A0 91 (Rev. 11/11) Criminal Complaint UNITED STATES DISTRICT COURT for the Distn'ct of Maryland United States of America v. Case No. 1:20-mj-2666 TMD JAMES DALE REED i Defendam(s) CRINIINAL 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 October 4, 2020 in the county of Frederick in the District of Maryland . the defendant(s) violated: Code Section O?ense Description 18 U.S.C. Section 879 Threats Against a Major Candidate for President and Vice-President This criminal complaint is based on these facts: See af?davit. if Continued on the attached sheet. 1M Complainant' Special Agent Emily Zagone Printed name and title Swom to before me over the telephone and signed by me pursuant to Fed .Crnn. P. 4. ?m Date: Jllugl; Sighulul a City and state: Baltimore, MD Hon. Thomas M. DiGirolamo Printed name and title IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND IN THE MATTER OF A CRIMINAL COMPLAINT AGAINST JAMES DALE REED 1:20-mj-2666 TMD Case No. ____________________ AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT I, Emily Zagone, Special Agent, United States Secret Service (“USSS”), being duly sworn, depose and state as follows: 1. This Affidavit is submitted in support of a Criminal Complaint for James Dale REED. As detailed below, there is probable cause to believe that on or about October 4, 2020, REED violated 18 U.S.C. § 879, Threats to a major candidate for the office of President or Vice President. The maximum penalty for this offense is five years’ imprisonment. 2. Specifically, on or about October 4, 2020 in the District of Maryland, the defendant, James Dale REED, knowingly and willfully threatened to kill and to kidnap and to inflict bodily harm upon Joseph Biden and Kamala Harris, who are major candidates for the office of the President and Vice President of the United States, respectively, by stating, in writing, that “when we capture Grandpa Biden we will all severely beat him to the point of death as for Mrs. Harris she will be bent over and anally raped by my rifle barrel then for the grand end the [sic] both will be executed on National Television,” in violation of Section 879 of Title 18 of the United States Code. AFFIANT’S BACKGROUND 3. I am a duly appointed Special Agent with the USSS and have been employed as such since June 2017. I have completed the Criminal Investigator Training Program at the Department of Homeland Security’s Federal Law Enforcement Training Center, as well as the Special Agent’s Training Course through the USSS James J. Rowley Training Center. Prior to 1:20-mj-2666 TMD serving with the USSS, I served as a Special Agent with the National Security Agency, Associate Directorate for Security and Counterintelligence. 4. Throughout my career in law enforcement, I have become familiar with the methods and techniques associated with financial institution fraud, identity theft, and protective intelligence cases. In the course of conducting investigations, I have incorporated the use of the following investigative techniques: interviewing informants, cooperating witnesses, victims and subjects; physical surveillance and utilization of various surveillance techniques; supporting undercover operations; participating in mobile wireless tracking missions; and preparing and executing search and arrest warrants that have led to seizures of counterfeit currency, access devices, instruments used to commit financial fraud, weapons, and other items of interest to protective intelligence investigations. 5. Based on my knowledge, training, and experience in the investigation of threat cases and protective intelligence investigations, I am familiar with the ways in which those who threaten violence plan and carry out the act of making threats. My familiarity includes the various means and methods by which individuals utilize cellular telephones and social media accounts to relay their intentions to the public. I am also familiar with the ways in which those who commit these crimes are able to do so without detection. As contrasted with financial crimes, which are characterized by ongoing and repeated criminal activity, crimes against persons tend to be discrete offenses. 6. I have set forth only the facts I believe are necessary to establish probable cause for the issuance of a criminal complaint. The information contained in this Affidavit is based upon my review of reports and documents, physical surveillances, observations, interviews and investigative activity by myself and other law enforcement officers. 2 1:20-mj-2666 TMD FACTUAL BASIS FOR THE COMPLAINT 7. I was advised that Frederick City Police Department (FPD) had reported a letter threatening candidates Joseph Biden and Kamala Harris was left on the doorstep of a resident of Frederick, MD, on Sunday morning, October 4, 2020, at approximately 0426 hours. The likeness of the subject who left the letter on the doorstep was captured by a Ring door camera. The Ring device clearly captured the likeness of the male subject. The subject appeared to be a white male wearing a beanie hat, gloves, and a military-like windbreaker. The resident of the home did not know the subject depicted on the Ring video, but had several Biden/Harris signs located in the yard. A photograph of the letter and the likeness of the male subject who delivered the letter are set forth below: 3 1:20-mj-2666 TMD ?(277)111- 9'5 r?Lwc? W5 \tM?ub L. td'ru WITH Icy-r. *?ijs-agl. W4, {991.- 611 14cm; my! address-13.: 193? ?ltoh?un Farting. Wt. m; purl?"h ?warp; wt- Uri-14$ Ld?w?" Gm?p-of? h3jk-?H-nwt?' mica/E, 71?: ?aog?pa mm Dwriv nu)? [ha-?r W4 ww't?t nc+ camf?la an, fab-Md LIP A GPO-?bkra. 13:70!? H'mrnx?) 8591;;?1l3 curb Lem! ka {raw- our? (Lou/1 PM. W-t/ Iva} C-mmha 13412.: [Van-J SUPFW fact/Ia; 064019? 1w?! 1?15?? ?19 Fancy}: whey-f HM ?V?n Cepttcuwnk Cf?qu-eokd-p 0?5, {My} Pen-mug, Pua- var-? Gloom l1 +0 RM Maggi mam-c, dam farm?- 11-? brag?; a: Hm boa-ch: at) him glauh, cw? but/bk oh; 0? {97141'*3m _rn1up MW. New of Pm. ?c?or-Ea" ML - erw?ufc. Back-M we m1] mu Swear! - me? elem of Mug Roped-?95 11mg ?rcn Grand. and fil?cufsw .T leol pit?c.2141. CNN wmat Sup-Farm Mi!) Wm WW 33va inc} r; mu. [37541.4 Wows-J" WM I ya? mt} CIT. WW ltW: mm, . 1:20-mj-2666 TMD 8. Investigators worked to identify the subject depicted in the video through multiple interviews, facial recognition software, and anonymous tips to FPD. On October 9, 2020, an anonymous tip to FPD provided information that caused investigators to focus on James Dale REED, of Redwood Avenue, Frederick, MD. REED is known to the USSS for making a 5 1:20-mj-2666 TMD threatening statement against a person under USSS protection in 2014. An individual familiar with REED viewed the Ring camera likeness of the person who delivered the threatening letter and confirmed that person to be James Dale REED. 9. On October 13, 2020, REED was interviewed at his Redwood Avenue residence. REED denied leaving a threatening letter or being the individual in the video presented to him. Your affiant was present at this interview and noted that, despite his denials, Reed’s features and mannerisms strongly resembled those of the individual featured in the Ring video surveillance. 10. On October 15, 2020, investigators contacted REED at his residence and requested elimination palm prints and a more extensive handwriting sample. REED consented and complied with both requests. Investigators again asked REED if he had written the threatening letter; REED indicated that he had written the letter by nodding his head. He then explained his involvement to the agents by saying that “This will happen” (referring to individuals making threatening comments) due to the political climate. 11. REED was advised of his Miranda rights, which he voluntarily and willingly waived by signing a Frederick Police Department Miranda form. Investigators audio-recorded this waiver and all subsequent questioning. REED then admitted to writing the letter on Saturday evening, October 3, 2020, because he was upset at the political situation. REED then drove to Kline Blvd in the early morning hours of October 4, 2020, and took the letter to the first house he saw with multiple democratic political signs. REED stated that he observed the residence located on Kline Boulevard, Frederick, MD, drove past the residence, exited his vehicle, and delivered the letter to the mailbox. REED stated repeatedly that he did not know the residents of the house, nor had he surveilled it previously. REED stated that upon dropping the letter in the mailbox, he left and returned to his residence. 6 1:20-mj-2666 TMD 12. Based on my training and experience, I know that the plain meaning as well as context of the threats of violence made in the letter constitutes a violation of 18 U.S.C. § 879. As a result of the above described information, there is probable cause to believe that James Dale REED violated 18 U.S.C. § 879, Threats to a major candidate for the office of President or Vice President. 13. WHEREFORE, I respectfully request that the Court authorize the attached Criminal Complaint. I declare under the penalty of perjury that the foregoing is true and correct to the best of my knowledge. _______________________________ Special Agent Emily Zagone U.S. Secret Service y telephone p Affidavit submitted by e-mail and attested to me as true and accurate by consistent with Fed. R. Crim. P. 4.1 and 41(d)(3) this day of October, 2020. _________ _______________________________ _________________________ __ Hon. Th H Thomas M M. DiGi DiGirolamo l United States Magistrate Judge 7