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Case 7:15-mj-00394-DC Document 1 Filed 09/28/15 Page 1 of 4

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A0 91 (Rev. 08/09) Criminal Complaint

UNITED STATES DISTRICT COURT

SEP 2 8

for the

2015

Western District of Texas

United States of America

V.

Gerald Dean Campbell

Case No.

00 3

CL

)
)
)

Defendant(s)

CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best of my knowledge and belief.

On or about the date(s) of

District of

Western

Code Section
18 USC 2423c

in the county of

2001 through 2003

Texas

Ector

the defendant(s) violated:

Offense Description
Engaging in illicit sexual conduct in foriegn places.

This criminal complaint is based on these facts:

See attachment titled "Affidavit"

( Continued on the attached sheet.

,/7Ciant'ssiatur
Joshua

L.

Howard, Special Agent HSl

Printed name and title

Sworn to before me and signed in my presence.

Date:
City and state:

09/28/2015
Alpine, Texas
Printed name and title

in the

Case 7:15-mj-00394-DC Document 1 Filed 09/28/15 Page 2 of 4

AFFIDAVIT

Affiant is a Special Agent (SA) with over 9 years' experience with the
United States Department of Homeland Security (DHS). I am assigned to
the Midland, Texas Office of Homeland Security Investigations. I have
investigated both criminal and administrative matters involving foreign
nationals and citizens of the United States. I have successfully completed
the Immigration Officer Basic and advanced training courses for
Immigration Enforcement Agents, the Criminal Investigator Training
Program, and the Homeland Security Investigations (HSI) Special Agent
Training Program at the Federal Law Enforcement Training Center (FLETC)
at Glynco, Georgia.
Facts included in this affidavit were gathered either by me, or by other
cooperating local, county, state, or federal law enforcement agencies. These
facts may not represent all of the facts gathered to date, but only those
necessary to establish probable cause in this matter.
This affidavit is made in support of a criminal complaint charging Gerald
Dean CAMPBELL with Engaging in Illicit Sexual Conduct in Foreign
Places in violation of Title 18 United States Code, Section 2423(c).

Your affiant being duly sworn, deposes and says:

On June 5, 2014, your affiant received information originally reported to the
HSI Tip-line Unit regarding Gerald Dean CAMBPELL who is from the
United States and currently residing in Odessa, Texas. Information given at
that time indicated CAMPBELL travelled to Malawi where he worked at the
Victory Children's Children Home (VCCH) and may have sexually abused
five minor boys at this orphanage.
A subsequent joint investigation conducted by HSI Midland, Texas and HSI
Pretoria, South Africa revealed CAMPBELL did work as the General
Manager (GM) at VCCH in Thyolo District, Malawi starting in 1997. In this
position CAMBPELL is reported to have been in charge of overseeing the
welfare of the children at this orphanage, as well as the person in charge of
overseeing the staff assisting in the daily operations.

Case 7:15-mj-00394-DC Document 1 Filed 09/28/15 Page 3 of 4

On September 25, 2015, CAMPBELL admitted he had Minor Victim 1

perform oral sex on him by putting his penis in Minor Victim l's mouth.
CAMPBELL ejaculated on Minor Victim l's belly and estimated this
occurred about every other week for approximately eight months to a year
while Minor Victim 1 slept at his house. CAMPBELL also admitted he
fondled with Minor Victim l's penis and had Minor Victim 1 fondle his
penis. CAMPBELL admitted he "took advantage of him," and stated that he
did it "because I knew I could." He also stated, "Who would believe him?"
CAMPBELL estimated Minor Victim l's age to be between 10 to 14 years
old at the time he sexually abused him. CAMPBELL also admitted to
abusing Minor Victim 2, who he estimated to be approximately 13 years old
when he touched Minor Victim 2's penis and placed Minor Victim 2's penis
in his mouth while Minor Victim 2 slept. CAMPBELL admitted that during
the course of working at VCCH, he had some form of sexual contact with a
total of eleven orphans, and this contact included oral sex and/or the
fondling of genital area of him and/or the orphan. Of the eleven named,
CAMPBELL believed eight were under the age of 18 years old at the time of
the sexual contact. CAMPBELL stated that he was attracted to certain boys,
and said "I took advantage of them; that's what I did. There's no excuse."
CAMPBELL also admitted he was wrong and knew he was "in charge" at
this orphanage; he also explained he could "buy" his way out of it.
CAMPBELL further stated two of the individuals he identified as being
victims of his sexual exploitation received money and/or things of value
from CAMPBELL to keep them from disclosing the abuse.

On June 24, 2015, Special Agent Marielle Schultz interviewed Minor Victim
1 who provided his date of birth to be xx/xx/1994. He later provided
investigators with a Malawian passport bearing the same information.
Minor Victim 1 reported going to VCCH in 1999 after he lost both of his
parents. In 2001, a Minor Victim 1 reported sleeping at CAMPBELL's first
house for approximately six months, and then two months at his second
house. During this time, Minor Victim 1 reported that CAMPBELL forced
him to "perform him sexually." Minor Victim 1 slept naked in the bed with
CAMPBELL for eight months, and the sexual activity started within two
weeks of his being released from the hospital. Because he was sick,
CAMPBELL helped him take a shower. Without permission CAMPBELL
started touching Minor Victim l's penis and "balls" with both of his hands
in the shower. Later CAMPBELL performed oral sex on Minor Victim 1
and forced Minor Victim 1 to perform oral sex on him while ejaculating in

Case 7:15-mj-00394-DC Document 1 Filed 09/28/15 Page 4 of 4

his mouth. Oral sex happened on a nightly basis over the course of eight
months. On one occasion CAMPBELL attempted to anally penetrate Minor
Victim l's anus with his penis, but Minor Victim 1 said he was too small for
CAMPBELL to complete the act. Minor Victim 1 also reports CAMPBELL
never used protection.

Information provided by the former VCCH Board Member and co-founder

to SA Schultz indicated that on or about August 17, 2009, he received
negative news from Malawi that some of the children accused CAMPBELL
of "immoral sexual behavior". CAMPBELL resigned from VCCH in
September 2009 after such reports.
Your Affiant uses the above facts to establish probable cause for a violation
of Title 18, United States Code 2423(c)., Engaging in Illicit Sexual Conduct
in a Foreign Place.
The aforementioned statutes have a maximum penalty of life in prison.

/hua L. Howard
Special Agent, Homeland Security Investigations

Sworn to and subscribed before me on

This.2 bDay of Sept

2015

B. Dwight

United States Magistrate Judge