Affidavit in Support of Criminal Complaint — No. 2:24-mj-00231 (Dkt. 1-1, S.D. Ohio)

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An affidavit filed April 30, 2024 as Document 1-1 in United States v. Jason Dawson, Case No. 2:24-mj-231, in the U.S. District Court for the Southern District of Ohio, Eastern Division. It is sworn by Joseph Smith, a Task Force Officer with Homeland Security Investigations, in support of a criminal complaint to arrest Dawson for violations of Title 18 United States Code §§ 2251, 2252 and 2252A, covering the sexual exploitation of a minor and the distribution, receipt or possession of child pornography. The affidavit was sworn before a United States Magistrate Judge on April 30, 2024.

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Case: 2:24-mj-00231-CMV Doc #: 1-1 Filed: 04/30/24 Page: 1 of 3 PAGEID #: 2

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF OHIO

EASTERN DIVISION
IN THE MATTER OF: )
)
United States of America, ) Case No: 2:24-mj-231
Vv. )
)
Jason Dawson )
2009 Darbywine Drive ) MAGISTRATE JUDGE: Vascura
Charlotte, North Carolina 28216 )

AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT
I, Joseph Smith (Your Affiant), a Task Force Officer (TFO) with Homeland Security

Investigations (HSI), of the United States Department of Homeland Security (DHS), being duly
sworn, hereby depose and state:

INTRODUCTION

I, HSI TFO Joseph Smith (your affiant), make this affidavit in support of a criminal
complaint to arrest Jason DAWSON for violations of Title 18 United States Code §§ 2251,
2252, and 2252A — the sexual exploitation of a minor and the distribution, receipt, and/or
possession of child pornography. The statements contained in this affidavit are based in part
on information and analysis provided by law enforcement agents; written reports about this
and other investigations that I have received, and your affiant’s personal knowledge and
finding during the investigation. Since this affidavit is being submitted for the limited
purpose of securing a criminal complaint and arrest warrant your affiant did not include each
and every fact known concerning this investigation. Your affiant did not withhold any
information or evidence that would negate probable cause. Your affiant set forth only the
facts that are believed to be necessary to establish probable cause that DAWSON committed
the violations listed above.

I am a Detective with the Franklin County Sheriffs Office (FCSO) and have been a Task
Force Officer (TFO) with Homeland Security Investigations (HSI) since March of 2023. I
am currently assigned to the Internet Crimes Against Children Task Force. I am primarily
responsible for investigating internet crimes against children, including child pornography
offenses and the online exploitation of children.

During my career as a TFO, I have led and participated in various state and federal
investigations involving computer-related offenses. I have executed numerous search
warrants, including those involving searches and seizures of computers, digital media,
software, and electronically stored information. I have worked with multiple law
enforcement agencies around the United States, focusing on cyber-terrorism, financial
crimes, and narcotics trafficking in addition to my current role. As part of my duties as a
Task Force Officer, I investigate criminal violations relating to child exploitation and child
pornography violations, including the illegal production, distribution, transmission, receipt,
and possession of child pornography, in violation of 18 U.S.C. §§ 2251, 2252, and 2252A. I

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Case: 2:24-mj-00231-CMV Doc #: 1-1 Filed: 04/30/24 Page: 2 of 3 PAGEID #: 3

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

Prior to joining the FCSO, I received my B.A from The Ohio State University in International
Studies- Security and Intelligence. I have since graduated with distinction receiving my
M.B.A. specializing in fraud and forensic examination from Tiffin University. During my
employment, I have received numerous forensic trainings from the International Society of
Forensic Computer Examiners, private forensic software companies, Internet Crimes
Against Children conferences, and formal and informal training with state and federal
partners. | am the 2023 recipient of the National Center for Missing and Exploited Children
Hero Award.

FACTS SUPPORTING PROBABLE CAUSE

In November of 2023, the Columbus Division of Police (CPD) began an investigation into
DAWSON based on reports made by two females, herein after Jane Doe One (DOB:
5/XX/2004) and Jane Doe Two (DOB: 7/XX/2004). More specifically, Jane Doe One and
Jane Doe Two reported that DAWSON, who was their high school basketball coach, had
engaged in sexual relationships with both Jane Does while they were 16 years old.

On or about November 15, 2023, law enforcement with CPD conducted an interview with
Jane Doe One at her residence. Jane Doe One explained that DAWSON was a teacher at
Worthington Christian High School located at 1485 Lazelle Road in Westerville, Ohio
43081. Jane Doe One had been a student there and DAWSON was both her teacher and
basketball coach. DAWSON would instruct Jane Doe One to meet him in the closet of his
office where he eventually began to have a sexual relationship with Jane Doe One, including
oral and vaginal intercourse. Jane Doe One indicated that DAWSON would sometimes
record their sex acts.

Jane Doe One then provided CPD with text messages between her and DAWSON as well as
a video of her and DAWSON engaged in oral and vaginal intercourse for which Jane Doe
Two indicated she was either 17 or 18 in the video.

Jane Doe One stated she and Jane Doe Two, who were both former students at Worthington
Christian, began conversing and discovered that they both had been having sex with
DAWSON during the same time frame which prompted them to report DAWSON to CPD.

On or about December 19, 2023, law enforcement with CPD interviewed Jane Doe Two at
her residence. Jane Doe Two explained that she met DAWSON her sophomore year at
Worthington Christian High School where she was a 16-year-old student, and he was her
basketball coach. In November of 2020, DAWSON had Jane Doe Two meet him in a
classroom after practice where he kissed her.

Jane Doe Two informed law enforcement that on January 13, 2021, when she was
approximately 16 years of age, she met DAWSON in an apartment complex parking lot
where they had sex in the back of his vehicle. She and DAWSON then continued to engage
in sex acts in his vehicle and in hotel rooms and Jane Doe Two confirmed that DAWSON
sometimes recorded their sex acts. Jane Doe Two provided CPD her phone which contained

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Case: 2:24-mj-00231-CMV Doc #: 1-1 Filed: 04/30/24 Page: 3 of 3 PAGEID #: 4

four videos of her and DAWSON with metadata indicating they were created on or about
November 23, 2021, December 17, 2021, December 20, 2021 and October 3, 2022. In the
videos, Jane Doe Two was filmed by DAWSON performing oral sex on him or having
vaginal intercourse with him in his vehicle and at the time, Jane Doe Two was approximately
sixteen or seventeen years of age.

On or about March 23, 2024, criminal complaints for DAWSON were issued out of Franklin
County, Ohio Municipal Court for violation of the Ohio Revised Code (ORC) Section
2907.03-A9 for Sexual Battery, a felony in the third degree as well as ORC Section
2907.322-Al for Pandering Sexually Oriented Material Involving a Minor, a felony in the
second degree. An accompanying Franklin County arrest warrant for DAWSON was issued
that same day.

On or about March 25, 2024, DAWSON was arrested by law enforcement, to include
personnel from North Carolina as well as CPD. In addition, CPD officers advised
DAWSON of his Miranda warnings and he agreed to speak with them. During the interview,
DAWSON stated he remembered making and sending the videos depicting sex acts between
him and Jane Doe One and him and Jane Doe Two and indicated he knew it was illegal
because he was their coach.

CONCLUSION

Based upon the above information, your affiant submits there is probable cause to believe
Jason DAWSON has committed violations of Title 18 U.S.C. §§ 2251, 2252, and 2252A —
the sexual exploitation of a minor, distribution, receipt, and/or possession of child
pornography. Therefore, your affiant respectfully requests this court to issue a criminal

complaint and arrest warrant.
y La Smith

Task Force Officer
Homeland Security Investigations

Sworn to and subscribed before me this 30th day of April, 2024.

Chelsey M. Vege

Unite
Unite

d States Magistrate Judge
d States District Court
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NiciexDixtkianor PamigK NAKA Southern District of Ohio

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