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Case 1:12-mj-01100-KMT Document 1 Filed 07/24/12 USDC Colorado Page 1 of 2 44444444444444444444444444444444444444444444444444444444444444444

United States District Court
DISTRICT OF COLORADO UNITED STATES OF AMERICA v. DAVID PAUL MOE CRIMINAL COMPLAINT CASE NUMBER: 12-mj-01100-KMT

I, the undersigned complainant, being duly sworn, state the following is true and correct to the best of myknowledge and belief: COUNT ONE On or about May 4, 2012, in the State and District of Colorado, DAVID PAUL MOE, defendant herein, knowingly distributed and attempted to distribute child pornography, as defined in Title 18, United States Code, Section 2256(8)(A), that has been mailed, and, using any means and facility of interstate and foreign commerce, shipped and transported in and affectinginterstate and foreign commerce by any means, including by computer. All in violation of Title 18, United States Code, Section 2252A(a)(2) and (b)(1). COUNT TWO On or about July 24, 2012, in the State and District of Colorado, DAVID PAUL MOE, defendant herein, did knowingly possess any computer disk and other material that contained an image of child pornography, as defined in Title 18, United StatesCode, Section 2256(8)(A), that has been mailed, and shipped and transported in interstate and foreign commerce by any means, including by computer, and that was produced using materials that have been mailed, and shipped and transported in interstate and foreign commerce by any means, including by computer. All in violation of Title 18, United States Code, Section 2252A(a)(5)(B) and (b)(2). // // //// //

Case 1:12-mj-01100-KMT Document 1 Filed 07/24/12 USDC Colorado Page 2 of 2 I further state that I am a Special Agent with Immigration and Customs Enforcement (ICE) Homeland Security Investigations (HSI) and that this complaint is based on the following facts: see Affidavit attached hereto and herein incorporated by reference.

Continued on the attached sheet and made a part hereof:__X_ Yes

____ No

_

s/Melissa Coffey_______________________

Signature of Complainant

Sworn to before me
Jul 24, 2012 6:33 pm
Date at Denver, Colorado City and State

Kathleen M. Tafoya United States Magistrate Judge
UNITED STATES MAGISTRATE JUDGE Name and Title of Judicial Officer _ _____________________________ ______________ _____________________________________________________________ _ Signature of Judicial Officer

Case 1:12-mj-01100-KMT Document 1-1 Filed 07/24/12 USDC Colorado Page 1 of 8 AFFIDAVIT I, Special Agent Melissa Coffey of United States Immigration and Customs Enforcement (ICE) Homeland Security Investigations (HSI), being duly sworn, hereby depose and state that the following is true to the best of my information, knowledge and belief: INTRODUCTIONAND AGENT BACKROUND 1. I am assigned to the Special Agent in Charge (SAC), Denver, Colorado. I have been so employed since July, 2006. I have successfully completed the Criminal Investigator Training Program and Special Agent Training Program at the Federal Law Enforcement Training Center in Glynco, Georgia. Prior to July, 2006, I was employed by U.S. Customs and Border Protection (and a predecessoragency, the Immigration and Naturalization Service (INS)) for over three (3) years. I have a Bachelor of Arts degree in Criminal Justice. As part of my duties, I investigate criminal violations relating to child exploitation and child pornography including violations pertaining to the illegal production, distribution, receipt and possession of child pornography, in violation of Title 18, UnitedStates Code, Sections 2252 and 2252A. I have received training and instruction in the field of investigation of child pornography and have had the opportunity to participate in investigations relating to the sexual exploitation of children. As part of my training and experience, I have reviewed images containing child pornography in a variety of formats (such as digital still images and video...