“1. On November 11, 2023, Detective […] was assigned to follow-up on a case in which Adult Victim 1 (hereafter “AV1”), an adult female whose identity is known to law enforcement, reported that she was seen by Defendant from the ages of 13 to 16. AV1 reported that Defendant was her psychologist. AV1 reported that Defendant once instructed AV1 to masturbate while Defendant was in the room.
2. Detective […] interviewed AV1.
a. AV1 stated that she initially saw Defendant for depression, anxiety, and self-harm.
When AV1 disclosed a











addiction to Defendant, the sessions between Defendant and AV1 became exclusively about that.
b. AV1 stated when she was approximately 14 years old, Defendant talked with AV1 about sex and AV1 became aroused. Defendant instructed AV1 to strip nude and masturbate while he was in the room. AV1 said that Defendant faced away from her and did not turn around, but made a comment suggesting that Defendant could see her. AV1 believed Defendant had a camera or recording device that he was monitoring.
c. AV1 reported another incident when Defendant told her to undress and stand on a scale while naked.
d. AV1 said she stopped seeing Defendant when she was 16 years old because Defendant told her that adolescents take too much of his time.
e. AV1 said she later confided in a co-worker about Defendant and learned that another juvenile female had also reported Defendant touched her inappropriately.
3. Detective […] reviewed police records regarding Defendant and located three other reports of Defendant inappropriately touching juvenile female patients. Two of the reports also included an allegation of Defendant telling patients to undress and weigh themselves nude.
4. Detective […] also located a report where Defendant was found with Adult Victim 2 (here after “AV2”), an adult female whose identity is known to law enforcement). AV2 appeared concededly younger, but during police contact, it was determined she was an adult.
5. On April 10, 2024, Law Enforcement served a search warrant on Defendant’s person and home.
6. Detective […] contacted Defendant at Defendant’s office. Detective […] immediately noticed a camera hanging from a diploma.
7. Detective […] seized two flash drives and an iPhone from Defendant’s person.
8. Post-Miranda, Defendant made the following statements:
a. Defendant could not recall when he saw AV1.
b. Defendant saw a number of male patients for issues related to sexuality, but could not recall the last female.
c. Defendant said it would not be normal to have a patient weigh themselves naked and stated he had never done that.
d. Detective […] said it seemed highly unlikely that multiple people would falsely report the same behavior over multiple years. Defendant agreed that it was highly unlikely.
9. While Detective […] was with Defendant at Defendant’s Office, other Law Enforcement agents executed the search warrant at Defendant’s home. Multiple electronic devices were recovered from Defendant’s home.
10. Detective […] located ten child sexual abuse material (CSAM) images/videos and two voyeuristic videos on one of Defendant’s hard drives.
11. The CSAM files are described as follows:
[description of 12 files]
13. After searching Defendant’s devices, Detective […] contacted AV4:
a. Defendant was AV4’s former therapist and Defendant had done inappropriate
things with AV4.
b. AV4 told Defendant that AV4 thought she had an eating disorder. Defendant told AV4 that to do weigh-ins. Defendant further said that AV4 needed to wear the same thing for each weigh-in to get an accurate weight. Defendant instructed AV4 to change in Defendant’s office.
c. AV4 said she had asked Defendant about the camera in Defendant’s office and Defendant told AV4 that the camera was unplugged.”