A091 (Rev. 0808) Criminal Compl United States of America HORACE DEXTER MCDADE and JOHN VINCENT HAILE — Defendants) 4 CRIMINAL COMPLAINT 7 RN i "sthe complainant inthis case, state that the following i true to the best of my knowledge and belief, On or about the date(s) of 2010 tothe present __inthe county of ___ Alexandria in the ——Eastem__ District of Virginia + the defendant(s) violated: Code Section Offense Description t8usc. 371 Conspiracy to Commit Theft Conceming Programs Receiving Federal Funds This criminal complaint is based on these facts: Please see attached affidavit. ® Continued on the attached sheet. Conplainan?™sigrarare Kevin Gaddis, Captain ———Metropolitan Transit Police Department Printed name and tle Swom to before me and signed in my presence, Date: orien és/Thomas Rawles Jones, Jr. 2 — see City and state: Alexandria, VA Hon. T. Rawies Jones, Jr., U.S. Magistrate Judge . Printed name and tle — By AUSA Chas GolderIN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA _ JAN 18 2012 Alexandria Division UNITED STATES OF AMERICA ) } Criminal No. 1:12-mj-24 v. ) ) HORACE DEXTER MCDADE, ) ) and ) ) JOHN VINCENT HAILE ) ) Defendants. ) AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT AND ARREST WARRANT 1, Kevin P. Gaddis, being first duly sworn, hereby depose and state as follows: INTRODUCTION AND AGENT BACKGROUND 1, Tama Captain with the Metro Transit Police Department (MTPD) of the Washington Metropolitan Area Transit Authority (WMATA) and have been a sworn employee since 1995. Law enforcement services provided by MTPD members are related to the protection of WMATA customers, personnel, and transit facilities. 1 am currently assigned to the Metro Transit Police Department’s Office of Responsibility and Inspections (OPRI), commonly referred to as “Internal Affairs.” My responsibilities include, but are not limited to, the investigation of serious employee misconduct, including corruption and criminal misconduct of members of the Metro Transit Police Department. I have been in my current position since July 2010.2, Tam assigned to this investigation and have participated in it since soon after it began. My involvement has included reviewing financial records and case materials provided to me by numerous individuals and financial institutions, as well as materials provided by other Metro Transit Police Officers and other law enforcement agencies. The facts in this affidavit come from my personal observations, my training and experience, and information obtained from other agents and witnesses, This affidavit is intended only to demonstrate that there is sufficient probable cause for the requested warrant and does not set forth all of my knowledge about this matter. PURPOSE OF AFFIDAVIT 3. This affidavit is submitted in support of the following: a. A criminal complaint charging HORACE DEXTER MCDADE and JOHN VINCENT HAILE with: = Conspiracy to commit theft concerning programs receiving Federal funds by, being agents of a State government or agency thereof, embezzling, stealing, obtaining by fraud, or otherwise without authority knowingly converting to the use of any person other than the rightful owner, property that is valued at $5,000 or more and is ‘owned by, or under the care, custody, or control of such government oragency, in violation of Title 18, United States Code, Section 371. b. Arrest warrants for HORACE DEXTER MCDADE and JOHN VINCENT HAILE.