Case 1:19-mj-00315-PJG ECF No. 1-1 filed 09/12/19 PageID.
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Continuation of Complaint
I, Kurt Fiegel, being duly sworn, hereby state the following:
Introduction
1. I am a Special Agent with the U.S. Department of Homeland Security
Investigations (HSI). I am assigned to the Office of the Resident Agent in Charge in
Grand Rapids, Michigan. I began my career with HSI in September 2007 and prior
to joining HSI, served as a probation and parole officer for the Michigan
Department of Corrections for approximately six years. As an HSI Special Agent, I
have received training in the production, receipt, and possession of child
pornography. I am responsible for criminal investigations of these violations, as well
as both criminal and administrative violations of the customs and immigration laws
of the United States.
2. Because this continuation is for the limited purpose of establishing
probable cause to support the criminal complaint, it contains only a summary of
relevant facts. I have not included each and every fact known to me concerning the
entities, individuals, and events described in the continuation. This continuation is
made for the purpose of establishing probable cause that Joseph Francis BRISSON
II committed the crime of sexual exploitation and attempted sexual exploitation of a
child, in violation of 18 U.S.C. § 2251(a) and (e).
3. The statements in this continuation are based on: (a) my personal
participation in this investigation; (b) information provided by other federal law
enforcement officers; (c) a review of the contents of BRISSON’s cellphone; and (d)
my training and experience and the training and experience of other officers.
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Probable Cause
4. Today, September 12, 2019, Joseph F. BRISSON was interviewed in
his pursuit of a position as a Customs and Border Protection (CBP) officer. As part
of the hiring process, he was going to be subjected to a polygraph examination. The
interview occurred in the Eastern District of Michigan.
5. During the pre-polygraph interview, he admitted that he had explicit
photographs of a minor on his cellphone. At that point, the interviewers on behalf of
CBP contacted HSI special agents in the Eastern District of Michigan who arrived
to interview BRISSON.
6. BRISSON, his girlfriend, and Minor Victim 1,1 all reside together at a
house on Hancock Street in Manistee, Michigan. Minor Victim 1 is not BRISSON’s
child but is his girlfriend’s daughter. BRISSON’s girlfriend has two adult children
who also reside there.
7. BRISSON told CBP interviewers and HSI special agents that he had
set up a hidden camera in a bathroom of the residence in approximately May 2019.
8. BRISSON admitted he used the camera surreptitiously to record
Minor Victim 1 getting into and out of the shower. BRISSON said he downloaded
1The identity of Minor Victim 1 is known to law enforcement but is not included
herein to protect her privacy.
the videos from the camera onto his home desktop computer. He also took stills
from parts of the videos and saved those.
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9. BRISSON also admitted that he used his Apple iPhone 6 to take
photographs of the computer screen when the naked stills were displayed.
BRISSON did this so that he could have copies of the images on his iPhone. He
stored those images in a portion of a Snapchat account labeled “My Eyes Only.” “My
Eyes Only” is a setting in Snapchat that allows a user to password protect any
“Snaps” (i.e. videos or images) that a user does not want other people to see.
10. Special Agent Chad Cable of HSI is a computer forensic agent who has
reviewed BRISSON’s iPhone 6. BRISSON gave HSI agents consent to review his
phone and provided all necessary unlock codes, account passwords, etc.
11. SA Cable relayed to me that six images of Minor Victim 1 unclothed
appear in the “My Eyes Only” tab of the Snapchat account on BRISSON’s iPhone 6.
Two of these appear to meet the federal definition of child pornography; these two
images depict Minor Victim 1 fully nude. She is framed from about her chin through
her thighs and is clearly a pubescent teenager. Her naked breasts and pubic area
are exposed in the photographs. The setting of the images is clearly a bathroom and
the viewer can tell that Minor Victim 1 is stepping into or out of a shower. These
images appear to be still shots of a video that were cropped by BRISSON. Minor
Victim 1’s head and her feet are not visible.
12. BRISSON further admitted that he used the images and videos for his
sexual gratification. BRISSON masturbated using the depictions about twice a
week, beginning in May.
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13. BRISSON gave investigators his consent to search his home and
retrieve the desktop computer on which he saved the videos. That search is ongoing
and additional investigation continues.
Conclusion
14. Based on the foregoing information, I believe there is probable cause
to charge Joseph Francis BRISSON II with sexual exploitation and attempted
sexual exploitation of a minor beginning in or about May 2019 and continuing
through September 2019.
