Case 8:13-cr-00472-RWT Document 13 Filed 09/11/13 Page 1 of 8 FILED

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LMFffMS: USAO 20 I3R00607

DISlTdCT Of ;1AIr(LMH)
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND 1013

lJ.S. DISTRICT COURT

UNITED STATES OF AMERICA

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WILLIAM GAZAFI, Defendant

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CRIMINAL

NO.

RWT1 3 CR'0 472

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(Sexual Exploitation of Minor for Purpose of Producing Child Pornography, 18 U.S.c. ~ 2251(a); Forfeiture, 18 U.S.c. ~ 2253)

INDICTMENT COUNT ONE The Grand Jury for the District of Maryland charges that: Between on or about April 3, 2012 and on or about April 7, 2012, in the District of Maryland and elsewhere, the defendant, WILLIAM GAZAFI,

did knowingly employ, use, persuade, induce, entice, and coerce a minor to engage in sexually explicit conduct as defined in Title 18, United States Code, Section 2256(2) for the purpose of producing a visual depiction of such conduct - including but not limited to images depicting a prepubescent female (a) restrained at the ankle with handculTs with the soles of her feet together and her legs spread apart, and (b) bound with restraints on her ankles connected through her underwear to display her genitalia - that was produced and transmitted using materials that had been mailed, shipped, and transported in and affecting interstate and foreign commerce by any means, including by computer.

18 U.S.c.

S 225 I(a)

Case 8:13-cr-00472-RWT Document 13 Filed 09/11/13 Page 2 of 8

COUNT TWO The Grand Jury for the District of Maryland further charges that: On or about June 16,2012, in the District of Maryland and elsewhere, the defendant,

WILLIAM GAZAFI,
did knowingly employ, use, persuade, induce, entice, and coerce a minor to engage in sexually explicit conduct as defined in Title 18, United States Code, Section 2256(2) for the purpose of producing a visual depiction of such conduct - including but not limited to an image that depicts a seven-year-old female, lying on a bed exposing her genitalia - that was produced and transmitted using materials that had been mailed, shipped, and transported in and affecting interstate and foreign commerce by any means, including by computer.

18 U.S.C.

S 2251 (a)

Case 8:13-cr-00472-RWT Document 13 Filed 09/11/13 Page 3 of 8

COUNT THREE The Grand Jury for the District of Maryland further charges that: On or about June 24, 2012, in the District of Maryland and elsewhere, the defendant, WILLIAM GAZAFI,

did knowingly employ, use, persuade, induce, entice, and coerce a minor to engage in sexually explicit conduct as defined in Title 18, United States Code, Section 2256(2) for the purpose of producing a visual depiction of such conduct - including but not limited to five images that depict a toddler female with defendant's hand pulling aside her underwear exposing her genitalia - that was produced and transmitted using materials that had been mailed, shipped, and transported in and affecting interstate and foreign commerce by any means, including by computer.

18 U.S.C.

S 225 I(a)

Case 8:13-cr-00472-RWT Document 13 Filed 09/11/13 Page 4 of 8

COUNT FOUR The Grand Jury for the District of Maryland further charges that: On or about July 4,2012, in the District of Maryland and elsewhere, the defendant, WILLIAM GAZAFI, did knowingly employ, use, persuade, induce, entice, and coerce a minor to engage in sexually explicit conduct as defined in Title 18, United States Code, Section 2256(2) for the purpose of producing a visual depiction of such conduct - including but not limited to a video that depicts the defendant holding his penis above the genitalia of a five- to six-month old baby, while exposing her genitalia and placing her feet on his erect penis - that was produced and transmitted using materials that had been mailed, shipped, and transported in and affecting interstate and foreign commerce by any means, including by computer.

18 U.S.C.

S 2251 (a)

Case 8:13-cr-00472-RWT Document 13 Filed 09/11/13 Page 5 of 8

COUNT FIVE The Grand Jury for the District of Maryland further charges that: Between on or about August 1,2012 and on or about June 1,2013, in the District of Maryland and elsewhere, the defendant, WILLIAM GAZAFI, did knowingly employ, use, persuade, induce, entice, and coerce a minor to engage in sexually explicit conduct as defined in Title 18, United States Code, Section 2256(2) for the purpose of producing a visual depiction of such conduct - including but not limited to a video file that depicts the defendant using his feet to rub the buttocks of and expose the genitalia of a seven-year-old female - that was produced and transmitted using materials that had been mailed, shipped, and transported in and affecting interstate and foreign commerce by any means, including by computer.

18 U.S.C.

S 225 1(a)

Case 8:13-cr-00472-RWT Document 13 Filed 09/11/13 Page 6 of 8

COUNT SIX The Grand Jury for the District of Maryland further charges that: Between on or about April 14,2013 and on or about April 19,2013, Maryland and elsewhere, the defendant, in the District of

WILLIAM GAZAFI,
did knowingly employ, use, persuade, induce, entice, and coerce a minor to engage in sexually explicit conduct as defined in Title 18, United States Code, Section 2256(2) for the purpose of producing a visual depiction of such conduct - including but not limited to two images that depict the defendant attempting to anally penetrate a toddler female - that was produced and transmitted using materials that had been mailed, shipped, and transported in and affecting interstate and foreign commerce by any means, including by computer.

18 U,S.C,

S 2251 (a)

Case 8:13-cr-00472-RWT Document 13 Filed 09/11/13 Page 7 of 8

FORFEITURE ALLEGATION The Grand Jury for the District of Maryland further finds that: 1. Pursuant to Fed. R. Crim. P. 32.2 notice is hereby given to the defendant that the

United States will seek forfeiture as part of any sentence in accordance with Title 18, United States Code, Section 2253, in the event of the defendant's conviction under Counts One through Six of this Indictment. 2. Pursuant to Title 18, United States Code, Section 2253, upon a conviction of the

offenses set forth in Count One through Six of this Indictment, in violation of Title 18, United States Code, Section 2251(a), the defendant, WILLIAM GAZAFI, shall forfeit to the United States of America: a. Any visual depiction described in Title 18, United States Code, sections 2251,

2251 A, or 2252, or any book, magazine, periodical, film, videotape, or other matter which contains any such visual depiction, which was produced, transported, mailed, shipped or received in violation of Title 18, United States Code, Chapter lID; b. Any property, real or personal, constituting or traceable to gross profits or

other proceeds obtained from the offenses; and e. Any property, real or personal, used or intended to be used to commit or to

promote the commission of the offenses, including and not limited to the residence of 743 Lazy River Road, Lusby, Maryland 20657.

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3.

Ifany of the property described above, as a result of any act or omission

of the defendant: a. b. c. d. c. cannot be located upon the exercise of due diligence; has been transferred or sold to, or deposited with, a third party; has been placed beyond the jurisdiction of the court; has becn substantially diminished in value; or has been commingled with other property which cannot be divided without difficulty, the United States of America shall be entitled to forfeiture of substitute property pursuant to Title 21, United States Code, Section 853(p), as incorporated by Title 18, United States Code, Section 2253(b).

18 U.S.C. ~ 2253

Rod . Rosenstein United States Attorney

A TRUE BILL:

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