E-FILED

IN COUNTY CLERK'S OFFICE

PIERCE COUNTY, WASHINGTON

October 02 2017 4:08 PM

1 SUPERIOR COURT OF WASHINGTON FOR PIERCE COUNTY
KEVIN STOCK
COUNTY CLERK
2 STATE OF WASHINGTON,

3 Plaintiff, CAUSE NO. 17-1-03748-8

vs.
4
MATTHEW JEFFREY HOLT, DECLARATION FOR DETERMINATION OF
5 PROBABLE CAUSE

6
Defendant.
7
GREGORY L GREER, declares under penalty of perjury:
8
That I am a deputy prosecuting attorney for Pierce County and I am familiar with the police
report and/or investigation conducted by the FBI SOUTH SOUND CHILD EXPLOITATION TASK
9
FORCE, initiated by LAKEWOOD PD incident number 1623701243;
10 That the reports from the SOUTH SOUND CHILD EXPLOITATION TASK FORCE and/or
investigation provided me the following information;
11
That in Pierce County, Washington, on or about the period between the 1st day of June, 2016 and
12 the 30th day of September, 2017, the defendants, MICHAEL JEROME HURST, MATTHEW JEFFREY
HOLT, JAMAAL LAMONT PINKNEY, QUANTREYVIS ALONZO SMITH, MONJAE NYKYLE
13 HAYNESWORTH, HOWARD RAY JONES, CLAYTON TYRONE KING and III, did commit the
crimes of CONSPIRACY TO COMMIT HUMAN TRAFFICKING IN THE FIRST DEGREE, HUMAN
14 TRAFFICKING IN THE FIRST DEGREE, HUMAN TRAFFICKING IN THE SECOND DEGREE, and
PROMOTING COMMERCIAL SEXUAL ABUSE OF A MINOR.
15 INTRODUCTION
In early August, 2016, a Lakewood PD sergeant was listening to recorded jail calls inmate MATTHEW
16 HOLT made while incarcerated in the Nisqually Jail. In some of the calls, HOLT discussed with others what
appeared to be ongoing prostitution activity. Because of what was heard, a copy of the calls was provided to FBI
17 Special Agent Kyle McNeal for follow-up investigation (SA McNeal is head of the FBI South Sound Child
Exploitation Task Force and investigates sex trafficking).
HOLT is well known to law enforcement and is the self-proclaimed leader of the Tillicum Park Gangsters
18 street gang. HOLTs street name is Boo and/or Get Money and he refers to himself as God or Tillicum
Park God.
19 Messages located by law enforcement on HOLTs Facebook account regarding his status as a gangster and
pimp, include one written August 8, 2016, when HOLT wrote the following:
Tbh (to be honest), idgaf (I dont give a fuck) anymore Im a fukkin pimp bitch . . . hoe or go
20 8 to 80 blind crippled or crazy if she cant walk bitch crawl cuz u gonna pay me . . . never money
over bitchs . . . its money outa bitchs is my (mob).
21 SA McNeals investigation, including a review of the jail calls, quickly led to evidence HOLT and other
males were prostituting young women, including minors.
22 The males involved as codefendants in this case have all been identified by victims and law enforcement as
Tillicum Park Gangsters, and include: HOLT; JAMAAL PINKNEY; MICHAEL HURST; MONJAE
HAYNESWORTH; CLAYTON TYRONE KING; QUANTREYVIS SMITH; and HOWARD JONES.
23 PINKNEYs street name is B1; HURSTs street name is SLIM; HAYNESWORTHs street name is
BABY BOO; KINGs street name is YG; and SMITHs street name is Q. (It is unknown at this time if
24 JONES uses a street name).
Office of the Prosecuting Attorney
DECLARATION FOR DETERMINATION 930 Tacoma Avenue South, Room 946
OF PROBABLE CAUSE -1 Tacoma, WA 98402-2171
Main Office (253) 798-7400
 1 All codefendants joined the Tillicum Park Gangsters with knowledge this gang exists solely for the
purpose of making large amounts of money by illegal means. All codefendants knew the rules involved in
becoming a member of the Tillicum Park Gangsters and joined in the existing agreement to comply with the rules
2 as they apply to every member of the gang equally. These rules include, among other requirements, that they
participate in the gangs activities and support each other in their endeavors.
3 The investigation in this case uncovered crimes committed by the codefendants including human
trafficking, assault, rape, and/or promoting commercial exploitation of a minor. There are at least fifteen victims of
4 these crimes identified thus far. These crimes were committed over a period of months that appear to begin in
summer, 2016 and date to September, 2017. The investigation is, however, ongoing.
For safety reasons, victims discussed in this affidavit will be identified by acronym only - AV (Adult
5 Victim) and JV (Juvenile Victim).
Some, but not all of the victims have been interviewed by law enforcement, however, all victims discussed
6 in this affidavit have been positively identified and those victims that have been interviewed were able to positively
identify the codefendants as the perpetrators of the crimes.
The charging period for this case will be June 1, 2016 through February, 2017 but may change as facts
7 develop further.

8 JAIL CALLS MADE BY HOLT AT THE NISQUALLY JAIL IN JULY, 2016

On July 27 through July 29, 2016, HOLT was incarcerated in the Nisqually Jail and made several
9 recorded phone calls to different people involved in this case. Some of the calls are described as
follows:
10
July 27, 2016 (1202 hours) HOLT calls PINKNEY and PINKNEY tells him he has several females
11 at a motel room in Bellingham. One of the females is identified as JV2;

12 On July 28, 2016 (1213 hours) HOLT talks to a female and tells her to tell that fucking bitch, I
said if she dont put some motherfucking money on my phone, right motherfucking now and tell that
13 bitch she didnt answer two times I called. On my mama you get, Im fucked up right now. Sittin in jail
cuz that dumbass snitch-ass bitch. HOLT also discusses several females and identifies one of them as
14 AV15;

July 27, 2016 (1537 hours) - HOLT talks to PINKNEY and PINKNEY tells HOLT he is at a motel in
15 Bellingham and per the discussion, there appear to be several females in the motel room. HOLT asks PINKNEY if
JV2 is at the motel and asks for her phone number. PINKNEY tells HOLT that JV2 and another girl are in a motel
16 room together on the first floor and HOLTs girl is with others on the third floor. PINKNEY tells HOLT he
renewed the rooms and discusses keeping the rooms secret so the girls dont know about each other. PINKNEY
17 also tells HOLT that PINKNEYs girl is doing two jugs for $400-$500 (a jug is street language for prostitution
date). PINKNEY then discusses with HOLT his plan of making $1500 per day, $750 from each girl.
July 27, 2016 (1639 hours) HOLT speaks with a female and tells her do you see how many
18 bitches done made me their God. I mean and continues, I gave you more than I gave any other
female. Theres females that would kill ta be treated the way I treated you, because I dont treat them
19 like nothing, but the shit on the bottom of my shoe. Bitches aint shit, I used to fuckem and forget
about em, now they bring me back hella chips.
20
Later in the same call, HOLT says a particular female is green lighted and states he doesnt
21 care about her baby and hopes the baby dies. He says youre talking to a full-fledged pimp. He tells
the female that if another female (he names) does not put money on his book by tomorrow, hes going
22 to smash her out.

23 Later in the conversation, the other female he threatened to smash out gets on the line and
HOLT tells her, your face is not pregnant, Ill punch you in the face.
24
Office of the Prosecuting Attorney
DECLARATION FOR DETERMINATION 930 Tacoma Avenue South, Room 946
OF PROBABLE CAUSE -2 Tacoma, WA 98402-2171
Main Office (253) 798-7400
 1
July 28, 2016 (0754 hours) HOLT asks PINKNEY about JV2 and asks to speak with her.
2 PINKNEY tells HOLT they did not make money yesterday and they needed to make a move because
nothing was coming through. PINKNEY says his girl is working the phone and he kept re-posting the ad.
3 PINKNEY says he left the girls at some point yesterday and went to Tacoma. HOLT tells PINKNEY either
he (HOLT) or PINKNEY needed to be there with the girls in order to make things happen. PINKNEY then
4 says he needed to make some money or he wouldnt have enough to pay for the rooms.

5 PINKNEY then gives the phone to JV2 and, among other things, tells JV2 he loves her but there is
this other girl that brings in $1200 a night. When JV2 asks if he will allow a specific girl to spend some of
6 the money, HOLT says Fuck no, I dont give no bitches no money. What the fuckin crazy.

7 Finally, HOLT tells JV2 he was going to get PINKNEY to take photos of the females for him and
that he wanted sexy photos.
8
July 28, 2016 (0917 hours) HOLT asks a female for Slims (HURSTs) phone number and to
make sure HURST gives him $1500 for his bail.
9
July 28, 2016 (0926 hours) HOLT talks to HURST and HURST references having spoken with JV2
10
and JV3. HURST tells HOLT they had not been hitting the phones. HURST also said PINKNEY told him
he was broke and HOLT mentioned to HURST he had sent PINKNEY $600.
11
July 28, 2016 (2151 hours) - HOLT calls PINKNEY and asks for money. PINKNEY tells HOLT they
12 had a telly (hotel room) and they were working on making money. HOLT tells PINKNEY to give the
money to Shelly, who he describes as the girl who came out with HAYNESWORTH to the motel in
13 Bellingham.

14

15 JAIL CALLS MADE BY HAYNESWORTH WITH IN PIERCE COUNTY JAIL FROM APRIL 26, 2017
THROUGH SEPTEMBER 15, 2017
16
HAYNEWSORTH was in custody in Pierce County Jail from April 26, 2017 through September 15, 2017.
17 During his incarceration he spoke on recorded phone calls and some of them were reviewed by SA McNeal. In
these calls HAYNESWORTH implicates himself in pimping activity with JV5 and other girls. The calls include a
request by HAYNESWORTH to have the bitches make money to then put on his books. Some of the calls are
18 outlined below:

19 May 9, 2017 (1906 hours) HAYNESWORTH talks to JV5 and discusses JV5 putting money on his
books. At one point HAYNESWORTH asks to talk to Jason and he then tells Jason to have that bitch
20 Makayla write him. HAYNESWORTH tells Jason he needed some pimp bells and discusses having
bitches put money on his books.

21 May 9, 2017 (2027 hours) HAYNESWORTH speaks with JV5 and asks who shes with. JV5 says she
is with Jason, Ron, and Rons grandpa. HAYNESWORTH tells JV5 to tell Ron to run the gang because
22 he is down right now.

May 9, 2017 (2046 hours) HAYNESWORTH speaks with JV5. JV5 says she is at the Howard Johnson
23 hotel with her home girls. JV5 tells HAYNEWORTH she was helping one of her girls with a couple of jugs.

24
Office of the Prosecuting Attorney
DECLARATION FOR DETERMINATION 930 Tacoma Avenue South, Room 946
OF PROBABLE CAUSE -3 Tacoma, WA 98402-2171
Main Office (253) 798-7400
 1 May 10, 2017 (1315 hours) HAYNESWORTH contacts and talks to JV5. JV5 tells HAYNESWORTH
she needs someone to take pictures of her. HAYNESWORTH then gives her permission to allow Jason to take
the pictures. JV5 tells HAYNESWORTH it has been difficult without him as she does not have any money or any
2 clothes. JV5 also discusses that Michael and Flex are trying to get at her (presumably to take over as her pimp).

3 May 10, 2017 (1546 hours) HAYNESWORTH speaks with JV5. JV5 tells him Q (SMITH) is also
trying to get at her. JV5 discusses going to treatment for three months and asks HAYNESWORTH if she should
4 go. HAYNESWORTH asks if she can stop using drugs and when JV5 says she can, he tells her to stay because he
needs her out there. JV5 also discusses a specific female as having snitched on Jay-ting. HAYNESWORTH
then says when he gets out he is going to stomp her (the specific female) face in. At the end of the call, JV5 tells
5 HAYNESWORTH she has to go because she has to finish posting this shit.

6 May 19, 2017 (1556 hours) HAYNESWORTH speaks with JV5. JV5 says she was about to be put on
tomorrow (put on means prostituting). JV5 notes she was getting a car.
7 May 19, 2017 (1624 hours) an unidentified male contacts JV5 and gives her a message from
HAYNESWORTH. The unidentified male says HAYNESWORTH wants her to put money on his books by
8 Monday and JV5 says she will put some money on his books that same day.

9 May 20, 2017 (0823 hours) - HAYNESWORTH talks to JV5 and asks about a specific named female.
JV5 tells him this female did not show up and HAYNESWORTH reacts by saying he needed to beat that bitch
up.
10
HAYNESWORTH then asks JV5 about a male named Ron and tells her Ron needs to run the gang
11 because he (HAYNESWORTH) is down right now. JV5 tells him she left Ron yesterday because Ron had
her on some bunk-ass missions. JV5 also tells HAYNESWORTH she has her own room.
12 May 20, 2017 (1030 hours) HAYNESWORTH talks to JV5 and tells her if this nigga leave you or
stuck out there, Im going to be hot. JV5 tells HAYNESWORTH she and the person (presumably Ron) had
13 already split up.

14
STATEMENTS BY OR ABOUT VICTIMS
15
1. STATEMENTS MADE BY OR ABOUT AV1 (17-19 years old during charged period):
16
JV3 was interviewed in September, 2017 and said HOLT prostituted AV1 sometime during the
17 summer of 2016, in Chocolate City and Tacoma. JV3 said she observed HOLT provide heroin to AV1 and
AV1 would prostitute for him as payment.
18
JV3 said she didnt see HOLT assault AV1 but they would fight and later she would see bruises
19 on AV1s body.

20 JV3 said when HOLT wasnt around, KING would collect money made by prostitution from AV1.
She said this occurred at the Red Lion Hotel in summer, 2016.
21
JV3 said HURST tried to get AV-1 to prostitute for him but she would not do it, however, she
22 said AV1 would have sex with HURST.

23 AV6 was interviewed by SA McNeal on April 17, 2017 and stated AV1 was present when other girls were
prostituting for HOLT and AV1 would hold the prostitution money for HOLT. AV6 was not aware of AV1
prostituting for HOLT, however.
24
Office of the Prosecuting Attorney
DECLARATION FOR DETERMINATION 930 Tacoma Avenue South, Room 946
OF PROBABLE CAUSE -4 Tacoma, WA 98402-2171
Main Office (253) 798-7400
 1
AV7 was interviewed by SA McNeal on May 1, 2017 and said she, AV1, AV6, PINKNEY, and HURST
would rent hotel rooms for prostitution and mostly they paid in cash to avoid detection by law enforcement. She
2 said they moved hotels frequently to avoid detection by law enforcement.

3 AV7 said AV1 worked phones and would set up dates. She said AV1 and the trick would establish a
price and AV1 would confirm it with HOLT. Ultimately HOLT would authorize the prices (half hour - $130; 2
4 hours - $160; 3 hours - $200, and 3-4 hours - $250).

AV7 said dates were set up through Backpage.com. She said AV1 and AV6 would set up the ads. HOLT
5 told AV7 she was too stupid to operate phones or set up dates. AV1 and AV6 would create content and take photos
of AV7 for the ads. She said ads were paid for with vanilla visa cards to avoid detection (vanilla visa card are
6 those that can be purchased without identification but money has to be loaded on them).

AV7 said AV1 was 18 but potentially 17 years old at the time the prostitution activity with HOLT
7 occurred. AV7 said AV1 wasnt with the group the entire time and that she came about halfway through and
assisted HOLT until the time AV7 was able to escape HOLT. AV7 believed AV1 and HOLT had some type of
8 relationship together.

9
2. STATEMENTS MADE BY OR ABOUT JV2 (15-17 years old during charged period):
10
JV3 was interviewed by SA McNeal in summer, 2017 and stated JV2 prostituted for HOLT in
11 summer, 2016 in Bellingham, Lakewood and Tacoma.

12 JV3 said she saw HOLT rape JV2 at the American Lodge in Tacoma sometime between early
summer, 2016 and August 1, 2016. She said HURST also witnessed the rape.
13
JV3 also said she saw HOLT assault JV2 during the same period as the rape. She said they were
14 at a Motel 6 and he choked JV2 until she fell to the floor.

15 AV6 was interviewed by SA McNeal and stated PINKNEY pimped juveniles during July or August, 2016,
including JV2 and JV3. AV6 described that she, PINKNEY, AV7, HURST, HOLT, JV3 and JV2 prostituted and
16 she witnessed JV2 and JV3 give their proceeds from prostituting to PINKNEY. She stated PINKNEY let the two
juveniles keep half the money but JV3 told her she had to give the other half to HOLT. (AV6 said AV7 would also
have to give half her money to PINKNEY and half to HOLT).
17 AV6 said HOLT prostituted JV2 from June until a recent arrest (prior to April, 2017). She said on
average, JV2 would do 10 dates per day for HOLT.
18 AV7 was interviewed by SA McNeal in May, 2017 and talked about observing HOLT pimp JV2.
She believed JV2 was 16-17 years old at the time because HOLTs sister and aunts were upset with him
19 for pimping an underage girl. AV7 said she observed HOLT prostitute JV2 for over a one month period.
AV7 said HOLT pimped JV2 in Bellingham, Tacoma and Chocolate City. AV7 said JV2 would also assist in
20 setting up prostitution ads and dates.

21 AV7 described HOLT assaulting JV2 on multiple occasions. She described one incident that occurred at
the Lakewood Town Center where JV-2 gave HOLT some attitude and HOLT punched and choked her, threw her
into a car, and kicked her. He called her a bitch and said I dare you to run! AV7 believed this happened on the
22 same day HOLT was pulled over by the police at the Days Inn in a stolen car. She said AV1 and AV6 also
witnessed the assault.
23
AV9 was interviewed by SA McNeal on May 16 and 17, 2017 and discussed her knowledge of
24 juvenile females pimped by HOLT and others. She stated that at some point in 2016, HOLT and AV1
Office of the Prosecuting Attorney
DECLARATION FOR DETERMINATION 930 Tacoma Avenue South, Room 946
OF PROBABLE CAUSE -5 Tacoma, WA 98402-2171
Main Office (253) 798-7400
 1 asked her to go for a ride with them. She got in the car and JV2 was already in the car with another female
named Hannah. She said the two girls said they were going to get some money. The group drove to a
house in Tacoma and AV1 and JV2 got out, saying it would be a quick visit (a quick visit is a very
2 brief prostitution encounter, i.e., a 15 minute encounter in a car). After about an hour, AV1 and JV2 came
out of the house and gave $180 to HOLT, who then gave JV2 $20 back, out of the proceeds.
3
The group then drove toward the vicinity of 56th and McKinley where JV2 did a car date or quick
4 visit. JV2 received $80 for this date and all the money was given to HOLT.

A few weeks after these events, AV9 found herself homeless and contacted AV1. AV9 said she
5 was invited to live with AV1, HOLT, PINKNEY, AV6, AV7, JV2 and an unknown female, at the
American Lodge in Tacoma, and she accepted the invitation. AV-9 said that on the first night she was with
6 them, AV6, AV7, JV2 and the unknown female went on more than 10 prostitution dates. The group then
rented a second room on the second night to keep up with demand.
7
3. STATEMTENTS MADE BY OR ABOUT JV3 (13-15 years of age during charged period):
8
JV3 was interviewed by SA McNeal in September, 2017, and stated she prostituted for HURST from early
9 summer, 2016, until August 1, 2016, in Lakewood, Tacoma, Lacey, Olympia and Bellingham. She said HURST
also tried to pimp her out of Portland.
JV3 said she did four dates a day while prostituting for HURST but said some days she didnt have any
10 dates and on others she did as many as eight. She said HURST believed she was 15 years old when they first met,
but she was really 13 years old at that time.
11 JV3 said HURST physically assaulted her on numerous occasions and described some of the assaults as
follows:
12 a. In about January, 2017, HURST assaulted her in his car at Harry Todd Park, in
Tillicum. She said he struck her with his fists on her head and body. JV3 said after
13 this assault, HURST kicked her out of his car;
b. In summer, 2016, HURST assaulted her at the Extended Stay hotel near the Tacoma
Mall in Tacoma. She said HURST picked her up from the bed in the hotel room and
14
threw her to the floor. She said she hurt her tailbone as a result of this;
c. Between summer, 2016 and August 1, 2016, HURST assaulted her at Chucks
15
house in Tillicum. She said HURST grabbed her by the neck and pushed her into his
car. She said she hit her head on the console of the car and suffered a knot on her
16 head and marks on her neck. She said HURST made her cover up the marks with
makeup;
17 d. Between summer, 2016 and August 1, 2016, JV3 said she had been asked by a
trick to send him a photo of her face but she didnt want to. She said HURST
18 choke slammed her into the closet and continued to choke her. She said HURST
told her she was going to take the picture; and
19 e. In September, 2017, in Tillicum, HOLT and KING both assaulted her.

20 JV3 said HURST forced her to have sex with him about two of every five times they had sexual
intercourse. JV3 said they would have sex sometimes as many as 3-4 times a day and she gave the following as
examples of the forced sex:
21 f. Two weeks into their relationship, HURST forced her to have sex with him at an
apartment in Woodbrook. She said this occurred between early summer, 2016 and
22 August 1, 2016;
g. HURST also forced her to have sex at the Red Lion Hotel in Tacoma between early
23 summer, 2016 and August 1, 2016;

24
Office of the Prosecuting Attorney
DECLARATION FOR DETERMINATION 930 Tacoma Avenue South, Room 946
OF PROBABLE CAUSE -6 Tacoma, WA 98402-2171
Main Office (253) 798-7400
 1 JV3 said HOLT always had a gun on him.

2 JV3 said she never saw HAYNESWORTH prostitute girls but knew he did. She said she heard
HAYNESWORTH joke with HOLT about prostituting girls and HAYNESWORTH referred to the girls as
3 female dogs. She said they would discuss who made the most money through prostitution.

4 JV3 said PINKNEY once paid her $120 in exchange for sex and she then gave the money to
HURST. She said it occurred in Bellingham.
5 AV6 was interviewed by SA McNeal and stated PINKNEY pimped juveniles during the months she was
with him, including JV2 and JV3. AV6 described a time in July or August, 2016, that she, PINKNEY, AV7,
6 HURST, HOLT, JV2 and JV3 prostituted. She said during that time period she witnessed JV2 and JV3 give their
proceeds from prostituting to PINKNEY. She stated PINKNEY let the two juveniles keep half the money but JV3
told her she had to give the other half to HOLT. (AV6 said AV7 would also have to give half her money to
7 PINKNEY and half to HOLT).
AV6 described an incident in August, 2016 when HOLT was violent with JV3. She said it
8 occurred at the Lakewood Town Center, in Lakewood. HOLT punched JV3 in the face, bit her back, and
threw her on the ground. AV6 said JV3s face was bloody and she had teeth marks on her back.
9
AV6 said, while in Bellingham, PINKNEY paid JV3 about $180 to have sex with her for five
10 minutes. AV6 said JV3 messaged her about it on Facebook and provided SA McNeal access to the screen
and information.
11
AV6 said HOLT prostituted JV3 from June until he was arrested (prior to April 14, 2017). She
said JV3 did 10 dates per day for HOLT.
12
AV6 said JV2 may have a tattoo related to HOLT on her body (branding).
13
AV7 was interviewed by SA McNeal and identified JV3 as LADY SLIM and said she was prostituting
14 for HURST (aka Slim). AV7 believed HURST and JV3 were in a relationship and noted HURST had sex with
JV3. AV7 believed JV3 was between 15 and 16 years old. AV7 said everyone knew JV3s age. She said she
had seen JV3 prostitute over a period of one week in Bellingham and Chocolate City.
15
AV7 said JV3 told her HURST once punched her in the face. She said JV3 had a black eye. AV7 asked
16 HURST about it and he denied it.

17

18 4. STATEMENTS MADE BY OR ABOUT JV4 (15-17 years of age during charged period):

JV3 was interviewed by SA McNeal and said JV4 prostituted for SMITH at the Motel 6, in Tacoma
19
on a day when HOLT and SMITH were shot at the same Motel 6 (police reports indicate this was August
1, 2016). She said SMITH knew JV4 had prostituted before meeting him and SMITH wanted part of the
20
money from her prostitution. JV3 said JV4 would give SMITH part of her prostitution money but SMITH
let JV4 got to keep part of it.
21
AV6 was interviewed by SA McNeal and described JV4 prostituting for SMITH. She said JV4 was
22 SMITHs girlfriend at the time. AV6 said JV4 would prostitute under the name Katie May and she saw her
work over a one week period before August 1, 2016 at the American Lodge, Howard Johnson and Motel 6, on
23 Hosmer St., in Tacoma. She said SMITH and JV4 talked to her about JV4 prostituting for SMITH.

24
Office of the Prosecuting Attorney
DECLARATION FOR DETERMINATION 930 Tacoma Avenue South, Room 946
OF PROBABLE CAUSE -7 Tacoma, WA 98402-2171
Main Office (253) 798-7400
 1 AV6 said she and JV4 were at the American Lodge hotel, in summer, 2016, when JV4 told her she hit a
$200 jug (jug is a prostitution date). She said SMITH messaged AV6 about Katie May prostituting for him
at that time.
2 AV7 was interviewed by SA McNeal and also described JV4 as prostituting for SMITH. She observed
this for one month starting in July, 2016. AV7 shared a hotel room with JV4 on several occasions. AV7 believed
3 JV4 was 15-16 years old and believed SMITH and HOLT knew her age.

4 AV9 was interviewed by SA McNeal and described SMITH as also pimping JV4. JV4
acknowledged prostituting, but denied SMITH was her pimp. She said she dated SMITH.
5
(An excerpt from SMITHs Facebook timeline dated September 10, 2017 states I guess you can
6 turn a hoe into house wife (emojis) even if she fucked all ur bros).

7
5. STATEMENTS MADE BY OR ABOUT JV-5 (16-17 years of age during charged period):
8
(see JAIL CALLS MADE BY HAYNESWORTH, above).
9

10

11 6. STATEMENTS MADE BY OR ABOUT AV-6 (19-20 years of age during charged period):
12 AV6 was interviewed by SA McNeal in April, 2017 and stated she met PINKNEY in February, 2016.
AV6 said that after a short romance, she moved in with him. She said Initially PINKNEY was nice and appropriate
but PINKNEY changed while incarcerated (May 5, 2016 June 4, 2016).
13 AV6 stated that two days after being released from jail (June 6, 2016), PINKNEY forced her to prostitute
with two adult males. AV6 told PINKNEY she didnt want to but PINKNEY told her to do it or he would beat her
14 ass.
AV6 described this first prostitution event with PINKNEY as involving HOLT and AV7. She said the
15 four of them rented a room at the Super 8 motel in Lacey, Washington. The motel was rented in her name but
PINKNEY placed the ad with Backpage.com for what would be the prostitution activity that would occur at the
motel. AV6 said she answered calls and set up dates but all money made from prostitution went to PINKNEY.
16 AV6 said she didnt want to do it after that but PINKNEY grabbed her by the hair and said she was still going to do
it.
17 AV6 said she prostituted for PINKNEY every day from June, 2016 through January 23, 2017 and would
do an average of 10-15 dates a day. She said she made about $2,000 per day from prostitution and all this money
was given to PINKNEY.
18 AV6 gave a detailed description of how the ads on Backpage.com were created and paid for. She described
PINKNEY as using various methods to avoid police detection, including using vanilla credit cards (purchased at
19 stores and not requiring identification) to buy bitcoins to then use to pay for the ads. She said he used multiple
phone numbers every few days via a smart phone app that allows a person to remain anonymous regarding phone
20 numbers. AV6 said PINKNEY created the ad content for AV6 and he set the prices for the dates ($150 for half
hour and $250 for hour), and she was not allowed to take less.
AV6 was able to list 11 hotels PINKNEY forced her to prostitute out of, including hotels in Olympia,
21 Lacey, Bellingham, Renton, Lakewood, Mount Vernon and Tacoma. She said hotel rooms would be rented in either
her or PINKNEYs names and were paid for with money made from prostitution dates. She said PINKNEY took
22 her to Oregon to prostitute and also made her prostitute out of his mothers home.
AV6 described PINKNEYs rules, which she was forced to comply with and included the following:
23 a. No BB (BB means bare back or, without condom). (AV6 was told she wasnt
allowed to do BB because she was his woman);
24
Office of the Prosecuting Attorney
DECLARATION FOR DETERMINATION 930 Tacoma Avenue South, Room 946
OF PROBABLE CAUSE -8 Tacoma, WA 98402-2171
Main Office (253) 798-7400
 1 b. No sleeping with black males (generally, because the pimp believes black males will
steal them in order to pimp them, themselves);
2 c. No use of a cell phone (PINKNEY would monitor any cell phone use AV6 was
allowed);
3 d. No coming and going as she pleased. A vehicle was purchased with proceeds from
prostitution dates and put in AV6s name, although she was not allowed to use it or
4 even possess the keys unless PINKNEY allowed it. When allowed to use the car,
PINKNEY put time restraints on her use.
5 e. All money collected from dates had to be handed to PINKNEY. AV6 was not allowed
to keep any money. When AV6 wanted something she had to ask PINKNEY and he
6 would give her money if he allowed the purchase.
f. AV6 was kept separate from other prostitute victims pimped by PINKNEY and HOLT;
7 AV6 was only allowed limited communication with them.
AV6 said she experienced violence at the hands of PINKNEY on a daily basis and added he assaulted her
8 at least twice a day. AV6 described a few of the violent events as follows:
a. In about October, 2016, in downtown Olympia, PINKNEY pulled out a handgun,
9 loaded it, pointed it at AV6 and pulled the trigger. AV6 said the gun jammed and
didnt fire. She said PINKNEY had been drinking;
10 b. At Comfort Inn in Lacey, PINKNEY struck her in face and ribs. PINKNEY hit her head
against a counter and tried to suffocate her. AV6 described her teeth bleeding and
11 having bruised ribs after this incident;
c. In September, 2016, PINKNEY kicked AV6 in her kidney and next day she developed
12 kidney infection and sought treatment at Capital Medical Center, in Olympia;
d. AV6 periodically memorialized assaults inflicted on her by PINKNEY by taking videos
13 and photos of her injuries and putting them on her Facebook account;
e. If she refused to go on a prostitute date, PINKNEY would beat and/or choke her.
14 AV6s mother was interviewed by SA McNeal on April 14, 2017 and confirmed seeing her daughters
body always bruised. She believed the bruising was inflicted by PINKNEY, although AV6 would make excuses for
15 the bruising. AV6s mother described an incident when PINKNEY withheld AV6s asthma inhaler from her, also.

PINKNEY offered AV6 heroin but she refused it.

16
AV6 said PINKNEY carried a black handgun and kept it in the hood of his vehicle (Dodge Ram) until he
17 lost it.

AV6 said HOLT told her he had been involved in pimping girls since he was 16-17 years old. AV6 said
18 PINKNEY and HOLT shared girls when prostituting them and described an event in Bellingham where she and
AV-7 did a date with a Mexican male for $1,000. She stated at times, HOLT would drop girls off with PINKNEY
19 and leave. PINKNEY would then run the girls and coordinate the prostitution. HOLT would receive the proceeds
of the prostitution from the girls he provided.
20
AV6 said PINKNEY showed HOLT how to set up the ads.

21 AV6 stated HAYNESWORTH was always with SMITH and although she doesnt have personal
knowledge of HAYNESORTH prostituting females, she does know hes always at the motel when it
22 occurs.

AV6 said she prostituted once before meeting PINKNEY (when she was 17 years old) and placed
23 a couple of ads on Backpage.com after breaking up with PINKNEY because she needed money, but she
said she never went through with the act.
24
Office of the Prosecuting Attorney
DECLARATION FOR DETERMINATION 930 Tacoma Avenue South, Room 946
OF PROBABLE CAUSE -9 Tacoma, WA 98402-2171
Main Office (253) 798-7400
 1
JV3 was interviewed by SA McNeal and said AV6 prostituted for PINKNEY in Lacey, Olympia,
2 Lakewood, Bellingham, Tacoma and Portland. She also said PINKNEY assaulted AV6 on numerous
occasions and described seeing him punch her in the face at the Super 8 in Lacey, as one of the
3 examples.
AV7 was interviewed by SA McNeal and identified AV6 as prostituting for PINKNEY. She said she
4 observed the prostitution as she was there with her and PINKNEY almost every day from July to August, 2016.
AV7 saw AV6 give the money to PINKNEY. AV7 saw PINKNEY assault AV6 on multiple occasions and said he
5 was cruel to her. She saw PINKNEY punch AV6 in the face, slap her in the face, and choke her until she passed
out. AV7 saw AV6 with black eyes on multiple occasions.

6 AV7 stated she once went to a hotel room for a prostitution date with a Mexican male, and had sex
with him. The Mexican male gave her $130 and she gave the money to HOLT. She said the room was
7 rented by either PINKNEY or AV6 and they were both present. AV7 believes PINKNEY, HOLT and
AV6 were in a car while the date occurred and were watching her baby. AV7 said AV6 was prostituting
for PINKNEY out of the same room during this time.
8
AV7 said dates were set up through Backpage.com and that AV1 and AV6 would set up the ads. AV7 said
9 if out-calls (ie, going to the dates residence), AV6 or HOLT would drive.

10 AV7 stated that in July, 2016, was with HOLT, PINKNEY and AV6 at the Bellingham Lodge and
AV6 had rented two rooms. She said HOLT wanted her to prostitute in the first room, but she didnt
11 want to. She did the date, however, and the date was hurting her so she told him to stop. She then
took money from the date and walked to the other room where HOLT was waiting in order to give him
12 the money but HOLT wouldnt let her in. AV6 told HOLT she wanted to see her baby (who was with
HOLT). HOLT then opened the door and punched her in the face. When she fell she went into a seizure
13 and HOLT filmed the seizure;

(On February 10, 2017, Lacey PD Off. Stanford responded to the Best Western Plus Hotel, in
14 Lacey, regarding a domestic violence call. AV6 told Off. Stanford that her fiance, PINKNEY, had
assaulted her. The officer took a recorded statement from AV6 in the presence of her mother. AV6
15 detailed the assault and also stated PINKNEY had forced her into prostitution and had threatened to kill
her if she ever snitched on him. Off. Stanford noted PINKNEY was continually sending AV6 messages
via Facebook messenger, asking where she was, during the interview).
16

17
7. STATEMENTS MADE BY OR ABOUT AV7 (19-20 years of age during charged period):
18
AV7 was interviewed by SA McNeal on May 1, 2017 and stated she began a two-week
19 relationship with HAYNESWORTH in summer, 2016. During these two weeks HAYNESWORTH
introduced her to HOLT. On or about July 4, 2016 HOLT asked AV7 to go somewhere with him but didnt
20 say where. AV7 and her infant daughter then got into HOLTs vehicle and HOLT drove them to a hotel in
Olympia. Once there, HOLT told her there was a date waiting for her in the hotel room and she needed
to go and bring him the money. AV7 knew this meant have sex with the date.
21
AV7 did not want to do this date but HOLT told her if she didnt he would kill her and leave
22 her on the highway and implied he would also kill her baby. AV7 said HOLT was known for physically
assaulting males and females and was known to shoot guns. AV7 was scared for her life and knew HOLT
23 would potentially kill her if she didnt do what he wanted.

24
Office of the Prosecuting Attorney
DECLARATION FOR DETERMINATION 930 Tacoma Avenue South, Room 946
OF PROBABLE CAUSE -10 Tacoma, WA 98402-2171
Main Office (253) 798-7400
 1 AV7 then went to the hotel room where she encountered the date, a Mexican male, and had sex
with him. The Mexican male gave her $130 and she gave the money to HOLT. She said she did not know
HOLT was a pimp before this event. She said the room was rented by either PINKNEY or AV6 and they
2 were both present. AV7 believes PINKNEY, HOLT and AV6 were in a car while the date occurred and
were watching her baby. AV7 said AV6 was prostituting for PINKNEY out of the same room during this
3 time.

4 AV7 said the next day, a different hotel was used and she engaged in more prostitution. She said
during the dates, HOLT was in a car, driving around. AV7 said she prostituted for HOLT from July 4,
2016 through August, 2016 and on August 30, 2016 she was able to escape HOLT when he was arrested.
5
AV7 listed numerous hotels in various cities where she prostituted for HOLT including Tacoma,
6 Lakewood, Olympia, Everett, Bellingham, and Chocolate City.

AV7 said the reason for moving hotels frequently was to avoid detection by law enforcement. She
7 said she, AV1, AV6, PINKNEY, and HURST would rent rooms and mostly they paid in cash to avoid
detection by law enforcement.
8
In exchange for prostitution, HOLT promised to take care of AV7 financially, provide a place for
9 her and her baby to live, help get her into school, and promised to be loyal to her.

AV7 described HOLTs rules as follows:

10
a. No leaving or going anywhere (AV7 restricted to hotel room and smoking area);
11 b. AV7 was allowed a cell phone but it was monitored by HOLT and she was not
allowed to bring it into the bathroom by herself;
12 c. All money goes to HOLT;
d. AV7 not allowed to buy food for herself, HOLT would buy it and bring it to her;
13 e. AV7 not allowed to talk to other males or other female prostitutes (HOLT would
occasionally purchase two rooms in order to split girls up because he didnt want
14 them speaking with each other);
f. AV7 to prostitute every day with no days off;
15 g. HOLT occasionally set a quota and girls would have to meet $200-$300 per day. If
they did not meet quota, AV7 speculated they would get beat but said she always
16 made her quota.

AV7 would do 4-5 prostitution dates per day and make about $600 per day, all of money would then go to
17 HOLT.

18 AV7 said AV1 worked phones and would set up dates. AV1 and the date would establish a price and AV1
would confirm it with HOLT. Ultimately HOLT would authorize the prices (half hour - $130; 2 hours - $160; 3
19 hours - $200, and 3-4 hours - $250).

AV7 said dates were set up through Backpage.com. She said AV1 and AV6 would set up the ads. HOLT
20 told AV7 she was too stupid to operate phones or set up dates. AV1 and AV6 would create content and take photos
of AV7. She said ads were paid for with vanilla visa cards to avoid detection.
21
AV7 said if out-calls (ie, going to the dates residence), AV6 or HOLT would drive.
22 AV7 said her relationship with HOLT began as boyfriend/girlfriend but quickly changed. She said he was
abusive to her mentally and physically. She said he called her names, broke her down, and made her feel bad. AV7
23 said she was homeless at the time and HOLT knew she had been in an abusive relationship in the past and that she
was vulnerable.
24
Office of the Prosecuting Attorney
DECLARATION FOR DETERMINATION 930 Tacoma Avenue South, Room 946
OF PROBABLE CAUSE -11 Tacoma, WA 98402-2171
Main Office (253) 798-7400
 1 AV7 said HOLT had punched her in the face, slapped her, choked her, and recorded her having a seizure
after he physically assaulted her. She said he assaulted her when she didnt do what he wanted and assaulted her
once every five days or so. She described some of the assaults, as follows:
2
a. In July, 2016, she was with HOLT, PINKNEY and AV6 at the Bellingham Lodge and
3 AV6 had rented two rooms. She said HOLT wanted her to prostitute in the first
room, but she didnt want to. She did the date, however, and the date was hurting
4 her so she told him to stop. She then took money from the date and walked to the
other room where HOLT was waiting in order to give him the money but HOLT
5 wouldnt let her in. AV7 told HOLT she wanted to see her baby (who was with
HOLT). HOLT then opened the door and punched her in the face. When AV7 fell
6 she went into a seizure and HOLT filmed the seizure;
b. AV7 described an incident in Chocolate City when he slapped her in the face;
7 c. AV7 described an incident when HOLT sexually assaulted her in Bellingham. AV7
said she was on her period and HOLT wanted to have sex with her but she didnt
8 want to and HOLT told her if she didnt, he would leave her dead on the side of the
road. AV7 said she then had sex with him but felt she was forced;
9 d. AV7 said HOLT threatened her everyday by telling her he would kill her, beat the
shit out of her and/or shoot her.
10
AV7 said HOLT always had a gun on him. She also said she had seen him using a shotgun. AV7
described HOLT as being involved in several shootings that told law enforcement what she knew about them.
11
AV7 denied ever prostituting before doing so with HOLT.
12
JV3 was interviewed by SA McNeal and said AV7 prostituted for HOLT in Bellingham and Tacoma
between summer, 2016 and August 1, 2016. JV3 said once, in summer 2016, HOLT choked AV7 and AV7 had a
13
seizure.

14 AV6 was interviewed by SA McNeal and described her own first prostitution event with PINKNEY as
involving HOLT and AV7. She said this may have been AV7s first time prostituting for HOLT, also. She said
15 the four of them rented a room at the Super 8 motel in Lacey, Washington. The motel was rented in her own name
but PINKNEY placed the advertisement with Backpage.com for what would be the prostitution activity that would
then occur at the motel. AV6 said she answered the calls and set up the dates but all the money made from the sex
16 went to PINKNEY. AV6 said she didnt want to do it after that but PINKNEY grabbed her by the hair and said she
was still going to do it.
17 AV6 described an incident when HOLT grabbed AV7 and pushed her onto a bed. AV6 said in
another incident, HOLT used his cell phone to record AV7 having an anxiety attack.
18
AV6 said PINKNEY and HOLT shared girls when prostituting them and described an event in
Bellingham where she and AV7 did a date with a Mexican male for $1,000.
19

20 8. STATEMENTS MADE BY OR ABOUT AV8 (18-19 years of age during charged period):

AV8 was interviewed on April 26, 2017 at S.C.O.R.E. detention facility by SA McNeal and
21
identified HOLT by his street name of Get Money and Boo. AV-8 picked HOLT from a sanitized
photo and discussed her relationship with HOLT and her knowledge of HOLT pimping females, as
22 follows.

23 AV8 met HOLT 7-8 years prior and they began dating about a year after they met. AV8 then
dated HOLT for about 5 years. AV8 said that during that 5 year time period, HOLT also dated AV10.
AV8 described HOLT as having been abusive to her and states he is why she no longer has her children.
24
Office of the Prosecuting Attorney
DECLARATION FOR DETERMINATION 930 Tacoma Avenue South, Room 946
OF PROBABLE CAUSE -12 Tacoma, WA 98402-2171
Main Office (253) 798-7400
 1
AV8 said she first discovered HOLT pimping females a couple weeks after they began dating.
She said HOLT told her about his hoes and how he lived off money they made prostituting for him.
2 AV8 said HOLT never had a legitimate job the whole time shes known him.

3 AV8 said the girls HOLT was pimping were between 13 and 15 years old. She said HOLT had
two to four girls working for him on a regular basis and some girls would only work for a short time. AV8
4 said one underage girl HOLT pimped had the same name as JV11 but did not know the full name of this
girl. She also did not know the names of any of the other girls he pimped. AV8 said HOLT tried to keep
her away from the prostitution and didnt know exactly how HOLT prostituted the girls but she overheard
5 him talking about Craigslist and Backpage.com.

6 AV8 said one time HOLT suggested she prostitute for him and told her how easy it was and other
details, but AV8 refused and HOLT never brought it up with her again.
7 AV8 said HOLT always had a lot of money on him and once drove up in a Lexus with $5,000
cash on him.
8
AV8 observed HOLT to be violent with the girls he pimped and said he would beat up a lot of
9 people. She specifically discussed the following violent events:

a. She and AV10 did not get along during the time period HOLT was dating both of
10
them. AV8 said once, at a trailer park in Tillicum, AV8 and HOLT were in a car and
AV10 jumped on the vehicle. She said HOLT got out of the car and punched AV10 in
11 the face and proceeded to punch her until she could not get up.
b. AV8 said HOLT beat AV10 on a daily basis and described AV10 as HOLTs punching
12 bag. AV8 was unaware of whether HOLT was pimping AV10 but assumed she was;
c. AV8 said the girl with the same first name as JV11 had been physically assaulted by
13 HOLT. AV8 said she did not witness the assaults but did witness the aftermath. She
said HOLT would take this girl away from everyone and when she would see her
14 again, the girl would have black eyes and swollen face. AV8 said she believed the
assaults happened because this girl did not have any money for HOLT;
15 d. AV8 said she, herself would receive minor beatings from HOLT about once a
week. She described minor beatings as being slapped in the face when he
16 disagreed with her. AV8 added he would do this in front of her children;
e. On one occasion in 2011, AV8 said HOLT got out of prison and he and HURST came
17 to the house she and HOLT were living in. AV8 told HOLT he needed to leave
because she was trying to keep her children and CPS had an issue with HOLT living
18 with her and the children. HOLT then took her upstairs, tied her up with cord, and
beat her for about 4 hours. One of her young children came upstairs when he heard
19 her scream and HOLT struck the child, also. She said HOLT said she was not going to
leave him and he proceeded to rape her. AV8 said after this beating her face was
20 unrecognizable and her father told her to file a report, which she says she did but
then told the detective she didnt want to go through with charges because she was
21 afraid of HOLT and his associates. AV8 said HOLT threatened to kill her and she is
still deathly afraid of him. AV8 said she had been trying to get her children back but
22 because of this incident, she wasnt able to and the children are still traumatized by
HOLT and the incident (law enforcement has not been able to locate a police report
23 regarding this incident as of yet);

24
Office of the Prosecuting Attorney
DECLARATION FOR DETERMINATION 930 Tacoma Avenue South, Room 946
OF PROBABLE CAUSE -13 Tacoma, WA 98402-2171
Main Office (253) 798-7400
 1 f. AV8 said HOLT bragged about knocking females out and he was known for that. She
said it occurred if they did something HOLT did not like or did not follow his
2 instructions
g. AV8 said on one occasion HOLT caught her in a lie and held a knife to her throat.
3 She said he later said hed just been kidding.

AV8 said HOLT would have sex with every girl that prostituted for him. She knew this because HOLT
4 would tell her, and the girls would tell her, also.

5 AV8 said HOLT is leader of the Tillicum Park Gangsters (hereafter, TPG). She said HOLTs associates
would have sex with girls HOLT pimped and they also were believed to be prostituting girls themselves. AV8 said
6 associates and HOLT would pass the girls around and share them like sharing girlfriends.

AV8 said HOLT would train young boys ages 9-11 to rob cars and become gang members and at times
7 would tell other gang members to have sex with the girls. She said if the individuals refused to do what he said,
there would be consequences, like beatings. AV8 said the girl with the same first name as JV11 and other girls were
8 afraid of HOLT and would do things for him out of fear.

AV8 said she had prostituted since 2011, after HOLT went to prison, but that HOLT was never her pimp.
9 She said she did it because she needed the money. She said she last prostituted about a year prior.

10
9. STATEMENTS MADE BY OR ABOUT AV9 (26-27 years of age during charged period):
11
AV9 was interviewed by SA McNeal on May 16 and 17, 2017 and discussed her knowledge of
12 juvenile females pimped by HOLT, and others. She said at some point in 2016, HOLT and AV1 asked her
to go for a ride with them. She got in the car and JV2 was in there with another female named
13 Hannah. She said they were going to get some money. The group drove to a house in Tacoma and
once there, AV1 and JV2 got out, saying it would be a quick visit. After about an hour, AV1 and JV2
14 came out of the house and gave $180 to HOLT (HOLT then gave JV2 $20 back, out of the $180 made
from the prostitution).
15
AV9 stated the residence the group went to was the residence of a former trick of AV1s sister. She said
AV9 was familiar with the trick and believed because of that, she set up the date there for JV2.
16
After this date, the group drove to the vicinity of 56th and McKinley where JV2 did a car date or
17 quick visit. JV2 received $80 for this date and gave the money to HOLT.

18 AV9 said after this, the group drove toward Hosmer, in Tacoma, and JV2 did a car date or quick visit.
She said JV2 made $80 and gave the money to HOLT. She said the group then let her off near a Subway restaurant
and she then received a call from AV1 asking her about getting on the team which meant joining them is
19 prostituting for HOLT.

20 AV9 said a few weeks after this she became homeless and she contacted AV1 who then told her to come to
their hotel. She was invited to live with HOLT, PINKNEY, AV1, AV6, AV7, JV2, and an unknown female, at the
21 American Lodge in Tacoma. AV9 said on her first night there, AV6, AV7, JV2 and the unknown female went on
more than ten prostitution dates. AV9 said the group rented a second room on the second night in order to keep up
with demand.
22
AV9 stated AV1 said as long as she was willing to help make money and be part of the team, she was
23 welcome to stay with them. AV9 described the team a HOLT being in charge of prostitution, a couple of the girls
would act as runners (runners set up dates, and supply food, clothes and drugs), and about five girls would
24
Office of the Prosecuting Attorney
DECLARATION FOR DETERMINATION 930 Tacoma Avenue South, Room 946
OF PROBABLE CAUSE -14 Tacoma, WA 98402-2171
Main Office (253) 798-7400
 1 prostitute for him. AV9 said she acted as a runner and would buy condoms and watch AV-7s baby during her
prostitution dates. AV9 said she never prostituted for HOLT.
2 AV6 was interviewed by SA McNeal and stated AV9 prostituted for HOLT for a couple of days in
summer, 2016 and all the money from the dates went to HOLT. AV6 also described an incident when HOLT
3 kicked AV9 in the face.

4 AV7 was interviewed by SA McNeal and identified AV9 as prostituting for HOLT. She said AV9 lived
next to AV1 and AV9 prostituted for HOLT a couple of times out of the Western Inn, in Lakewood. AV7 noted
HOLT physically abused AV9 by kicking her face into a wall at the Western Inn. AV7 said AV9 was trying to get
5 money from her mother and the defendant wanted the money. AV9 wasnt getting it fast enough and as a result,
HOLT assaulted her (AV9 described this incident in her interview with SA McNeal, also). AV7 believed they were
6 at the hotel for two days. AV7 said she also witnessed HOLT slap AV9.

7
10. STATEMENTS MADE BY OR ABOUT AV-10 (25-26 years of age during charged period):
8
AV10 was interviewed on May 24, 2017 by SA McNeal and Lakewood PD Det. Ryan Larson and stated
9 she first began prostituting when she was 18 years old and at first prostituted for herself (no pimp) but did have a
pimp shortly after beginning.
10 AV10 said she went to school with HOLT and has known him many years; they were in a relationship
about 5-6 years ago. AV10 described HOLT as very abusive to her and that he both physically and sexually
11 assaulted her on several occasions. She described some of these assaults as follows:

12 1. HOLT raped her in front of her children on two separate occasions (AV10 believes
one of her children is still traumatized by the events);
13 2. In April, 2012, HOLT bruised AV10s spine. She said HOLT had misplaced some
methamphetamine and had everyone looking for it. AV10 got tired of looking and
14 tried to sneak out the back door. HOLT caught her and pounded something on her
back and then beat her and kicked her in the face. AV10 tried to get HOLT to take
15 her to the hospital but he wouldnt let her go. (AV10s mother eventually took her
but AV10 lied to the hospital officials about how it happened);
3. AV10 said she sought medical treatment on at least five different occasions after
16
being injured in assaults inflicted by HOLT. In some of these incidents HOLT cut her
hair, busted her lip, broke her tooth, punched her, kicked her, pistol whipped her,
17
put a gun to her head, and kidnapped her and her son;
18 AV10 said HOLT would beat her if she tried to leave or if she said something wrong. She eventually
was able to leave HOLT but she still suffers from PTSD.
19
AV10 said HOLT was released from jail in May, 2016 but went back to jail in August or September, 2016.
AV10 said while he was out he heard AV10 was making money so he wanted her to prostitute for him. AV10
20 said she then prostituted for HOLT on and off from about June, 2016 through August, 2016. AV10 said HOLT
promised to take care of her. She said she mostly prostituted for HOLT out of the Rodeway Inn, in Fife.
21
AV10 said HOLT set up prostitution dates through Backpage.com and HOLT created the ads, determined
22 the prices for dates and set up dates via texts. She said HOLT controlled her phone and both HOLTs and her
phone was used to set up dates. AV10 said HOLT would tell her when she had a date and she never talked to the
date until they arrived. She said at times HOLT would set up dates for as low as $30. She said she did 3-4 dates
23 per day and brought in about $200 per day. She said HOLT would be nearby during the dates.

24 AV10 said HOLT enforced the following rules:

Office of the Prosecuting Attorney
DECLARATION FOR DETERMINATION 930 Tacoma Avenue South, Room 946
OF PROBABLE CAUSE -15 Tacoma, WA 98402-2171
Main Office (253) 798-7400
 1
a. AV10 was only allowed to have her phone when date showed up;
2 b. All money made went to HOLT;
c. No days off;
3 d. AV10 not allowed to leave the hotel.

AV10 said if she broke a rule, HOLT would beat her and she felt like she was stuck. She said during the
4 time she prostituted for HOLT he said he would kill her or her family if she didnt do a prostitute date. She said he
made similar threats if she cooperated with law enforcement. AV10 said HOLT beat her on at least 4-5 occasions
5 during the time she prostituted for him.

AV10 said HOLT sold heroin and methamphetamine and supplied her with heroin in order to control her.
6 If she wasnt prostituting for him, he would withhold heroin from her.

7 AV10 said HOLT carried a black pistol with him at all times and pistol whipped him with it on two
occasions while she was prostituting for him.
8
AV10 said HOLT provided her with food when she needed it but she had to scrounge for it.
9 AV10 said HOLT had several associates who were also involved in prostitution, including Q
(SMITH), HURST, and PINKNEY. She said SMITH helped HOLT set up ads and she witnessed him set up
10 dates for her. AV10 also saw HOLT give SMITH money from the prostitution dates.

AV10 said HOLT wanted her to get a tattoo that would say Lady Boo and she said HOLT had her
11 name and initials tattooed on himself.

12 AV6 was interviewed by SA McNeal and said AV-10 has MATTHEW tattooed on her body
and that HOLT had AV10s name tattooed on his neck, but has since covered it up.
13
AV6 also said PINKNEY had prostituted AV10 in the past.
14
AV8 was interviewed by SA McNeal and said she and AV10 did not get along during the time
period HOLT was dating both of them. AV8 said once, at a trailer park in Tillicum, AV8 and HOLT were in
15
a car and AV10 jumped on the vehicle. She said HOLT got out of the car and punched AV10 in the face
and proceeded to punch her until she could not get up.
16

17 AV8 said HOLT beat AV10 on a daily basis and described AV10 as HOLTs punching bag. AV8
was unaware of whether HOLT was pimping AV10 but assumed she was;
18

19 11. Statements made by or about JV11 (17-18 years of age during charged period):

20 AV6 was interviewed by SA McNeal and described knowing SMITH as being involved in
prostituting females and stated he always stays at the Motel 6 on Hosmer St., in Tacoma and he pimped JV-
11. AV6 said SMITH pimps JV11. AV-6 said JV11 prostituted for SMITH after he was done with
21 pimping JV4. AV6 said JV11 may have recently turned 18 years of age a few days before AV6s
interview with SA McNeal (April 14, 2017). Thus, AV6 believed JV11 was 17 when she began
22 prostituting for SMITH.

AV6 said HAYNESWORTH was always with SMITH when prostitution would occur, although
23 she never personally saw HAYNESWORTH prostitute females.

24
Office of the Prosecuting Attorney
DECLARATION FOR DETERMINATION 930 Tacoma Avenue South, Room 946
OF PROBABLE CAUSE -16 Tacoma, WA 98402-2171
Main Office (253) 798-7400
 1 AV8 was interviewed by SA McNeal and stated she observed the girl with the same first name as
JV11 and several other girls give HOLT money from prostitution.
2 AV8 said HOLT would train young boys ages 9-11 to rob cars and become gang members and at times
would tell other gang members to have sex with the girls. She said if the individuals refused to do what he said,
3 there would be consequences, like beatings. AV8 said the girl with the same first name as JV-11 and other girls
were afraid of HOLT and would do things for him out of fear.
4
12. Statements made by or about AV12 (20-21 years of age during charged period):
5
AV6 was interviewed by SA McNeal and stated AV12 prostituted for HOLT, PINKNEY and KING. She
6 said AV12 first prostituted for HOLT in spring/summer, 2016, in Tacoma. She said she later prostituted for
PINKNEY and KING. AV6 said she observed AV12 prostituting for them in Mount Vernon, Bellingham, Lacey
7 and Tacoma. AV6 said she observed AV12 hand money to PINKNEY.
AV7 was interviewed by SA McNeal and described AV12 as prostituting for HOLT.

9
13. STATEMENTS MADE BY OR ABOUT AV13 (19-20 years of age during charged period):
10
JV3 was interviewed by SA McNeal and said AV13 prostituted for HOLT at the Red Lion Hotel in
11 Tacoma sometime between early summer, 2016 and August 1, 2016.

12 JV3 also stated KING collected money from AV13 when she prostituted at the Red Lion in
Tacoma in summer, 2016. She said KING kept the money from AV-13 at that time.
13
AV6 was interviewed by SA McNeal and stated AV13 prostituted for PINKNEY before PINKNEY got
locked up. She said AV13 would give AV6 the money and AV6 would give the money to PINKNEY. She
14 identified Bellingham as one of the locations where PINKNEY prostituted AV13.
AV6 stated AV13 would also be present at times when prostitution occurred and would hold money for
15 HOLT.

16
14. STATEMENTS MADE BY OR ABOUT AV14 (unknown age during charged period):
17
JV3 was interviewed by SA McNeal and said JONES was AV14s pimp. JV3 said she met AV14 at
the Motel 6, in Tacoma where AV14 was with JONES. JV3 said SMITH, Desmond, Flex, Tori, and an
18
unidentified female were there. JV3 said this occurred in 2017 during a time HOLT was in jail.
19
JV3 said JONES was having sex with JV3 at the time and he knew her age (14 years old).
20 AV6 was interviewed by SA McNeal and identified AV14 as prostituting for HOLT and PINKNEY. She
said she observed AV14 prostituting for PINKNEY in Bellingham and said HOLT told her he had pimped AV14.
21

22 15. STATEMENTS MADE BY OR ABOUT AV-15 (24-25 years of age during charged period):

AV6 was interviewed by SA McNeal and stated AV15 prostituted for HOLT for a couple of days in
23 summer, 2016 out of the Super 8 hotel, in Lacey. She said she observed AV15 give money from the prostitution
dates directly to HOLT.
24
Office of the Prosecuting Attorney
DECLARATION FOR DETERMINATION 930 Tacoma Avenue South, Room 946
OF PROBABLE CAUSE -17 Tacoma, WA 98402-2171
Main Office (253) 798-7400
 1

2 HOTEL ROOM RECORDS

Law enforcement has attempted to verify information provided by the victims, including attempts to access
3 hotel records. As an example, the owner of the Quality Inn in Mount Vernon was contacted and verified that AV-7
rented a room on July 13, 2016.
4
As another example, the general manager at the Quality Inn in Lacey was interviewed and provided law
enforcement with information that PINKNEY paid for a room at the hotel on July 9, 2016 and listed AV-6 as
5 another individual who would be staying at the room. He stated AV-6 and another female around AV-6s age were
seen together and PINKNEY checked the girls in but did not stay. He stated he observed a lot of different visitors in
6 and out of the room throughout the night and he thought it was prostitution related. He stated AV-6 stayed in a
different room on a different occasion but couldnt find the records. Finally, the general manager remembered AV-6
7 staying at the Super 8 hotel right next to the Quality Inn on and off for about a month.

8
I DECLARE UNDER PENALTY OF PERJURY UNDER THE LAWS OF THE STATE OF
9 WASHINGTON THAT THE FOREGOING IS TRUE AND CORRECT.

10 DATED: October 2, 2017

PLACE: TACOMA, WA
11
/s/ GREGORY L GREER
12
GREGORY L GREER, WSB# 22936
13

14

15

16

17

18

19

20

21

22

23

24
Office of the Prosecuting Attorney
DECLARATION FOR DETERMINATION 930 Tacoma Avenue South, Room 946
OF PROBABLE CAUSE -18 Tacoma, WA 98402-2171
Main Office (253) 798-7400