Human Trafficking

On April 1, 2020, at approximately 2:00 a.m., San Diego Police Department (SDPD) Officer Smith was patrolling the area of El Cajon Blvd and 30th Avenue in San Diego, California, an area well known for prostitution activity. Officer Smith observed a young-looking, scantily clad, female walking slowly against
traffic. Officer Smith then observed the young female talk on a cell phone for a few moments, and then walk
to one of the motels and enter Room 222. A few minutes later, Officer Smith observed a young male leave
Room 222 and get into a car parked in the motel parking lot on the passenger side. Officer Smith saw that
the vehicle had two other males inside. Moments after that, Officer Smith observed a 50-60 year old male in
an older model Mercedes drive into the motel parking lot and park. The male exited the car and entered
Room 222. About 40 minutes later, Officer Smith observed the 50-60-year-old male exit the room and get into his car and drive off in the Mercedes. Officer Smith then observed the young male exit the passenger side of the Impala and walk back into Room 222. Believing that human trafficking was afoot, Officer Smith called SDPD’s Human Trafficking Team (SDPDHTT) for backup.
At the motel, SDPDHTT Detectives Johnson and Drilling made contact with the two males in the vehicle,
which was still parked in the parking lot. The two males were identified as members of the Washington Park
Criminal Street Gang. Both were on parole or probation for various criminal felony offenses. The driver
(Danny Driver) states he and his buddy (Bobby Backseat) are hanging out while their “homie” hangs with
his “wifey” in Room 222. Bobby Backseat states the same. Det. Johnson observes a firearm under the front passenger seat. Both Driver and Backseat are ordered to exit the car. Both deny knowledge of the firearm under the seat although Driver claims the vehicle belongs to him. Both are arrested for parole or probation violations.
Det. Drilling seizes the cell phones found on both Driver and Backseat’s person. Backseat has a “Fourth
Waiver” so Det. Drilling searches his cell phone and finds text messages between Backseat, Driver, and
another person named “Paulie.” The text messages appear to concern prostitution and pimping. Picture of
Backseat and other males throwing gang signs are observed. Det. Drilling asks Backseat who Paulie is and
Backseat states he does not know. Det. Drilling takes Backseat’s phone and texts “Paulie” the following message: “Hey, 5-0 out here. You better come out.” Detective Drilling then puts the phone down and it eventually locks itself. When Drilling tries to access it again, he can’t. He asks Backseat for the password to
unlock the phone and Backseat tells him to “eff himself.” Frustrated, Drilling holds the phone up to
Backseat’s face and it unlocks. Thrilled, he removes the password feature, places the phone in airplane
mode, and tosses the phone in an evidence bag.
A young male exits Room 222 (the same one who was observed by Officer Smith coming and going from that room) and walks towards the vehicle. He is wearing a shirt that reads “I make pimping look easy.” Det.
Drilling makes contact and later identifies him as Paulie Pimp, a member of the Washington Park Street
Gang. Police find out that Room 222 is registered to Paulie Pimp. Det. Drilling asks Paulie if he can go inside the room. Paulie denies it is his room but gives consent to enter.
Inside the room, police find Mary Minor in the bed half-dressed and Betty Bottom hiding in the bathroom.
Police also discover multiple used condoms, two cell phones, one computer, and some clothing in a bag.
Mary Minor states that she is 19 years of age and says she does not know Paulie Pimp. Later, when police take her outside away from Betty Bottom, Mary states she is 15 years old. She admits to working as a
prostitute for Betty and Paulie for about 3 weeks. Mary states she met Paulie on Facebook about 6 weeks earlier. About 4 weeks ago, Paulie agreed to pick her up in Arizona and drive her to San Diego. Both Paulie and Betty picked her up and drove her to San Diego. The three of them have been staying at the motel for 3
weeks or so. Mary claims Paulie is her pimp and has threatened her if she tried to leave. Mary also claims that Betty has been “schooling her” on what to do. Mary observed Paulie kick and punch Betty numerous times when she does not make her quota of $1000/day in prostitution.
Det. Drilling calls you because you are a federal prosecutor for the Southern District of California and prosecute human trafficking cases. Det. Drilling knows that trafficking of minors and child pornography carries “way more time” in federal court than similar offenses in state court. He wants you to take the case
and asks the following questions:
(a) What federal charges can be brought against Paulie Pimp? What evidence applies to each of the proposed federal charges? What further investigative steps can be taken to develop more potential evidence? What are the weaknesses or defenses that might be raised in the investigation? Can the weaknesses or defenses be overcome?
(b)What federal charges can be brought against Betty Bottom? What evidence applies to each of the proposed federal charges? What further investigative steps can be taken to develop more potential evidence? What are the weaknesses or defenses that might be raised in the investigation? Can the weaknesses or defenses be overcome?

(c)What federal charges can be brought against Danny Driver and/or Bobby Backseat? What evidence applies to each of the proposed federal charges? What further investigative steps can be taken to develop more potential evidence? What are the weaknesses or defenses that might be raised in the investigation? Can the weaknesses or defenses be overcome?