7.11.1.1 FILE SEP 2 2020 Clerk. US. District 2; Case: Assigned to: Judge Robin M. Meriweather Assign Date: Description: COMPLAINT WI ARREST WARRANT IN SUPPORT OF CRIMINAL COM Bankruptcv Court; 1. Jonathan Preston. being duly sworn. state as follows: INTRODUCTION AND AGE: BACKGROUND I am a Special Agent Bomb Technician with the Federal Bureau assigned to the Washington. D.C.. Field Office. [joined the FBI in 2009 as a Biologist arid in 2012 as a Special Agent. 1 am currently a Special Agent Bomb "Technician on a squad that responds to attd investigates weapons of Mass destruction and explosive precursoribombing matters. I hold a bachelor's degree in forensic biology. a Public Safety Bomb Technician Certi?cation and I have obtained extensive academic and professional training and experience on WMD and explosive matters. 1 ant an investigative or law enforcement ot'lieerofthe United States within the meaning ot'Titlc United States lCode. Section 2510(7). I make this affidavit in support of criminal complaint charging defendant Pascale Cecile Veronique l-?errier with Threatening the President of the United States. in violation ofTitlc 13. United States Code. Section 371. Speci?cally, as set forth below. there is probable cause to believe that the defendant knowingly and willfully threatened to take the life of. and to in tliet bodily harm upon. the President of the United States in violation of'l?itle 18. United States Code. Section 871. The facts set forth in this af?davit come frotn my personal involvement with this investigation. interviews with witnesses. review ol'documents. and forensic itWestigatiott and analysis. In submitting this af?davit. I have not included each and every fact known to me about this investigation. Rather. I have included only those facts i believe sufficient to establish probable cause. PROBABLE CAUSE 6. On 18 September 2020, at approximately 0900, United States Secret Service noti?ed FBI Washington Field Of?ce of a letter addressed to ?Donald Trump, The White House, 1600 Avenue NW, Washington DC 20500 This letter was post-marked from Canada and traveled interstate via US. postal service and arrived at the White House Mail Sorting Facility in Washington, DC. Upon being reviewed by personnel at the facility on approximately September 18, 2020, the FBI Washington Field of?ce was contacted and responded to the facility. Review of the letter revealed it contained a white, powdery material and stated the following: a. found a new name for you: ?The Ugly Tyrant Clown? I hope you like it. You ruin USA and lead them to disaster. I have US cousins, then I don?t want the next 4 years with you as president. Give up and remove your application for this election. So I made a ?Special Gift? for you to make a decision. This gift is in this letter. if it doesn?t work, I?ll ?nd better recipe for another poison, or I might use my gun when I?ll be able to come. Enjoy! Based upon my training and experience, I know Ricin to be an extremely toxic plant protein derived from seeds of the castor bean plant (Ricinus Communus). Ricin causes toxicity by inhibiting the formation of proteins in the exposed individual. The material found in the letter was ?eld tested by personnel and tested as presumptive positive for Ricin. This ?eld test presumptive positive result was con?rmed via extensive laboratory testing by the National Bioforensic Analysis Center in Frederick. Maryland, which found that the substance tested positive for Ricin toxin. 7. While submitting the letter for forensic examination, Washington Field Of?ce was informed of the existence of six additional letters that appeared similar from other FBI ?eld of?ces in Texas. The letters from the other FBI ?eld of?ces were received on September 15-16, 2020, and also had cancellation stamps indicating mailing from Canada, contained a powdery substance, and were addressed to individuals working at penitentiaries and detention centers in Texas. The letters contained similar language to the letter sent to the President and were addressed to individuals af?liated with facilities at which the defendant had been housed while incarcerated in Texas in 20l9. Each of the letters contained the statement referencing ?if it doesn?t work I will ?nd a better recipe? and all contained similar material to the material found in the letter received at the White House Mail Sorting Facility in Washington, DC. Subsequent investigation of individuals with Canadian connections recently arrested and incarcerated in the FBI San Antonio area of responsibility revealed an individual by the name of Pascale Fem'er who had been arrested by Mission Police Department (Mission, TX) on March 13, 2019, for weapons possession and was transferred into Immigration and Customs Enforcement (ICE) custody. A comparison of the letters received in San Antonio/I-louston and Washington, DC. showed multiple similarities. Further investigation of the letters revealed enough similarities between the letters to conclude the Texas and Washington DC letters were sent by the same individual. Similarities included a signature block of REBEL and matching language in each letter similar to ?special gift for you.? and ?if it doesn?t work I will ?nd a better recipe for another poison or I might use my gun when I?ll be able to come" in some of the San Antonio letters and the letter in Washington, DC Forensic examinations conducted at the National Bioforensic Analysis Center (NBFAC) of all letters received in Texas and Washington, DC revealed latent ?ngerprints on four (4) of the letters recovered in San Antonio. Manual examinations of the recovered ?ngerprints revealed a match to fingerprints in FBI databases to the defendant. Investigation of the defendant?s social media platforms revealed FaceBook and Twitter postings on or about September 9, 2020, which referenced ?#killTrump? and discussed wording such as ?Ugly Clown Tyrant? (which is nearly the same wording used in the letter sent to the President). investigations of these postings and 2702d returns from Twitter and Facebook revealed the registration email address as Google email address 10. On September 20, 2020, the defendant attempted to enter the'United States at the Peace Bridge border crossing in Buffalo, New York, from Canada, and was detained by Customs and Border Patrol Of?cers (CBP). The defendant made statements to CBP Of?cers referencing ?being wanted by the FBI for the ricin letters,? and was found to be in possession of a7 loaded ?rearm in her waistband, as well as a knife. Based upon my knewtedge. training and experience. and the facts set forth in this af?davit. I respectfully submit there is prnhahie cause 10 Iaetieve that the defendant cunuuitted ?l?hreata A the President, in violatiuu United States Code, Seetimt 871. t: Respectfully submitted, WV/?mm Jonathan V, Preston Special Agent Bomb Technician Federal Bureau of Int-'estigalieu Sultaeribed and sworn pursuant to Fed. R. (Trim. P. 4.1 on September 20. 2020 2020.09.20 20:48:30 . -04'00' The I-lunurable Robin M. Meriweather United States Magistrate Judge