Case 0:16-mj-06390-LSS Document 1 Entered on FLSD Docket 09/06/2016 Page 1 of 7

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1/111 Crimie CGnple t

U N ITED STATES D ISTRICT C OURT

forthe

Southern DiseictofFlotida

United StattsofAmerica
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Crai
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rth

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CRIM INAL CO M PLAINT

thetomplainantinthiscase,statqthatthefollowing istruetothebestofmy knowledgeandbelief.

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autthedatets)of
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inthecountyof - -.- Broward

,thedetkndantts)violated:

C# eSectloa

U.S.C.675(c)

- inthe

OjjknseDescription
Threatening C'ommunlcations. The defendantdid knowinglytransmitin

inteotat:coYmercea communio tioncontai

ning athfealto injure the person
ofanoth6r.

n iscrimlnalomplaintisbased onthesefc$%:
jthed amdavit

# conunua ontlw attacedsheet.

tomplutnantsxlgno/lfz'e

Ellsa FrancesGermano.U.S.SecretServi (JTTF)

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Case 0:16-mj-06390-LSS Document 1 Entered on FLSD Docket 09/06/2016 Page 2 of 7

AFFIDAVIT IN SUPPORT OF CRIM INAL COM PLAINT

1,ElisaFrancesGerm ano,being duly sworn, deposeand state the following:
1am a SpecialAgent with the United States Secret Service and have been so

employed since February 2010.1 am currently assigned to the M inm iDivision of the Secret
Service, specifically to the M iami Joint Terrorism Task Force with the Federal Bureau of

Investigation(FB1).
2.

The information contained in this Complaintisbased on m y personalknowledge

and on information obtained from other sources, including:a)statementsmade orreported by

variouswitnesseswith knowledge ofrelevantfacts, including otherlaw enforcem entpersolmel;

b)my review ofpublicly available information relating tothedefendants;and c)my review of

records and otherdocum entsand evidence obtained through Courtorders, subpoenas and other

sources. Because this Complaint is being submitted for the lim ited purpose of establishing
probable cause, l have not included each and every fact known to me concem ing this
investigation. lhave setforth only the facts which lbelieve are necessary to establish probable
causeand havenotsetforth allofm y knowledge aboutthism atter.
This affidavitis submitted in supportofa erim inal complaintcharging thaton

August30,2016,Craig Allen Jungwirth (JUNGW IRTH)did knowingly transmitin interstate

commerce a communication containing athreatto injuretheperson ofanother,in violation of
Title18,UnitedStatesCode,Section 875(c).
Backeround of lnvestitation

4.

On August30,2016,theFederalBureau oflnvestigation (FBl),M iamiDivision

wasnotified by locallaw enforcem ent,otherFBlfield offices,and mem bersofthepublicviathe

public tip line,that alarm ing tlzreats tow ards the gay com m tm ity located w ithin W ilton M anors,

Case 0:16-mj-06390-LSS Document 1 Entered on FLSD Docket 09/06/2016 Page 3 of 7

FL had been posted on Facebook.

Specifically,on oraboutAugust30, 2016,an individualbearing the screen nam e
tscraig Jungwirth''posted the following,;tM y eventsare selling outcause you faggots are total
patsies.None ofyou deserve to live.Ifyou losersthoughtthe Pulse nightclub shooting wasbad,
waittillyou seewhatI'm plnnning forLaborDay.''Jungwirth then posted,dtYou can nevercatch

a genius from M 1T and since you faggots aren't dying from AIDS anym ore, l have a better
solution to exterminate you losers.'' Jungwirth finally posted, il'm gonna be killing you fags
fasterthan cops killniggers.It's tim e to clean up W ilton M anors from a11you AID S infested
losers.''

6.

On June 12,2016,OmarM ateen,a 29-year-old individual, killed 49 people and

wounded 53 othersin an attack inside the Pulse nightclub, a gay nightclub in Orlando,Florida.

Ultimately,hewasshotand killed by Orlando Police Department(OPD)officersafterathreehourstandoff. Itwasthe deadliestm assshooting by a single shooterand the deadliestincident

ofviolence againstlesbian,gay,bisexual,and transgender (LGBT) people in United States

history,and the deadliest attack in the United States since the Septem ber 11, 2001 terrorist
attacks.

On August30th, 2016, craig JUN GW IRTH w asidentified by the W ilton M anors

Police Department as a known individualand past city residentwho had previously been the

subject of numerous complaints involving the harassment and stalking of W ilton M anors
residents. Based upon the abovereferenced postsand the fearcreated within the W ilton M anors
LGBT comm unity,both the W ilton M anorsand Ft.Lauderdale police departments imm ediately
increasedtheirpatrolsofthe community andwereplaced on heightened alert.
8.

Using open source and investigative databases, on August

2

2016,

Case 0:16-mj-06390-LSS Document 1 Entered on FLSD Docket 09/06/2016 Page 4 of 7

lnvestigatorsidentifed 8333 CitrusChaseDrive, Orlando,FL 32836,astheaddressbelongingto

JUN GW IRTH'Sm other,M arynnn T. Jtm gwirth.
On August 31,2016, JUN GW IRTH was located walking outside 8333 Citrus
Chase Drive,Orlando,FL 32836 by a SpecialAgentwith the FBl and a Detective with the
Orlando Police Depm ment. JUNGW IRTH was asked if he knew why investigators were

prtsent, and JUN GW IRTH answered that he did not. As investigators moved to show
JUN GW IRTH a copy of the threats made on Facebook, JUNGW IRTH refused to read the
Facebook statem ents and stated thathe denied posting those threats, before investigators even
had an opportunity to show him the plzrported threats. JUN G W IRTH then refused to speak
furtherwith Agentsand requested thatthey contacthislawyer.
10.

On August31,2016,investigatorsidentified a 1998 Ford Utility vehicle, bearing

Florida license plate 362RLP,parked acrossthe streetfrom 8333 Citrus Chase Drive, Orlando,
32836. According to the State of Florida Driver and Vehicle Infonnation Database,

(DAVID),thisvehidewasregisteredtoCraigJUNGW IRTH onDecember8,2015.

Thereafter, on September 1, 2016, a subpoena was issued to Facebook for
subscriberinformation forthe Facebook accountofdcraig Jungwirth,''bearing accountnum ber
743595083,the source ofthe threatening com munications. Facebook responded and provided
documentation thatthe Facebook page was registered on February 18, 2007, under the nam e

Craig JUNGW IRTH. M oreover, the email addresses lEcraigungwihh@facebook.com'' and

icraigiungwidh@ alum.mit.edu''were listed as registered emailaccotmtsassociated with the
JUNGW IRTH Facebook page. Facebook also disclosed thaton August 30,2016, dtlring the
tim esthe threatswere posted,thatthe userlogged onto Facebook utilizing an electronic device

associated with internet protocol (IP) addresses of 97.101.149.33 and 97.101.171.6.

3

Case 0:16-mj-06390-LSS Document 1 Entered on FLSD Docket 09/06/2016 Page 5 of 7

lnvestigation furtherrevealed thatthese IP add

resses were owned by BrightHouse N etworks,
LLC. M oreover, investigators confirm ed that JUN GW IRTH h
ad in fact attended M lT as
claim ed in both thethreatening postsand asindi
cated in theFacebook registered em ailsedion of
thesubscriberinformation wherein the emailadd
resscraig- jungwi
rth@alum.mit.edu waslisted.
On Septem ber 1, 2016, TFO Elisa Germ ano and another FB1 ag
ent reviewed
multiple incident/investigation reports provided by th
e W ilton M anors Police Departm ent

regarding Craig JUNG W IRTH . M ultiple complaints for stalking and harassing beh
avior w ere
docum ented,aswellasincidentsofsabotage, vandalism ,and trespassing
.

13.

On September 1, 2016, TFO Elisa Germ ano and another FBI

agent also
interviewed the Ownerand a GeneralM anagerofa W ilton M anorsnightclub. Both individuals

stated thatthey havehad interaction with Craig JUNGW IRTH and thathe has previously acted
in an aggressive m anner. They stated that JUNGW IRTH advertises him self as an eventand
party prom oterin W ilton M anors and has a history of attempting to get what JUNGW IRTH
perceives as dtcom peting events''shutdown. They stated thatthey have increased security over
the pastfew m onths as a directresultofJUNGW IRTH , and thateveryone on theirrespective
staffs have been m ade aware of JUNGW IRTH . M oreover, they stated that JUN G W IRTH 'S
Facebook profile picture was being used without perm ission and was actually the photo ofa
friend oftheirswho worksasaDJin the M inmiarea.
On Septem ber 1, 2016, TFO Elisa Germ ano and another FB1 agent also

interviewed an individualwho had previously filed a complaintwith the W ilton M anors Police
Department against Craig JUN GW IRTH for harassment. They stated thatthe harassing calls
began following a personal,non-work-related dispute betw een JUNGW IRTH and a form er
employee of theirs.They stated that they had received hundreds of calls from JUN GW IRTH
4

Case 0:16-mj-06390-LSS Document 1 Entered on FLSD Docket 09/06/2016 Page 6 of 7

threatening to shutdown theirbusinessdue to the personaldispute between JUNGW IRTH and

their employee.They stated thatJUNGW IRTH had posted multiple negative review s on their
business website using m ultiple identities in an attem ptto ruin their business and its reputation.
They also stated that al1of his fake profiles utilized the sam e language and threats and thatthey

feared fortheirpersonalsafety based on hisaggressive and threatening dem eanorasthey worked

alonein the businesson multipleoccasions.
15.

On Septem ber 1, 2016, TFO Elisa Germ ano and another FBI agent also

interview ed one ofthe individuals w ho had notified the W ilton M anors Police D epartm entofthe

threatening Facebook post. Thecom plainantconfirm ed the inform ation they had provided in the
originalcomplaint,and stated thatthey have filed and attempted to fle m ultiple reportswith the
W ilton M anors Police Depm ment,including one thatultim ately resulted in the issuance of a
restraining order against JUN G W IRTH on July 12,2016. The Com plainant stated that in the

past several months, they had received thousands of tllreatening text m essages, Facebook
m essages,and phone calls from JUN GW IRTH,many tim es with JUNGW IRTH stating dsl'm

goingto getyou.''ThecomplainantstatedthatJUNGW IRTH hasm ultiple Facebook profilesand

has used multiple phone nllmbers in the past. ln addition, the complainant stated that

JUN GW IRTH had utilized several other harassing techniques including creating false online
profilesin thecomplainantsnameand likeness,threateningthecomplainantsfnmily and business
relations, and falsely providing the complainants information to the police as a danger to
themselves or others.The com plainantstated thatdue to JUN GW IRTH,they feared for their
physicalsafety.
16.

On September2,2016,a subpoena was issued to BrightHouse Networks,LLC.,

for subscriber inform ation associated w ith IP addresses 97.101.149.33 and 97.101.171.6

Case 0:16-mj-06390-LSS Document 1 Entered on FLSD Docket 09/06/2016 Page 7 of 7

provided by Facebook as the IP

addresses tiom which the th

reatening eomm unications
origiaated. BrightHouse Networksrcspond
ed.and providtd documentationth
atthe accountwas
registee on Febrtlary 8. 2003 to Mary Jullg
wirth,and that01)rclevantdatesand ti
mesbetween
August29.1016 22:07:31t)1'C and A
ugust30.2016 18:33:17 tJ'I'
C. IP addressqs97.
101.149.33
and 97.101.171-6 we> assigned to the service addre
ssof2333 Cittus Chnqe Drive, Orlando,FL
32836.Aspxviously m entioA
ed,this location isowned by M aryann Jun
gwirth,and iscunvntly
the homeaddressofCY g Allvn JUNGW IR
TH.
.

Bacebook hascoaflrm ed thatth

ey do nothaveany computerdata centerslocated
in lbe State ofFloridw a
ndth tal1communicationsthatoriginated in thiscasetraveled through

oneifnotmore outofstatetatacent

erspriorto reaching theirultim ate destination in W ilton

M o ors.Blodda. n erefore,t:e comm unicationsnecessaril

y traveled in interstatecommerce.

conclusion

18.

B> ed upon thv foregoing, your Afflantsubmitsthatiert isprobable cause to

belleve thaton oraboutAugo t30, 2016,Craig Allen JUNGM RTH did knowingly transm iti

inlemfmte comm erce a comm unication containing

a threatto injure the person ofanother, in

dolauon ofTitle 18, UnitedSktesCode,Section#75(c)
.

FURTRER YOUR W/WM NFXVW YETH NA UGH T

ElisaGemmno
FederalBurtau oflnvestigation

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