United States v. CHARUDET SMITH, Southern District of New York (Feb. 9, 2024) — Complaint

AUSA Marcia S. Cohen 
UN
ITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
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UNITED STATES OF AMERICA 
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v-
CHAR
UDET SMITH, 
a/k/a “Charles Smith, 
Defendant. 
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SEALED COMPLAINT 
Violation of 18 U.S.C. § 2251(a) 
COUNTY OF OFFENSE: 
Westchester 
SOUT
HERN DISTRICT OF NEW YORK, ss.: 
ANDRE
W M. PAPPAS, being duly sworn, deposes and says that he is a Special Agent 
with the Federal Bureau of Investigation (“FBI”) and charges as follows: 
COUNT ONE 
(Sexual Exploitation of a Child) 
Fro
m at least on or about December 21, 2019 up to and including at least on or about 
February 13, 2020, in the Southern District of New York and elsewhere, CHARUDET SMITH, 
a/k/a “Charles Smith,” the defendant, knowingly employed, used, persuaded, induced, enticed, 
and coerced a minor to engage in sexually explicit conduct for the purpose of producing a visual 
depiction of such conduct and for the purpose of transmitting a live visual depiction of such 
conduct, and the defendant knew and had reason to know that such visual depiction would be 
transported and transmitted using any means and facility of interstate and foreign commerce and 
in or affecting interstate and foreign commerce and mailed, and the visual depiction was 
produced using materials that had been mailed, shipped and transported in and affecting 
interstate and foreign commerce by any means including by computer, and such visual depiction 
was transported and transmitted using any means and facility of interstate and foreign commerce 
and in and affecting interstate and foreign commerce and mailed, to wit, SMITH, while in 
Westchester County, New York, used trickery and deceit to persuade a 17-  year-old minor in 
California (“Victim-1”) to engage in sexually explicit activity and transmit to SMITH, via the 
internet, videos and photos of such activity.  
(Title 18, United States Code, Section 2251(a)) 
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4mj551

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The bases for my knowledge and for the foregoing charge are, in part, as follows: 
1.I am a Special Agent with the Federal Bureau of Investigation (“FBI”), assigned
to the FBI Bridgeport Safe Streets Task Force (BSSTF) in Connecticut. I have been employed by 
the FBI since March 2019.  I have participated in numerous investigations, including 
investigations involving violent crimes, narcotics, frauds, firearms, and crimes against children. 
I have gained expertise in these areas through training and daily work related to conducting and 
participating in these types of investigations. 
2.I have been personally involved in the investigation of this matter.  This affidavit
is based upon my conversations with law enforcement agents and others, and my examination of 
reports and records.  Because this affidavit is being submitted for the limited purpose of 
establishing probable cause, it does not include all the facts that I have learned during the course 
of my investigation.  Where the contents of documents and the actions, statements and 
conversations of others are reported herein, they are reported in substance and in part, except 
where otherwise indicated. 
3.On or about February 10, 2020, I spoke with an individual (“Victim-1”), who was
17-years-old at the time, who advised me, among other things, that he had engaged in
communications and in-person meetings with CHARUDET SMITH, a/k/a “Charles Smith,” the
defendant.  Victim-1 reported, in substance and in part:
a.I
n or about December 2019, Victim-1 was an avid amateur photographer
who was living with his parents in San Diego, California. In connection with his desire to pursue 
a career in photography, he maintained a website and Instagram account showcasing his 
photography.  On or about December 21, 2019, an Instagram account, purporting to belong to 
someone who was an employee of a well-known international camera company (“Company-1”), 
initiated contact with Victim-1 and offered Victim-1 the opportunity to do freelance work for 
Company-1 with a purported freelance photographer.  The purported freelance photographer’s 
Instagram address was “@charudetsmith.” 
b.Victim-1 exchanged messages with @charudetsmith via Instagram and
also by text messages.  For the text messages, Victim-1 contacted @charudetsmith using the 
phone number @charudetsmith provided him, xxx-xxx-8496 (“8496-Phone”). The 8496-Phone 
told Victim-1 that he had numerous contacts within the media industry. The individual, later 
identified as CHARUDET SMITH, a/k/a “Charles Smith,” offered to provide Victim-1 with such 
contacts.  Among other things, SMITH told Victim-1 that he was an alumnus of a Junior 
Ambassador Program that he claimed Company-1 maintained in order to pair aspiring teenage 
photographers with established photographers in a mentor/mentee relationship.   
c.A
fter his communications with SMITH began, Victim-1 received
additional messages via email, text and Instagram from multiple individuals who purported to be 
Company-1 representatives who invited him to apply for the Junior Ambassador (“JA”) 
Program.  Victim-1 completed the required steps and was welcomed into the JA Program and 
paired with SMITH, the defendant, as his purported mentor.  Soon after being accepted into the 

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JA Program, Victim-1 was invited to contact a young woman who, according to the 
representatives, was another JA. Victim-1 contacted her at the Instagram account that was 
provided by the representatives and spoke to someone he believed to be a female JA. 
d.In or about January 2020, Victim-1 received messages via text and
Instagram from various individuals -- an individual who purported to be a Company-1 
representative, an individual who purported to be a director at an outdoors magazine, an 
individual who purported to be an employee of an apparel company, and an individual who 
purported to work for an airline (“Airline-1”).  The purported employee of Airline-1 
communicated with Victim-1 via Instagram and arranged for Victim-1 to accompany SMITH to 
a January 18, 2020 photography shoot in Jackson Hole, Wyoming on January 18, 2020.   
e.On or about January 18, 2020, Victim-1 flew to Jackson Hole, Wyoming
with the airline ticket provided by the purported Airline-1 employee and, once in Wyoming, met 
CHARUDET SMITH, a/k/a “Charles Smith,” the defendant, in person. While in Wyoming, 
Victim-1 and SMITH stayed in the same hotel room in different beds.  During the trip, 
purportedly at the request of the “sponsor,” SMITH directed Victim-1 to pose for photographs 
wearing only underwear.  Also while in Jackson Hole, Wyoming, SMITH told Victim-1 that his 
purported girlfriend was a sex therapist and provided Victim-1 with her phone number, xxx xxx-
8334 (“8334-Number”).  
f.W
hile in Wyoming, SMITH gave Victim-1 the Instagram contact
information, “katiemsoto,” for someone he said was a female JA and told Victim-1 that he 
wanted Victim-1 to go on a “date night” with her.  Via Instagram, the purported female JA sent a 
nude photo of herself to Victim-1.  Later, during the trip, Victim-1 saw the same nude photo on 
SMITH’s phone on an Internet browser page.   
g.While Victim-1 was in Wyoming, a purported Company-1 representative
contacted Victim-1 and told him that he had to be “initiated” into the JA Program via a ritual 
involving alcohol consumption.  The purported representative told Victim-1 to take 10-20 photos 
and do a “clean” (i.e. sober) edit and then do a “dirty” edit while intoxicated.  The purported 
representative advised Victim-1 that he would be judged on the quality of the edits and his 
membership in the JA Program would depend on their quality. SMITH provided Victim-1 with 
alcohol. After drinking multiple shots of liquor, Victim-1 did the “dirty” edit while intoxicated. 
After submitting the “dirty” edit, a purported Company-1 employee then sent a message to 
Victim-1 informing Victim-1 that his edits were inadequate and that Victim-1 would be asked to 
leave the JA program.   
h.SMITH volunteered to help Victim-1 remain in the JA Program and said
he would garner the support of an alleged movie director friend. Another purported Company-1 
representative contacted Victim-1 and told him that he would have another opportunity to redo 
the “dirty” (i.e., intoxicated) photo shoot. SMITH told Victim-1 he could ensure that Victim-1 
would remain in the JA Program if Victim-1 took nude photos of himself and sent them to the 
purported female JA who had previously sent Victim-1 the nude photo.  Again, SMITH provided 
alcohol to Victim-1.  Then, during a second “dirty” edit, Victim-1 took images of his naked 

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genitalia.  At SMITH’s insistence, Victim-1 sent the images via Instagram to the purported 
female JA. 
i.
While in Wyoming, Victim-1 told SMITH that he (Victim-1) was 17
years old and would not be 18 until his birthdate in spring of 2020.  
j.After the Wyoming trip, Victim-1 remained in contact with the purported
female JA.  Between on or about January 28, 2020 and February 8, 2020, at her request, Victim-
1 sent the purported female JA additional nude photos of himself via Instagram.  During their 
communications, the purported female broached with Victim-1 the idea of having a “threesome” 
with SMITH. 
k.After the Wyoming trip, SMITH also introduced Victim-1 to an individual
who was a purported Seattle model and blogger (“Model-1”) who was, purportedly, setting up a 
photo shoot for SMITH and Victim-1 in Seattle, Washington.  Model-1 told Victim-1 that she 
was interested in engaging in sexual activity with SMITH and Victim-1 as part of a “threesome” 
and also potentially as a “foursome” involving an additional purported female friend. Victim-1 
received nude photographs from Model-1 that purported to be Model-1 and her friend.  During 
his communications with Model-1, Model-1 told Victim-1 that she would engage in sexual acts 
only if SMITH and Victim-1 also engaged in sexual acts.  Initially, Victim-1 told Model-1 that 
he would not participate.  When Model-1 said she would cancel her participation in the 
upcoming Seattle photo shoot, Victim-1 agreed to participate.  The Seattle trip was scheduled to 
begin on February 13, 2020.  Victim-1 agreed to participate in sexual activity scheduled for 
February 17, 2020.  He also agreed to participate in sexual activity with SMITH on February 13, 
2020 to “practice” for the February 17, 2020 sexual activity. 
l.A
fter Victim-1 agreed to participate, Victim-1 received communications
from SMITH’s purported sex therapist girlfriend (“Girlfriend-1”), who used the 8344-Number 
that SMITH had provided to Victim-1.  Girlfriend-1 instructed Victim-1 to “practice” the sexual 
activity with SMITH before engaging in the threesome, in order to become comfortable.  
Girlfriend-1 sent messages to Victim-1 with explicit and graphic instructions as to how Victim-1 
should engage in oral and anal sex with SMITH during the practice session set for the evening of 
February 13, 2020 in Seattle.  Girlfriend-1 asked Victim-1 to make and send her videos of 
Victim-1 masturbating. Victim-1 made and sent these videos to Girlfriend-1 via both email and 
text message on January 28, 2020.  Victim-1 spoke to SMITH about the intended “foursome” 
and, among other things, asked SMITH if Model-1 and her friend knew that he was only 17 
years old.  SMITH responded that they did.  
4.On or about February 10, 2020, Victim-1 and his family provided consent for the
review of Victim-1’s phone.  On or about February 14, 2020, an examiner employed by the FBI 
who is specially trained in the forensic examination of digital evidence extracted material from 
Victim-1’s phone.  I have reviewed the material extracted and am aware that, among other things, 
Victim-1’s phone contained the following, in substance and in part: 
a.The  contacts  in  Victim-1’s  phone  included a  contact  for  an  individual
(“Individual-1”) identified as “Head [Company-1] Ambassador.”  The contact lists Individual-1’s 
phone  number  as  xxx  xxx-2389  (“2389-Number”).    Victim-1’s  phone  contains  text  messages  

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between  the  2389-Number  and  Victim-1  from  in  or  about  January  21,  2020  to  on  or  about  
February 10, 2020.  In a message dated January 21, 2020, the 2389-Number said, “Hi [Victim-1], 
I’m going to figure out what’s going on. But you want to be with Charles?”  In a message on or 
about February 10, 2020, the 2389-Number said, “In all my years at [Company-1], I don’t think 
I’ve seen more promise and talent than I see in both of you.”  
b. The  contact  in  Victim-1’s  phone  included  a  contact  for  an  individual  
(“Individual-2”) identified   as “Marketing Director of [Company-1].” The contact lists Individual-
2’s phone number as xxx-xxx-9752 (“9752-Number”).  Victim-1’s phone contains text messages 
between  the  9752-Number  and  Victim-1  from  on or  about  December  23,  2019  to  on   or  about  
January 30, 2020.  On or about December 23, 2019, Individual-2 wrote, “Hi [Victim-1]. This is 
[Indivdiual-2].  I  locked  myself  out  of  my  Instagram  account,  so  please  message  me  here  or  
through High Tail until I get back in. We will make your plane reservations tomorrow!”  
c. The  contacts  in  Victim-1’s  phone  included  a  contact  for  an  individual  
(“Individual-3”) identified as “Apple.”  The contact lists Individual-3’s phone as xxx-xxx-2954 
(“2954-Number”).  Victim-1’s phone contains text messages from the 2954-Number from on or 
about February 6, 2020 to February 12, 2020.  On or about February 6, 2020, the 2954-Number 
said, “Hey [Victim-1]! We’d love to help you and Charles with your nomadic vlog!” Later that 
day, the 2954-Number said, “Perfect, just wanted to confirm that you’ll be doing the 2
nd
 video 
next Thursday in Seattle. The requirements are to get drunk and talk photography, edit, and do 
what you do best.” 
d. Victim-1’s   phone   contained   a number   of   screenshots   of   Instagram   
conversations between Victim-1 and a user named “katiemsoto.”  In the conversations that appear 
in the screenshots, “katiemsoto” requested that Victim-1 provide nude pictures to her and Victim-
1 sent her photos of an erect male penis.  In these communications, “katiemsoto” also suggested 
a threesome with Victim-1 and CHARUDET SMITH, a/k/a “Charles Smith,” the defendant.  
e. Victim-1’s phone contained numerous messages with the purported Model-
1, who used a phone number ending in 9308 (“9308 Number”).  In addition, Victim-1’s phone 
contained  numerous  3-way  text  messages  between  the  8496-Number,  Model-1,  and  Victim-1 
from on  or about February 5, 2020 through on or about February 9, 2020.  In this group text, 
there  is  discussion  about  a  sexual  encounter  between  all  three  individuals.    For  example,  on  
February  5,  2020,  Model-1,  using  the  9308-Number,  said,  “Hey  guys,  after  the  male-male-
threesome I thought that I would fulfillyour fantasy with a female-female-male threesome. My 
friend fromNashville, Tennessee will be in town and wants in! Let me know your thoughts!” 
5. On or about February 10, 2020, based on my review of Airline-1 records, I learned 
that CHARUDET SMITH, a/k/a “Charles Smith,” the defendant, had purchased an airline ticket 
on Airline-1 to fly from John F. Kennedy Airport in Queens, New York to Seattle, Washington on 
February 13, 2020 at 7:00 a.m.   
6. On February 12, 2020, the Honorable Lois Bloom, in the Eastern District of New 
York, authorized the search and seizure of SMITH’s phone while he was at John F. Kennedy 
airport (“JFK”).  On February 13, 2020, at approximately 6:00 a.m., I and other law 
enforcement officers approached CHARUDET SMITH, a/k/a “Charles Smith,” the defendant, 

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at JFK, and executed the search warrant.  We recovered two cellphones from him.  SMITH 
identified one of the phones as his phone (“Phone-1”) and stated that the other phone (“Phone-
2”) was his mother’s work phone. 
7. On or about February 19, 2020, I dialed the 8334-Number, the number that was 
supposedly for SMITH’s girlfriend, Girlfriend-1, and Phone-2 rang and displayed my phone 
number as the incoming call number.  I also dialed the 9308-Number, the number that was 
supposedly for Model-1, the Seattle model and blogger.  Again, Phone-2 rang and displayed my 
number as the incoming call number.  After I hung up, a notification with the icon from the 
application “Text Free” appeared on the screen of Phone-2 showing a missed call from my phone 
number on the phone screen of Phone-2.  I am aware that Text Free is an application that allows 
multiple phone numbers to receive calls and forward the calls to a single phone number.   
8. On or about February 19, 2020, I dialed the 2389-Number and the 2954-Number.  
Both numbers rang on Phone-2 and displayed my number as the incoming call number.  When I 
dialed the 2389-Number, two notifications appeared on Phone-2.  The first notification indicated 
a missed call from my number.  The second notification, which showed an icon from the 
application “Burner,” stated, “Missed call from [my number] on [first name of Individual-1].”  
When I dialed the 2954-Number, two notifications, again, appeared on Phone-2.  The first 
notification indicated a missed call from my number.  The second notification stated, “Voicemail 
[my number] on [first and last name of Individual-3].”  I am aware that Burner is an application 
that, like Text Now, allows multiple phone numbers to receive calls and forward calls to a single 
phone number.  
9. On or about February 24, 2020, an examiner employed the FBI who is specially 
trained in the forensic examination of digital evidence extracted the material on each of the 
phones.  I have reviewed this material.  The telephone number for Phone-1 was the 8496-
Number.  The telephone number for Phone-2   was the 8334-Number. 
10. Based on my review of the material extracted from Phone-1, I am aware that 
Phone-1 contained hundreds of text messages between the 8496-Number and Victim-1 from in 
or about December 22, 2020 to February 12, 2020.  These messages include the following: 
a. On 12/22/2019, Victim-1 sent a text to the 8496-Number that said, “I'm a 
senior in high school so this is very exciting.” 
b. There is a series of messages between Victim-1, the 8496-Number, and 
the 9308-Phone.  These messages match the messages recovered from Victim-1’s phone.  The 
messages discuss the coordination of a sexual encounter between Victim-1, the 8496-Number, 
and the 9308-Phone. For example, on February 5, 2020, the 9308-Phone said, “Here’s our deal.  
You guys have to promise to do stuff too, otherwise it’s not fair. We have our fantasies too! It’ll 
be worthwhile... trust us! Let us know your answer now.”  In response, Victim-1 wrote, “We are 
willing to makeout and give blowjobs” and asked, “Would that be enough?”  The 9308-Phone 
replied, “I’m sorry but it wouldn’t. It would have to be all 3. It’s only fair that way. No double 
standards.”  

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11. Based on my review of the material extracted from Phone-2, I am aware that 
Phone-2 contains over 200 text messages exchanged between the 8344-Number, and Victim-1 
from on or about January 23, 2020 through and including February 11, 2020.  Among these 
messages are the following: 
a. In a message on or about January 23, 2020, at approximately 6:30 p.m., 
the 8344-Number wrote to Victim-1, “Hey [Victim-1]!!! Tess here! I wanted to tell you that 
your photography is amazing. I hope you guys are having a lot of fun. Let me know if Charles 
gets annoying lol.” 
b. On January 23, 2020, at approximately 7:00 p.m., the 8344-Number told 
Victim-1, “I can help you if you would like help.”  The 8344-Number stated, “Promise I won't 
tell Charles.” 
c. On January 23, 2020, at approximately 8:12 p.m., the 8344-Number said, 
“I can definitely help you. But need to know your actual refractory period. Can you ejaculate 
then wait 15 minutes and try to ejaculate again. If it's more than 15 minutes please let me 
know.”    
d. On January 25, 2020 at approximately 7:54 p.m., the 8344-Number wrote, 
“Also, congratulations!!!! 
�������
����
�����������
������ On getting accepted into the [Company-1] program!” 
e. On January 28, 2020 at approximately 10:15 a.m., the 8344-Number told 
Victim-1, “I have some time this afternoon to review your case and would love to help you out. 
Can you provide me with the requested information by the afternoon?” 
f. On January 28, 2020, at approximately 11:29 a.m., the 8344-Number told 
Victim-1, “Also, please provide me with a video of both sessions. (It's not necessary to show 
your face). It will help me to determine if your receiving enough blood flow, tensing your 
muscles or withholding your pc muscle, level of relaxation and arrousel, etc. It'll be really 
helpful and beneficial to getting results.”  At 11:38 a.m, Victim-1 responded, “Got it.” 
g. On January 28, 2020, at approximately 7:14 p.m., Victim-1 wrote, “The 
second video had to be cut short because it was too big to send” and “They were in the span of 
10 minutes.”  The 8344-Number responded, at approximately 7:49 p.m., “Will take a look in 5 
minutes.” 
h. On January 30, 2020, at approximately  2:23 a.m., Victim-1 wrote, “Sorry 
I didn't send you anything today, I got really busy.  I'll try to get some stuff tomorrow 
afternoon.”  At 9:46 a.m., the 8344-Number responded, “Not a problem. If file size is too large 
to send via text you can email it to me at [email protected].” 
i. On February 4, 2020 at approximately 9:03 p.m., the 8344-Number told 
Victim-1, “Ok. For the next 2 videos don't look at any photos or porn. Also please video from 
flaccid to erection. And try not to pause at all or change the rhythm/speed when you're about to 
ejaculate.” 

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12.Based on my review of the material extracted from Phone-2, I am aware that
Phone-2 contains a video file titled “20200128_152306_001.mp4” (“File-1”).  File-1 is an 
approximately 34-second video and depicts a male standing in a bathtub.  The camera is angled 
so that only the male’s naked torso is visible. The male’s right hand is on his erect penis and 
moving up and down.  At approximately 30 seconds into the video, the male ejaculates.  The 
8344-Number received File-1 from Victim-1 on January 28, 2020 at approximately 7:20 p.m. 
eastern time. 
13.Based on my review of the material extracted from Phone-2, I am aware that the
user accounts on Phone-2 include the Instagram account, “katiemsoto” and an Instagram account 
with the name of Individual-2. 
14.Based on my review of the material extracted from Phone-2, I am aware that the
extracted material includes location data for Phone-2.  Based on my training and experience, I 
am aware that, when a phone is on, it communicates with satellites and the communication 
generates location data for the phone that is preserved in the phone’s location logs.  This location 
data provides a latitude and longitude for the phone’s location at given times.  Based on my 
review of the location data contained in the material extracted from Phone-2, I am aware that, on 
January 29, 2020, from approximately 12:42 a.m. to February 1, 2020 at approximately 10:54 
a.m., Phone-2 was at a location (“Location-1”) in New Rochelle, New York.  From
approximately February 4, 2020 at 5:51 p.m. to on or approximately February 7, 2020 at
approximately 12:52 p.m., Phone-2 was located at Location-1.
15.In February 2020, I obtained telephone records for the 8496-Number.  Based on
my review of those records, I am aware that the subscriber of the 8496-Number at that time was 
an individual who I know, based on this investigation, to be the mother of CHARUDET SMITH, 
a/k/a “Charles Smith,” the defendant.  Further, the records for the 8496-Number indicated an 
address in  New Rochelle, New York (“Address-1”).   
16.Based on my review, in or about February 2020, of New York Motor Vehicle
Records, I am aware that, at that time, SMITH had a New York driver’s license and Address-1 
was the address listed on SMITH’s driver’s license.  Based on information I have obtained from 
publicly available sources, I am aware that Address-1 is located on an approximately two-acre 
lot and that Location-1 is located within the property of Address-2.   
17.On or about February 1, 2024, I obtained subscriber records for the 8433-Number.
Based on my review of those records, I am aware that, from approximately August 3, 2019 
through August 19, 2021, the subscriber of the 8433-Number was the mother of CHARUDET 
SMITH, a/k/a “Charles Smith,” the defendant, at Address-1, SMITH’s residence.  
18.Based on my review of Instagram records relating to the Instagram account
“katiemsoto,” I am aware that this account was created on or about March 6, 2019 and that this 
account was accessed on numerous occasions from an IP address ending in 216 (“216-IP”)  In 
January and February 2020, the “katiemsoto” account was accessed on approximately 30 
occasions from the 216-IP.  These occasions include an occasion on February 13, 2020, at 
approximately 2:58 a.m..  Based on my review of publicly available IP address location data, I 
am aware that the 216-IP returns to New Rochelle, New York.   

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19.Based on my review of Instagram records relating to the Instagram account
I found on Phone-2 with Individual-2’s name, I am aware that this account was created on or 
about January 31, 2020 and that this account was accessed on numerous occasions from the 216-
IP.  
20.Based on my conversations with another Special Agent of the FBI (“Agent-1”), I
am aware that, on March 2, 2020, Agent-1 interviewed an individual with the same name as 
Individual-1 (“Witness-1 ”).  Witness-1 stated that he has been a professional photographer 
employed by Company-1 for the past 35 years.  Witness-1 stated that Company-1 does not have 
a Junior Ambassador Program but does have an Ambassador Program.  Witness-1 stated that he 
oversees the Ambassador Program and has never heard of or talked to anyone by the name  
“Charudet Smith” or “Charles Smith.”  According to Witness-1, the 2389-Number was never 
Witness-1’s telephone number.  
21.Based on my conversations with Agent-1, I am aware that, on February 27, 2020,
Agent-1 interviewed the Director of Human Resources and Operations for Company-1 (Witness-
2).  At Agent-1’s request, Witness-2 reviewed Company-1’s records.  Witness-2 stated that no 
one by the name “Charudet Smith” or “Charles Smith” had ever been an employee of Company-
1 and no one by either of those names had ever been paid by Company-1 for any services or any 
employment.  At Agent-1’s request, Witness-2 also consulted with Company-1’s Ambassador 
Program and reviewed the program’s records.  According to Witness-2, no one by the name 
“Charudet Smith” or “Charles Smith” had ever been a member of Company-1’s Ambassador 
Program. 
22.Based on my review of Google records, I am aware that the email address,
[email protected] was created on January 29, 2020 from the 216-IP.  As discussed 
above, Victim-1 received this email address on January 30, 2020 from the 8344-Number with the 
instruction that Victim-1 should use this email if the sexually explicit video files requested by the 
8344-Number were too large to send via text.   
23.Based on all of the above, I believe that CHARUDET SMITH, a/k/a “Charles
Smith,” the defendant, impersonated various individuals and created and used a series of 
Instagram accounts, emails, and phone numbers in order to deceive Victim-1 into creating and 
sending sexually explicit videos and images to SMITH and agreeing to meet SMITH to engage 
in sexual activity in Seattle, Washington. 

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WHEREFORE, the deponent respectfully requests that CHARUDET SMITH, a/k/a 
“Charles Smith,” the defendant, be arrested and imprisoned or bailed, as the case may be. 
__________________________________ 
Andrew M. Pappas 
Special Agent 
Federal Bureau of Investigation 
Sworn to me through the transmission of this 
Complaint by reliable electronic means, pursuant to 
Federal Rules of Criminal Procedure 41(d)(3) and 4.1, this 
______ day of February, 2024 
__________________________________ 
THE HONORABLE VICTORIA RESNIK 
United States Magistrate Judge 
Southern District of New York 
/s/ Andrew M. Pappas signed by VR with permission
5th