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Criminal Complaint (Dkt. 1, M.D. Pa.)

Summary

A criminal complaint filed 07/21/26 in the Middle District of Pennsylvania, Case 1:26-mj-00050-SES, with continuation sheets by an FBI Special Agent from the Capital Area Resident Agency in York, Pennsylvania, alleges that Jesse White received and possessed child pornography. The agent says the case began with National Center for Missing and Exploited Children Cybertipline Reports 246509293 and 246571621, which concerned images Google LLC submitted. On July 21, 2026, the FBI searched White's residence in Mechanicsburg, Pennsylvania and seized computers and hard drives; agents report finding approximately 100 such files on one drive. The agent states that White, after being Mirandized, admitted accessing the material through Telegram, Qbittorrent and the Tor browser. The complaint cites 18 U.S.C. § 2252(a)(2) and § 2252A(a)(5)(B).

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                   Case 1:26-mj-00050-SES           Document 1               Filed 07/21/26        Page 1 of 12
AO 91 (Rev. 08/09) Criminal Complaint


                                     UNITED STATES DISTRICT COURT
                                                                for the
                                              Middle District
                                             __________       of of
                                                                Pennsylvania
                                                         District   __________

                  United States of America                         )
                             v.                                    )
                                                                   )       Case No.             000050
                                                                   )
                                                                   )
                                                                   )
                           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                                                in the county of                             in the
                       District of                          , the defendant(s) violated:

            Code Section                                                     Offense Description




         This criminal complaint is based on these facts:




             Continued on the attached sheet.



                                                                                             Complainant’s signature


                                                                                              Printed name and title

                                                            .


Date:        07/21/2026
                                                                                                Judge’s signature

City and state:
                                                                                              Printed name and title
     Case 1:26-mj-00050-SES   Document 1   Filed 07/21/26   Page 2 of 12




               CONTINUATION SHEETS IN SUPPORT
                  OF A CRIMINAL COMPLAINT

           INTRODUCTION AND AGENT BACKGROUND

     1.    I am a Special Agent with the Federal Bureau of

Investigation (“FBI”) assigned to the Capital Area Resident Agency

office located in York, Pennsylvania. I have been employed as a Special

Agent with the FBI since 2021.

     2.    I am currently assigned to investigate crimes against

children including, but not limited to, child exploitation and child

pornography offenses in violation of Title 18, United States Code,

Sections 2251, 2252/2252A, 2422, and 2423. Additionally, I have been

involved with investigations of violations of other federal statutes

including Hobbs Act extortion, fraud, violent crime, online sexual

exploitation, and kidnapping. As a Special Agent, one of my primary

duties is the enforcement of federal laws and the security of government

witnesses and entities identified during the course of these

investigations. I have been trained in conducting child exploitation

investigations using digital and electronic techniques. I have had the

opportunity to review numerous examples of digital evidence, conduct

interviews with subjects, witnesses and victims, participated in the


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     Case 1:26-mj-00050-SES   Document 1   Filed 07/21/26   Page 3 of 12




execution of many search warrants involving child exploitation and

enticement offenses and have reviewed thousands of images of illegal

child sexual abuse material related to these investigations.

     3.    As a federal agent, I am authorized to investigate violations

of United States laws and to execute warrants issued under the

authority of the United States.

     4.    The statements in these continuation pages are based on my

personal investigation and information provided by other law

enforcement officers. These statements are intended to show only that

there is sufficient probable cause for the criminal complaint and do not

set forth all of my knowledge about this matter. I have set forth only the

facts that I believe are necessary to establish probable cause that Jesse

White,                  , violated Title 18, United States Code, Sections

2252(a)(2) (receipt and distribution of child pornography), and

2252A(a)(5)(B) (possession of child pornography).

                         LEGAL AUTHORITY

     5.    This criminal complaint concerns violations of the following

federal criminal statutes:




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     Case 1:26-mj-00050-SES   Document 1   Filed 07/21/26   Page 4 of 12




           A. 18 U.S.C. § 2252A(a)(2) and (b)(1) prohibit a person from

             knowingly receiving or distributing, or attempting or

             conspiring to receive or distribute, any child pornography

             or any matter than contains child pornography, as defined

             in 18 U.S.C. § 2256(8), that has been mailed, or using any

             means or facility of interstate or foreign commerce

             shipped or transported in or affecting interstate or foreign

             commerce by any means, including by computer.

           B. 18 U.S.C. §2252A(a)(5)(B) prohibits anyone from

             knowingly possessing material that contains child

             pornography.

              TECHNICAL TERMS AND DEFINITIONS

     6.    Based on my training and experience, I use the following

technical terms and definitions to convey the following meanings:

           A. “Child Pornography,” as used herein, includes the

             definition in Title 18 U.S.C. § 2256(8) (any visual

             depiction of sexually explicit conduct where (a) the

             production of the visual depiction involved the use of a

             minor engaged in sexually explicit conduct, (b) the visual



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Case 1:26-mj-00050-SES   Document 1   Filed 07/21/26   Page 5 of 12




        depiction is a digital image, computer image, or

        computer-generated image that is, or is indistinguishable

        from, that of a minor engaged in sexually explicit conduct,

        or (c) the visual depiction has been created, adapted, or

        modified to appear that an identifiable minor is engaged

        in sexually explicit conduct), as well as any visual

        depiction, the production of which involves the use of a

        minor engaged in sexually explicit conduct (see Title 18

        U.S.C. §§ 2252 and 2256(2)).

     B. The term “minor”, as used herein, is defined pursuant to

        Title 18, United States Code, Section 2256(1) as “any

        person under the age of eighteen years.”

     C. “Sexually explicit conduct" means actual or simulated (a)

        sexual intercourse, including genital-genital, oral-genital,

        or oral-anal, whether between persons of the same or

        opposite sex; (b) bestiality; (c) masturbation; (d) sadistic

        or masochistic abuse; or (e) lascivious exhibition of the

        genitals or pubic area of any persons. (See Title 18 U.S.C.

        § 2256(2)).



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     Case 1:26-mj-00050-SES    Document 1   Filed 07/21/26   Page 6 of 12




           D. “Visual depictions” include undeveloped film and

              videotape, and data stored on computer disk or by

              electronic means, which is capable of conversion into a

              visual image. (See Title 18 U.S.C. § 2256(5)).

                             PROBABLE CAUSE

     7.    The National Center for Missing and Exploited Children

(NCMEC) receives complaints via their Cybertipline from Internet

Service Providers (ISPs), Electronic Service Providers (ESPs), and

others. These Cybertipline reports are reviewed by a NCMEC analyst

and forwarded to law enforcement for further investigation based on the

information provided in the Cyber Tipline report.

     8.    On or about July 20, 2026, FBI CARA received NCMEC

Cybertipline Report number 246509293. The report was received by

NCMEC on June 19, 2026. It was flagged as “child pornography

possession, distribution, manufacture”. Further, this report was flagged

for files that appear unfamiliar and may depict new produced and/or

homemade content.

     9.    According to the Cybertipline Report 246509293, the subject

was identified as follows:



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     Case 1:26-mj-00050-SES   Document 1   Filed 07/21/26   Page 7 of 12




           Name: Jesse White

           Mobile Phone:                   (Verified 12-17-2025 23:59:03

           UTC)

           Date of Birth:

           Email Address:                             (Verified)

           Email Address:

     10.   According to the Cybertipline Report, Google LLC.,

submitted an image associated with this report. Specifically, the file

Google submitted was labeled Google-CT-RPT-246509293-

368b55e92dbccb0b9f428d3e6e4f6d4c-IMG_0648.HEIC.

     11.   I viewed file Google-CT-RPT-246509293-

368b55e92dbccb0b9f428d3e6e4f6d4c-IMG_0648.HEIC. The file depicts

a prepubescent minor male child, approximately 5-6 years of age, fully

nude in the shower. The child is seen with one hand holding his penis.

There is a reflection of an adult male visible in the photo. The adult

male appears to be a white male subject, holding his phone taking the

picture. The subject appears to be wearing a ring in this reflection.

     12.   The metadata associated with this file indicates that an Apple

iPhone was utilized to produce this image in January 2019.



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     Case 1:26-mj-00050-SES   Document 1   Filed 07/21/26   Page 8 of 12




     13.   In addition, a second Cybertipline Report was submitted

associated with this subject. The second Cybertipline Report is

246571621.

     14.   The second Cybertipline Report identified file “Google-CT-

RPT-246571621-4dc5c0ada23f36d0dbceffda915513ef-IMG_5946.HEIC,”

which was described as depicting a naked prepubescent male pressing

his buttocks against a window.

     15.   The metadata associated with this file indicates that an

Apple iPhone was utilized to produce this image in August 2021.

     16.   Jesse White has two minor male children.

     17.




     18.   Based upon the images of                                    that I

viewed on social media, it is estimated that the minor who appears in

the images flagged by Google and which are the subject of the

Cybertipline Reports is 9-11 years old.




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     Case 1:26-mj-00050-SES   Document 1     Filed 07/21/26   Page 9 of 12




     19.   After receiving the NCMEC Cybertip Reports, I learned that

Jesse White had or has accounts with ProtonMail as well as encrypted

applications like Telegram.

     20.   Based on my training and experience, I know that encrypted

applications like Telegram and ProtonMail are utilized for anonymity

and because of their enhanced security and encryption features. I know

from my training and experience that individuals engaged in child

exploitation use ProtonMail to communicate securely and anonymously

with other individuals interested in or engaged in child exploitation

activities. I also know from my training and experience that

individuals engaged in child exploitation favor ProtonMail not only

because of its encryption and security, but because they believe that

ProtonMail (which is based in Switzerland) will not comply with U.S.-

based legal process.

     21.   On July 21, 2026, the FBI executed a federal search warrant

at Jesse White’s residence at 1831 Vista Drive, Mechanicsburg,

Pennsylvania 17055. During the execution of the search warrant, FBI

agents seized multiple computers and hard drives and conducted a

preliminary on-site review of the devices.



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     Case 1:26-mj-00050-SES   Document 1   Filed 07/21/26   Page 10 of 12




     22.   In Jesse White’s home office, agents seized two laptops and

multiple external hard drives. One of the laptops, a Lenovo, had a 20-

terabyte external hard drive mounted to it, which was found to contain

numerous files containing images of child pornography depicting minors

between the estimated ages of seven to 15 years old engaged in sexually

explicit activity. Agents observed that the titles of some of the files

identified the ages of the minors depicted in the child pornography.

     23.   In a separate drive, identified as the “Z” drive on the Lenovo

laptop computer, agents found approximately 100 files depicting child

pornography. Based on a preliminary review of this material, it

appears the hard drive was organized by categories of child

pornography depicted in the files.

     24.   For example, one video file depicted two minor females,

approximately 10-to-13 years old fully nude in the shower, with one of

the minor females performing oral sex on the other minor female.

Another file is a still photograph that depicts a minor female

approximately 8-to-10 years old with her legs over her head, exposing

her genitals.




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     Case 1:26-mj-00050-SES   Document 1   Filed 07/21/26   Page 11 of 12




     25.   Agents also seized an Apple laptop computer with an

account labeled “Jesse White,” which contained an image of a minor

female approximately 12-to-14 years old kneeling with her genitals

exposed.

     26.   After being Mirandized, Jesse White spoke voluntarily with

the agents during the execution of the search warrant. White told the

agents that he had used Telegram, Qbittorrent (commonly referred to

as “Bit Torrent,” which a peer-to-peer file sharing program), and the Tor

browser to access the “dark” web. White admitted that while using

Telegram, Qbittorrent, and while on the Tor browser he accessed what

he referred to as “inappropriate content.” In response to further

questioning, White confirmed that what he meant by “inappropriate

content” was child pornography. White also admitted that the devices

the agents seized during the execution of the search warrant would

contain child pornography.

     27.




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                              CONCLUSION

     28.   Based on the foregoing information, I submit that there is

probable cause that Jesse White received child pornography on an as-

yet unconfirmed date, in violation of 18 U.S.C. § 2252(a)(2), and that he

possessed child pornography on or about July 21, 2026, in violation of

18 U.S.C. § 2252A(a)(5)(B).




                                    11


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