Case 3:13-mj-03331-MAT Document 1 Filed 07/19/13 Page 1 of 4

/I
AO 91 (Rev, 08/09) Criminal Complaint
II I,

$,2013

UNITED STATES DISTRICT COURT

for the

Western District of Texas

United States of America

Case No. P.' /

m,rCi)

DEION LOCKHART

Defendant(s)

CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best

On or about the date(s) of

Western

August, 2012 to October, 2012

District of

Texas

of my knowledge and belief.

in the county of

El

Paso

in the

the defendant(s) violated:

Offense Description

Code Section

Knowing, or in reckless disregard of the fact, that force, threats of force,

fraud, or coercion will be used to cause sex trafficking of children and/or a
person to engage in a commercial sex act.

Title 18 U.S.C. 1591

This criminal complaint is based on these facts:

See attached affidavit.

( Continued on the attached sheet.

4A'
Complainant's signature

Clinton J. Smith, FBI Special Agent

Printed name and title

Sworn to before me and signed in my presence.

Date:

ZOI
Judge s signature

City and state:

El

Paso, Texas

Miguel A. Torres, U.S. Magistrate Judge

Printed name and title

Case 3:13-mj-03331-MAT Document 1 Filed 07/19/13 Page 2 of 4

Affidavit in Support of an Arrest Warrant

1.

I, Clinton J. Smith, hereinafter referred to as Complainant, am a Special Agent (SA)

of the

Federal Bureau of Investigation (FBI), and conduct investigations of violations of Federal

Criminal Law, including Human Trafficking.
2. From approximately August, 2012 to October, 2012, Deion LOCKHART, also known as
MEMPHIS, forced juvenile victim AG to prostitute in El Paso, Texas, which is in the Western
District of Texas.
3.

The victim, henceforth identified as AG, has conveyed to Complainant through interviews some

of the facts contained in this affidavit.

4.

In approximately August 2012, AG was invited by a friend she knew from high school to a motel
room to "make some money". AG was 16 at the time. When AG arrived at the motel room, at

COMFORT INN at 900 North Yarbrough Drive, El Paso, 79915, there were four to five black
males in the room smoking marijuana. One of the males was a tall, light complexioned black

male with several tattoos that went by the moniker "MEMPHIS". Also present were two other
girls that AG did not know. AG was told that she was just going to sit in a motel room and

answer the door, and when men came in, LOCKHART would rob them. After some time, AG
went to the bathroom. When she returned, the friend she arrived with was gone. LOCKHART

told AG that her friend would return later.

5.

LOCKHART and the other men had two adjoining rooms at the COMFORT INN. LOCKHART
told AG to come to the adjoining room. LOCKHART then told AG she had to take pictures for
"the website," and when she asked what website and what kind of pictures, he ignored her.
LOCKHART told AG to take off her shirt and pants and then all the males except for

LOCKHART's cousin came in to the room. The men instructed her how to pose for the pictures.
When AG told the men that she did not want to take pictures, they responded by continuing to

pressure her to pose for pictures; AG then followed their instructions. The men spoke openly
about "posting" but she did not know what that meant. After taking the pictures, AG was allowed
to get dressed and the men gave her more marijuana. Approximately 10 minutes later, a man AG

did not know came to the door of the motel room that AG was in. AG was then instructed by
LOCKHART to have sex with the man. AG told LOCKHART that she did not want to have sex
with the man but he continued to pressure her. He further instructed her to put the money under

the door to the adjoining room. As she went to the motel room door and let the man in,
LOCKHART closed the door to the adjoining room. AG let the man in and did everything
LOCKHART instructed her to do to include having sex with the man for money. That night AG

had sex with two men. The two men paid her by handing her the money or leaving the money on

Case 3:13-mj-03331-MAT Document 1 Filed 07/19/13 Page 3 of 4

the dresser. She did not leave the motel because LOCKHART was big and he scared
her. LOCKHART took all of the money that she made through prostitution that night.
6.

In the following days LOCKIHIART continued to give AG marijuana and forced her to have sex

with five to six men a day every day of the week. AG was never given a day off, but there were
some days that she did not have to work as much and only had sex with a couple of men at night.
The men would pay AG $100 for 30 minutes or $180 for an hour for sex with customers.

However, if she spent more than 15 minutes with a customer, LOCKHART would yell at her and
accuse her of enjoying it. This cycle continued until approximately late September or early
October 2012.
7.

The first customer that AG had sex with failed to tell her that the condom broke during sex. AG

did not know if she had any sexually transmitted diseases (STDs) or if she was pregnant. After
the first night, LOCKHART took AG to his brother's house. AG was kept at his brother's house

and at various hotels during the time she was with MEMPHIS.
8.

AG was not allowed to have a phone and was not permitted to keep any of the money she earned

through prostitution. AG slept on a couch in MEMPHIS 's brother's house and was given food

(usually fast food) only once a day. AG was given toiletries and clothes by the other girls present
at the house and by LOCKHART. The men would mistreat the girls, often assaulting them and

calling them names such as "bitch", "whore" and "ho". LOCKHART was considered a pimp by
the girls and the men.
9.

LOCKHART continually intimidated AG. If she was not making money, prostituting

LOCKHART would yell at AG and tell her that he did not "have her there for no reason." If
LOCKHART thought that AG wasn't paying attention to him, he would grab her arms and yell at
her. LOCKHART forced AG to have sex with him four to five times, even though she did not

want to. When she resisted, LOCKHART pulled her in closer and forced her. While at motels,

AG was not allowed to leave the room. LOCKHART intimidated her and whenever she asked to
leave, she was told no. LOCK}IART would tell AG that she could not leave because "money was
calling".
10. LOCKHART did not beat AG, but AG saw other men hit their girls. At one point one of the men

beat his girl because she took too long with a customer and was paid in one dollar bills. When the
girl came into the room after being with the customer, the man asked her why she took so long

with the customer and asked if she had been dancing for the one dollar bills. When the girl went
to take a shower in the hotel room, the man went into the bathroom and began yelling at her and
hitting her. He threw her out of the bathroom and continued to hit and kick her in the back,

Case 3:13-mj-03331-MAT Document 1 Filed 07/19/13 Page 4 of 4

stomach, and side. LOCK}IART and others in the group were present when this happened. One

female in particular Was assaulted frequently by the entire group of men.

11. LOCKHART told AG that

if she ever got arrested, she would be given a light charge and he

would bond her out. LOCKHART used the money that he obtained from her prostitution to
customize his car. Lt2KHART taught AG how to "post up," meaning what to write in the escort
ads. After a while, LOtKHART began to let AG use his phone to text customers and set up

"dates" for prostitution. AG advised that one of the other girls coached her how to have sex with
the customers.
12. AG finally escaped in late September or early October but did not report the incident. After AG

escaped, some of the men attempted to contact her on Facebook.com. AG did not know how they
found her on FACEBOOK.COM, as she didn't know these men before this incident. AG thought
that CRENSHAW and TRIGG may have found her through the friend that first brought her to the
hotel. The men attempted to get AG to come back to group. One of the men put link(s) to the
BACKPAGE.COM escort ads (that depicted AG) on FACEBOOK.COM and AG's friends saw
the photos. This embarrassed AG, caused her to close her FACEBOOK account, and ultimately
drop out of school.
13. A witness (Witness 1) with first hand information advised agents that AG worked as a prostitute
for LOCKHART. Witness 1 advised thatLOCKHART would make AG cook and clean and he
told AG what to do. Witness 1 one believed that AG was 17 and admitted that she "looked
young".
14. Another witness (Wfftiess 2) with first hand information advised agents that AG worked as a
prostitute for LOCKI4ART. Witness 2 thought that AG "looked young" but did not know her age.
Witness 2 advised that AG looked sad and scared when she first began working as a prostitute.
Witness 2 advised that when AG did not want to work as a prostitute LOCKHART would yell at
her and he would call her "bitch" and "hoe".
15. Based on the foregoing facts Complainant requests that an arrest warrant be issued for DEJON
LOCKHART.

Clinton J. Smith
2013

Miguel A. Torres, U.s. Magistrate Judge