IN THE UNITED STATES DISTRICT COT]RT FOR THE
WESTERN DISTRICT OF OI(LAHOMA

FILED
sEP 0 5

UNITED STATES OF AMERICA,

Plaintiff,
-vs-

JOSEPH MALDONADO-PASSAGE,
alkl a Joseph Allen Maldonado,
alkl a Joseph Allen Schreibvogel,
alklz "Joe Exotic,"
Defendant.

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2018

CARMEUTA REEDER SHINN. CLERK

No.

B'WLBffi
urt t$ *'azTsLP

Violation: 18 U.S.C. $ 1958(a)

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INDICTMENT
The Federal Grand Jury charges

At all times relevant to this Indictment

1.

Defendant JOSEPH MALDONADO-PASSAGE was a resident

of

the

Western District of Oklahoma.

2-

"Jane Doe" was a resident of the state of Florida.

3.

Beginning at least by February 2014, MALDONADO-PASSAGB posted

content online, including on Facebook and YouTube websites, containing threats of
violence against Jane Doe

 Count

1

(Use of Interstate Commerce Facilities in the Commission of

Murder-for-Hire)

4.

The Federal Grand Jury incorporates paragraphs 1-3 by reference.

5.

At least by early November 2017, MALDONADO-PASSAGE inquired of

Individual

1

whether Individual

for a sum of money. Individual

I would travel to Florida to murder Jane Doe in exchange
1

told MALDONADO-PASSAGE that he would travel

to Florida to murder Jane Doe in exchange for a sum of money.

6.
Individual

On or about November 6, 2017, MALDONADO-PASSAGE
1

caused

to travel from the Western District of Oklahoma to Dallas, Texas, to obtain a

fake identification card for use in a proposed plot for Individual 1 to travel to Florida to
murder Jane Doe.

7.

On or about November 25,20L7, MALDONADO-PASSAGE used the U.S.

Postal Service to mail Individual 1's cell phone from the Western District of Oklahoma to

Nevadato conceal Individual 1's involvement in aproposedplot to murderJane Doe in
Florida.

8.

On or about November 25,2017, in the Western District of Oklahoma,

MALDONADO-PASSAGE gave Individual

1

approximately $3,000 in cash in exchange

for Individual 1's agreement to travel to Florida to murder Jane Doe. MALDONADOPASSAGE promised to pay Individual 1 thousands of dollars more after Individual

1

murdered Jane Doe.

9.

MALDONADO-PASSAGE agreed with Individual 1 that Individual

1

would travel from the Western District of Oklahoma to South Carolina, and then to Florida,
2

 to murder Jane Doe.

10.

On or about November 26,2017, Individual 1 traveled from the Western

District of Oklahoma to South Carolina.

11. No physical harm came to Jane Doe as a result of MALDONADOPASSAGE's proposed plot for her murder

12. In or about November 2017, in the Western District of Oklahoma and
elsewhere,

JOSEPH MALDONADO-PASSAGE,
alkl r Joseph Allen Maldonado,
alWa Joseph Allen Schreibvogel,
alklr "Joe Exotic."
caused another person to travel in interstate commerce, used and caused another person to
use the mail, and used and caused another person to use any facility of interstate commerce,

with intent that the murder of Jane Doe be committed in violation of the laws of the state

of

Oklahoma and the state

of Florida as consideration for the receipt of, and as

consideration for a promise and agreement to pay, anything of pecuniary value.

All in violation of Title

18, United States Code, Section 1958(a).

Count

2

(Use of Interstate Commerce Facilities in the Commission of Murder-for-Hire)

13.

The Federal Grand Jury incorporates paragraphs l-3 by reference

14.

Beginning

in

approximately

July 2016, and continuing through

approximately March 2018, MALDONADO-PASSAGE repeatedly asked Individual 2

3

 whether Individual 2 could find someone to murder Jane Doe in exchange for a sum of
money

15.
spoke

On or about December 5,2017, Individual2 called from his cell phone and

with MALDONADO-PASSAGE on his cell phone. Individual 2 offered

to

introduce MALDONADO-PASSAGE to a person who would be willing to murder Jane
Doe in exchange for a sum of money. MALDONADO-PASSAGE agreed to the meeting

16.

On or about December 8,2017, Individual2 introduced MALDONADO-

PASSAGE to an undercover FBI agent, and together the three individuals discussed the
details of MALDONADO-PASSAGE's proposed plot to murder Jane Doe

17.

On various dates from December 2017 to March 2018, MALDONADO-

PASSAGE used his cell phone to speak with Individtral2 on his cell phone about using
the undercover FBI agent to murder Jane Doe.

18. No physical

harm came to Jane Doe as a result of MALDONADO-

PASSAGE's proposed plot for her murder.

19.

Beginning at least by December 5, 2017, and continuing through about

March 20L8, in the Western District of Oklahoma,

JOSEPH MALDONADO.PASSAGE,
alkl aloseph Allen Maldonado,
alkJa Joseph Allen Schreibvogel,
alkla "Joe Exoticr"
used and caused another person to use any facility of interstate commerce, with intent that
the murder of Jane Doe be committed in violation of the laws of the state of Oklahoma and

the state of Florida as consideration for the receipt of, and as consideration for a promise

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 and agreement to pay, anything of pecuniary value
A11

in violation of Title 18, United States Code, Section 1958(a).

A TRUE BILL:

FOREPERSON OF THE GRAND JURY

ROBERT J. TROESTER
First Assistant United States Attorney

AMANDA GREEN
Assistant U.S. Attorney

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