Case 8:16-mj-00449-CBD Document 1 Filed 02/23/16 Page 1 of 1

AO 91 (Rev. 11/11)

Criminal Complaint

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United States of America

v.
DEONTE CARRA WAY

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Case No.

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Defendont(s)

CRIMINAL COMPLAINT
I, the complainant

in this case, state that the following

On or about the date(s) of

October 20 IS-January 2016

Maryland

District of

in the county of

, the defendant(s)

and belief.

Prince George

in the

violated:

OfJellse Descriptioll

Code Sectioll
18 USC Sec,ion 2251
Counts 1 through 8

is true to the best of my knowledge

Count
Count
Count
Count
Count
Count
Count
Count

1
2
3
4
5
6
7
8

On
On
On
On
On
On
On
On

or about
or about
or about
or about
or about
or about
or about
or about

October 11, 2015, Carraway produced child pornography.

October 30, 2015, Carraway produced child pornography.
November 25,2015, Carraway produced child pornography.
December 14, 2015, Carraway produced child pornography.
December 22, 2015, Carraway produced child pornography.
December 22, 20 IS, Carraway produced child pornography.
January 8, 2016, Carraway produced child pornography.
January 8, 2016, Carraway produced child pornography.

This Criminal Complaint is based on these facts as described in the attached affidavit

if

Continued

on the attached

sheet.

SA Jaqueline Dougher,

Federal Bureau oflnvestigation

Printed /lame and title

Sworn to before me and signed in my presence.

Date:

_~~~~i_~))
__
I

02/23/2016

Judge 's signature

City and state:

Greenbelt, Maryland

Charles B. Day, United States Magistrate Judge

Printed name and title

Case 8:16-mj-00449-CBD Document 1-1 Filed 02/23/16 Page 1 of 8

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D1STRIL

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IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MARYLAND
UNITED STATES OF AMERICA

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*

*
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*

v.

DEONTE CARRA WA Y,

*
*

*
*

Defendant

AFFIDAVIT

IN SUPPORT

OF A CRIMINAL

COMPLAINT

I, Jacqueline Dougher, a Special Agent (SA) with the Federal Bureau of Investigation
(';FBI"), Baltimore Division, Baltimore, Maryland, being duly sworn, depose and state as
follows:
1.

This Affidavit is submitted in support of a Criminal Complaint charging

DEONTE

CARRA WAY (';CARRA WAY") with eight counts of Production of Child

Pornography, in violation of Title I 8, United States Code, Section 225 I.

2.

Based on the facts contained in this Affidavit, there is probable cause to

believe that CARRA WAY employed, used, persuaded, induced, enticed and coerced
multiple children between the ages of nine (9) and eleven (1 I) years old to engage in
sexually explicit conduct for the purpose of producing visual depictions of that conduct
on at least eight separate occasions between October I I, 2015 and January 8, 2016. The
facts supporting each count of Production of Child Pornography are detailed below in
paragraphs 9a - 911.

"

Case 8:16-mj-00449-CBD Document 1-1 Filed 02/23/16 Page 2 of 8

BACKGROUND OF AFFIANT
3.

I have been a Special Agent with the FBI since October 14, 1997. I am

currently investigating federal violations concerning child pornography and the sexual
exploitation of children.

I have gained experience through training in seminars, classes,

and daily work related to conducting these types of investigations.

Specifically, I have

obtained and provided FBI Crimes Against Children Online Undercover training.

I have

also participated in the execution of numerous search warrants, of which many have
involved child exploitation and/or child pornography offenses and included the search
and seizure of computers,

computer equipment,

software, and electronically

stored

information. As a federal agent, I am authorized to investigate violations of laws of the

United States and to execute warrants issued under the authority of the United States.
STATEMENT OF PROBABLE CAUSE
4.

On February 4, 2016, at approximately 7:00 pm, Prince George's County

Police Department ('"PGPD") Officer Defreitas responded to a residence in Hyattsville,

Maryland for a complaint involving child pornography.

Upon arrival, PGPD Officer

Defreitas spoke with the complainant, who stated that his family member, a nine (9) yearold male (hereinafter "Victim I"), had electronically sent a picture of his naked buttocks
to CARRA WAY through the Kik messenger
CARRA WAY was a '"Dedicated Assistant"

application

("Kik").

At the time,

for Judge Sylvania Woods Elementary

School in Prince George's County (hereinafter .the Elementary School"), where Victim I
was enrolled as a student.

I Kik is a smartphone
messenger application C'app") available for most Apple, Android,
and Windows 7 devices. Kik messenger lets users send text, pictures, and videos within
the Kik app. Kik uses usernames rather than phone numbers to identify users.

Case 8:16-mj-00449-CBD Document 1-1 Filed 02/23/16 Page 3 of 8

5.

On Victim I's phone, investigators observed sexually suggestive messages

and a picture of Victim I's buttocks, which Victim I sent through Kik to CARRA WAY
on January 18,2016.

During an interview with law enforcement officers, Victim I stated

that, in December 2015, while Victim

1 was in class at the Elementary

School,

CARRA WAY provided Victim I with CARRA WAY's unique Kik user name so they

could communicate2

Victim 1 stated that CARRA WAY requested a picture of Victim

I's naked buttocks and Victim I complied.

Law enforcement

officers conducted a

forensic examination of Victim I's cellular phone. The examination revealed messages
sent between CARRA WAY and Victim 1, which were sexual in nature.
6.

On February 5, 2016, Prince George's

County police officers arrested

CARRA WAY and advised him of his constitutional rights.

CARRA WAY waived his

rights and voluntarily agreed to speak with PGPD Detectives.

CARRA WAY

provided a written statement.

During the interview,

The following is an excerpt of that

statement: "Okay, it's time I told the truth yes I have videos and yes you will find some
on my orange phone basically the same ones.

How I get the videos is the kids would

send them in the Chat[.] I would hide them but I really do care for the children.

I know

it was wrong, I'm a bad person, I'm no child of god for doing this, I know ['m grown. I
made a lot of mistakes .... [ only got the orange, white, and little tracfone [phones].

It's

true I directed one video[,] the rest of the videos the kids recorded their selfs ..... you will
find videos of the group .... the videos you see me in are the ones I already had saved in
my phone. No matter what the kids say, I have the videos of the group. Everything the
group did was recorded, either if its Play fighting, sexual, hide and seek, tag .... .1 take full

The unique Kik usemames for CARRA WAY and Victim I are known to your Affiant
but not included in this affidavit in order to protect the Victim's identity.

Case 8:16-mj-00449-CBD Document 1-1 Filed 02/23/16 Page 4 of 8

ownership for making A.K.A .... For some of the videos the kids used their tablets or cell
to send the videos to me and the one at the school was my phone. I know I'm older and I
knew it was wrong because kids don't know better and I just lost it and now it don't look
good on my part."
7.

CARRA W AV also voluntarily

consented

to a search of his white

Sam sung cellular telephone that he was in possession of at the time of his arrest. Officers
subsequently conducted a forensic examination of the cellular phone and the SO card.
The examination revealed approximately

23-26 videos of prepubescent and pubescent

children in sexually suggestive poses and engaged in sexual acts with each other.

For

example, ofticers recovered a video, recorded on or January 27, 2016, depicting an

eleven (I 1) year-old male (hereinafter "Victim 2") with his buttocks exposed toward the
camera.

During an interview with law enforccment,

Victim 2 stated that he was a

member of CARRA W AV's choir. Victim 2 further stated that CARRA W AV recruited
Victim 2 to be a part of the "AKA" club.

Victim 2 and CARRA W AV communicated

with each other through Kik. CARRA W AV sent Victim 2 a photo of his genitals and
Victim 2 sent CARRA W AV several photos of his naked buttocks and his genital area.
8.

On or about February 5, 2016, the parents of a ten (10) year-old male

(hereinafter "Victim 3"), discovered a blue, black, and white backpack in their residence
and indicated that the backpack belonged to CARRA W AV. During the interview with
CARRA WA V, officers showed him the backpack and he stated that the backpack and its
contents belonged to him. CARRA W AV then provided consent to search the backpack.
Investigators searched the backpack and recovered an orange colored "BLU" cellular

Case 8:16-mj-00449-CBD Document 1-1 Filed 02/23/16 Page 5 of 8

phone,

model

number

8700,

serial

number

LS 153250 1689

(hereinafter

"CARRA WA Y's cellular phone"), from the backpack.

9.

On Fcbruary 11, 2016, United States Magistrate Judge Charles B. Day

signed a search warrant authorizing officers to conduct a search of CARRA WAY's

cellular phone and other digital items.

Oflicers subsequently

conducted a forensic

analysis of CARRA WAY's cellular phone. The examination revealed approximately 38

videos depicting children engaged in sexually explicit conduct, including the following
videos that serve as the basis for Counts One through Eight of the accompanying
Criminal Complaint.
a.

Count One:

A video, recorded on or about October 11, 2015,

depicting CARRA WAY and Victim 3, both nude from the waist down, in Victim 3's
bedroom.

During the video, CARRA WAY is seated on a chair and Victim 3 is kneeling

down in front of CARRA WAY. Victim 3 then performs oral sex on CARRA WAY.
During an interview with law enforcement oflicers, Victim

I.

3 stated hc was part of the "AKA" club and CARRA WA Y recorded several videos of
Victim 3 engaged in sex acts with other children.
b.

Count Two:

A video, recorded on or about October 30, 2015,

depicting an eleven (11) year-old male (hereinafter "Victim 4"). and CARRA WAY, both
of whom were nude from the waist down, on a bed in Victim 4's bedroom.
video, Victim 4 is positioned

During the

on all-fours on the bed with his buttocks exposed.

CARRA WAY then begins to have anal sex with Victim 4.

I.

During a subsequent

interview

with law enforcement

officers, Victim 4 stated that he was in CARRA WAY's choir group.

CARRA WAY

Case 8:16-mj-00449-CBD Document 1-1 Filed 02/23/16 Page 6 of 8

directed Victim 4 to have anal sex with an eleven (II) year-old female (hereinalter
"Victim 5"), in Victim 4's residence and CARRA WA Y recorded the sex acts with his
phone. On another occasion, CARRA WAY attempted to have anal sex with Victim 4 in
Victim 4's residence.

CARRA WA Y also directed

Victim 4 to send pictures to

CARRA WAY using Kik.

c.

Count Three: A video, recorded on or about November 25, 20 IS,

depicting CARRA WAY and Victim 3 in Victim 3's bedroom.

During the video,

CARRA WAY engages in anal sex with Victim 3, while Victim 3 is on all-fours on his

bed.
d.

Count Four: A video, recorded on or about December 14, 20 IS,

depicting Victim 3, who is nude from the waist down, and an eleven (II) year-old male
(hereinalter "Victim 6") in Victim 3's bedroom. During the video, Victim 3 is seated on
a bed and Victim 6 attempts to perform oral sex on Victim 3.
e.

Count Five: A video, recorded on or about December 22, 2015,

depicting CARRA WAY and Victim 3, both of whom are nude from the waist d0\\11, in
Victim 3's bedroom.

During the video, Victim 3 has one leg on the 1100r and the other

leg draped over CARRA WAY's leg. Victim 3 appears to be fondling CARRA WAY's
erect penis.
f.

Count Six:

A video, recorded on or about December 22, 2015,

depicting Victim 3 and an eleven (11) year-old male (hereinalter "Victim 7"), partially
clothed on a bed.

During the video, Victim 3 fondles Victim 7's genitals and then

attempts to perform oral sex on Victim 7.

Case 8:16-mj-00449-CBD Document 1-1 Filed 02/23/16 Page 7 of 8

During an interview with law enforcement ot1icers, Victim

I.

7 stated that he was a member of CARRA \VA Y's choir and a part of the "AKA" club.
Victim 7 also stated that, on one occasion, CARRA WAY showed Victim 7 a video of
CARRA WAY engaged in anal sex with Victim 3.

g.

Count Seven:

A video, recorded on or about January 8, 2016,

depicting a nine (9) year-old male (hereinafter Victim 8), and Victim 5 in the basement of
a residence.

During the video, Victim 8 is nude from the waist down and Victim 5

performs oral sex on Victim 8.

During a subsequent

I.

interview

with law enforcement,

Victim 8 stated that CARRA WAY removed Victim 8 from class and brought Victim 8 to
a dressing room in the Elementary School. CARRA \VA Y directed Victim 8 to take his
pants off. When Victim 8 refused, CARRA \VA Y told Victim 8 that hc would contact
the police and the principal.

Victim

8 then complied

and removed

his pants.

CARRA WAY then directed Victim 3 to get on top of Victim 8 and Victim 3 put his

penis in Victim 8's buttocks. CARRA WA Y recorded the sex act with his phone.
h.

Count Eight:

A video, recorded on or about January 8, 2016,

depicting Victim 8 and Victim 5, both nude from the waist down, in the same basement.
During the video, Victim 5 is bent over at the waist with her buttocks exposed and Victim
8 appears to be having anal sex with Victim 5.
I.

During an interview with law enforcement, Victim 5 stated

that CARRA \VA Y performed anal sex on Victim 5 in Victim 4's basement.

Case 8:16-mj-00449-CBD Document 1-1 Filed 02/23/16 Page 8 of 8

CONCLUSION
10.

Based on the above described information, there is probable cause to

believe that CARRA WAY has produced child pornography on at least eight separate
occasions, in violation of 18 U.S.C.

9 2251.

I declare under penalty of perjury that the foregoing is true and correct to the
best of my knowledge and belief.

SWORN TO AND SUB CRIBED before me this 23rd day of February, 2016.

~7~/
Honorable Charles B. Day
United States Magistrate Judg