Case 0:19-mj-06026-LSS Document 1 Entered on FLSD Docket 01/18/2019 Page 1 of 13

AO 91(R:v.l1/11hCrl
ml
nalCemplaiat

UNITED STATESD ISTRICT rouRy
fc?1he
Scuthem DistrictcfFlnrida

United sutesofAmerka

)
)
)

M.

BrendonFleury,

caseNô.

)

/f-6026-sNow

)
)

p#ndantl
zl

CRIM INAL C OM PLAINT
lvthecomplainantinthisçce,statethatth:following istroetcthebestofmy knowkdgeand belief.

Onorabûutthedatels)ef Detember2$,2018-January11$2019 tnthetokmtyof
Broward
icyht
Southem
Dlltrictof
Florl
d.
,t
hedefendctts)vinlated:
C* eSection
e al:Dezcrèdon
16U.S.C,675$)
TransmiqlngInInterst.t:commero atommunàtatlontontalnlngathreatto
kl
dnap apeœon;

18U.S.C.2261A(2)(B)

WiththeIntenttoharas::ndInti
ml
dateanotherperson,uslngeninteradive
computere,rvlce and el
edrenlccommonlcatl
onsystem ofInteatate
x mmemeto engagelnacetlr:eQfcendud thatcatlR d,attemptedtocause,
orwouldbereasonabl
yexpectedto cause x bstantlalemotlonaldletres:to
thatperx n.

Thlscrimina.
lcomplalntisbasedônthesefacts:
Seeettach.dAmtavlt.

O Cnntinuedonlheattach:dshed.
@

Complalnant'
zztgnature

CameronMcD- eII'Specl
alAgent FBI

Prinusxe
z-eanittde
Swom todeforemean1signed inmy presence,
G

rlate: / /v /q

,-

z'

..

6,

'

cityandstate:

Fod Laudedal.,Florlda

e
z

yp
@

...y
.
J'
vdge'
JzWnatvre

'
k

. a .yy...'l

LtlranaS.Sn- ,Unlted State,MaglatrateJudge
Printedo .JnJtltl.

 Case 0:19-mj-06026-LSS Document 1 Entered on FLSD Docket 01/18/2019 Page 2 of 13

AFFIDAVIT IN SUPPORT OF CRIM INAL COM PLAINT
1,Cam eron M cDowell,beingduly sworn, deelareand state asfollows:
1. INTRODUCTION

1.

I am a SpecialAgent (SA) with the Federal Bureau of Investigation (FBI),

currently assigned to the ViolentCrim esand Fugitive Task Force ofthe FBl'sM iam iDivision.
M y duties involve the investigation ofa variety offederaloffenses, including bank robberies

,

HobbsActrobberies,extortion, interstate threatsand otherviolationsoffederallaw . Iwashired

by the FBIin M ay of2017 and havebeen assigned to theM iamiDivision sinceOctober2017.
lI. PURPO SE OF AFFIDAVIT

This A ffdavit is subm itted in support of a crim inal complaint charging

BRANDON FLEURY (FLEURY) with violations ofTitle 18,United States Code, Sections
875(c)(threats in interstate communications)and 2261A(2)(B)(cyberstalking) Based on the
.

facts set forth below,I respectfully submit that there is probable cause to believe that, on

or

about Decem ber 25, 2018,FLEU RY did transmit in interstate comm erce a comm unication

containing a threatto kidnap a person, in violation ofTitle 18,United States Code, Section

875(c).lalso submitthatthereisprobablecausetobelievethat, between on oraboutDecember
22,2018,and January 11,2019, FLEURY did,with the intentto harass and intim idate another

person,use an interactive computer service and electronic communication system ofinterstate
commerce to engage in a course of conduct that caused, attempted to cause, or would be
reasonably expected to cause substantialem otionaldistress to thatperson, in violation ofTitle

18,United StatesCode,Section2261A(2)(B).
3.

The statementscontained in this Affidavitare based on m y personalknowledge,

as wellas inform ation relayed to m e by other law enforcem ent officials in this investigation. 1

have notincluded in this Aftsdaviteach and every factknown to m e. Rather,1 have included

onlythefactsthatare necessaryto establish probablecause.

Page 1 of 12

 Case 0:19-mj-06026-LSS Document 1 Entered on FLSD Docket 01/18/2019 Page 3 of 13

111. SUM M ARY O F PRO BABLE CAUSE
4.

Between on oraboutDecember22, 2018,and January 11,2019, FLEURY madea

striesofthreatening and harassing poststhrough the socialm edia application Instagram .l These
m essagesalliçm entioned''Instagram aceountsused by relativesand friendsofstudentswho were

killed in the mass shooting atM arjory Stoneman DouglasHigh School(M SD), in Parkland,

Florida,on February 14,1018 (itthe M SD shootinf'l.z Becaust tht posts ldmentioned''the
Instagram accounts of these relatives and friends, they received notitscations, including the
contentsofthe messages,when they accessed theirInstagrnm accounts. One postthreatened to

kidnap them essagerecipients,whileotherssoughtto harasstherecipientsby repeatedly taunting
therelativesand friendsoftheM SD victim s, cheering thedeathsoftheirloved onesand,

am ong

otherthings,askingthem to cry.

W hile the posts were made through several different Instagram accounts and
usernames,recordsforatleasttlve ofthe accounts3 show thatthey were allusing the sam e IP
address,which was assigned to an address in Santa Ana, California(the SantaAna address)at
thetim eofrelevantposts. FLEURY residesatthe SantaAnaaddresswith hisfatherand brother.
11nstagram ownsandoperatesafree- accesssocial-networking websiteofthe sam enam ethatcan
beaccessed athttp://www.instagram .com . U serscan accesslnstagram through the lnstagram

websiteorbyusingaspecialelectronicapplication(ç1app'')createdbythecompanythatallows
usersto accessthe servicethrough an electronicm obile device. U pon creating an lnstagram
account,an Instagrnm usermustcreateaunique lnstagram usernameand an accountpassword.
lnstagram allowsitsusersto createtheirown profilepages, postphotos,postcomm entson other
users'photos,and send directm essagesto otherInstagram users.
2A ccording to Instagram 'swebsite, one lnstagram usercan ilm ention''another Instagram

userinacommentorpostbytypingthe%%@ ''symbol,followedimmediatelybytheotheruser's

usenmme. W hen oneuseriçmentions''another, theiçm entioned''userreceivesanotiscation in
theirActivity feed,which willshow thecomm entorpost. See
ht
tps://help.in.
vtagram.com/627963287377328/.?hel
f11
pl-ef=hc fhav&bcf01=368390626577968&bc
=

898918476885209&bc(21=1771676186445020(lastac-cessedJanuary 10,2019)
.

3Thesim ilarsubstance oftherelevantposts, including repeated use ofthe sam e language

and emojis,indicatesthatthepostscamefrom thesameindividual,regardlessofthefactthathe
isusing multipledifferentInstagram accountsand usernam es. Because Fleury continually
changed accountsand usernames,thegovermnenthasnotyetobtained IP addressrecordsfor
everyaccountand usernamedescribed herein.However,al1oftheaccountsforwhich the
govem menthasobtained recordshave retlected the sameIP address.
Page 2 of 12

 Case 0:19-mj-06026-LSS Document 1 Entered on FLSD Docket 01/18/2019 Page 4 of 13

FBIagents and other 1aw enforcem ent officers obtained and executed a search
warranton theSantaAnaaddress.During execution ofthe search warrant, theexecuting officers

identified FLEURY asthe subjectwho made the online threats FLEURY provided a post.

M iranda statementadm itting to creating atleastsome ofthe lnstagram profiles and posting the

m essagesin an attemptto tauntortitroll''the victim sand gain popularity. FLEURY adm itttd to

targeting fam ily m emberswho wereVbactivists''who had a largesocialm ediapresence. FLEURY
adm itted to creating m ultiple Instagram profilesbecause he knew hiscomm entswould resultin

theprofilesbeing reported to,andremoved by, Instagram .
lV. STATEM ENT OF PROBABLE CAUSE
A.

Friendsand Fam ily oftheM SD Shooting ReceiveHarassing and
Threatening M essagesin Decem ber2018 and January 2019

Between December22,2018 and up to January 11, 2019,friendsand fnmily of

theM SD shootingreceivedharassingandthreateningmessages(viapostsinwhichtheywere
Stmentioned'')onlnstagram from variouslnstagram handles Those lnstagram m essagestraced
.

back to thesame IP address.
D ecem ber 22.2018 M essaaes

10.

On or aboutDecember22, 2018,several individuals, who are siblings,friends,

and parents of victim s of the M SD shooting, fled a harassm entand threating comm unication

reportwith theBroward County SheriffsOffce (BSO),in Broward County, Florida. Am ong
the reporting individuals wtre $1JG ,''SCFG '' and :SLS ''the brother, father, and best friend,
respectively, of itlam ie,'' who was killed in the M SD shooting. Another of the reporting
individualswasçiM S,''thefatherofanotherstudentkilled in the shooting.

The reporting individuals showed BSO screenshots of m essage notifications they had
received on Instagram . The notifications showed postsm ade by otherInstagram accountsthat
had iimentioned''the Instagram accountsofJG , LS,M S,and others,aswellasanotherInstagram

usernamethatcontained the name of(butdid notactually belongto)FG A sdescribed below ,
.

Page 3 of12

 Case 0:19-mj-06026-LSS Document 1 Entered on FLSD Docket 01/18/2019 Page 5 of 13

the reporting individuals continued to receive similar notifcations at least up to and through
January 11,2019,screenshotsofwhich they sim ilarly provided to 1aw enforcem ent.
11.

On oraboutDecember22,2018, from approxim ately 3:00 a.m .-4:11a.

m.(EST)

the victim swere m entioned in posts m ade by Instagrnm username S'nikolas.killed.your.sister.''
Notably, Nikolas Cruz is the nnm e of the adm itted pem etrator of the M SD shooting;he is
currently in law enforcem ent custody in Broward County, Florida.

The posts from

linikolas.killed.your.sister''thatiémentioned''JG included thefollowingmessages(amongothers)
in quick succession:
a.

:iIkilled yourloved oneshahaha''
iicry forme''

itYourgriefismyjoy''
çiW ith thepowerofmy AR-15, lerased theirexistence.''Thism essage
wasfollowed by sm iling,applause, andhandgun emojis.
4
e.

ç%Igavethem nom ercy''

f.

çll-hey had theirwhole livesahead ofthem and 1fucking stole itfrom

them.''Thismessagewasfollowed bythreeççcryingwhilelaughing''emojisandthewords
'çhahaha.''
g.

:ç1took Jaim eaway from you.''Thism essagewasfollowed by astring of

i'blowingakiss''emojis.
;$Itook Jaimeaway from you. You'llneversee heragain hahaha.''
$çltook ashiton yoursister'sgrave.''Thism essage wasfollowedby a

çicryingwhilelaughing''emoji,anapplauseemoji,andthreeçépoop''emojis.
12.

Otherpostsby éfnikolas.killed.your.sister''thatwere directed atLS included:
a.

i:Ikilled yourfriends,baby girl''

b.

1ûI'm a m urderer''

4Emojisaresmallpiduresorsymbolsused in textm essaging orpostson socialmediato
conveyemotionsorrepresentthingsorideas.
Page 4 of 12

 Case 0:19-mj-06026-LSS Document 1 Entered on FLSD Docket 01/18/2019 Page 6 of 13

çtDidyou likem y Valentinesgift? lkilled yourfriends.''
13.

JG's

Instagram

account also

received

a

direct message

from

itnikolas.killed.your.sister,''which read:$$Ikilled yoursister, Itwasfunl.
)Shehad herwholelife
ahead ofherand Ifucking stole itfrom her. Hahahag.)W armabeatmyass?Comeon,(JG'Sfirst

nmnej.How fucking bad do you wmma beatthe shitoutofme? W antme to getthe death
Penalty?''

Accordingto recordsprovided by Instagram in responseto asubpoena, the person
using the accountwith username t'nikolas.killed.your.sister''provided lnstagram with the nam e

ttNikolasJacob Cruz''andan emailaddressofnikolastheshooter@ gmail.com. The recordsalso
show that,atthe tim e of the posts described above, on December 22,2018,the accountwas

accessedfrom IP address68.5.103.67(ççthe67IP address'').
During his post-M iranda statem ent on Janum.
y 16, 2019,FLEURY adm itted to
using theGinikolas.killed.your.sister''Instagram usernam e.
Decem ber24.2018 M essaees

16.

On oraboutDecem ber24,2018,from approximately 9:40 p.m.-9:50p.m.(EST),

JG and LS wereSfm entioned''in Instagram postsby anotherInstagram usernam e,
isbullseyetauntsyou .''Thepostsincluded:
-

a.

çlYoo-hoo!N ikolastook Jaim eaway from you so cry form eplz.'' This

messagewasfollowedby smilingfaceandapplauseemojis.
û1You'11neverseeJaim eagain,littleorphan.Nikolastook herfrom you.''
During hisvost-M iranda statem ent,FLEURY admitted to using nicknamesthat
included the name l%bullseye,''areference to am ovie villain.

18.

Also on December24,2018,from approximately 9:45p.m .-11:13p.m.(EST),

JG and LS wereiçmentioned''in postsmadeby anotherlnstagram usernam e ççangie.and.lola.''

Thepostsincludedthefollowingmessages(amongothers)withinthespanofapproximately20
minutes:

a.

ççl-low 'sJamie,hun?''
Page 5 of12

 Case 0:19-mj-06026-LSS Document 1 Entered on FLSD Docket 01/18/2019 Page 7 of 13

b.

SsDead huh?''
fdN ikolastookyourloved onesaway from you, doll''

d.

éiNikolasstole Jaime'sfuture,boo''

e.

tçEatthepoopforJaimehun''(followedbyfourS%poop''emojis).

çûEatthepoopforJaime''(followedbyseveralççpoop''emojis).
g.

SûEatsomepoopforJaimethisholidayseason''(followedbyseveralpoop

emojis).
19.

The nam e associated with the 'sangie.and.lola''accountin lnstagram 's recordsis

iéAngie& Lola.'' Thoserecordsalso show thatthe accountwasopened with, and used,the67 IP
address.

20.

Continuing on oraboutDecember24,2018, from approxim ately 10:00p.m .-

10:05p.m .(EST),JG andLScontinuedreceivingnotificationsofadditionalmessagespostedby
lnstagram nameçinik.taunts .''Thepostsincludedthefollowing(among others):
a.

ççlkilled Jaim e,fool.'' Thism essagewasfollow ed by lfcrying while

laughing,''smiling,andhandgunemojis.
b.

4$lstole yoursister'sfuture,buddy, W ith thepowerofmy AR-159'

(followedbysmiling,handgun,andapplauseemojis).
1élkilled Jaim ehahaha''and
d

ççl'm hermurderer.''

Accordingto recordssubpoenaed from Instagram ,the nam eassociated with the
'fnik.taunts ''accountin Instagram 'srecordsisçtNikolas.''However,thoserecordsshow that,at

thetim eofthe messagesdescribed above,the accountwasbeing accessed by the67 IP address.
Decem ber25.2018 M essages
22.

On oraboutD ecem ber25,2018,from approxim ately 7:59 p.m.-8:02p.
m.(EST),

JG and LS werem entioned in morepostsfrom Instagram usernam edlteddykillspeople.'' These
postsincluded:

Page 6 of12

 Case 0:19-mj-06026-LSS Document 1 Entered on FLSD Docket 01/18/2019 Page 8 of 13

l%l'm yourabductorgsmileand applaudingemojisj1'm kidnapping you
fool''(followedbytwoemojisshowingalock,aswellasapplaudingand dtblowingakiss''
emojis).
b.
23.

çiIkilled Janice Ottand DeniseNaslund.''

Notably,Janice Ottand Denise Naslund were abducted and m urdered by serial

killer Ted Bundy in 1974. Although FLEU RY initially stated he did not recall using the
Séteddykillspeople''usem am e,during hisinterview ht admitted to having a strong interestin Ted
Bundy and having researched him .
Continuing on oraboutDecem ber25, 2018 from approxim ately 9:21p.m .-9:23

p.m .,JG and LS were limentioned''in Instagram posts from usernam e çstedtheabductor.'' The
postsincluded:
a.

tiNikolasm urdered yourfriendsand teachersbutguesswhat? lmurdered

JaniceOttand DeniseNaslund.''
b.

25.

ût1kidnapped them and killed them both on July 14, 1974.55

Based on thethreatto kidnap in thepostsfrom tûteddykillspeople,''Instagram

voluntarily provided theIP addressused by thataccounton an em ergency basisto law
enforcement.Instagram identifed the 67 IP addressastheIP addressused by thataccountatthe
tim eofthethreats.
December31.2018 M essaees
26.

On oraboutDecem ber31,2018,atapproxim ately 12:37a.m.(EST)JG was

m entioned in postsby Instagram username ltnikolasthem urderer.''Thepostsincluded:
a

ttltook away Jaime'sfuture'';and

b.

çflwittlt(AS)willntverplaymusicagain.''Thismessagewasfollowedby

smiling,applauding,and handgun emojis. This message also mentioned %IM S,''whose sons
(W S,''wasalso killed in the M SD shooting.

Page 7 of 12

 Case 0:19-mj-06026-LSS Document 1 Entered on FLSD Docket 01/18/2019 Page 9 of 13
'*

Januarv 9.2019 M essages

On oraboutJanuary 9,2019,between approxim ately 12:00 -2:00 a.m.(EST),JG,
LS,and otherswereéfm entioned''in additionalpostsby the tinik.taunts ''usernameand
lnstagram usem ame tfbullseyeteaseshisvictim s.''Thepostsincluded:
a.

IIW HOO!! Ikilled Jaim eand ScottBeigelhehehaha''

b.

$û1shootthrough thewindow''

Slwith my AR-15''
itldey om han''

28.

e.

ViNikolastook Scottaway from you and hisfamily''and

f.

çûhey you!1killed ScottBeigel!Hahahal''Sél-ley orphan.''s

Continuing on oraboutJanuary 9,2019, between approxim ately 8:13p.m .and

9:00 p.m .,JG and otherswerementioned in postsby Instagram username çsthe.douglas.shooter.''

Thepostsincluded(amongothers):
a.

1$1killed ScottBeigel1shothim dead''

b.

1$lenjoyedittoo''
VlW ith thepowerofmy AR-15,you a11die''

d.

:$I'm a m urderer.It'sw hat1do,fool''
l'l'm a m urderer.Hahahahal''

ç$Ikilled Scott!Hahaha!W ith thepowerofmy AR-15''and

g.

ç$1'm ahom icidaloutrage,mother*#*ersl''

Januarv 10 - 11.2019 M essaees

29.

On oraboutJanuary 10,2019,JG and otherswerem entioned in additionalposts

by the finikolas.the.m urderer ''usernam e.

5 ScottBeigelwasateacherkilled during the M SD shooting. W hen asked duringhis
interview ifhe could name som eoftheM SD shooting victim s, FLEURY fsrstnamed Scott
Beigel.
Page 8 of 12

 Case 0:19-mj-06026-LSS Document 1 Entered on FLSD Docket 01/18/2019 Page 10 of 13

On oraboutJanuary 11,2019,from approxim ately 5:58a.m.- 6:23a.
m .(EST),

JG and otherswere mentioned in postsfrom Instagram usernam eEldani.dont.give.two.fucks.''

Thesepostsincluded(amongothers):
a.

EtN ikolaskilled yourloved oneshuh?''

b.

tiN ikolaskilled ScottBeigelin cold blood.'' Thism essagewasfollowed

bythreeéçcryingwhilelaughing''emojis.
ûillehehaha! M r.Beigelisdeadl''and
d
31.

tç1tauntyou.''

Continuing on oraboutJanuary 11,2019,from approximately 6:26 a.m .- 6:29

a.m.(EST),JSandotherswerementionedinpostsfrom lnstagram usemame
iibullseye.taunts.and.teases.''Thesepostsincluded(nmongothers):
a*

tillahaha'hey orphanl''

b.

itcome atm elittleom han! lkilledyourfatherl''and
tiYoo-hoo!!Orphan! Let'splayl''

32.

Continuing on oraboutJanuary 11,2019,between approximately 5:58 a.m . and

6:23a.m.(EST),JG andotherswerementionedinadditionalpostsfrom lnstagram username
the.douglas.shooter.Theseincluded(amongothers):
a.

lçW ith the powerofm y AR-15,1take yourloved onesaway from you

PERM ANENTLY''and

b.
33.

lil-lahaha!I'm theDouglasshooter!SCREAM !!''

Asaresultofthethreatofmurder,Instagram voluntarily identified the IP address

related to usernam e tsthe.douglas.schooter''to law enforcem ent. The IP address used by this

usem am ewasthe67 IP address.
34.

O n oraboutJanum.y 4,2019,Detective M ealer ofBSO and linterview ed JG , FG ,

LS,and M S. These individualsadvised they received notificationsvia Instagram ofthe postsin
which they were m entioned described above. A11 the victim s viewed the posts and
acknowledged they caused emotionaldistress. Specitk ally,the postm ade on Deeember 25,
Page 9 of12

 Case Document 1 Entered on FLSD Docket 01/18/2019 Page 11 of 13

2018, by "teddykillspeople," which stated "I'm your abductor l'm kidnapping you fool" placed
JG, FG. LS. and MS in fear. On or about January 10, 2019, the Affiant spoke again with FG,
who indicated that both he and JG remain in fear from the kidnapping threat arid are afraid to
respond to the repeated messages.

B. The IP Addresses Associated with the Harassing Instagram Posts Traces
Back to the Santa Ana Address

35. A query of the 67 11' address revealed it was serviced by Cox Communications.
Cox Communications informed law enforcement that this address was assigned to the
subscriber account located at the Santa Ana
address, from October 8, 2017, through December 27, 2018.6 According to queries of the law
enforcement database CLEAR, the Santa Ana address is associated with FLEURY, his father,
and his brother.

36. Law enforcement also conducted a check of the Wi-Fi signals accessible from the
street outside the Santa Ana address. Four different Wi>>Fi connections appeared. Law
enforcement attempted to access all four Wi-Fi connections but discovered they were all
password--protected and inaccessible without the password Based on my training and
experience. the fact that the Santa Ana address's Wi-Fi is not public means that it is unlikely that
an individual not living in the address would have the 67 IP address.

C. Execution of the Search Warrant

37, On January 11, 2018, US. Magistrate Judge Edward lnfanle, of the Central
District of California. signed a Search Warrant for the Santa Ana address. under Case Number


38. On January 16, 2018, at approximately 6:00 am. (PST), FBI agents and other law
enforcement officers executed the Search Warrant at the Santa Ana address. Upon execution,

they found FLEURY. his father. and his brother in the home. FLEURY made spontaneous

Law enforcement requested this infon'nation prior to the posts made on December 31,
2018 and January 9-1 1, 2019. A request to Cox for information on the assignment ofthe 67 IP
address on these later dates is currently pending.

Page 10 ole

Case 0:19-mj-06026-LSS Document 1 Entered on FLSD Docket 01/18/2019 Page 12 of 13

statem ents to the effectthatthe agents were there because of Slsom e stupid shit''he had done on
the Internet.

39.

Based on these statements and subsequent statem ents during his post-M iranda

interview,1aw enforcement identifed FLEURY asthe subjectwho made the online threats.
FLEURY adm itted to creating m ultiple Instagram profiles, including using variations on

nikolastheshooter and nikolas, the.douglas.shooter, and bullseye. FLEURY described his
t'fascination''with Nikolas Cruz,other mass shooters,Ted Bundy,and otherserialkillers. He
further admitted to posting the messages in an attem pt to iûtroll'' the victim s, trying to tiget
reactions''from people and be controversial. FLEURY stated he was m otivated by gaining

popularity and notoriety afterposting the messages.FLEURY admitted to targeting shooting
victim 's fam ily m emberswho were çtactivists''and who had large who had large socialmedia
presences. FLEURY adm itted to creating multiple Instagram profles because he knew his
comments would result in the profiles being reported and removed. FLEURY did notshow
rem orse forposting the com ments butexplained he would notfollow through on the threatshe
communicated. He claimed that his m essages were notthreats,butwere %ûm ore like tatmts.''

However,when asked whetherhe could see why amessageslike '$Iam yourabductor''and $i1am
kidnapping you,fool''would feelthreatening to the messagerecipients,FLEURY responded,$1I
guessso.'' He also explained thathe established multiple Instagram accounts,anticipating that
lnstagram would shut down at least som e of those accounts based on complaints about his
m essages.
40.

FLEURY furtheradm itted to using histabletto authorthetaunting m essages.The

tabletwascollected asevidence.7
C O N C LU SIO N
Based on the foregoing facts,Irespectfully subm itthatthere isprobable cause to

believe that,on oraboutDecem ber 25,2018,FLEURY did transm itin interstate com merce a
1A search ofthistablet, and otherelectronicdevicesfound in theSantaAnaaddress,
pursuantto the search w arrant,isongoing.
Page 11 of12

 Case 0:19-mj-06026-LSS Document 1 Entered on FLSD Docket 01/18/2019 Page 13 of 13

*

cûmmunication containing a threatto kidnap a person,in violation ofTitle 18,United Sztes

Code,Section275(c), lalsosubmltthatthtrtisprohbk causttobtlievethat.betwten ûnor
abûutDeccmber22,2012,and Janual 11,2019,FLEURY did,with the intentto harassand
intimidate anothery rson,us: an interactive computerservice and electronic communication

system ofinterstatecommerceto engagein acourseofconductthatcaused.attemptedtocause,
ûr would be reasonably expected to cause substantialemotionaldistress to that person,in

viclationofTitle18,UnhedStatesCode,Section2261A(2)(B).

C= eron M cDow:1
SpecialAgent
FederalBureau oflnvestigation

Swoy At andsubscribedbefûreme
thi:/ 1 dayofJanuary,2019.

I

NA S.SNOW

UNITED STATESM AGISTM TE JUDGE

Page 1: of 12