United States v. KYLE WHITE, Southern District of New York (Jan. 18, 2024) — Complaint

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT 
OF NEW YORK 
UNITED STATES OF AMERICA 
V. 
KYLE WHITE, 
Defendant. 
SOUTHERN DISTRICT 
OF NEW YORI(, ss.: 
AUSA: Chelsea L. Scism 
-41 MAG 
SEALED COMPLAINT 
Violations 
of 18 U.S.C. §§ 225l(d)(l)(A), 
(d)(2) and (e), and 2252A(a)(2)(B) and 
(b)(l) 
COUNTY 
OF OFFENSE: 
NEW YORK 
NICOLE KWASNAZA, being duly sworn, deposes and says that she 
is a  Special Agent 
with the Federal Bureau oflnvestigation, and charges 
as follows: 
COUNT ONE 
(Advertisement 
of Child Pornography) 
1. From at least in or about September 2022 through in or about December 2023, in 
the Southern District 
ofNew York and elsewhere, KYLE WHITE, the defendant, knowingly made, 
printed, and published, and caused 
to be made, printed, and published, a notice and advertisement 
seeking and offering to receive, exchange, buy, produce, display, and reproduce a visual depiction, 
where the production 
of such visual depiction involved the use of a  minor engaging in sexually 
explicit conduct and such visual depiction is 
of such conduct, and WHITE, the defendant, lmew 
and had reason to know that such notice and adve1tisement would 
be transp01ied using any means 
and facility 
of interstate and foreign commerce and in or affecting interstate and foreign commerce 
by any means including by computer and mailed,  and such notice and adve1tisement was 
transpmied using any means and facility 
of interstate and foreign commerce and in and affecting 
interstate and foreign commerce by any means including by computer and mailed, to wit, KYLE 
WHITE adve1tised the sale of, and sold, access 
to groups and channels on Telegram lmown as 
"The Ho Zone" containing sexually explicit images and videos of minors to numerous individuals, 
including individuals located 
in New York, New York. 
(Title 
18, United States Code, Sections 2251 ( d)(l )(A), ( d)(2) and ( e ).) 
COUNT TWO 
(Receipt and Distribution 
of Child Pornography) 
2. From at least in or about September 2022 through in or about December 2023, in 
the Southern District of New York ai;id elsewhere, KYLE WHITE, the defendant, knowingly 
received and distributed material that contains child pornography using a  means and facility 
of 
interstate and foreign commerce and that has been mailed and has been shipped and transpmied in 
and affecting interstate and foreign commerce by any means, including 
by computer, to wit, KYLE 
WHITE, granted access to groups and channels on Telegram known as "The Ho Zone" containing 

sexually explicit images and videos of minors to numerous individuals, thereby distributing those 
materials, including to individuals located in New York, New York. 
(Title 18, United States Code, Sections 2252A(a)(2)(B) and 
(b )(1 ).) 
The bases for my lmowledge and for the foregoing  charges are, 
in part, as follows: 
3. I am a Special Agent with the Federal Bureau oflnvestigation ("FBI"). I have been 
employed by the FBI since June 2017, first 
as an FBI Honors Intern, next as an Information 
Technology Specialist/Forensic Examiner, and now 
as a  Special Agent. I  have been a  Special 
Agent since December 2022. During my career with FBI, I  have participated 
in criminal 
investigations involving cybercrime, fraud, child exploitation,  and counte1ierrorism. I have been 
personally involved 
in the investigation of this matter. I base this affidavit on that experience and 
on training I have received, on my conversations with other law enforcement officers, and on my 
examination 
of various repmis and records, including electronic evidence. Because this affidavit 
is being submitted for the limited purpose of demonstrating probable cause, it does not include all 
the facts I have learned during the course 
of my investigation. Where the contents of documents 
and the actions, statements, and conversations 
of others are repmied herein, they are repo1ied in 
substance and 
in part, except where otherwise indicated. 
"The Ho Zone" 
4. Based on my review of the Telegram website and my h·aining and experience, I 
have learned that Telegram 
is a free, cloud-based mobile and desktop messaging application with 
over 700 million monthly active users.
1 
Telegram users can send messages, photos, videos, and 
other files, 
as well as create groups for up to 200,000 members, or channels for broadcasting to 
audiences 
of unlimited size. Telegram groups can be public or private, and there is a  setting 
allowing group administrators to permit or prevent group members' access 
to messages in the 
group that pre-date when a member joins. According to the Telegram website, group 
administrators can "pin important messages to the top 
of the screen so that all members can see 
them, including those who have just joined." An administrator can add people 
to a Telegram group 
via his contacts list, searching 
by username, or sending an invite link. "Anyone who has Telegram 
installed will be able 
to join [ a] group by following [that] link." Separately, Telegram channels 
"are a tool for broadcasting messages 
to large audiences," and channels can have "an unlimited 
number 
of subscribers." New subscribers can see the entire message history in a  channel once 
they join. Like groups, channels can be public or private. "Private channels are closed 
societies-
you need to be added by the owner or get an invite link to join." 
5. Based on my pa1iicipation in this investigation and my review of Telegram, I have 
learned, among other things, the following: 
a. "The Ho Zone" is a Telegram group that on or about November 8, 2023 had 
approximately 10,272 members, 1,077 photos, 1,041 videos, and 364 shared links. The 
administrators 
of The Ho Zone are "THZ Admin (Check Bio)" with handle @THZAdmin 
. 
1 
See telegram.org/faq and telegram.org/faq_ channels. 
2 

(hereinafter, "THZ Admin"), and "RemovejoinGroupMsgBot" with handle @Bot442.
2 
A 
screenshot containing information about The 
Ho Zone group is below.
3 
b. THZ Admin is  a Telegram user with a profile picture that says, "THE HO 
ZONE ADMIN." The bio for THZ Admin states: "Tap the button at the bottom to join my free 
group T.me/thzmarket." Below is  a screenshot 
of user information for THZ Admin. 
2 
According to open-source information, "RemovejoinGroupMsgBot" is a bot that automatically 
removes messages populated when users join or leave a group. 
3 
Each screenshot in this Complaint was taken by me or another law enforcement officer when we 
viewed publicly available groups and channels on The Ho Zone from our computers and/or phones 
while located in New York, New York. Unless otherwise stated, when we captured these images, 
we were viewing The Ho Zone 
as members of the public who had "joined" The Ho Zone. No 
payments or approvals were required in order for 
us to gain access. 
3 

c. The website T.me/thzmarket links to the Telegram channel "The Ho Zone 
Market." The Ho Zone Market was created on October 6, 2022. As 
of on or about September 18, 
2023, The Ho Zone Market had over 3,400 subscribers, and as of on or about November 8, 2023, 
The 
Ho Zone Market had approximately 3,610 subscribers. The Ho Zone Market channel is pa1t 
of The Ho Zone group.  In addition to linking to The Ho Zone Market, THZ Admin also posts in 
the main The Ho Zone group. 
the following: 
d. The 
Ho Zone group has dozens of channels, including, but not limited to, 
Other Teen (18+) Leaks 
MOST POPULAR GIRLS LISTS 
PAYMENT GUIDE & MORE INFO! 
Tiktoker Private Leaks 
ATHLEAKS 
Other Onlyfans Girls
4 
Tiny Tits Onlyfans 
Huge Tits Onlyfans 
Old Leaks + New Onlyfans 
e. As fmther explained below, The Ho Zone sells access to sexually explicit 
photographs and videos 
of minors and adult women without their consent, and the above-listed 
channels categorize the type 
of material for sale on The Ho Zone. The Ho Zone group is open to 
4 
OnlyFans is an 18+ subscription platform in which individuals can sell access to their private, 
and often sexual, content. 
4 

the public. Below is  a screenshot of some of the channels available within The Ho Zone group, 
with references to names or monikers 
of victims omitted to protect their privacy. 
f. Within The Ho Zone channels, customers can purchase access to sexually 
explicit photographs and videos 
of dozens of women and girls who are listed by name. For 
example, a pinned message from THZ Admin on the "MOST POPULAR GIRLS LISTS" channel 
advertises this channel as "[ e ]very girl I  have 
so far." THZ Admin directs users to click on the 
names of specific women and girls "to go directly to their free preview with prices." THZ Admin 
tells users that 
if they "can't  find a preview for them or if [they're] looking for rare leaks," they 
should "DM," or send a direct message, to @THZadmin.  Below are screenshots listing only some, 
but not all, 
of the women and girls whose sexual images and videos are for sale on The Ho Zone 
channel "MOST POPULAR GIRLS LISTS."  Specifically, the below images list victim names 
in 
alphabetical order showing only a  pmiion of A through C on the left, and only a  pmiion of N 
through T  on the right. The names or monikers 
of victims have been omitted in these images to 
protect their privacy. Each 
of these victim names or monikers links to a separate channel within 
The Ho Zone. 
5 

g. When a Telegram user clicks on the name of a specific woman or girl, the 
user is directed to a separate channel filled with content specific to that individual woman or girl. 
Each channel includes a variety 
of free and often publicly available content as a preview of what 
a user will get 
if they pay money for full access. The free channel preview also typically includes 
a description 
of what additional sexually explicit content the user will get if they pay. 
h. For instance, The Ho Zone channel selling stolen, sexually explicit content 
of one young adult woman who is well known on social media platforms including TikTok
5 
and 
Instagram
6 
("Victim-I") includes free photographs in which Victim-I is fully clothed • (the 
"Victim-I Channel"). The description for the Victim-I Channel states, "Only place u can get the 
full [Victim-I] leaks set."
7 
As on or about of January 3, 2024, the Victim-I Channel containing 
free content has approximately 4,387 subscribers. The price for access 
to the paid Victim-I 
5 
TikTok is a social media application where users can post short-form videos. 
6 
Instagram is a social media application where users can post photos and sh01i-form videos. 
7 
From my participation in this investigation, conversations with witnesses, conversations with 
other members 
of law enforcement, and review of records, I have learned that in or around August 
2022, the cellphone 
of Victim-I was unlawfully accessed via a social engineering scheme, and 
private, sexually explicit photographs and videos 
of Victim-I and others, including Victim-1 's 
sexual pa1iners, were stolen from Victim-1 
's Snapchat application on her cellphone. Snapchat is 
a multimedia instant messaging application that features photos and videos that disappear after a 
message recipient views the message.  There 
is no evidence to suggest that KYLE WHITE, the 
defendant, hacked Victim-1 
's cellphone. 
6 

Channel was previously $75 and was then offered on sale for $45. As of on or about January 3, 
2024, the paid Victim- I  Channel has approximately 75 subscribers.
8 
A message on the Victim-I 
Channel advertises, "Has abt 4 mins 
w01th of her sucking dick and getting fucked in all positions. 
(My compilations/edits and the OG files inc) plus 50 more new extremely rare [flames emoji] nude 
pics/vids[.]" The message fu1ther states, "This 
is the only FULL original in HD with the OG leaks 
and edits/enhancements I  spent hours making. Not some trash recordings from a  phone[.]" 
According 
to an icon at the bottom right of the message, this particular message was seen by 
approximately 115,300 people. 
i. Another message 
on the Victim-I Channel includes information on "[h]ow 
to pay" 
as "[p]roof I'll actually add u and this isn't some scam," which links to 
http://t.me/NSFTTpaymentguide.
9 
This link connects users to a  channel with over 1,000 
subscribers called "Payment Guide," with handle @NSFTTPaymentGuide, with a profile picture 
stating, "THE HO ZONE PAYMENT GUIDE" (the "Payment Guide Channel" or "Payment 
Guide"). The Payment Guide Channel was created on or about July 27, 2022. Below 
is a 
screenshot 
of the Payment Guide Channel information. 
THEOOZOfE Payment Gulde 
i~n:m c::.-1 
1.19K 1 
.,.., 
00\'IULOA0 TELEG~AM 
8 
As explained fmther below in Paragraph 22, I know information about the paid Victim-I Channel 
because an undercover FBI agent purchased access to it, and I have personally reviewed 
it. 
9 
Google search results indicate that ''NSFTT" is an abbreviation for "Not safe for TikTok." 
According 
to the TikTok Community Guidelines, "Nudity, pornography, or sexually explicit 
content are not allowed on our platform. Any content that depicts or supports non-consensual 
sexual acts, [and] the sharing 
of non-consensual intimate imagery ... are strictly prohibited." See 
https://www.tiktok.com/creators/creator-p01tal/en-us/community-guidelines-and-
safety/community-guidelines/. 
7 

6. Based on my participation in this investigation and my review of publicly available 
webpages, I  know that the first result in a Google search of   "NSFTT" 
is the website 
https://nsftt.com, called "@TheHoZone,"  adve1tising "Onlyfans girls, Teen leaks, Tiktokers, and 
more! Tap here to pay."  Below 
is a screenshot of this Google search. 
Go gle 
NSFTT 
Images Videos 
Shopping 
About 10.300 results (0.25 seconds) 
El @TheHoZone 
ht1ps://nsttt.com : 
@TheHoZone 
New s Maps 
Onlyfans girls. Teen leaks, Tiktokers, and more
1 
Tap here to pay. 
Bo 
7. Based on my participation in this investigation and my review of publicly available 
webpages, I know that the @TheHoZone website (https://nsftt.com) links directly 
to The Ho Zone 
Telegram groups and channels, including t.me/THZmarket and t.me/NSFTTPaymentGuide. 
Below is  a screenshot 
of the @TheHoZone website. 
8. Based on my paiticipation in this investigation and my review of Telegram, I know 
that the Payment Guide Channel (t.me/NSFTTPaymentGuide) features numerous posts about The 
Ho Zone 
in a question-and-answer format. Below are some of these posts, with screenshots from 
the Payment Guide Channel. 
8 

a. "What am I buying exactly? Permanent access to a Telegram Channel that 
I made where I upload all 
of their content. Everything is organized and in HD." 
b. "What are the prices? All the prices are listed next to the girl's names in 
their preview in T.me/thzmarket." 
c. "How long does it take to get the link? I should send it immediately. If not, 
I'm prob just asleep and I'll send it when I wake up." 
d. "I found leaks so why would I pay you? l. Leaks don't usually have new 
content and I  buy shit myself too that u 
won't find elsewhere[.] 2. You have to download it  all 
and it's often uncropped and/or LQ. Mine have everything cropped and enhanced (Ifnec) already 
uploaded and sorted for.you[.] 
3. Most include my own custom edits and compilations." 
9 

e. "What happens ifit gets taken down? It won't be it's just a small private 
group, but I  have everything backed up on a  separate acct just in case 
so even if it  did, I'll just 
make another one." 
f. "What if/ accidentally leave/delete them? If you need me to send you the 
links again you have 
to pay again (not full price). You can Copy and paste them in your notes app 
or somethin to avoid this." 
g. "Can I get in Legal Trouble for this? No, the only one who possibly could 
is me for sharing it." 
9. Based on my paiticipation in this investigation and my review of Telegram, I have 
learned, among other things, the following: 
a. "THZ Black Market" is another channel associated with The Ho Zone. I 
believe that "THZ" is  an abbreviation for "The Ho Zone." As 
of in or around August 2023, THZ 
Black Market had 759 subscribers, 119 photos, and 56 videos. As of on or about September 8, 
2023, THZ Black Market was no longer accessible to the public on Telegram. Below is a 
screenshot 
of the information about this channel before it  was taken down, taken on or about 
August 17, 2023. 

b. THZ Black Market includes the link to the same Payment Guide Channel 
connected 
to other channels of The Ho Zone: http://t.me/NSFTTPaymentGuide. Below is a 
screenshot. 
c. Material for sale on the THZ Black Market is adve1iised to be the product 
of blackmail or coercion. For instance, as of August 2023,  the THZ Black Market channel 
advertised the following: 
1. " [Victim-2]: $15 Full video call where she's made to str·ip and crying and 
the rest 
of her [emoji] super rare BM leaks." 
ii.   "[Victim-3]: $15 a 22 min video call where she reluctantly follows orders 
to strip and masturbate.  Plus 2 riding vids & more." 
11 

iii. "[Victim-4 and Victim-SJ: $35 Inc live video calls and convos [Victim-4] 
and her friend where she does whatever her blaclanailer (Snapgod) teller 
her."10 
1v. "[Victim-6]: $25 Girl blaclanailed into filming sextapes with her BF, pussy 
& anal fingering, pissing, and more." 
v. "[Victim-7]: $10 Cute girl blaclanailed into fucking her ass." 
d. "Other Teen (18+) Leaks" is another channel to which The Ho Zone sells 
access 
to s·exually explicit content of minors, and adult women without their consent. As of on or 
about September 
8, 2023, Other Teen (18+) Leaks has nearly 10,000 members, 212 photos, and 
144 videos. A screenshot of the information for this channel is below. 
e. On or about July 30, 2023, THZ Admin posted the following message on 
the Other Teen (18+) Leaks channel: 
"Legal Disclaimer: These girls are all 18+ as far as I know. 
Some just look young but if you know of any who are actually UA 
11 
lmk. Also I  didn't hack, 
blaclanail or get any 
of this content directly from the girls myself so it's not illegal." A screenshot 
of this message is below. 
10 
Based on my participation in this investigation and open-source information, "Snapgod" is a 
known moniker for a specific group 
of individuals who ext01i and blaclanail women and minors 
on the internet into recording sexually explicit content against their will. 
11 
"UA" is a commonly known abbreviation for "underage." 
12 

10. Based on my paiticipation in this investigation and my review of Telegram, I know 
that despite this "legal disclaimer," the Other Teen (18+) Leaks channel does in fact sell access to 
sexually explicit images and videos 
of minors. 
a. For example, as of in or around September 2023, the Other Teen (18+) 
Leaks channel advertises the sale 
of material depicting a certain minor victim ("Minor Victim-1 "). 
The cost for access is $25 and the description reads: "Pait of THZ BLACK MARKET," and "THZ 
BLACK MARKET" 
is hyperlinked. Through conversations with other law enforcement officers 
and 
as fmther described below, I  have learned that Minor Victim-I is a  minor in the material 
available for purchase 
on the "Other Teen (18+) Leaks" channel. 
b. As of in or around September 2023, the Other Teen (18+) Leaks channel 
also advertises the sale 
of material depicting a  different minor victim ("Minor Victim-2"). The. 
cost for access 
is $25 and the description reads: "Long Video Calls, upclose pussy fingering, naked 
Tiktoks, and much more." Through conversations with other law enforcement officers and 
as 
fmther described below, I have learned that Minor Victim-2 is a minor in the material available 
for purchase 
on the Other Teen (18+) Leaks channel. 
c. As of in or around September 2023, the Other Teen (18+) Leaks channel 
also adve1tises the sale of material depicting an additional minor victim ("Minor Victim-3"). The 
cost for access 
is $25 and the description reads: "Blackmailed into getting fingered by and sucking 
her little brother's dick. Rough pussy/anal masturbation and much more shit." Through 
conversations with other law enforcement officers and 
as fmther described below, I have learned 
that Minor Victim-3 is a  minor in the material available for purchase on the Other Teen (18+) 
Leaks channel. 
KYLE WHITE is the Owner and Operator of The Ho Zone 
11. As further detailed below, there is probable cause to believe that KYLE WHITE, 
the defendant, 
is the owner and operator of The Ho Zone group and its associated accounts, groups, 
and channels, including the accounts, groups, and channels advertising and selling access to 
sexually explicit images and videos 
of minors. 
12. Based on my participation in this investigation and my review of Telegram, I know 
that The Ho Zone Payment Guide Channel contains a  link connecting users 
to another channel 
called "PAYMENT GUIDE & MORE INFO!" The "PAYMENT GUIDE & MORE INFO!" 
13 

channel includes a message posted on or about June 18, 2023 by THZ Admin regarding how users 
can pay for premium access on The 
Ho Zone. "Current Payment Methods" include: (1) Apple Pay 
and Zelle, with directions for payments to be sent to [email protected]; (2) credit or debit 
card for users outside the United States, with directions 
to pay via http://wishtender.com/THZ;
12 
and (3) cryptocurrency payments in the form ofBitcoin (BTC) and Ethereum (ETH), with specific 
cryptocurrency wallets listed. After paying, users are directed to send "@thzadmin a screenshot 
with the name(s) of who u want and I'll send the links." Below is a screenshot of this message. 
13. Based on my paiiicipation in this investigation and my review of Telegram, I know 
the cryptocurrency instructions in the above message fmiher link 
to 
http://allmylinks.com/paymentportal, which shows a user by the name of "THZ Payment Pmial" 
with the handle @paymentp01ial, and with a profile picture stating, "THE HO ZONE PAYMENT 
GUIDE." Two screenshots 
of "THZ Payment Pmial" are below, with the image on the left "[l]ast 
active" 
as of April 22, 2023 and the image on the right "[l]ast active" as of August 7, 2023. 
12 
According to its website, WishTender is a  "free and safe way to share wishlists." Users can 
create lists 
of items they desire, and other individuals can give users money through Wish Tender 
to purchase those goods. 
14 

Last active Apr 22 
THZ Payment Portal 
0
1
p:1'fmP.nt11ort.:1! 
... 
ii'.lS 
ij IJ  IJ If you live in the US/UK use cashapp! If not, use crypto 
or wishtender and just buy whatever the amount is ur trying to 
pay (NO PAYPAL) IJ IJ Ci 
Read The Inst ructions Above 
Cash App 
cash.app/TheHoZone2 
CashApp Sign up link (free $5) 
cash.app/app/CBW22M3 
For PPL outside the US/UK 
I _i:'f, Wishtender (Credit or Debit Card) 
1 
~ wishtender.com/thz 
My BTCwallet 
bc1qm3I2hjlzp4u7tgyx83ky03gf5vysmr2x ... 
My ETH wallet 
Oxe18a7d5b36100d551 F5db6993773ca70 ... 
I 
I 
l 
l 
I 
lllZ Payment Portal ~ 
r;,w~p11~111 .rno.Mtlhtn 
S-,l~on Cf'YJ«)it:tdj'StoUS:,UWffi 
,.., .. ~ 
' 
Wish tender (Credit or Debit Card) ' 
;.!':t.1,.,:n,J<$. ( IL 
"' 
------:r-, ;~ I :.. 
Bllcoln Wallet 
!rn1<~'lfcu.:.V..:s1sv hl'ci3 , rJF,r,1 
,· 
~ My ETH wallet 
'11" 0:rCl41-l43!CebM2lJi.OJ56C7f6.lf1F320.J~3ll"'S!5q 
1 11/!"l OM me ror other crypto addys 
"' Ln,e/fH~ 1 I 
0 
APPLE PAV & lELLE I Sood to~ 
IH '"°"' 11"•}1 ""11 
14. As depicted above, the payment instructions provided by THZ Payment Portal as 
of April 22, 2023 include the option to pay for The Ho Zone material using online payment 
platform Cash App, and specifically directs users to send funds 
to cash.app/TheHoZone2 
("TheHoZone2 Cash App Account"). 
a. Records obtained from Block, Inc.
-the entity that owns Cash App-reflect 
that the TheHoZone2 Cash App Account was created on or about Octo_ber 4, 2022. Using the date 
of bi1th and social security number provided by the owner of the TheHoZone2 Cash App Account, 
Block was able to verify the identity of the owner to be "Kyle White." There have been three 
display names used by the TheHoZone2 Cash App Account: (1) "Kyle White"; (2) "HoZone"; and 
(3) "THZ." Aliases and phone numbers associated with the TheHoZone2 Cash App Account 
include, among others: "thehozone2"; "kwhitcash12"; "kwhitcashl l "; 
[email protected], and a phone number ending in -4595 (the "4595 Number"). 
b. The records obtained from Block reflect that there are two addresses 
associated with TheHoZone2 Cash App Account: (1) a Louisville, Kentucky address where KYLE 
WHITE, the defendant, resides (the "Louisville Address"); 
13 
and (2) an Albuquerque, New Mexico 
13 
I know that the Louisville Address belongs to WHITE because, among other reasons, as further 
discussed below, on September 19, 2023, I paiiicipated in the execution 
of a search warrant at the 
Louisville Address,  confirmed that WHITE resides there, and interviewed WHITE during the 
15 

address which belongs to fictional television character Walter White, the high-school-chemistry-
teacher-turned-narcotics-kingpin played by actor Bryan Cranston in the hit AMC television series 
Breaking Bad. Additional records indicate that WHITE has also used the alias "Walter White" in 
dealings with Block. 
c. Records obtained from Google show that [email protected] 
email address associated with the TheHoZone2 Cash App Account-
is an account belonging to 
"Kyle White." The recovery SMS phone number for this Google account is the 4595 Number. 
d. Block records link the TheHoZone2 Cash App Account to a card issued by 
Sutton Bank. Records provided by Sutton Bank identify an account owner named "Kyle Stephen 
White" who resides at the Louisville Address. Transaction information from Sutton Bank reflects 
transactions with OnlyFans, Cash App, Apple Pay, and Venmo. 
e. Block records further link the TheHoZone2 Cash App Account to a  bank 
account at Republic Bank and Trust Company ("Republic Bank"). Records provided by Republic 
Bank indicate that the owner 
of the relevant bank account is "Kyle White," who resides at the 
Louisville Address, and whose cellphone is the 4595 Number. The Republic Bank records include 
account statements from in or around July 2016 through in or around June 2023. Between 
approximately February 2023 and June 2023, approximately $117,117.53 was deposited 
by "Cash 
App THZ" into WHITE's Republic Bank account. 
15. Based on my participation in this investigation and my review of Telegram, I know 
that the payment instructions provided 
by the THZ Payment Portal as of August 7, 2023 include 
the option to pay for The Ho Zone material using Apple Pay or Zelle, and the THZ Payment Portal 
directs users to send such payments to [email protected]. 
a. Records obtained from Google identify the owner of 
[email protected] to be "Kyle White." 
b. Records obtained from Apple identify [email protected] as an 
additional email associated with [email protected], which is owned by "Kyle White" of the 
Louisville Address.
14 
Two phone numbers are associated with the Apple account, one of which is 
the 4595 Number. 
16. Based on my paiiicipation in this investigation and my review of Telegram, I know 
that the payment instructions provided 
by "THZ Payment Po1ial" as of August 7, 2023 also include 
the option to pay for The Ho Zone material using cryptocurrencies Bitcoin and Ethereum. 
Specifically, users who wish to pay in Bitcoin are directed to a patiicular BTC wallet, and users 
who wish 
to pay in Ethereum are directed to a  particular ETH wallet. Records obtained from 
cryptocurrency exchange platform Coinbase indicate the same account information associated 
execution 
of the search. In addition, WHITE's valid Kentucky driver's license indicates that his 
home address 
is the Louisville Address. 
14 
I know that the email account [email protected] belongs to KYLE WHITE, the defendant, 
because on November 20, 2023, WHITE sent me an email from this account which stated in part, 
"Hey this Kyle White. We met a couple months ago when you executed a search warrant 
.... " 
16 

with both the particular BTC and ETH wallets referenced above.  Both cryptocurrency wallets are 
owned 
by "Kyle White" of the Louisville Address, who uses the 4595 Number. 
17. An open-source search of Venmo, using identifiers associated with the 
TheHoZone2 Cash App Account, resulted in the discovery ofVenmo account "TheHo Zone" (the 
"TheHo Zone Venmo Account"
). 
a. Records obtained from Pay Pal, Inc.-the owner of Venmo-reflect three 
account numbers associated with the TheHo Zone Venmo Account. Each account number 
is 
owned by first name "TheHo,"  last name "Zone." The phone number provided to PayPal by 
"TheHo Zone" is the 4595 Number. Email addresses associated with the TheHo Zone Venmo 
account include [email protected], [email protected], and 
kwhitukl 2+ l @gmail.com. 
b. PayPal records show financial transactions on the TheHo Zone Venmo 
Account,  under one account number,  from 
in or around August 2022 through in or around 
September 2022, and under a second account number, from in or around October2022 through in 
or around December 2022. The third account number remained active at least through January 
2023. Transaction notes from all three account numbers associated with TheHo Zone Venmo 
Account include the names 
of women and girls listed on the "MOST POPULAR GIRLS LISTS" 
channel. 
18. Further open-source searching of Venmo resulted in the discovery of Venmo 
account "thzl23"  (the "thzl23 Venmo Account"). 
a. Records obtained from PayPal indicate that thz123 Venmo Account was 
created in June 2023 and·remained active 
as of September 2023. 
b. Records obtained from Pay Pal identify one account number associated with 
the thzl23 Venmo Account. The account owner 
is "Kyle White" of the Louisville Address with 
email [email protected].
15 
c. Transaction notes from the thz123 Venmo Account include "Telegram," 
"Tele," "TG," "Services," and "Fee payment." Transaction notes also include the names 
of women• 
and girls listed on the "MOST POPULAR GIRLS LISTS" channel. 
19. Based in my pa1ticipation in this investigation, I know that on or about September 
18, 2023, the Honorable Colin 
H. Lindsay, United States Magistrate Judge, Western District of 
Kentucky, signed a search warrant authorizing the search of the premises located at the Louisville 
Address and the search 
of the person of KYLE WHITE, the defendant (the "WDKY Warrant"). 
As noted above in Footnote 
13, on or about September 19, 2023, I personally participated in the 
execution 
of the WDKY Warrant at the Louisville Address. During the execution of the WDKY 
Warrant, a OnePlus 7TPro cellphone was seized from the person 
of WHITE (the "White Phone"), 
15 
The phone number associated with this account ends in -2796 (the "2796 Number"). 
17 

and a Samsung S8 Tablet was seized from a TV tray inside of the Louisville Address (the "White 
Tablet"). 
16 
20. Based on my review of the electronic contents of the White Phone, I have learned 
the following: 
a. The call number associated with the White Phone is the 4595 Number. 
b. The name 
of the hotspot on the White Phone is "Kyle's Hotspot." 
c. Hundreds of user accounts are connected to the White Phone. These 
include, for example: 
1. Google usernames "kwhitukl [email protected]," 
"kwhitzigzag 
I [email protected]", "[email protected]", and 
"thehozone [email protected]"; 
11. CashApp username "thz12345"; 
111. Reddit usernames "thehozone," "kwhituk12," "[email protected]," 
"kwhitzigzag 
12 ", "nsfttadmin"; 
iv. Wish Tender username "[email protected]"; 
17 
v. PayPal username "[email protected]"; 
vi. Twitter username "NSFTiktok"; 
v11. Republic Bank username "kwhitukl 2"; 
v111. Venmo username "[email protected]"; 
1x. Coinbase username "[email protected];" and 
x.   Telegram identifier "5242630950," among others. 
d. The THZ Admin Telegram account, including groups and channels 
associated with The Ho Zone, 
is accessible from the White Phone. 
21. Based on my review 
of the electronic contents of the White Tablet, I have learned 
the following: 
16 
The White Phone and the White Tablet are just two of numerous devices that were seized during 
the execution of the WDKY Warrant. 
17 
As shown in the screenshot in Paragraph 13 above, WishTender is one method of payment 
accepted by The Ho Zone. 
18 

a. Hundreds of user accounts are connected to the White Tablet. These 
include, for example: 
1. Reddit usernames "kwhituk12", "[email protected]", "nsfttadmin," 
"kwhitzigzagl2", "NSFTikTok", and "thehozone"; 
11. Venmo usernames "[email protected]" and "TheHoZone"; 
iii. WishTender usernames "[email protected]" and 
"thehozone [email protected]"; 
1v. Coinbase username "[email protected]"; 
v.   Republic 
Bartl<: username "kwhituk12"; and 
v1. Telegram identifier "5242630950," among others. 
b. The THZ Admin Telegram account, including groups and channels 
associated with The Ho Zone, 
is accessible from the White Tablet. 
Undercover Purchase of Child Pornography 
22. Based on my conversations with other law enforcement officers and my review of 
law enforcement rep01ts, communications, images, videos, and other data, I know that on or about 
September 18, 2023-before the execution of the WDKY Warrant, and at a  time when KYLE 
WHITE, the defendant, still possessed all 
of his devices-an undercover FBI agent (the "UC") 
made a purchase 
of child pornography from The Ho Zone (the "Controlled Buy"). 
a. At the time of the Conh·olled Buy, the UC was located in New York, New 
York. 
b. In keeping with the instructions on The Ho Zone Payment Guide, the UC 
sent $135 
on Venmo to the thz123 Venmo Account. Below is a screenshot of this Venmo payment 
taken by the UC, which lists "Kyle White" 
as the user of the thzl23 Venmo Account. 
19 

• 
I 
Kyle White 
{i~lht123 •  2 friends 
V Pay or Request 
You poid Kylo Whito · $135.00 
c. Next, the UC sent a  screenshot of the Venmo transaction as proof of 
payment to THZ Admin and requested access to the following five paid channels: 
1. Minor Victim-1, which costs $25; 
11. Minor Victim-2, which costs $25; 
111. Minor Victim-3, which costs $25; 
1v. Victim-1, which costs $45; and 
v. A semi-professional female athlete ("Victim-8"), which costs $15 .
18 
d. Within 12 minutes after the UC sent proof of payment and requested access 
to these channels, THZ Admin granted the UC access to all five channels by sending the UC links 
to each paid channel on Telegram.  Below is a screenshot 
of the chat between THZ Admin and the 
UC, which was taken 
by the UC. The username of the UC, the names and monikers of victims, 
and portions 
of the links have been redacted. 
18 
Based on my review of open-source news a1ticles, I know that when Victim-8 was 23 years old, 
an unknown individual hacked Victim-S's email address,  changed her iCloud password, and 
subsequently leaked sexually explicit videos Victim-8 had made with a sexual paitner when she 
was 
18 years old. There is no evidence to suggest that KYLE WHITE, the defendant, hacked 
Victim-S's email address. In addition to The Ho Zone, Victim-S's intimate videos were posted on 
pornographic websites without her consent. 
20 

THZ Admin (Check Bio) 
• 
18 September 2023 
Hi Just 
sent you a payment for S 135 
can you send me 
--S25 
• $25 
--$25 
• $45 
• $15 
ca::a 
THZ Admin (Check Bio) 
., https://t.me/+is 
-https://r.me/+4E 
https://r.
me/+M 
-https:// r.me/+J 
https://r.me/+N 
TY 
14:24 
1.i:24 
14:24 
1~:24 
14:24 
1
4:24 
14:24 
1 :26 
14:35 
14:35 
14:36 
14:35 
14:36 
14:37 
e. Based on my review of the electronic contents of the White Phone, I know 
that this two-person Telegram message between the UC and THZ Admin 
is on the White Phone. 
The chats the 
UC received from the THZ Admin user appear in the message thread on the White 
Phone as being sent by Telegram user "5242630950." As discussed above 
in Paragraphs 20 and 
21, "5242630950" is  a Telegram identifier associated with WHITE. 
23. Based on my review 
of the Ho Zone Telegram channel featuring Minor Victim-I 
(the "Minor Victim-I Channel"), I know that on or about September 18, 2023, the Minor Victim-
1 Channel had 
98 subscribers, which means that 98 people at that time had access to the child 
pornography depicted on the channel. The Minor Victim-I Channel was created on or about 
December 
3, 2022. 
a. The content on the Minor Victim-I Channel depicts a  minor girl (Minor 
Victim-I) and a minor boy ("Minor Victim-4") engaging in sex acts with each other. The content 
also depicts Minor Victim-I engaging in sex acts with herself. 
21 

b. Based on conversations I  have had with other law enforcement officers 
familiar with the content 
on the Minor Victim-I Channel, I know that at  the time the content was 
created, Minor Victim-I was approximately 
15 years old, and Minor Victim-4 was her younger 
brother, who was approximately 
11 years old. 
24. Based 
on my review of the Ho Zone Telegram channel featuring Minor Victim-2 
(the "Minor Victim-2 Channel"), I know that on or about September 18, 2023, the Minor Victim-
2  Channel had 
41 subscribers, which means that 41 people at that time had access to the child 
pornography depicted 
on the channel. The Minor Victim-2 Channel was created on or about 
October 13, 2022. 
a. The content on the Minor Victim-2 Channel depicts a  minor girl (Minor 
Victim-2) engaging in sex acts with herself. 
b. Based on conversations I  have had with other law enforcement officers 
familiar with the content on the Minor Victim-2 Channel, 
I know that at the time the content was 
created, Minor Victim-2 was approximately 
14 to 16 years old. 
25. Based on my review 
of the Ho Zone Telegram channel featuring Minor Victim-3 
(the "Minor Victim-3 Channel"), I know that 
on or about September 18, 2023, the Minor Victim-
3  Channel had 
80 subscribers, which means that 80 people at that time had access to the child 
pornography depicted on the channel. The Minor Victim-3 Channel was created on or about 
September 29, 2022. 
a. The content on the Minor Victim-3 Channel depicts a  minor girl (Minor 
Victim-3) performing sex acts on a minor boy ("Minor Victim-5"). The content also depicts Minor 
Victim-3 engaging 
in sex acts with herself. 
b. Based on conversations I  have had with other law enforcement officers 
familiar with the content 
on the Minor Victim-3 Channel, I know that at the time the content was 
created, Minor Victim-3 was approximately 
15 years old, and Minor Victim-5 was her younger 
brother, who was approximately 
13 years old. 
KYLE WIDTE Knowingly Advertised and Sold Child Pornography 
26. As described below, I  believe KYLE WHITE, the defendant, knew that what he 
advertised, sold, and gave people access to on The Ho Zone included child pornography. 
27. As described fmiher above in Paragraph 10( c ),  the description 
.on The Ho Zone of 
the Minor Victim-3 Channel includes the following: "Blackmailed into getting fingered by and 
sucking her little brother's dick." I believe this reference to "little brother" indicates that WHITE 
has viewed this content and believes it to show a minor male child engaging in sexually explicit 
conduct. 
28. Based on 
my participation in this investigation and my paiiicipation in the 
execution of the WDKY Warrant, I know that during tμe execution of the WDKY Warrant, the 
FBI seized a laptop from the residence 
of KYLE WHITE, the defendant. A one-terabyte external 
drive was plugged in to the laptop at the time 
of the search (the "White Drive"). 
22 

29. Based on my review of the electronic contents of the White Drive, I have learned, 
among other things, the following: 
a. The White Drive contains a  subfolder called "CoolPpl." The "CoolPpl" 
folder contains approximately 3,773 files, which consist largely 
of videos. 
b. Although I  did not open every file in the "CoolPpl" folder, I  opened a 
sampling 
of approximately 100 files. Each file that I opened appeared to contain sexually explicit 
depictions 
of minors.  Some files contained videos and images of individuals who appeared to be 
teenagers and could potentially 
be over 18 years of age, but many of the files appeared to contain 
obvious, prepubescent minors, including toddlers. 
c. Some of the file names in the " CoolPpl" folder are nondescript, but many 
of them suggest that the files contain sexually explicit depictions of minors.   For instance, just 
some 
of the file names include: "teen vids," "2 white tods,"
19 
"adolescent," "cp nifia mamanda a 
hombre adolescente,"
20 
"my granddaughter," and "mom and son first try." 
30. Based on my participation in the review 
of the electronic contents of the White 
Phone, I have learned, among other things, the following: 
a. The White Phone contains a note that was created on or about April 8, 2023 
and modified on June 14, 2023. In relevant part, the note reads: 
[T]hroughout the vid 
... 
say Kyle everytime [sic] (most important pa1t) . ... 
Tell me to cum FOR (not on) your tiny little 15 yr old boobies and body and shake your 
ass for me .
... 
Say "we love you kyle" then make out and then "say we love you soo much kyle" 
Suck on each other's nipples 
.... 
But most imp01tantly I want you to say my name ALOT [sic] in the vids. Say things like: 
Cum for me/us Kyle 
Jerk 
off for me/us Kyle 
You like that/my titties/pussy Kyle? 
Ur such a good boy Kyle 
I love you Kyle
21 
19 
I believe "tods" is a reference to the word "toddlers." 
20 
According to Google Translate, this Spanish phrase roughly translates to "cp girl blowjob teen 
man." Even assuming that KYLE WHITE, the defendant, has 
no knowledge of Spanish and did 
not consult Google Translate or another translation service, the Spanish word for "adolescent" 
is 
only one letter different from the English word. Moreover, this file name contains the words "cp," 
which 
is a commonly known abbreviation for "child pornography." 
21 
Based on my training and experience, I  believe that this appears to be a  script or instructions 
given by KYLE WHITE, the defendant, to a minor or multiple minors directing the minor/minors 
to create a sexually explicit video. 
To date, law enforcement has not recovered such a video. 
23 

b. On or about December 26, 2022, WHITE exchanged the following 
messages on Telegram with another Telegram user ("Individual-I" or "Indiv-1 ") : 
Indiv-1: 
WHITE: 
Indiv-1: 
WHITE: 
Indiv-1: 
WHITE: 
Indiv-1: 
WHITE: 
Indiv-1: 
WHITE: 
You have anyone like [Minor Victim-6]? 
U mean UA girls? 
Ide just blondes with good videos 
IfUA would be better 
Got anything like that? 
Yeah alot [sic] 
U seen [Minor Victim-7] already? 
No 
What's she look like? 
[Telegram link] 
How old 
is [Minor Victim-7]? 
She was 
16 in those vids I think. I just say 18 so ppl don't report it 
If you have anyone else similar let me know and I'll buy those too 
I got this girl too. She only has like 5 vids 
[Image file] 
c. Between on or about January 6, 2023 and January 7, 2023, WHITE and 
Individual-I exchanged the following messages on Telegram: 
Indiv-1: 
WHITE: 
Indiv-1: 
WHITE: 
Got any new UA? 
There's some 
in here 
[Telegram link] 
Also word 
of the wise keep UA off your main pages 
Yeah 
ik. 
22 
That's why the Most popular one
23 
got taken down. I'm making 
a secret private channel for it now 
.... 
d. On or about February 20, 2023, WHITE exchanged the following messages 
on Telegram with another Telegram user ("Individual-2" or "Indiv-2"): 
Indiv-2: 
WHITE: 
Indiv-2: 
WHITE: 
How old 
is that [Minor Victim-8] girl? 
[Telegram link 
to channel of Minor Victim-7] 
Older than her lol 
Yea I did NOT expect [Minor Victim-
7] to be that age 
Lol i think [Minor Victim-8] 
is like 17 
22 
I believe "ik" is an abbreviation for "I know." 
23 
I believe this is a reference to The Ho Zone "MOST POPULAR GIRLS LISTS" channel. 
24 

e. On or about April 11, 2023, WHITE exchanged the following messages on 
Telegram with another Telegram user ("Individual-3" or "Indiv-3"
): 
Indiv-3: 
WHITE: 
Indiv-3: 
WHITE: 
Indiv-3: 
WHITE: 
Indiv-3: 
WHITE: 
Indiv-
3: 
WHITE: 
Btw please just say you won' t  send me something 
if anything I  ask for is 
UA.   I don't wanna know,  i just I  don't wa1ma look at it. That's why I 
dropped [Minor Victim-9] cause I  didn't know and felt weird.  Other teen 
leaks
24 
gives me anxiety Lmao 
Ight I gotchu 
lol 
There's rlly no way of knowing how old the girls are in the leaks tbh 
Even 
if Ik their current age, the content could be from 3 yrs ago for all Ik 
As long as it's nothing guaranteed UA I'm good. I'm not cool w that jazz 
so just don't send it my way and I'll appreciate you 
Gotchu 
Just avoid that black market
25 
channel I made 
Good 
to know g01ma avoid that one 
Just gonna avoid that channel from this point on honestly 
Prob a good idea lol 
I don't like sellin that stuff but ppl keep buyin it 
so it's whatever I guess as 
long 
as their not like actual kids 
Big dog honestly, the money ain' t w01ih it for that type 
of shit 
That' s big time jail. 
Not just tax evasion type shit 
Tax evasion you 
do okay in jail, chomo
26 
shit you don't make it  out 
Yeah ik. I  rlly need to stop but every time I  goto [sic] to delete them 
someone buys another and 
I'm like shit 
Prob made over $10k 
off the girls in that black market 
Brother just delete the channels · 
.... 
Those are folk you don't wanna be associated with. It'll get you into deep 
shit. 
Like yeah it'll lose you some money but you're not committing "get killed" 
felonies 
Yeah ik I will soon. It' s just easier said than done givin up $1,000's 
How risky even is  it tho? Like they gonna lock me up for selling some 
16 
yr olds nudes on here? There's tons of ppl postin the same shit. I'm sure 
the feds got more important things 
to won-y abt lol 
24 
I believe this is a reference to The Ho Zone Other Teen (18+) Leaks channel. 
25 
I believe this is a reference to The Ho Zone THZ Black Market channel. 
26 
Individual-3 explains later in this chat thread that "chomo" means "[p ]edo shit. Stands for 
child molester but it  doesn't just mean kid diddler[.]" 
25 

Indiv-3: 
WHITE: 
Indiv-3: 
WHITE: 
Indiv-3: 
WHITE: 
[L ]uckily I never put watermarks or anything on them like some dumbasses 
did 
so no one will be able to trace it back to me later 
Like where 
do I draw the line tho? U sayinjust sell ONLY from OF?
27 
Cuz 
that'd cut my earnings in half 
Nah bro leaks are fine 18+ 
to your knowledge. As long as you're pretty 
sure they're solid don't worry about 
it. 
Then I can use the ole "officer I swear I thought she was 18" defense lmao 
As long 
as you genuinely believe it and do your due diligence to make sure 
It's still gotta be illegal for me to sell em without their consent even 
if they 
are 
18 tho, right? Like I'm breakin the law regardless 
It 
is but it isn't get murdered in jail illegal 
I'll take em down from the market but I'm not gonna delete the actual 
channels cuz ppl already paid for those 
As long 
as I'm not advertising them publicly no one will know they even 
exist 
f. On or about April 12, 2023, WHITE exchanged the following messages on 
Telegram with another Telegram user ("Individual-4" or "Indiv-4"
): 
WHITE: 
Indiv-4: 
WHITE: 
Indiv-4: 
WHITE: 
You talking abt the girl I posted? She was def underage 
?? 
Which girl? 
[Telegram link] 
Oh I'm not in blackmarket [sic] anymore. I think you gotta invite me 
[Telegram link] 
g. On or about April 13, 2023, WHITE exchanged the following messages on 
Telegram with another Telegram user ("Individual-5" or "Indiv-5"): 
Indiv-5: 
WHITE: 
Indiv-5: 
WHITE: 
Indiv-5: 
WHITE: 
Indiv-5: 
Is the [Minor Victim-3] set really blackmail videos and her younger 
brother? 
If [sic] come across a  few that say blackmail but they weren't. 
Just wanna make sure their [sic] real and thats really her brother before I 
pay for it 
Oh yeah she was deffblackmailed and it's deff her brother. I saw a family 
portrait 
Oh shit, where is the family portrait and how old was he 
[Image file] 
Shit that's crazy, how old was her brother 
No clue but 
he looks pretty young 
Do you have anymore blackmail sets besides the ones already listed 
27 
I believe "OF" is an abbreviation for Only Fans. 
26 

WHITE: Yeah a bunch 
Indiv-5: And what about more sister and brother 
WHITE: Might have a couple somewhere. Thise [sic] are harder 
to find 
On or about August 
3, 2023, WHITE notified Individual-5, "I got more" blackmail and/or 
sister and brother videos. 
h. On or about April 28, 2023, WHITE sent the following message on 
Telegram to Individual-4, in relevant part: "No UA girl has ended 
up on [Website-I] be of me and 
I only sold like 
15 of em not 150." 
i. On or about June 22, 2023, WHITE exchanged the following messages on 
Telegram with another Telegram user ("Individual-6" or "Indiv-6"): 
Indiv-6: 
WHITE: 
Is the [Minor Victim-IO] sextape actuslly [sic] her 
And how old 
is she 
Yeah and idk her tiktok bio days [sic] 
18 but she says she's 15 in one of the 
vids i think 
j. On or about June 27, 2023, Individual-4 sent the following message on 
Telegram to WHITE: "Well you ran  a reasonably successful online emporium. That took some 
guts[.]" WHITE responded: 
"I've made over 300k in the first year. That's an understatement 
lol[.]" 
k. Between on or about July 24, 2023 and July 26, 2023, after an individual 
familiar to WHITE and Individual-4 was arrested by the FBI, WHITE and Individual-4 exchanged 
the following messages on Telegram: 
WHITE: 
Indiv-4: 
WHITE: 
Indiv-4: 
WHITE: 
Indiv-4: 
I'd just have to get a good lawyer but there's no real evidence I sold CP or 
did anything illegal 
You might get exposed to a civil suit 
THZ after dark or whatever 
is iffy though 
I'm like 95% sure some of the girls like [Minor Victim-7] have UA shit 
Yeah put [sic] can u prove that that's the case and that ik abt it in a comi 
of law 
I think 
so. You had a THZ cashapp at one time 
trust me, you're not in a precarious state legally, but you wouldn't 
be 
bulletproofed against criminal proceedings 
Ifhe actually does alert the FBI to me that could be bad tho 
Is there anything 
in there abt how the FBI caught him that i should try to 
avoid doing? 
hmm. 
I'm not sure what it was that made the agents target him 
27 

WHITE: 
Indiv-4: 
WHITE: 
Indiv-4: 
. WHITE: 
Indiv-4: 
WHITE: 
Indiv-4: 
WHITE: 
Indiv-4: 
WHITE: 
Indiv-4: 
WHITE: 
its good you are crypto only 
I'm not tho 
t.me/nsfttpaymentguide 
I thought you dropped the other methods 
IDK man, how many times have I said itm's [sic] imp011ant to interview 
buyers 
I'm sure I could have spotted those agents 
I got way too many 
to do that 
IDK what to tell you. 
It's possible you could get pinched for selling UA 
sets 
... 
If you want to sell on cashapp you have to get rid of the UA 
I 
don't use cashapp anymore 
Apple Pay and Zelle are equally 
if not more traceable 
I try to keep a pretty low profile.  Only like 9k subs
28 
in the main market. 
Doubt I'll draw any law enforcement attention unless someone tips them 
off. .. 
What 
if I post sum like "Disclaimer: As far as I know all of these girls are 
atleast [sic] 
18. If you' re aware of any that aren' t pls lmk"
29 
• 
Feel like that might protect me 
Ehhhh in a com1 
of law that would be tough to prove that you had no idea 
Tough to prove that I DID tho too 
You have a video 
of [Minor Victim-I I] where she says shes 14 
like it's not that easy to wriggle out of it on a technicality 
Not in the main market tho 
The UA sets could ruin your life 
if those same undercover agents had hit 
you 
up 
Yeah fuck i should just remove em 
Just sucks cuz those sell alot [sic] lol 
Also I meant that msg would probably tum 
off any feds too. unless they 
somehow recognize the girls and know they're under 18, they' d prob 
just 
take my word for it and move on 
28 
I believe "subs" refers to Telegram subscribers. 
29 
WHITE sent this message to Individual-4 on or about July 26, 2023. As described above in 
Paragraph 9(e), 
on or about July 30, 2023, THZ Admin added a "Legal Disclaimer" to the "Other 
Teen (18+) Leaks" channel claiming that "[t]hese girls are all 18+ 
as far as I know." 
28 

WHEREFORE, I  respectfully request that a  warrant be issued for the arrest of KYLE 
WHITE, the defendant, and that he be arrested, and imprisoned or bailed, as the  case may be. 
'/4 ~-
A~AZA 
Special ent 
Federal Bureau oflnvestigation 
Sworn to before me this& day 
of January, 2024. 
~ t!IZl 
THE HONORABLE KATHARINE H . PARJ(ER 
United States Magistrate Judge 
Southern Disti•ict 
of New York 
29