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Case
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AO 91' (Rev. 5/85) Criminal Complaint

United States District Court

NORTHERN DISTRICT OF TEXAS

UNITED STATES OF AMERICA

v.
ERLYNDON J. LO

CRIMINAL COMPLAINT

I, Lantre Conrad, hereinafter Complainant, being duly sworn, state the following is true and
correct to the best of my knowledge and belief:

On or about April 2, 2010, in the Northern District of Texas and elsewhere, Erlyndon
JosephLo, did knowingly transmit in interstate and foreign commerce a
communication containing a threat to injure employees and clients of the Southwestern
Women's Surgery Center in violation of 18 U.S.C.§ 875(c); and

On or about April 2, 2010, in the Northern District of Texas and elsewhere, Erlyndon
Joseph Lo, by threat of force, knowingly and intentionally attempted to intimidate and
interfere.with, the clients and employees of the Southwestern Women's Surgery
Center, a facility that provides reproductive health services, because the employees of
Southwestern Women's Surgery Center were and had been providing reproductive
health services, and in order to intimidate the clients and employees of Southwestern
Women's Surgery Center from obtaining and providing reproductive health services in
violation of 18 U.S.C. § 248(a)(I). '

1. Complainant is a Special Agent of the FBI. I have been so employed for approximately
six years and,am currently assigned to the Dallas Field Division's Civil Rights Squad. I was a
deputy with the Harris County Sheriffs Office in Harris County, Texas for eleven years and was,
employed as a guard with the Texas Department of Corrections for two years.

2. The statements contained in this Complaint are based, in part, on my personal

observations and on information provided by other Special Agents of the FBI, Deputies with the
United States Marshal Service, officers with the Plano Police Department and Dallas Police
Department and other law enforcement agencies. Statements herein are also based on infonnation
provided, by witnesses believed by me to be reliable and credible, my review of public filings and
electronic communications, and on my experience and training.

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3. Southwestern Women's Surgery Center"(SWSC) is located in Dallas, Tex~ in the

Northern District of Texas. SWSC provides reproductive health services as defined in 18 U.S.C. §
248(e)(5).

4. The Plano Courthouse for the Sherman Division of the United States Courts for the
Eastern District of Texas is located at 7940 Preston Road in Plano, Texas, in the Eastern District of
Texas. The United States District Clerk's Office is located in the courthouse. Unless filed under
seal , all matters filed with the clerk's office are made electronically available to the public on the
internet via the CMJECF and Pacer filing systems.

5. Defendant Erlyndon Joseph Lo (Lo) resides at 3504 Nancy Court in Plano, Texas in
the Eastern District of Texas.

6.· On April 2, 2010 at approximately 8:13 a.m. CST, Lo walked into the United States
District Clerk's Office in the Plano Courthouse and filed a document styled Erlyndon J. Lo v.
Roberts, et al. and entitled "Motion for an Immediate Temporary Restraining Order ('TRO'),.
Seeking a Preliminary and Pennanent Injunction." (A copy of the filing is attached as Exhibit 1).
The TRO seeks to have the district court declare abortion illegal in the Un~ted States. Lo's motion
contains the following statements:
" .
"My life is at stake. I could be MURDERED AND KILLED as early as Friday, April 2,
2010 at 12:00 p.m. NOON in Dallas, Texas ('TX') if you do not IMMEDIATELY GRANT MY
REQUEST for in the very least a TEMPORARY RESTRAINING ORDER!!!"

"I plan on saving a least one human life in Dallas, Texas at 12:00 p.m. at the Southwestern
late-tenn abortion facility, 8616 Greenville Ave. at Royal Ln. (NE comer), Dallas 75243."

"My religious beliefs include the beliefs that an individual is alive at the moment of
conception, abortion is murder and is the worst murder of all murders possible because these babies
are completely defenseless, and I am entitled under my religious beliefs to use deadly force if
necessary to save the innocent life of another."

"[Specific facts: ON FRIDAY, APRIL 2, 2010, TOMORROW, I WJLL BEAT

SOUTHWESTERN LATE-TERM ABORTION FACILITY LOCATED AT 8616 Greenville Ave.
at Royal Ln. (NE comer), Dallas 75243, I will try to stop an abortion using oral words, and if words
are not enough. I will use physical force if necessary, and if anyone tries to physically "stop me, I
will overcome that force, and if I must use deadly force to defend the innocent life of another
human being, I will."

7. Approximately three weeks prior to Lo's filing of the TRO, a male matching the
general description ofLo went to SWSC alone with a receipt, claiming that he wanted to find out if
his wife had an abortion. After asking the male several questions, SWSC employees told the male
that they could not' give out any information about services or even whether a particular person was
a patient.

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8. Lo maintains a website at www.erlyndon.com.. (A hard copy of the written content

of the website is attached as Exhibit 2) On his website, Lo claims that he graduated from law
school at Southern Methodist University and has taken the New York Bar Exam. Lo also states
that law school "really broke him. n Lo's website contains an extensive discussion on abortion,
including a hypothetical in which President Obama's wife is raped. Lo also specifically references
the lawsuit he filed in he Eastern District of Texas on his website, stating: "I sued John Roberts, the
Chief Justice of the United States Supreme Court. The case is pending. The "CAUSE NO:" is
4:10cvl19... , The "CAUSE STYLE: n is ERLYNDON J. LO V. ROBERTS, ET AL. (This is a
class action lawsuit, with me versus the 9 members of the Supreme Court)." Lo, further references
the lawsuit in stating, "JUDGE RICHARD A. SCHELL WILL BE PREISIDING. IF HE
COOPERATES WITH rvlli, TOGETHER HE AND I WILL PERMANENTLY AND
EFFECTIVELY END MURDER/ABORTION FOREVER WITHIN 1 YEAR." Lo further states
on his website that "[i]t is MY SINCERE AND DEEPLY HELD religious belief (from now on
"religious belief') that when I am completely innocent, in order to defend or 'protect myself or my
own life, I may use necessary force, and I also may use necessary force to protect or defend the life
of an innocent third person, even if that force happens to be deadly."

9. " Lo's website and the U.S. District Court Pacer filing system can be accessed by
clients and employees oftheSWSC and others in the Northern District of Texas and elsewhere.

10. Lo made" frequent visits to the Plano Courthouse in the weeks preceding the filing of
his motion for a TRO. During these visits, Lo exhibited erratic behavior including .raising his voice
at members of the clerk's office, obsessively washing his hands in the public restrooI\1 and sitting in
a court witness room in the dark without authorization to enter the room. Lo also attempted to and
did speak with members of the court. Lo provided his resume to courthouse staff. Lo provided
information that he was an intern or volunteer clerk for a United States Bankruptcy Judge in the
Northern District of Texas. Lo's internship with a United States Bankruptcy Judge in the Northern
District of Texas was confmned. Case filings in the Northern District of Texas are also available
and accessible to the public on the internet via the CMlECF and Pacer filing systems. Based on
Lo's background as a law stUdent and an intern for a United States Bankruptcy Judge in the
Northern District of Texas, he knew or had reason to know that his filings would be placed on the
internet and that his specific threat to use deadly force if necessary fo stop an abortion at the SWSC
located at 8616 Greenville Ave. at Royal Ln. (NE corner), Dallas 75243 at 12:00 p.m. on Friday,
April 2, 2010 would be accessible to clients and employees of SWSC and others.

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11. In response to Lo's threat, to be carried out as early as 12:00 p.m. on April 2, 20 I0,
that he knew or had reason to know would be posted on the internet, multiple law enforcement
agencies were contacted, and those agencies responded, including the United States Marshal
Service, Federal Bureau of Investigation, Plano P.olice Department, and the Dallas Police
Department. Those agencies. responded to the SWSC in Dallas, Texas before 12:00 p.m. on Friday
and provided and continue to provide protection and monitoring of the facility in response to he
- threat. .

~c::::=0?
Lantre Conrad, Special Agent,
Federal Bureau of Investigation

Sworn to before me and subscribed in my presence, A ril5

2008, at Dallas, Texas, at / /)() o'clock,j.m.

Paul D. Stickney
UNITED STATES MAGISTRATE JUDGE