This complaint and testimony arises from a collection of facts, observations and media reports and seeks to demonstrate that: Defendants planned and executed the intentional distribution of pornographic material in book form, eBook, and/or audio, knowingly, to minors under the age of seventeen. The book, “This Book is Gay”, author James Dawson/Juno Dawson is currently accessible to students/children in the Springville Griffith Institute High School School. The book is also available in audio form to the Springville Griffith Middle, Elementary, and Colden Elementary School libraries. With knowledge of the content of this book and since these schools are in general, settings with minors under the age of seventeen, the defendants are knowingly disseminating indecent, obscene material to minors; sexually exploiting children. Through multiple cartoon like pictures/diagrams, utilizing slang terms, and referring to sexual acts as “feeling good”, the book is written and tailored towards minors and the child is tricked into thinking obscene sexual behavior for children is typical and standard. Heterosexual parents are spoken of very negatively, while homosexual relationships are cited as the quintessential. (Encouraging confusion between child and heterosexual parents) Masturbation and multiple different sex partners are encouraged. Erotic sexual desire and acting on these desires is mentioned throughout the entire book in a format to sexually excite the minor. Children are coached and groomed on sex through graphically detailed drawn pictures and written directions on how to sexually please a sex partner. This book is harmful to the mental, moral, and physical welfare of children; it must be removed from the schools immediately.
In accordance to written correspondence (the response to a FOIL request submitted on July 20, 2023) on August 24, 2023, received from Jennifer Carlton, the Records Access Officer/School Business Administrator at Springville Griffith Institute Central School District, On August 15, 2016 the Library Media Specialist ordered/submitted a request for sixty (60) copies of “This Book is Gay” author James Dawson. Per Ms. Carlton,” the district no longer has records relating to the purchase after seven years due to “(LGS-1) requirements retention period of seven years.” Per Ms. Carlton, as of August 24, 2023 “all component districts of Erie 2 Boces shares one physical copy and one audiobook copy” of “This book Is Gay” by James Dawson. Ms. Carlton states “One physical copy is available through the Springville High School Library Media Center.” (General age of high school student is 14-18, however the exact age can vary). Ms. Carlton did not answer the question “Who approved the book to be inside the library”?
Penal Code 260.10: Endangering the Welfare of a Child. By producing/offering/lending this book to minors, through the school library system, the Defendants are knowingly creating harm to the mental, moral and physical safety/welfare of the children/minors in school. The following are two examples of many in the book that compromise the moral and mental welfare of children. Page 38 attempts to put odd thoughts into the minds of children regarding their parents and heterosexual relationships. “I want you to imagine your mom’s and dad’s genetic codes (don’t worry I’m not going to ask you to imagine them bumping uglies)” and ”Now, for a long time it was assumed that these post its were removed before being passed via SWEATY PARENT SEX (sorry couldn’t resist) to their baby”. These statements not only attempt to affect the mental health of the reader but it also puts a trashy thought about parents and heterosexual relationships into the child’s thought process, disrupting healthy mental and moral thought. “This Book Is Gay” by James Dawson that was/is permitted into the school system for minors to be indoctrinated into obscenity and early sexual behavior, by the defendants, also educates children/minors with “some sex app tips” on how to pick up quick sex with strangers, starting on page 153 titled “ONLINE”: Quote “These websites and there are severalallow you to meet up with other LBGT people for coffee, dinner or sometimes plain, old fashioned sex.” The websites are in fact named in the book. Page 159 “Include a picture of yourself”. “If you’re THAT HORNY that you want to do a “sex meet”, meet the “trick” in a public place for a drink first. That way you can assess if you fancy them in the flesh/they are not a twitchy-eyed freakazoid before letting them into your house. This is much MUCH safer, obviously”. Page 155 “It is a fact that although grown-up adult types are sometimes looking for a serious relationship, sometimes they are just looking for a spot of sexfuntime. You may come to establish that gay and bi men in particular do seem to quite like sex. OK, nearly everyone likes sex, but gay guys really seem to have cornered the market. Remember, this is fine as long as you’re honest and always use a condom. Gay and bi men have taken to app sex like ducks to sexy water”.
Penal Code 260.25: Endangering Welfare of an incompetent or physically disabled person-class E Felony. There are many children in the school with learning disabilities that require IEP, Individualized Educational Plan developed to ensure that children who have a disability identified under the law receive special instruction or related services. There is an audio book available for students.
Penal Law 263.10: Promoting an obscene sexual performance by a child. “A person is guilty of the use of a child in a sexual performance if knowing the character and content thereof he employs, authorizes or induces a child less than seventeen years of age to engage in a sexual performance”. Page 156 has a written diagram of “How sex apps work” and gives instruction on how to sign up on sex apps. The defendants, knowing the content of the book and disagreements from local citizens, did in fact assure that the book is available in some form, be it physical book or audio, to children as young as five years old in elementary school. The audio version persuades and influences minor children into performing sexual acts. The writer of the book utilizes slang language while defiling the purpose of male/female human body, in order to get onto the level of the child and win him/her over. “Gay men have slightly longer and thicker winkies. Excellent”. Page 179 “Doing the Sex”. “Fingers: Far more effective than a penis in many ways, a hand can do the job of five penises. When gay women refer to having sex, this is usually what they mean. Lesbians can stimulate the clitoris and vagina and bring their partner to orgasm with their fingers; sometimes both partners can do this simultaneously.” Page 178. Nipples: “A lot of girls like having their nipples played with---they are mega sensitive”. This is some of many instances in the book of coaching minors/children on performing sexual acts. Page 16 “SEXTHOUGHTS” “You can act on them AND adopt an identity to define yourself. This is the bit where you’d get the membership card and become part of a community”. Persuasion and authorization to have sex if a child feels lonely, “membership card and become part of a community”.
Penal Law 263.15: Promoting Sexual Performance By A Child. The defendants are providing, circulating a published a book that knowingly promotes the sexual performance of children. There are over fifty (50) examples of this book promoting sex, here are a few. Page 16 instructs children that if they have “SEXTHOUGHTS” “you can acknowledge them and act on them-have the sex you wanna have”. Page 171 and 178 promote sexual performance by way of cartoon like pictures of a naked “boy” and a naked woman. Page 171 termed “Boy-on-boy Sex” with a cartoon like diagram for a “rough guide” which states “up your bum you have a prostate gland which feels nice when massaged. The anus is also sensitive and responds to being played with”. Page 178 termed “Girl-on-Girl Sex”, with a cartoon like picture of a naked woman presents with a drawing of the female genitals identifying the “clitoris: The clitoris is a super sensitive cluster of nerve endings that, when rubbed, kissed or licked can make a woman orgasm (which is a good thing)”.
Penal law 263.25 Proof of Age. Since the defendants are aware the book of obscenities will be accessible, in audiobook and or physical book, to elementary, middle and high school students, it should be understood that the majority of students that have access to the book are under the age of seventeen.
Penal law 235.05 Obscenity in the third degree. The defendants do in fact possess the pornographic book, “This Book is Gay” and they deviously present it to children under the age of seventeen through the elementary, middle and high school libraries. The book predominantly describes and encourages sexual intercourse, masturbation, and discusses experimenting with dominant and submissive sex roles, sex smutty cartoon like drawing on display of a naked “boy” and naked “woman” (as identified in the book on pages 171 &178) with diagrams indicating, educating and encouraging sexual activity of minor children.
Penal 235.07 Obscenity in the first degree. The defendants have full intent to promote/possess obscene material to school age minors. The book is in the elementary, middle and high school libraries under their supervision with their approval. Page 17 obscenely reveals more encouragement of child sex Under the Heading “Doing the Sex”. “A GOOD HANDIE is all about the wrist action. Rub the head of his cock back and forth with your hand. Try different speeds and pressures until he responds positively”. The book lacks “serious literary, artistic, political and scientific value for minors”. The foundation of book is geared toward, but not limited to, coercing, coaching and encouraging children/minors to engage in sexual acts and join sex apps in order to have sex with strangers and “feel nice”.
Penal 235.10 Obscenity; presumptions. Utilizing the school libraries, the defendants have and continue to possess and promote, with intent and knowledge of material, an obscene book, “This Book is Gay” by James Dawson, to children/minors in a school setting. School libraries do apply to the NYS penal code article 235.10 as evidenced by the terminology utilized in NY Educ. Law 253, which is quoted in 235.10 as defining public library. In accordance with N.Y. Educ. Law 253, school libraries do apply to Penal 235.10 and do not fall under public libraries or association libraries. Therefore, the school libraries do apply to the NYS penal code article 235.
Penal law 235.21 Disseminating indecent material to minors in second degree. Class E felony. With knowledge of the obscene content of the book, community members coming forward and requesting the book be removed from schools due to obscenity, the defendants continue to keep the book accessible to minor children. Page 63. “Lesbians like vaginas. They don’t even want blokes watching. I KNOW, how INCONSIDERATE. Note the sarcastic tone”.
Penal law 235.22 Disseminating Indecent Material to Minors in the First Degree. Knowing the character and content of the book, which describes in words and /or images explicit sexual acts, the defendants chose to keep the book accessible to minors. On August 8, 2023, offensive portions of the book were read at a school board meeting by a citizen. The material was so offensive, the president of the Board President, Chris Cerrone and a female board member stood up and walked out of the meeting for the duration the citizen read the material, while the citizen read the material from the book and showed the cartoon like picture of a naked boy and naked woman. The citizen told Mr. Cerrone and the board that if they didn’t like what was being said, they need to remove the books that have the content from the school library. This material offended school board members yet the defendants, some of which walked out due to offensive material, refuse to remove the obscenity from the school system. This material was offensive to adults. Page 61 “NO ONE WANTS TO HAVE SEX WITH A BALD SPOTTY PSYCHO WITH BALLS LIKE SHRIVELLED RAISINS”.
Penal law 135.65 Coercion In The First Degree. Violating his/her duty as public servant. This book is not subtle intimidation; this book is blatant coercion into participating in sexual activities for minors, grooming minors. The Defendants, through this book are compelling the victims, the children/minors, five year old innocent prey, to commit a felony, cause mental and physical injury to themselves, and the defendants are violating their duty as public servants.
Article 460 “Organized crime in New York State involves highly sophisticated, complex and widespread forms of criminal activity”. There is an obvious COORDINATED effort in the teaching system in NY Board of Regents and NY School Boards, which dominates over the school system due to their employment position , and the content of education is being manipulated to include at minimal increased sexual awareness encouraging participation, child grooming, loss of morals and pornography as evidenced by the book being pushed, “This book is gay” , in order to corrupt and infiltrate the innocent minds of children in order to influence/groom. Per nysed.gov “The Regents are responsible for the general supervision of all education activities within the state, presiding over The University and the New York State Education Department”. In the words of nysed.gov, “The University of the State of New York is the nation’s most comprehensive and unified educational system”. There is a pattern of conduct which is criminal under the above existing statutes. The defendants have formed a corrupt group with a distinct pattern structured to promote child pornography. They are related to each other through the school system and work to intentionally promote child pornography.
Penal law 460.20 Enterprise Corruption. The defendants knowingly and intentionally acquired, maintained and dispensed pornography in schools from ages 5 to 17.
Penal Law 410 Seizure and Forfeiture of Equipment Used in Photographing, filming, producing, manufacturing, projecting or DISTRIBUTING pornographic still or motion pictures. I am requesting the Sheriff’s office immediately remove the pornographic book “This book is Gay” by James Dawson from all Erie County School Libraries.
18 U.S.C. 1470 Obscene Material to Minors. The US Supreme Court ruled, “transmitting obscenity and child pornography whether via internet or other means, is…illegal under federal law for both adults and juveniles.” Distribution of obscene matter to minors is not protected under the First Amendment. It is a criminal offense to breach federal obscenity laws. The book, “This Book Is Gay”, by James Dawson, fits the point of reference of the Miller test that is utilized to determine if the material is obscene; obscenity in this book is expressed via visual depictions(drawing of naked boy), spoken word (audio book in ELEMENTARY SCHOOL) and written book. (example page 171 has cartoon like drawing of a naked boy with arrows pointing to areas that “feel nice when touched”.) “The Cheat Sheet” chapter (starts on page 255) is similar to a dictionary and it defines some of the most disgusting amoral acts for children to follow. For example, page 259, SCAT: EATING POOP.
18 US Code 2251 Sexual exploitation of children. The premise of the book, “This Book Is Gay” by James Dawson is to persuade minors to engage in sexual activity. The word “sex” is ridiculously used 243 times, “sexual’ is used 67 times, “sex thoughts” is used 12 times, “sexy” is used 12 times, “sexyfuntime” is used five times, “sexpert” is used one time, “horny” is used two times, “porn” is used 14 times, “pornography” is used four times, “porn star” is used four times, “oral sex” is used seven times, “blowies” is used three times, “hand job” is used one time, “handies” is used five times, “dildo” is used seven times, “cum” is used six times, and “trick” is used three times. This book, in elementary, middle and high school libraries is full of outrageous offensive statements. One example is page 168, “If all gay women really had fingernails that long, emergency rooms would be a lot busier with all the clit injuries.” In many states, parents have been fighting to have “This Book is Gay” by James Dawson removed from school libraries. There is literature on the internet going back
Conclusion
“This Book is Gay” by James Dawson is masqueraded in the school system as a “sex education” book for LBGT+ in order for pedophiles to utilize a claim of discrimination when a decent parent or citizen questions the vulgarity of the content of the book. Based on the above information there is probable cause to believe that one or more of the named Defendants has committed the offenses set forth above in this Criminal Complaint. All or some of the Defendants intentionally, with malice, and in criminal coordination engaged in the act of attempting to normalize sexual activity of/with children/minors by:
In a very small localized search in WNY, “This Book is Gay” by James Dawson aka Juno Dawson has been located in the following school libraries:
Springville Griffith Institute