Indictment No — No. 3:21-cr-00021 (Dkt. 1, E.D. Ky.)
Summary
An indictment filed October 21, 2021 as Doc #: 1 in United States v. Edward Leonidas Lewis, Case 3:21-cr-00021-GFVT-EBA, in the U.S. District Court for the Eastern District of Kentucky, Central Division. The eight-page document sets out seven counts citing 18 U.S.C. § 2251(a), 18 U.S.C. § 2251(a) and (e), 18 U.S.C. § 2252(a)(2) and 18 U.S.C. § 2252(a)(4)(B), with offense dates from June 1, 2018 through February 25, 2021. A forfeiture allegation under 18 U.S.C. § 2253 lists a cell phone, a laptop computer and flash drives. A penalties page lists the maximum terms and special assessments for each count.
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“Indictment No — No. 3:21-cr-00021 (Dkt. 1, E.D. Ky.).”
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Case: 3:21-cr-00021-GFVT-EBA Doc #: 1 Filed: 10/21/21 Page: 1 of 8 - Page ID#: 1
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UNITED STATES DISTRICT COURT
PILI D
EASTERN DISTRICT OF KENTUCKY
CENTRAL DIVISION
OCT 2 1 202!
FRANKFORT AT LEXINGTON
ROBIRT R. CARR
CLERK U.S. DISTRICT COURT
UNITED STATES OF AMERICA
V. INDICTMENT NO. 3,'&-1-C~-8:1-S {-VT
EDWARD LEONIDAS LEWIS
* * * * *
THE GRAND JURY CHARGES:
COUNTl
18 U.S.C. § 225l(a)
On or about June 1, 2018, in Franklin County, in the Eastern District of Kentucky,
and elsewhere,
EDWARD LEONIDAS LEWIS
employed, used, persuaded, induced, enticed, and coerced Minor Victim #1 to engage in
sexually explicit conduct for the purpose of producing a visual depiction of that conduct,
knowing and having reason to !mow that the visual depiction was produced or transmitted
using materials that were mailed, shipped, or transported in or affecting interstate or
foreign commerce by any means, including computer, all in violation of 18 U.S.C.
§ 2251(a).
COUNT2
18 U.S.C. §§ 225l(a) and (e)
On or about June 1, 2018, in Franklin County, in the Eastern District of Kentucky,
Case: 3:21-cr-00021-GFVT-EBA Doc #: 1 Filed: 10/21/21 Page: 2 of 8 - Page ID#: 2
EDWARD LEONIDAS LEWIS
attempted to employ, use, persuade, induce, entice, and coerce Minor Victim# 1 to
engage in sexually explicit conduct for the purpose of producing a visual depiction of that
conduct, knowing and having reason to know that the visual depiction would be produced
or transmitted using materials that were mailed, shipped, or transported in or affecting
interstate or foreign commerce by any means, including computer, all in violation of 18
U.S.C. §§ 2251(a) and (e).
COUNT3
18 U.S.C. § 2251(a)
On or about June 2, 2018, in Franklin County, in the Eastern District of Kentucky,
and elsewhere,
EDWARD LEONIDAS LEWIS
employed, used, persuaded, induced, enticed, and coerced Minor Victim# 1 to engage in
sexually explicit conduct for the purpose of producing a visual depiction of that conduct,
knowing and having reason to know that the visual depiction was produced or transmitted
using materials that were mailed, shipped, or transported in or affecting interstate or
foreign commerce by any means, including computer, all in violation of 18 U.S.C.
§ 225l(a).
COUNT4
18 U.S.C. §§ 225l(a) and (e)
On or about June 2, 2018, in Franklin County, in the Eastern District of Kentucky,
EDWARD LEONIDAS LEWIS
attempted to employ, use, persuade, induce, entice, and coerce Minor Victim# 1 to
Case: 3:21-cr-00021-GFVT-EBA Doc #: 1 Filed: 10/21/21 Page: 3 of 8 - Page ID#: 3
engage in sexually explicit conduct for the purpose of producing a visual depiction of that
conduct, knowing and having reason to !mow that the visual depiction would be produced
or transmitted using materials that were mailed, shipped, or transported in or affecting
interstate or foreign commerce by any means, including computer, all in violation of 18
U.S.C. §§ 2251(a) and (e).
COUNTS
18 U.S.C. §§ 2251(a) and (e)
On or about May 28, 2020, in Franklin County, in the Eastern District of
Kentucky, and elsewhere,
EDWARD LEONIDAS LEWIS
attempted to employ, use, persuade, induce, entice, and coerce Minor Victim# 2 to
engage in sexually explicit conduct for the purpose of producing a visual depiction of that
conduct, knowing and having reason to !mow that the visual depiction would be produced
or transmitted using materials that were mailed, shipped, or transported in or affecting
interstate or foreign commerce by any means, including computer, all in violation of 18
U.S.C. §§ 2251(a) and (e).
COUNT6
18 U.S.C. § 2252(a)(2)
On or about August 7, 2018, in Franklin County, in the Eastern District of
Kentucky,
EDWARD LEONIDAS LEWIS
did knowingly receive a visual depiction using any means or facility of interstate or
foreign commerce, including by computer, and the production of said visual depiction
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involved the use of a minor engaging in sexually explicit conduct and the visual depiction
was of such conduct, all in violation of 18 U.S.C. § 2252(a)(2).
COUNT7
18 U.S.C. § 2252(a)(4)(B) &(b)(l)
On or about February 25, 2021, in Franklin County, in the Eastern District of
Kentucky,
EDWARD LEONIDAS LEWIS
did knowingly possess a matter containing a visual depiction that was produced using
materials that had been mailed, shipped or transported in interstate or foreign commerce
by any means, including by computer, and the production of said visual depiction
involved the use of a minor engaging in sexually explicit conduct and the visual depiction
was of such conduct, all in violation of 18 U.S.C. § 2252(a)(4)(B) & (b)(l).
FORFEITURE ALLEGATION
18 u.s.c. § 2253
By virtue of the commission of the offenses alleged in this Indictment, any and all
interest EDWARD LEONIDAS LEWIS has in the following property:
COMPUTER AND ASSOCIATED EQUIPMENT:
1. Blue Samsung Galaxy Note 9 cell phone, serial number RF8K8133YST;
2. HP Pavilion laptop computer, serial number 5CD6223N5P;
3. Sandisk Cruzer 4 GB flash drive, model number SDCZ35-004G;
4. Sandisk Cruzer 16 GB flash drive, model number SDCZ36-016G;
5. Plug-to-Cam "spy camera", camera id./user number C36694;
6. Plug-to-Cam "spy camera", camera id./user number C40159; and
7. All software and peripherals which are contained on or associated with the
listed equipment.
Case: 3:21-cr-00021-GFVT-EBA Doc #: 1 Filed: 10/21/21 Page: 5 of 8 - Page ID#: 5
is vested in the United States and hereby forfeited to the United States pursuant to
18 u.s.c. § 2253.
A TRUE BILL
FOREPERSON
CARLTON S. SHIER, IV
s
ACTING UNITED STATES ATTORNEY
Case: 3:21-cr-00021-GFVT-EBA Doc #: 1 Filed: 10/21/21 Page: 6 of 8 - Page ID#: 6
PENALTIES
COUNTS 1-5: Not less than 15 years nor more than 30 years imprisonment,
$250,000 fine, and not less than 5 years nor more than lifetime
supervised release.
If one prior conviction under chapter 110, section 1591, chapter 71,
chapter 109A, or chapter 117, or under section 920 of title 10 (article
120 of the Uniform Code of Military Justice), or under the laws of
any State relating to aggravated sexual abuse, sexual abuse,
abusive sexual contact involving a minor or ward, or sex trafficking
of children, or the production, possession, receipt, mailing, sale,
distribution, shipment, or transportation of child pornography, not
less than 25 years nor more than 50 years imprisonment, $250,000
fine, and not less than 5 years nor more than lifetime supervised
release.
If two or more prior convictions under chapter 110, chapter 71,
chapter 109A, or chapter 117, or under section 920 of title 10 (article
120 of the Unifonn Code of Military Justice), or under the laws of
any State relating to the sexual exploitation of children, not less than
35 years nor more than life imprisonment, $250,000 fine, and not
less than 5 years nor more than lifetime supervised release.
COUNTS 6: Not less than 5 years nor more than 20 years imprisonment,
$250,000 fine, and not less than 5 years nor more than lifetime
supervised release.
If one prior conviction under chapter 110, section 1591, chapter 71,
chapter 109A, or chapter 117, or under section 920 of title 10 (article
120 of the Uniform Code of Military Justice), or under the laws of
any State relating to aggravated sexual abuse, sexual abuse, or
abusive sexual conduct involving a minor or ward, or the production,
possession, receipt, mailing, sale, distribution, shipment, or
transportation of child pornography, or sex trafficking of children,
not less than 15 years nor more than 40 years imprisonment,
$250,000 fine, and not less than 5 years nor more than lifetime
supervised release.
COUNT 7: Not more than 10 years imprisonment, $250,000 fine, and not less
than 5 years nor more than lifetime supervised release.
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Not more than 20 years imprisonment, $250,000 fine, and not less
than 5 years nor more than lifetime supervised release if any visual
depiction involves a prepubescent minor.
If one prior conviction under chapter 110, chapter 71, chapter 109A,
or chapter 117, or under section 920 of title 10 (article 120 of the
Uniform Code of Military Justice), or under the laws of any State
relating to aggravated sexual abuse, sexual abuse, or abusive sexual
conduct involving a minor or ward, or the production, possession,
receipt, mailing, sale, distribution, shipment, or transportation of
child pornography, not less than 10 years nor more than 20 years
imprisonment, $250,000 fine, and not less than 5 years nor more
than lifetime supervised release.
PLUS: Forfeiture of all listed property.
PLUS: Mandatory special assessment of$100 per count. Additional
mandatory special assessment of$5,000 per count, pursuant to 18
U.S.C. § 3014, for non-indigent Defendants convicted of certain
offenses, including those in chapter 110, committed after May 29,
2015 through December 31, 2021.
Pursuant to 18 U.S.C. §2259A, per count ofno more than:
(1) $17,000.00 if convicted of 18 U.S.C. §2252(a)(4) or
§2252A(a)( 5);
(2) $35,000.00 if convicted of any other trafficking in child
pornography offense as defined by §2259(c)(3), which
includes offenses under 18 U.S.C. §§2251(d), 2252(a)(l)
through (3), 2252A(a)(l) through (4), 2252A(g) (in cases in
which the series of felony violations exclusively involves
violations of sections 2251 (d), 2252, 2252A( a)(l) through
(5), or 2260(b )), or 2260(b );
(3) $50,000.00 if convicted of child pornography production
as defined by 18 U.S.C. §2259(c)(l), which includes offenses
under 18 U.S.C. §225l(a) through (c), 2251A, 2252A(g) (in
cases in which the series of felony violations involves at least
1 ofthe violations listed in this subsection), 2260(a) or any
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offense under chapter 109A or chapter 117 that involved the
production of child pornography (as such term is defined in
section 2256), for offenses committed after December 7,
2018.
PLUS: Restitution, if applicable.
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