Case 1:11-cr-00345-AJT Document 17

Filed 07/29/11 Page 1 of 3 PageID# 40

IN THE UNITED STATES DISTRICT COURT FOR T

EASTERN DISTRICT OF VIRGINIA
Alexandria Division

UNITED STATES OF AMERICA

v.

COOPER KWEME, also known as Jason Pathers, also known as Jason, also known as Jason Forhee,
Defendant.

CRIMINAL NO. 1:1 lcr345

Judge Anthony J. Trenga

STATEMENT OF FACTS

If this case went to trial, the United States would prove by admissible evidence and beyond a reasonable doubt the following:

1. From in and around February 2011 through in and around May 2011, in Arlington

County, Virginia, within the Eastern District of Virginia, and elsewhere, the defendant, COOPER
KWEME, also known as "Jason" in and affecting commerce, knowingly recruited, enticed,

transported, and provided AK , ajuvenile female who had notattained the age of 18 years,

knowing and in reckless disregard of the fact that AK had not attained the age of 18 years and
that AK would be caused to engage in a commercial sex act, in violation of Title 18, United
States Code, Section 1591(a)(1).

2. In and around February 2011, COOPER KWEME met AKon a social network
internet site. AK was born in 1994. AK's social network profile accurately stated that she was a

16-year-old girl. KWEME claimed to be in his mid-20s, when in fact he was 31 years old.

Case 1:11-cr-00345-AJT Document 17

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3. On or about February 14, 2011, KWEME and AK began an intimate relationship.

Shortly after the relationship began, KWEME took sexually suggestive photographs of AK in a hotel room. Unknown to AK, KWEME later used the photographs to advertise her as a
prostitute on the internet. 4. In and around March 2011, KWEME began advertising AK on the internet as a

prostitute. From March 2011 into May 2011, KWEME transported AK from northern Virginia
to locations in Maryland and northern Virginia where AK engaged in sex acts for money with
various clients. Amongthe locations where AK engaged in sex acts for money were hotels and

residences in Maryland, and hotels in northern Virginia. When clients paidAK for the sex acts

that she performed, she would take the money to KWEME who would give her a percentage of
the fee charged to the client.

5. At all times, COOPER KWEME acted intentionally, unlawfully and not as a result of
accident, mistake or other innocent reason.

Respectfully submitted,

Neil H. MacBride

United States Attorney

By:
Morris R. Parker, Jr.

Mary K. Daly Assistant United States AttoMeys

6. After consulting with my attorney and pursuant to the plea agreement entered into this

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day between the defendant, COOPER KWEME, and the United States, I hereby stipulate that the
above Statement of Facts is true and accurate, and that had the matter proceeded to trial, the

United States would have proved the same beyond a reasonable doubt.

Date:

7/W;/
COOPER KWEME
Defendant

7. I am COOPER KWEME'S attorney. I have carefully reviewed the above Statementof

Facts with him. To my knowledge, his decision to stipulate to these facts is an informed and
voluntary one.

Date: ifa /ft

44-

jffrey Corey, Esq. Whitney Minter

Counsel to the Defendant