RUSSELL D.

SMITH (7628)
Assistant Attorney General
SEAN D. REYES, (7969)
Utah Attorney General
5272 South College Drive, Suite 200
Murray, Utah 84123
Tel: 801-281-1218
Fax: 801-281-1266
Email: rsmith3@utah.gov
Attorneys for Plaintiff
______________________________________________________________________________

IN THE THIRD DISTRICT COURT

IN AND FOR THE COUNTY OF SALT LAKE, STATE OF UTAH

CUSTODY STATUS: SLC/ADC

THE STATE OF UTAH,
INFORMATION
Plaintiff,
-vs- Utah Attorney General
Case No. AG 2016-275
CHARLES DARYL KELLEY
DOB: 03/14/1956
AKA GEORGE CLOWENS Case No.
AKA CRANSTON KELLEY
AKA KELLY CRANSTON Judge:
AKA DARRYL KELLEY
AKA DARRYL SLICE

Defendant.

The undersigned states upon information and belief that the above-listed defendant
committed the following criminal offenses:
COUNT I
PATTERN OF UNLAWFUL ACTIVITY
(SECOND DEGREE FELONY)

On or about and between April 1, 2016, through April 19, 2016, in the State of Utah, in
violation of Title 76, Chapter 10, Section 1603, Utah Code Annotated, the defendant, CHARLES
KELLEY:

(1) did receive proceeds derived, whether directly or indirectly, from a pattern of
unlawful activity in which he participated as a principal, and did use or invest,
 directly or indirectly, any part of that income, or the proceeds of the income, in the
establishment or operation of any enterprise; and/or

(2) through a pattern of unlawful activity, did acquire or maintain, directly or indirectly,
any interest in or control of any enterprise; and/or

(3) while associated with any enterprise, did conduct or participate, whether directly or
indirectly, in the conduct of that enterprises affairs through a pattern of unlawful
activity; and/or

(4) did conspire to violate any of the above provisions; and

the unlawful activity included three or more violations, whether charged or uncharged, of
Exploiting Prostitution, U.C.A. 76-10-1305, Attempted Exploiting Prostitution, U.C.A. 76-10-
1305, and Aiding Prostitution, U.C.A. 76-10-1304, which episodes were not isolated, but were
similar in purpose, results, participants, person engaged in commercial sexs, or methods of
commission, or otherwise were interrelated by distinguishing characteristics, to wit:

Defendant owned, controlled, managed, supervised, or otherwise kept a

prostitution business at a motel in Midvale, Utah, from April 1, 2016 through
April 19, 2016. During that time, Defendant encouraged, induced, or otherwise
purposely caused at least two women to become or remain prostitutes working for
his prostitution business. Defendant also attempted to induce at least two other
women to become prostitutes during that time. Defendant also solicited patrons to
patronize his prostitution business and procured or attempted to procure
prostitutes for those patrons. Defendant paid for motel rooms where this
prostitution operation took place, and in doing so, he permitted a placed
controlled by him to be used for prostitution. Therefore, Defendant committed
three or more violations of Exploiting Prostitution and Aiding Prostitution.
Defendant acquired or maintained control of the unlawful prostitution enterprise,
received proceeds from this pattern of unlawful activity and used those proceeds
to continue to fund the enterprise, and conducted or participated in the conduct of
the enterprises affairs through a pattern of unlawful activity.

COUNT II
EXPLOITATION OF PROSTITUTION
(THIRD DEGREE FELONY)

On or about and between April 16, 2016 through April 19, 2016, in the State of Utah,
Motel 6, 7263 S Catalpa, Midvale, Utah, rooms #239 and #240, the defendant did commit
Exploitation of Prostitution, in violation of Title 76, Chapter 10, Section 1305, Utah Code
Annotated, wherein the defendant CHARLES DARRYL KELLEY, did exploit prostitution, in
that he did encourage, induce, or otherwise purposely cause another to become or remain a
prostitute; did transport a person into or within this state with a purpose to promote that persons
engaging in prostitution or procuring or paying for transportation with that purpose; did share the
proceeds of prostitution with a prostitute pursuant to an understanding that he is to share therein;
or did own, control, manage, supervise, or otherwise keep, alone or in association with another, a
house of prostitution or a prostitution business. to wit: the defendant encouraged, induced, or
otherwise purposely caused Person engaged in commercial sex 1 to enter into or remain in
prostitution, transported her within and outside of the state for that purpose, kept most of the
proceeds of the prostitution operation, and owned, controlled, managed, or supervised that
prostitution operation.

COUNT III
EXPLOITATION OF PROSTITUTION
(THIRD DEGREE FELONY)

On or about and between April 13, 2016 through April 15, 2016, in the State of Utah,
Motel 6, 7263 S Catalpa, Midvale, Utah, rooms #239 and #240, the defendant did commit
Exploitation of Prostitution, in violation of Title 76, Chapter 10, Section 1305, Utah Code
Annotated, wherein the defendant CHARLES DARRYL KELLEY, did exploit prostitution, in
that he did encourage, induce, or otherwise purposely cause another to become or remain a
prostitute; did transport a person into or within this state with a purpose to promote that persons
engaging in prostitution or procuring or paying for transportation with that purpose; did share the
proceeds of prostitution with a prostitute pursuant to an understanding that he is to share therein;
or did own, control, manage, supervise, or otherwise keep, alone or in association with another, a
house of prostitution or a prostitution business. to wit: the defendant encouraged, induced, or
otherwise purposely caused Person engaged in commercial sex 1 to enter into or remain in
prostitution, transported her within and outside of the state for that purpose, kept most of the
proceeds of the prostitution operation, and owned, controlled, managed, or supervised that
prostitution operation.

COUNT IV
EXPLOITATION OF PROSTITUTION
(THIRD DEGREE FELONY)

On or about and between April 9, 2016 through April 12, 2016, in the State of Utah,
Motel 6, 7263 S Catalpa, Midvale, Utah, rooms #239 and #240, the defendant did commit
Exploitation of Prostitution, in violation of Title 76, Chapter 10, Section 1305, Utah Code
Annotated, wherein the defendant CHARLES DARRYL KELLEY, did exploit prostitution, in
that he did encourage, induce, or otherwise purposely cause another to become or remain a
prostitute; did transport a person into or within this state with a purpose to promote that persons
engaging in prostitution or procuring or paying for transportation with that purpose; did share the
proceeds of prostitution with a prostitute pursuant to an understanding that he is to share therein;
or did own, control, manage, supervise, or otherwise keep, alone or in association with another, a
house of prostitution or a prostitution business. to wit: the defendant encouraged, induced, or
otherwise purposely caused Person engaged in commercial sex 1 to enter into or remain in
prostitution, transported her within and outside of the state for that purpose, kept most of the
proceeds of the prostitution operation, and owned, controlled, managed, or supervised that
prostitution operation.

COUNT V
EXPLOITATION OF PROSTITUTION
(THIRD DEGREE FELONY)

On or about and between April 1, 2016 through April 8, 2016, in the State of Utah, Motel
6, 7263 S Catalpa, Midvale, Utah, rooms #239 and #240, the defendant did commit Exploitation
of Prostitution, in violation of Title 76, Chapter 10, Section 1305, Utah Code Annotated, wherein
the defendant CHARLES DARRYL KELLEY, did exploit prostitution, in that he did
encourage, induce, or otherwise purposely cause another to become or remain a prostitute; did
transport a person into or within this state with a purpose to promote that persons engaging in
prostitution or procuring or paying for transportation with that purpose; did share the proceeds of
prostitution with a prostitute pursuant to an understanding that he is to share therein; or did own,
control, manage, supervise, or otherwise keep, alone or in association with another, a house of
prostitution or a prostitution business. to wit: the defendant encouraged, induced, or otherwise
purposely caused person 1 engaged in commercial sex to enter into or remain in prostitution,
transported her within and outside of the state for that purpose, kept most of the proceeds of the
prostitution operation, and owned, controlled, managed, or supervised that prostitution operation.

NOTICE OF FORFEITURE UNDER THE UTAH UNIFORM FORFEITURE

PROCEDURES ACT

In accordance with Title 24, Chapter 1, et al, Defendant was found in possession of
$1472.00 in U.S. currency and said money is believed to be subject to criminal forfeiture as the
money was found in the Defendants wallet while in the act of exploitation of prostitution, and it
is believed that the Defendant has no other form of lawful employment from which he could
acquire said funds.

PROBABLE CAUSE STATEMENT

This INFORMATION is based upon evidence from Attorney General SECURE Strike Force
report no. AG 2016-275, Unified Police Dept.- Greater SL, report no. 2016-59780, and the
following witness statements:

Detective Geoffrey Clark, Unified Police Department

I responded to Motel 6 located at 7263 S Catalpa, Midvale, Utah and spoke with the manager.
The manager stated a guest by the name of Charles Kelley (hereinafter Kelley) was staying in
room 240, and suspected Charles was a pimp and the girls in room 239 were working for him.
M.V. was the listed person on room 239.
Surveillance of Motel 6 room 239 on from April 1, 2019 thought April 19, 2016 revealed that
throughout the evenings several males showed up to room 239 one at a time and entered room
239. After 15 to 20 minutes the same male would leave the room. One such male was
interviewed and stated he had paid $80.00 for a hand job performed by person 1 engaged in
commercial sex in room 239. A separate male was interviewed and stated that he had paid
$180.00 for person 1 engaged in commercial sex and person 2 engaged in commercial sex in
room 239 to give him a blow job and to have sexual intercourse with person 2 engaged in
commercial sex.

After each of the males would leave room 239, person 2 engaged in commercial sex was
observed going into room 240.

A search warrant was executed on Motel 6, rooms 240 and 239. In room 240 Kelley was present
and possessed in his wallet $1,472.00. In room 239 person 1 engaged in commercial sex and
person 2 engaged in commercial sex were present. A search of the room revealed multiple
packages of condoms, some clothing, but no money.

On April 19, 2016, person 1 engaged in commercial sex was interviewed. Person 1 engaged in
commercial sex stated she only knew Kelley by his last name.

Person 1 engaged in commercial sex stated that she met person 2 engaged in commercial sex a
few weeks prior in Las Vegas, Nevada. Person 2 engaged in commercial sex referred to Kelley
as her pimp. Person 2 engaged in commercial sex had asked person 1 engaged in commercial sex
to come to Salt Lake City, Utah, to make some money performing commercial sex acts for
Kelley. Person 1 engaged in commercial sex did travel with Kelley and person 2 engaged in
commercial sex to Midvale, Utah to preform commercial sex for Kelley.

Person 1 engaged in commercial sex was reluctant to answer law enforcements questions
because she was scared of what would happen to her. Person 1 engaged in commercial sex stated
that she was afraid of Kelley. Person 1 engaged in commercial sex said that Kelley had become
angry with her in the past and assaulted her.

Person 1 engaged in commercial sex stated that since arriving in Midvale, Utah, she engaged
with five male purchasers of commercial sex acts, on average each day. Person 1 engaged in
commercial sex said she was told to charge $150 for a half hour and $200 for an hour. Person 1
engaged in commercial sex said the money paid would include any commercial sex act except
anal sex. She said the lowest she was to charge was $80 which would most likely result in a
hand job. This is consistent with a statement made by a "john" that we interviewed.

Person 1 engaged in commercial sex said that all the money went to Kelley and that she did not
receive any of the money derived from the commercial sex acts performed. Person 1 engaged in
commercial sex explained the Kelley would buy what she needed. Person 1 engaged in
commercial sex stated that she no longer wanted to perform commercial sex acts but could not
get out.
Between April 1, 2016 and April 19, 2016, Kelley spoke with a 15-year-old girl at the Midvale
Motel 6 attempting to recruit her to prostitute for him. The 15-year-old girls mother overheard
Kelleys request and took her daughter back into their motel room. The 15-year-old stated Kelley
scared her and would not go outside if Kelley was around.

Between April 1, 2016 and April 19, 2016, Kelley also attempted to recruit another adult female
guest at the Midvale Motel 6. Kelley spoke with this female guest for about 10 minutes
attempting to recruit her to be a prostitute for him. This female refused his offer and reported the
conduct.

In a video captured off one of the electronic devices seized in the execution of a search warrant,
Kelley is seen and heard setting up a commercial sex appointment. The rooms at Motel 6 were
paid for by and at the direction of Kelley.

Pursuant to Utah Code Annotated 78B-5-705 (2008) I

declare under criminal penalty of the State of Utah that the
foregoing is true and correct to the best of my belief and
knowledge.

Executed on: April 25, 2016

/s/ Josh Caless

Declarant: Agent Josh Caless, SECURE Strike Force

Authorized for presentment and filing:

SEAN D. REYES, Utah Attorney General

/s/ Russell D. Smith

RUSSELL D. SMITH
Assistant Utah Attorney General
This 25th day of April, 2016
AG Case No. 2016-159