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edward lang affidavit in support of criminal complaint and arrest warrant PDF

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA : Case No: : : UNITED STATES OF AMERICA : VIOLATIONS: : v. : 18 U.S.C. § 111(b) (Assaulting, resisting, or impeding certain : officers or employees) : EDWARD JACOB LANG : 18 U.S.C. § 231(a)(3) : Defendant. (Civil Disorder) : : 18 U.S.C. § 1752(a) : (Restricted Building or Grounds) : : 40 U.S.C. § 5104(e)(2) : (Violent Entry or Disorderly Conduct) AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT AND ARREST WARRANT I, LaNard Taylor, Special Agent with the Federal Bureau of Investigation (“FBI”), being duly sworn, deposes and states under penalty of perjury that the following is true to the best of my information, knowledge and belief. PURPOSE OF AFFIDAVIT 1. This Affidavit is submitted in support of a Criminal Complaint charging EDWARD JACOB LANG (“LANG”) with violations of 18 U.S.C. §§ 111(b), 231(a)(3), 1752(a) and 40 U.S.C. § 5104(e)(2). Specifically, on or about January 6, 2021, LANG traveled to Washington, D.C., and knowingly and willfully joined a crowd of individuals who forcibly entered the grounds of the United States Capitol and impeded, disrupted, and disturbed the orderly conduct of business by the United States House of Representatives and the United States Senate. AGENT BACKGROUND 2. I have been a Special Agent with the FBI since June 2016. I am presently assigned to the Washington Field Office’s International Corruption Squad, where I am responsible for investigating Antitrust, Foreign Corrupt Practices Act, and Kleptocracy violations. I was previously assigned to the FBI’s Los Angeles Field Office, where I was responsible for investigating public corruption, fraud against the government, violent crime, narcotics offenses, and a host of other violations of federal law. Prior to my employment with the FBI, I was a law enforcement officer in the State of Florida for four years, where I investigated crimes relating to fraud, narcotics, violent crimes, and a variety of other criminal acts. 3. I am one of the agents assigned to an ongoing investigation by the FBI, United States Capitol Police (“USCP”), Metropolitan Police Department (“MPD”), and other law enforcement agencies, of riots and civil disorder that occurred on January 6, 2021, in and around the United States Capitol grounds. Since I became involved in this investigation on January 6, 2021, I have conducted interviews, reviewed public tips, reviewed publicly available photos and video, and reviewed relevant documents, among other things. 4. The facts in this affidavit come from my review of the evidence, my personal observations, my training and experience, and information obtained from other agents and witnesses. Except as explicitly set forth below, I have not distinguished in this affidavit between facts of which I have personal knowledge and facts of which I have hearsay knowledge. This affidavit is intended to show simply that there is sufficient probable cause for the requested arrest warrant and does not set forth all of my knowledge about this matter. BACKGROUND 5. On January 6, 2021, a joint session of the United States Congress convened at the United States Capitol, located at First Street Southeast, Washington, District of Columbia. During the joint session, elected members of the United States House of Representatives and Senate met in the United States Capitol to certify the vote count of the Electoral College for the 2020 Presidential Election, which took place on November 3, 2020. 6. The United States Capitol is secured 24 hours a day by security barriers and USCP occupy various posts throughout the grounds. Restrictions around the United States Capitol include permanent and temporary security barriers and posts manned by USCP. USCP officers wore uniforms with clearly marked police patches, insignia, badges, and other law enforcement equipment. Only authorized people with appropriate identification are allowed access inside the United States Capitol. On January 6, 2021, the exterior plaza of the United States Capitol was also closed to members of the public. 7. The January 6, 2021 joint session began at approximately 1:00 p.m. Shortly thereafter, by approximately 1:30 p.m., the House and Senate adjourned to separate chambers to resolve a particular objection. Vice President Michael R. Pence was present and presiding, first in the joint session, and then in the Senate chamber. 8. As the proceedings continued in both the House and the Senate, and with Vice President Pence present and presiding over the Senate, a large crowd gathered outside the United States Capitol. As noted above, temporary and permanent barricades were in place around the exterior of the United States Capitol building and USCP were present, attempting to keep the crowd away from the Capitol building and the proceedings underway inside. As the certification proceedings were underway, the exterior doors and windows of the Capitol were locked or otherwise secured. 9. At approximately 2:00 p.m., certain individuals in the crowd forced their way through, up, and over the barricades, and past officers of the USCP, and the crowd advanced to the exterior façade of the building. The crowd was not lawfully authorized to enter or remain in the building and, prior to entering the building, no members of the crowd submitted to security screenings or weapons checks by the USCP or other authorized security officials. 10. A short time later, at approximately 2:20 p.m., members of the United States House of Representatives and United States Senate, including the President of the Senate, Vice President Pence, were instructed to—and did—evacuate the chambers. As such, all proceedings of the United States Congress, including the joint session, was effectively suspended until shortly after 8:00 p.m. the same day. In light of the dangerous circumstances caused by the unlawful entry to the United States Capitol, including the danger posed by individuals who had entered the United States Capitol without any security screening or weapons check, Congressional proceedings could not resume until after every unauthorized occupant had left the United States Capitol, and the building had been confirmed secured. The proceedings resumed at approximately 8:00 pm after the building had been secured. Vice President Pence remained in the United States Capitol from the time he was evacuated from the Senate Chamber until the sessions resumed. 11. After the Capitol was breached, USCP requested assistance from MPD and other law enforcement agencies in the area to protect the Capitol, keep more people from entering the Capitol, and expel the crowd that was inside the Capitol. Multiple MPD officers and other law enforcement officers came to assist. 12. During national news coverage of the aforementioned events, video footage which appeared to be captured on mobile devices of persons present on the scene depicted evidence of violations of local and federal law, including scores of individuals inside the United States Capitol building without authority to be there. STATEMENT OF FACTS SUPPORTING PROBABLE CAUSE 13. Beginning on or about January 7, 2021, the investigative agencies began receiving tips from the public related to the civil unrest and breach of the United States Capitol and multiple identified LANG as being involved. The tips included photographs of LANG on the grounds of the Capitol on January 6, 2021. At least one photograph, shown below, identified Instagram @realjakelang (the “Subject’s Instagram”) as the account used by LANG. The photograph appears to have been posted at some point during or after the attack on the Capitol, and depicts LANG wearing a black jacket with numerous silver zippers and a ribbed pattern on the shoulders, standing on the steps of the Capitol. LANG captioned the photograph, is “1776 has commenced.” 14. On January 9, 2021, the FBI interviewed witness 1 (“W1”) who identified LANG as a person involved in the riot at the Capitol. W1 met LANG when they were children and has maintained a social media connection with him in excess of ten years. W1 provided photographs and video of LANG actively participating in the attack on the Capitol. W1 identified www.facebook.com/JAKExLANG as the account belonging to LANG, which was consistent with the Facebook account attributed to LANG by investigators. 15. W1 also provided April 7th as a potential birth month and day for LANG and believed LANG was born in either 1995 or 1996. Law enforcement agents retrieved a driver’s license photograph of LANG, a resident of New York, DOB , and asked W1 if IT recognized the person in that photograph. W1 confirmed that the person in the photograph was LANG. 16. W1 also provided the below photograph of LANG, which was posted to LANG’s Facebook page, and an accompanying video showing him and a large crowd at the lower west terrace door of the Capitol on January 6, 2021. 17. Additional photographs provided by W1 from LANG’s Facebook page included more references to LANG’s participation in the attack on the Capitol - such as the following: 18. Based on my training and experience, I understand that Instagram account holders can post photographs, videos and temporary stories, among other things. Photographs and videos posted to the user’s account remain displayed indefinitely, unless intentionally deleted by the user or Instagram, while stories automatically vanish after 24 hours. 19. Between on or around January 6, 2021 and the present, the Subject’s Instagram posted several stories, videos, and pictures depicting the riot that occurred at the Capitol. Some of the depictions are described below in greater detail. 20. On or about January 7, 2021, LANG posted a photograph on the Subject’s Instagram, which tagged the location as “Capitol Hill” and showed LANG smiling and wearing a blue and white floral-patterned shirt, which matches the shirt in the still shot from the video referenced above. The caption read, in part, “Pepper spray really does wonders for your complexion #1776.” The photograph, shown below, appeared to be taken on the Capitol grounds and the images in the background are consistent with known images of the Capitol breach. 21. On or about January 8, 2021, LANG posted a video on the Subject’s Instagram, which appeared to be a compilation of multiple videos with the caption “GIVE ME LIBERTY OR GIVE ME DEATH.” The video depicted the following two moments: a. The video initially showed LANG in a crowd saying “I ain’t done yet.” LANG wore a black leather jacket with a blue floral-patterned shirt underneath, consistent with the ones depicted and pictured in paragraphs 12, 15, and 19. b. As the video progressed, another video included in the compilation showed an individual consistent with LANG with a green gas mask on and the same black jacket and blue floral-patterned shirt underneath. LANG appeared to film himself directly in front of law enforcement personnel and to be pointing at them.

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Most books are stored in the elastic cloud where traffic is expensive. For this reason, we have a limit on daily download.