Case 1:11-mj-00452-TRJ Document 3

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IN THE UNITED STATES DISTRICT COURT FOR THE

..

JUN -9 2011

EASTERN DISTRICT OF VIRGINIA Alexandria Division

UNITED STATES OF AMERICA Criminal No.

COOPER KWEME

Uov|4^

I, Sean P. Clark, Special Agent (SA) with the Federal Bureau of Investigation (FBI),
being duly sworn, depose and state as follows: 1. I have been with the FBI since January 1996 and as a Special Agent with the FBI since 1999. I am currently assigned to the Crimes Against Children Squad CR-18, Criminal

Division of the Washington Field Office of the FBI. Prior to that, I worked in Washington, DC assigned to the FBI's Weapon of Mass Destruction Directorate as a Supervisory Special Agent.
Prior to FBI Headquarters, I was assigned to the FBI New York Field Office working CounterTerrorism Investigations. During my career, I have participated in numerous criminal

investigations, to include counter-terrorism, international parental kidnaping, child prostitution,

threats to the homeland, and have participated in the execution of numerous search and arrest
warrants.

2. This affidavit is submitted in support of a criminal complaint charging Cooper Kweme with transportation of a minor for prostitution in violation of 18 U.S.C. 2423(a), and
an arrest warrant for Cooper Kweme.

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3. The facts and information contained in this affidavit are based upon my personal

knowledge and the investigation and observations of other officers and agents involved in the
investigation. All observations referenced below that were not personally made by me were related to me by the persons who made such observations. This affidavit contains information

necessary to support probable cause for arrest. It is not intended to include each and every fact
and matter observed by me or known to the government.
4. On May 31, 2011, AK (a juvenile) and her mother spoke to members of the Arlington

County Police Department about AK's sexual involvement with a 24-year-old male from Maryland, who had recently subjected AK to perform sexual acts with men in exchange for money (prostitution).
5. AK advised she had met the Maryland male she referred to as Jason Pathers (known to

the FBI as Cooper Kweme, here-in-after referred to as Kweme) on the social networking site

"Tagged". AK could not recall the exact date that she and Kweme first began corresponding but
knew that it was sometime in January 2011. AK was on the website to chat with friends when

Kweme contacted AK. AK had a profile online on the website stating that she was a 16 year old

girl in Virginia. When AK first started to correspond with Kweme online, Kweme presented

himself as a girl and AK believed she was talking with another girl. The first message she
received from Kweme, he was complaining about his "boyfriend," as if he was a teenage girl.
AK and Kweme corresponded online for a few weeks before they became more familiar with

each other and exchanged telephone numbers. They began speaking via cellular telephone and
text messages and ceased using the website "Tagged" to communicate. The first time AK and

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Kweme spoke on the telephone AK was surprised to hear a man's voice because she believed she had been speaking with a girl. After they began speaking and texting via telephone, Kweme told AK that the profile he was using on "Tagged" was actually an undercover police profile the
police used to catch sexual predators.

6. AK's "Tagged" profile stated she was 16 years old at the time she first started communicating with Kweme. Kweme told AK on the telephone he was 24 years old and AK told Kweme on the telephone she was 16 years old. AK advised Kweme repeated back to AK
that she was 16 years old. After chatting online and talking on the telephone for a few weeks,
AK first met Kweme in person on February 14,2011.

7. On February 14,2011, Kweme called AK and told her he was at the Best Western Iwo
Jima on Arlington Boulevard and wanted to see her. AK walked over to the Best Western to

meet Kweme where they had sexual intercourse. When it was over, she left and walked home.
AK and Kweme had sexual intercourse a second time at Kweme's house somewhere in the Silver

Spring area of Maryland.

8. Shortly after they began having sex Kweme started taking pictures of AK. These pictures were explicit in nature showing her in her bra and panties, just her panties with her hands over her breasts, and without her panties showing her genitalia. AK said that Kweme took all the pictures himself; no one else took any photos of her. Kweme had a small silver camera.

Kweme told AK he wanted the photos for himself. Kweme took about five such photographs of
AK while they were in the Best Western hotel in Arlington.

9. AK advised she and Kweme would also frequent the Quality Inn in Silver Spring,

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Maryland, in the area of New Hampshire Avenue and University Boulevard. Kweme would come pick AK up in the parking lot of her apartment in Arlington and then drive her either to his
house in Silver Spring, Maryland or to the Quality Inn in Silver Spring, Maryland. AK believed
Kweme lived somewhere in the vicinity near the Quality Inn.
10. A few weeks after AK had sex with Kweme and he took photos of her, Kweme

suggested AK have sex with his friends. The first time this happened was in Maryland and AK
had sex with a man named Andre. Kweme picked AK up in the parking lot of her apartment

building in Arlington and Kweme drove AK to Maryland. When they arrived at Andre's
apartment building, Kweme directed AK to Andre's apartment and told AK that he (Kweme) would soon join her. AK went to the apartment and Andre let her in. AK did not know why she was there at first; Kweme never told her what she was supposed to do. Andre began to kiss her

and AK quickly understood why she was there. AK did not want to have sex with Andre but he
was a big guy and she did not feel that she could get away from him. Kweme never entered the apartment. After Andre and AK had sexual intercourse, Andre gave AK $250 in cash to give to
Kweme. AK went downstairs where Kweme met her. When AK provided the cash to Kweme,

Kweme gave her $125 of the $250.

11. After the first incident with Andre, AK had sexual intercourse with about seven other

men for money. Kweme prearranged each appointment in which AK had sexual intercourse for
money. One appointment occurred in Arlington County, Virginia. AK did not know the exact
address but she would be able to locate the address. Another appointment occurred in the

Tyson's Corner area of McLean, Virginia. The rest of the appointments occurred in Maryland,

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mostly in the Quality Inn hotel in Silver Spring. Usually, Kweme would travel to Arlington and
pick up AK and drive her to a location in Maryland or Virginia. Kweme would tell AK that they
were visiting one of his friends or clients. Kweme would tell AK to let the man put down the

money, then she could pick the money up and count it. Kweme would tell AK how much money to expect. Kweme would then pick up AK when it was over. AK would provide the cash to
Kweme and then he would give AK her half. Most often the price was $250, although one man paid $100.
12. AK advised she had sex with about eight different men on about ten separate

occasions. AK had sex with three different men on the same day at the Quality Inn in Silver
Spring. AK did not know the exact date, but advised she first started to have sex with these men at the beginning of April 2011. AK recalled only working for Kweme for about two to three
weeks.

13. Kweme told AK he was a police officer. AK did not know the jurisdiction Kweme

was an officer in but AK saw Kweme wearing a uniform. Kweme was wearing blue or black pants but no uniform shirt. Kweme wore an outer carrier style ballistic vest with a gold badge and on the back of the vest was "police". Kweme also wore a duty belt. AK advised Kweme
had both a gun and a taser which she had observed. When AK and Kweme met, Kweme would
leave the gun and uniform in the car but he would bring the taser into the hotel. On one instance,

Kweme drove AK to her apartment and they stopped by the Iwo Jima Memorial. AK and
Kweme got into an argument and AK wanted to leave the car but the car door was locked. AK

felt something and looked over at Kweme when she saw Kweme holding the taser against her

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arm. Kweme was sitting in the driver's seat and AK was in the passenger seat. AK told Kweme

if he pointed the taser at her, he had better be prepared to use it. Kweme told AK that he did not
want her to leave because he really loved her. Kweme did not use the taser against AK. 14. AK described Kweme as a black male 25 years of age, 6' 3" and about 280 pounds.

The cellular telephone number AK contacted Kweme on was 240-705-5946. AK believed that Kweme's birthday was the last day of March and he turned 25 this year.
15. On June 1, 2011, Cooper Kweme was arrested while driving his Honda CR-V vehicle bearing license plate number 17427M8 on a Virginia state warrant charging him with

taking a person into a bawdy place for sexual intercourse, and production of child pornography.
Kweme was interviewed after he was arrested, was read and signed his Miranda rights. Kweme's Honda CR-V vehicle bearing license plate number 17427M8 was seized at the time of his arrest. After Kweme waived his Miranda, he admitted to being the "manager" of girls for

prostitution and establishing an escort business to promote his girls for sex in exchange for

money. Kweme would transport the girls in his Honda CR-V vehicle to Maryland, Virginia, and the District of Columbia to provide sexual services to clients for money. Kweme administered,

as well as created an escort website, "theempireservice.com," that promoted his girls to his clients. Kweme admitted the website was for an escort business. Kweme would pay for the
hotel/motel rooms in cash or with his credit card for the girls to have sex with clients or customers. Kweme would also transport the girls to private residences to have sex with clients.

Kweme had two telephones, one was his personal telephone (cricket telephone 240-705-5946)
and one was for the escort business (prepaid cellular 240-330-9128). He would take photos of

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the girlsthat were working for him, post their photos but never showing their faces, write the
advertisements and post to internet sites, such as Backpage. Kweme would pay $7 per week to

Backpage in orderto have his girls advertisements stay at the top of the Backpage list. Kweme
would take photos of the girls and admitted taking nude photos of AK that he posted to Backpage. Kweme took these photos with a silver camera he advised he no longer has since
broken the camera and he tossed it in the trash. Kweme believes the photos of AK and other

girls may still be on his laptop that is in a black bag in his vehicle (aforementioned vehicle).
Kweme would use a USB cord to connect from the camera to his laptop to post the photos of the

girls online. Kweme's camera did not have an SD card. Kweme also stated that one of his two
mobile telephones is in his vehicle.

16. Kweme further explained that he would post the advertisements when the girl(s)
were available to work. Kweme would work one girl at a time since it was too difficult to work
more than one. The clients/customers would call the number listed on the advertisement which

was Kweme's business number (240-330-9128), a pre-paid telephone. Kweme would start
texting with the customers and drive to pick up the girl that was working that day. Kweme

would put the girl on the telephone to talk with the client/customer only when the girl was in
Kweme's vehicle and on the way to the job. Kweme would tell the clients the cost for one hour

of sexual intercourse with the girls was $250. Kweme would receive 40 percent of the money
and the girl would keep 60 percent. When the girl would go with the client in the room, Kweme

would provide the girl his personal cellular telephone (240-705-5946). He would call this
telephone number and the girl was to leave the telephone on in the answered state while she was

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with the client. Kweme would be able to hear everything going on, and he did this for the girl's

protection. If something went wrong, Kweme would be able to hear. Kweme has been

"managing" girls since October 2010, and he has had only one issue with a client that occurred
with one of his girls.

17. Kweme further stated that he learned how to manage and establish a prostitution
business through television shows and/or movies. Kweme admitted to purchasing the condoms for the girls at stores such as 7-eleven and would purchase the condoms in three packs. Kweme

taught the girls the rules of the game. The rules Kweme would tell the girls are: always wear a
condom, no kissing, no oral sex, and have the customer leave the money on the table. Kweme

believed if the client was a police officer and the girl did not touch the money, then she could not
be arrested or it was defensible.

18. Kweme admitted to having consensual sexual intercourse with AK, who Kweme said

he believed to be 19 years old. He met AK after matching with her on the website "Tagged". Kweme had sexual intercourse with AK 8 times, to include an Arlington hotel (known to investigators as Best Western, Arlington, Va), in his vehicle in a parking lot adjacent to AK's
apartment complex, as well as in the Quality Inn located in Takoma Park, MD. Kweme first met

AK in person on February 14, 2011 at the Best Western hotel in Arlington where they had consensual intercourse. Kweme videotaped using his Flip camera, having sex with AK once in his car in Arlington, Virginia, and having sex with AK once at the Quality Inn, Takoma,
Maryland. Kweme admitted the flip camera and laptop were located in his vehicle that he was
driving when arrested (Honda CR-V listed above).

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19. Kweme admitted to having a number of girls that worked prostitution for him. Some
of the girls he could not remember their names because they did not work long for him, perhaps

one day. Kweme would always be in the Wheaton Mall working as a security guard and
admitted he would walk around trying to recruit girls for his prostitution business. 20. Based on the information obtained through my investigation, I believe that probable cause exists for a criminal complaint charging Cooper Kweme with transportation of a minor for

prostitution in violation of 18 U.S.C. 2423(a). I respectfully request a warrant for his arrest.

Sean P. Clark

Special Agent Federal Bureau of Investigation

is Sworn and subscribed to before me this

' '

day of June, 2011

/s/Thomas Rawles Jones, Jr.

The Honorable Thomas Rawles Jones, Jr.

United States Magistrate Judge