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11.01.2011. Samuel J. Crump - defendant. Criminal Complaint. USDC, Northern District of Georgia, Gainesville Division.

11.01.2011. Samuel J. Crump - defendant. Criminal Complaint. USDC, Northern District of Georgia, Gainesville Division.

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Published by Lucas Daniel Smith

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Published by: Lucas Daniel Smith on Nov 25, 2011
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11/25/2011

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NORTHERN DISTRICT OF GEORGIA
U.S.D.C
Gainesville
UNITED STATES OF AMERICA
v.
CRIMINAL CO
IDl
M1:Sllr.
SAMUEL
J.
CRUMP
(UNDER SEAL)
(Name
and
Address
of Defendant)
AO 91
(Rev.
51llS)
Criminal
Complaint
United States District
Courr'LED
INCLERK'S
OFFICE 
I,
the undersigned complainant being duly sworn state the following is true and correct to the best
of
my knowledge and belief.Beginning on a date unknown, but at least as
of
September 2011, and continuing up to and including November, 2011, in StephensCounty, Georgia and elsewhere, in the Northern District
of
Georgia defendant did,aided and abetted by Ray H. Adams and others, knowingly attempt to develop, produce, and possess a biological agent and toxin,to wit: ricin, for use as a weaponin violation
of
Title
II
United States Code, Sections 175(a) and
2. 
I
further state that
I
am a Special Agent
of
Federal Bureau
of
Investigation and that this complaint
is
based on the following facts: See attached affidavit. Continued on the attached sheet and made a part hereof.
Signature
of
Complainant
(/
David W. WylieBased upon this complaint, this Court finds that there is probable cause to believe that an offense has been committed and thatthe defendant has committed it. Sworn to before me, and subscribed in
my
presence
~ : . . = ~ ~ ~ ~ . ! . -
____________
atGainesville, Georgia 
DateCity
and
State 
SUSAN
S.
COLEUnited States Magistrate JudgeName and Title
of
Judicial OfficerSignature
of
Judicial Officer
AUSA
JetITey
A.
Brown
Case 2:11-cr-00044-RWS-SSC Document 1 Filed 11/01/11 Page 1 of 26
 
AFFIDAVIT 
I,
David
Wylie,
being
first
duly
sworn,
do
hereby
deposeand
State:
1.
I
am
a
Special
Agent
with
the
Federal
Bureau
of
Investigation
(FBI)
and have
been so
employed
for
approximately
twenty
-
five years.
I
am
currently
assigned
to
the
FBI's
office
in
Gainesville,
Georgia.
My
investigative
responsibility
includes
investigating
different
federal
crimes
such
as
bank
robbery,
bank
fraud,
mortgage
fraud
and
domestic
terrorism.
have
been
involved
ininvestigations
relating
to
domestic
terrorism
and
have
participatedin
theexecution
of
search
warrants
and
seized
evidence
that relates
to
violations
of
domestic
terrorism
statutes.
I know
the
following
principally
based
on
information
obtained
from
my
investigation
and
from
other
law
enforcement
officers.
2.
As a
federal
agent,
I
am
authorized
toinvestigate
violations
of
laws
of the
United
States
and
to
execute
warrants
issued
under
the
authority
of the
United
States.
3.
This
affidavit
is
in
support of
a
request
for
a
federal
search
warrant
to
be
served
upon
and
executed
at
the residenceof
Samuel
Jerry
CRUMP,
111
Woodlawn
Drive,
Toccoa
Georgia
30577
is
a
single story
family
residence
single
wide
mobile
home
with
1
I
Case 2:11-cr-00044-RWS-SSC Document 1 Filed 11/01/11 Page 2 of 26
 
no
basement
located
wi
thin
Stephens
County.
The
exterior
is
white
siding
with
an
enclosed
addition
attached
to
the
front
of
the
home
which
appears
to
be
the
main
entrance
off
the
driveway.
The
property
consists
of
.27
acres
which
includes the
main
residence.
The
property
is
recorded
on
the
Stephens
County
tax
map
as
parcel
number
T34
068;
to
search
for
evidence, contraband
and
fruits
of
a
crime
as
set
forth
in
Exhibit
B
(attached
hereunto
and
express
incorporated
herein
by
this
reference),
as
well
as
any
vehicles
located
on
the property
and
any
out
buildings located
on
the
properties.
I
am
also
requesting
authority
to
search the referenced
properties
and any
computers,
and computer
media
located
therein
where
the
items
specified
in
Attachment
B
may
befound, and
to seize
I
items
listed
in
Attachment
B
as
instrumentalities,
fruits,
and
evidence
of
a
violation
of
Tit
18,
Uni
tedStates
Code
Section
175,
prohibitions
with
respect
to biological
weapons.
4.
This
affidavit
is
also
being submitted
for the
purpose
of
securing
a
complaint
and
warrant
forthe
arrest
of
Samuel
Jerry
CRUMP
(CRUMP)
foraiding
and
abetting
Ray
H. Adams
in
the
knowing
attempt
to
produce
and
possess
the
biological
toxin,
ricin,
for
use
as
a
weapon
in
violation
of
Title
18,
United
State
Code,
Sections
175(a) and 2.
I
have
notincluded
each
and
every
known
fact
concerning
this
investigation;
rather,
I
have
2
Case 2:11-cr-00044-RWS-SSC Document 1 Filed 11/01/11 Page 3 of 26

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