storage devices that may give evidence of the possession, reproduction, distribution, or facilitation of child pomography or evidence of child sexual abuse, as well as other materials specified in the warrant. The warrant was issued by the magistrate of Roanoke City. 7. Roanoke City Police Detective Perez and I went to locate Bobrosky at her place of employment. We advised Bobrosky we had a search warrant for SEM Although not under arrest, Bobrosky signed a Miranda waiver and agreed to speak with law enforcement. Bobrosky was in possession of a cellular telephone at that time. 8. Law enforcement conducted a search of Bobrosky’ s BEGRERRB¥ond seized multiple electronic devices. 9. Bobrosky agreed to a voluntary interview at the Roanoke City Police Department (RCPD). During the interview, Bobrosky signed a RCPD Consent to Search Form, authorizing law enforcement to search the cellular telephone in her possession at the time she was encountered 10. The FBI Computer Analysis Response Team conducted a preliminary forensic review of the cellular telephone. ‘The FBI identified at least the following thumbnail images on Bobrosky’s phone: a. IMAGE I, IMAGE3, IMAGES, IMAGE10~ A female hand fondling the penis and genitalia ofa pre-pubescent boy with the genitalia as the focal point of the image. b, IMAGE 4 and IMAGES —a female mouth in very close proximity to a prepubescent boy’s exposed penis, appearing to simulate the moment before oral sex commences. 11. During the interview, Bobrosky was shown the images deseribed in Paragraph 10. She admitted the following about her production of sexually-explicit photographs of VICTIM-1: a, Bobrosky took pictures of VICTIM-1’s genitalia for purposes of distribution via the Kik messenger application and otherwise to persons with whom she had an online relationship. 3 Case 7:17-mj-00015-RSB Document1 Filed 02/16/17 Page 4of6 Pageid#: 4\ \ vbb. Bobrosky confirmed the identity of VICTIM-I as the young male in the images described in Paragraph 10. ©. Bobrosky stated the pictures were taken in Virginia, d. The female hand in the images described in Paragraph 10 is Bobrosky's hand, ce. The female mouth in the images described in Paragraph 10 is Bobrosky’s mouth, £ Bobrosky stored the images on her cellular phone, which is an LG phone. 12, Further review of the content of Bobrosky’s LG phone revealed an image of an individual appearing to be Bobrosky performing what appears to be oral sex on & currently unidentified minor. CONCLUSION 13, Your affiant is aware that (sea ERAGE are located in the Western District of Virginia, 14, Based on my training and experience, Tam aware that an [LG phone is comprised of components which ate made outside of the Commonwealth of Virginia, the images, therefore, were produced using materials shipped in interstate commerce. a. Further, I am aware that that Kik is a Canadian-based mobile messa; application, which uses the Internet for transmission, The internet is a means or facility of interstate commerce 15, Based on the aforementioned factual information, your affiant respectfully submits that there is probable cause to believe that Shannon Bobrosky has produced child pornography of XSERIES VICTIM-1, in violation of 18 USC 2251 (a). Respectfully Jerre ¥. Harvard Hil Special Agent Homeland Security Investigations Roanoke, Virginia 4 7 @ 7:17. RSB Filed 02/16/17 Page $ oo Case 7:17-mj-00015-RS8 Document Filed 02/16/17 Pages of6 Pageia#¥s, \ \\ye Subscribed and sworn to before me on the _/ day of February, 2017 HONORABLE ROBERT S. BALLOU | UNITED STATES MAGISTRATE JUDGE. Case 7:17-mj-00015-RSB Document 1 Filed 02/16/17 Page 6 of6 Pageid#: 6