-------------
Case 1:25-cr-00281-PAE Document 34 Filed 06/20/25 Page 1 of 3
UNITED STATES DISTRJCT COURT
SOUTHERN DISTRJCT OF NEW YORK
UNITED STA TES OF AMERICA INFORMATION
V.
JUSTIN HEATH SMITH,
a/k/a "Austin Wolf,"
28 1
Defendant.
COUNT ONE
(Enticement of a Minor)
The United States Attorney charges:
1. In or about late 2023 or early 2024, in the Southern District of New York and
elsewhere, JUSTIN HEATH SMITH, a/k/a "Austin Wolf," the defendant, knowingly, using a
facility and means of interstate and foreign commerce, persuaded, induced, enticed, and coerced
an individual who had not attained the age of 18 years to engage in prostitution and sexual activity
for which a person can be charged with a criminal offense, and aided and abetted the same, and
attempted to do the same, to wit, SMITH and another individual induced a 15-year-old minor to
engage in sexual activities while in New York, New York.
(Title 18, United States Code, Sections 2422(b) and 2.)
FORFEITURE ALLEGATION
2. As a result of committing the offense alleged in Count One of this Information,
JUSTIN HEATH SMITH, a/k/a "Austin Wolf," the defendant, shall forfeit to the United States,
pursuant to Title 18, United States Code, Section 2428, any and all property, real and personal ,
constituting or derived from proceeds obtained, directly or indirectly, as a result of said offense;
and any and all property, real or personal, that was used or intended to be used to commit or
Case 1:25-cr-00281-PAE Document 34 Filed 06/20/25 Page 2 of 3
facilitation the commission of said offense, including but not limited to a sum of money in United
States currency representing the amount of proceeds traceable to the commission of said offense
and the following specific property:
Description Serial Number/Unique ID
Silver iPhone 357414192344317
WD MyCloud EX2 Ultra WUBM31061262
16GB MicroSD Card 01160C21
16GB MicroSD Card Not Visible
32GB MicroSD Card 8044XV91283J
32GB MicroSD Card 6067XV5075L0
64GB MicroSD Card 20121413
64GB MicroSD Card 8053ZV91E2ZC
1TB SD Card C1921052250G
Samsung SIM Card DPHH1E5GW844
WD hard drive WXE108283138
WD MvPassportUltra WX11D89E28KV
32GB MicroSD Card 8075XV70234G
256GB MicroSD Card 84250YDTN4MM
WD Elements WX41D67HYEVI
MicroSD Card 03070XL TH0CX
MicroSD Card 0367DXNPT09J
MicroSD Card 2451DXHSK06S
WD EasyStore 2GGARY9U
WD MyBookDuo WUBS20160554
WD MyBookDuo WUBS20362531
Mac Pro F5KPN06MF9VN
Mac Mini C07C707QJYW0
Mac Mini C07WC0UXG 1J2
MacBookPro Cl 7J645TDTY3
Substitute Assets Provision
3. If any of the above-described forfeitable property, as a result of any act or
omission of the defendant:
a. cannot be located upon the exercise of due diligence;
b. has been transferred or sold to, or deposited with, a third person;
c. has been placed beyond the jurisdiction of the Court;
d. has been substantially diminished in value; or
2
Case 1:25-cr-00281-PAE Document 34 Filed 06/20/25 Page 3 of 3
e. has been commingled with other property which cannot be subdivided
without difficulty;
it is the intent of the United States, pursuant to Title 21 , United States Code, Section 853(p) and
Title 28, United States Code, Section 2461 (c), to seek forfeiture of any other property of the
defendant up to the value of the above forfeitable property.
(Title 18, United States Code, Section 2428;
Title 21, United States Code, Section 853; and
Title 28, United States Code, Section 2461.)
