Case 2:22-mj-01826 Document 1 Filed 11/15/22 Page 1 of 8

Harrell) 22-095
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Defendant(s)

CRIMINAL COMPLAINT
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Code Section Offense Description

18 USC 2252(a)(2) Distribution and attempted distribution of child pornography
18 USC 2252(a)(4)(B) Possession of child pornography

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See Attachment A

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/s/ Samantha Estevez

Complainant’s signature

Samantha Estevez, FBI Special Agent

Printed name and title

6ZRUQWREHIRUHPHDQGVLJQHGLQP\SUHVHQFH

'DWH November 15, 2022 /s/ Honorable Richard A. Lloret

Judge’s signature

&LW\DQGVWDWH Philadelphia, PA Honorable Richard A. Lloret, U.S.M.J.

Printed name and title
 Case 2:22-mj-01826 Document 1 Filed 11/15/22 Page 2 of 8

AFFIDAVIT IN SUPPORT OF ARREST WARRANT

I, Samantha Estevez, a Special Agent with the Federal Bureau of Investigation (FBI),

Philadelphia Division, being duly sworn, depose and state as follows:

1. I have been employed as a Special Agent with the FBI for 13 years and am

currently assigned to the Philadelphia Division's Violent Crimes Against Children Squad. While

employed by the FBI, I have investigated federal criminal violations related to White Collar

Crime, Public Corruption, Civil Rights, Counterintelligence and most recently, Violent Crimes

Against Children. I have gained experience through training at the FBI Academy, and training in

the fields of counterintelligence and criminal law violations, to include the enforcement of

federal child pornography laws. I have received training in the area of child pornography and

child exploitation, and have had the opportunity to observe and review numerous examples of

child pornography (as defined in 18 U.S.C. § 2256) in all forms of media, including computer

media.

2. As a federal agent, I am authorized to investigate violations of laws of the United

States and to execute warrants issued under the authority of the United States.

3. The statements in this Affidavit are based in part on my investigation of this

matter and on information provided by other law enforcement officers. Because this affidavit is

being submitted for the limited purpose of securing an arrest warrant, I have not included each

and every fact known to me concerning this investigation. I have set forth only those facts that I

believe are necessary to establish probable cause to believe that RICHARD KENNETH

WELCH, date of birth April xx, 1995, committed violations of Title 18 U.S.C. § 2252(a), the

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distribution and attempted distribution of child pornography and the possession of child

pornography.

FACTS SUPPORTING PROBABLE CAUSE

4. On November 8, 2021, NCMEC (the National Center for Missing and Exploited

Children) received a CyberTipline Report filed by Kik regarding the account associated with email

address: richardkw95@gmail.com, and screen/user name: wayfarerx. Kik reported that the above-

referenced account distributed 33 files between October 15, 2021 and November 5, 2021

containing apparent child pornography to another user or group of users via private chat

messages. Personnel from Kik did review the files prior to submitting the report.

5. Your Affiant reviewed the 33 files provided by Kik and, in your Affiant’s opinion,

31 of the files depicted child pornography within the meaning of Title 18 USC §2256. The 31

files are of minor girls engaged in sexually explicit conduct, to include intercourse, oral sex and

the lascivious exhibition of the genitals.

6. In addition to the files described above, Kik provided other information pertaining

to the Kik account wayfarerx. Kik records show that the account was created on October 14, 2021,

registered using an iPhone device.

7. Kik also provided the internet protocol (IP) address associated with the files

distributed by the account. The IP address resolves to Verizon. Through investigation, the FBI

determined that the Verizon IP address is subscribed to Jill Welch, the mother of RICHARD

WELCH, at their shared residence at 1xx West Gorgas Lane, Philadelphia, Pennsylvania 19119.

The IP address was assigned to this Verizon account on December 22, 2019 through at least April

2022.

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8. A criminal history check for RICHARD KENNETH WELCH, date of birth April

xx, 1995, revealed a prior conviction on January 23, 2020 for Possession of Child Pornography in

Montgomery County, Pennsylvania, in violation of 18 Pa.C.S. § 6312(d). WELCH was sentenced

to 9-23 months’ incarceration to be followed by 5 years of probation. The conviction

stemmed from an offense that occurred on August 28, 2018 for which WELCH was arrested for

on January 30, 2019. He is a current registered Pennsylvania Megan's Law Tier 1 sex offender.

WELCH’s name and date of birth is consistent with the email address, richardkw95@gmail.com,

which was used to create the Kik account reported to NCMEC in the CyberTipline Report.

9. On November 10, 2022, federal search warrant 22-1699-M was authorized by

United States Magistrate Judge Richard A. Lloret, for the residence of 1xx West Gorgas Lane,

Philadelphia, Pennsylvania 19119 and for the person of RICHARD KENNETH WELCH.

10. On November 15, 2022, the FBI and other law enforcement officers executed this

federal search warrant. RICHARD WELCH and his younger, adult sister were home at the

residence at 1xx West Gorgas Lane at the time of the search warrant.

11. Pursuant to the federal search warrant, law enforcement seized several electronic

devices from the residence, including an Apple iPhone 8 cell phone bearing serial number

F4GWP016JC6N from a nightstand in the bedroom of RICHARD WELCH directly next to his

bed. A forensic preview of this device was conducted at the scene. Among other evidence of user

attribution, the phone contained “selfie” style photographs of WELCH.

12. A review of the iPhone identified, in your Affiant’s opinion, over 300 files, to

include videos and photographs, depicting child pornography, as defined in 18 U.S.C. § 2256.

These files were saved in the iPhone’s internal photo albums. The files depicted minor girls,

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engaged in sexual activity, to include sexual intercourse, oral sex, masturbation and exposing their

genitals, (Count Two – Possession of Child Pornography), including the following image files:

a. a 54-second-long video depicting a prepubescent minor female being anally

penetrated by an adult man’s penis;

b. a 1-minute-long video depicting a prepubescent minor female being anally

penetrated by an adult man’s penis, followed by the male ejaculating and

then digitally penetrating the child’s vagina; and

c. a 30-second-long video depicting an adult man masturbating and then

ejaculating into a prepubescent minor female’s mouth.

13. The forensic preview also revealed that WELCH had the Telegram application

installed on the cell phone. Telegram is an end-to-end encrypted messaging application through

which users can exchange messages, images, and videos with other users via private message and

in groups. Within the Telegram application on WELCH’s phone, there were several conversations

with other users in which WELCH distributed and received images of children engaged in sexually

explicit conduct.

14. For example, on May 12, 2022, WELCH engaged in the following exchange with

another Telegram user (Count One – Distribution and attempted distribution of child

pornography):

WELCH: [sends a video depicting a prepubescent minor female being

vaginally penetrated by adult man’s penis]

Other user: I don’t have any videos to share with you I’m sorry!

WELCH: got pics of yourself?

Other user: No

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WELCH: Lol alright.

[Sends six videos depicting prepubescent females being digitally,
orally, and vaginally/anally penetrated by adult men]

Other user: I think I reallyyyyyy loved the last one, him talking and moaning
and fucking her face really turned me on.

WELCH: Mm I'm glad you liked it.

Other user: thanks for letting me see.

WELCH: I'm feeling generous lol.

[Sends six videos: one video depicts an adult woman having sex
with a minor boy; another depicts an adult woman performing oral
sex on a minor boy; another depicts an adult woman fondling a
minor boy’s penis; one depicts a minor female performing oral sex
on an adult male after which he ejaculates; another depicts a minor
female being anally penetrated by an adult man; and the last video
depicts a woman performing oral sex on a prepubescent minor
girl.]

Other user: Watching her lick that little clit and ass (emoji) her tongue deep in
there and that mom riding her baby soooo hot.

WELCH: Mmm I fucking love pedomoms. so hot hehe. How old are you?

Other user: I'm 16.

WELCH: Oh damn. way younger than I thought lol.

Other user: Yes (emoji) I'm sorry if that bothers you.

WELCH: Not at all. Just makes me wish you did have some pics of yourself
to share (emoji). What are you into other than young?

Other user: I may take some for you. I haven't seen anything I'm not into so I
really do think I'm into everything. It just turns me on knowing
how far people go to pleasure themselves, if that makes sense.

WELCH: Yeah I get it.

Other user: What are you into?

WELCH: Well young girls, of course lol. Some of my other favorites are
incest, rape, public, cumshots and piss.

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Other user: Rape incest and piss cum shots good taste.

WELCH: Hehe I'm glad you agree

[Sends six additional videos depicting apparent child
pornography].

CONCLUSION

15. Based upon the information above, I respectfully submit that there is probable

cause to believe that RICHARD KENNETH WELCH, distributed and attempted to distribute

visual depictions of minors engaging in sexually explicit conduct, in violation of Title 18 U.S.C.

§ 2252(a)(2), and possessed visual depictions of minors engaging in sexually explicit conduct, in

violation of Title 18 U.S.C. § 2252(a)(4)(B), as more fully set forth in Attachment A. Therefore,

I respectfully request that the attached arrest warrant be issued authorizing the arrest of

RICHARD KENNETH WELCH.

/s/ Samantha Estevez

Samantha Estevez
Special Agent
Federal Bureau of Investigation

SWORN TO AND SUBSCRIBED

BEFORE ME THIS 15th DAY
OF November, 2022.

/s/ Honorable Richard A. Lloret

_______________________________________
HONORABLE RICHARD A. LLORET
United States Magistrate Judge

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ATTACHMENT A

Count One – Distribution and Attempted Distribution of Child Pornography – Title 18,
United States Code, Section 2252(a)(2), (b)(1)

On or about May 12, 2022, in the Eastern District of Pennsylvania, defendant RICHARD
KENNETH WELCH knowingly distributed and attempted to distribute visual depictions using
any means and facility of interstate and foreign commerce, and that had been mailed and shipped
and transported in and affecting interstate and foreign commerce by any means, including by
computer, the producing of which involved the user of minors engaged in sexually explicit
conduct, and the visual depictions were of such conduct.

Count Two – Possession of Child Pornography – Title 18, United States Code, Section
2252(a)(4)(B), (b)(2)

On or about November 15, 2022, in the Eastern District of Pennsylvania, defendant RICHARD
KENNETH WELCH knowingly possessed matter, that is, an Apple iPhone 8 cell phone bearing
serial number F4GWP016JC6N, which contained visual depictions that had been shipped and
transported using a means and facility of interstate and foreign commerce, and in and affecting
interstate and foreign commerce. The production of these visual depictions involved the use of
minor engaging in sexually explicit conduct and the visual depictions were of minors engaging in
sexually explicit conduct.