Thursday, August 28, 2014
John Vastis Criminal Complaint
There were three counts to Lakemoor teacher John Vastis' Criminal Complaint by Homeland Security Special Agent Michael Schuster:
Offense Description 1: did knowingly use, persuade, induce, and entice a minor, namely, Minor A, to engage in sexually explicit conduct, namely, lascivious exhibition of Minor A’s genitals, for the purpose of producing a visual depiction of such conduct, which visual depiction was produced and transmitted using materials that had been mailed, shipped, and transported in interstate and foreign commerce and which visual depiction was transported or transmitted using any means or facility of interstate or foreign commerce
Offense Description 2: did knowingly use, persuade, induce, and entice a minor, namely, Minor A, to engage in sexually explicit conduct, namely, lascivious exhibition of Minor A’s genitals, for the purpose of producing a visual depiction of such conduct, which visual depiction was produced and transmitted using materials that had been mailed, shipped, and transported in interstate and foreign commerce and which visual depiction was transported or transmitted using any means or facility of
interstate or foreign commerce.
Offense Description 3: knowingly received, and attempted to receive, material, namely, a video recording entitled “Movie on 7-13-14 at 1.32 AM.mov,” which contained images of child pornography as defined in Title 18, United States Code, Section 2256(8)(A), such images having been mailed,
shipped, and transported in interstate and foreign commerce by any means, including by computer.
Schuster's affidavit follows:
AFFIDAVIT
I, MICHAEL A. SCHUSTER, being duly sworn, state as follows:
1. I am a Special Agent with Homeland Security Investigations. I have
been so employed since approximately 2006. My current responsibilities include the
investigation of fraud cases. In addition, I have received training in child
exploitation and child pornography investigations.
2. This affidavit is submitted in support of a criminal complaint alleging
that JOHN C. VASTIS, also known as “Pete,” has violated Title 18, United States
Code, Sections 2251(a) and 2252A(a)(2). The statements in this affidavit are based
in part on my personal knowledge, as well as information I have received from other
law enforcement personnel and from persons with knowledge regarding relevant
facts. Because this affidavit is being submitted for the limited purpose of
establishing probable cause in support of a criminal complaint charging VASTIS
with sexual exploitation of a child and receipt of child pornography, I have not
included each and every fact known to me concerning this investigation. I have set
forth only the facts that I believe are necessary to establish probable cause to
believe that the defendant committed the offense alleged in the complaint.
FACTS SUPPORTING PROBABLE CAUSE TO ARREST
A. Background and Information Concerning “Minor A”
3. On or about August 15, 2014, HSI Chicago Special Agents, Task Force
Officers, and officers from a local police department executed a State of Illinois
search warrant at the residence of an individual (“Minor A”) who was suspected of
possessing and distributing child pornography in violation of Illinois law. During
the execution of the state warrant, agents conducted a consensual interview of
Minor A, who admitted to distributing and receiving images of child pornography
through Skype. Based on Minor A’s admissions and a visual examination of Minor
A’s Illinois driver’s license, agents have determined that Minor A is currently 17
4. During the August 15 interview, Minor A admitted that, beginning in
September 2013 when Minor A was 16 years old, Minor A began communicating via
Skype and text messages with an adult subject he identified as “PETE.” As
discussed below, agents have since identified “PETE” as defendant VASTIS, who, as
explained below, lives at a residence (the “Lakemoor residence”) located in
Lakemoor, Illinois, a municipality within the Northern District of Illinois. During
the August 15 interview, Minor A provided agents with a telephone number for
“PETE”; the number was stored in Minor A’s cell phone under the heading “PETE
(Skype).” Also during the August 15 interview, Minor A claimed to have sent images
and videos of child pornography, including images of Minor A, to “PETE” via Skype.
B. Online Chats Between Minor A and “PETE”/VASTIS and VASTIS’s Receipt of Child Pornography via the Internet
5. During the week of August 18, 2014, agents analyzed data obtained
pursuant to the execution of the state warrant from Minor A’s computer and cell
phone. Agents recovered over 3,200 lines of chat messages between Minor A and
“PETE” from Minor A’s computer. Excerpts of these chat messages are reproduced
below. FN1 For example, on September 4, 2013, at or around 22:25, the following chat
occurred between Minor A and “PETE”/VASTIS:
Minor A: “hey"
PETE: "saw ur addy on [a website]" [According to Minor A, he first
encountered “PETE” during an online visit to a website. Based
on information obtained from other sources, agents believe that
the relevant website has since been deactivated]
PETE: "how's it going?"
Minor A: "good, u?"
PETE: "good....what's up?"
Minor A: "not much"
Minor A: "trade?"
PETE: "I'm very new to this...trade what?"
Minor A: "vids and pics"
PETE: "I don't have anything like that...lke I said, very new to this"
Minor A: "of course, I understand"
PETE: "what kinds of ids and pics do u mean?"
PETE: "vids"
PETE: "still there??"
Minor A: "yea"
Minor A: "ummm"
= = = = =
FN 1 Certain portions containing expletives and other salacious material have been omitted
from the excerpted chat conversations reproduced below. The location of such omitted
material is marked by brackets.
= = = = =
Minor A: "you're from gg right?"
PETE: "not a registered member...just look at what anyone can see if
Minor A: "oh ok"
Minor A: "well, if you ever get registered"
Minor A: "you'll find out what I mean very fast"
PETE: "I'm nervous to do that...is it a monitored site?
Minor A: "idk"
PETE: "are u really 16?"
Minor A: "yea, but most people think I'm a cop"
PETE: "I will admit it crossed my mind...ur into older guys?
PETE: "?"
Minor A: "yes"
Minor A: "very much so"
PETE: "I'm 50"
Minor A: "nice"
PETE: "do u ever meet up for real or just like to chat and play online?"
Minor A: "haven't done either actually, I'm setting something up soon
though"
PETE: "do you like chubby bear type guys?
Minor A: "to an extent"
PETE: "im 5'8", 245 broad chest n shoulders, nice legs n rear, big bellied
Minor A: "nicee"
Minor A: "I like"
Minor A: "can I see a pick?"
PETE: "can u go on cam here for a quick few seconds so I know ur not a
Minor A: "lol dude even if I was a cop I wouldn't bust you for anything,
PETE: "true"
PETE: "[email address omitted] contact me there and we can exchange
they go onto the site"
bear"
cop?"
you're not doing anything wrong"
pics"
6. On December 22, 2013, at or around 17:37, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "when do u turn 17?"
Minor A: "march"
PETE: "cool."
PETE: "maybe we could meet sometime. Maybe find a halfway point
Minor A: "absolutely"
Minor A: "can I see a picture of you?"
PETE: "how do you send it through here?"
Minor A: "push the + button next to the video call button in the top right"
Minor A: "then press send files"
PETE: "Screen shot 2013-12-22 at 5.40.57 PM.png" [Agents were unable to recover the file from
Minor A’s computer]
Minor A: "mmm hot"
PETE: "glad u like it"
PETE: "I'd love to meet you sometime but I will admit I'm nervous that
you might be a cop or something. If I could see u on cam I'd feel
less apprehensive about it"
you a pic of me doing it and that way I can prove im not a cop"
Minor A: "tell me what you want to see me doing in a photo and I'll send
PETE: "good idea"
PETE: "send me a pic of you giving me the finger. Lol"
Minor A: "lol if u say so"
Minor A: "photo on 12-22-13 at 5.46 PM.jpg" [The image depicts Minor A holding up his middle
finger]
PETE: "ok cool, I feel better about it now, thnx"
Minor A: "no problem"
PETE: "so do you think you'd really be up for meeting sometime?
Minor A: "hell yes"
7. On December 22, 2013, at or around 17:54, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "is [Minor A] your real name?"
Minor A: "no"
Minor A: "is your real name pete Thomas?"
PETE: "no"
Minor A: "lol"
PETE: "haha, u can't be too careful, right?"
PETE: "so e"
PETE: "here's the deal"
PETE: "I would like to maintain a consistent conversation with you but
for obvious reasons I'm nervous about it. Will u make it appoint
to check Skype more frequently so we can talk?"
Minor A: "I will especially over the break since theres no school"
PETE: "cool. Once I feel more comfortable, we can switch to texting....but id be careful of the things
I say in text"
PETE: "and id want you to be as well"
Minor A: "of course"
Minor A: "deleting messages"
Minor A: "only contacting as we need to"
PETE: "once ur 17, theres no problem. 17 is legal age of consent in
Illinois"
8. On January 3, 2014, at or around 22:27, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "send me a new pic. This time with no shirt on and sucking on your finger"
Minor A: "Photo on 1-3-14 at 10.27 PM.jpg" [The image depicts Minor A, nude from the waist up,
placing a finger in his mouth]
PETE: "damn, ur def real..at least I know that much...sure would love
to meet u for real"
9. On January 3, 2014, at or around 22:47, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "I got another pic request.....one finger on ur nipple, face and
chest in shot"
Minor A: "Photo on 1-3-14 at 10.47 PM #2.jpg" [The image depicts Minor A, nude from the waist up,
touching his nipple]
PETE: "damn, so hot"
Minor A: "haha thanks"
Minor A: "sorry if I look bad in some of these, I've been sick all day lol"
PETE: "u look awesome"
PETE: "hold on , gonna send u something"
PETE: "Screen shot 2014-01-03 at 10.49.59 PM.png" [Agents were unable to recover the file from
Minor A’s computer]
Minor A: "you're so hot"
PETE: "thnx bud, u 2"
PETE: "have I sent u a face pic yet?"
Minor A: "no"
PETE: "probably best to wait a while, the risk is so much worse for me
than for u"
10. On January 3, 2014, at or around 23:05, the following chat occurred
between Minor A and “PETE”/VASTIS:
Minor A: "do you have a video of yourself common [sic]?"
PETE: "no, do u?"
Minor A: "yes"
Minor A: "Movie on 12-12-13 at 12.46 AM.mov" [The video, which is
approximately one minute and six seconds in length, depicts
Minor A in the nude while masturbating. Minor A then appears
to ejaculate on his own face]
PETE: "oh really? Planning on sending it to me?"
PETE: "oh my [ ] god...that was smoking hot...ok, I completely trust
you now"
PETE: "I HAVE to meet you SOON!!!"
Minor A: "<ss type="kiss">:*</ss>"
Minor A: "I cant wait to see you"
PETE: "when did u film that?"
Minor A: "last month"
11. On January 3, 2014, at or around 23:32, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "thnx for the vid, super hot"
Minor A: "haha no problem"
Minor A: "I have others just like that"
PETE: "u do?"
Minor A: "oh yes"
Minor A: "like 5 or 6 more"
PETE: "send me at least 1 more right now...make me wait for the rest"
Minor A: "Movie on 11-30-13 at 3.45 AM.mov" [this video, approximately
PETE: "[ ] HOT!!! Nit u sexy boy"
12. On January 18, 2014, at or around 20:55, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "what r u wearing?"
Minor A: "everything haha, 2 shirts, pants, boxers, socks lol"
PETE: "why u covering up that hot body?"
Minor A: "haha I guess I'm just waiting for someone to help me take it all
PETE: "text me a pic fully dressed..to start with...or send it thru here”
47 seconds in length, depicts Minor A masturbating]
off <ss type="wink">:*</ss>"
Minor A: "photo on 1-18-14 at 9.00 PM.jpg" [The image depicts Minor A
PETE: "so cute"
PETE: "are u alone or are people?"
Minor A: "I can go into my room if I need to lol, I'm just watching tv"
Minor A: "but my parents are right upstairs"
PETE: "yeah, you'll need to...cuz each pic is gonna require one less
Minor A: "oh my god you really know how to get me goin <ss
PETE: "yeah, I like to take my time”
PETE: "I'm playful"
13. On January 18, 2014, at or around 21:13, the following chat occurred
between Minor A and “PETE”/VASTIS:
Minor A: "Photo on 1-18-14 at 9.12 PM.jpg" [The image depicts Minor A
sitting on a chair]
PETE: "nice...I like the way u take orders"
Minor A: "I am yours to control <ss type="smile">:*</ss>"
Minor A: "I like being dominated haha"
PETE: "so did u just leave the skype page ope while u were gone?"
Minor A: "yea, but it was in my room, nobody goes in my room"
PETE: "u do understand how extremely careful u need to be, right?"
14. On January 18, 2014, at or around 21:25, the following chat occurred
lying down on a bed, lifting up his shirt, exposing his stomach]
between Minor A and “PETE”/VASTIS:
PETE: "tell me the truth...are u really 15 and ur waiting for your
birthday for ur license?"
Minor A: "no dude, I'm 16 [ ]"
PETE: "ok,,,its fine...I would've kept talking if if u were....lol, no
worries"
piece of clothing at a time"
type="wink">:*</ss>"
15. On January 18, 2014, at or around 21:49, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "ready for another pic handsome?"
Minor A: "yes <ss type="smile">:*</ss>"
PETE: "same as the last one but lose the red shorts and leave the
underwear on"
Minor A: "those are my underwear lol"
PETE: "oh I thought that was a pair of shorts over another
pair...hmmmm..ok, lose em<ss type="wink">;)</ss>"
Minor A: "its about time <ss type="wink">;)</ss>"
Minor A: "Photo on 1-18-14 at 9.52 PM.jpg" [The image depicts Minor A,
PETE: "holy [ ]...you are amazing...all boy from the waist up, all man
from the waist down...so [ ] hot!"
PETE: "and I love the look in your eyes in that last one...like you're
laying down on a bed, nude, with his penis erect] saying, ‘come get me daddy’ "
16. On January 18, 2014, at or around 21:56, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "I need a pic of you lying on your tummy so I can see that sweet
[buttocks]"
Minor A: "Photo on 1-18-14 at 9.57 PM.jpg" [the image depicts Minor A,
laying down on his stomach, nude, with his buttocks exposed as
the focal point of the image]
PETE: "damn, it is ....PERFECT"
17. On January 18, 2014, at or around 22:03, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "when do u turn 17 again?"
Minor A: "march [xx]th"
PETE: "u think we should wait?"
Minor A: "nope”
PETE: "<ss type="smile">:)</ss>"
Minor A: "lets have a taste of the forbidden fruit"
Minor A: "while its still forbidden <ss type="wink">;)</ss>"
PETE: "I love that answer babe"
PETE: "and I agree"
18. On January 20, 2014, at or around 21:00, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "so...I gtg soon... ready for another pic?"
Minor A: "aww"
Minor A: "but sure"
PETE: "another sign...this one says ‘just for daddy’ and you gotta hold
it so it's blocking your [buttocks] ... ur on your knees facing
away from the camera but the pic shows your back including
your back head, back, and [buttocks]"
Minor A: "haha hold on, this'll take a while"
Minor A: "shirt on or off?"
PETE: "off of course"
Minor A: "haha <ss type="wink">;)</ss>"
Minor A: "underwear too?"
PETE: "NO!"
Minor A: "haha ok
Minor A: "gimme a sec"
PETE: "k"
Minor A: "Photo on 1-20-14 at 9.06 PM.jpg" [This image depicts Minor A,
standing with his back to the camera, wearing boxers, holding
up a sign with "just for daddy" written on it]
Minor A: "hope that was good enough haha"
PETE: "I like it...but the underwear was supposed to be off"
PETE: "do another one"
Minor A: "ok hold on"
Minor A: "Photo on 1-20-14 at 9.07 PM.jpg" [this image depicts Minor A,
standing with his back to the camera, nude, with his buttocks
showing, holding the sign, "just for daddy." The focal point of the
image is the sign and Minor A's buttocks.]
PETE: "mmm mmmm mmmmm...so nice baby!"
PETE: "you gotta remember me to shred that sign now"
19. On March 3, 2014, at or around 20:36, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "what u got on?"
Minor A: "naked, but I can dress up if you want me to"
PETE: "bi"
PETE: "typo"
PETE: "I was gonna say birthday suit sounds nice"
Minor A: "so no clothes on?"
PETE: "wrap a towel around ur waist...like u just got out of the
shower"
Minor A: "Photo on 3-3-14 at 8.38 PM.jpg" [The image depicts Minor A,
lying down on a bed, with nothing covering his upper body. A
towel is draped over his lower half]
PETE: "damn, I have missed that!!!!"
Minor A: "<ss type="kiss">:*</ss>"
PETE: "[ ] so tempting...before the 30th"
Minor A: "I know"
PETE: "yeah... I just wish there was some way you could assure me
that I'd never pay the price for it"
Minor A: "we could try my way and if anything seems weird, we can just
stop”
PETE: "u delete everything on here, right?"
Minor A: "yes sir"
PETE: "and never ever anything incriminating said thru texts"
Minor A: "yep"
20. On March 3, 2014, at or around 20:47, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "wrap that towel around your neck now, hanging on your chest"
Minor A: "[expletive term for penis omitted] in the pic?"
PETE: "yeah"
Minor A: "Photo on 3-3-14 at 8.48 pm.jpg" [this image depicts Minor A,
lying down on a bed, with a towel draped over his shoulders. In
the image, Minor A’s penis is exposed]
PETE: "nice boy! You take orders so nicely"
21. On March 12, 2014, at or around 19:51, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "are we still considering the 21st to the 24th?"
Minor A: "yep, sounds like the best deal
Minor A: "now, instead of me walking for like an hour to the hotel, why
don't you just pick me up a few blocks away from my house in a
remote location"
Minor A: "then we can spend some real time together"
PETE: "idk, makes me uncomfortable to be honest"
Minor A: "pleaseeeeee"
PETE: "honestly, idk. Have to give it some thought. Even tho we've
been talking and u have sent specific pics, I still have this fear
that ur an undercover cop or something like that
Minor A: "what can I do to convince you otherwise?"
PETE: "I don't know. If I knew ur real name maybe...or saw a school id
with ur name blacked out if u want
Minor A: "alright, but my hair's different than it is now, I probably don't
even look that similar, but I can try to find it"
Minor A: "gimme a moment"
PETE: "k"
Minor A: "meanwhile, think of some nice positions I can model for you <ss
PETE: “standing with only a button shirt on...unbuttoned almost all
Minor A: "photo on 3-12-14 at 8.58 PM.jpg" [This image depicts Minor A
holding his school ID, which shows Minor A’s name and school]
Minor A: "photo on 3-12-14 at 8.58 PM #3.jpg" [This image depicts Minor
A’s school ID].
PETE: "so your name is [Minor A’s name]"
Minor A: "yes sir"
PETE: "I got to tell you, I really appreciate you sending that, I def.
believe ur for real now"
Minor A: "haha yay <ss type="smile">:)</ss>"
PETE: "and I want you to know that I won't in any way abuse that
information, I promise
Minor A: "I trust you"
Minor A: "it sounds weird to say, but I definitely trust you"
PETE: "I need to know that no matter what, you would never ever tell
type="smile">:)</ss>" another living soul about this between us...no matter how u feel
about it down the live as u get older"
the way down but not completely"
Minor A: "Photo on 3-12-14 at 9.04 PM.jpg" [this image depicts Minor A,
wearing a black shirt, holding his exposed penis]
Minor A: "absolutely"
Minor A: "I won't tell anyone"
22. On March 12, 2014, at or around 20:31, the following chat occurred
between Minor A and “PETE”/VASTIS:
Minor A: "Movie on 5-20-13 at 6.45 PM.mov" [The video, which is
approximately one minute and five seconds long, depicts Minor
A inserting a pepper into his anus]
PETE: "wow, u just recorded that right now???"
Minor A: "nope just had that on my computer lol"
PETE: "haha, ok... u r so naughty. I love it that the world sees u as
this clan cut nice kid...If they only knew what I know"
PETE: "clean*"
23. On April 5, 2014, at or around 23:36, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "take of picture of yourself in them...tugging the waistband
down just a tiny bit"
Minor A: "my [colloquial term for penis] is hanging out bc they're so tight"
PETE: "haha, ok"
Minor A: "Photo on 4-6-14 at 12.36 AM. jpg" [The image depicts Minor A,
nude from the waist up, lying down on a bed. The head of Minor
A’s penis is visible coming out of Minor A’s underwear]
PETE: I can't believe ur really 17...I swear u look like ur 14 or so"
24. On April 5, 2014, at or around 23:59 and continuing into early morning
April 6, 2014, the following chat occurred between Minor A and “PETE”/VASTIS:
Minor A: "any more poses daddy?"
PETE: "surprise me this time"
Minor A: "Photo on 4-6-14 at 1.01AM.jpg" [The image depicts Minor A,
spreading his buttocks and exposing his anus, which is the focal
point of the image]
PETE: "wow!!!"
Minor A: "<ss type="smile">:)</ss>"
PETE: "I mean... WOW WOW WOW!!!"
25. On April 6, 2014, at or around 00:12, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "can't wait...send me another surprise"
Minor A: "Photo on 4-6-14 at 1.12 AM #3.jpg" [The image depicts Minor A,
nude, from the side and bending over. Minor A’s genitals and
buttocks are not visible]
Minor A: "Photo on 4-6-14 at 1.12 AM #2.jpg" [The image depicts Minor A,
nude, from the side and bending over. Minor A’s genitals and buttocks are not visible]
Minor A: "Photo on 4-6-14 at 1.12 AM.jpg" [The image depicts Minor A,
nude, from the side and bending over. Minor A’s erect penis is
visible]
PETE: "wow, so hot, are u a gymnast"
26. On April 20, at or around 21:53, the following chat occurred between
Minor A and “PETE”/VASTIS:
Minor A: "if I sent you a video that may or may not be legal, would you
mind? Its technically child pornography [ ]
Minor A: "15.wmv" [Agents were unable to recover the file from Minor A’s
computer]
Minor A: "you can delete it right after if you want"
PETE: "I feel really nervous to even open it. I hear all sorts of stories
about guys getting in huge trouble for that kind of thing"
Minor A: "just delete it right after"
Minor A: "its hot"
PETE: "describe it to me first, what's the approx age?"
Minor A: [Following agents’ analysis of the data and conversion into
spreadsheet format, the numbers provided by Minor A during
this chat were converted to a date format of “9/11/14”; agents
believe, however, that Minor A told “PETE” that the child
depicted in the video described by Minor A was 9-11 years old]
PETE: "where did u find something like that?"
Minor A: "I traded with someone for it"
PETE: "what do u give in return? Where do u guys find stuff like this?"
Minor A: "idk"
Minor A: "I just do favors for him"
Minor A: "like sending my nudes lol"
PETE: "damn I'm so tempted"
Minor A: "lol just do it"
Minor A: "and delete it right after it"
PETE: "hold on"
PETE: "says it may be an application downloaded form [sic] [internet.
Minor A: "yea, that's the app that runs the movie"
PETE: "ur certain I can't get in trouble for this if I delete it right away?
Minor A: "lol no"
PETE: "says it can't be opened"
Minor A: "oh ok, well then don't worry about it"
PETE: "why do u suppose I can't open it?"
Minor A: "idk, id have to look more into it"
Minor A: "I can show you a screenshot if you want"
PETE: "yeah"
Minor A: "Screen Shot 2014-4-20 at 11.00.47 PM.png" [Agents were
PETE: "[ ] hot"
Minor A: "told you"
PETE: "I think younger than u said tho"
Minor A: "really?"
Minor A: "any more pics you want from me? Anything at all"
PETE: "wish I could see the movie now"
Minor A: "Screen Shot 2014-4-20 at 11.03.39 PM.png" [Agents were
unable to recover the file from Minor A’s computer]
Minor A: "man [****]ing 9 year old boy"
Minor A: "cute"
Minor A: [ ]
PETE: "same film or different one?"
Minor A: "different"
PETE: "try sending that film"
Minor A: "video4.wmv" [Agents were unable to recover the file from Minor
A’s computer]
PETE: "nope, same message"
Minor A: "sorry, maybe ill show you one day"
Asking if I'm sure about opening it.
"Can't be traced back"
unable to recover the file from Minor A’s computer]
Minor A: "I have a lot of videos"
PETE: "take a screen shot of that last one that shows the boy"
Minor A: "it doesn't show him"
Minor A: "they like to protect the kids"
PETE: "I see"
PETE: "ok, last oil from u...sitting on your knees, back to the camera,
PETE: "pic"
Minor A: "but I want to do more than that"
Minor A: "something sexy"
Minor A: "anything"
Minor A: "something extreme"
PETE: "surprise me then"
Minor A: "Photo on 4-20-14 at 11.10 PM.jpg" [The image depicts Minor A
underwear off, turn ur face and smile at the camera"
bending over with his anus exposed. A foreign object has been
inserted into Minor A's rectum]
PETE: "haha, feel good son?"
Minor A: "better than good, dad"
PETE: "I think u need my [expletive term for penis] in there instead"
27. On April 20, 2014, at or around 22:27, the following chat occurred
between Minor A and “PETE”/VASTIS:
Minor A: "one more pic before I go?
PETE: "yeah, surprise me"
PETE: "and assure me once again that u completely delete these
conversations"
Minor A: "Photo on 4-20-14 at 11.28 PM.jpg" [The image depicts Minor A,
bending over and facing away from the camera. Minor A is
spreading his buttocks and exposing his anus]
Minor A: "yea of cousse"
Minor A: "course"
PETE: "great pic"
PETE: "and yeah, bring the laptop, we gonna have an interesting
time...nit, talk again soon"
28. On April 23, 2014, at or around 21:26, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "so u have lots of that kind of stuff? Aren't u worried you'll be
Minor A: "I'm careful"
Minor A: "but yes I have a lot of it lol"
PETE: "no danger in me receiving screenshots like us sent, right?"
Minor A: "not if you delete it"
PETE: "yeah I did"
Minor A: "ok, you're fin e"
PETE: "u should surprise me with another one"
Minor A: "Screen Shot 2014-4-23 at 10.29.45 PM.png" [Agents were
PETE: "cool... how old do u suppose that one is?"
Minor A: "not sure, could be 9, could be 11"
Minor A: "can't really tell"
PETE: "hard to believe that stuff really happens"
29. On April 23, 2014, at or around 21:52, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "back to cam, [buttocks] showing, head turned toward the cam,
blow daddy a kiss"
Minor A: "Photo on 4-23-14 at 10.52 PM.jpg" [The image depicts Minor A,
bending over and away from the camera, looking back towards
the camera. He is making a motion like blowing a kiss. The top
half of his buttocks are visible]
caught with it?
unable to recover the file from Minor A’s computer]
PETE: "[ ] YES!!!! NICE!!!
30. On May 15, 2014, at or around 17:32, the following chat occurred
between Minor A and “PETE”/VASTIS:
Minor A: "what do you do?"
PETE: "I thought u knew"
Minor A: "nope"
PETE: "am I talking to the right person? Lol"
Minor A: "lol yes"
Minor A: "idk maybe you told me, I probably forgot"
PETE: "teach"
Minor A: "really? What do you teach?"
PETE: "wait a sec... send me a quick pic, I want to make sure no one is
on your computer"
Minor A: "omg fine"
Minor A: "Photo on 4-20-14 at 11.28 PM.jpg" [The image depicts Minor A
bending over and facing away from the camera. Minor A is
spreading his buttocks, exposing his anus]
Minor A: "you've never told me what you teach"
Minor A: "you said it was private"
PETE: "I teach 5th and 6th grade"
Minor A: "6th grade what?"
Minor A: "what class"
PETE: "public speaking"
31. On May 15, 2014, at or around 18:26, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "got any new interesting pics to send my way?"
Minor A: "of me?"
PETE: "well yeah, but I mean from your hobby"
Minor A: "oh ok"
Minor A: "gimme a sec"
Minor A: "_FO9ZC0X2.jpg" [Agents were unable to recover the file from
Minor A’s computer]
PETE: "nice"
32. On May 15, 2014, at or around 18:44, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "now, flex one arm while ur other hand is on ur [penis]"
Minor A: "Photo on 5-15-14 at 7.44 PM.jpg" [The image depicts Minor A,
bending over and away from the camera, exposing his buttocks
and testicles]
PETE: "awesome"
PETE: "[buttocks] shot, don't spread cheeks tho"
Minor A: "Photo on 5-15-14 at 7.47 PM.jpg" [The image depicts Minor A,
curling his left arm, while his right hand holds his erect penis]
PETE: "nice"
33. On June 19, 2014, at or around 13:19, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "did your reading get u all horned up?"
Minor A: "hell yea it did"
PETE: "yeah me too... I soooo need a boy right now"
Minor A: "I just need someone to dominate me rn"
PETE: "year, that's exactly what I'm in the mood to do
34. On July 12, 2014, at or around 22:19, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "next pic... standing... underwear off... let me see my boy's
sweet [buttocks]"
Minor A: "Photo on 7-12-14 at 11.20 PM.jpg" [The image depicts Minor A,
standing and facing away from the camera, nude from the legs
up. His buttocks are exposed]
PETE: "nice, again now but with your arms and hands down to your
side"
Minor A: "Photo on 7/12/14 at 11.22 PM.jpg" [The image also depicts
Minor A, standing and facing away from the camera, nude from
the legs up. Minor A’s buttocks are exposed]
PETE: "very very nice"
PETE: "are u feeling good about this boy?
Minor A: "hell yes daddy"
PETE: "show me, turn around and let me see for myself"
Minor A: "Photo on 7-12-14 at 11.25 PM.jpg" [The image depicts Minor A,
standing at a 90 degree angle to the camera, nude from the legs
up, holding his erect penis]
PETE: "HOT!!!! Damn"
PETE: "ur getting hotter all the time son"
35. On July 13, 2014, at or around 00:07, the following chat occurred
between Minor A and “PETE”/VASTIS:
Minor A: "Movie on 7-13-14 at 1.32 AM.mov" [The video, which is
[graphic discussion of Minor A masturbating omitted]
approximately one minute and fifty-two seconds in length,
depicts Minor A masturbating]
PETE: "don't leave, wait till I view it"
PETE: "HOLY [ ]!!!!"
PETE: "are u here?"
Minor A: "I told you"
PETE: "SO [ ] HOT. Yeah, I [ ] trust u kid... u deliver!"
36. On July 13, 2014, at or around 21:05, the following chat occurred
between Minor A and “PETE”/VASTIS:
Minor A: "I got some pics you might like <ss type="wink">;)</ss>"
Minor A: "I traded people for some kiddie porn lol"
PETE: "Send thru here like u did a while back"
Minor A: "042424k7ifz6wqq2ap62re.jpg" [Agents were unable to recover
PETE: "jesus, what the hell? How old do u think he is?"
[ ]
37. On July 13, 2014, at or around 21:12, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "had an interesting cam session today"
Minor A: "really?"
Minor A: "tell me about it"
PETE: "13"
Minor A: "mmm"
Minor A: "what did you make him do?"
PETE: "didn't have to...he volunteered it all"
PETE: "just basically watched him [masturbate]"
Minor A: "what did he do?"
PETE: "did you take screenshots?"
PETE: "no"
PETE: "never even occurred to me, sorry"
Minor A: "aww <ss type="sad">:(</ss>"
PETE: "had a similar one a few weeks ago, used mic with that
one...said 15 but think he was younger...hottest moo I ever
played on cam with"
the file from Minor A’s computer]
C. Identification of “PETE” as Defendant VASTIS
38. Based on my training and experience, and the experience of others
with whom I have consulted, I understand that an internet protocol address is
unique to a particular computer or residence during an online session. The IP
address provides a unique locator, making it possible for data to be transferred
between computers. Each time an individual accesses the Internet, the computer
from which that individual initiates access is assigned an IP address. A central
authority provides each Internet Service Provider with a limited block of IP
addresses for use by that ISP’s customers or subscribers. Many ISPs employ
dynamic IP addressing; in other words, they allocate an unused IP address each
time a customer or subscriber accesses the Internet. The ISP logs the date, time,
and duration of the Internet session for each IP address and can identify from these
records the user of that IP address for a particular session.
39. Typically, home users of the internet are assigned an IP address from
a pool of IP addresses for the duration of a session. In the case of dial-up modems, a
user’s IP address is released when the user’s computer disconnects from the
telephone service, and that IP address is available for others to use. In the case of
cable modems or DSL service, an IP address is commonly held by a user for a longer
period of time, from days to months, until the provider chooses to change it. Some
services use static addressing, where an IP address is permanently assigned to a
specific computer and is difficult to change
40. On or about August 25, 2014, pursuant to an administrative subpoena,
an ISP disclosed IP addresses pertaining to the Skype-based chat logs summarized
above that occurred on or about April 6, 2014; May 18, 2014; June 17, 2014; July 13,
2014; July 14, 2014, July 17, 2014, and August 14, 2014. According to the
information provided by the ISP, all of the IP addresses associated with the
relevant chat logs were assigned to the ISP account of Subject A, an individual who,
as described below, resides at the Lakemoor residence along with VASTIS.
41. Based upon agents’ searches of public databases, Subject A appears to
be the spouse of VASTIS and resides at the Lakemoor residence. In addition, based
upon those same searches of public databases, agents have determined that
VASTIS’s date of birth is consistent with the age provided by “PETE” during the
chats excerpted above. In addition, a review by agents of VASTIS’s Illinois Driver’s
License information and photograph revealed that VASTIS appears to be a white
male who has brown hair, brown eyes, is 5' 9" tall, weighs approximately 235 lbs.,
and resides at the Lakemoor residence. These biographical measurements are
consistent with the physical self-description provided by “PETE” during one of the
chats listed above that occurred on September 4, 2013.
42. A search of open sources on the internet also revealed that VASTIS is a
teacher at Meridian Middle School in Buffalo Grove, Illinois, which is consistent
with “PETE”’s reference in paragraph 30 to teaching fifth and sixth graders.
43. After reviewing the photograph associated with VASTIS’s Illinois
Driver’s License, an HSI Computer Forensic agent searched the images on Minor
A’s telephone pursuant to the state warrant. During that search, the agent located
at least two different photographs of VASTIS, both of which depict VASTIS in the
nude, apparently lying down, with his penis exposed. Those images were received
by Minor A’s telephone on or about July 30, 2014. Both the HSI Computer Forensic
Agent and another agent have compared these images with VASTIS’s Illinois
Driver’s License photograph and have concluded that the images depict VASTIS.
44. In addition, during surveillance on August 26 and 27, 2014, HSI
agents and Task Force officers compared VASTIS’s Illinois Driver’s License
photograph to the appearance of a person seen entering and exiting the Lakemoor
residence and have concluded that the person entering and exiting was VASTIS.
45. Also on August 25, 2014, at approximately 17:50 hours, an HSI
Chicago Task Force officer performed surveillance of the Lakemoor residence.
Located in the driveway of the residence was a maroon Honda Civic bearing an
Illinois license plate registered in the name of VASTIS at the Lakemoor residence.
46. Based on the foregoing information, in combination with the
information "PETE" provided about himself in the chat logs summarized above, I
respectfully submit that VASTIS and "PETE" are the same individual who resides
at the Lakemoor residence.
D. Information Concerning Minor A’s Computer
47. Agents have examined the computer that Minor A used to
communicate with VASTIS via Skype. Based on that examination, agents
determined that the computer is an Apple “Macintosh Pro” Model A1278 that,
according to a label affixed to the computer, was made in China.
CONCLUSION
48. Based on the foregoing, I respectfully submit that probable cause
exists to believe that VASTIS has violated Title 18, United States Code, Sections
2251(a) and 2252A(a)(2), in that VASTIS (a) used, persuaded, induced, and enticed
a minor under the age of eighteen with the intent that the minor engage in sexually
explicit conduct for the purpose of producing visual depictions of such conduct,
which visual depictions were produced and transmitted using materials that had
been mailed, shipped, and transported in interstate and foreign commerce and
which visual depictions were transported or transmitted using any means or facility
of interstate or foreign commerce; and (b) knowingly received, and attempted to
receive, material that contained images of child pornography, such images having
been mailed, shipped, and transported in interstate and foreign commerce by any
means, including by computer.
FURTHER AFFIANT SAYETH NOT.
MICHAEL A. SCHUSTER
Special Agent
Homeland Security Investigations
SUBSCRIBED AND SWORN to before me on August 27, 2014.
Offense Description 1: did knowingly use, persuade, induce, and entice a minor, namely, Minor A, to engage in sexually explicit conduct, namely, lascivious exhibition of Minor A’s genitals, for the purpose of producing a visual depiction of such conduct, which visual depiction was produced and transmitted using materials that had been mailed, shipped, and transported in interstate and foreign commerce and which visual depiction was transported or transmitted using any means or facility of interstate or foreign commerce
Offense Description 2: did knowingly use, persuade, induce, and entice a minor, namely, Minor A, to engage in sexually explicit conduct, namely, lascivious exhibition of Minor A’s genitals, for the purpose of producing a visual depiction of such conduct, which visual depiction was produced and transmitted using materials that had been mailed, shipped, and transported in interstate and foreign commerce and which visual depiction was transported or transmitted using any means or facility of
interstate or foreign commerce.
Offense Description 3: knowingly received, and attempted to receive, material, namely, a video recording entitled “Movie on 7-13-14 at 1.32 AM.mov,” which contained images of child pornography as defined in Title 18, United States Code, Section 2256(8)(A), such images having been mailed,
shipped, and transported in interstate and foreign commerce by any means, including by computer.
Schuster's affidavit follows:
AFFIDAVIT
I, MICHAEL A. SCHUSTER, being duly sworn, state as follows:
1. I am a Special Agent with Homeland Security Investigations. I have
been so employed since approximately 2006. My current responsibilities include the
investigation of fraud cases. In addition, I have received training in child
exploitation and child pornography investigations.
2. This affidavit is submitted in support of a criminal complaint alleging
that JOHN C. VASTIS, also known as “Pete,” has violated Title 18, United States
Code, Sections 2251(a) and 2252A(a)(2). The statements in this affidavit are based
in part on my personal knowledge, as well as information I have received from other
law enforcement personnel and from persons with knowledge regarding relevant
facts. Because this affidavit is being submitted for the limited purpose of
establishing probable cause in support of a criminal complaint charging VASTIS
with sexual exploitation of a child and receipt of child pornography, I have not
included each and every fact known to me concerning this investigation. I have set
forth only the facts that I believe are necessary to establish probable cause to
believe that the defendant committed the offense alleged in the complaint.
FACTS SUPPORTING PROBABLE CAUSE TO ARREST
A. Background and Information Concerning “Minor A”
3. On or about August 15, 2014, HSI Chicago Special Agents, Task Force
Officers, and officers from a local police department executed a State of Illinois
search warrant at the residence of an individual (“Minor A”) who was suspected of
possessing and distributing child pornography in violation of Illinois law. During
the execution of the state warrant, agents conducted a consensual interview of
Minor A, who admitted to distributing and receiving images of child pornography
through Skype. Based on Minor A’s admissions and a visual examination of Minor
A’s Illinois driver’s license, agents have determined that Minor A is currently 17
4. During the August 15 interview, Minor A admitted that, beginning in
September 2013 when Minor A was 16 years old, Minor A began communicating via
Skype and text messages with an adult subject he identified as “PETE.” As
discussed below, agents have since identified “PETE” as defendant VASTIS, who, as
explained below, lives at a residence (the “Lakemoor residence”) located in
Lakemoor, Illinois, a municipality within the Northern District of Illinois. During
the August 15 interview, Minor A provided agents with a telephone number for
“PETE”; the number was stored in Minor A’s cell phone under the heading “PETE
(Skype).” Also during the August 15 interview, Minor A claimed to have sent images
and videos of child pornography, including images of Minor A, to “PETE” via Skype.
B. Online Chats Between Minor A and “PETE”/VASTIS and VASTIS’s Receipt of Child Pornography via the Internet
5. During the week of August 18, 2014, agents analyzed data obtained
pursuant to the execution of the state warrant from Minor A’s computer and cell
phone. Agents recovered over 3,200 lines of chat messages between Minor A and
“PETE” from Minor A’s computer. Excerpts of these chat messages are reproduced
below. FN1 For example, on September 4, 2013, at or around 22:25, the following chat
occurred between Minor A and “PETE”/VASTIS:
Minor A: “hey"
PETE: "saw ur addy on [a website]" [According to Minor A, he first
encountered “PETE” during an online visit to a website. Based
on information obtained from other sources, agents believe that
the relevant website has since been deactivated]
PETE: "how's it going?"
Minor A: "good, u?"
PETE: "good....what's up?"
Minor A: "not much"
Minor A: "trade?"
PETE: "I'm very new to this...trade what?"
Minor A: "vids and pics"
PETE: "I don't have anything like that...lke I said, very new to this"
Minor A: "of course, I understand"
PETE: "what kinds of ids and pics do u mean?"
PETE: "vids"
PETE: "still there??"
Minor A: "yea"
Minor A: "ummm"
= = = = =
FN 1 Certain portions containing expletives and other salacious material have been omitted
from the excerpted chat conversations reproduced below. The location of such omitted
material is marked by brackets.
= = = = =
Minor A: "you're from gg right?"
PETE: "not a registered member...just look at what anyone can see if
Minor A: "oh ok"
Minor A: "well, if you ever get registered"
Minor A: "you'll find out what I mean very fast"
PETE: "I'm nervous to do that...is it a monitored site?
Minor A: "idk"
PETE: "are u really 16?"
Minor A: "yea, but most people think I'm a cop"
PETE: "I will admit it crossed my mind...ur into older guys?
PETE: "?"
Minor A: "yes"
Minor A: "very much so"
PETE: "I'm 50"
Minor A: "nice"
PETE: "do u ever meet up for real or just like to chat and play online?"
Minor A: "haven't done either actually, I'm setting something up soon
though"
PETE: "do you like chubby bear type guys?
Minor A: "to an extent"
PETE: "im 5'8", 245 broad chest n shoulders, nice legs n rear, big bellied
Minor A: "nicee"
Minor A: "I like"
Minor A: "can I see a pick?"
PETE: "can u go on cam here for a quick few seconds so I know ur not a
Minor A: "lol dude even if I was a cop I wouldn't bust you for anything,
PETE: "true"
PETE: "[email address omitted] contact me there and we can exchange
they go onto the site"
bear"
cop?"
you're not doing anything wrong"
pics"
6. On December 22, 2013, at or around 17:37, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "when do u turn 17?"
Minor A: "march"
PETE: "cool."
PETE: "maybe we could meet sometime. Maybe find a halfway point
Minor A: "absolutely"
Minor A: "can I see a picture of you?"
PETE: "how do you send it through here?"
Minor A: "push the + button next to the video call button in the top right"
Minor A: "then press send files"
PETE: "Screen shot 2013-12-22 at 5.40.57 PM.png" [Agents were unable to recover the file from
Minor A’s computer]
Minor A: "mmm hot"
PETE: "glad u like it"
PETE: "I'd love to meet you sometime but I will admit I'm nervous that
you might be a cop or something. If I could see u on cam I'd feel
less apprehensive about it"
you a pic of me doing it and that way I can prove im not a cop"
Minor A: "tell me what you want to see me doing in a photo and I'll send
PETE: "good idea"
PETE: "send me a pic of you giving me the finger. Lol"
Minor A: "lol if u say so"
Minor A: "photo on 12-22-13 at 5.46 PM.jpg" [The image depicts Minor A holding up his middle
finger]
PETE: "ok cool, I feel better about it now, thnx"
Minor A: "no problem"
PETE: "so do you think you'd really be up for meeting sometime?
Minor A: "hell yes"
7. On December 22, 2013, at or around 17:54, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "is [Minor A] your real name?"
Minor A: "no"
Minor A: "is your real name pete Thomas?"
PETE: "no"
Minor A: "lol"
PETE: "haha, u can't be too careful, right?"
PETE: "so e"
PETE: "here's the deal"
PETE: "I would like to maintain a consistent conversation with you but
for obvious reasons I'm nervous about it. Will u make it appoint
to check Skype more frequently so we can talk?"
Minor A: "I will especially over the break since theres no school"
PETE: "cool. Once I feel more comfortable, we can switch to texting....but id be careful of the things
I say in text"
PETE: "and id want you to be as well"
Minor A: "of course"
Minor A: "deleting messages"
Minor A: "only contacting as we need to"
PETE: "once ur 17, theres no problem. 17 is legal age of consent in
Illinois"
8. On January 3, 2014, at or around 22:27, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "send me a new pic. This time with no shirt on and sucking on your finger"
Minor A: "Photo on 1-3-14 at 10.27 PM.jpg" [The image depicts Minor A, nude from the waist up,
placing a finger in his mouth]
PETE: "damn, ur def real..at least I know that much...sure would love
to meet u for real"
9. On January 3, 2014, at or around 22:47, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "I got another pic request.....one finger on ur nipple, face and
chest in shot"
Minor A: "Photo on 1-3-14 at 10.47 PM #2.jpg" [The image depicts Minor A, nude from the waist up,
touching his nipple]
PETE: "damn, so hot"
Minor A: "haha thanks"
Minor A: "sorry if I look bad in some of these, I've been sick all day lol"
PETE: "u look awesome"
PETE: "hold on , gonna send u something"
PETE: "Screen shot 2014-01-03 at 10.49.59 PM.png" [Agents were unable to recover the file from
Minor A’s computer]
Minor A: "you're so hot"
PETE: "thnx bud, u 2"
PETE: "have I sent u a face pic yet?"
Minor A: "no"
PETE: "probably best to wait a while, the risk is so much worse for me
than for u"
10. On January 3, 2014, at or around 23:05, the following chat occurred
between Minor A and “PETE”/VASTIS:
Minor A: "do you have a video of yourself common [sic]?"
PETE: "no, do u?"
Minor A: "yes"
Minor A: "Movie on 12-12-13 at 12.46 AM.mov" [The video, which is
approximately one minute and six seconds in length, depicts
Minor A in the nude while masturbating. Minor A then appears
to ejaculate on his own face]
PETE: "oh really? Planning on sending it to me?"
PETE: "oh my [ ] god...that was smoking hot...ok, I completely trust
you now"
PETE: "I HAVE to meet you SOON!!!"
Minor A: "<ss type="kiss">:*</ss>"
Minor A: "I cant wait to see you"
PETE: "when did u film that?"
Minor A: "last month"
11. On January 3, 2014, at or around 23:32, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "thnx for the vid, super hot"
Minor A: "haha no problem"
Minor A: "I have others just like that"
PETE: "u do?"
Minor A: "oh yes"
Minor A: "like 5 or 6 more"
PETE: "send me at least 1 more right now...make me wait for the rest"
Minor A: "Movie on 11-30-13 at 3.45 AM.mov" [this video, approximately
PETE: "[ ] HOT!!! Nit u sexy boy"
12. On January 18, 2014, at or around 20:55, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "what r u wearing?"
Minor A: "everything haha, 2 shirts, pants, boxers, socks lol"
PETE: "why u covering up that hot body?"
Minor A: "haha I guess I'm just waiting for someone to help me take it all
PETE: "text me a pic fully dressed..to start with...or send it thru here”
47 seconds in length, depicts Minor A masturbating]
off <ss type="wink">:*</ss>"
Minor A: "photo on 1-18-14 at 9.00 PM.jpg" [The image depicts Minor A
PETE: "so cute"
PETE: "are u alone or are people?"
Minor A: "I can go into my room if I need to lol, I'm just watching tv"
Minor A: "but my parents are right upstairs"
PETE: "yeah, you'll need to...cuz each pic is gonna require one less
Minor A: "oh my god you really know how to get me goin <ss
PETE: "yeah, I like to take my time”
PETE: "I'm playful"
13. On January 18, 2014, at or around 21:13, the following chat occurred
between Minor A and “PETE”/VASTIS:
Minor A: "Photo on 1-18-14 at 9.12 PM.jpg" [The image depicts Minor A
sitting on a chair]
PETE: "nice...I like the way u take orders"
Minor A: "I am yours to control <ss type="smile">:*</ss>"
Minor A: "I like being dominated haha"
PETE: "so did u just leave the skype page ope while u were gone?"
Minor A: "yea, but it was in my room, nobody goes in my room"
PETE: "u do understand how extremely careful u need to be, right?"
14. On January 18, 2014, at or around 21:25, the following chat occurred
lying down on a bed, lifting up his shirt, exposing his stomach]
between Minor A and “PETE”/VASTIS:
PETE: "tell me the truth...are u really 15 and ur waiting for your
birthday for ur license?"
Minor A: "no dude, I'm 16 [ ]"
PETE: "ok,,,its fine...I would've kept talking if if u were....lol, no
worries"
piece of clothing at a time"
type="wink">:*</ss>"
15. On January 18, 2014, at or around 21:49, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "ready for another pic handsome?"
Minor A: "yes <ss type="smile">:*</ss>"
PETE: "same as the last one but lose the red shorts and leave the
underwear on"
Minor A: "those are my underwear lol"
PETE: "oh I thought that was a pair of shorts over another
pair...hmmmm..ok, lose em<ss type="wink">;)</ss>"
Minor A: "its about time <ss type="wink">;)</ss>"
Minor A: "Photo on 1-18-14 at 9.52 PM.jpg" [The image depicts Minor A,
PETE: "holy [ ]...you are amazing...all boy from the waist up, all man
from the waist down...so [ ] hot!"
PETE: "and I love the look in your eyes in that last one...like you're
laying down on a bed, nude, with his penis erect] saying, ‘come get me daddy’ "
16. On January 18, 2014, at or around 21:56, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "I need a pic of you lying on your tummy so I can see that sweet
[buttocks]"
Minor A: "Photo on 1-18-14 at 9.57 PM.jpg" [the image depicts Minor A,
laying down on his stomach, nude, with his buttocks exposed as
the focal point of the image]
PETE: "damn, it is ....PERFECT"
17. On January 18, 2014, at or around 22:03, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "when do u turn 17 again?"
Minor A: "march [xx]th"
PETE: "u think we should wait?"
Minor A: "nope”
PETE: "<ss type="smile">:)</ss>"
Minor A: "lets have a taste of the forbidden fruit"
Minor A: "while its still forbidden <ss type="wink">;)</ss>"
PETE: "I love that answer babe"
PETE: "and I agree"
18. On January 20, 2014, at or around 21:00, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "so...I gtg soon... ready for another pic?"
Minor A: "aww"
Minor A: "but sure"
PETE: "another sign...this one says ‘just for daddy’ and you gotta hold
it so it's blocking your [buttocks] ... ur on your knees facing
away from the camera but the pic shows your back including
your back head, back, and [buttocks]"
Minor A: "haha hold on, this'll take a while"
Minor A: "shirt on or off?"
PETE: "off of course"
Minor A: "haha <ss type="wink">;)</ss>"
Minor A: "underwear too?"
PETE: "NO!"
Minor A: "haha ok
Minor A: "gimme a sec"
PETE: "k"
Minor A: "Photo on 1-20-14 at 9.06 PM.jpg" [This image depicts Minor A,
standing with his back to the camera, wearing boxers, holding
up a sign with "just for daddy" written on it]
Minor A: "hope that was good enough haha"
PETE: "I like it...but the underwear was supposed to be off"
PETE: "do another one"
Minor A: "ok hold on"
Minor A: "Photo on 1-20-14 at 9.07 PM.jpg" [this image depicts Minor A,
standing with his back to the camera, nude, with his buttocks
showing, holding the sign, "just for daddy." The focal point of the
image is the sign and Minor A's buttocks.]
PETE: "mmm mmmm mmmmm...so nice baby!"
PETE: "you gotta remember me to shred that sign now"
19. On March 3, 2014, at or around 20:36, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "what u got on?"
Minor A: "naked, but I can dress up if you want me to"
PETE: "bi"
PETE: "typo"
PETE: "I was gonna say birthday suit sounds nice"
Minor A: "so no clothes on?"
PETE: "wrap a towel around ur waist...like u just got out of the
shower"
Minor A: "Photo on 3-3-14 at 8.38 PM.jpg" [The image depicts Minor A,
lying down on a bed, with nothing covering his upper body. A
towel is draped over his lower half]
PETE: "damn, I have missed that!!!!"
Minor A: "<ss type="kiss">:*</ss>"
PETE: "[ ] so tempting...before the 30th"
Minor A: "I know"
PETE: "yeah... I just wish there was some way you could assure me
that I'd never pay the price for it"
Minor A: "we could try my way and if anything seems weird, we can just
stop”
PETE: "u delete everything on here, right?"
Minor A: "yes sir"
PETE: "and never ever anything incriminating said thru texts"
Minor A: "yep"
20. On March 3, 2014, at or around 20:47, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "wrap that towel around your neck now, hanging on your chest"
Minor A: "[expletive term for penis omitted] in the pic?"
PETE: "yeah"
Minor A: "Photo on 3-3-14 at 8.48 pm.jpg" [this image depicts Minor A,
lying down on a bed, with a towel draped over his shoulders. In
the image, Minor A’s penis is exposed]
PETE: "nice boy! You take orders so nicely"
21. On March 12, 2014, at or around 19:51, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "are we still considering the 21st to the 24th?"
Minor A: "yep, sounds like the best deal
Minor A: "now, instead of me walking for like an hour to the hotel, why
don't you just pick me up a few blocks away from my house in a
remote location"
Minor A: "then we can spend some real time together"
PETE: "idk, makes me uncomfortable to be honest"
Minor A: "pleaseeeeee"
PETE: "honestly, idk. Have to give it some thought. Even tho we've
been talking and u have sent specific pics, I still have this fear
that ur an undercover cop or something like that
Minor A: "what can I do to convince you otherwise?"
PETE: "I don't know. If I knew ur real name maybe...or saw a school id
with ur name blacked out if u want
Minor A: "alright, but my hair's different than it is now, I probably don't
even look that similar, but I can try to find it"
Minor A: "gimme a moment"
PETE: "k"
Minor A: "meanwhile, think of some nice positions I can model for you <ss
PETE: “standing with only a button shirt on...unbuttoned almost all
Minor A: "photo on 3-12-14 at 8.58 PM.jpg" [This image depicts Minor A
holding his school ID, which shows Minor A’s name and school]
A’s school ID].
PETE: "so your name is [Minor A’s name]"
Minor A: "yes sir"
PETE: "I got to tell you, I really appreciate you sending that, I def.
believe ur for real now"
Minor A: "haha yay <ss type="smile">:)</ss>"
PETE: "and I want you to know that I won't in any way abuse that
information, I promise
Minor A: "I trust you"
Minor A: "it sounds weird to say, but I definitely trust you"
PETE: "I need to know that no matter what, you would never ever tell
type="smile">:)</ss>" another living soul about this between us...no matter how u feel
about it down the live as u get older"
the way down but not completely"
Minor A: "Photo on 3-12-14 at 9.04 PM.jpg" [this image depicts Minor A,
wearing a black shirt, holding his exposed penis]
Minor A: "absolutely"
Minor A: "I won't tell anyone"
22. On March 12, 2014, at or around 20:31, the following chat occurred
between Minor A and “PETE”/VASTIS:
Minor A: "Movie on 5-20-13 at 6.45 PM.mov" [The video, which is
approximately one minute and five seconds long, depicts Minor
A inserting a pepper into his anus]
PETE: "wow, u just recorded that right now???"
Minor A: "nope just had that on my computer lol"
PETE: "haha, ok... u r so naughty. I love it that the world sees u as
this clan cut nice kid...If they only knew what I know"
PETE: "clean*"
23. On April 5, 2014, at or around 23:36, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "take of picture of yourself in them...tugging the waistband
down just a tiny bit"
Minor A: "my [colloquial term for penis] is hanging out bc they're so tight"
PETE: "haha, ok"
Minor A: "Photo on 4-6-14 at 12.36 AM. jpg" [The image depicts Minor A,
nude from the waist up, lying down on a bed. The head of Minor
A’s penis is visible coming out of Minor A’s underwear]
PETE: I can't believe ur really 17...I swear u look like ur 14 or so"
24. On April 5, 2014, at or around 23:59 and continuing into early morning
April 6, 2014, the following chat occurred between Minor A and “PETE”/VASTIS:
Minor A: "any more poses daddy?"
PETE: "surprise me this time"
Minor A: "Photo on 4-6-14 at 1.01AM.jpg" [The image depicts Minor A,
spreading his buttocks and exposing his anus, which is the focal
point of the image]
PETE: "wow!!!"
Minor A: "<ss type="smile">:)</ss>"
PETE: "I mean... WOW WOW WOW!!!"
25. On April 6, 2014, at or around 00:12, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "can't wait...send me another surprise"
Minor A: "Photo on 4-6-14 at 1.12 AM #3.jpg" [The image depicts Minor A,
nude, from the side and bending over. Minor A’s genitals and
buttocks are not visible]
Minor A: "Photo on 4-6-14 at 1.12 AM #2.jpg" [The image depicts Minor A,
nude, from the side and bending over. Minor A’s genitals and buttocks are not visible]
Minor A: "Photo on 4-6-14 at 1.12 AM.jpg" [The image depicts Minor A,
nude, from the side and bending over. Minor A’s erect penis is
visible]
PETE: "wow, so hot, are u a gymnast"
26. On April 20, at or around 21:53, the following chat occurred between
Minor A and “PETE”/VASTIS:
Minor A: "if I sent you a video that may or may not be legal, would you
mind? Its technically child pornography [ ]
Minor A: "15.wmv" [Agents were unable to recover the file from Minor A’s
computer]
Minor A: "you can delete it right after if you want"
PETE: "I feel really nervous to even open it. I hear all sorts of stories
about guys getting in huge trouble for that kind of thing"
Minor A: "just delete it right after"
Minor A: "its hot"
PETE: "describe it to me first, what's the approx age?"
Minor A: [Following agents’ analysis of the data and conversion into
spreadsheet format, the numbers provided by Minor A during
this chat were converted to a date format of “9/11/14”; agents
believe, however, that Minor A told “PETE” that the child
depicted in the video described by Minor A was 9-11 years old]
PETE: "where did u find something like that?"
Minor A: "I traded with someone for it"
PETE: "what do u give in return? Where do u guys find stuff like this?"
Minor A: "idk"
Minor A: "I just do favors for him"
Minor A: "like sending my nudes lol"
PETE: "damn I'm so tempted"
Minor A: "lol just do it"
Minor A: "and delete it right after it"
PETE: "hold on"
PETE: "says it may be an application downloaded form [sic] [internet.
Minor A: "yea, that's the app that runs the movie"
PETE: "ur certain I can't get in trouble for this if I delete it right away?
Minor A: "lol no"
PETE: "says it can't be opened"
Minor A: "oh ok, well then don't worry about it"
PETE: "why do u suppose I can't open it?"
Minor A: "idk, id have to look more into it"
Minor A: "I can show you a screenshot if you want"
PETE: "yeah"
Minor A: "Screen Shot 2014-4-20 at 11.00.47 PM.png" [Agents were
PETE: "[ ] hot"
Minor A: "told you"
PETE: "I think younger than u said tho"
Minor A: "really?"
Minor A: "any more pics you want from me? Anything at all"
PETE: "wish I could see the movie now"
Minor A: "Screen Shot 2014-4-20 at 11.03.39 PM.png" [Agents were
unable to recover the file from Minor A’s computer]
Minor A: "man [****]ing 9 year old boy"
Minor A: "cute"
Minor A: [ ]
PETE: "same film or different one?"
Minor A: "different"
PETE: "try sending that film"
Minor A: "video4.wmv" [Agents were unable to recover the file from Minor
A’s computer]
PETE: "nope, same message"
Minor A: "sorry, maybe ill show you one day"
Asking if I'm sure about opening it.
"Can't be traced back"
unable to recover the file from Minor A’s computer]
Minor A: "I have a lot of videos"
PETE: "take a screen shot of that last one that shows the boy"
Minor A: "it doesn't show him"
Minor A: "they like to protect the kids"
PETE: "I see"
PETE: "ok, last oil from u...sitting on your knees, back to the camera,
PETE: "pic"
Minor A: "but I want to do more than that"
Minor A: "something sexy"
Minor A: "anything"
Minor A: "something extreme"
PETE: "surprise me then"
Minor A: "Photo on 4-20-14 at 11.10 PM.jpg" [The image depicts Minor A
underwear off, turn ur face and smile at the camera"
bending over with his anus exposed. A foreign object has been
inserted into Minor A's rectum]
PETE: "haha, feel good son?"
Minor A: "better than good, dad"
PETE: "I think u need my [expletive term for penis] in there instead"
27. On April 20, 2014, at or around 22:27, the following chat occurred
between Minor A and “PETE”/VASTIS:
Minor A: "one more pic before I go?
PETE: "yeah, surprise me"
PETE: "and assure me once again that u completely delete these
conversations"
Minor A: "Photo on 4-20-14 at 11.28 PM.jpg" [The image depicts Minor A,
bending over and facing away from the camera. Minor A is
spreading his buttocks and exposing his anus]
Minor A: "yea of cousse"
Minor A: "course"
PETE: "great pic"
PETE: "and yeah, bring the laptop, we gonna have an interesting
time...nit, talk again soon"
28. On April 23, 2014, at or around 21:26, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "so u have lots of that kind of stuff? Aren't u worried you'll be
Minor A: "I'm careful"
Minor A: "but yes I have a lot of it lol"
PETE: "no danger in me receiving screenshots like us sent, right?"
Minor A: "not if you delete it"
PETE: "yeah I did"
Minor A: "ok, you're fin e"
PETE: "u should surprise me with another one"
Minor A: "Screen Shot 2014-4-23 at 10.29.45 PM.png" [Agents were
PETE: "cool... how old do u suppose that one is?"
Minor A: "not sure, could be 9, could be 11"
Minor A: "can't really tell"
PETE: "hard to believe that stuff really happens"
29. On April 23, 2014, at or around 21:52, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "back to cam, [buttocks] showing, head turned toward the cam,
blow daddy a kiss"
Minor A: "Photo on 4-23-14 at 10.52 PM.jpg" [The image depicts Minor A,
bending over and away from the camera, looking back towards
the camera. He is making a motion like blowing a kiss. The top
half of his buttocks are visible]
caught with it?
unable to recover the file from Minor A’s computer]
30. On May 15, 2014, at or around 17:32, the following chat occurred
between Minor A and “PETE”/VASTIS:
Minor A: "what do you do?"
PETE: "I thought u knew"
Minor A: "nope"
PETE: "am I talking to the right person? Lol"
Minor A: "lol yes"
Minor A: "idk maybe you told me, I probably forgot"
PETE: "teach"
Minor A: "really? What do you teach?"
PETE: "wait a sec... send me a quick pic, I want to make sure no one is
on your computer"
Minor A: "omg fine"
Minor A: "Photo on 4-20-14 at 11.28 PM.jpg" [The image depicts Minor A
bending over and facing away from the camera. Minor A is
spreading his buttocks, exposing his anus]
Minor A: "you've never told me what you teach"
Minor A: "you said it was private"
PETE: "I teach 5th and 6th grade"
Minor A: "6th grade what?"
Minor A: "what class"
PETE: "public speaking"
31. On May 15, 2014, at or around 18:26, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "got any new interesting pics to send my way?"
Minor A: "of me?"
PETE: "well yeah, but I mean from your hobby"
Minor A: "oh ok"
Minor A: "gimme a sec"
Minor A: "_FO9ZC0X2.jpg" [Agents were unable to recover the file from
Minor A’s computer]
32. On May 15, 2014, at or around 18:44, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "now, flex one arm while ur other hand is on ur [penis]"
Minor A: "Photo on 5-15-14 at 7.44 PM.jpg" [The image depicts Minor A,
bending over and away from the camera, exposing his buttocks
and testicles]
PETE: "awesome"
PETE: "[buttocks] shot, don't spread cheeks tho"
Minor A: "Photo on 5-15-14 at 7.47 PM.jpg" [The image depicts Minor A,
curling his left arm, while his right hand holds his erect penis]
PETE: "nice"
33. On June 19, 2014, at or around 13:19, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "did your reading get u all horned up?"
Minor A: "hell yea it did"
PETE: "yeah me too... I soooo need a boy right now"
Minor A: "I just need someone to dominate me rn"
PETE: "year, that's exactly what I'm in the mood to do
34. On July 12, 2014, at or around 22:19, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "next pic... standing... underwear off... let me see my boy's
sweet [buttocks]"
Minor A: "Photo on 7-12-14 at 11.20 PM.jpg" [The image depicts Minor A,
standing and facing away from the camera, nude from the legs
up. His buttocks are exposed]
PETE: "nice, again now but with your arms and hands down to your
side"
Minor A: "Photo on 7/12/14 at 11.22 PM.jpg" [The image also depicts
Minor A, standing and facing away from the camera, nude from
the legs up. Minor A’s buttocks are exposed]
PETE: "very very nice"
PETE: "are u feeling good about this boy?
Minor A: "hell yes daddy"
PETE: "show me, turn around and let me see for myself"
Minor A: "Photo on 7-12-14 at 11.25 PM.jpg" [The image depicts Minor A,
standing at a 90 degree angle to the camera, nude from the legs
up, holding his erect penis]
PETE: "HOT!!!! Damn"
PETE: "ur getting hotter all the time son"
35. On July 13, 2014, at or around 00:07, the following chat occurred
between Minor A and “PETE”/VASTIS:
Minor A: "Movie on 7-13-14 at 1.32 AM.mov" [The video, which is
[graphic discussion of Minor A masturbating omitted]
approximately one minute and fifty-two seconds in length,
depicts Minor A masturbating]
PETE: "don't leave, wait till I view it"
PETE: "HOLY [ ]!!!!"
PETE: "are u here?"
Minor A: "I told you"
PETE: "SO [ ] HOT. Yeah, I [ ] trust u kid... u deliver!"
36. On July 13, 2014, at or around 21:05, the following chat occurred
between Minor A and “PETE”/VASTIS:
Minor A: "I got some pics you might like <ss type="wink">;)</ss>"
Minor A: "I traded people for some kiddie porn lol"
PETE: "Send thru here like u did a while back"
Minor A: "042424k7ifz6wqq2ap62re.jpg" [Agents were unable to recover
PETE: "jesus, what the hell? How old do u think he is?"
[ ]
37. On July 13, 2014, at or around 21:12, the following chat occurred
between Minor A and “PETE”/VASTIS:
PETE: "had an interesting cam session today"
Minor A: "really?"
Minor A: "tell me about it"
PETE: "13"
Minor A: "mmm"
Minor A: "what did you make him do?"
PETE: "didn't have to...he volunteered it all"
PETE: "just basically watched him [masturbate]"
Minor A: "what did he do?"
PETE: "did you take screenshots?"
PETE: "no"
PETE: "never even occurred to me, sorry"
Minor A: "aww <ss type="sad">:(</ss>"
PETE: "had a similar one a few weeks ago, used mic with that
one...said 15 but think he was younger...hottest moo I ever
played on cam with"
the file from Minor A’s computer]
C. Identification of “PETE” as Defendant VASTIS
38. Based on my training and experience, and the experience of others
with whom I have consulted, I understand that an internet protocol address is
unique to a particular computer or residence during an online session. The IP
address provides a unique locator, making it possible for data to be transferred
between computers. Each time an individual accesses the Internet, the computer
from which that individual initiates access is assigned an IP address. A central
authority provides each Internet Service Provider with a limited block of IP
addresses for use by that ISP’s customers or subscribers. Many ISPs employ
dynamic IP addressing; in other words, they allocate an unused IP address each
time a customer or subscriber accesses the Internet. The ISP logs the date, time,
and duration of the Internet session for each IP address and can identify from these
records the user of that IP address for a particular session.
39. Typically, home users of the internet are assigned an IP address from
a pool of IP addresses for the duration of a session. In the case of dial-up modems, a
user’s IP address is released when the user’s computer disconnects from the
telephone service, and that IP address is available for others to use. In the case of
cable modems or DSL service, an IP address is commonly held by a user for a longer
period of time, from days to months, until the provider chooses to change it. Some
services use static addressing, where an IP address is permanently assigned to a
specific computer and is difficult to change
40. On or about August 25, 2014, pursuant to an administrative subpoena,
an ISP disclosed IP addresses pertaining to the Skype-based chat logs summarized
above that occurred on or about April 6, 2014; May 18, 2014; June 17, 2014; July 13,
2014; July 14, 2014, July 17, 2014, and August 14, 2014. According to the
information provided by the ISP, all of the IP addresses associated with the
relevant chat logs were assigned to the ISP account of Subject A, an individual who,
as described below, resides at the Lakemoor residence along with VASTIS.
41. Based upon agents’ searches of public databases, Subject A appears to
be the spouse of VASTIS and resides at the Lakemoor residence. In addition, based
upon those same searches of public databases, agents have determined that
VASTIS’s date of birth is consistent with the age provided by “PETE” during the
chats excerpted above. In addition, a review by agents of VASTIS’s Illinois Driver’s
License information and photograph revealed that VASTIS appears to be a white
male who has brown hair, brown eyes, is 5' 9" tall, weighs approximately 235 lbs.,
and resides at the Lakemoor residence. These biographical measurements are
consistent with the physical self-description provided by “PETE” during one of the
chats listed above that occurred on September 4, 2013.
42. A search of open sources on the internet also revealed that VASTIS is a
teacher at Meridian Middle School in Buffalo Grove, Illinois, which is consistent
with “PETE”’s reference in paragraph 30 to teaching fifth and sixth graders.
43. After reviewing the photograph associated with VASTIS’s Illinois
Driver’s License, an HSI Computer Forensic agent searched the images on Minor
A’s telephone pursuant to the state warrant. During that search, the agent located
at least two different photographs of VASTIS, both of which depict VASTIS in the
nude, apparently lying down, with his penis exposed. Those images were received
by Minor A’s telephone on or about July 30, 2014. Both the HSI Computer Forensic
Agent and another agent have compared these images with VASTIS’s Illinois
Driver’s License photograph and have concluded that the images depict VASTIS.
44. In addition, during surveillance on August 26 and 27, 2014, HSI
agents and Task Force officers compared VASTIS’s Illinois Driver’s License
photograph to the appearance of a person seen entering and exiting the Lakemoor
residence and have concluded that the person entering and exiting was VASTIS.
45. Also on August 25, 2014, at approximately 17:50 hours, an HSI
Chicago Task Force officer performed surveillance of the Lakemoor residence.
Located in the driveway of the residence was a maroon Honda Civic bearing an
Illinois license plate registered in the name of VASTIS at the Lakemoor residence.
46. Based on the foregoing information, in combination with the
information "PETE" provided about himself in the chat logs summarized above, I
respectfully submit that VASTIS and "PETE" are the same individual who resides
at the Lakemoor residence.
D. Information Concerning Minor A’s Computer
47. Agents have examined the computer that Minor A used to
communicate with VASTIS via Skype. Based on that examination, agents
determined that the computer is an Apple “Macintosh Pro” Model A1278 that,
according to a label affixed to the computer, was made in China.
CONCLUSION
48. Based on the foregoing, I respectfully submit that probable cause
exists to believe that VASTIS has violated Title 18, United States Code, Sections
2251(a) and 2252A(a)(2), in that VASTIS (a) used, persuaded, induced, and enticed
a minor under the age of eighteen with the intent that the minor engage in sexually
explicit conduct for the purpose of producing visual depictions of such conduct,
which visual depictions were produced and transmitted using materials that had
been mailed, shipped, and transported in interstate and foreign commerce and
which visual depictions were transported or transmitted using any means or facility
of interstate or foreign commerce; and (b) knowingly received, and attempted to
receive, material that contained images of child pornography, such images having
been mailed, shipped, and transported in interstate and foreign commerce by any
means, including by computer.
FURTHER AFFIANT SAYETH NOT.
MICHAEL A. SCHUSTER
Special Agent
Homeland Security Investigations
SUBSCRIBED AND SWORN to before me on August 27, 2014.
# posted by Cal Skinner : 12:05 PM
