Case Document 1' Filed 02/14/19 Page 1 of 1 A0 91 (Rev. 11/11) Criminal Complaint AUSA Wlndom?2019R00010 UNITED STATES DISTRICT COURT for the District of Maryland United States of America V. as- nag; i Christopher Paul Hasson FEB i 4 2019 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 10/14/2016 - 2/5/2019 in the county of Montgomery in the District of Maryland the defendant(s) violated: Code Section Offense Description 18 USS 922(g)(3) possession of ?rearm and ammunition by unlawful user or addict of any A 195 controlled substance 21 U.S.C. 844 simple possession of Tramadol, a Schedule lV controlled substance This criminal complaint is based on these facts: See the attached Af?davit of Special Agent Alexandria M. Thoman dated February 14, 2019. Continued on the attached sheet. ii I W, Complainant ?s signature Alexandria M. Thoman, SpeciWnt, Printed name a tile Sworn to before me and signed in my presence. . 9? Date: lt/ ?6 2/t8/A City and state: Greenbelt, MD Gina L. Simms, U.S. Magistrate Judge Printed name and title Judge ?5 signature Case Document 1-1 Filed 02/14/19 Page 1 of wm' it" TPW: USAO 2019R00010 IN THE UNITED STATES DISTRICT ?36182 . FOR THE DISTRICT OF MARYL W19 we): 3' UNITED STATES OF AMERICA 2: c. v. CASE No. 615-. 53 1: CHRISTOPHER PAUL HASSON, FILED UNDER SEAL I Defendant AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT AND ARREST WARRANT Your af?ant, Alexandria Marie Thoman, I Special Agent with the Federal Bureau of Investigation, being duly sworn, deposes and states as follows: and 1. I am a Special Agent with the Federal Bureau of Investigation AS such I am a ?federal law enforcement officer? within the meaning of Federal Rule of Criminal Procedure that iS, a government agent engaged in enforcing the criminal laws. I have been a Special Agent with the FBI for approximately two years, prior to which I spent approximately four years in the Bureau of Counterterrorism at the US Department of State. During my tenure with the FBI and the State Department, I have investigated and participated in the investigations of numerous international and domestic terrorism violations and, among other things, have conducted or participated in surveillances, debrie?ngs of informants, reviews of taped conversations and records, and the executions of search and tracking warrants. 2. I submit this Af?davit in support of a criminal complaint and arrest warrant. Based on the facts in this af?davit, I respectfully submit that there is probable cause to believe that CHRISTOPHER PAUL HASSON has committed Violations of 18 U.S.C. Case Document 1-1 Filed 02/14/19 Page 2 of 9 922(g)(3) (possession of ?rearm and ammunition by unlawful user or addict of any controlled substance) and 21 U.S.C. 844 (simple possession of Tramadol, a Schedule IV controlled substance) 3. This Af?davit is based upon my participation in the investigation, my examination of reports and records, and my conversations with other law enforcement agents and other individuals. Because this Af?davit is being submitted for the limited purpose of obtaining a criminal complaint and arrest warrant, it does not include all the facts that I have learned during the course of this investigation. Where the contents of documents and the actions, statements, and conversations of others are reported herein, they are reported in substance and in part, except where otherwise indicated. In making this application, I am relying only on the facts stated herein. 4. Information in this Af?davit resulting from surveillance does not always set forth my personal observations, but rather at times re?ects information from video surveillance, as well as information provided to me by other law enforcement agents who observed the events described . and to whom I have spoken or whose reports I have read. Information Regarding the Target Email Facilities 5. Records provided by show that HASSON has been the subscriber for TARGET EMAIL-1 since August 4, 2008. Also, HASSON listed TARGET EMAIL-1 as his ?home e-mail address? on an federal government form that HASSON completed on or about February 5, 2016. 6. Records provided by Google show that HASSON has been the subscriber for TARGET EMAIL-2 since February 13, 2016. 7. TARGET is an email account used by narcotics supplier. 8. As part of this investigation, law enforcement agents have obtained federal search Case Document 1-1 Filed 02/14/19 Page 3 of 9 warrants for TARGET TARGET. EMAIL-2, and TARGET EMAIL-3. Certain information from those warrants is included in this af?davit. Facts Establishing Probable Cause 9. HASSON is a Lieutenant in the United States Coast Guard, and currently assigned to the United States Coast GuardHeadquarters, Washington, DC 10. HASSON currently lives at a residence in Silver Spring, Maryland. Based on a review of information contained in Coast Guard email account, HASSON began his lease at his Silver Spring residence on June 1, 2016. Possession of Firearms 11. As described below, HASSON has possessed ?rearms since at least late 2017. 12. According to records obtained from the holder of a Federal Firearms License 1 HASSON purchased a Spring?eld 1911 45ACP pistol for $899.99 from a business in Cedar Bluff, Virginia, on October 1, 2017. In emails obtained from a search of TARGET dated March 25, 2018, HASSON admits that he owns a Spring?eld 1911, stating: have 3 Spring?eld range of?cer elite compact 1911 45 cal with 4 mags, holster etc. It was 1k new 6 months old.? Attached to the email is a photograph with a ?rearm and four magazines. In the emails, HASSON is attempting to trade the ?rearm for what appear to be two other ?rearms. 13. In addition, in the records obtained for TARGET EMAIL-2, agents identi?ed photos uploaded to TARGET on or about the following dates and which show the following: a handgun, taken on or about November 13, 2017, and uploaded on or about December 1, 2017; two long guns resting on a couch, taken on or about November 29, 2017, and uploaded on or about December 1 1, 2017; a handgun and four magazines, taken on or about March 16, 2018 (which appears to be the same photo as the one referenced above from Case Document 1-1 Filed 02/14/19 Page 4 of 9 TARGET and a photograph of driver?s license, taken on or about May 17, 2018. The carpet in the photos with the handgun and four magazines appears to be the same type of carpet from known pictures of the interior of apartment in Silver Spring, Maryland. And the wallboard in the photoof the long guns also appears to be the same type of wallboard from known pictures of the interior of apartment in Silver Spring, Maryland. Furthermore, according to Gmail records, each photo was uploaded from Internet Protocol address 96.255.198.78. Records obtained from Verizon show that this IP address, from at least July 24, 2017, through May 20, 2018 (covering more than the entire timeframe during which the photos were uploaded) was assigned to a Verizon account located at the address of residence in Silver Spring, Maryland. The Verizon account is in the name of an individual whom I know rents the property to HASSON, based on rental checks 1 have seen, as well as emails in which the individual seeks joint utility payments from HASSON. 14. The fact that HASSON owns at least one long gun is corroborated by an admission HASSON made in certain emails obtained from TARGET For example, in an email dated February 11, 2018, HASSON states: have a b14 in 308 great gun. I am looking at getting ridge in 7mm will rem 700 long action stocks with the ridge in 7mm? Thanks.? Based on my training and experience, and knowledge of this investigation, I know that a .308 ri?e is a common type of ri?e. As well, on February 15, 2018, based on records obtained from a business in Florida, HASSON purchased seven boxes of .308 ammunition for $128.11. The ammunition was shipped by FedEx to residence in Silver Spring, Maryland. 15. HASSON also appears to have possessed a ?rearm prior to the October 1, 2017 purchase identi?ed above and through at least late 2018. According to an email obtained from TARGET on May 29, 2017, HASSON signed up for the June 24, 2017, AAFG IDPA Case Document ?1-1 Filed 02/14/19 Page 5 of 9 Action Pistol Safety and Observation Class. Based on an open source search, I believe that AAFG is Anne Arundel Fish and Game Association, which identi?es itself as Shooting Sports Club.? According to ?nancial records obtained by subpoena, HASSON made purchases at in Fairfax, Virginia, on December 27, 2017, and August 20, 2018. Based on my training and experience, and my knowledge of this investigation, I believe that is a reference to the shooting range at the National Ri?e Association headquarters in Virginia. Tramadol Purchases 16. Since at least October 2016, HASSON has purchased Tramadol from an individual likely located in Mexico, though the ?nal shipments appear to be sent from locations in California to addresses designated by HASSON (all but one of which was his home addresses in Maryland and North Carolina). Using TARGET as well as a Proton Mail address,I HASSON placed orders by sending emails to his supplier at TARGET EMAIL-3, speci?cally requesting that quantities of Tramadol (a Schedule IV controlled substance) be shipped for overnight delivery. Certain emails from TARGET EMAIL-3 (including one on March 27,2018) explicitly referenced the offering for sale of Tramadol (?Tramadol 100mg 100 tabs $150 Citra Brand?), as well as many other controlled narcotics, including Xanax, Suboxone, Oxycodone, Vicodin, Percoset, Dilaudid, Adderall, Morphine, and Ritalin. 17. The chart below summarizes records from prior email search warrants for TARGET EMAIL-1 and TARGET and information obtained by subpoenas to UPS, FedEx, MOneyGram, and Western Union. Though HASSON placed the orders by email to the user of TARGET EMAIL-3, the user of that email address directed HASSON to send payment to a different receiver for each shipment. Indeed, according to the user of TARGET EMAIL-3, the 1 I know that Proton Mail is a Swiss?based email provider that advertises itself as ?the world?s largest secure email service.? Case Document 1-1 Filed 02/14/19 Page 6 of 9 receiver changes each day. Moreover, when the name is known, the perSon sending the narcotics to HASSON used a different name than the money recipients. Based on my training and experience, and my knowledge of this investigation, I believe this is evidence that the purchases are illegal, as there would be no legitimate reason to pay a lawful vendor by sending payments out of the country, by a money remitting service, to a different individual each day, and then have the Schedule IV narcotics sent by overnight delivery using the name of still another individual. [late UTE-127 I I Payment 'Hecipient Delivery Order Payment 7 Blamed Method Locauon HorneyGram 10l14l2016 100 Tramadol 3215 #84587358 Mexico UPS Shummy Tiiuana, . . 12l2?ll2016 100 Trmadol 8185 {@367 481822 II 0 UPS 1:47616080141330466 HASSON North Carolina Residence 271372017 monamdol 4215 Iggmg.? ups 0.734070133354532 77053077 nonl- Carolina Residence 200 Trmdol 3365 HoneyGrarn Tijuana. UPS 12.221137012007500? 8550" . North Sarah: Residence Tracking Number Recipient Flucupient Address: 1:17 618080207421422 North Carolina Residence 300 Tramadol 334355173 mum 1:7437430130170300 Homygarn Tliuana, 771372017 300 Tramadol 3520 344302430 "we? 771433077 Maryland Residence HmeyGrarn Tiium, $13291? 300 Tran-ado! 3520 080310911 Mexico HASSON Maryland Residence 1171472017 300 Tramadol 4530 ?Wm" FedEx 700474334474 77055077 Maryland Residence 1T4383777 lie-loo HoneyGreln 'l'liuana, #47023758 Henioo MoneyGrarn Tiiuana. 3l25l2018 300 Tramadol $530 '33 ?7701 Mexico HoneyGrarn Till-llnl. 57""2018 300 Tramadol #530 I34287813 "Elba UPS ?26071337331301 HASSON Maryland Residence mull-Pram Tijuana. ?2312018 300 Tramadol $520 UPS 1237140821305430213 HASSON Maryland Residence UPS 1:61007451337433272 HASSON Maryland Residence 072072010 300 Tramadol 4530 431273053 MW 0735 12.012007553507702 HASSON Maryland Raider-co 071472010 300 Trarnadol 3520 03.30% Lam: FedEn 702333404044 777153077 Maryland Residence 107072010 300 Tremedol $520 Joell-329:; ?71:01:: FedErr 703106750403 7 777155077 Moss Point, pussissippi. Hotel 1173072010 300 Tramadol 4520 $133336; L212: FedEx 704150105470 77033077 Maryland Residence 17072013 300 Tramadol 4520 .333331 1:22: FedEx 704002770407 77773300 Maryland Residence 27572013 300 human: 4520 mm" FedEx 705340724130 7703an Maryland Residence '33-265-8081 Mexico 18. Another indication that the user of TARGET is illegally selling narcotics (and that, in turn, HASSON is illegally purchasing narcotics) is a ?disclaimer? sometimes included in emails from TARGET EMAIL-3. -In the disclaimer, the user of TARGET EMAIL-3 states, among other things: ?*We are not responsible for lost,1ate,and/or damaged packages*. . . . Safety is number one. We want to continue to service you which is why we enforce security measures. We cannot offer refunds at this time due to the nature of our business. We cannot accept orders under 400$.? Case Document 1-1 Filed 02/14/19 Page 7 of 9 19. Other evidence suggests that HASSON is a user, rather than a distributor, of the Tramadol he purchases from the user of TARGET According to Navy Federal Credit Union records, HASSON made two purchases from a $142.76 purchase on July 24, 2018, and a $97.40 purchase on August 2, 2018. According to emails obtained from TARGET EMAIL-1, the July 24, 2018, purchase was for Urine,? ?Golden Flask Urine,? and ?The Clean Kit,? and the August 2, 2018, purchase was for ?Golden Flask Urine? and ?The Clean Kit.? A search of the Alternative Lifestyle website shows that a Golden Flask is a ?ask ?lled with four ounces of urine, as well as a heating pad, presumably to bring the urine up to body temperature. On the Alternative Lifestyle website, The Clean Kit is described as follows: ?The Clean Kit is the ?rst empty re?llable kit from ALS. This kit comes with everything you need to discreetly [sic] hide any type of ?uids. It comes with an empty vinyl medical grade bag attached to a cotton elastic belt. It has an easy to read temperature strip, a re?ll port and a hose with two clips attached. You will also receive a medical grade syringe, 2 organic heat pads and a set of instructions. You can choose to put any type of ?uid in the bag, just be sure to clean it out after every use.? 20. In my training and experience, I know that users of illegal narCotics sometimes attempt to ?beat? urinalysis tests by using urine. Based on the above information, it appears that a user of illegal narcotics could use The Clean Kit in tandem with the Golden Flask and urine to attempt to avoid a positive urinalysis test. I also know, from information received from the Coast Guard, that as a result of his position, HASSON is subject to random- urinalysis tests. For example, HASSON had a urinalysis test in January 2018, which returned negative for the presence of the types of narcotics for which the test searched. Case Document 1-1 Filed 02/14/19 Page 8 of 9 21. Further evidence that HASSON is a user of the Tramadol is that, in October 2018, HASSON asked the user of TARGET to ship 300 Tramadol to a hotel in Mississippi, where HASSON was working at the time. According to emails obtained from TARGET- as well as USAA Federal Savings Bank records, HASSON stayed for approximately one month from September 17, 2017, through October 27, 2017, at the particular hotel in Moss Point, Mississippi, to which the Tramadol was shipped. 22. On February 12, 2019, pursuant to a search warrant signed by a military judge, law enforcement agents searched desk at work in Washington, DC. During the search, agents found a bottle labeled ?Fish lox in which agents observed dOZens of small pink pills. Pursuant to the warrant, agents seized two of the pink pills, which then were submitted to laboratory analysis. According to the lab results, the pink pills returned positive as Tramadol. In addition, during the search of desk, agents observed what appears to be some of the material mentioned above that HASSON purchased from Alternative Lifestyles. 23. On February 13, 2019, using video surveillance, law enforcement agents observed HASSON remove the ?Fish Flox? bottle from his desk drawer, from which he removed several pills that he then cut with a knife. HASSON then orally ingested one of the cut pills. Case Document 1-1 Filed 02/14/19 Page 9 of 9 Conclusion 24. Based on the foregoing, I respectfully submit that HASSON has committed the TARGET VIOLATIONS and therefore request the issuance of a criminal complaint and arrest Alexandria M. Thoman Special Agent Federal Bureau of Investigation warrant. Sworn to before me this/j: day of Febru A Honorable Gina L. Simms United States Magistrate Judge District of Maryland