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Full text of "2017 03 01 Sealed Complaint United States Vs Juan Thompson ( 17 MAG 1533)"

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Approved : 

JACbB WARREN 

Assistant United States Attorney 

Before: THE HONORABLE SARAH NETBURN 

United States Magistrate Judge 
Southern District of New 


UNITED STATES OF AMERICA 

- v . - 

JUAN THOMPSON, : 

Defendant. 

— - — - — — — — — - — — x 

SOUTHERN DISTRICT OF NEW YORK, SS . : 

CHRISTOPHER MILLS, being duly sworn, deposes and says 
that he is a Special Agent with the Federal Bureau of 
Investigation (the "FBI"), and charges as follows: 

COUNT ONE 
(Cyber stalking) 

1. From at least in or about July 2016 up to and 
including at least on or about March 1, 2017, in the Southern 
District of New York and elsewhere, JUAN THOMPSON, the 
defendant, with the intent to kill, injure, harass, intimidate, 
and place under surveillance with intent to kill, injure, 
harass, and intimidate another person, used the mail, any 
interactive computer service and electronic communication 
service and electronic communication system of interstate 
commerce, and any other facility of interstate and foreign 
commerce to engage in a course of conduct that placed that 
person in reasonable fear of the death of and serious bodily 
injury to that person and caused, attempted to cause, and would 
be reasonably expected to cause substantial emotional distress 
to that person, to wit, THOMPSON circulated false and 
threatening information to, about, and in the name of a woman 
("Victim-1") over the Internet, which caused Victim-1 
substantial emotional distress. 


SEALED COMPLAINT 

Violation of 18 U.S.C. 
§§ 226 1A ( 2 ) and 2 

COUNTY OF OFFENSE: 

NEW YORK 



(Title 18, United States Code, Sections 2261A(2) and 2.) 


The bases for my knowledge and for the foregoing 
charge are, in part, as follows: 

2. I am a Special Agent with the FBI, and I have 
been involved in the investigation of JUAN THOMPSON, the 
defendant. This affidavit is based upon my personal 
participation in the investigation of this matter, my 
conversations with law enforcement officers, witnesses, and 
others, as well as my examination of reports, and records. 
Because this affidavit is being submitted for the limited 
purpose of establishing probable cause, it does not include all 
of the facts that I have learned during the course of my 
investigation. Where the contents of documents and the actions, 
statements, and conversations of others are reported herein, 
they are reported in substance and in part, except where 
otherwise indicated. 


Overview 

3. In recent months, the FBI has been investigating 
a series of threats across the country principally targeting 
Jewish Community Centers ("JCC"), schools, and other 
organizations that provide service to and on behalf of the 
Jewish community (the "JCC Threats") . Based on the FBI's 
investigation, JUAN THOMPSON, the defendant, appears to have 
made some of the JCC Threats as part of a sustained campaign to 
harass and intimidate Victim-1. As set forth in greater detail 
below, THOMPSON'S harassment of Victim-1 appears to have begun 
shortly after their romantic relationship ended and to have 
included, among other things, defamatory emails and faxes to 
Victim-1' s employer, see infra 4(c), 4(h), 4 (k) - (n) , false 
reports of criminal activity by Victim-1, see infra 5,9, and 
JCC Threats in Victim- 1 's name, see infra U 7. 

THOMPSON'S STALKING OF VICTIM- 1 


4. Based on my involvement in this investigation, 
the FBI's interview of Victim- 1, and my review of materials that 
Victim-1 has provided to the FBI, I have learned the following, 
in substance and in part : 

a. Victim-1 works at a social service 
organization in the greater New York area ("Company-1") . In or 
around 2015 and 2016, Victim- 1 was involved in a romantic 
relationship with JUAN THOMPSON, the defendant. 

b. On or about July 26, 2016, Victim-1 ended 
Victim-1' s romantic relationship with THOMPSON. 


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c. On or about July 27, 2016, Company-1' s 
executive director (the "Executive Director") received an email 
from someone purporting to be a producer with a national news 
organization (the "Hoax News Email") stating that Victim-1 had 
been pulled over for drunk driving, and was currently being sued 
for spreading a sexually transmitted disease. Based on my 
review of records provided to the FBI, it appears the Hoax News 
Email was sent from an IP address that THOMPSON used to access 
one of his social media accounts as recently as three days 
before the Hoax News Email was sent. 

d. Over the next several weeks, Victim- 1 
received text messages and emails, purportedly from a close 
friend and relative of THOMPSON, stating, in substance and in 
part that : 


i. THOMPSON had been the victim of 

computer hacking by an unknown person, and THOMPSON was not 
responsible for the recent acts of harassment towards Victim-1; 

ii. THOMPSON was sorry for hurting Victim- 

1, and THOMPSON had written a check to compensate Victim-1; 

iii. THOMPSON had been the victim of a 

robbery and shooting, had multiple gunshot wounds, and had gone 
into cardiac arrest; and 

iv. THOMPSON was dying of his injuries and 

was going to be taken off of life support. 

e. Based on my review of law enforcement 
records, it appears that THOMPSON had not, in fact, been the 
victim of a shooting. 

f. In or around August 2016, Victim-1 obtained 
a New York State order of protection (the "Order of Protection") 
against THOMPSON. Victim- 1 renewed the Order of Protection 
against THOMPSON in October and December 2016. 

g. In or around September 2016, THOMPSON told 
Victim-1 that THOMPSON'S computer had been hacked by someone in 
Africa . 


h. On or about September 12, 2016, the 
Executive Director received an anonymous email stating, in 
substance and in part, that Victim- 1 has a sexually transmitted 


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disease and Victim- 1 should not be working at an organization 
who helps individuals with sexually transmitted diseases. 

i. On or about September 20, 2016, Victim-1 
received an anonymous email attaching nude photographs of 
Victim- 1 and threatening to release the photographs to the 
public. On or about September 21, 2016, Victim-1 received a 
similar anonymous email attaching nude photographs of Victim- 1 
and threatening to release the photographs to the public. 

j. On or about October 5, 2016, the human 
resources manager at Company- 1 received an email from an email 
address that Victim- 1 knows to have been used by THOMPSON (the 
"Thompson Account"), 1 stating, in substance and in part, that 
Victim- 1 had threatened to kill THOMPSON. 

k. On or about October 11, 2016, Company- 1 
received two faxes from anonymous senders stating, in substance 
and in part, that Victim-1 was anti-Semitic (the "Hoax Faxes") . 
The Hoax Faxes contained a screenshot of Victim- 1 's username on 
a particular social media service, and included anti-Semitic 
statements that were purportedly written by Victim- 1. 

l. On or about October 15 and 16, 2016, a 
Company- 1 employee that Victim- 1 supervises received emails from 
different anonymous email addresses, stating, in substance and 
in part, that Victim- 1 has a sexually transmitted disease. The 
emails also contained a picture of Victim-1' s leg. 

m. On or about October 28, 2016, the Executive 
Director received an email that stated, in substance and in 
part, that Victim- 1 has a sexually transmitted disease and that 
Company- 1' s clinical records had been hacked. 

n. On or about November 8, 2016, a Company- 1 
board member received an anonymous fax with a picture of Victim- 
1, which stated, in substance and in part, that Victim- 1 has a 
sexually transmitted disease. 

5. Based on the FBI's conversations with officers 
from the New York City Police Department (the "NYPD" ) , and my 
review of police reports prepared by the NYPD, I have learned 
the following, in substance and in part: 


1 Victim- 1 has received other emails from THOMPSON from the 
Thompson Account. Additionally, the Thompson Account's username 
includes THOMPSON'S last name. 


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a. On or about October 15, 2016, the National 
Center for Missing and Exploited Children ( "NCMEC" ) received an 
electronic communication from an anonymous source using a 
particular internet protocol address (the "Thompson IP 
Address"), which stated: "I was at a disco-tech two weeks ago 
and met [Victim- 1] who said she watched child porn. I thought 
she was joking until she showed me two pictures, on her phone, 
of a child engaged in sex acts." The anonymous source also 
provided Victim-1' s name, address in New York City, and Company- 
l's information. 

b. I have reviewed AT&T records, which show the 
Thompson IP Address is subscribed to in the name of a particular 
individual ( "Individual -1" ) . The subscriber information lists 
Individual-1 as residing at a particular address in St. Louis, 
Missouri (the "Thompson Address") and provides a phone number 
for the account ("Phone-1") . Based on my review of a law 
enforcement database, I know JUAN THOMPSON, the defendant, 
resides at the Thompson Address because, among other things, the 
St. Louis Police Department interviewed THOMPSON at the Thompson 
Address in November 2016. 

c. On or about November 22, 2016, a detective 
with the NYPD (the "Detective") called Phone-1 and asked to 
speak to Individual-1. A male voice answered the call and 
purported to be Individual- 1 . The Detective asked Individual -1 
if he knew THOMPSON, and Individual -1 said no. The Detective 
informed Individual -1 that the Detective needed to make a 
notification to anyone related to THOMPSON. Individual -1 placed 
the Detective on hold, and a male voice picked up and said that 
he was THOMPSON. The Detective asked THOMPSON if THOMPSON had 
ever seen or known Victim- 1 to possess child pornography, and 
noted that the allegation NYPD received regarding Victim-1 
possessing child pornography was from the Thompson IP Address 
where THOMPSON resides . THOMPSON said that he did not think 
Victim- 1 possessed child pornography and told the Detective that 
his email accounts were hacked a few weeks ago. When the 
Detective spoke with THOMPSON, more than a month had elapsed 
since the anonymous tip to NCMEC. The Detective told THOMPSON 
that THOMPSON'S conduct must stop, and that THOMPSON should not 
attempt to contact Victim-1. 

JANUARY AND FEBRUARY 2017: THE JCC THREATS 

6. As set forth below, it appears that JUAN 
THOMPSON, the defendant, has made at least eight JCC Threats 
nationwide as part of his campaign of harassment against Victim- 
1. These threats appear to fall into two categories. The first 


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category includes threats that appear to have been made in 
Victim- 1 's name. See infra U 7. The second category includes 
threats that appear to have been made in THOMPSON' s own name but 
which THOMPSON has later claimed were made by Victim- 1 in an 
effort to falsely implicate THOMPSON. See infra H 8. 

JCC Threats in Victim-1' s Name 


7 . Based on my review of police reports and the 
FBI's conversations with other law enforcement agents, I have 
learned the following: 

a. On or about February 21, 2017, at 
approximately 1:28 a.m., an email account ("Email Account-1") 2 
was used (the "February 21, 2017 email") to send a message to 
the Anti-Defamation League ( "ADL" ) , 3 which stated: "[Victim-l's 
name and birthdate] is behind the bomb threats against jews. She 
lives in nyc and is making more bomb threats tomorrow." As 
noted above, in recent months, the FBI has been investigating a 
series of threats to Jewish community organizations. See supra 
1 3 . 


b. On or about February 22, 2017, at 
approximately 10:27 a.m., the ADL received a phone call from an 
unknown individual who stated in substance and in part that 
there was "C-4," that is, explosive material, in the ADL' s New 
York office, and that it would be "detonated within one hour." 
The caller made the call using a voice disguiser and from an 
untraceable phone number. Immediately after the call, the ADL's 
New York Office, located in midtown Manhattan, contacted 
emergency services, which swept the ADL's New York Office. No 
explosives were found. 

c. On or about February 21, 2017, at 

approximately 1:08 a.m., the Council on American-Islamic 
Relations received an email from an anonymous email account 


2 On February 24, 2017, The Honorable Henry B. Pitman 
authorized a search warrant for Email Account-1. Based on my 
review of Email Account-1' s contents, it appears that Email 
Account-1 had been compromised and that Email Account-1' s true 
user was unaware that the above-referenced message had been 
sent . 

3 The ADL is a non-profit civil rights organization with a 
particular emphasis on combating anti-Semitism. 


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("Email Account-2") 4 that stated: "[Victim-l's name and 
birthdate] a social worker in Nyc has put a bomb in the Jewish 
center in Dallas. She leads a group called Affirm in nyc and is 
behind the jewish threats across the country." 

d. On February 20, 2017, at approximately 10:38 
p.m., the JCC in San Diego, California (the "San Diego JCC" ) 
received an email from Email Account-2 that stated: "(Victim-l's 
name and birthdate] hates Jewish people is the head of a ring 
and put a bomb in the center at [the San Diego JCC's address] to 
kill as many Jews asap. She is from Nyc and lived in San Diego 
before Nyc. Tomorrow. Ask her acquaintances she hates jews." 

JCC Threats in THOMPSON'S Name 


8. Based on my review of FBI reports, I have learned 
the following, in substance and in part: 

a. On or about January 28, 2017 the Jewish 
History Museum located in Manhattan received a bomb threat from 
Email Account- 2, which stated: "Juan Thompson put 2 bombs in the 
History Museum set to go off Sunday. [THOMPSON'S birthdate] ." 

A sweep of the Jewish History Museum was conducted by the NYPD 
and no bomb was found. 

b. On or about February 1, 2017, a Jewish 
school in Farmington Hills, Michigan received a bomb threat from 
Email Account-2 (the same email account that was later used to 
send a threat in Victim-l's name, see supra f 7(c)), which 
stated: "Juan Thompson [THOMPSON'S birthdate] put two bombs in 
your school last night. He is eager for Jewish newtown." Based 
on my training and experience, this email's use of the phrase 
"Jewish newtown" appears to refer to a December 2012 school 
shooting in Newtown, Connecticut, in which a gunman murdered 
twenty victims. 


c. On or about February 1, 2017, a Jewish 
school in Manhattan received two separate bomb threats from 
Email Account-2 ( see supra 7(c), 8(b)), within ten minutes of 
each other, which both stated: "Juan Thompson [THOMPSON'S 
birthdate] put two bombs in the middle school last night. He is 
eager to a Jewish newtown." 


4 Based on my review of law enforcement reports, I have 
learned, among other things, that Email Account-2 is an email 
address produced from a web-based, anonymous email generator. 


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d. On or about February 7, 2017 a JCC in 
Manhattan received a bomb threat from Email Account -2 ( see supra 
ft 7 (c) , 8 (b) - (c) ) , which stated: "Juan Thompson [THOMPSON' s 
birthday] put two bombs in the office of the Jewish center 
today. He wants to create Jewish newtown tomorrow. Look at his 
twitter [the Thompson Twitter Account, see infra f 9] ." 

9. Based on my review of publicly available portions 
of a Twitter Account that appears to be used by JUAN THOMPSON, 
the defendant (the "Thompson Twitter Account"), 5 I know that the 
Thompson Twitter Account recently posted the following messages 
regarding Victim-1: 

a. On or about February 24, 2017, the Thompson 
Twitter Account posted: "Know any good lawyers? Need to stop 
this nasty/racist #whitegirl I dated who sent a bomb threat in 
my name & wants me to be raped in jail." Embedded below the 
Twitter message are three paragraphs of text, which state, among 
other things, " [s] he [Victim-1], though I can't prove it, even 
sent a bomb threat in my name to a Jewish center, which was odd 
given her antisemitic statements. I got a visit from the FBI. 

So now I'm battling the racist FBI and this vile, evil, racist 
white woman." 


b. On or about February 26, 2017, the Thompson 
Twitter Account posted: "I'm been tormenting by an anti-semite 
[sic] named [Victim-1] . She works for Company-1. She sent an 
antijewish bom threat in my name. Help." 

c. On or about February 26, 2017, the Thompson 
Twitter Account posted: "The hatred of Jews goes across all 
demos. Ask NYC's [Company-1] . They employ a filthy anti-Semite 
in [Victim-1] . These ppl are evil." 

10. Based on my conversations with Victim- 1, I know 
that the above -described course of conduct has caused Victim-1 
substantial emotional distress. 


5 Among other things, the Thompson Twitter Account has a profile 
photograph of THOMPSON and a username that includes THOMPSON'S 
first and last name. Victim-1 has also advised me that Victim-1 
understands the Thompson Twitter Account to be used by THOMPSON. 

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WHEREFORE, deponent respectfully requests that a 
warrant be issued for the arrest of JUAN THOMPSON, the 
defendant, and that he be arrested and imprisoned or bailed, as 
the case may be . 



CHRISTOPHER MILLS 
Special Agent 

Federal Bureau of Investigation 


Sworn to before me this 
1st day of March, 2017 

. 

THE HONORABLE' SARAH NETBURN 

UNITED STATES MAGISTRATE JUDGE 
SOUTHERN DISTRICT OF NEW YORK 

!p yyftk ’ 


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