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LAX threats - Onuoha criminal complaint

LAX threats - Onuoha criminal complaint

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Published by Sam Gnerre

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Published by: Sam Gnerre on Sep 11, 2013
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07/13/2014

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AO 91Rev. 11/82
CRIMINAL COMPLAINT
UNITED STATES DISTRICT COURTCENTRAL DISTRICT OF CALIFORNIAUNITED STATES OF AMERICAv.
DOCKET NO.
 NAA ALPHA ONUOHA
MAGISTRATE'S CASE NO.
Complaint for violation of Title 18, United States Code, Sections 1038(a) and 844(e).
NAME OF MAGISTRATE JUDGE
PATRICK J. WALSHUNITED STATESMAGISTRATE JUDGE
LOCATION
Los Angeles, CA
DATE OF OFFENSE
September 10, 2013
PLACE OF OFFENSE
Los Angeles, California
ADDRESS OF ACCUSED (IF KNOWN)
773 S. Hindry Ave., 709A, Los Angeles, CA (lastknown)
COMPLAINANT'S STATEMENT OF FACTS CONSTITUTING THE OFFENSE OR VIOLATION
:On or about September 10, 2013, in Los Angeles County, within the Central District of California, defendant NAAALPHA ONUOHA engaged in conduct with intent to convey false or misleading information under circumstanceswhere such information may reasonably be believed and where such information indicates that an activity has taken,is taken, or will take place that would constitute a violation of Title 18, United States Code, Section 37 (Violence atInternational Airports), namely, that a person using a device, substance, or weapon, would destroy or seriouslydamage the facilities of LAX, an airport serving international civil aviation, or disrupt the services of the airport, ina manner that would endanger or likely endanger safety at the airport.On or about September 10, 2013, in Los Angeles County, within the Central District of California, defendant NAAALPHA ONUOHA, acting in or affecting interstate commerce, used the telephone and other instruments of interstate and foreign commerce to willfully make a threat or to maliciously convey false information knowing thesame to be false, concerning an attempt or alleged attempt being made, or to be made, to kill, injure, or intimidatean individual or unlawfully to damage or destroy a building or other real or personal property by means of fire or anexplosive.BASIS OF COMPLAINANT'S CHARGE AGAINST THE ACCUSED: 
(See attached affidavit which is incorporated as part of this Complaint)MATERIAL WITNESSES IN RELATION TO THIS CHARGE
: N/A 
Being duly sworn, I declare that theforegoing is true and correct to thebest of my knowledge.SIGNATURE OF COMPLAINANT
DAVID GATES
OFFICIAL TITLE
Supervisory Special AgentSworn to before me and subscribed in my presence,
SIGNATURE OF MAGISTRATE JUDGE(1) DATE
September 11, 20131)
See Federal Rules of Criminal Procedure rules 3 and 54.
AUSA Melissa Mills
REC: DETENTION
 
A F F I D A V I TI, David Gates, being duly sworn, hereby depose and statethe following:1.I am a Special Agent of the Federal Bureau ofInvestigation (FBI), and I have been so employed for over nineyears. Since August 2004, I have been assigned to the LosAngeles International Airport Office of the FBI, where Iinvestigate violations of Federal law which occur within theairport environment and on board aircraft.2.This affidavit is in support of a complaint chargingNNA ALPHA ONUOHA, (“ONUOHA”) with violating of Title 18, UnitedStates Code, Section 1038(a): False Information and Hoaxes; andTitle 18, United States Code, Section 844(e): Threats AffectingInterstate Commerce; on September 10, 2013, at the Los AngelesInternational Airport (“LAX”), located in Los Angeles,California.3.The facts set forth in this affidavit are based on mypersonal observations, my training and experience, andinformation obtained from other law enforcement officers andwitnesses. This affidavit is intended to show that there isprobable cause for the requested complaint and does not purportto set forth all of my knowledge or investigation into thismatter.4.Title 18, United States Code, Section 1038(a) prohibits“engag[ing] in any conduct with intent to convey false or
 
misleading information under circumstances where such informationmay reasonably be believed and where such information indicatesthat an activity has taken, is taking, or will take place thatwould constitute a violation of chapter 2 . . . of this title.”5.Chapter 2 of Title 18 includes Section 37: Violence atInternational Airports. This section prohibits, in pertinentpart, the following conduct: “destroy[ing] or seriouslydamag[ing] the facilities of an airport serving internationalcivil aviation . . . or disrupt[ing] the services of the airport,if such an act endangers or is likely to endanger safety at thatairport.”6.Title 18, United States Code, Section 844(e) prohibits“use of the mail, telephone, telegraph, or other instrument ofinterstate or foreign commerce, or in or affecting interstate orforeign commerce, willfully makes any threat, or maliciouslyconveys false information knowing the same to be false,concerning an attempt or alleged attempt being made, or to bemade, to kill, injure, or intimidate any individual or unlawfullyto damage or destroy any building, vehicle, or other real orpersonal by means of fire or an explosive.”7.As I explain below, I believe that ONUOHA violated 18U.S.C. §§ 1038(a) and 844(e) by the following actions: (a)immediately after resigning his employment with theTransportation Security Administration (“TSA”) at LAX on
2

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