Case 3:23-mj-00487-GLS Document 2 Filed 05/03/23 Page 1 of 1

AO 91 (Rev. 11/11) Criminal Complaint

UNITED STATES DISTRICT COURT

for the
District of Puerto Rico E]
United States of America )
V. )
) Case No.
) 23-487 (M)
JEREMY FROIAS
)
)
)
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 April 30, 2023 - May 1, 2023 in the county of San Juan in the
District of Puerto Rico , the defendant(s) violated:

Code Section Offense Description

18 U.S.C. § 1801 Video voyeurism

18 U.S.C. § 2252A(a)(S)(B) Attempted possession of child exploitation material

This criminal complaint is based on these facts:

See attachment.

� Continued on the attached sheet.

Complainant's signature

John Auchter, FBI Special Agent

Printed name and title

Sworn in accordance with the Requirements of Fed. R. Crim. P. 4.1 by telephone at 4:55
____ pm on May 3rd, 2023.

Hon. Giselle
Date: May 3, 2023
Judge's López-Soler
signature

City and state: San Juan, Puerto Rico US Magistrate Judge, Giselle Lopez Soler
Printed name and title
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AFFIDAVIT IN SUPPORT OF COMPLAINT AND ARREST WARRANT

I, FBI San Juan Field Office Special Agent John Auchter, being duly sworn, hereby depose

and state that:

BACKGROUND

1. I am a law enforcement officer of the United States within the meaning of 18 U.S.C.

§ 2510(7), in that I am empowered by law to conduct investigations and to make arrests for federal

felony and misdemeanor offenses.

2. I am a Special Agent with the FBI and have been since May 1, 2016. I am also a

licensed attorney and have been admitted to practice by the Illinois Supreme Court since

November 1, 2012. I am currently assigned to the FBI San Juan Field Office, and I am part of the

Violent Crimes squad.

3. Because this Affidavit is submitted for a limited purpose, I have not included details

of every aspect of this investigation. I am thoroughly familiar with the information contained in

this Affidavit, either through personal investigation or discussions with other law enforcement

officers who have interviewed individuals or personally have obtained information, which they in

turn have reported to me.

4. Based on my training and experience and the facts set forth below in this affidavit,

there is probable cause to believe Jeremy Froias violated 18 U.S.C. § 1801 (video voyeurism) and

18 U.S.C. § 2252A(a)(5)(B) (attempted possession of child exploitation material).

FACTS SUPPORTING PROBABLE CAUSE

5. On or about April 29, 2023, Jeremy Froias (“Froias”) boarded the Harmony of the

Seas (the “Harmony”) in Miami, Florida. The Harmony is a cruise ship operated by Royal

Caribbean and was set to begin a seven-day cruise departing from Miami, Florida. The Harmony
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was also set to make land calls at Saint Maarten on May 2, San Juan on May 3, and the Bahamas

on May 5. The Harmony is scheduled to return to Miami, Florida on May 6, 2023.

6. On or about April 30, 2023, when the Harmony was navigating in international

waters, Froias installed a hidden Wi-Fi camera in a public bathroom on the aft of the Harmony’s

top deck, between the “Flow Rider” surfing simulator and a bar. The bathroom where the camera

was hidden is depicted in the following photos:

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7. The camera which Froias hid in this bathroom was secreted in a section of the wall

above the door which had been removed for repairs:

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8. At about 7:00 p.m. on May 1, 2023, another passenger noticed the hidden camera

and reported it to the Harmony’s crew. Harmony security personnel searched the bathroom and

found and seized the hidden camera. The hidden Wi-Fi camera is depicted in the following photo:
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9. The only portion of the hidden camera which was visible was the camera lens itself,

circled in the image above. The security personnel noticed that the camera had a Micro SD card

inserted so they reviewed the data on the card. The data included several hours’ worth of .mp4

video files. The initial videos depict Froias hiding the camera and adjusting the angle of the camera,

so it focuses on the area of the toilet. Froias is also seen taking his Apple iPhone 14 Pro Max out

of his pocket and appears to have connected the phone to the hidden camera using Wi-Fi. Froias

then exits the bathroom.

10. The additional videos on the camera depict more than 150 individuals, including

what appears to be at least 40 minors. Individuals are seen coming into the bathroom to either use

the toilet or to change into or out of swimsuits. Froias’s camera captured these individuals in

various stages of undress, including capturing videos of their naked genitals, buttocks, and female

breasts.

11. At about midnight on May 1, 2023, Harmony security personnel interviewed Froias

regarding the hidden camera. During this interview Froias admitted to placing the hidden camera

in the bathroom. Froias told Harmony security personnel that he knew the camera had been found

and taken because when he went to look for it on the evening of May 1, 2023, he was unable to

find it.

12. On May 3, 2023, I reviewed videos from the hidden camera’s micro-SD card. I saw

several videos which included several different minors using the toilet and the bathroom. These

videos depicted the minors’ naked genitals and buttocks. Some of these minors appeared to be as

young as four or five years old.

13. The videos also depicted Froias initially installing the camera on or about April 30,

2023, based on the camera’s timestamp. The videos depicted Froias then returning to the bathroom
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on or about May 1, 2023, to adjust the angle of the camera lens. Froias’s iPhone can be seen in this

video, and it appears to be displaying the video feed being captured by the camera.

CONCLUSION

14. Based upon my training, experience, and the above facts, I respectfully submit there

is sufficient probable cause to show Jeremy Froias violated 18 U.S.C. §§ 1801 (video voyeurism)

and 18 U.S.C. § 2252A(a)(5)(B) (attempted possession of child exploitation material).

I hereby declare, under penalty of perjury, that the information contained in this Affidavit

is known to be true and correct to best of my knowledge.

4:55 pm
Subscribed and sworn before me pursuant to FRCP 4.1 at __________ by telephone, this

3rd
________day of May, 2023.

John Auchter
Special Agent
Federal Bureau of Investigation

Hon. Giselle
Giselle López-Soler López-Soler
United States Magistrate Judge
District of Puerto Rico