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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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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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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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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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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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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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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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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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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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).
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