Professional Documents
Culture Documents
JO SH U A J.K ELLY ,
a/k/a,RU STO U S,''
Defendant.
CR IM IN A L C O V ER SH EET
Did this m atteroriginate from a m atterpending in the N orthern Region ofthe United
States Attom ey'sO ffice priorto October 14, 2003? Yes X No
Did thism atteroriginate from a m atterpending in the CentralRegion ofthe U nited States
Attorney's O ffice priorto Septem ber 1, 2007? Y es - X No
W IFRED O A .FERR ER
U NITED STATES ATTO RN EY
BY: . p
N CISCO R.M A D L
A SSISTAN T UN ITED STATES A TTORN EY
Fla.Bar.N o.41481
99 N .E.4th Street
M iam i,Florida 33132-2111
TEL (305)961-9159
FAX (305)530-7976
francisco.maderal@ usdoj.gov
Case 1:17-mj-02572-JG Document 3 Entered on FLSD Docket 04/27/2017 Page 2 of 18
AO 91(Rev.08/09) Cri
minalComplaint
United StatesofAmerica
casexo.l4 <;
'o ; 5 p2 -.
7-
0
JOSHUA J.KELLY,a/k/a,''USTOUS,''
Thiscriminalcomplaintisbased on thesefacts:
SEE ATTACHED AFFIDAVIT.
W Continuedontheattachedsheet.
Complainant'
ssi
gnature
Lili
ta Infante,S/A ,DEA
Printed nameandtitle
o -t-, )?J.z-
, f J: Judge'
ssignature
AFFIDA V IT
1,LILITA IN FAN TE , SpecialA gentw ith the Drug Enforcem entA dm inistration being
,
firstduly sw ol'
n,hereby depose and state as follow s:
INTRODUCTION
l am an investigative or law enforcem ent officer of the U nited States w ithin the
offenses enum erated in Title 18, United StatesCode,Section 2516(1),and in Title 21,United
This affidavit is m ade in support of a crim inal com plaint charging Joshua J.
K ELLY, aIV a, 'QU STOU S,''w ith conspiracy to distribute in narcotics in violation of Title 21
,
United States Code, Section 846, and conspiracy to launder m oney, in violation of Title
UnitedStatesCode,Section 1956(h).
I have not necessarily included in the affidavit each and every fact known to m e
about the m atters set forth herein, butonly those facts and circum stances that l believe are
sufficientto establish probable cause forthe Courtto sign a crim inalcom plaint.
inform ation provided by other sw ol'n 1aw enforcem ent officers and on m y experience and
PROBABLE C AUSE
This application stem s from an ongoing clim inal investigation into drug dealers
operating on crim inal online m arketplace w ebsites, including a w ebsite know n as the V alhalla
M arket.
Case 1:17-mj-02572-JG Document 3 Entered on FLSD Docket 04/27/2017 Page 4 of 18
Valhalla M arketis designed to prom ote the anonym ous sale ofillegalitem s, such asnarcotics,in
exchange for Bitcoin and other, peer-to-peer crypto-currencies (also known as, virt
ual
currencies).
A s set forth in m ore detailbelow ,probably cause exists that K ELLY is trafficking
conspiracywiththeunknownadministratorts)oftheValhallaMarket.
A .TH E TO R N ETW O R K A N D TH E RD AR K W EB''
8. The lnternet is a globalnetw ork ofcom puters and other devices. Devices directly
colm ected to the Intenzet are identified by their unique IP address. This num ber is used to route
inform ation betw een devices. Generally, whcn one device contacts a second device, the tirst
devicemustbe directed to the IP addressofthe second device. M oreover,w hen the firstdevice
that the second device know s w here to direct its response. A ccordingly, the tw o connected
user will type the dom ain name of the website- which comm only corresponds to a plain -
language nam e for the w ebsite, c.g., w ww .google.com - into the Uniform Resource Locator
(EURL'')baratthetop oftheirwebbrowsers.ThisdomainnamewillbetransmittedtoaDomain
Name System (ttDNS'') server,which then translates the domain name into the appropliate
num ericalIP address,and thereby allow sthe userto connectw ith the requested w ebsite.
Case 1:17-mj-02572-JG Document 3 Entered on FLSD Docket 04/27/2017 Page 5 of 18
thatm anner.
addressforany known URL and the registered ownerand location ofany IP address. Thus,w ith
anonm ous.
com m unication sent through Tor is directed through num erous relays w ithin the network and
-
wrapped in a layer ofencryption ateach relay- such thatthe end recipientofthe com m unication
software and use it to access the intem et. The user simply inputs a w ebsite IP address or UR L
through severalrelays and then outto the destination so thatthe destination w ebsite can only see
lI
l
Pome Comptlter wsN,
w-.google.
wom
'
:I23.4.
$6.789
In this illustration of a standard internet connection, the w ebsite w w w .google.com can see the
browserto connectto thewebsite in the firstplace. Thus,each users'IP address is know n to the
15. Sim ilarly,any person m onitoring the intenzet traffic at a point betw een the two
would see the connection between IP 123.456.786 and w w w .google.com and know that those
On the other hand,in the case of a Tor netw ork com m unication, w hen a person
connects to a website, the traffic is encrypted and routed through m ultiple relays, and that
TorRelay l
lP:00l.1 I-(J0l
Hom eCompater
1P'
.123.456.139
$:,
Max.googre-com
TorRelay 2
lP:1 1.6(2.66)
TorRelay 3
IP;(
/):.90:,
903
In this illustration of a Tor netw ork connection, the website w ww .google.com cannot see the
homecomputerIP address(123.456.789),
.instead itonly seesthe IP addressofthedevice itis
directly connectd to,the third (ortexif')Torrelay,with IP address003.003.003,which IP
address cannotbe traced back to the hom e com puteruser.
ln addition,any person m onitoring the intenzcttraftic ata pointbetw een the hom e
computer and www.google.com and would not know that those two devices were
com m unicating. lnstead, depending on the m onitoring point, that person would only see thc
directconnectionsbetweenthehomecomputerandfirst(orGGentry'')Torrelay,between thefirst
and second, or second and third Tor relays, orbetween the third (or%
exif')Torrelay and
ww w .google.com .
18. A s w ith a standard intenw tconnection, the user m ust have known the U RL or IP
address ofthe website in order to have directed a connection to itthrough the Tor network.
Case 1:17-mj-02572-JG Document 3 Entered on FLSD Docket 04/27/2017 Page 8 of 18
A ccordingly,although the IP addressofthe user is hidden from the w ebsite, theIP addressofthe
w ebsite m ustbeknown to the user- the anonym ity is only one-w ay.
The Tor netw ork addresses this problem through a feature known as 'hidden
SCrVices.''
C .H idden Services:W ebsite A nonym ity Provided by the Tor N etw ork
To achieve true,tw o-w ay anonym ity, the Tor netw ork also enables w ebsites to
operate inside the network in a m anner thatconceals the tnle IP address of the com puter server
hosting the w ebsite. Such hidden services'' operating on Tor have com plex w eb addresses
,
21. This alleviates the need for a Tor netw ork user to know the tl-ue IP address of a
neitherthe user nor the w ebsite knows the other's IP address- tw o-w ay anonp nity is achieved.
22. Crim inals have taken advantage of the D ark w eb to create w ebsites w ith online
m arketplaces dedicated to the trafficking of controlled substances and other illicit goods.
on the D ark W eb, and how -to guides such as: l-low to Buy D rtlgs O nline from Darknet
M arkets.''3
transactions online,in a m anner sim ilar to w ell-know n online m arketplaces such as eBay. Like
eBay:
create accounts on V alhalla to advertise their products, such as narcotics or hacked com puter
passwords,and buyers create accountsto browse sellers'products and purchase them ;in this
com plaints,providing technicalassistance,and allow ing custom ers to post review s of Valhalla
vendors. V alhalla also provides a m eans by which its users can com m unicate w ith its
24. How ever, unlike legitim ate online m arketplaces, V alhalla is dedicated and
com m erce by w orking to ensure the anonym ity ofits adm inistrators, asw ellas ofthe buyersand
sellers who participate in com m erce on the w ebsite. The w ebsite is designed to achieve this
anonym ity prim arily by operating asa hidden service on the Tornetw ork.
Case 1:17-mj-02572-JG Document 3 Entered on FLSD Docket 04/27/2017 Page 10 of 18
To further prom ote anonym ity,purchases are m ade prim arily in bitcoin
subsequently transfersthe funds to the seller's accountorw alletupon satisfaction ofthe tenns of
sale. ln doing so, Valhalla also provides a 4tum bling'' or ttm ixing'' service which essentially
scram bles m ultiple buyer-seller Bitcoin transactions together in order to conceal the bitcoin
paym ents from buyer to seller or com m ission paym ents to the adm inistrator. Thus,there is no
25. The true identity of the individual or individuals w ho control and operate the
Valhallawebsite,f.c.,theadministratorts),isunknown.
E .<CU STO U S''V endor on V alhalla and O ther D ark W eb M arkets
26. Since at least O ctober of 2015, agents identified a narcotics vendor, know n as
GtU STOU S,''appearing on num erous dark w eb m arketplaces, including A lphabay, V alhalla, and
M iddle Earth. O n several occasions,DEA agents have m ade undercover online purchases of
from EEU STO U S''on the M iddle Earth M arketfor 0.2749 bitcoins.ln the description,USTOUS
10 pills of M DM A from %CU STO U S'' on the V alhalla M arket for 0.05250935 BTC and
0.07679129 BTC respectively. ln the description for alpha-pv p, U STO U S stated: ''Blue
W recked Benz M ega Speed Press,''containing ''Ethylone, A -PV P,Hexadron and A M P salts.'' ln
8
Case 1:17-mj-02572-JG Document 3 Entered on FLSD Docket 04/27/2017 Page 11 of 18
M ail to M iam i, Florida w ith respective return addresses in Saint Louis and Festus, M issouri.
Laboratoryresultshaveconfirmedtheitemsreferencedinparagraph (a)containedheroinandthe
itemsreferencedinparagraph (b)containedalpha-pvp andM DM A.
28. tEU STOU S'' has conducted thousands of transad ions on num erous D ark W eb
140 transactions, M iddle Earth M arket w ith at least 159 transactions.4 O n a1l of these
m arketplaces, 4CU STO U S'' advertised dangerous opioids, synthetic drugs and Schedule 11
oxycodone.
4 D EA w as able to confirm that CCU STO U S'' is the sam e vendor on V alhalla and A lphabay
M arket by confirm ing that in each instance EEU STO U S'' w as advertising the sam e public
encryption key and signature. Persons w ho are involved w ith Dark W eb narcotics trafticking
utilize public key encryption to com m unicate with other purchasers and sellers on the
m arketplace in order, for instance, to provide infonuation such as a shipping address. lf the
m essage was not encrypted, it w ould be visible by the adm inistrators of the Dark W eb
m arketplace,and by law enforcem ent,if the marketplace server was ever located and seized.
Public key encryption allows the sender of a message to encrypt that m essage using a long
passcode know n as a public key,which the recipientofthe m essage publicly providesto anyone
w ishing to com m unicate w ith them .Thatm essage, in turn,can onlybedecryptedby therecipient
using a corresponding private key known only to them . The m ostcom m only used encryption is
thatknownasPretty GoodPrivacy(PGP)encryption.AlmostallDark W eb marketplacevendor
profiles advertise a public PG P key for thispum ose;the PG P key, therefore,doubles asa unique
fingep rintvisibleacrossdark web platform s.
9
Case 1:17-mj-02572-JG Document 3 Entered on FLSD Docket 04/27/2017 Page 12 of 18
Decem ber 5,2016 revealed thatU STOU S distributed controlled substances on V alhalla atleast
F.K ELLY & IQELLY Business A ssociated with SCU STO U S''
30. Since the tim e of the first controlled purchase from EEU STOU S''on October
2015,D EA and other1aw enforcem entagents have been able to identify KELLY as Q4U STO U S''
by analyzing the shipping records associated w ith the dnlg package shipped to D EA via the
UnitedStatesPostalService(USPS).
31. U SPS records revealed thatthe tirst undercover drug purchase w as shipped using
postage purchased atEndicia.com ,''an online com pany w hieh allow s itscustom ersto printtheir
ship the drugs to UC agents w as accessed from IP address 97.91.242.30 belonging to internet
service provider Charter Com m unications and used Vanilla prepaid debit cards to purchase
$9,433 worth ofpostage for shipm ents allover the United States from Septem ber 9, 2015 to
Septem ber 8, 2016. A Subpoena of Charter Com m unications revealed that the IP address
97.91.242.30 is being utilized exclusively by internet selw ice subscliber H EA DY W A REZ w ith
service addl-ess located at 1802 Broadw ay St.,Cape G irardeau, M O . A public database search
A search of M issouri D epartm ent of Revenue revealed that K ELLY lists the
aforem entioned HEA D Y W A REZ address ashis residentialand m ailing address on hisM issouri
driver'slicense.
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Case 1:17-mj-02572-JG Document 3 Entered on FLSD Docket 04/27/2017 Page 13 of 18
trash bin. During the trash pull,agentsrecovered 26 pieces ofpaper with varioushandwritten
acronym s, colors and num bers, such as ttl0 yellow Benz'' ::85 X an'' k:10 O C 40 orange'' 6
D& G .'' These acronym s closely m atched 6tU STO U S'' drug listings on V alhalla M arket and
A lphabay M arket, such as, EE300m g GO LD BEN Z SPEED BA LL ,'' CCOC 40 D ark Orange
experience,as well as the listing descriptions provided by EEU STOU S'' the acronym ttB enz''
stands for controlled substance benzodiazepine, O C 40 stands for O xycodone 40m g, 'x an''
standsforX anax.
35. ln order to determ ine w hether KELLY , or som e other narcotics-trafticking co-
conspirator,w asaccessing crim inal,Dark W eb m arketplaces from the HEA DY W A REZ intem et
connection,law enforcem ent began m onitoring the internet traftic to and from the IP address
36. A s discussed above,because ofthe anonym ity provided by the Tor network such
m onitoring w ould notrevealthe ultim ate IP address of devices com m unicated w ith through the
Tor netw ork. H ow ever, such m onitoring could reveal colm ections to com puters generally
For exam ple,m onitoring the IP connections of a com puter connecting to V alhalla
through Tor, w ill not reveal any specitic IP address associated w ith Valhalla. R ather such
Case 1:17-mj-02572-JG Document 3 Entered on FLSD Docket 04/27/2017 Page 14 of 18
m onitoring couldsrevealcolm ections to com puters generally associated w ith the Tornetw ork as
t6l'or N odes,''w hich are the com puters and servers designated by the adm inistrators of the Tor
38. A com puter attem pting to connectto the Tor netw ork m ust know how to contact
a Tor N ode in order to initiate a Tor network session,and Tor N ode IP addresses are publicly
the Tornetw ork could revealconnections to IP addressespublicly associated w ith com puters and
40. O n January 26,2017,the DEA obtained a pen/trap order for a1l internettraffic to
and from the Charter Com m unications IP address utilized by HEAD Y W A REZ.The pen/trap
order results obtained through M arch 27,2017 reveal internet connections from the H EA D Y
W A REZ IP address to known Tor N odes and,therefore,the Tor netw ork,w hich is consistent
w ith som eone logging on to the crim inal,D ark W eb m arketplaces,such asV alhalla, through the
5 This would not necessarily be the case if the person was adding an additional layer of
anonymity,such asa virtualprivate network (VPN) connection,between them and the Tor
network.
l2
Case 1:17-mj-02572-JG Document 3 Entered on FLSD Docket 04/27/2017 Page 15 of 18
receptacle belonging to the K ELLY Residence.Insidethe trash receptacle, agents seized m ultiple
O range,''3 D & G''and :G6 Y ellow Benz,''m atching CCU STOU S''drug listings and sim ilarto the
ones found previously in the trash receptacle at H EA D Y W A REZ . In addition, the trash
contained a shipping labelcreated with the sam e Endicia.com shipping accountthatwas utilized
by CCU STOU S''to m ail drugs to D EA agents. The destination nam e and address m atched the
Endicia.com records ofshipm enton August5,2016. A lso seized from the trash w ere a syringe
O n August 16, 2016, D EA agents conducted another trash pull at the K ELLY
Residence trash receptacle. D uring the trash pull,agents recovered a V anilla prepaid debitcard
bearing the sam e cal'd num berasthe one used by the ttU STO U S''Endicia.com shipping account
to purchase stam ps. In addition, agents recovered m ultiple pieces of paper w ith various
'tU STO U S'' drug listings and sim ilar to the ones found previously in the trash receptacle at
Other item sseized from the K ELLY Residence trash include m ultiple parcels from
China and Canada, Ziploc bags containing residue of cellulose, and an envelope containing
13
Case 1:17-mj-02572-JG Document 3 Entered on FLSD Docket 04/27/2017 Page 16 of 18
m anufacture pharmaceutical tablets to make tablets hard and stable,giving them EEbulk'' and
On August 23, 2016, DEA agents conducted another trash pull at the KELLY
depositslips.
45. O n Februaly 28,2017,D EA agents observed a moving truck departing the KELLY
m other.
47. A public utility check on the KELLY Residence revealed that a1l utilities were
changed from KELLY 'S nam e to the nam e ofthe landlord ofthe K ELLY Residence. The utilities at
from Singapore destined for Jeannette K ELLY at K ELLY Residence # 2. A border search of the
parcelrevealed 2 round die m olds and 4 m etalparts for a pillpress with a letter V ,num bers 48-12,
letterA and num bers 215. A search ofpharm aceuticalm arkingsrevealed thatV 48-12 isthe m arking
49. Records from KELLY 'S personal Ebay buyer account indicate that in the past,
KELLY purchased a TDP-5 tablet press, powder m ixers and multiple die m olds for Oxycodone,
N orco,and X anax.
J.Bitcoin A nalysis
A nalysis ofK ELLY 'Sfinancialrecords revealed thatK ELLY has a bitcoin account
w ith C oinbase- a bitcoin w allethostand exchanger. K ELLY 'SCoinbase accountis linked to his
K elly Enterplise.txlwc at W ood & Huston Bank. Coinbase records revealed that in the span of
three m onths from Septem ber 7th, 2015 to Decem ber 14th5 2015, K ELLY received bitcoins
and transferred to the aforementioned linked bank accounts. Analysisofthe bitcoin block chain
revealed thatthe majority ofthe extem aladdresses that sentbitcoins to KELLY'S Coinbase
accountbelonged to dark web m arkets,such as A lphabay M arketand AbraxasM arket.
Case 1:17-mj-02572-JG Document 3 Entered on FLSD Docket 04/27/2017 Page 18 of 18
C ONCLUSION
Joshua J.K ELLY ,did,at leastfrom Septem ber 2016 to D ecem ber 2016,
b. Joshua J.K ELLY ,did,at least from Septem ber 2016 to Decem ber 20l6
know ing thatthe transaction w as designed to concealand disguise the nature of the proceeds, in
H ON OR A E J ATHA N GO O DM AN
UN ITED S A T S M A G ISTRA TE JU D GE
16