United States of America v.

STERL YNN ROBBINS

) ) ) ) ) )

Case No.

AO 91 (Rev. 08/09) Criminal Complaint

UNITED STATES DISTRICT COURT

for the

District of Massachusetts

Defendamts)

CRIMINAL 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 March 17 and 18,2011 in the county of Bristol in the

District of Massachusetts , the defendant(s) violated:

Code Section Title 18 United States Code, Section 875(c)

Offense Description

Transmission in interstate or foreign commerce communications containing threats to injure the peson of another

This criminal complaint is based on these facts:

See the Affidavit of Massachusetts State Police Officer Lucas Jorge, which is attached and marked as Exhibit One, and incorportaed by reference.

~~n~~-nt-s-Sl-gn-a-'U-re----------Lucas Jorge, MA State Police Officer

lit Continued on the attached sheet.

Printed name and title

Sworn to before me and signed in my presence.

Date:

'}: J. J

03/23/2011 W- of.

City and state:

Boston M ssachusetts Hon,:-;.~R;.ro:.=b~e'-!.rt-"B:.!:. ~C"",o~·~~~...!!7===;~PIF-_j

I-ION. RO:8ER'I' :8-:- COIJ .... .Il'4 \,.7~ Print

TED STATES !vlAGISTRf\TEJUDGE United States District Court }QhnJoseph Moakley United States Courthouse 1 Courthouse Way, Suite 7420

AFFIDAVIT OF TROOPER LUCAS JORGE

Massachusetts State Trooper Lucas Jorge deposes and states as follows:

A. INTRODUCTION

1. I am employed by the Commonwealth of Massachusetts as a

State Police Officer. I have been a Massachusetts State Police

Officer continuously for the past fourteen years and currently

hold the rank of Trooper First Class. I am a graduate of the

Massachusetts State Police Academy. For the past three years, I

have been assigned as a Task Force Officer on the FBI Joint

Terrorism Task Force and work out of the Lakeville Resident

Agency Office. Prior to my current assignment, I was assigned to

the Criminal Information Section of the Massachusetts State

Police and worked out of the Bourne, Holden, and Middleboro

2. This affidavit does not set forth all the facts

Barracks. I have investigated various types of crimes including

threats, larcenies, narcotics offenses, terrorist threats, and an

array of state offenses.

developed during the course of this investigation. Rather, it

sets forth only those facts that are necessary and sufficient to

establish probable cause that Sterlynn Robbins has committed a

violation of Title 18 United States Code, Section 875{c), in that

he transmitted in interstate of foreign commerce communications

containing threats to injure the person of another.

3. I have personally participated in the investigation of

the matter which is the subject of this affidavit. I am familiar

with the facts and circumstances of this investigation from oral and written reports made by other officers of the Massachusetts State Police, the Town of Easton Police Department, and the Stonehill College Police Department. I submit this affidavit in support of a criminal complaint charging Sterlynn Robbins with a violation of Title 18 United States Code, Section 875(C), in that he transmitted in interstate of foreign commerce communications containing threats to injure the person of another.

B. SUMMARY OF EVIDENCE

4. On March 17, 2011, at approximately 11:39:30 p.m.,

a female student at Stonehill College in Easton, Massachusetts, received the following a text message on her cell phone: "Yea do me a favor. Be at stonehil1 the day I blow it up and fucking kill those fucked up people." The text message had been sent from a phone with the number 1-203-530-

2860. At approximately 11:39:53 p.m., ived a

second text message from same phone number, which read: "Ill make all of you fucking beg for mercy bitch." At approximately

11:40:11 p.m.,

ceived a third text message rom the

same phone number, which read: "You're just as bad as ._

and "At approximately 11:40:27 p.m.,

received a fourth text message from the same phone number, which read: "You should apply for their position." Approximately twenty minutes later, at approximately 12:01:46 a.m. [March 18,

2011] ,

eived a fifth text message from the same

approximately 12:05:32 a.m.,

ceived a seventh text

phone number, which read: "Just wait and see what im gonna do."

sent the following reply by text message: \\what are you gonna do sterl?" At approximately 12: 05: 18 a.m., • ...... received a sixth text message from the same phone number, which read: "You don't listen well I just told you. You

think im joking but what else do I have to lose." At

message from the same phone number, which read: "The school

already stripped me of· everything." At approximately 12:05:48

a.m. ,

received an eighth text message from the same

number, which stated: "It's not hard to get on campus and do what

I need to." ent the following reply text message:

"Don't threaten me." At approximately 12:07:03 a.m.,.

eived a ninth text message from the same phone number, which read,"im not. Its more like warning. And its not

you im saying the school too At approximately 12:07:12 a.m.,

•• It. "

received a tenth

text message from the same phone number, which read, "Im gonna

kill them both I swear." At approximately 12:08:50 a.m. ceived an eleventh text message from the same phone, which read,"I don't fucking care. I was already arrested once.

I don't even care if they try to kill me in my attempt. At least my pathetic life will be over." At approximately 12:09:29 a.m.,

received a twelfth text message from the same phone,

5.

recognized that telephone number 1-203-

which read, "I have nothing to live for anyways except revenge."

4530-2860 belonged to Sterlynn Robbins, a former Stonehill College student, who had been separated from the college in 2009. and Mr. Robbins had been friends, but never dated, when Mr. Robbins was a student at the college and the two maintained contact after Mr. Robbins left Stonehill College. At

some point prior to March 17, 2011, end her relationship with Mr. Robbins.

6. On March 18, 2011, at approximately 1:45 p.m.,~

had attempted to

ified the Stonehill Police of the threats made by Mr.

Robbins. At 2:07 p.m., she notified

and".

the two Stonehill employees threatened by Mr. Robbins in his text messages, of the threats and sent them each copies of the text messages she received from Mr. Robbins.

7. is the

at Stonehill College. In March 2007, she found Mr. Robbins responsible for physically assaulting another student. Mr. Robbins was required to take anger management training and placed on deferred separation from residency.

8.

is the

at

Stonehill College. In the spring of 2009, she chaired a disciplinary hearing, in which Mr. Robbins was accused of physically assaulting another student. Mr. Robbins was found responsible for the assault and separated from the college for a

period of time. Mr. Robbins appealed his separation, but his

appeal was not granted.

9. The Town of Easton Police Department took custody of

and received by

ell phone and downloaded the text messages sent cell phone during the period it

received the threatening text messages. I have reviewed a copy

of the text message record and noted the text messages sent to

phone on March 17 and 18, 2011, from telephone

number 1-203-530-2860.1 The record reflects that this number is

associated with "Robbins Sterlyn." Additionally, the Easton

Police downloaded the telephone directory from

cell phone. The directory reflects that the phone number

"12035302860" belongs to "Robbins Sterlynn."

10. I believe that Mr. Robbins resides at 67 Wood Chase

Road, North Branford, Connecticut. My review of the phone

records for the phone used by Mr. Robbins to communicate wi

which were obtained by the Easton Police Department

from Verizon Wireless pursuant to an "Emergency Information

Request," revealed that the text messages sent by Mr. Robbins to

on March 17 and 18, 2011, traveled over a

telecommunications switch in Wallingford, Connecticut.

I The text message history downloaded by the Easton Police

Department from ell phone does not reflect the

replies sent by 0 Mr. Robbins; however, records

obtained from Verizon Wireless contain?' 71' ILLresponses.

C. CONCLUSION

11. Based on the foregoing, I believe that there is

probable cause to believe that Sterlynn Robbins has committed a

violation of Title 18 united States Code, Section 875(c), in that

he transmitted in interstate of foreign commerce communications

containing threats to injure the person of another.

police

Sworn to and subscribed before me this 23rd day of March

2011.

OBERT B. COLLINGS U.S. Magistrate Judge

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