- The defendants, Brooke D. Waters, 44, and Clifton H. Gibbs, 66, face nine counts of sex trafficking and six counts of forced labor of 13 victims.
- All of the victims were actively using cocaine or heroin or were in the early stages of recovery, according to court documents.
- The Justice Department says Waters and Gibbs obtained “hundreds of thousands of dollars” from the victims’ commercial sex work.
The U.S. Department of Justice wants a Lewes woman who was charged in April with sex trafficking and forced labor to be held behind bars while she awaits trial, according to federal court documents.
The documents make the case that she should not be out in public, detailing the crimes for which she and her partner are charged.
The defendants, Brooke D. Waters, 44, and Clifton H. Gibbs, 66, face nine counts of sex trafficking and six counts of forced labor of 13 victims. The charges, which spanned at least six years from 2014-2020, also include one count each of interstate travel for the purpose of prostitution.
The U.S. DOJ filed the request for pretrial detention on May 18, saying Waters should not be released because the crimes are “so serious and so dangerous” that if she were to be let go, there would be no assurance of “the safety of the community.”
The initial indictment, filed on April 13, came after a lengthy investigation by the U.S. Immigrations and Customs Enforcement’s Homeland Security Investigations.
The original indictment:Delaware man and woman federally charged with trafficking 13 victims for sex and labor
The document describes Waters as Gibbs’ right-hand woman and suggests that she “directly effectuated” the criminal behavior.
Here is what the DOJ claims Watters and Gibbs have done.
Young, drug-addicted women were targeted

The DOJ claims that Waters and Gibbs targeted “young, vulnerable individuals, primarily women, who were experiencing homelessness/financial instability, and, most importantly, drug addiction.”
All of the victims were actively using cocaine or heroin or were in the early stages of recovery, according to court documents. They were also experiencing additional vulnerabilities, such as poverty or physical trauma.
Gibbs recruited the victims through various methods, documents say, including reaching out to women on social media and searching known drug locations. After striking up a conversation, Gibbs then convinced the victims to continue their talks at his properties, where he gave the victims drugs “for free” and promised they would be “taken care of,” with more drugs, housing and food in exchange for staying with Gibbs, court documents say.
But after a few days, the DOJ says, Gibbs told the victims that the drugs, housing and food were “not free” and instructed them to perform commercial sex dates, steal items from stores or conduct manual labor.
If the work was not done to Gibbs’ liking, he withheld drugs from the victims, inducing withdrawal sickness. One of the victims told investigators that her withdrawal included severe flu-like symptoms that made her “want to scratch her skin off,” and she would not “wish it on (her) worst enemy.”
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The DOJ found that the defendants posted 909 commercial sex advertisements online for various women, many of whom have never been identified, from April 2014 through November 2016 on websites such as the now-defunct Backpage.com. Waters was responsible for managing and paying for the advertisements, according to one victim, which the DOJ calls “direct and active” participation in the criminal misconduct.
Nearly a month after indicting the defendants, Homeland Security Investigations agents searched the properties and found approximately 350 condoms.
Threats of harm and violence
Gibbs used threats of sexual assault and physical violence, including “brandishing a firearm,” to coerce his victims, according to the court document. Multiple victims told investigators that Gibbs choked and hit them, and two of the victims said that he raped them. One victim also told investigators that Gibbs threatened to make a different victim “disappear” if that individual spoke to the police.
Waters often belittled victims and called them “replaceable” or “junkies,” the court documents say. She was aware of Gibbs’ violent acts and that they “were used to control” victims, court records say.
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The victims knew their treatment was unfair, but the prosecutors argue that, due to the isolation of the properties and themselves, as well as their fear of withdrawal, the victims continued to conduct labor for the defendants.
Gibbs was ‘making his living’ from trafficking

The Justice Department says Waters and Gibbs obtained “hundreds of thousands of dollars” from the victims’ commercial sex work.
One victim told investigators that her rates for customers were set at $150 for 30 minutes and $300 for an hour. Another victim said she made a little over $2,000, all of which went to Waters, in just two days of doing dates, according to court records.
But what made the defendants even more money was stealing, or what the victims referred to as “boosting.” The documents say that Gibbs and Waters coerced their victims to steal expensive goods, including power tools and electronics. One victim told investigators she stole approximately $100,000 worth of goods for the defendants.
After obtaining various records and tax returns, the DOJ claims it has information that supports the theory that Gibbs was “making his living from his sex trafficking and forced labor scheme.”
The 26-page document also suggests that Waters continued the trafficking scheme despite having knowledge of the federal investigation as early as 2015 when Homeland Security Investigations first interviewed her.
At that time, prosecutors didn’t have enough to charge Gibbs and Waters, the court documents say. However, the investigation picked up again in 2018 when local law enforcement “alerted HSI to a group of women with connections” to the defendants. Prosecutors were then able to gather enough evidence to build a case.
The DOJ argues that Waters’ continuance of the trafficking scheme, despite being aware of a potential investigation, shows “a lack of respect for the law.”
Not their first run-in with the law

This case is not the first time that Waters and Gibbs have been arrested.
The pair, along with one of the later-identified victims, was arrested for drug possession in Ocean City, Maryland, in 2015. Along with the arrested victim, another victim at the scene participated in voluntary interviews and told police that Waters and Gibbs posted advertisements for commercial sex.
These interviews prompted HSI to open the investigation, the court document says.
The Justice Department also states that Waters was arrested twice for drug paraphernalia in less than two weeks in 2014. The document says that, following Waters’ 2014 arrests, one of the victims witnessed Gibbs moving “logs of heroin” into trash bags and claimed he said he was going to get rid of them in case the police came to his property.
The toll this case has taken
After years of what the document describes as “herculean efforts” by law enforcement agents, victim witness advocates and prosecutors, Waters and Gibbs were charged last month. But not before a significant aftermath.
One of the victims died in a suspected heroin overdose in 2017, the document says. Over time, others have entered addiction recovery programs, moved away from Delaware or stabilized their lives.
Anyone who believes that they may have been a victim of this case or may have relevant information to share is asked to call the Homeland Security Investigations tip line at (866) 347-2423.