Case: 7:16-mj-00002-EBA Doc #: 1 Filed: 05/12/16 Page: 1 of 1 - Page ID#: 1

AO 91 (Rev. 11111) Criminal Complaint

UNITED STATES DISTRICT COUR

for the

MAY 12 2016

Eastern District of Kentucky

EDWARD 8. ATKINS

United States of America

U.S. Magistrate Judge

)
)

v.

)
)

Willard Dean Hall

)
Defendant(s)

CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
On or about the date(s) of _ _ _9_/1_/2_0_1_5_to_1_1/_2_4/_2_0_15_ _ _ in the comia of _ _ _ _K_n_o_tt_ _ _ _ in the
Eastern

District of _ _ _K_e_n_tu_cc_k:J__y_ _ _ , the defendant(s) violated:

Offense Description

Code Section
18 U.S.C. 2251 (a)
18 U.S.C. 2251 (a)(2)
18 U.S.C. 2251(a)(4)

Production of Child Pornography - 2 counts

Receipt of Child Pornography - 2 counts
Possession of Child Pornography - 1 count

This criminal complaint is based on these facts:

SEE AFFIDAVIT

~ Continued on the attached sheet.

11rJ ~:/:'!.~,: };t,.,{'J3;1~: !;i,,

Special Agent Thad Lambdin
Printed name and title

Sworn to before me and signed in my presence.

$~~._,is;IS'~> Signed By:

!

Date:

~\ EdwardB.Atkinse~

\""a.srRC'~# United States Magistrate Judge

12-051,Y1'72016

Judge 's signature

City and state:

Pikeville, Kentucky

Hon. Edward B. Atkins, U.S. Magistrate Judge

Printed name and title

Case: 7:16-mj-00002-EBA Doc #: 1-1 Filed: 05/12/16 Page: 1 of 19 - Page ID#: 2

AFFIDAVIT IN SUPPORT OF
CRIMINAL COMPLAINT

I, Special Agent Thad Lambdin of the Federal Bureau of

Investigation, being duly sworn under oath, do hereby depose and
state:
INTRODUCTION
1.

I have been a Special Agent with the Federal Bureau of

Investigation, United States Department of Justice, since April

2003, and am currently assigned to the Louisville Division,
London Resident Agency. My responsibilities include the
investigation of various criminal offenses, including crimes
involving the sexual exploitation of children; specifically the
production, distribution, receipt and possession of child
pornography. From 2000 to 2003, and prior to becoming a Special
Agent,

I was a Systems Administrator for both the county and

city of Huntington, Indiana, where in addition to my primary

responsibilities,

I assisted the Huntington Police Department

with reviews of suspect's computers for child pornography. Prior

to this employment (1992 to 2000), I was a Patrolman with the
Huntington City Police Department, Huntington, Indiana for
approximately 8 1/2 years.

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2.

In the course of my employment with the Federal Bureau of

Investigation,

I have participated in the execution of search

warrants resulting in the seizure of computers, magnetic storage

media for computers, other electronic media, and other items
evidencing violations of federal law.

3.

As a federal agent,

I am authorized to investigate

violations of United States laws and to execute warrants issued

under the authority of the United States.

4.

I am investigating the criminal activities of Willard Dean

Hall, who resides at 5326 HWY 1087 E, Mousie, Kentucky 41839. As

will be shown below,

I submit there is probable cause to believe

that Willard Dean Hall has produced, distributed and possessed

child pornography, in violation of 18 U.S.C.

2251(a),

2252(a)(2), 2252(a)(4).

5.

The statements in this affidavit are based in part on

information provided by Kentucky State Police (KSP)

Detective

Joseph Dials, assigned to KSP Post 13, Hazard, Kentucky, and on

my investigation of this matter. Since this affidavit is being
submitted for the limited purpose of securing a criminal
complaint, I have not included each and every fact known to me
concerning this investigation.
2

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STATUTORY AUTHORITY

6.

This investigation concerns alleged violations of 18 U.S.C.

2251(a), 2252(a) (2),

2252(a) (4), relating to material

involving the sexual exploitation of minors.

a. 18 U.S.C. 2251(a) prohibits using, persuading,
inducing or enticing a minor to engage in sexually
explicit conduct for the purpose of producing visual
depictions of such conduct and that these depictions
were produced using materials that had been mailed,
shipped or transported in interstate or foreign
commerce.
b. 18 U.S.C. 2252(a) (2) prohibits knowingly receiving or
distributing, by computer or mail, any visual depiction
of minors engaging in sexually explicit conduct that has
been mailed, shipped, or transported in interstate or
foreign commerce. That section also prohibits knowingly
reproducing any visual depiction of minors engaging in
sexually explicit conduct for distribution in interstate
or foreign commerce by any means, including by computer
or the mail.
c. 18 U.S.C. 2252(a) (4) prohibits possessing one or more
books, magazines, periodicals, films,
3

or other materials

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which contain visual depictions of minors engaged in

sexually explicit conduct that have been transported in
interstate or foreign commerce, or that were produced
using materials that had traveled in interstate or
foreign commerce.

DEFINITIONS

7.

The following definitions apply to this Affidavit:

a. "Child Pornography" includes any visual depiction of
sexually explicit conduct where (a) the production of
the visual depiction involved the use of a minor engaged
in sexually explicit conduct;

(b) the visual depiction

was a digital image, computer image, or computergenerated image that is, or is indistinguishable from,
that of a minor engaged in sexually explicit conduct; or
(c) the visual depiction has been created, adapted, or
modified to appear that an identifiable minor is engaged
in sexually explicit conduct. See 18 U.S.C. 2256(8).
b. "Computer" refers to "an electronic, magnetic, optical,
electrochemical, or other high speed data processing
device performing logical or storage functions, and
includes any data storage facility or communications

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facility directly related to or operating in conjunction

with such device." See 18 U.S.C. 1030

(e)

(1)

c. "Internet Protocol address" or "IP address" refers to a

unique number used by a computer to access the Internet.
d.

"Minor" means any person under the age of 18 years. See

18

e.

u.s.c.

2256(1).

"Sexually explicit conduct" is a term that applies to

visual depictions that involve the use of a minor,

see

18 U.S.C. 2256(8) (A), or that have been created,

adapted, or modified to appear to depict an identifiable
minor,

see 18 U.S.C. 2256(8) (C).

In those contexts,

the term refers to actual or simulated (a)

intercourse

sexual

(including genital-genital, oral-genital, or

oral-anal), whether between persons of the same or

opposite sex;

(b) bestiality;

( c) masturbation;

sadistic or masochistic abuse; or (e)

( d)

lascivious

exhibition of the genitals or pubic areas of any person.

See 18 U.S.C. 2256(2) (A).
f.

"Visual depictions" include undeveloped film and

videotape, and data stored on computer disk or by
electronic means, which is capable of conversion into a
visual image. See 18 U.S.C. 2256(5).

g. The terms "records," "documents," and "materials"

include all information recorded in any form, visual or
5

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aural, and by any means, whether in handmade form

(including, but not limited to, writings, drawings,
painting), photographic form (including, but not limited
to, microfilm, microfiche, prints, slides, negatives,
videotapes, motion pictures, photocopies); mechanical
form (including, but not limited to, phonograph records,
printing, typing); or electrical, electronic or magnetic
form (including, but not limited to, tape recordings,
cassettes, compact discs, electronic or magnetic storage
devices such as floppy diskettes, hard disks, CD-ROMs,
digital video disks

(DVDs), Personal Digital Assistants

(PDAs), Multi Media Cards (MMCs), memory sticks, optical

disks, printer buffers, smart cards, memory calculators,
electronic dialers, Bernoulli drives, or electronic
notebooks, as well as digital data files and printouts
or readouts from any magnetic, electrical or electronic
storage device).

BACKGROUND OF THE INVESTIGATION

8.

On or about Monday, November 23, 2015, Detective Dials

received information from Carr Creek Elementary School Assistant

Principal Debbi Back, that there were four students, Student 1
(12 years old), Student 2 (13 years old), Student 3 (12 years
6

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old) and Student 4 (13 years old) who had sent nude photographs
of themselves to a person named Jimmy Slone via Facebook. The
Facebook account for Jimmy Slone indicated Slone was a 15-yearold male. Facebook is an online (internet-based) social
networking site that includes a "Messenger" application allowing
users to exchange messages and computer files,

including digital

images. Based on my training and experience, I know that

accessing Facebook necessarily requires use of the internet,
which is a facility of interstate commerce.

9.

On November 24, 2015, Detective Dials spoke with the

students identified by Debbi Back. Student 1 received a nude

photo of Jimmy Slone from Jimmy Slone and sent two nude photos
of Student 1 to Jimmy Slone via Facebook Messenger. This
occurred about two weeks prior. Student 2 sent Jimmy Slone nude
pictures of Student 2 on Facebook and Jimmy Slone sent Student 2
nude pictures of Student 1 on Facebook. Student 3 did not send
nude photos of Student 3, but Student 3 indicated Student 4 had
nude pictures of Student 2 that were supposed to have come from
Jimmy Slone's Facebook account. Student 4 received nude photos
of Student 2 from Jimmy Slone on Student 4's cell phone. Jimmy
Slone also told Student 4 that he had nude photos of Student 1,
but never sent those to Student 4.

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10.

On or about February 11, 2016, Detective Dials obtained a

search warrant for Facebook records for the Jimmy Slone Facebook
account. On or about March 29, 2016, Detective Dials reviewed
the Facebook materials returned pursuant to the search warrant
and verified there were several images of suspected child
pornography contained in the account. The majority of messages
showed an origination Internet Protocol (IP) address of
199.116.159.129 for the user of the Jimmy Slone account.

11.

On or about March 30, 2016, Detective Dials obtained a

Grand Jury Subpoena requesting Thacker Grigsby Communications,

the Internet Service Provider (ISP) that controls IP address
199.116.159.129, for subscriber information. On or about March
31, 2016, Thacker Grigsby Communications identified Willard Dean
Hall as the subscriber to IP address 199.116.159.129, at 5326
HWY 1087 E, Mousie, Kentucky.

12.

On or about April 4, 2016 Detective Dials obtained and

executed a search warrant for Willard Dean Hall's residence,

5326 HWY 1087 E, Mousie, Kentucky. During the execution of the
search warrant, Willard Dean Hall, a 43-year-old male, was
interviewed and confessed to controlling multiple Facebook
accounts, including the Jimmy Slone Facebook account, and using
these accounts to obtain nude images of female minors.
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13.

Based on my review of the Facebook account records returned

pursuant to the February 11, 2016 search warrant and my

knowledge of Willard Dean Hall's statements in his April 4, 2016
interview with Detective Dials, I have found that Willard Dean
Hall used the Facebook persona Jimmy Slone to use, persuade,
induce, and entice at least two minors to engage in sexually
explicit conduct for the purpose of producing visual depictions
of such conduct. In some cases he threatened to distribute
previously obtained images to convince minors to produce new
images of child pornography. The following paragraphs are
examples of Willard Dean Hall's Facebook conversations involving
the production, receipt, and distribution of child pornography.

14.

On 11/03/2015, the following exchange took place between

Willard Dean Hall, using the Jimmy Slone (JS)

and Student 1 (Sl), a 12-year-old minor:

Sl

How old are u

JS

15 going on 16

Sl

I'm 12

JS

You show your boobs

Sl

u wanted me to so

JS

I want to see your pussy and ass

9

Facebook account,

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Sl

Why

JS

You show them to me and I will show you mine dick

Sl

If I show u will u delect them

JS

Yes I promise

Sl

Who do live with

JS

Just my mom but she is gone right now

JS

Can I see them

Sl

Delect the text to or I wont

JS

I will delete everything

Sl

Sl

I'll show u Friday because I'm on my period

Sl

That's when I get off of it

JS

I don't care about that I just want to see

Sl

Show me yours first

JS

[sends photo of a penis being held by a left hand]

JS

Now your turn

Sl

[sends photo of herself in blue shirt and lighter blue

shorts with right wrist band; right hand by crotch
area with finger beside vagina]

JS

Can't see it

JS

You can do better

Sl

[sends another photo of herself in blue shirt with

right wrist band; her right hand is pulling lighter
blue shorts to side so vagina is displayed]
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Sl

[sends blue thumbs up png]

JS

What about the ass

Sl

[sends another close up of her vaginal area with her

right hand visible pulling lighter blue shorts to
side; blue shirt visible above shorts.]

15.

Sl

Not right now

JS

Have you had sex yet

Sl

No I'm 12

JS

Could you take mine

Sl

How would

JS

We could meet some time

Sl

Where

JS

Maybe go out

Sl

My dad won't let me so no

JS

Do you know where the big y market is

Sl

Yes

ever do that with u

On 9/23/2015, the following exchange took place between

Willard Dean Hall, again using the JS Facebook account, and

Student 5 (S5), a 16-year-old female minor:

S5

I lost wifi

JS

Can I have one

11

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SS

[sends non-pornographic photo in school setting,

wearing an orange/red Aeropostal shirt]

JS

Flash me

SS

Why

JS

I need it

SS

Why

JS

I need to see

SS

Meet me at brake stand at the sciences room upstairs

Adams

JS

I'm nit there

JS

Not

SS

What u mean

JS

I'm not at school

SS

Why

JS

Sick

SS

Yewh

JS

That's the truth

SS

Yup

JS

Can j get a flashing pie

SS

U ain't here

JS

Well I know what your going to say so I will just get

me one off ksmeron messages

JS

Sorry I asked and bothered you

SS

Ok bye
12

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JS

Well I will get all them pies off message that I sent
ksmeron

S5

Cause I won't send one

JS

Yes

SS

Why

JS

I need one

SS

You don't need one

JS

Yes I do

JS

Fine you keep 1 I will get 20 from him messages

JS

His

SS

[sends a picture of her breasts, right hand pulling up

black shirt and possibly a bra. Not the same clothes
as the previously described photo]

JS

Thought you didn't have any

SS

Well there so

JS

How many more do you have

JS

I wanted a new one

JS

Not one I seen before

SS

I don't have Anymore

JS

Well do you want to make a deal right now

JS

If you give me a new titty pie and pussy pie I will

delete every body's messages I sent pies to

SS

That's not far u lied to me u said u would never ask

for any pies anymore
13

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JS

I sorry baby but after I deleted all them and the

message me and you had I missed looking at them

JS

What do you say uou want to make that deal

JS

But it's got to be new pies one I didn't see before

SS

No I don't cause u lied to me

JS

I'm sorry I did

JS

See if I go back and get the pies off the messages it

would be maybe 40 or 50 of them

JS

Well ok I just wanted you to send 2 new ones and I

would delete all there messages

SS

Yeah that's going to be another lie

JS

No it's not baby

JS

But that's fine you keep them 2 pies and I will go get
them other ones off them messages

S5

Ok

JS

Can I get 2 new pies

SS

[sends a picture of herself lifting a black blouse

above her breasts; she has a cloth jacket with zipper
on over the shirt]

S5

One

JS

No 2

SS

One

JS

I want the pussy pie

SS

Why
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JS

I want it

SS

I don't want to give it

JS

Fine I will get it off the messages I sent your mom

SS

Really

JS

Yes

JS

So do I get it from you or the messages

SS

[sends closeup of her vagina with fingers spreading

herself open, with black blouse, chin, and hair
visible in top right of photo; some pink writing is
visible on the shirt]

JS

You can do better

JS

The cam was to high

SS

U didn't say it has to be good so

JS

You knew it did

SS

Nope

JS

Do a good one

SS

Later

JS

Now

SS

Why now

JS

Fine you keep it

will go get all the pies from your

moms and her boyfriend and ksmeronss messages

SS

Ok

JS

So you won't do a good one

SS

And u won't stop asking

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JS

Last time I ask will you do a new pussy pie or do I go

get all them other pictures

S5

[send png of blue thumbs up]

JS

Which one

JS

Well when you take time from Joseph sand can talk to
me let me fucking know

S5

[sends another photo of vaginal area with fingers

pulling area open with black blouse visible above and
to right; some pink writing is visible on the shirt]

JS

That's the same one you sent before the cam is to high

S5

No it's not

S5

[sends another photo of vaginal area with fingers from

right hand opening area for view; black blouse with
pink writing visible]

JS

That's nice just needs me more light

S5

No

JS

Yes it does

S5

Well I'm not doing it

JS

Why are you mad

S5

I ain't

JS

It seems like you are

S5

No

JS

Why are your nips hard

S5

There not
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JS

Looks like thay are in that pie you sent

JS

May I see your face

SS

[sends photo with same orange/red Aeropostal top on as

in the initial non-pornographic photo sent to JS]

JS

And you smiled

JS

and it's on Facebook

JS

Give me one that isn't on Facebook already

SS

[sends photo of V's face; black blouse with pink

writing is visible in photo]

JS

There is the smile I have been waiting to see

JS

Thank you for it

SS

Yw

JS

SS

U ti

JS

Let me ask you if we was together and alone somewhere

love you

could I eat your pussy and suck your tits

SS

16.

idk

I have reviewed the Jimmy Slone Facebook warrant response

and verified there are numerous images of child pornography

present and that Willard Dean Hall used, persuaded, induced, and
enticed Student 1 and Student S to produce images of child
pornography. Willard Dean Hall persuaded Student 1 to produce
and transmit to him multiple pictures of her pulling her shorts
17

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to the side to provide a lascivious, close-up display of her

vagina. Willard Dean Hall persuaded Student 5 to produce and
transmit to him multiple close-up pictures of her using her
fingers to spread open her vagina, displaying it in a lascivious
manner. He threatened to disseminate other pictures of Student 5
to convince her to produce and transmit to him these images of
child pornography. Moreover, I verified the identity and age of
Student 1 with Dwight Creech, the principal of Carr Creek
Elementary School.

Willard Dean Hall identified Student 5 and

stated that she was a student at Knott County Central High

School. He also stated that he had spoken to Student 5 in
person, but did not tell her that he was the person using the
Jimmy Slone Facebook account. I confirmed the identity and age
of Student 5 with Bobby Pollard, the principal of Knott County
Central High School.

17.

In addition to confessing to Detective Dials that he

obtained nude images of minors using the Jimmy Slone Facebook

account, as well as other accounts not named in this Affidavit,
Willard Dean Hall also confessed to Detective Dials that
additional nude images of minors would be found on the items
seized during the search warrant.

18

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CONCLUSION
The above-described conduct involving Student 1 and Student
5 provide probable cause that Willard Dean Hall violated 18

u.s.c.

2251(a) (production of child pornography) and 18 U.S.C.

2252 (a) (2) (receipt of child pornography) on at least two

occasions.

Willard Dean Hall's admissions to Detective Dials,

corroborated by the presence of multiple images of child

pornography in the response to the search warrant for the Jimmy
Slone Facebook account, provide probable cause that Willard Dean
Hall violated 18 U.S.C. 2252 (a) (4)

(possession of child

pornography) .

/ha..2-- 4-.t /. ....

4J

/SA-

vv

f'L. /e/,,,,.:u,--v..J

Thad Lambdin
Special Agent
FEDERAL BUREAU OF INVESTIGATION

19

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t c., _ ;\'\

:r - o z - ~ E'A

Rule 4.1 Addendum

Per Rule 4 l(d)(3) and Rule 4.1, the Court processed the warrant remotely. The Court verified
the Affiant's identity (by AUSA confirmation, through Affiant self-identification, and by
personal knowledge), with badge # / f 5 0 c./
. Affiant simply attested to the affidavit and
application, which the AUSA transmitted by remote electronic means (e-mail). The Court issued
the original warrant and transmitted same to the Applicant, via the AUSA, by remote electronic

m;~~
~ail).SIQ1nMBlf,ess complied with Rule 4.1.

Edward B. Atkinse~
\~'lTB.-la!,.:
~~! United States Magistrate Judge

~\

Edward B. Atkins,
United States Magistrate Judge

EASTERN DISTRICT OF KENTUCKY

FILED

MAY 12 2016
~------------------
EDWARD 8. ATKINS
U.S. Magistrate Judge

Date and Time: