Case Document 1 Filed 09/02/20 Page 1 of 4

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF NEW YORK

Criminal No. 243 (051(5)

UNITED STATES OF AMERICA, 

v. Indictment

Violations: 18 U.S.C. 876(c)
DENNIS J. NELSON, [Threat by Mail]
18 U.S.C. 115(a)(1)(B)
Defendant. [Impede, Intimidate, and
Interfere by Threat]

6 Counts

Counties of Washington and Oneida
Offenses:

THE JURY CHARGES:

COUNT 1
[Threat by Mail]

On or about August 1, 2018, in Washington County, in the Northern District of New York,
the defendant, DENNIS J. NELSON, did knowingly deposit in an authorized depository for mail
matter to be sent and delivered by the Postal Service, and knowingly cause to be delivered by the
Postal Service according to the direction thereon, a communication addressed to a United States
Judge that contained a threat to injure the person of the addressee and of others, for the purpose of
issuing a threat and knowing that the communication would be perceived as a threat, that is,
DENNIS J. NELSON, then an inmate incarcerated in the New York State Department of
Corrections Great Meadow Correctional Facility, deposited in the mail and caused to be delivered

by the United States Postal Service a letter that contained a threat to kill Senior United States

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District Judge Thomas J. McAvoy and others with a bomb, in violation of Title 18, United States
Code, Section 876(0).

COUNT 2
[Impede, Intimidate, and Interfere With by Threat]

On or about August 1, 2018, in Washington County, in the Northern District of New York,
the defendant, DENNIS J. NELSON, did threaten to murder Senior United States District Judge
Thomas J. McAvoy, with intent to impede, intimidate, and interfere with, and to retaliate against
Senior Judge McAvoy while he was engaged in the performance of his of?cial duties, in violation
of Title 18, United States Code, Section 

COUNT 3
[Threat by Mail]

On or about July 15, 2019, in Oneida County, in the Northern District of New York, the
defendant, DENNIS J. NELSON, did knowingly deposit in an authorized depository for mail
matter to be sent and delivered by the Postal Service, and knowingly cause to be delivered by the
Postal Service according to the direction thereon, a communication addressed to an of?cer or
employee of the United States Government engaged in the performance of his of?cial duties that
contained a threat to injure the person of the addressee and of others, for the purpose of issuing a
threat and knowing that the communication would be perceived as a threat, that is, DENNIS J.
NELSON, then an inmate incarcerated in the New York State Department of Corrections Mohawk
Correctional Facility, deposited in the mail and caused to be delivered by the United States Postal
Service a letter that contained a threat to kill United States Congressman Anthony Brindisi and
others with a bomb, in violation of Title 18, United States Code, Section 876(c).

COUNT4 
 Impede, Intimidate, and Interfere With by Threat]

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On or about July 15, 2019, in Oneida County, in the Northern District of New York, the
defendant, DENNIS J. NELSON, did threaten to murder United States Congressman Anthony
Brindisi, with intent to impede, intimidate, and interfere with Congressman Brindisi while he was
engaged in the performance of his official duties, in violation of Title 18, United States Code,
Section 

COUNT 5
[Threat by Mail]

On or about July 15, 2019, in Oneida County, in the Northern District of New York, the
defendant, DENNIS J. NELSON, did knowingly deposit in an authorized depository for mail
matter to be sent and delivered by the Postal Service, and knowingly cause to be delivered by the
Postal Service according to the direction thereon, a communication addressed to an of?cer or
employee of the United States Government engaged in the performance of his official duties that
contained a threat to injure the person of the addressee and of others, for the purpose of issuing a
threat and knowing that the communication would be perceived as a threat, that is, DENNIS J.
NELSON, then an inmate incarcerated in the New York State Department of Corrections Mohawk
Correctional Facility, deposited in the mail and caused to be delivered by the United States Postal
Service a letter that contained a threat to kill United States Senator Charles Schumer and others
with a bomb, in violation of Title 18, United States Code, Section 876(c).

COUNT 6
[Impede, Intimidate, and Interfere With by Threat]

On or about July 15, 2019, in Oneida County, in the Northern District of New York, the
defendant, DENNIS J. NELSON, did threaten to murder United States Senator Charles Schumer,

with intent to impede, intimidate, and interfere with Senator Schumer while he was engaged in the

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performance of his official duties, in violation of Title 18, United States Code, Section

1 

Dated: September 2, 2020
A TRUE BILL, REDA TED

 

 

ANTOINETTE T. BACON
Acting United States Attorney

By: @442 

AUSA Carl'o. Eurenius
Assistant United States Attorney
Bar Roll No. 511746