AO 91 (Rev.

11/11) Criminal Complaint

UNITED STATES DISTRICT COURT

for the
Middle District of Tennessee
U.S. DISTRICT COURT
MIDDLE DISTRICT OF TENN.
United States of America
V. DEC 06 2017
Case No.
KARA ADKINS
17-mj-4231
BY
DEPUTY CLERK
)

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 August 14, 2017 in the county of Montgomery in the
Middle District of Tennessee , the defendant(s) violated:

Code Section Offense Description

18 U.S.C. 2251(a) Production of Child Pornography
18 U.S.C. 2252A(a)(1) Transportation of Child Pornography

This criminal complaint is based on these facts:

See Attached Affidavit

0 Continued on the attached sheet.

Conaptainant's signature

FBI Special Agent Tammi F. Laskowski

Printed name and title

Sworn to before me and signed in my presence.

Date: T) ~~ G , ~'
)0 13

" s signatwq

City and state: Nashville, Tennessee United States Magistrate Judge'AliStair E. Newbern
Primed name and title

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 STATEMENT IN SUPPORT OF A CRIMINAL COMPLAINT

I, Tammi F. Laskowski, being first duly sworn, hereby depose and state as follows:

I am a Special Agent with the Federal Bureau of Investigation. As such, I am an

investigative or law enforcement officer of the United States within the meaning of Title
18 U.S.C. § 2510(7) and empowered by law to conduct investigations and to make arrests
for offenses enumerated in Title 18 U.S.C. §§ 2251 and 2252A.

2. I have been a Special Agent of the Federal Bureau of Investigation since August 2016.
Prior to that time, I was an Intelligence Analyst with the FBI from August 2011 through
August 2016. In that role, I primarily investigated international terrorism. I am presently
assigned to the Nashville Resident Agency where I investigate federal crimes within the
Middle District of Tennessee. Those investigations include violations relating to child
pornography, including possession, transportation, distribution, receipt, and production of
child pornography in interstate commerce by computer.

3. The facts in this statement come from my personal observations, my training and
experience, and information obtained from other law enforcement officers and witnesses.
This statement is intended to show merely that there is sufficient probable cause for the
requested warrant and does not set forth all of my knowledge about this matter.

4. This affidavit is submitted in support of a Criminal Complaint for the arrest of KARA
ADKINS, for the offense of production and transportation of child pornography, in
violation of Title 18 U.S.C. §§ 2251 and 2252A(a)(1), on or about August 14, 2017, in the
Middle District of Tennessee and elsewhere, in that Kara Adkins did knowingly produce
and transport child pornography using any means or facility of interstate or foreign
commerce.

5. On February 7, 2017, the National Center for Missing and Exploited Children (NCMEC)
sent CyberTip #16888528 to the Montgomery County Sheriff's Office (MCSO) in
Montgomery County, Tennessee. The CyberTip, which originated with Google, reported
that an internet user in Montgomery County, Tennessee, uploaded multiple video files
containing child pornography using the email address kadlcins1007@gmail.com. The user
associated with this gmail account submitted the following phone number: 304-543-4844.
Additionally, the CyberTip provided four images alleged to contain child pornography. I
subsequently reviewed the images provided in the CyberTip Report, which are described
as follows:

a. An up-close image of what appears to be a pre-pubescent boy's penis and scrotum,

in which the boy appears to be approximately 5 to 8 years old.

b. An image of a nude pre-pubescent boy (approximately 4 to 6 years old), lying

across a large dog who is sleeping in an armchair. The boy's thighs are spread.

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 c. An image of the same pre-pubescent (approximately 4 to 6 years old) nude boy,
lying across the same dog, whose legs are spread as described above. This image is
shot from a different angle than the image described in the previous paragraph.

d. A screenshot that contains three separate images: two of the images involved adults
engaged in sexual activity with dogs and the relevant image depicted a semi-nude
adult male whose erect penis was lying across the thigh of a nude, pre-pubescent
girl. The girl, who was lying on her back, appeared to be a toddler, between the age
of one and three years.

Google had reported three CyberTips to NCMEC relating to the same email
(lcadkins1007@gmail.com) and phone number (304-543-4844) in the two to three week
period leading up to February 7, 2017.

6. Per open source database checks, on August 17, 2017, phone number 304-543-4844 was
associated with Robert Adkins and Kara J. Adkins, 3613 Aurora Drive, Clarksville,
Tennessee 37040. As of that date, Robert Adkins, who is married to Kara Adkins, was
active duty in the U.S. Army, and was then stationed at Camp Henry in Korea.

7. Additionally, according to the Clarksville Montgomery County School System (CMCSS)

Powerschool Database, Robert Adkins and Kara Adkins are parents who have three
children enrolled in the CMCSS school system. Robert Adkin's listed email address is
robert.adkinsI@soar.army.mil. Kara Adkins' listed e-mail address in the CMCSS database
is kadkins 1007@gmail.com, the same e-mail address used to upload the child pornography
images reported in CyberTip #16888528. The CMCSS database listed, for each child, the
primary contact and/or home phone number as 304-543-4844. This is the same phone
number associated with the aforementioned email address that was used to upload child
pornography images, as reported in CyberTip #16888528.

8. On August 17, 2017, a law enforcement officer searched for "Kara Adkins" in the
Tennessee Criminal Justice Portal. This search revealed that a 2012 Nissan Armada, tag
number 2075HL, was registered to Kara and Robert Adkins. The registration listed 3613
Aurora Drive, Clarksville, Tennessee as the address for Kara and Robert Adkins.

9. On August 17, 2017, law enforcement officers with the MCSO executed a state search
warrant at the residence of Kara Adkins to search for evidence of sexual exploitation of a
minor. During the search, a number of items were seized pursuant to the search warrant,
including an iPhone belonging to Kara Adkins. During the execution of the search warrant,
investigators also were able to identify the child and the dog depicted in two of the photos
described above in paragraphs 5(b) and 5(c).

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10. I subsequently reviewed the KIK chat logs from the seized iPhone belonging to Kara
Adkins. Review of the contents of Kara Adkins's iPhone revealed that Kara Adkins had
sent child pornography images to her husband, Robert Adkins, using the KIK application.
The children depicted included infants, prepubescent children, and adolescents. Robert
Adkins and Kara Adkins also "chatted" through the KIK application, often about sexual
activity with children as well as other adults.

11. In one of the chat conversations on May 7, 2017, "hockeydad1026 (Rob Adkins)" typed,
"You could get away with a lot in the bathv." This message was sent at 10:25:26 pm
(UTC+O). At 10:25:36 pm (UTC+O), "ItsMe1007 (Kara Adkins)" responded with, "Yeah?
Like What?" To which "hockeydadl026 (Rob Adkins)" responded, "Just fingering,
playing with it rubbing it him kissing you."

12. In another series of chats that began on August 14, 2017, at 1:49:59 am (UTC+O), Kik
Account "ItsMe1007 (Kara Adkins)" sent Kik Account "hockeydadl026 (Rob Adkins)" a
photo of a boy, approximately 5 to 8 years-old, who was partially nude. The photo's focus
was on the boy's penis. At 1:50:02 am (UTC+O), Kara Adkins sent a second photo, which
depicted a boy, approximately 5 to 8 years-old, nude and standing in a bathtub with what
appears to be an adult hand holding a loofah under the boy's exposed genitals. At 1:50:31
am (UTC+O), Robert Adkins responded with, "Fuck! ! ! I love it." Robert Adkins sent a
second response at 1:50:59 am (UTC+O): "Touch it for me."

13. On the day the search warrant was executed, Kara Adkins identified the minor referenced
in paragraphs 5(b) and 5(c). She further admitted that she had taken the photographs of the
same minor boy described above in paragraph 12.

14. Robert Adkins was interviewed at Camp Henry in Korea on August 19, 2017. During his
interview, Robert Adkins confirmed that he had received five images of the identified
minor's penis from his wife, Kara Adkins. According to Robert Adkins, one of the photos
depicted his wife playing with the identified minor's penis. Robert Adkins stated he
received the first photo in March or April 2017, and that he had received the last two photos
in August 2017. Robert Adkins also stated that he and his wife would talk dirty about the
photos for a few minutes after he received them. Robert Adkins viewed the photos on his
phone with telephone number 010-2264-3686.

15.A forensic examination was conducted on an Apple Wad belonging to Kara Adkins. The
two photographs described in paragraph 12 were located on the device. EXIF data of those
photographs reveal the photos were taken by an Apple iPhone 7 on August 13, 2017 at 8:24
and 8:26 pm respectively. August 13, 2017, 8:24 pm and 8:26 pm convert to August 14,
2017, 1:24 am and 1:26 am (UTC+O). The forensic exam revealed that the photos were
taken approximately 25 minutes before Kara Adkins sent the first photo to her husband via
the Kik application.

16.A forensic exam of an LG cell phone with telephone number 010-2264-3686, that was in
the possession of Robert Adkins, revealed that the two photos described in paragraph 12
were received through the Kik application on August 14, 2017, at 1:50 am (UTC+O).

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17. Based upon the foregoing, I believe there is probable cause to believe that Kara Adkins has
committed offenses in violation of Title 18 U.S.C. §§ 2251(a) and 2252A(a)(1), which
makes it a crime to produce and transport child pornography in interstate or foreign
Moll-INIMM

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