Case 1:13-cr-00053-RP-RAW Document 2 Filed 11/25/13 Page 1 of 6 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF row A RECEIVED NOV 25 2013 CLERK OF DISTRICT COURT SOUTHERN DISTRICT OF IOWA UNITED STATES OF AMERICA, V. ADRIEN JAMAAL COLE, a/k/a Adrien Cole, Jamaal Cole, Jamaal Prince, Adrien Jamaal Prince, Defendant. Criminal No. 1: 13-cr-053 INDICTMENT T. 18, U.S.C., 1591(a(l T. 18, U.S.C., 1591(a(2 T. 18, U.S.C., 1591(b(2 T. 18, U.S.C., 1594(a THE GRAND JURY CHARGES: Introductory Allegations 1. As used in this Indictment, the terms "prostitute" and "prostitution" refer to a person engaging in sex acts for money or other things of value, that is, a commercial sex act. 2. As used in this Indictment, the term "sex act" includes "sex act" as defined in Title 18, United States Code, Sections 2246(2(A-(D, inclusive. 3. At all times material to this Indictment, www.backpage.com, craigs list, and similar web sites were internet web sites which engaged in interstate commerce, including the posting of "advertisements" or "solicitations", and which did business across the state-lines of various States of the United States of America, including among others, doing business between the Southern District of Iowa and the State of Nebraska. 4. As referred to in this Indictment, Omaha is a city located in the State and District of Nebraska; and Council Bluffs is a city located in the Southern District of Iowa and the State of : Iowa, which city is attendant to and a part of the Omaha Metropolitan Area. 5. At all times material to this Indictment, Defendant was approximately 24-25 years of
Case 1:13-cr-00053-RP-RAW Document 2 Filed 11/25/13 Page 2 of 6 age. 6. At all times material to this Indictment, M-1 was a minor female, approximately 14 years of age. 7. At all times material to this Indictment, M-2 was a minor female, approximately 16 years of age. 8. That from at least in and about the summer of 2012, and continuing to in and about February of 2013, the exact dates to the Grand Jury unknown, Defendant entered into a scheme, plan and pattern to recruit, entice, harbor, transport, provide, obtain, and maintain, by any means, a person or persons, including, but not limited to, persons under the age of 18 years, to engage in commercial sex acts, all or part of the financial benefit of which went to Defendant. 9. That as a part of said scheme, plan and pattern, Defendant found and contacted one or more persons on Facebook, an instrumentality of interstate commerce, including persons under 18 years of age; and by the use of Facebook and otherwise, including other internet-based media, Defendant recruited, enticed, obtained, maintained and provided said persons as prostitutes for Defendant, providing them as prostitutes to customers for commercial sex acts. 10. That as a part of said scheme, plan and pattern, Defendant took photographs and caused the taking of photographs of said persons, that is prostitutes, including persons under 18 years of age, which photographs Defendant "posted" on one or more interstate websites to solicit customers to purchase sex acts from Defendant with said prostitutes. Said photographs included photographs of said prostitutes naked. Defendant also caused said prostitutes to send photographs of themselves, including in naked and provocative poses, to prospective customers. 11. That as a part of said scheme, plan and pattern, Defendant used and caused others, including persons under 18 years of age, to use aural and wire communications by cell phones, 2
Case 1:13-cr-00053-RP-RAW Document 2 Filed 11/25/13 Page 3 of 6 facilities of interstate commerce, for the purpose of communicating with each other and with customers regarding the solicitation and providing of commercial sex acts. 12. That as a part of said scheme, plan and pattern, Defendant maintained and provided said persons, including persons under 18 years of age, as prostitutes for Defendant, including telling them when and where to perform commercial sex acts, how to dress, what to say to prospective customers, what to charge for sex acts, and otherwise. 13. That as a part of said scheme, plan and pattern, Defendant provided said prostitutes, including persons under 18 years of age, with alcohol and marijuana for the purpose of manipulating them regarding the providing of commercial sex acts. 14. That as a part of said scheme, plan and pattern, and to recruit, entice, obtain, maintain and provide said persons as prostitutes for Defendant, Defendant engaged in sex acts with one or more of said prostitutes, including persons under 18 years of age. 15. That as a part of said scheme, plan and pattern, Defendant threatened one or more of said prostitutes, including persons under 18 years of age, with physical harm if the prostitute did not do as Defendant directed regarding serving as a prostitute for Defendant. 16. That as a part of said scheme, plan and pattern, Defendant caused one or more of said prostitutes, including persons under 18 years of age, to intentionally miss school to serve as ~ prostitute for Defendant. 17. That as a part of said scheme, plan and pattern, Defendant caused said prostitutes, including persons under 18 years of age, to engage in a series of commercial sex acts in and about Omaha, Nebraska, and the surrounding vicinity; and as a part of said scheme, plan and pattern, Defendant at times transported said prostitutes, including persons under 18 years of age, in interstate commerce, especially between Nebraska and Iowa, for the purpose of engaging in 3
Case 1:13-cr-00053-RP-RAW Document 2 Filed 11/25/13 Page 4 of 6 and attempting to engage in commercial sex acts. 18. That as a part of said scheme, plan and pattern, Defendant benefitted financially, that is, by receiving United States currency, for providing to customers said prostitutes, including persons under 18 years of age, to perform sex acts. COUNT 1 (Sex Trafficking 1. The Grand Jury realleges and by this reference incorporates herein, paragraphs 1-18, inclusive, of the Introductory Allegations of this Indictment, as though fully set forth herein. 2. On or about February 5, 2013, in the Southern District oflowa and elsewhere, the Defendant, ADRIEN JAMAAL COLE, a/k/a Adrien Cole, Jamaal Cole, Jamaal Prince, Adrien Jamaal Prince, did knowingly, in and affecting interstate commerce, recruit, entice, harbor, transport, provide, obtain, and maintain, and did attempt to recruit, entice, harbor, transport, provide, obtain, and maintain, by any means, a person, that is, M-1, knowing and in reckless disregard of the fact that M-1 had not attained the age of 18 years, and with Defendant having had a reasonable opportunity to observe M-1, and that M-1 would be caused to engage in a commercial sex act; that is, as a part of said scheme, plan and pattern, Defendant transported M-1 from Nebraska, to Council Bluffs in the Southern District of Iowa, to engage in and attempt to engage in one or more commercial sex acts, including but not limited to vaginal intercourse or any other sex act described in Title 18, United States Code, Sections 2246(2(A-(D, inclusive; and Defendant benefitted financially and by receiving anything of value from the commercial sex act and attempted commercial sex act performed by M-1 in Council Bluffs. This is a violation of Title 18, United States Code, Sections 159l (a(l, 1591(a(2, 1591(b(2, and 1594(a. 4
Case 1:13-cr-00053-RP-RAW Document 2 Filed 11/25/13 Page 5 of 6 COUNT2 (Sex Trafficking 1. The Grand Jury realleges and by this reference incorporates herein, paragraphs 1-18, inclusive, of the Introductory Allegations of this Indictment, as though fully set forth herein. 2. On or about December 7, 2012, in the Southern District of Iowa and elsewhere, the Defendant, ADRIEN JAMAAL COLE, a/k/a Adrien Cole, Jamaal Cole, Jamaal Prince, Adrien Jamaal Prince, did knowingly, in and affecting interstate commerce, recruit, entice, harbor, transport, provide, obtain, and maintain, and did attempt to recruit, entice, harbor, transport, provide, obtain, and maintain, by any means, a person, that is, M-2, knowing and in reckless disregard of the fact that M-2 had not attained the age of 18 years, and with Defendant having had a reasonable opportunity to observe M-2, and that M-2 would be caused to engage in a commercial sex act; that is, as a part of said scheme, plan and pattern, Defendant transported M-2 from Nebraska, to Council Bluffs in the Southern District oflowa, to engage and attempt to engage in one or more commercial sex acts, including any sex act as defined in Title 18, United States Code, Sections 2246(2(A-(D, inclusive; and Defendant benefitted financially and by receiving anything of value from the commercial sex act and attempted commercial sex act performed by M-2 in Council Bluffs. This is a violation of Title 18, United States Code, Sections 159l(a(l, 1591(a(2, 159l(b(2, and 1594(a. COUNT3 (Sex Trafficking 1. The Grand Jury realleges and by this reference incorporates herein, paragraphs 1-18, inclusive, of the Introductory Allegations of this Indictment, as though fully set forth herein. 2. On or about December 24, 2012, in the Southern District oflowa and elsewhere, the 5
Case 1:13-cr-00053-RP-RAW Document 2 Filed 11/25/13 Page 6 of 6 Defendant, ADRJEN JAMAAL COLE, a/k/a Adrien Cole, Jamaal Cole, Jamaal Prince, Adrien Jamaal Prince, did knowingly, in and affecting interstate commerce, recruit, entice, harbor, transport, provide, obtain, and maintain, and did attempt to recruit, entice, harbor, transport, provide, obtain, and maintain, by any means, a person, that is, M-2, knowing and in reckless disregard of the fact that M-2 had not attained the age of 18 years, and with Defendant having had a reasonable opportunity to observe M-2, and that M-2 would be caused to engage in a commercial sex act; that is, as a part of said scheme, plan and pattern, Defendant transported M-2 from Nebraska, to Council Bluffs in the Southern District oflowa, to engage and attempt to engage in one or more commercial sex acts, with one or more customers, including vaginal intercourse and any other sex act described in Title 18, United States Code, Sections 2246(2(A- (0, inclusive ; and Defendant benefitted financially and by receiving anything of value from the commercial sex act and attempted commercial sex act performed by M-2 in Council Bluffs. This is a violation of Title 18, United States Code, Sections 1591(a(l, 1591(a(2, 1591(b(2, and 1594(a. A TRUE BILL. ISi ~~~~~~~~~~~~~- FOREPERSON Nicholas A. Klinefeldt United States Attorney By: SI Patrick Stephen O 'Meara Stephen Patrick O'Meara Assistant United States Attorney 6