Declaration of Greg Rogers: Expert Opinion on Undercover Practices and “Couples Ruse”
A sworn declaration submitted by Greg Rogers, a former FBI Special Agent and federal prosecutor, provides expert opinion regarding undercover operational practices in cases involving child exploitation and human trafficking.
Professional Background
Rogers states that:
- He served as an FBI Special Agent from 1988 to 2017
- His work focused primarily on violent crime and undercover operations
- He served as Chief Division Counsel in FBI field offices in Oklahoma City and Salt Lake City
- He previously worked as an Assistant U.S. Attorney in Texas
- He was a founding member of an FBI Child Sex Tourism Team
- He conducted undercover operations in Southeast Asia targeting offenders traveling to abuse children
- He later served as an Undercover Coordinator, reviewing and approving undercover operations
This background is presented to establish his expertise in evaluating undercover techniques.
Scope of Review
Rogers states that he reviewed:
- Civil complaints involving Tim Ballard
- Public statements and media interviews by Ballard
His declaration focuses specifically on Ballard’s description of a tactic referred to as the “couples ruse.”
Assessment of the “Couples Ruse”
Rogers states that, based on his experience, the “couples ruse” is not a legitimate or appropriate undercover technique in child sex tourism or trafficking investigations.
He outlines several reasons:
1. Inconsistency with Offender Behavior
- Rogers states that individuals engaged in child sex tourism typically do not travel with spouses or romantic partners
- Based on his experience, such offenders operate independently and conceal their behavior from family members
2. Lack of Operational Necessity
- Rogers states that undercover operatives are generally not required to disclose lodging details or maintain shared accommodations
- He states there is no operational justification for:
- sharing hotel rooms
- showering together
- participating in couples massages
- presenting as married in a way that involves intimate conduct
3. Violation of Undercover Policies
- Rogers states that federal and state law enforcement policies prohibit sexual activity between undercover operatives
- He states that, given Ballard’s background, he would have been aware of these restrictions
4. Comparison to Accepted Practices
- Rogers acknowledges that undercover operatives may sometimes pose as couples in certain investigations
- However, he states that:
- such roles involve trained operatives
- participants maintain separate accommodations
- all policies prohibiting sexual conduct are followed
Conclusion of Expert Opinion
Rogers concludes that the “couples ruse,” as described by Ballard, was:
- not consistent with accepted undercover practices
- not operationally justified
- not aligned with law enforcement policy
He further states his opinion that the tactic was:
- unprofessional
- unethical
- manipulative
- unrelated to legitimate undercover objectives
Conclusion
The declaration provides an expert assessment from a former FBI undercover specialist regarding the validity of certain operational claims made by Tim Ballard. It challenges the legitimacy of the “couples ruse” as a recognized or appropriate investigative method.
The opinions expressed are those of the declarant and have not been adjudicated in court.
