Case 5:17-mj-00301-CG Document Filed 07/01/17 Paget of 13 gale AO 91 (rev.11/11) Criminal Complaint AUTHORIZED AND APPROVED DA a United States District Court for the WESTERN, DISTRICT OF OKLAHOMA United States of America DANIELLE DANA LAYMAN, all/a Samantha Dowry, ail/a Danielle Givati, alka Dana Abecassis. Case No: M-17- 30] -CBG FILED JUL 01 2017 CRIMINAL COMPLAINT —__ CARMELITA REEDER SHINN, CLERK DIST. COURT, WESTERN DIST. OKLA |, the complainant in this case, state thatthe following is true to the best of my kal DaPUTY Count 1 (On or about April 18, 2017, to on or about May 9, 2017, within the Wester District of Oklahoma, the defendant(s) Danielle Dana Layman, a/kia Samantha Dowry, a/W/a Danielle Givati, a/k/a Dana Abecassis violated: Code Section Offense Description 18:1958(a) Whoever uses or causes another to use the mail or any facility of interstate or foreign commerce with intent that a murder be committed in violation of any laws of any state, or the United States, as consideration for the receipt of, or as consideration for a promise or agreement fo pay, anything of pecuniary value, or who conspizes to do ‘This criminal complaint is based on these fets: Soe attached Affidavit of Task Force Officer David M. Otwell, Federal Bureau of Investigation, which is incorporated and “Caw r6ul Obren Complainants signature DAVID M. OTWELL ‘Task Force Officer feral Bureau of Investigation ri en adv iy spon pa aly 1, 200% Check, B. Judge’ signature HARLES B. GOODWIN, U.S Magistrate Judge FR Continued on the attached sheet. City and State: Kklahoma City, OklahomaCase :17-mj-00301-CG Document 1 Filed 07/01/17 Page 2 of 13 (N THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF OKLAHOMA AFFIDAVIT 1, David M. Otwell, being duly swom, depose and state: AFFIAI .XPERIE] E 1. Lama Task Force Officer (TFO) with the Federal Bureau of Investigation (FBI Joint Terrorism Task Force (ITTF). Tam an investigative or law enforcement officer of the United States within the meaning of Title 18 U.S.C, § 2501(7); that is, an officer of the United States who is empowered to conduct investigations for violations of federal offenses. Thave been employed as a Police Officer with the City of Edmond for approximately 26 years and have been assigned to the Oklahoma City Division of the FBI JTTF as a TFO for the last 13 and a half years. I have participated in investigations involving individuals suspected of terrorist activities, assisted in the execution of search and arrest warrants, conducted physical surveillance, analyzed records and have spoken to informants and subjects of investigations involving numerous types of federal violations. 2. The facts and information set forth in this affidavit are derived from an investigation conducted by myself as well as other agents, other law enforcement agents involved with this case, FBI intelligence analysts and from a review of documents and other records related to this investigation. Since this affidavit is being submitted for the limited purpose of establishing probable cause, I have not included each and every fact known to investigators about this investigation. I have set forth only the facts that I believe are eeCase 5:17-mj-00301-CG Document Filed 07/01/17 Page 3 of 13 necessary to establish probable cause to support the issuance of a criminal complaint, PURPOSE OF AFFIDAVIT 3. Based on my training and experience and the facts as set forth in this affidavit, there is probable cause to believe that violations of Title 18, United States Code, Section 1958(a), Use of Interstate Commerce Facilities in the Commission of Murder for Hire, committed by Danielle Dana Layman, a.k.a Samantha Dowry, a.k.a. Danielle Givati, a.kca, Dana Abecassis, Section 1958(a) prohibits using or causing another to use (or conspiring to use or cause another to use) the mail or any facility of interstate or foreign commerce, with intent that a murder be committed in violation of the law of any State or the United States as consideration for the receipt of, or as consideration for, a promise or agreement to pay anything of pecuniary value. FACTS AND CIRCUMSTANCES 4, OnMay 9, 2017, at 12:58 p.m. Eastern Time, CHS #0008387 (CHS) called the FBI Public Access Line (PAL) to report having been hired to murder an individual in Tel Aviv, Israel, using ricin, CHS stated that Samantha Dowry, cellular telephone number XXX- XXX-9503, craigslist email address nvxnj-6093775010@gigs.craigslist.org, in Ponca Oklahoma, had provided her with ricin 5. On May 3, 2017, at 3:40 p.m., Central Standard Time, CHS responded to a craigslist post (Posting ID# 6093775010) titled: “10 day gig overseas for amateur, ie competitive pay!” The body of the post is as follows: eeCase 5:17-mj-00301-CG Document 1 Filed 07/01/17 Page 4 of 13 For production overseas, looking for talent, 30-45 years old. Doesn’t have to be a professional actor. Required: Creative, outgoing and friendly, positive personality, boldness and bravery (Some stunts may seem risky, although they are completely safe), Discrete (you must not disclose any information related to the plot to ANYONE under ANY CIRCUMSTANCES, until afier it premiers, except with explicit permission from production) valid passport not required but preferred: Experience in acting, Experience performing in magic shows, Experience as casino dealer, No need to pass a background check however, no one with drug related convictions or current drug use will be hired. Send resume and cover letter by email and we will contact you to set up interview. 6. After responding to Samantha Dowry (the person who posted Posting ID# 6093775010) via Craigslist Messenger and by text message to discuss the potential job posting, CHS agreed to meet Samantha Dowry at the Perk Beverage Company, 415 North 14th Street, Ponca City, Oklahoma, on May 9, 2017, at approximately 11:30 a.m, CHS later provided to law enforcement a series of text messages with Samantha Dowry, which I have reviewed, These text messages corroborate CHS’s account of the logistics of the meeting on May 9, 2017. 7. At the meeting, Samantha Dowry informed CHS she wanted CHS to poison someone with ricin, CHS was wamed if he/she told anyone about this, she and CHS would both be killed. 8. Samantha Dowry proceeded to show CHS an entire PowerPoint presentation, which was on a laptop computer brought to the coffee shop by Samantha Dowry concerning what CHS was being asked to do, where CHS would stay, and how CHS would get there. eSCase 5:17-mj-00301-CG Document1 Filed 07/01/17 Page 5 of 13 Samantha Dowry advised CHS to use ricin on an individual with the last name of Qasis, cellular telephone number XXX-XXX-9101, in Tel Aviv, Israel. Samantha Dowry explained Qasis was a taxi driver for Ashdod Mall Taxi with business telephone *6868. Samantha Dowry provided CHS with a packet containing codes and instructions on what the CHS would need and the names of other individuals involved in this endeavor. 9. The instructions, which CHS provided to law enforcement and I have reviewed, were titled “Operation Insecticide” and were as follows: A. Preparation for mission. 1) Prepare your body 2 weeks in advance for an 8 hours’ time change 2) Packing list ~ clothing for 10 days at 90 degree weather - laptop - lock and key ~ vials of powder ~ in both ca money - passport ~ flight ticket on and checked baggage. B. communication: 1) Report updates via code 01 01 0000 . 000 000 0000 to Tammy XXXXXX. 2) abort code: 9999 — from Tammy XXXXXX ONLY. 3) no communications unless there is an update C. Lodging: Any backpackers hostel, prefer in Ashdod or Tel Aviv, check www.Airbnb.com or any other website eSCase 5:17-mj-00301-CG Document 1 Filed 07/01/17 Page 6 of 13, D. Mission Details: 1) You will be given $1000 for your stay expenses. Any unused portion is yours 10 keep. 2) The powder you are carrying is not a drug. If questioned about it at the airport explain itis a religious relic that is supposed to ward off evil spirits, It is made of a plant common in Israel (Castor) and is highly toxic. 3) While at the hostel, make friends and offer them to join you on a tour to tourist attractions. Offer to take a taxi and split the cost. Itis recommended to have at least one “friend” join you, but not a requirement. 4) Call your mark, His name is XXXXXXX XXX Qasis, his cell number is XXX- XXX-9101 (local number). He works as a taxi driver for Ashdod Mall Taxi (aka Canyon Ashdod). Local phone number for the taxi station is *6868. Tell him you received his phone number from another tourist who recommended him. Ask him to quote you a price to drive you daily to tourist attractions for one week. You may negotiate the price down, Price negotiations is common in Israel and is expected. 5) Prepare 2 cups of coffee. Add powder to one of them, As your mark arrives at your hostel to pick you up in the morning, offer him a cup of coffee. Repeat every morning and monitor the driver's health. Report if he starts showing signs of illness, if he is vomiting, and if he fails to come pick you up at the hostel. 6) When your mark is hospitalized [or] eliminated — move to a different hotel or motel until your flight back home. 7) Upon confirmation of mission success, you will be paid $4,000 in cash. The money will be given to you via your operator 10. While at the Perk Beverage Company, Samantha Dowry gave CHS a small package and was told it contained ricin in its plant form and was warned about opening the package without the use of gloves. CHS had already provided Samantha Dowry with a copy of his/her passport for proof of identification prior to meeting Samantha Dowry in person. | oeCase 5:17-mj-00301-CG Document Filed 07/01/17 Page 7 of 13 CHS was told that any further communication with Samantha Dowry was to be about a modeling job and not the upcoming trip. CHS was told a person identified as Tammy XXXXXX will reach out to him/her to set up the travel arrangements. 11. Ricin isa poison found naturally in castor beans. Based upon my training and experience, I understand that ricin is a “toxin” for purposes of Title 18, United States Code 178(1). Ifingested, inhaled, or injected, ricin can be fatal. Those knowledgeable in the field of ricin toxin state that ricin could be extracted using certain common ingredients and instrumentalities including: castor beans (from which ricin is actually extracted), syringes, strainers, coffee grinders, coffee filters, latex gloves, and acetone. Properly disseminated, it could kill numerous people. Ricin poisoning has no known antidote and is extremely difficult to detect as a cause of death. 12, Samantha Dowry offered CHS $1,000.00 for his/her personal expenses for 10 days in Tel Aviv and another $4,000.00 if he/she was successful. CHS was told this would take place in the fall of 2017. 13. When CHS departed the meeting, CHS took photographs of the two pieces of paper that contained the codes and instruction of the operation, the bag containing the glass vials, and the baggie containing ricin. CHS then sent a text message to an attomey friend. CHS sent the attorney friend the photographs, details regarding the murder-for-hire proposal and asked him what CHS should do. The attomey responded via text message to CHS and told CHS to stop what CHS was doing and call the FBI immediately. SwCase 5:17-mj-00301-CG Document1 Filed 07/01/17 Page 8 of 13 14. Shortly after CHS contacted his/her attorney friend requesting advice, CHS. called the FBI Public Access Line (PAL) to report the murder-for-hire plot. 15. To corroborate and determine the reliability of CHS, the attomey was interviewed by FBI agents. The attorney verified the fact that the CHS contacted him via text message on May 9, 2017, the same day CHS met Samantha Dowry at the Perk Beverage Company in Ponca City and was requested to conduct the murder using ricin. He also provided agents with screen shots of the text message exchanges between him and CHS, including the photos of the two pieces of paper that contained the codes and instruction of the operation, the bag containing the glass vials, and the baggie containing ricin. 16. CHS explained when CHS arrived at CHS’s residence, CHS told his/her roommate about the meeting and showed hinvher the pieces of paper containing the codes and instructions of the operation, the bag that contained the ten glass vials, and the baggie containing ricin, CHS said the items were then placed in an upper cabinet in his/her laundry room so children were not able to get to them. CHS said his/her roommate decided to take the items out of the upper cabinet and dispose of them in a trash dumpster in an apartment complex in Oklahoma City, Oklahoma. 17. During an interview with the CHS, agents showed the CHS a photograph of Danielle Dana Layman to see if she was the same person CHS met with at the Perk Beverage Company in Ponca City, Oklahoma, who identified herself as Samantha Dowry. AfterCase 5:17-mj-00301-CG Document 1 Filed 07/01/17 Page 9 of 13 looking at the photograph for approximately two seconds, the CHS positively identified the photograph as the female who attempted to hire hinv/her to commit the murder-for-hire plot, 18. Iman attempt to corroborate and determine the reliability of the CHS, agents interviewed the roommate of CHS. During the interview, the roommate was cooperative and ultimately verified each detail that CHS provided him/her regarding the murder-for-hire plot. The roommate explained CHS showed his/her the baggie containing ricin, the glass vials, and the two pieces of paper detailing the codes and instructions of the operation. ‘The roommate was extremely scared and upset at CHS for giving out their address to the person ‘who was attempting to hire CHS for the murder-for-hire plot. The roommate decided to take the glass vials and the baggie containing the ricin to a dumpster at an apartment complex on the south side of Oklahoma City, where she discarded them. 19, Inanattempt to corroborate and to determine the reliability of CHS, database queries were conducted on “Samantha Dowry” in an attempt to completely identify her. The database checks were unsuccessful in identifying “Samantha Dowry” as a true person. A cheek of the telephone number “Samantha Dowry” provided to CHS, (XXX) XXX-9503, had returned to an active phone for Danielle Dana Layman, aka: Danielle Givati. A query within FBI holdings for Danielle Layman, DOB: XX/XX/1980, revealed one non-immigrant visa (NIV) which listed Danielle Givati as an Isracli national and a lawful permanent resident of the United States. Your Affiant knows from visa paperwork submitted by Danielle Layman that she claims to be a former Director of Nursing for the Ministry of Labor in Israel and qo”Case 5:17-mj-00301-CG Document’ Filed 07/01/17 Page 10 of 13 therefore would have some type of a medical and scientific background, 20. When additional queries were conducted through FBI holdings concerning the telephone number Samantha Dowry provided to CHS to contact Qasis in Israel, XXX-XXX- 9101, there was a NIV application for XXXXXX Abecassis, DOB: XX/XX/1977. Abecassis’ occupation was listed as “taxi driver,” with a work number of XXX-XXX-9101. 21. A search for Danielle Givati's NIV application showed she was an Israeli national. Additionally, an alias for Givati was listed as “Dana Abecassis,” the same last name as the taxi cab driver. 22. Open database searches were conducted using the names “Abecassis” and. “Layman.” Numerous Israeli newspaper articles dated in late 2014 appear to indicate Danielle Layman, described as an American-Israeli woman, was in a battle with her ex- husband, XXXXXX Abecassis, over visitation rights with their then-13 year-old daughter. 23. According to the open source reporting, Danielle Layman was divorced from XXXXXX Abecassis in 2003. Danielle Layman later married an American soldier, Jeremy Layman in 2010. In 2014, while her husband was on a deployment, Layman took her children on an extended visit to Israel to visit family. While they were there, XXXXXX Abecassis found out the family was in Israel. Abecassis filed a lawsuit with the Ashdod Region Rabbinical Courts, demanding visitation rights with his daughter. The daughter was reportedly prevented from leaving Israel for an undetermined time; however, a search of social media sites appears to indicate that the daughter is currently back in the United States. CO 9Case 5:17-mj-00301-CG Document1 Filed 07/01/17 Page 11 of 13 According to open source reporting, Abecassis’ current wife at that time, XXXXX Abecassis, was serving as XXXXXX Abecassis’ attorney. 24. An emergency disclosure request was submitted to Craigslist for any and all available information related to Craigslist Posting ID# 6093775010, to include but not limited to IP Addresses, User/Account Owner information, communication records, responders to the post, etc. 25. Within a short period of time, Craigslist responded and provided the FBI the original post, including IP address, email address, and the dates and times when individuals responded to the post. Some of the information is as follows: posting_id: 6093775010 poster email: samanthadowry@gmail.com user_id: 313392304 poster_ip: 70.254.224.177 auth_user_phone: wa auth_user_phone_modify: n/a record_created: Tue Apr 18 2017 12:22:27 PM (Pacific) posted date: Tue Apr 18 2017 12:29:27 PM (Pacific) posting renewal dates: n/a record modified: Sat Jun 03 2017 01:07:17 AM (Pacific) area_description: stillwater, OK subarea_description: n/a neighborhood: n/a geographic_area: wa category description: talent gigs category type: gigs pricelage: n/a invoice_item_id: n/a privacy: anonymized email address posted state: Expired posting title: 10 day gig overseas for amateur, competitive pay! PostingBody 10Case 5:17-mj-00301-CG Document 1 Filed 07/01/17 Page 12 of 13 For a production overseas, looking for talent, 30-45 years old. Doesn't have to be a professional actor. Required: Creative Outgoing and friendly, positive personality Boldness and bravery (some stunts may seem risky, although they are completely safe) Discrete (you must not disclose any information related to the plot to ANYONE under ANY CIRCUMSTANCES, until afier it premiers, except with explicit permission from production) valid passport not required but preferred: Experience in acting Experience performing in magic shows Experience as casino dealer No need to pass a background check however, no one with drug related convictions or current drug use will be hired send resume and cover letter by email and we will contact you to set up interview. 26. Based on the information obtained, there were two individuals who responded to the Craigslist posting, one being CHS. 27. On June 30, 2017, federal agents executed a search warrant at Danielle Layman’s residence in Ponca City, Oklahoma. Agents found several dozen castor beans in the kitchen, Agents also found a mortar and pestle with residue that could be remnants of ground castor beans, On the kitchen counter, agents found instructions on how to make ricin, apparently printed from the internet. 28. Inmy presence, Danielle Layman made phone calls to her husband to let him know that federal agents had executed a search warrant at their residence, Ms, Layman knew that I was able to hear her side of the conversation. During one of the conversations, she ctCase 5:17-mj-00301-CG Document1 Filed 07/01/17 Page 13 of 13 informed her husband that agents were searching for castor beans. She told her husband that she had ordered castor beans, which she explained is not illegal. She told her husband that one can turn castor beans into ricin and stated that she knew how to do that. She also told her husband that she had printed instructions off of the internet on how to make ricin a year and a half ago and stated that agents would find those printed instructions. CONCLUSION 29. Based on the facts herein and my training and experience, I submit there is probable cause to arrest Danielle Dana Layman for an offense in violation of Title 18, U.S.C., § 1958(a), Use of Interstate Commerce facilities in the commission of Murder-for- Hire, 30. I swear the forgoing is true and correct to the best of my knowledge and belief. DAVID M. OTWELL Task Force Officer Federal Bureau of Investigation Subscribed and sworn to before me this Ist day of July 2017, in Oklahoma City, Oklahoma. Mauka B, ieoie CHARLES B. GOODWIN United States Magistrate Judge 12