Three cheers for FBI, UDOJ, NYPD, Postal Inspectors and other law enforcement for fine work identifying the alleged source of some 13 improvised explosive devices (IEDs) meant to kill and maim two former Presidents, Senators, Congressmen, et al. Here's a copy of FBI Special Agent David Brown's affidavit filed in the Southern District of New York against alleged MAGAbomber CESAR ALTIERI SAYOC. SAYOC typfiies the genre of sick, twisted, angry, deluded, hateful DONALD JOHN TRUMP supporters. Every single IED that SAYOC sent was to the targets of TRUMP.
Denounce DONALD JOHN TRUMP and all of his works and pomps -- let's get this country back on track again. When one of your friends or relatives indulges in hate speech, or spreads disinformation lies, you know what to do -- tell the truth.
President Harry S Truman, described as "Give 'Em Hell Harry," said he just told the truth and that Republicans "think that's Hell."
SOUTHERN DISTRICT OF NEW YORK, s s . :
Defendant.
DAVID BROWN, being duly sworn, deposes and says that heis a Special Agent with the Federal Bureau of Investigation("FBI"), and a member of the FBI's Joint Terrorism Task Force
("JTTF"), and charges as follows:
COUNT ONE(Interstate Transportation of an Exp1osive)
1. In or about October 2018, in the Southern District of New York and elsewhere, CESAR ALTIERI SAYOC, the defendant, transported and received, and attempted to transport and receive, in interstate and foreign commerce, an explosive with the knowledge and intent that it would be used to kill, injure, and intimidate individuals, and unlawfully to damage and destroy buildings, vehicles, and other real and personal property, to wit, SAYOCmailed approximately 13 packages containing improvised explosive devices ("IEDs") to certain current and former U.S. Governmentofficials, politicians, and others, including mailings acrossstate lines.
(Title 18, United States Code, Sections 844(d) and 2.)
("JTTF"), and charges as follows:
COUNT ONE(Interstate Transportation of an Exp1osive)
1. In or about October 2018, in the Southern District of New York and elsewhere, CESAR ALTIERI SAYOC, the defendant, transported and received, and attempted to transport and receive, in interstate and foreign commerce, an explosive with the knowledge and intent that it would be used to kill, injure, and intimidate individuals, and unlawfully to damage and destroy buildings, vehicles, and other real and personal property, to wit, SAYOCmailed approximately 13 packages containing improvised explosive devices ("IEDs") to certain current and former U.S. Governmentofficials, politicians, and others, including mailings acrossstate lines.
(Title 18, United States Code, Sections 844(d) and 2.)
COMPLAINT
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COUNT TWO{Illegal Mailing of Explosives)
2. In or about October 2018, in the Southern District of New York and elsewhere, CESAR ALTIERI SAYOC, the defendant,knowingly deposited for mailing and delivery, and knowingly causedto be delivered by mail, according to the direction thereon, andat a place at which it was directed to be received by the personto whom it was addressed, a thing declared nonmailable as defined in Title 18, United States Code, Section 1716(a), to wit, the IEDsdescribed in Count One, with intent to injure another and injure the mails and other property.
(Title 18, United States Code, Sections 1716{j) (2) and 2.)
COUNT THREE(Threats Against Former Presidents and Certain Other Persons)
3. In or about October 2018, in the Southern District of New York and elsewhere, CESAR ALTIERI SAYOC, the defendant, knowingly and willfully threatened to kill and inflict bodily harm upon a former President and a member of the immediate family of aformer President, to wit, SAYOC mailed an IED to former First LadyHillary Clinton, who resides with her husband, former PresidentWilliam Jefferson Clinton.
(Title 18, United States Code, Sections 879 and 2.)
COUNT FOUR(Threatening Interstate Communications)
4. In or about October 2018, in the Southern District of New York and elsewhere, CESAR ALTIERI SAYOC, the defendant,knowingly transmitted in interstate and foreign commerce acommunication containing a threat to injure the person of another, to wit, SAYOC mailed the IEDs described in Count One, including multiple mailings with photographs of the target-recipient marked with a red "X."
(Title 18, United States Code, Sections 875(c) and 2.)
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2. In or about October 2018, in the Southern District of New York and elsewhere, CESAR ALTIERI SAYOC, the defendant,knowingly deposited for mailing and delivery, and knowingly causedto be delivered by mail, according to the direction thereon, andat a place at which it was directed to be received by the personto whom it was addressed, a thing declared nonmailable as defined in Title 18, United States Code, Section 1716(a), to wit, the IEDsdescribed in Count One, with intent to injure another and injure the mails and other property.
(Title 18, United States Code, Sections 1716{j) (2) and 2.)
COUNT THREE(Threats Against Former Presidents and Certain Other Persons)
3. In or about October 2018, in the Southern District of New York and elsewhere, CESAR ALTIERI SAYOC, the defendant, knowingly and willfully threatened to kill and inflict bodily harm upon a former President and a member of the immediate family of aformer President, to wit, SAYOC mailed an IED to former First LadyHillary Clinton, who resides with her husband, former PresidentWilliam Jefferson Clinton.
(Title 18, United States Code, Sections 879 and 2.)
COUNT FOUR(Threatening Interstate Communications)
4. In or about October 2018, in the Southern District of New York and elsewhere, CESAR ALTIERI SAYOC, the defendant,knowingly transmitted in interstate and foreign commerce acommunication containing a threat to injure the person of another, to wit, SAYOC mailed the IEDs described in Count One, including multiple mailings with photographs of the target-recipient marked with a red "X."
(Title 18, United States Code, Sections 875(c) and 2.)
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COUNT F I V E(Assaulting Federal Officers)
5. In or about October 2018, in the Southern District of New York and elsewhere, CESAR ALTIERI SAYOC, the defendant, with the intent to commit another felony, to wit, the charges set out in Counts One through Four of this Complaint, forcibly assaulted and intimidated any person who formerly served as aperson designated in Title 18, United States Code, Section 1114,to wit SAYOC mailed the IEDs described in Count One to two formerPresidents, a former Vice President, former Members of the U.S. Congress, and former Executive Branch employees.
(Title 18, United States Code, Sections lll(a), lll(b), and 2.)
The bases for my knowledge and the foregoing chargesare, in part, as follows:
6. I am a Special Agent with the FBI and a member of the FBI's New York-based JTTF, and I have been personally involved in the investigation of this matter. This affidavit is based in part upon my conversations with law enforcement agents and other people, and my examination of reports and records. Because this affidavit is being submitted for the limited purpose of establishing probable cause, it does not include all of the facts that I have learned during the course of my investigation. Wherethe contents of documents and the actions, statements, andconversations of others are reported herein, they are reported in substance and in part, except where otherwise indicated.
Overview
7. During the course of October 2018, as further d e t a i l e d b e l o w , CESAR A L T I E R I SA YOC, t h e d e f e n d a n t , m a i l e dapproximately 13 IEDs through U.S. mail to certain current and former U.S. Government officials, politicians, and others, including mailings across state lines.
a. The intended targets of the defendant's IEDsincluded former President Barack Obama; former Vice PresidentJoseph Biden; former Secretary of State, former Senator, formerFirst Lady, and 2016 Presidential Candidate Hillary Clinton;former Attorney General Eric Holder; Congressperson Maxine waters; Senator Cory Booker; former Director of the Central Intelligence
Agency John Brennan; former Director of National IntelligenceJames Clapper; philanthropist and billionaire George Soros; andactor and director Robert De Niro.
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5. In or about October 2018, in the Southern District of New York and elsewhere, CESAR ALTIERI SAYOC, the defendant, with the intent to commit another felony, to wit, the charges set out in Counts One through Four of this Complaint, forcibly assaulted and intimidated any person who formerly served as aperson designated in Title 18, United States Code, Section 1114,to wit SAYOC mailed the IEDs described in Count One to two formerPresidents, a former Vice President, former Members of the U.S. Congress, and former Executive Branch employees.
(Title 18, United States Code, Sections lll(a), lll(b), and 2.)
The bases for my knowledge and the foregoing chargesare, in part, as follows:
6. I am a Special Agent with the FBI and a member of the FBI's New York-based JTTF, and I have been personally involved in the investigation of this matter. This affidavit is based in part upon my conversations with law enforcement agents and other people, and my examination of reports and records. Because this affidavit is being submitted for the limited purpose of establishing probable cause, it does not include all of the facts that I have learned during the course of my investigation. Wherethe contents of documents and the actions, statements, andconversations of others are reported herein, they are reported in substance and in part, except where otherwise indicated.
Overview
7. During the course of October 2018, as further d e t a i l e d b e l o w , CESAR A L T I E R I SA YOC, t h e d e f e n d a n t , m a i l e dapproximately 13 IEDs through U.S. mail to certain current and former U.S. Government officials, politicians, and others, including mailings across state lines.
a. The intended targets of the defendant's IEDsincluded former President Barack Obama; former Vice PresidentJoseph Biden; former Secretary of State, former Senator, formerFirst Lady, and 2016 Presidential Candidate Hillary Clinton;former Attorney General Eric Holder; Congressperson Maxine waters; Senator Cory Booker; former Director of the Central Intelligence
Agency John Brennan; former Director of National IntelligenceJames Clapper; philanthropist and billionaire George Soros; andactor and director Robert De Niro.
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b. Each of the 13 IEDs was largely similar in design and construction; they each consisted of approximately six inches of PVC pipe, a small clock, a battery, wiring, and energetic material.l Certain of the mailings included photographs of the target-recipients marked with a red "X."
c. Each of the 13 IEDs was packaged in a tan- colored manila envelope lined with bubble wrap. Each was stampedwith approximately six self-adhesive postage stamps each bearinga picture of an American flag. Each envelope listed a return sender of "DEBBIE WASSERMAN SHULTZ" at a particular address in Florida ("Schultz Office-1"). Each envelope misspelled "Florida" in the Schultz Office-1 return address as "FLORIDS" rather than"FLORIDA." The return sender and the target-recipient listed on each envelope was typed in black ink on white paper.
8. As discussed below, based on initial analysis fromthe FBI laboratory in Quantico, Virginia (the "FBI Lab"), a latent fingerprint was detected on one of the envelopes containing an IEDthat was sent to Congressperson Waters and this fingerprint wasidentified to CESAR ALTIERI SAYOC, the defendant. In addition, there is a possible DNA association between a sample collectedfrom a piece of the IED inside two of the envelopes containingIEDs and a sample previously collected from SAYOC.
SAYOC's Targets
9. Based on my review of publicly available information, I have learned the following, among other things:
a. Barack Obama served as President of the UnitedStates from 2009 to 2017. One of former President Obama's mailing addresses is a Post Office Box located in Washington, D.C. ("ObamaMailing Address-1")
b. Hillary Clinton served as the First Lady of the United States from 1993 to 2001, a United States Senator from approximately 2001 to 2009, United States Secretary of State from approximately 2009 to 2013, and as a nominee for President of theUnited States in the 2016 Presidential Election. Clinton resides
1 Based on my conversations with other law enforcement officersand my training and experience, I understand energetic material to include explosives and material that gives off heat and energy through a rapid exothermic reaction when initiated by heat, shock,or friction.
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c. Each of the 13 IEDs was packaged in a tan- colored manila envelope lined with bubble wrap. Each was stampedwith approximately six self-adhesive postage stamps each bearinga picture of an American flag. Each envelope listed a return sender of "DEBBIE WASSERMAN SHULTZ" at a particular address in Florida ("Schultz Office-1"). Each envelope misspelled "Florida" in the Schultz Office-1 return address as "FLORIDS" rather than"FLORIDA." The return sender and the target-recipient listed on each envelope was typed in black ink on white paper.
8. As discussed below, based on initial analysis fromthe FBI laboratory in Quantico, Virginia (the "FBI Lab"), a latent fingerprint was detected on one of the envelopes containing an IEDthat was sent to Congressperson Waters and this fingerprint wasidentified to CESAR ALTIERI SAYOC, the defendant. In addition, there is a possible DNA association between a sample collectedfrom a piece of the IED inside two of the envelopes containingIEDs and a sample previously collected from SAYOC.
SAYOC's Targets
9. Based on my review of publicly available information, I have learned the following, among other things:
a. Barack Obama served as President of the UnitedStates from 2009 to 2017. One of former President Obama's mailing addresses is a Post Office Box located in Washington, D.C. ("ObamaMailing Address-1")
b. Hillary Clinton served as the First Lady of the United States from 1993 to 2001, a United States Senator from approximately 2001 to 2009, United States Secretary of State from approximately 2009 to 2013, and as a nominee for President of theUnited States in the 2016 Presidential Election. Clinton resides
1 Based on my conversations with other law enforcement officersand my training and experience, I understand energetic material to include explosives and material that gives off heat and energy through a rapid exothermic reaction when initiated by heat, shock,or friction.
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at, among other locations, an address in Chappaqua, New York, withher husband, former President William Jefferson Clinton, whoserved as President of the United States from 1993 to 2001
("Clinton Residence-1") . Certain staff members for the Clintonfamily operate out of a residence located in Chappaqua, New York
("Clinton Residence-2").
c. Joseph Biden served as Vice President of theUnited States from 2009 to 2017 under President Obama. Fromapproximately 1973 to 2009, Vice President Biden was a member of the U.S. Senate. Former Vice President Biden resides at an address in Wilmington, Delaware ("Biden Residence-1").
d. Eric Holder served as the Attorney General of the United States from approximately 2009 to 2015 under PresidentObama. He is currently employed as a partner of a certain law firm, and is based out of the law firm's Washington, D.C. office
("Holder Office-1")
e. Maxine Waters serves as a member of the U.S. House of Representatives. She has served as a Congressperson since1990. Congressperson Waters has two principal offices: one is located in Washington, D.C. ("Waters Office-1"), and one is located in Los Angeles, California ("Waters Office-2") .
f. Cory Booker serves as a member of the U.S.Senate. He has served as a Senator since 2013. One of SenatorBooker's offices is located in Camden, New Jersey ("Booker Office-1") .
g. Kamala Harris serves as a member of the U.S.Senate. She has served as a Senator since 2017. One of Senator Harris's offices is located in Sacramento, California ("Harris Office-1") .
h. John Brennan served as Director of the Central Intelligence Agency ("CIA") from approximately 2013 to 2017, underPresident Obama.
i. James Clapper served as Director of National Intelligence from approximately 2010 to 2017, under PresidentObama.
j. George Soros is a prominent U.S. -based philanthropist and billionaire. Soros resides at, among other locations, an address in Katonah, New York ("Soros Residence-1") .
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("Clinton Residence-1") . Certain staff members for the Clintonfamily operate out of a residence located in Chappaqua, New York
("Clinton Residence-2").
c. Joseph Biden served as Vice President of theUnited States from 2009 to 2017 under President Obama. Fromapproximately 1973 to 2009, Vice President Biden was a member of the U.S. Senate. Former Vice President Biden resides at an address in Wilmington, Delaware ("Biden Residence-1").
d. Eric Holder served as the Attorney General of the United States from approximately 2009 to 2015 under PresidentObama. He is currently employed as a partner of a certain law firm, and is based out of the law firm's Washington, D.C. office
("Holder Office-1")
e. Maxine Waters serves as a member of the U.S. House of Representatives. She has served as a Congressperson since1990. Congressperson Waters has two principal offices: one is located in Washington, D.C. ("Waters Office-1"), and one is located in Los Angeles, California ("Waters Office-2") .
f. Cory Booker serves as a member of the U.S.Senate. He has served as a Senator since 2013. One of SenatorBooker's offices is located in Camden, New Jersey ("Booker Office-1") .
g. Kamala Harris serves as a member of the U.S.Senate. She has served as a Senator since 2017. One of Senator Harris's offices is located in Sacramento, California ("Harris Office-1") .
h. John Brennan served as Director of the Central Intelligence Agency ("CIA") from approximately 2013 to 2017, underPresident Obama.
i. James Clapper served as Director of National Intelligence from approximately 2010 to 2017, under PresidentObama.
j. George Soros is a prominent U.S. -based philanthropist and billionaire. Soros resides at, among other locations, an address in Katonah, New York ("Soros Residence-1") .
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Soros's former spouse resides at a second address in Katonah, NewYork ("Soros Residence-2").
k. Robert De Niro is an American actor, producer,and director. De Niro is the co-founder of a film and television production company located at a particular address in New York,New York ("De Niro Address-1").
1. Debbie Wasserman Schultz serves as a member of the U.S. House of Representatives. She has served as aCongressperson since 2005. Congressperson Schultz has an office at a particular location in Florida ("Schultz Office-1").
SAYOC Mails 13 IEDs
The Soros Package
10. Based on my review of documents and records, myconversations with other law enforcement officers, and myinvolvement in this investigation, I have learned the following,among other things:
a. On or about October 22, 2018, a packagecontaining an IED addressed to "GEORGE SOROS" was delivered viaU.S. mail to Soros Residence-2 (the "Soros Package," and together with the other 12 packages described below, the "Packages").
b. The Soros Package consisted of a tan-coloredmanila envelope lined with bubble wrap. Approximately six self-adhesive postage stamps each bearing a picture of an American flagwere stamped on the top right corner of the Soros Package. Each envelope listed a return sender of "DEBBIE WASSERMAN SHULTZ" at Schultz Office-1. Each envelope misspelled "Florida" in the Schultz Office-1 return address as "FLORIDS" rather than"FLORIDA." The return sender and the target-recipient listed onthe Soros Package were typed in black ink on white paper. Thereturn address for the Soros Package was Schultz Office-1.
c. The Soros Package was later received bypersonnel at Soros Residence-1. Personnel at Soros Residence-1opened the package and, upon identifying what appeared to be an IED, called law enforcement authorities.
d. On or about October 22, 2018, the FBIidentified what appeared to be an IED inside the Soros Package.
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k. Robert De Niro is an American actor, producer,and director. De Niro is the co-founder of a film and television production company located at a particular address in New York,New York ("De Niro Address-1").
1. Debbie Wasserman Schultz serves as a member of the U.S. House of Representatives. She has served as aCongressperson since 2005. Congressperson Schultz has an office at a particular location in Florida ("Schultz Office-1").
SAYOC Mails 13 IEDs
The Soros Package
10. Based on my review of documents and records, myconversations with other law enforcement officers, and myinvolvement in this investigation, I have learned the following,among other things:
a. On or about October 22, 2018, a packagecontaining an IED addressed to "GEORGE SOROS" was delivered viaU.S. mail to Soros Residence-2 (the "Soros Package," and together with the other 12 packages described below, the "Packages").
b. The Soros Package consisted of a tan-coloredmanila envelope lined with bubble wrap. Approximately six self-adhesive postage stamps each bearing a picture of an American flagwere stamped on the top right corner of the Soros Package. Each envelope listed a return sender of "DEBBIE WASSERMAN SHULTZ" at Schultz Office-1. Each envelope misspelled "Florida" in the Schultz Office-1 return address as "FLORIDS" rather than"FLORIDA." The return sender and the target-recipient listed onthe Soros Package were typed in black ink on white paper. Thereturn address for the Soros Package was Schultz Office-1.
c. The Soros Package was later received bypersonnel at Soros Residence-1. Personnel at Soros Residence-1opened the package and, upon identifying what appeared to be an IED, called law enforcement authorities.
d. On or about October 22, 2018, the FBIidentified what appeared to be an IED inside the Soros Package.
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The FBI's Special Agent Bomb Technicians, along with the Westchester Hazardous Device Unit, rendered safe the contents ofthe Soros Package. An initial examination of the contents of theSoros Package revealed what appeared to be PVC pipe, a cap, clock, battery, wires, and energetic material. Included in the Soros
Package was a photograph of George Soros marked with a red "X."
The C1inton Package
11. Based on my review of documents and records, myconversations with other law enforcement officers, and myinvolvement in this investigation, I have learned that on or about October 23, 2018, a package containing an IED was delivered to Clinton Residence-2 addressed to "HILARY [sic] CLINTON" (the "Clinton Package").
The Obama Package
12. Based on my review of documents and records, myconversations with other law enforcement officers, and myinvolvement in this investigation, I have learned that on or about October 23, 2018, a package containing an IED was delivered toObama Mailing Address-1, and it was addressed to "BARRACK [sic]OBAMA" (the "Obama Package") . Included in the Obama Package was a photograph of President Obama marked with a red "X."
The Brennan Package
13. Based on my review of documents and records, myconversations with other law enforcement officers, and myinvolvement in this investigation, I have learned that on or about October 24, 2018, a package containing an IED was delivered to"TIME WARNER (CNN)" at a certain address in Manhattan, New York
("Manhattan Address-1") , and it was addressed to "JOHN BRENAN"
[sic] (the "Brennan Package") . Included in the Brennan Packagewas a photograph of John Brennan marked with a red "X."
The Ho1der Package
14. Based on my review of documents and records, myconversations with other law enforcement officers, and myinvolvement in this investigation, I have learned that on or about October 24, 2018, a package containing an IED addressed to "ERIC HIMPTON HOLDER" at Holder Office-1 was returned to sender (the "Holder Package").
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Package was a photograph of George Soros marked with a red "X."
The C1inton Package
11. Based on my review of documents and records, myconversations with other law enforcement officers, and myinvolvement in this investigation, I have learned that on or about October 23, 2018, a package containing an IED was delivered to Clinton Residence-2 addressed to "HILARY [sic] CLINTON" (the "Clinton Package").
The Obama Package
12. Based on my review of documents and records, myconversations with other law enforcement officers, and myinvolvement in this investigation, I have learned that on or about October 23, 2018, a package containing an IED was delivered toObama Mailing Address-1, and it was addressed to "BARRACK [sic]OBAMA" (the "Obama Package") . Included in the Obama Package was a photograph of President Obama marked with a red "X."
The Brennan Package
13. Based on my review of documents and records, myconversations with other law enforcement officers, and myinvolvement in this investigation, I have learned that on or about October 24, 2018, a package containing an IED was delivered to"TIME WARNER (CNN)" at a certain address in Manhattan, New York
("Manhattan Address-1") , and it was addressed to "JOHN BRENAN"
[sic] (the "Brennan Package") . Included in the Brennan Packagewas a photograph of John Brennan marked with a red "X."
The Ho1der Package
14. Based on my review of documents and records, myconversations with other law enforcement officers, and myinvolvement in this investigation, I have learned that on or about October 24, 2018, a package containing an IED addressed to "ERIC HIMPTON HOLDER" at Holder Office-1 was returned to sender (the "Holder Package").
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The W aters Packages
15. Based on my review of documents and records, myconversations with other law enforcement officers, and myinvolvement in this investigation, I have learned the following,among other things:
a. On or about October 24; 2018, a packagecontaining an IED was delivered to Waters Office-1, and it wasaddressed to "MAXIM [sic] WATERS" ("Waters Package-1").
b. On or about October 24, 2018, a packagecontaining an IED was delivered to Waters Office-2 ("Waters Package-2," and together with "Waters Package-1," the "Waters Packages") . Waters Package-2 was addressed to "MAXIM [sic] WATERS"at Waters Office-2. Included in Waters Package-2 was a photographof Congressperson Waters marked with a red "X."
The Biden Packages
16. Based on my review of documents and records, myconversations with other law enforcement officers, and myinvolvement in this investigation, I have learned the following,among other things:
a. On or about October 25, 2018, a packagecontaining an IED addressed to "JOSEPH ROBINETTE BIDEN JR." at acertain assisted living facility was unsuccessfully delivered andrecovered in Delaware ("Biden Package-1") .
b. On or about October 25, 2018, a packagecontaining an IED was unsuccessfully delivered to Biden Residence-1 ("Biden Package-2," and together with "Biden Package-1," the"Biden Packages"). Biden Package-2 was addressed to "JOSEPH BIDEN"at Biden Residence-1.
The De Niro Package
17. Based on my review of documents and records, myconversations with other law enforcement officers, and myinvolvement in this investigation, I have learned that on or about October 25, 2018, a package containing an IED addressed to "ROBERTDE NIRO" was delivered to De Niro Address-1 (the "De Niro Package") .
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15. Based on my review of documents and records, myconversations with other law enforcement officers, and myinvolvement in this investigation, I have learned the following,among other things:
a. On or about October 24; 2018, a packagecontaining an IED was delivered to Waters Office-1, and it wasaddressed to "MAXIM [sic] WATERS" ("Waters Package-1").
b. On or about October 24, 2018, a packagecontaining an IED was delivered to Waters Office-2 ("Waters Package-2," and together with "Waters Package-1," the "Waters Packages") . Waters Package-2 was addressed to "MAXIM [sic] WATERS"at Waters Office-2. Included in Waters Package-2 was a photographof Congressperson Waters marked with a red "X."
The Biden Packages
16. Based on my review of documents and records, myconversations with other law enforcement officers, and myinvolvement in this investigation, I have learned the following,among other things:
a. On or about October 25, 2018, a packagecontaining an IED addressed to "JOSEPH ROBINETTE BIDEN JR." at acertain assisted living facility was unsuccessfully delivered andrecovered in Delaware ("Biden Package-1") .
b. On or about October 25, 2018, a packagecontaining an IED was unsuccessfully delivered to Biden Residence-1 ("Biden Package-2," and together with "Biden Package-1," the"Biden Packages"). Biden Package-2 was addressed to "JOSEPH BIDEN"at Biden Residence-1.
The De Niro Package
17. Based on my review of documents and records, myconversations with other law enforcement officers, and myinvolvement in this investigation, I have learned that on or about October 25, 2018, a package containing an IED addressed to "ROBERTDE NIRO" was delivered to De Niro Address-1 (the "De Niro Package") .
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The Booker Package
18. Based on my review of documents and records, myconversations with other law enforcement officers, and myinvolvement in this investigation, I have learned that on or about October 26, 2018, a package containing an IED addressed to "CORY BOOKER" was recovered in the U.S. Postal Service's Royal Palm MailProcessing Center in Opa-Locka, Florida (the "Booker Package") .
The ciapper Package
19. Based on my review of documents and records, myconversations with other law enforcement officers, and myinvolvement in this investigation, I have learned that on or about October 26, 2018, a package addressed to "JAMES ROBERT CLAPPER" atManhattan Address-1 was recovered in Manhattan (the "Clapper Package") .
The Harris Package
20. Based on my review of documents and records, myconversations with other law enforcement officers, and myinvolvement in this investigation, I have learned that on or about October 26, 2018, a package addressed to "KAMALIA HARRIS" wasrecovered in Sacramento, California (the "Harris Package").
The 13 Packages Taken Together
21. The Packages--the Soros Package, the ClintonPackage, the Obama Package, the Brennan Package, the Holder Package, W aters Package-1, W aters Package-2, Biden Package-1, Biden Package-2, the De Niro Package, the Booker Package, theClapper Package, and the Harris Package--are largely identical with respect to size and shape. In addition, approximately six self-adhesive American flag postage stamps are located on the topright corner of each of the Packages, the return address for eachof the Packages is the same, and the sender and target-recipient address labels on each of the Packages are substantially similar in terms of color, size, and font.
Latent Print and DNA Ana1ysis
22. Based on corrununications with personnel from the FBILab, I know, among other things, that a latent fingerprint wasdetected on Waters Package-1 and this fingerprint was identified to CESAR ALTIERI SAYOC, the defendant. According to the FBI Lab,
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18. Based on my review of documents and records, myconversations with other law enforcement officers, and myinvolvement in this investigation, I have learned that on or about October 26, 2018, a package containing an IED addressed to "CORY BOOKER" was recovered in the U.S. Postal Service's Royal Palm MailProcessing Center in Opa-Locka, Florida (the "Booker Package") .
The ciapper Package
19. Based on my review of documents and records, myconversations with other law enforcement officers, and myinvolvement in this investigation, I have learned that on or about October 26, 2018, a package addressed to "JAMES ROBERT CLAPPER" atManhattan Address-1 was recovered in Manhattan (the "Clapper Package") .
The Harris Package
20. Based on my review of documents and records, myconversations with other law enforcement officers, and myinvolvement in this investigation, I have learned that on or about October 26, 2018, a package addressed to "KAMALIA HARRIS" wasrecovered in Sacramento, California (the "Harris Package").
The 13 Packages Taken Together
21. The Packages--the Soros Package, the ClintonPackage, the Obama Package, the Brennan Package, the Holder Package, W aters Package-1, W aters Package-2, Biden Package-1, Biden Package-2, the De Niro Package, the Booker Package, theClapper Package, and the Harris Package--are largely identical with respect to size and shape. In addition, approximately six self-adhesive American flag postage stamps are located on the topright corner of each of the Packages, the return address for eachof the Packages is the same, and the sender and target-recipient address labels on each of the Packages are substantially similar in terms of color, size, and font.
Latent Print and DNA Ana1ysis
22. Based on corrununications with personnel from the FBILab, I know, among other things, that a latent fingerprint wasdetected on Waters Package-1 and this fingerprint was identified to CESAR ALTIERI SAYOC, the defendant. According to the FBI Lab,
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Case 1:18-mj-09159-UA Document 1 Filed 10/26/18 Page 10 of 11
the identification has been through the appropriate quality assurance measures. 2
23. Based on communications with personnel from the FBILab, I know, among other things, that (a) there is a possible DNAassociation between a sample collected from a piece of the IEDinside Waters Package-1 and a sample previously collected fromCESAR ALTIERI SAYOC, the defendant, by the Florida Department ofLaw Enforcement, (b) there is a possible DNA association betweena sample collected from a piece of the IED inside the Obama Package and a sample collected from SAYOC by the Florida Department of LawEnforcement, and (c) to this point, the FBI Lab has not identifiedany other possible matches on the evidence from the Packages thatit has examined.
The Routing of the Packages
24. Based on conversations with employees of the U.S.Postal Service, I know, among other things, that:
a. Between on or about October 18, 2018 and on orabout October 20, 2018, the Obama Package, the Clinton Package,the De Niro Package, Waters Package-1, and Biden Package-1 wererouted through the U.S. Postal Service's Royal Palm Mail ProcessingCenter in Opa-Locka, Florida (the "Opa-Locka Center").
b. The county in which CESAR ALTIERI SAYOC, the defendant, resides is serviced by the Opa-Locka Center.
SAYOC's Arrest
25. Based on my conversations with other law e n f o r c e m e n t o f f i c e r s , I k n o w t h a t CESAR A L T I E R I SA YOC, t h e defendant, was arrested on or about October 26, 2018, in Florida, in the vicinity of his white van. The windows of SAYOC's van were covered with images including images critical of CNN.
2 Consistent with FBI policy, all latent fingerprint results are considered preliminary until an official FBI report is issued following technical and administrative review.
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23. Based on communications with personnel from the FBILab, I know, among other things, that (a) there is a possible DNAassociation between a sample collected from a piece of the IEDinside Waters Package-1 and a sample previously collected fromCESAR ALTIERI SAYOC, the defendant, by the Florida Department ofLaw Enforcement, (b) there is a possible DNA association betweena sample collected from a piece of the IED inside the Obama Package and a sample collected from SAYOC by the Florida Department of LawEnforcement, and (c) to this point, the FBI Lab has not identifiedany other possible matches on the evidence from the Packages thatit has examined.
The Routing of the Packages
24. Based on conversations with employees of the U.S.Postal Service, I know, among other things, that:
a. Between on or about October 18, 2018 and on orabout October 20, 2018, the Obama Package, the Clinton Package,the De Niro Package, Waters Package-1, and Biden Package-1 wererouted through the U.S. Postal Service's Royal Palm Mail ProcessingCenter in Opa-Locka, Florida (the "Opa-Locka Center").
b. The county in which CESAR ALTIERI SAYOC, the defendant, resides is serviced by the Opa-Locka Center.
SAYOC's Arrest
25. Based on my conversations with other law e n f o r c e m e n t o f f i c e r s , I k n o w t h a t CESAR A L T I E R I SA YOC, t h e defendant, was arrested on or about October 26, 2018, in Florida, in the vicinity of his white van. The windows of SAYOC's van were covered with images including images critical of CNN.
2 Consistent with FBI policy, all latent fingerprint results are considered preliminary until an official FBI report is issued following technical and administrative review.
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Case 1:18-mj-09159-UA Document 1 Filed 10/26/18 Page 11 of 11
SAYOC's Socia1 Media Posts
26. Based on my review of publicly available information on Twitter, I know that there is an account withusername "Cesar A ltieri" 3 that contains the following, amongother things:
a. Various posts with misspellings consistent with the Packages, including "Hilary" rather than "Hillary,"
"Shultz" rather than "Schultz"; and
b. A post dated October 24, 2018--i.e., afterthe recovery of the Soros Package--that is critical of, amongothers, President Barack Obama and George Soros.
WHEREFORE deponent prays that CESAR ALTIERI SAYOC, the defendant, be imprisoned, or bailed, as the case may be.
26. Based on my review of publicly available information on Twitter, I know that there is an account withusername "Cesar A ltieri" 3 that contains the following, amongother things:
a. Various posts with misspellings consistent with the Packages, including "Hilary" rather than "Hillary,"
"Shultz" rather than "Schultz"; and
b. A post dated October 24, 2018--i.e., afterthe recovery of the Soros Package--that is critical of, amongothers, President Barack Obama and George Soros.
WHEREFORE deponent prays that CESAR ALTIERI SAYOC, the defendant, be imprisoned, or bailed, as the case may be.
Sworn to before me this26th day of October 2018
HONORABLE KA THARINE
HONORABLE KA THARINE
Special Agent David BrownFederal Bureau of Investigation Joint Terrorism Task Force
*Sworn to before me by reliable electronic means (Face Time).
*Sworn to before me by reliable electronic means (Face Time).
3 Based on my training and experience, as well as my review of law enforcement databases, I believe that SAYOC is the user of the"Cesar A ltieri" Twitter account because (i) A ltieri is SAYOC' smiddle name, and (ii) the location of SAYOC's last known residence in Aventura, Florida is proximate to the two locations listed in the account information for the "Cesar Altieri" Twitter account
(Sunny Isle Beach and Hollywood, Florida)
(Sunny Isle Beach and Hollywood, Florida)
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