UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK ‘UNITED STATES OF AMERICA against IN SUPPORT OF ARREST WARRANTS JEFFREY HURANT, also known as “Jeffrey Davids,” M.No, MICHAEL SEAN BELMAN, 9 ‘also known as “Sean Van Sant” 1.18, Us.c,,§37) CLINT CALERO, EDWARD LORENZ ESTANOL, also known as “Ei Lewis,” SHANE LUKAS, also known as “Hawk Kinkaid,” DIANA MILAGROS MATTOS, also known as “Coo0 Lopez,” and MARCO SOTO DECKER, Defendants. ee ie x EASTERN DISTRICT OF NEW YORK, SS: ‘Susan Ruiz, being duly sworn, deposes and states that she i @ Special Agent with the Department of Homelaed Security, Homeland Security Investigations (“HSI”), duly appointed according to lawand acting as such. (On or about and between January 1997 and August 2015, within the Eastern District of New York and esewhere the defendants JEFFREY HURANT, MICHAEL SEAN BELMAN, also known as “Sean Van Sant,” CLINT CALERO, EDWARD LORENZ ESTANOL, also known a “Eli Lewis," SHANE LUKAS, also known as “Hawk Kinkaid,” DIANA MILAGROS MATTOS, also known as “Coco Lopez,” and MARCO SOTO DECKER (collectively, the “Defendants” conspired to use facilities in interstate commerce with the intentto promote, manage, establih, cary on and faiitate the promotion, management, establishment, and carrying on of an unlawul activity, namely an enterprise involving the prostitution in violation ofthe laws ofthe State of New York that criminalize various ets of prostitution and the promotion of prostittnn, and thereafter commited or attempted tn commit an act “otherwise promote, manage establish, cary on and facilitate the promotion, management, ‘sablishment, and cerryingon of such unlawful activity in violation of Tile 18, United States Cove, setions 195293) and (0.1. (itl 18, Urited tates Code, Section 371). ‘The source cf your deponent’s information andthe grounds for her belief are as follows: 1, Lama Special Agent with the Department of Homeland Security, Homeland Security Investigations (“HSI’). Ihave been employed by HSI as a Special Agent since 2010, During my employment with HSI, I have participated in numerous investigations involving crimes related t violations of immigration laws. Among other things, [have ‘conducted or participated ia physical surveillance and consensual recordings. Ihave deployed confidential informants, eccuted search warrants, and analyzed immigration files, passports, and various petitions and applications submitted by individuals seeking immigration benefits. Tam ‘currently assigned tothe Special Investigations Unit, which handles investigations ona variety of ‘matters including illegal posttution, 2. Thave personally participated in the investigation of the offenses discussed below. Iam familar with ihe facts and circumstances ofthis investigation from: (a) my personal * Because this complaint is submitted forthe limited purpose of establishing probable ‘cause, Ihave not set forth each and every fact leamed during the course of the investigation,participation inthis investigation and (b) reports made to me by other law enforcement authorities. 1. RENTBOY.COM 3. RENTROV.COM ies commersal male escort advertising site that promotes prostitution, RENTBOY.COM was founded in 1997 and advertises itself tobe the “orginal and largest male escort service online” Escorts pay fes to advertise sexual serves on te site, Customers may then contact the escorts directly to arrange meeting. 4. RENTBOY.COM advertises that they receive approximately $00,000 ‘uigue visitors each day, stout 70 percent of whom acess the ste fom the United States. There are several thousand advertsements on RENTBOY.COM, Between 2010 and 2015, RENTBOY.COM had overS10 milion in gross proceeds. 5, JEFFREY HURANT isthe chief executive officer of RENTBOY.COM nd he remaining Defendants ae employees whose actives promote RENTBOY.COM and further illegal prostitution. A. RENTBOY.COM WEBSITE 6. While RENTBOY.COM has disclaimers hat the advertisements on the site are for companionship any and not for sexual serves, RENTBOY. COM is designed rimarity forthe advertisement of sexual services: the advertisements on RENTBOY.COM are clearly for sexual services; and RENTBOY.COM’s owner and employees have made statements that the site's purpose is for facilitating illegal prostitution,7, RENTBOY.COM takes its name from a Britsh slang term fora male prostitute, (The Merriam-Webster Dictionary definition for rent boy is “a usually young male prostitute") R —_RENTROY.COM’s slogan is “Money can't buy you love ... but the rest is negotiable.” 9, RENTBOY.COM’s primary business is conducted through its website at ‘wonw.rentboy.com, When ¢ user navigates to the website wwwrentboy.com, they are asked to accept a set of Terms of Sewvice, The terms of service state that “This site may not be wsed for the advertising of sexual sevees orto engage in activities requiring the payment of money for sex or other illegal activities” However, asset forth below, the entire website is designed forthe ‘purpose of advertising prosituion. 10. _Afterauserhas accepted the terms of service, they arrive a the RENTBOY.COM homepage. The homepage features advertisements for featured escorts including new escorts and escorts who have recently updated their advertisements. ‘There is also a navigation button that allows a user search for escorts. A user may search by a number of ‘parameters including geographic location, A search displays short advertisements for prostitutes ‘that meet the user's parameters in the form of escort truncated profiles 11, A.user can then click on a particular esvor’s truncated profile to see their full profile, As detailed futher below, escort profile pages generally detail the sexual acts each escort i willing to perform and the price. They often also contain nude pictures and indications relating to their penis size. In addition, profile pages sometimes have link toa separate website 2 RENTBOY.COM primarly refers to the prostitutes advertising on the site as “escort.”called DADDYSREVIEWSCOM that contains explicit reviews of the escorts writen by previous customers, 12, RENTBOY.COM makes money through payments from escorts for advertisements on the site sad toa smaller degree hy offering advertising for products RENTBOY.COM offers four different advertisement levels to escorts: classic, gold platinum, and diamond, The more exxensive advertisement levels move the placement ofthe escon’s profile up in searches. The price for advertisements depends on the type of advertisement and the escont’s location, Advertisements can range in price from $59.95 for a one month Classic advertisement to $299.95 fra one month Platinum advertisement. Diamond advertisement prices are based on an auction system and ean cost significantly more than other types of| advertisements, In addition, escorts can bid fora “powerboost” that will move their ad to the top of the searches for a predetermined time. 13, An escort manages their advertisements by logging into the RENTBOY.COM site through a special account page solely for escorts, When an escort sets up an advertisement with RENTBOY.COM, the top ofthe page stites: “Make a profile field calls ‘and emails, count your money.” The escort can enter a small amount oftext. In addition, there are several eategories pre qrogrammed into the advertisement by RENTBOY. COM that the scot is asked to selet opfons for. Inthe “Physical Atibuos” category, the escorts are asked to select answers forthe atebutes:“Foreskin,” “Cock Siz,” and “Build.” The eseorts are asked to provide in the “Prefernses” category their“Seual Orientation," “Safe Sex," and “Sexual Position.”M4. ‘The escort profile page also has a pre-defined list of “Primary Interests” that an escort can check offto denote sexual act that they are willing to perform. In addition, if the mouse cusor is placed cver the ttle ofan interest a description appears. The RENTDOY.COM cscoet profile pags lists the following “Primary Interest” and deceriptions. Vanilla ‘Straight and tidy, clean and “nie” sex, with as litle foreplay 2s possible, The opposite of kinky, notin any way involved with B/D orSM, Pleasuring another person with one’s mouth, especially ‘cocksucking ora “blowjob’ Leather: Dressing up in leather fetish gear, possibly involving bondage, SEM: iscpline oc SIM roleplay. ‘Sexual gratification inthe infliction of pain or suffering upon or by another person. Shaving: A fetish for smooth skin. Shaving pubic hai, chest, or armpits ean create new, exciting, sometimes prickly sensations. ‘Watersports: Sexval activity in which urine (pee) is involved. Taking the piss Seat: cut of your lover. ‘Sex play involving shit. A rare teat forthe connoisseur only, unless there is a sudden and involuntary “mudslide.” Kissing: Old-fashioned lips together, “making out,” or sucking face Anal: Activity involving the anus, asshole, or but play. Sneakers: Enjoys athletic shoes and especially and feet of an athlete. pep: ondage and Discipline involving handeus, rope, ete. “Whip me, ‘beat me, make me write bad checks!” Spanking: Slapping onthe buttocks with a bare hand, paddle, or belt. “He ave the brat a good spanking.” Diapers: A fetish practice where an adult role plays at being an infantRole Playing: Imitating a fantasy character, like a policeman, priest, football coach, oF cheerleader. A great way to lt loose and step outside your normal self, Toys: Dildos, vibrators, cockrings,clothespins, or other objects used for sex or role-play, Please, don’t try light bulbs! Feet: Admization and stration to a person's bare fet, inspiring worship, and care ‘To place much of the hand, or the entre hand, into the bunghole. ‘Maybe even up tothe elbow. Latex: Erotic play wearing rubber costumes, ger, o toys. “Wanna go souba diving?” PNP: Party and Play means using drugs with sex. Beware addictive substances, por judgment, and hangovers! 15, The profile page also has required feds forthe “Escort In Rate.” “Eseot’s Out Rate,” “Escot’s Overnight Rat,” and “Eseons Weekend Rate The aes are generally listed in amount of United States Dollars per hour. Based on my taining and experienc, Iam aware dati a prosttton business, the term “Escorts In Rate” refers to the mount that a customer must pay to engage ina sexual act wih a prostitute at a loeation controle bythe prostitute (such as the prostates apartment or hotel room). The tem “Bscont’s Out Rate refersto the amount tata customer must pay to engage in asexual at with a prostitute at a location controlled bythe customer (such asthe customer's apartment or hotel room). The tem “Escon’s Overnight Rate” refers tothe amount tht a customer must py to have the prostate spend tk entire night with the customer and engage in sexual act. 16, When Searching for an escort, user can iter by a numberof extegories, including penis size, whether the penis has foreskin or not, Sexual postion, whether the escort only performs sex with a condom and the “Primary Interests” deseribed above.17, RENTROY.COM includes a disclaimer about what content may be included in advertisements. Nexto the advertisement text ox sa dscaimer that says ““Guideines for ext in your listing: Text cannot nce the following: Offers of sexual conduct in exchange for money; Explicit sexual conduct expected at part of you ine; Offers of references to illegal drugs, illegal drug paraphernalia, or illegal use of drugs and Slanderous, Violent, or unprofessional txt.” The disclaimer indicates hat “Al new uploads and listing conten as well as any changes made to your listing, must be approved by our customer sevice team.” The disclaimer fre states that “Any violations of text approval guidelines risk permanent removal fom the sit.” 18, Inpromotional materials, RENTBOY.COM states that “RENTBOY.COM’s behind -the-scenes team includes customer service reps, telemarketing and sales staff, marketing and cient managers, accountants, graphic designers and computer programmers The stars of RENTBOY.COM are the rentboys themselves. As with any successful business, quality contol is key. Site administrators screen each escorts photo, phone ‘number, and credit ard nuner to confirm validity. They also encourage liens topos eviews ofthe reaboys on thee sister site, RENTBOYREVIEWS.COM” B. — RENTBOYPROFILES 19, Profiles on RENTBOY.COM are clearly advertising payment in ‘connection with sexual erices. Ata given ime thre are hundreds of advertisements for scot in New York Cty en RENTBOY.COM and thousands across the United States. Thase advertisements regularly refer to sexual acts, sexual paraphernalia, and penis size in both theirtext portions and in the portons required by RENTBOY.COM. For example, in July 2015, he following profiles appearedon RENTBOY.COM: 20, A pile for “Brandon,” averising serves in Brooklyn, New York tse that eis “airy handsome versatile uninhibitd.” The profile noted that he was willing to have Brooklyn incalls ni had “sling and rimehain.” Based on my investigation, have Jeamed that a ling ls known asa “sex ling,” a device that allows two people to have sex while one i suspended anda imehair is a sat resembling raised olet seat designed so that that anus is accessible whl someone is siting onthe seat, Ihave also learned tat “imming™ refers to the touching of the tongue tothe anus. Brandon’s profile also identified that his “eock size” is “large” and that hisforeskin’ is “cut In ation, Brandon's profile on RENTBOY.COM included link to DADDYSREVIEWS.COM. DADDYSREVIEWS.COM is a website hat features reviews of prostitutes by their ustomers. The lik on Brandon’s profile takes a wer to 10 eviews of Brandon's sexual performance. The reviews indicate the sexual ets that Brandon engaged 'n with each reviewer and the price that each customer paid for one hou wih Brandon. 21. Apne for “Kit Hammond” advertising services in Brooklyn, New York stated “ome and meet me or my hot body and hard cock and make a fiend too while you are at it” The advertisement indeated that he was 6'L 16SThs Bin cut cock with cool feet” The xvertisement sted his “inrate," “out rate,” and weekend rate as $150 an how. 22. Appi for “Master Lebeau” advertising services in Brooklyn, New ‘York stated “10 iesisbleinches/ long & strong” and that he was available for “ole play, ‘watersport sessions” and “domination.” The advertisement also identified that his “cock size” is10 “extra large” and foreskin" is “cut” and indicated that his “sexual position” is “top.” The advert et lise his “ou rate” as $230, his overnight rate as $1500 and his weekend rateas $3500, 22. A prfile for “Ryan Roe” advertizing servos in Manhatan, New York stated: “havea very innocent shy mid-west ook, but one you get me behind closed doors it's am amazing experience... lve botoming but am aso very versatile. thee area number of reviews forme out there soif you wish to ind them Iam certain you wil be happy wid the resis.” The advertsemen: lis his “ock size” as “average” and his “foreskin” as “et” Italso lists his“ rat” and “out rte” as $300, Aa interview with “Ryan Raz” was also featured by RENTBOY.COM. The interview is branded as a “RentboyTalk” and starts with the logo for RENTBOY.COM. Inthe interview, “Ryan Raa” says that the first ime that he escorted someone sid to ims “have you ever thought about making some extra cash Raz explained that he was going to receive $250 and thatthe man “was not someone he would normally... meet” bt after doing ithe found tat it was “so cay.” Raz also sid regarding esconing that “you eve to be able totum something off up here [pointing to his head] in order to really please someone and enjoy what you're doing” 24, Api for “Dilla” advertising services in Manhattan, New York stated that hes an adult film performer and sid “excellent messages, body, hung well and filly functional, rte, sensual, nd very sexual. am a business tat provided unlimited pleasure.” ‘The sdvertisement noted ht his “cock sie” was “extra large” and his “foreskin” was “cut.” It also included his “sexual pssition” as “top” and listed numerous “primary interests,” as describedu above, ‘The advertisement sated that his “in rate” was $250 an hour, his “out rat was $300 and hour, his overnight rate wasS1,000 and up and his weekend rate was $2500 and up. 25, April for “Rick,” advenising services in Manhattan, New York tated that he was “an all Ameren bay next door who loves to have good Sime.” Hsaid “My sats sre 62,160, bubble but, vel hung thick and completely versatile.” The advertisement noted his “cock size” a5 “arg” and his “foreskin” as “cu.” It sso included alist ofthe “Primary Interests” he had, 8 deseried above, Inston, the advertisement provided his “in ate” and out rat” as $200 and his cvemight rte as $1000, The adverisement ls stated “Here's a ink to my reviews” and consid a link to a DADDYSREVIEWS.COM pape containing 10 reviews of Rick, The reviews ident fed numerous sexual acts that Rick performed with customers. The ‘most recent reviews also sted the rates thatthe customers pid, which were consistent with he rates listed on Rick's RENTBOY.COM profil 26, Ape for “Killian James," advertising services in Houston, Texas stated “I'm a vanilla bottom anda sensual or dominant tp.” Tse his cock ize” as Large” and his “reskin” as “out” Ials sid: “come highly recommended, Take some time to read ‘my reviews and included Tink to a page at DADDYSREVIEWS.COM that contained 24 reviews, The reviews note explicitly the sexual acts performed by James during each meeting with a customer. C. HOOKIES 27. Asapromotional tol, RENTBOY.COM holds yearly awards show for the “Intemational Escort Awards,” which refers to asthe Hookies. On March20, 2015, RENTBOY.COM hosted the 9th Annual Hokies atthe XL Outnye hotel located at 516 Westn 42nd St, New York, New York, They advertised the show as “esognizing 17 categories of covering all aspects ofthe ces profession as presente in the newest media” Jam aware that prostitution is often referred to as “the oles profession.” 28, During the course ofthe show, escort who advertise on RENTBOY.COM, received awards in variety of categories. Those categories inched “best tink,” “best tp.” “best bottom,” and “best cosk.” Iam aware thatthe term “twink” isa slang term fora young, say man with an effeminate manner, thin build, and no ody or facil hat. Tam aware that “bottom isa slang tem fora sexually submissive partner. Tam aware hat Yop” isa slang term fora sexlly dominant parner. 29, The nominees and winners ofthe awards were escorts who advertised on RENTBOY.COM. D. RENTBOY.COM OWNERSHIP 30, RENTROY.COM is controlled by EASY RENT SYSTEMS, INC, which docs business as RENTBOY.COM. EASY RENT SYSTEMS, INC, which s sometimes also refered to as EZ RENT SYSTEMS, is a New York corporation whose President and Chief Executive Office is JEFFREY HURANT, HURANT hs been the chief executive officer since its incorporation, EASY RENT SYSTEMS, INC. has offices at 6 West 14th Sues, Suite 4W, ‘New York, New York, The mailbox for that address has the name “Easy Rent System followed bythe names “J. Hurant” aod “Sean Van Sant.” As set forth below, Sean Belman also known as “Sean Van San."is the dtztor of RENTBOY COM. 31. The domain name RENTBOY.COM was registered on January 18,1996 Public records indicate thatthe registrant name is Fasyrent Systems located at 6 West 14thB Sweet, The Administrator Name i identified as Jeffey Davids at Easy Rent Systems, Ine, with te emul address jef@rentoy com. 32, On Aptl 2,002, EASY RENT SYSTEMS, INC. applied to the United Sttee Patent and ‘Trademark Office for trademack: onthe masie RENTROY.COM, The application also includes an affidavit signed by HURANT, which identifies him a the President of EASY RENT SYSTEMS, INC. The RENTBOY.COM website has a copyright notice that the copyright is owned by EASY RENT SYSTEMS, INC. 33. RENTBOY.COM allows payment for advertisements in cash at is office, money onde, and credit earl. However, RENTBOY.COM doesnot have an internet ret cand processing system, Rather to pay by credit card an escort mus fill outa “Credit Cand Authorization Form" and snd it by fax or email to RENTBOY.COM. The “Credit Card Authorization Form,” is provided on the RENTBOY.COM site has the name EASY RENT SYSTEMS, INC. athe top and sate I, [blank], authorize Easy Rent Systems, Inc. to charge my credit at listed below forthe following services” 34, BRAVE NEW TELEMEDIA, INC. is @ New York corpraton. LHURANT is the Principal Executive Officer of BRAVE NEW TELEMEDIA, INC. On @ ‘monthly basis, BRAVE NEW TELEMEDIA received payments from EASY RENT SYSTEMS, INC. and then makes payments to an intel service provider located in Viena tat provides, services lating tothe RENTBOY.COM domain, The internet service provider's records identify HURANT as the Pimary Technical Officer at BRAVE NEW TELEMEDIA,“4 , JEFFREY HURANT, RENTBOY CEO 35, JEFFREY HURANT isthe President and Chief Executive Officer of RENTBOY.COM. HURANT has frequeatly given interviews about RENTROY.COM. 36, 1n22010 videotaped intereiew HURANT identified hime “efiey Davids, the founder and president of RENTBOY.COM.” Ina 2008 videotaped interview, HURANT was ideniied as “Tefiey David, the owner of RENTBOY.COM.” HURANT stated that be stated he site because he Fl that “escorts were a disenfranchised group” and that there ‘wore “alot of hookup sites alt of sex sites, but for escorts nothing.” He sad that he went to Oxford University and leamed that “Tenby” was “the word for escorts.” 37. HURANT has also told reporters that “Rentboy was designed from the stato showease the working boys of the world and to help you find someone to spend your evening with and then to say goodbye" and that “We jst want to keep the oldest profession in the world upto date with all the latest technology.” 38, HURANT was present tthe 2015 HOOKIES, where he provided an undercover agent ard wih the RENTBOY.COM name on onesie. nthe opposite side the card says “leftey Davids, xincipal” Italo lists his email address as “cyberpimp(@rentboy.com:” HURANT was asked by the undercover agent how the Hookies awards stated, HURANT responded “Have you ever hd sex with anyone and it was 0 good, you had ttell someone? ‘That's what it's al about!” 39. HURANT as also made statements about his attempts to skirt laws that robibit he promotion of rotation. Tn one intervie, he stated “Theres no place on this ‘website where somebody says I'll have sex for money because that is against the law. We can1s tak about what you lok ie, what you are, what yu like to do, what people say abou you in bed... Poople say 'm a great top, people say I fuck like nobody's business, but you cant say Ti fuck you fortwo hunded bucks.” F. OTHER RENTEOY.COM EMPLOYEES 40. RENTBOY.COM employed over a dozen people during the time ofits operation. There is probable eause to believe ha anyone employed by the organization was aware th sim was the promotion of prostitution, based on its publicly disseminated ‘advertising and promotional material andthe content of the site itself. The remaining defendants are or were RENTBOY.COM employees, whose involvement with the website is set forth in deuail below. MICHAEL SEAN BELMAN, also known as “Sean Van Sant” 41, From at least April 2010, BELMAN has heen employed by Easy Rent Systems. He is currently ientified in RENTBOY.COM promotional material asthe Marketing Director of RENTBOY.COM, In interviews, BELMAN is sometimes deseribed asthe “U.S. head of Rentboy.com.” His name is listed onthe mailbox for RENTBOY.COM headquarters in Manhattan, 42, BELMAN has given numerous interviews in which he made clear that he ‘was aware that RENTBOY.COM promoted prostitution, In one interview, BELMAN stated that “Rentboy.com does more than any other website to promote a sunny, sex-positve attitude toward escorting” and that “Escorts are not just sex objects; they are real people performing @ valuable service.” In an imerview relating to the HOOKIES, BELMAN referred to the prize 3 BELMAN is currently using the name “Sean Van Sant” Thave compared pictures from. [BELMAN’s driver's license to pictures of “Sean Van Sant” from RENTBOY.COM’s promotional materials and Setermined that they are the same person.16 _winners—ho advertise on RENTBOY.COM—as “sexual therapists." BELMAN was present at the 2015 HOOKIES. 43. BELMAN as also acknowledged RENTBOY.COM’s attempts to shield {self Bom the illegal condi t promotes. Th an iterview, BEEMAN incorety stated that RENTROY.COM was legal because: “We say that escort are selling thee ime only... What ‘happens between you and th escort upto you, That's the way its considered legal.” CLINTCALERO 44, CALZRO is a Senior Sales Agent st RENTBOY.COM. In a government filing, RENTBOY.COM described his job asthe creation, implementation and management of campaigns to increase andor reverse ation and help build healthy relaonships with our customers. CALERO’s jo duties include answering phone calls related to customer issues and ‘zaveling fo worldwide RENTBOY.COM evens 45. CALERO also sends emul to sans who adverse on RENTBOY.COM con behalf of RENTROY.COM. The emails adverts sales for escorts whose ads ave lapsed on RENTROY.COM, opportnties to work at RENTBOY.COM events in exchange for ice ads, and sales for advertisements on another ste operated by EASY RENT SYSTEMS, INC. CCALERO’s emails end wit Stove Matin quotation: “Tbeliove that sexs one ofthe most ‘beautiful, natural, and wholesome things that money ean buy.”7 EDWARD. wn as “El 46, LORENZESTANOL is an escort who worked at RENTBOY.COM as a Sovial Media Coordinator until approximately May 2014. 47, As of July 2015, LORENZ ESTANOL had an active advertisement on RENTBOY.COM. The ad included a subtitle that sad: “This boy isa bottom.” The advertisement included his “sexual position” as “bottom,” “cock size” as “average” and his “foreskin” as “uncut” In alton, his “primary interests” were listed as “Vanilla, kissing, oral, anal, lather, and shaving.” The advertisement listed his in rate and out rate as $300 an hour, his ‘overnight rate as $1400 and his weekend rate as $3000. The edvertsement also included a link to DADDYSREVIEWS.COM, 48 The DADDYSREVIEWS.COM page linked to the advertisement included five reviews by customers who had hired LORENZ ESTANOL to have sex with them. ‘The reviews included the price pid by the customer and the sexual acts thatthe customers had engaged in with LORENZ ESTANOL. 49, LORENZ ESTANOL maintains a personal website, “DEEP INSIDE ELI” at wow EliLewisOnline.com, which can be accessed by clicking on a link on his RENTBOY.COM ad. In an April 2013 post on that site, LORENZ. ESTANOL explained that escorting isa great way to explore your sexuality and get paid doing it. LORENZ ESTANOL refered to RENTBOY.COM as the “leading social networking website for escorts and masseurs. ‘The site receives alot of heavy trafic from allover the world and is the most well-known, platform from which potential clients can hite ther fantasy by the hour”. ESTANOL also * LORENZ ESTANOL used the name “Eli Lewis" in connection with his prostitution. Thave compared pictures from LCRENZ ESTANOL's diver’ license to picture from “Eli Lewis" ‘promotional material and isterviews and determined that they are the same person,8 reffered to DADDY'S REVIEWS as the “Yelp of Escortng”. ESTANOL was nominate forthe 2015 HOOKIES award for “Best Royfriend Fantasy” and “Best Website.” SHANE LUKAS, also 4 kai 50. LUKAS is presently the Chief Operating Officer at RENTBOY.COM and EASY RENT SYSTEMS, INC, positions he took over in April 2014.5 LUKAS is also the founder of Hook Online, a 2on-profit online resouree for men in the sex trade, LUKAS has said ‘that he intially became involved with RENTBOY.COM alter reaching out to RENTBOY.COM ‘with respect to his work for Hook Online, 51, LUKAS has stated in interviews that he was formerly a prostitute LUKAS has said in interviews that he became involved in prostitution when he needed suldtional money to suppoit himself during an internship. 52. Whi LUKAS says that “time is what a Rentboy sell,” he routinely refers to RENTBOY.COM and esconts as part of the “Sex industry.” LUKAS says that the business “is about smart sex selling.” LUKAS has also done interviews with RENTBOY.COM escorts in ‘which the escorts discuss the fact that they have sex with their clients. In another interview, LUKAS talked about the importance of escort reviews inthe escort industry and specifically ‘mentions DADDYSREVIEWS.COM as one such site. LUKAS said in the interview that the nature ofthe client reviewsaffeets the amount of money that an esvort can charge. 5 LUKAS is curently using the name “Hawk Kinkaid” In one interview, LUKAS identified that the name “Hawk Kinkaid" was an alias. Ihave compared photographs from LUKAS” driver’s license to images of “Hav Kinkaid” in RENTBOY.COM promotional materials and in ‘videotaped interviews and Jetermined that they are the same person.» DIANA MILAGROS MATTOS, so known “Coco Lops’ 53. MILAGROS MATTOS was Sales Account Managerat EASY RENT ‘SYSTEMS, INC. from September 2009 to June 2015.° She was the highest commissioned sales gent eter in ale for five years in aro, She lio mentored ad ined ae sles ages 34, During her ine at RENTROY.COM, MILAGROS MATTOS mainsined twtr cout in which ste identified hela the “stort whisperer” She offered help escorts boost tr soil msdn profil, ott they increased the smount of basnes they revtved, MILAGROS MATTOS relat posed meses on hero count lating RENTBOY.COM eon none message she sed “Wanna write glowing review fran escort rethoy? Vist DayaReviews com! Respste, legit it for male fescoreviews! Greatboy”” MILAGROS MATTOS also posted on forums st DADDYSREVIEWS.COM wing the mame “Caco Lope” MaRco soTopECK. 55. SOTO DECKER isan accountant who handled EASY RENT SYSTEMS, INC books and rsords fom 202 unl he resent 55, in Sepember 2010 and Mach 2013, ASY RENT SYSTEMS, INC. applied othe United Sates Dearent of Homeland Seer, iizenship and Immigration Services for an H-1B non-inmigrant work visa on behalf of SOTO DECKER.” The application identi tat BASY RENT SYSTEMS, INC us RENTBOY.COM which “evoisionie3 the “ MILAGROS MATTOS also uses the name “Coco Lopez.” I have compared driver's license poograps of MILAGROS MATTOS to pstresofCoco Lopes” and dtemined hat they pe 2010 action was snd by Jefe Haran for EASY RENT SYSTEMS, INC. The 2013 application was signed by Michael Sean Belman, who was identified asthe EASY RENT. SYSTEMS, INC marketing director.escorting industry by moving it online and away ftom agencies and disreputable bars” The pplication also said that SOTO DECKER had been operating as the accountant rom July 2012, «positon that reported direly to JEFFREY HURANT and which required hm to prepare all financial statement and to ersogialy analyze, manipulate, and interpret nancial data “in ender to develop strategies ind make recommendation etal forthe CEO to ulize i his work to successfilly manage and grow the company.” 57. In conection with he application, EASY RENT SYSTEMS, INC. also submited a jb offer leter addressed to SOTO DECKER dated July 20,2012, which identified the duties and responsibilities ofhis position. Among those duties was meeting with marketing, 1, sales, and customer service staf 0 review monthly expenses and se revenue and expenses optimization; supervising te company’s daily e-commerce tansaetons; managing the entre accountng, budgeting and econiition process forthe company's evens inluding the HOOKIES. 58. The application also ineluded some of EASY RENT SYSTEMS, INC.'s ‘books and reconds, Among the expenses identified was a listing for ya Sean” Tn adkition, the aplication included numerous articles about RENTBOY.COM. Many of those antics identified wnambignousl tha the escorts advertising on RENTBOY.COM were having sex with thee customers inexchange for money. 59, SOTO DECKER was one ofthe pins of contacts for Cogent Communications. In some communications with Cogent, SOTO DECKER described himself as HURANT s assistant,a 60, SOTO DECKER was alsoa signatory on one bank account asocated ‘with EASY RENT SYSTEMS, INC’ event business. The only ote signatories on accounts related to EASY RENT SYSTEMS, INC. were HURANT and HURANT's mother. II NEWYORK STATELAW 61, NewYork State has a number of laws erimializingprosttton and the promotion of prostiuion, Specifically, New York Penal Laws Section 230.25 provides that “A person is guilty of promoting prostitution in the third degree when he knowingly’... vances or rofis fom prostitution by managing, supervising, controlling or owning, ether alone orn association with others. prostitution busines or enterprise involving prostitution atvity by ‘wo or more prostitutes.” New York Penal Law Section 230.20 provides that “A person is guilty of promoting prostnson ir the fourth degree when he or she knowingly’. advanees or profits from prostitution.” New York Penal Law Section 230.00 provides that “A person i uty of rotation when such person engages or agrees or fers to engage in sexual conduct with nother person in return fora fe.” WHEREFORE, your deponent espectflly requests tha he defendants JEFFREY HURANT, MICHAEL SEAN BELMAN, also known as “Sean Van Sant,” CLINT CALERO, EDWARD LORENZ ESTANOL, also known as “Ei Lewis” SHANE LUKAS, also novi as “Hawk Kinkaid DIANA MILAGROS MATTOS, also knows as “Coco Lopez.” MARCO SOTO DECKERbe dealt wth according to law. Your deponent also requests hat this affidavit and the associated arrest warrants be sealed until further onde ofthe Court. Ifthe2 defendants were aware that there were warrants for their arrest, they may fee or take measures to destroy evidence, ‘Susan Ruiz ~ 0 Y Special Agent United States Departmen of Homeland Security, Homeland Security Investigations Sworn to before me this 18th day of Augusts208§ 4 THE HONORABLE VIRTOR V. POHORELSKY UNI ITED STATES MAGISTRATE JUDGE EASTERN DISTRICT OF NEW YORK