AO 91 (Rev. 08/09) Criminal Complaint UNITED STATES DISTRICT COURT for the District of Columbia ) ) ) ) ) ) United States of America v. DOMINIC ADESANYA Case: 1:14-mj-00629 Ass~gned To : Magistrate Judge Deborah A Robinson Ass1gn. Date : 10/23/2014 Description: Criminal Complaint and Arrest Defendant(s) CRIMINAL COMPLAINT I, the complainant in this case, state that the following is true to the best of my knowledge and belief. On or about the date(s) of District of October 22, 2014 Columbia in the county of in the , the defendant(s) violated: Code Section Offense Description 18 U.S.C. section 1752(a)(1) Knowingly entering or remaining in restructed building or grounds without lawful authority 18 U.S.C. section 1368(a) Harming animals used in law enforcement This criminal complaint is based on these facts: SEE ATTACHED AFFIDAVIT 0 · Continued on the attached sheet. Complainant's signature Special Agent John Grimsley Printed name and title Sworn to before me and signed in my presence. Date: 10/23/2014 / City and state: Washington, D.C. Judge's signature Magistrate Deborah A. Robinson Printed name and title UNITED STATES DISTRICT COURT DISTRICT OF COLUMBIA UNITED STATES OF AMERICA v. Case: 1:14-mj-00629 . Assigned To : Magistrate Judge Deborah A Robmson Assign. Date: 10/23/2014 Description: Criminal Complaint and Arrest DOMINIC ADESANY A, Defendant. AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT AND ARREST WARRANT John Grimsley, an Officer with the United States Secret Service, Washington, D.C., (hereinafter "your affiant") being duly sworn, deposes and states as follows: 1. I am a Special Agent with the United States Secret Service. 2. This affidavit is based, in part, upon my personal observations, information provided to me by other Special Agents of the United States Secret Service, witnesses, and other information gathered during the course of this investigation. Since this affidavit is being submitted for the limited purpose of obtaining a criminal complaint and arrest warrant, I have .not included each and every fact known to me concerning this investigation. I have set forth only the facts which I believe are necessary to establish probable cause for a criminal complaint. and arrest warrant. 3. This affidavit is submitted in support of an application for a criminal complaint and arrest ·warrant charging DOMINIC ADESANY A with knowingly entering or remaining in a restricted building or grounds without lawful authority to so, in violation of Title 18, United States Code § 1752(a)(1), and with Harming Animals Used in Law Enforcement, in violation of Title 18, United States Code § 1368(a). 4. As a result of my personal participation in this investigation, as well as through interviews with and analysis of reports submitted by other officers of the United States Secret Service and other law enforcement agencies who are involved in this investigation, I am familiar with all aspects of this investigation. On the basis of this familiarity, and on the basis of other information which I have reviewed and determined to be reliable, I allege the following facts to show there is probable cause to believe that DOMINIC ADESANYA committed offenses involving knowingly entering or remaining in a restricted building or grounds, and willfully and maliciously harming a police animal. 5. Under Title 18, United States Code, § 1752(a)(l ), whoever knowingly enterers or remains in any restricted building or grounds without lawful authority to do so shall be punished by a fine or imprisonment for not more than 1 year. 6. Under Title 18, United States Code, § 1752(c)(l)(A), the term "restricted buildings or grounds" includes any posted, cordoned off, or other restricted area of the White House or its grounds. 7. Under Title 18, United States Code, § 1368(a), whoever willfully and maliciously harms any police animal, or attempts or conspires to do so, shall be imprisoned not more than 1 year. 8. Under Title 18, United States Code, § 1368(b), the term "police animal" means a dog or horse employed by a Federal agency (whether in the executive, legislative, or judicial branch) for the principal purpose of aiding in the detection of criminal activity, enforcement of laws, or apprehension of criminal offenders. 9. On October 22, 2014, Officer David Roney, a member of the Uniform Division of the Secret Service, saw a black man wearing a black, long-sleeve shirt, grey shorts and black tennis shoes, later identified as DOMINIC ADESANY A, climb over the White House north 2 fence and enter the White House grounds as Officer Roney approached to stop him. 10. Adesanya ran towards the north doors of the White House while members of the Uniform Division of the Secret Service ordered Adesanya to stop and get on the ground. Adesanya did not comply with those orders. 11. While Adesanya was crossing the White House grounds, members ofthe Uniform Division's Canine Division released two dogs, who were trained to assist in the apprehension of criminal offenders. One dog, Jordan, confronted Adesanya, who kicked the dog. 12. The other dog, Hurricane, knocked Adesanya down. Adesanya got up and threw the dog to the ground. Adesanya also repeatedly struck the dog with a closed fist. 13. Moments later, Adesanya was apprehended and placed in handcuffs by members of the Secret Service. 14. After Adesanya was apprehended, Special Agent Ronald Axt heard Adesanya say that Adesanya needed to talk to President Obama because he, Adesanya, was a targeted individual, and that Adesanya was going to keep coming back until he saw President Obama. CONCLUSION 11. Based on the aforementioned factual information, I respectfully submit that there is probable cause to believe that DOMINIC ADESANY A knowingly entered or remained in a restricted building or grounds, namely, the White House, without lawful authority to do so, in violation of 18 U.S.C. § 1752(a)(1), and willfully and maliciously harmed a police animal, or attempted to do so, in violation ofTitle 18, United States Code,§ 1368(a). 3 ~ubmitted, j-:JJ_ . " OGT ! $ 2014 John Grimsley Subscribed and sworn to before me this - - of October, 2014. 4