Case 6:19-mj-04052-MWP Document 1 Filed 04/04/19 Page 1 of 5 AO 91 (Rev. 02109) Criminal Complaint tlmf,ted Staues Dfls for the 'Westerr District of New Y United States of America case No. re-Mr- v. 4orx PATRICK W. CARLINEO, JR., Defendant 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 March 29,2019, in the County of Steuben, in the Western District of New York, the defendant violated Title 1& United States Code, Section 115(aX1(B), said offenses described as follows: the defendant, did threaten to assault and murder a United States official with intent to impede, intimidate and interfere with such United States official while engaged in the performance of official duties and with intent to retaliate against such United States official on account of the performance of official duties, in that he threatened to kill United States Congresswoman Ilhan Omar while she was engaged in the performance of her official duties, in violation of 18 u.S.C. $ 115(aX1)(B). This Criminal Complaint is based on these facts: A Continued on the attachedsheet. ./' .,/ --/-a / 3 SEN, JR. SPECIAL AGENT FEDERAL BUREAU OF INVESTIGATION Printed name and title Sworn to before me and signed in my presence. Date:Aoril 4 .2olg m*i^61^ar'-Judge's signature City and State: Rochester. New York HONORABLE MARIAN W. PAYSON I.INITED STATES MAGISTRATE ruDGE Printed name and title Case 6:19-mj-04052-MWP Document 1 Filed 04/04/19 Page 2 of 5 Arrmavrr IN Supponr Or Cnnm.qan Cowr,amr State of New York ) County of Monroe ) City of Rochester ) ss: / 0-rn9*4ttl- KENNETH A. JENSEN, JR., being duly sworn, deposes and says: IxtnopucrroN 1. I am a Special Agent (SA) of the Federal Bureau of Investigation (FBt), United States Deparffnent of Justice, Buffalo, New York. As a Special Agent of the FBI, I am an investigative or law enforcement officer perform of the United States, empowered to investigations and make arrests related to violations of federal law. I have been employed as a Special Agent with the FBI since March of 2002 and am currently assigned to the Coming, New York, Resident Agenry. 2. The statements contained in this affidavit are based upon my personal knowledge and observations, information provided to me by other law enforcement officers, information provided to me by witnesses with personal knowledge of events, my review of tecords, and my investigation and experience and training as a Special Agent with the FBI. Because this affidavit is being submitted for the limited purpose of securing a criminal complaint, I have not included each and every fact known to me conceming this investigation. 3. This affidavit is made in support of a criminal complaint charging PATRICK W. CARLINEO, JR., with and threatening $ 11s(a)(1)(B). a United States official, in violation of 18 U.S.C. Case 6:19-mj-04052-MWP Document 1 Filed 04/04/19 Page 3 of 5 Pnonlnrp Causs 4. On March 21, 2019,at approximately l2:20p.ffi., a telephone call was received by a staffmember for United States Congresswoman Ilhan Omar, a representative from the 5tr Congressional District in Minnesota, at Congresswoman Omar's offices in Washington, D.C. During the telephone call, an individual who eventually identified himself as PAT CARLINEO stated to the staffmember, "Do you work for the Muslim Brotherhood? Why are you working for her, she's a fucking terrorist. I'11 put a bullet in her fucking skull." CARLINEO sounded anry, but spelled his name and provided contact information. The call was placed from telephone number (607) 684-5330, which is a cellular telephone serviced by AT&T. Telephone records from AT&T show that this telephone number is listed to Lisa M. Caslin, 6480 CountyRoute 21, Addison, NewYork. Historicalprecisionlocationinformation from AT&T shows that the telephone was physically located in the Western District of New York at the time CARLINEO placed the above-described call. 5. After receiving the threatening telephone calT from CARLINEO, Congresswoman Omar's staffreferred the tfueat to the United States Capitol Police, Threat Assessment Section, who began an investigation in coordination with the FBI. 6. OnMarch 29,2019,I interviewed CARLINEO athis residence at6480 County Route 21, Addison, New York. CARLINEO stated ttrat he knew why the FBI wanted to speak to him. Initially, he stated that it was because he said "if our forefathers were still alive, they'd put a bullet in her head." He further stated that he was referringto atelephone call that he made to Congresswoman Omar's office using the cellular telephone number (607) 6845330. CARLINEO stated that he was a patriot, that he loves the President, and that he hates Case 6:19-mj-04052-MWP Document 1 Filed 04/04/19 Page 4 of 5 rudicalMuslims in our govemment. CARLINEO was shown an e-mail which contained the text of the quote, "Do you work for the Muslim Brotherhood? Why are you working for her, she's a fucking terrorist. I'11put a bullet in her fucking skull." CARLINEO was asked to read the quote aloud, which he did. He then stated that the quote is not what he said, but repeated his original version of events. CARLINEO stated that Congresswoman Omar supported Hamas and the Muslim Brotherhood, and that her election to Congress was illegitimate. 7. FBI Special Agent Christina Peklak-Scott, who was also present for the interview, then admonished CARLINEO that it was a separate crime to lie to an FBI agent, and asked what investigators would hear when we listened to the recording of his telephone conversation with Congresswoman Omar's staff member. CARLINEO responded that he would be honest, and that he was arrry, and could not remember exactly what he said. CARLINEO went on to he was not sure. say that he may have said something like the quote that he read,but CARLINEO was asked if there were any weapons in the residence. He stated that there are a shotgun and a .22 calber firearm in the house. He initially stated that the weapons belonged to his girlfriend, but later in the interview stated that the guns belonged to him. 8. A Member of Congress is a United States official within the meaning of 18 U.S.C. $ 1ls(cXa). Coucrusrolu 9. Based on the foregoing, there is probable cause to believe that PATRICK W. CARLINEO, JR., did threaten to assault andmurder a United States official with intent to impede, intimidate and interfere with such United States official while engaged in the Case 6:19-mj-04052-MWP Document 1 Filed 04/04/19 Page 5 of 5 performance of official duties and with intent to retaliate against such United States official on account of the performance of official duties, in that he threatened to kill United States Congresswoman Ilhan Omar while she was engagedin the performance ofher official duties, in violation of 18 U.S.C. g 115(aX1XB). Dated: Rochester, New York April , zOtS 'f Subscribed and sworn to before me day of Aprtl,2}lg. *rir lL F...--) (Y*;*r A (c,4, rr^HON. MARIAN W. PAYSON United States Magisffate Judge Western District of New York 4