Case: 1:17-cr-00220 Document #: 2 Filed: 04/05/17 Page 1 of 13 PageID #:14

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EASTERN DIVISION
THOMAS G. BRUTON--
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CASE NUMBER:
v.

IESI{A STANCIEL
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220
CBIIVIINAL coMPr,ArNtlAG ISTRATE JU DGt Flltffi0AN
I, the complainant in this case, state that the following is true to the best of my knowledge
and belief.
From on or about November 5, 20L6, through on or about April 4, 2017 , in the Northern District
of Illinois, Eastem Division, the defendant(s) violated:

Cade Sec:tinn Offense Description

fitle 18, United States Code, Section with the intent to intimidate another person,
22614(2)(A) used an interactive computer service or electronic
communication service, namely, Facebook, to
engage in a course of conduct that placed that
person in reasonable fear ofserious bodily injury

X Continued on the attached sher :'f

This criminal complaint is based upon these facts:

mh/nf
uflcnam ERTiKS
Specia] Agent, Federal Buraau of Investigation (FBD

Sworn to befone me and signed in my presence.

Date: April5. 2017

Judgeb

City md s*atq Chicaeo. Illinois

Printed name and Title
 Case: 1:17-cr-00220 Document #: 2 Filed: 04/05/17 Page 2 of 13 PageID #:15

UNITED STATES DISTRICT COIIRT

NORT}IERN DISTRICT OF ILLINOIS

AFFIDAVIT

I, MICHAEL ERICKS, being duly swom, state as follows:

1. I am a Special Agent with the Federal Bureau of Investigation, and have

been so employed since approximately 2011. My current responsibilities include the

investigation of violent crimes, including, among others, kidnapping, bank robbery,

firearm offenses, and the apprehension of violent fugitives.

2. Ttris afHdavit is submitted in support of a criminal complaint alleging

that IESIIA STANCIEL has violated Title 18, United States Code, Section
22614(2XA). Because this affidavit is being submitted for the limited purpose of

establishing probable cause in support of a criminal complaint charging STANCIEL

with cyberstalking, I have not included each and every fact known to me eoncerning

this investigation- I have set forth only the facts that I believe are recessary to

establish probable eause to believe that the defendant committed the offense alleged

in the complaint

3. , Ttris affidavit is based on my personal knowledge, infomation prcvided

to me by other Iaw enforcement agents, and my review of electronic ommunications

and recordings.

4. On or about October 24, 20L6, the government charged Brian Stafford

by criminal complaint with possessing a firearrr in and a{fectinginterstate commerce

after having been convicted of a felony, in violation of 18 U.S.C. $ 922(d(1). In support

 Case: 1:17-cr-00220 Document #: 2 Filed: 04/05/17 Page 3 of 13 PageID #:16

of that complaint, the government submitted an affidavit describing a purchase of

firearms from Staffordby a cooperating sonrce ('CS') working with the FBI. Stafford

was subsequently indicted for violations of 18 U.S.C. $922(gX1) and his case is

currently pending in the Northern District of Illino is. tlnited, States u. Brian Stafford,,

16 CR 727. T}l,e CS is a potential witness in that case.

5. Beginning approximately 6 days afber Stafford was charged, and

continuing until the present, STANCIEL has used the electronic communication

service, namely, Faceboo\ to write a number of posts and messages with the intent

to intimidate the CS and place him in reasonable fear of serious bodily injury, as

detailed below.

I. BACKGROUNDINFORMATIONABOUTFACEBOOK
6. Based on my training and experience, I have learned the foltowing about

Facebook. Facebook o$/ns and operates a free-access social networking website of the

same name that can be accessed at http://www.facebook.com. Facebook altows its

users to establish aceounts with Facebook, and users can then use their accounts to

share written news, photographs, videos, and other information with other Facebook

users, and sometimes with the general public.

7. Facebook
"sers
can select different levels of pri\racy for the
communications and information associated with their Facebook acounts. By

adjusting these privacy settings, a Facebook user can make information available

only to himself or herself, to particular Facebook users, to all Facebook users, or to

anyone with access to the Internet, including people who are not Faeebook users.
 Case: 1:17-cr-00220 Document #: 2 Filed: 04/05/17 Page 4 of 13 PageID #:17

Facebook accounts also include other account settings that users can adjust to control,

for example, the types of notifications they receive from Facebook"

8. Facebook users can create proflles that include photographs, Iists of

personal interests, and other information- Facebook users ean also post "siatus"

updates about their whereabouts and actions, as well as links to videos, photographs,

articles, and other items available elsewhere on the Internet. Facebook users can also

post information about upcoming "events,' such as social occasions, by listing the

event's time, location, host, and guest list. A particular user s profrle page also

includes a'TVall," which is a space where the user and his or her "Friends" can post

messages, attachments, and links that will typically be visible to anyone who can

view the user's profrle.

9. Facebook allows usert to upload photos andvideos. It also providesusers

the ability tn'?.;a{' (i.e., label) other Facebook users in a photo or video. When a user

is tagged in a photo or video, he or she receives a notification of the tag and a link to

see the photo or video.

II. STANCIEL'S USE OF THE FACEBOOK

ACCOIINT
10. As detailed below, STANCIEL has used the Facebook acoount
to make intimidating posts directed at the CS. STANCIEL has

been identified as the user of the EFacebook account ('Stanciel

Account') in the following ways.

11. First, the profrle for the Stanciel Account can be viewed at the following
-
. Agents most recently viewed the
 Case: 1:17-cr-00220 Document #: 2 Filed: 04/05/17 Page 5 of 13 PageID #:18

profile on April 5, 20L7, at which time the user of this account listed her name as
o'Iesha
Stanciel."

L2. Second, the CS has viewed the profrle information and photographs

associated with the Stanciel Account, and believes that the information and

photographs associated with the Stanciel Account profrle depict the individual who

the CS knows to be IESHA STANICIEL.T One of the images associated with the

Stanciel Account is attached to this affrdavit as Exhibit 1. The CS has identified this

photograph as depicting IESHA STANCIEL. f have also viewed the photographs

contained in the Stanciel Account, and compared those photographs to the

photograph on IESHA STANCIEL's Illinois driver's license; based on that

comparison, f believe that the Stanciel Account contains photographs of IESHA

STANCIEL.

13. Third, on or about November 8, 2016, in response to what the CS told

agents the CS perceived to be an intimidating post by STANCIEL on his Facebook

wall, detailed in the following paragpaph, the CS contacted STANCIEL at the

telephone number (630) 788-rcOO(. CS believed that number ta be used by
STANCIEL because On or about November 5,20L6, at approximately L2:41 p.m., an

1 CS is a former gang member who began cooperating with the FBI in this investigation in
2016. To date, the CS has received approximately $13,250 for his/her cooperation in this
investigation. The CS has pmvided reliable information in the past and has been paid
approximately $L,000 fuom the FBI and $2,000 from another law enforcement agency for
hislher cooperation in a prior investigation. The CS has criminal convictions for narcotics
offenses, battery offenses, attempt armed robbery, attempt obstruction ofjustice, and traffrc
offenses. The CS's information has been corroborated by investigators through surveillance,
other source information, and consensual calls. Neither the FBI nor the United States
Attorney's Office has made any promises to the CS in exchange for his/her cooperation.

4
 Case: 1:17-cr-00220 Document #: 2 Filed: 04/05/17 Page 6 of 13 PageID #:19

individual utilizing this phone number sent a text message to the CS that read, "This

Iesha call me."z The CS, who is familiar $rith STANCIEL's voice from their prior

interactions, recogni zed, tine voice on the other line as belonging to STANCIEL. In

this phone call, which was recorded, the CS asked STANCIEL, "What you post that

for on my Face fFacebook]?'The individual on the phone, who the CS reeognized by

voice to be STANCIEL, responded, "I was angry for why you did what you did."

III. STANCIEL Used the Stanciel Account to Make Intimidating Posts

That Placed the CS in Beasonable Fear of Serious Bodily Injury.

L4. On or about November 8,20L6,|STANCIEL, using the Stanciel Account,

made the following post on the CS's public4 wall, which read, "Snitches get stitches

and found in ditches" followed by 11 emojiss of firearms. Based on my training and

experience, in writing this message, I believe that STANCIEL was conveying her
belief that as a result of being a "snitclf' (cooperating with Iaw enforcement), the CS

2 Agents also obtained subscriber information for this phone number from T-Mobite. The
records fmm T-Mobile indicate that the phone number dialed by the CS was subscribed to by
"[firstname] Stanciel." Ttre T-Mobile records aiso indicate that the subscriber to this phone
number provided T-Mobile with the same residential address at which law enforcement
believes STANCIEL resides based on other publicly available records.
3This was approximately 6 days after the government filed a criminal complaint against
Brian Stafford in case number L6 CR727.
a Due to the Facebook privacy settings chosen by the CS, this post would have been visible to
the CS's contacts on Facebook, but not visible to the public at }arge.
5 Based on my training and experience, an emoji is a small image, symbol, or icon used in
text fields in electronic communications to express the emotional attitude of the writer,
convey information succinctly, or communicate a thought without using words.
 Case: 1:17-cr-00220 Document #: 2 Filed: 04/05/17 Page 7 of 13 PageID #:20

should "get stitches'' (be the recipient of serious bodily harm) or be 'found in [a ditch]"

(be killed).

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Holy Grind - Stand Up - TFILMEDBYJERELLI - Yor.lTube

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I Journee Williarns
Snitches get stitches and found in ditchest-'rlt
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6
 Case: 1:17-cr-00220 Document #: 2 Filed: 04/05/17 Page 8 of 13 PageID #:21

15. On the same date, STANCIEL, using the Stanciel Account, shared a

profile photograph of the CS on her public wall6 and typed the following comment:

"Have anyone seen him, if so [7 emojis of firearms] his head back." Based on my

training and experience, in writing this mess age, T believe that STANCIEL was
directing or asking others to shoot the CS in the head.

Journee Williams shared your photo,

Have anyone seen him, if so'tlE'A'q1"dt'it his head

back

6Due to the privacy settings associated with the Stanciel Account, this post would have been
visible not only to the Stanciel Account's contacts, but also to the public at large.
 Case: 1:17-cr-00220 Document #: 2 Filed: 04/05/17 Page 9 of 13 PageID #:22

16. On or about March LL, 2017, STANCIEL, using the Stanciel Account,

made a post on her public Facebook wall which stated, "[First and last name of CS]

have been working with the Feds since 2004, 2005, 20A7,2010 and now ["100"

graphicl. Fact# Why this nigga ain't been found in a ditch [eye graphic followed by

frve "100P graphics]"7. STANCIEL further urged others to "Please Shard'her post.

FacebooL enables users to share posts widely so that a user's message can be viewed

on many different users' accounts at the same time. Based on my training and

experience, I believe that, in writing this message, STANCIEL was exhorting others

to commit violence against the CS by questioning why his body was not already in a

diteh.

s
Ot'Q t.at ^'i!l ilorri,.renls'i - 2F. Si iare.s

;f r-i*e I comnrurt ;} slrare

Please Share

lesha Slarciel
5 hrs . Eatavia, lllinr:is . $

with the Feds since 2004,2m5,2007,2A10

and nowlqeFacts# Whythis nigga aint
been found in a ditchr,slg f,rg.P-lg

I
-havebeenworking
f, t"ite ! Comment I Share

7Based on my training and experience, a "100" emoji generally mearrs 'teeping it real" or an
expression of pride or a general acceptance of an idea.
 Case: 1:17-cr-00220 Document #: 2 Filed: 04/05/17 Page 10 of 13 PageID #:23

L7. On or aboutApril 4, 20L7,STANCIEL, using the StancielAccount, made

two additional threatening posts on her public Facebook wa1l. The first read, "I'm

speaking Facts, this ain't no rumor straight facts [100 emoji] I know some of y'allare

goirlg to be in shock, or disbelief. Word is this nigga [first and last name of CS] caugh{

a retail thief case, and set up his 30 year nigga up with the Feds. This shit rite here

hurt the heart [100 emoji] Keep your head up Bryan Stanford [first name] Stafford

[frrst name] Stafford ftelieved to be relatives of Brian Stafford).[L00 emoji]."

lesha Stanciel
f :-.t-. f.tftf: li- *
I'rn spealcing Facts, this ain't no rumor straight trctspl lmow sorne of y'all are
going to be in shoclr, or clisbelief. Wonl is this nqga
caught a retail thief case, and set up his 30 year nrgga up with the Feds. This
shit rite here hurt the heart l$l(eep )tour head up Bryan Stanforcl

r& Like 6I Share

Orya

I
 Case: 1:17-cr-00220 Document #: 2 Filed: 04/05/17 Page 11 of 13 PageID #:24

18. The second threatening post made by STAI{CIEL on or about April 4,

20L7, read as follows: 'I don't understand how mutherfuckers want to be silent when

it comes to a snitch, just sweep that shit under the rug like y'all do everything else

that ever happened in y'all life [100 emoji]."

lesha Stanciel
i "r.g [i.:ri*: Ii* $
I dont understand how mutherfrIckers want to be silent wnen it comes to a
snitch, just sweep that shit uncler the rug like y'all do everything else that ever
happened in y'all life$

id: Like d- Share

@z

10
 Case: 1:17-cr-00220 Document #: 2 Filed: 04/05/17 Page 12 of 13 PageID #:25

IV. Conclusion

19. Based on the above information, f respeetfuIly submit that there is

probable cause to believe that from on or about November 5,2ALG through on or about

April 4,20L7, the d.efendant IESHA STANCIEL, with the intent to intimidate the
CS, did use an interactive computer service or electronic communication service,

namely, Facebook, to engage in a course of conduct that placed the CS in reasonable

fear of serious bodily injury, in violation of fitle 18, United States Cod.e, Section

226LA(2)(A)

FUBTHER AFFIANT SAYETH NOT.

Special Agent, Federal Bureau of

Investigation

SUBSCRIBED AIq S\trORN to before me on April 5,20L7-

SHEILA FINNEGAN
United Stat€s Magistrate J

11
Case: 1:17-cr-00220 Document #: 2 Filed: 04/05/17 Page 13 of 13 PageID #:26

EXHIBIT