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Mitchell Kusick Criminal Complaint

Mitchell Kusick Criminal Complaint

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Published by Michael_Lee_Roberts

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Published by: Michael_Lee_Roberts on Nov 14, 2012
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11/14/2012

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U
 NITED
S
TATES
D
ISTRICT
C
OURT
for theDistrict of ColoradoUnited States of Americav.MITCHELL KENNETH KUSICK  
 Defendant(s)
))))))Case No.
CRIMINAL COMPLAINT
I, the undersigned complainant, being duly sworn, state the following is true and correct to the best of myknowledge and belief:
On or about October 29, 2012, in the State and District of Colorado, MITCHELL KENNETH KUSICK,defendant herein, did knowingly and willfully make a threat to take the life of and inflict bodily harm upon thePresident of the United States.All in violation of Title 18, United States Code, Section 871.I further state that I am an agentwith the United States Secret Serviceand that this complaint is based onthe following facts:See Affidavit attached hereto and herein incorporated by reference, which is continued on the attached sheetand made a part hereof.
 s/Melissa Blake
Complainant’s signature
Melissa Blake, Special Agent
 Printed name and title
Sworn to before me and signed in my presence.Date:
 Judge’s signature
City and state:
 Printed name and title
 
rne name an e
 
Michael J. WatanabeU.S. Magistrate JudgeDenver, ColoradoNovember 9, 2012
Case 1:12-mj-01148-MJW Document 1 Filed 11/09/12 USDC Colorado Page 1 of 9
12-mj-01148-MJW
 
 
AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT
I, Melissa Blake,Special Agent with the United States Secret Service, Department of HomelandSecurity, being duly sworn, deposes and states under penalty of perjury that the following is trueto the best of my information, knowledge and belief.I, Melissa Blake, being duly sworn, do hereby depose and state as follows:1.I am a Special Agent with the U.S. Secret Service (“USSS”), and have been so employedsince August 30, 1999. I am currently assigned to the Denver Field Office. Prior to beingappointed a Special Agent, I attended school at Virginia Polytechnic Institute and StateUniversity, and graduated with a Bachelors Degree in Political Science and Spanish. I am also agraduate of the Criminal Investigator Training Program at the Federal Law EnforcementTraining Center in Glynn County, Georgia and the Special Agent Training Program at the JamesJ. Rowley Training Center in Laurel, Maryland. In my official capacity, under Title 18, UnitedStates Code, Section 3056, I am charged with investigating violations of the United States Coderelating to threats against the President and successors to the Presidency under Title 18, UnitedStates Code, Section 871.2.I am currently involved in an active investigation (described in this affidavit), relating toa threat against the President of the United States, a violation of Title 18, United States Code,Section 871.3.The opinions set forth in this affidavit are based upon my experience and education aswell as consultation with other experienced investigators and agents and other sources of information relative to the investigation of threats against the President of the United States.
Case 1:12-mj-01148-MJW Document 1 Filed 11/09/12 USDC Colorado Page 2 of 9
12-mj-01148-MJW
 
 
4.This affidavit does not detail all of the facts known to me or other law enforcementofficials regarding this matter, but instead relates only to those facts which I believe are necessary to establish the requisite probable cause in support of an application for anarrest warrant for Mitchell Kenneth KUSICK, Date of Birth: September 1, 1992; Address: 11290Fenton Street, Westminster, CO, whom I believe has violated Title 18, United States Code,Section 871.
Background of Investigation
5.On October 30, 2012, the USSS Denver Field Office received a police report from theWestminster, Colorado Police Department (WPD) regarding subject Mitchell Kenneth KUSICK.The report stated that on October 29, 2012, the Broomfield Police Department (BPD) notified theWPD that Kusick made credible threats and took steps toward shooting children at StandleyLake High School. Additionally, KUSICK made statements about a desire to kill people onHalloween and that he had been tracking President Obama’s schedule so he can assassinate thePresident. The police report indicated Kusick wanted to commit the shootings so he could godown in “infamy.”6.On October 29, 2012, KUSICK called his therapist, Corey Candeleria, and left a voicemessage in which he stated that he was in crisis and need to speak with Candeleria. Candeleriatelephoned KUSICK and they agreed to meet that afternoon. KUSICK arrived later that day,along with his aunt and uncle. Candeleria spoke with KUSICK during a session. KUSICK’saunt and uncle remained in the waiting room. KUSICK told Candeleria that, the day before, hegot into an argument with his parents because he had taken a large amount of money out of hissavings account. As he was arguing with his parents, KUSICK informed them that he was okaywith homicide. KUSICK’s father ordered KUSICK out of the house. KUSICK and his mother 
Case 1:12-mj-01148-MJW Document 1 Filed 11/09/12 USDC Colorado Page 3 of 9

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