Third Superseding Indictment — U.S. v. Tiwan Robert Bailey, Carrie Roy and David Lee White (S.D. W. Va.)

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A Third Superseding Indictment filed October 16, 2024 as Document 22 in United States of America v. Tiwan Robert Bailey, also known as "Quick," Carrie Roy, also known as "Carrie Ash," and David Lee White, Criminal No. 2:24-cr-00118, in the U.S. District Court for the Southern District of West Virginia, Charleston. Count One alleges that in and around December 2023 Bailey and Roy, aided and abetted by one another, recruited and otherwise dealt in Victim 1 in a venture affecting commerce. Counts Two, Three and Four name Bailey and Victim 2, Victim 3 and Victim 4 respectively. A further count alleges obstruction of the enforcement of 18 U.S.C. § 1591 aided and abetted by White, and Count Six alleges a conspiracy by Bailey and Roy involving Victim 1. A forfeiture section cites 18 U.S.C. § 1594(d).

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Case 2:24-cr-00118 Document 22 Filed 10/16/24 Page 1 of 8 PagelD #: 56

FILED
ho le ae UNITED STATES DISTRICT COURT FOR THE
Ai Eh SOUTHERN DISTRICT OF WEST VIRGINIA OCT | 6 2024
: CHARLESTON GRAND JURY 2023
OCTOBER 16, 2024 SESSION RORY TE Penn i CLEAR

is strict Cour
Southam District of West Virginia

UNITED STATES OF AMERICA

W's CRIMINAL NO. 2:24-cr-00118
18 U.S.C. § 1591 (a) (1)
18 U.S.C. § 1591 (a) (2)
TIWAN ROBERT BAILEY 18 U.S.C. § 1591 (b) (1)
also known as “Quick” 18 U.S.C. § 1591 (b) (2)
CARRIE ROY 18 U.S.C. § 1591 (c)
also known as “Carrie Ash” 18 U.S.C. § 1591 (d)
DAVID LEE WHITE 18 U.S.C. § 1594 (c)
18 U.S.C. § 2
THIRD

The Grand Jury Charges:
COUNT ONE

In and around December 2023, at or near Charleston and Rand,
Kanawha County, West Virginia, within the Southern District of
West Virginia, defendant TIWAN ROBERT BAILEY, also known as
“Quick,” and CARRIE ROY, also known as “Carrie Ash,” aided and
abetted by one another, in and affecting interstate or foreign
commerce, knowingly recruited, enticed, harbored, provided,
obtained, maintained, patronized, and solicited, by any means,
Victim 1, and benefitted financially and by receiving anything of
value from participation in a venture which recruited, enticed,

harbored, provided, obtained, maintained, patronized, and
Case 2:24-cr-00118 Document 22 Filed 10/16/24 Page 2 of 8 PagelD #: 57

solicited, by any means, Victim 1, having had a reasonable
opportunity to observe Victim 1 and knowing and in reckless
disregard of the fact that Victim 1 had not attained the age of 18
years and that Victim 1 would be caused to engage in a commercial

sex act.

In violation of Title 18, United States Code, Sections

1591 (a) (1), (a) (2), (b) (2), and (c), and Section 2.
Case 2:24-cr-00118 Document 22. Filed 10/16/24 Page 3 of 8 PagelD #: 58

COUNT TWO

From in and around November 2023 through in and around January
2024, at or near Charleston and Rand, Kanawha County, West
Virginia, within the Southern District of West Virginia, defendant
TIWAN ROBERT BAILEY, also known as “Quick,” in and affecting
interstate or foreign commerce, knowingly recruited, enticed,
harbored, provided, obtained, maintained, patronized, and
solicited, by any means, Victim 2, and benefitted financially and
by receiving anything of value from participation in a venture
which recruited, enticed, harbored, provided, obtained,
maintained, patronized, and solicited, by any means, Victim 2,
knowing and in reckless disregard of the fact that means of force,
threats of force, coercion, as defined in 18 U.S.C. § 1591 (e) (2),
and any combination of such means would be used to cause Victim 2
to engage in a commercial sex act.

In violation of Title 18, United States Code, Sections

159i (a) (1), (a) (2), and (b) (1).
Case 2:24-cr-00118 Document 22 _ Filed 10/16/24 Page 4 of 8 PagelD #: 59

COUNT THREE

From in and around December 2023 through in and around July
2024, at or near Charleston and Rand, Kanawha County, West
Virginia, within the Southern District of West Virginia, defendant
TIWAN ROBERT BAILEY, also known as “Quick,” in and affecting
interstate or foreign commerce, knowingly recruited, enticed,
harbored, provided, obtained, maintained, patronized, and
solicited, by any means, Victim 3, and benefitted financially and
by receiving anything of value from participation in a venture
which recruited, enticed, harbored, provided, obtained,
maintained, patronized, and solicited, by any means, Victim 3,
knowing and in reckless disregard of the fact that means of force,
threats of force, coercion, as defined in 18 U.S.C. § 1591(e) (2),
and any combination of such means would be used to cause Victim 3
to engage in a commercial sex act.

In violation of Title 18, United States Code, Sections

1591 (a) (1), (a) (2), and (b) (1).
Case 2:24-cr-00118 Document 22 _ Filed 10/16/24 Page 5 of 8 PagelD #: 60

COUNT FOUR

From in and around November 2023 through in and around January
2024, at or near Charleston and Rand, Kanawha County, West
Virginia, within the Southern District of West Virginia, defendant
TIWAN ROBERT BAILEY, also known as “Quick,” in and affecting
interstate or foreign commerce, knowingly recruited, enticed,
harbored, provided, obtained, maintained, patronized, and
solicited, by any means, Victim 4, and benefitted financially and
by receiving anything of value from participation in a venture
which recruited, enticed, harbored, provided, obtained,
maintained, patronized, and solicited, by any means, Victim 4,
knowing and in reckless disregard of the fact that means of force,
threats of force, coercion, as defined in 18 U.S.C. § 1591 (e) (2),
and any combination of such means would be used to cause Victim 4
to engage in a commercial sex act.

In violation of Title 18, United States Code, Sections

1591 (a) (1), (a) (2), and (b) (1).
Case 2:24-cr-00118 Document 22 _ Filed 10/16/24 Page 6 of 8 PagelD #: 61

From on
15, 2024, at
the Southern

TIWAN ROBERT

or about May 20, 2024, through on or about October
or near Rand, Kanawha County, West Virginia, within
District of West Virginia, and elsewhere, defendant

BAILEY, also known as “Quick,” aided and abetted by

defendant DAVID LEE WHITE, obstructed, attempted to obstruct, and

in any way interfered with and prevented the enforcement of 18

U.S.C. § 1591.

In violation of Title 18, United States Code, Section 1591 (da)

and Section 2.
Case 2:24-cr-00118 Document 22 Filed 10/16/24 Page 7 of 8 PagelD #: 62

COUNT SIX

In and around December 2023, at or near Charleston and Rand,
Kanawha County, West Virginia, within the Southern District of
West Virginia, defendants TIWAN ROBERT BAILEY, also known as
“Quick,” and CARRIE ROY, also known as “Carrie Ash,” together with
other persons whose identities are known and unknown to the Grand
Jury, conspired with one another to knowingly, in and affecting
interstate or foreign commerce, recruit, entice, harbor, provide,
obtain, maintain, patronize, and solicit, by any means, Victim 1,
and having had a reasonable opportunity to observe Victim 1 and
knowing and in reckless disregard of the fact that Victim 1 had
not attained the age of 18 years and that Victim 1 would be caused
to engage in a commercial sex act.

In violation of Title 18, United States Code, Sections 1591 (a)

and {(c) and 1594(c).
Case 2:24-cr-00118 Document 22 _ Filed 10/16/24 Page 8 of 8 PagelD #: 63

FORFEITURE

Pursuant to 18 U.S.C. § 1594(d), upon conviction of an offense
in violation of Title 18, United States Code, Section 1591, the
defendant, TIWAN ROBERT BAILEY, also known as “Quick,” shall
forfeit to the United States of America any property constituting,
or derived from, any proceeds obtained, directly or indirectly, as
the result of such offenses and any property used, or intended to
be used, in any manner or part, to commit, or to facilitate the
commission of, the offenses.

This property includes, but is not limited to, any real and
personal property constituting or traceable to gross profits and
other proceeds obtained from the violations set forth in this Third
Superseding Indictment and any real and personal property used or
intended to be used to commit or to facilitate the commission of

the violations set forth in this Third Superseding Indictment.

WILLIAM S. THOMPSON
United States Attorney

HNNIFKR RADA HERRALD
SENT FaR United States Attorney


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