AO 91 Rev.

11/82

CRIMINAL COMPLAINT UNITED STATES DISTRICT COURT UNITED STATES OF AMERICA v. NAA ALPHA ONUOHA CENTRAL DISTRICT OF CALIFORNIA
DOCKET NO.

MAGISTRATE'S CASE NO.

Complaint for violation of Title 18, United States Code, Sections 1038(a) and 844(e).
NAME OF MAGISTRATE JUDGE

UNITED STATES MAGISTRATE JUDGE

LOCATION

Los Angeles, CA

PATRICK J. WALSH
DATE OF OFFENSE PLACE OF OFFENSE ADDRESS OF ACCUSED (IF KNOWN)

September 10, 2013

Los Angeles, California

773 S. Hindry Ave., 709A, Los Angeles, CA (last known)

COMPLAINANT'S STATEMENT OF FACTS CONSTITUTING THE OFFENSE OR VIOLATION:

On or about September 10, 2013, in Los Angeles County, within the Central District of California, defendant NAA ALPHA ONUOHA engaged in conduct with intent to convey false or misleading information under circumstances where such information may reasonably be believed and where such information indicates that an activity has taken, is taken, or will take place that would constitute a violation of Title 18, United States Code, Section 37 (Violence at International Airports), namely, that a person using a device, substance, or weapon, would destroy or seriously damage the facilities of LAX, an airport serving international civil aviation, or disrupt the services of the airport, in a manner that would endanger or likely endanger safety at the airport. On or about September 10, 2013, in Los Angeles County, within the Central District of California, defendant NAA ALPHA ONUOHA, acting in or affecting interstate commerce, used the telephone and other instruments of interstate and foreign commerce to willfully make a threat or to maliciously convey false information knowing the same to be false, concerning an attempt or alleged attempt being made, or to be made, to kill, injure, or intimidate an individual or unlawfully to damage or destroy a building or other real or personal property by means of fire or an explosive. BASIS OF COMPLAINANT'S CHARGE AGAINST THE ACCUSED:
(See attached affidavit which is incorporated as part of this Complaint) MATERIAL WITNESSES IN RELATION TO THIS CHARGE:

N/A
SIGNATURE OF COMPLAINANT

Being duly sworn, I declare that the foregoing is true and correct to the best of my knowledge.

DAVID GATES
OFFICIAL TITLE

Supervisory Special Agent Sworn to before me and subscribed in my presence,

SIGNATURE OF MAGISTRATE JUDGE(1) DATE

September 11, 2013 1) See Federal Rules of Criminal Procedure rules 3 and 54. AUSA Melissa Mills REC: DETENTION

A F F I D A V I T I, David Gates, being duly sworn, hereby depose and state the following: 1. I am a Special Agent of the Federal Bureau of

Investigation (FBI), and I have been so employed for over nine years. Since August 2004, I have been assigned to the Los

Angeles International Airport Office of the FBI, where I investigate violations of Federal law which occur within the airport environment and on board aircraft. 2. This affidavit is in support of a complaint charging

NNA ALPHA ONUOHA, (ONUOHA) with violating of Title 18, United States Code, Section 1038(a): False Information and Hoaxes; and Title 18, United States Code, Section 844(e): Threats Affecting Interstate Commerce; on September 10, 2013, at the Los Angeles International Airport (LAX), located in Los Angeles, California. 3. The facts set forth in this affidavit are based on my

personal observations, my training and experience, and information obtained from other law enforcement officers and witnesses. This affidavit is intended to show that there is

probable cause for the requested complaint and does not purport to set forth all of my knowledge or investigation into this matter. 4. Title 18, United States Code, Section 1038(a) prohibits

engag[ing] in any conduct with intent to convey false or

misleading information under circumstances where such information may reasonably be believed and where such information indicates that an activity has taken, is taking, or will take place that would constitute a violation of chapter 2 . . . of this title. 5. Chapter 2 of Title 18 includes Section 37: Violence at This section prohibits, in pertinent

International Airports.

part, the following conduct: destroy[ing] or seriously damag[ing] the facilities of an airport serving international civil aviation . . . or disrupt[ing] the services of the airport, if such an act endangers or is likely to endanger safety at that airport. 6. Title 18, United States Code, Section 844(e) prohibits

use of the mail, telephone, telegraph, or other instrument of interstate or foreign commerce, or in or affecting interstate or foreign commerce, willfully makes any threat, or maliciously conveys false information knowing the same to be false, concerning an attempt or alleged attempt being made, or to be made, to kill, injure, or intimidate any individual or unlawfully to damage or destroy any building, vehicle, or other real or personal by means of fire or an explosive. 7. As I explain below, I believe that ONUOHA violated 18

U.S.C. 1038(a) and 844(e) by the following actions: (a) immediately after resigning his employment with the Transportation Security Administration (TSA) at LAX on

September 10, 2013, leaving a sealed express-mail envelope at TSA headquarters at LAX addressed to a specified TSA manager; (b) calling the TSA checkpoint at Terminal 3 at LAX a few minutes after leaving the envelope to speak with the same specified TSA manager and, upon learning that the individual was unavailable, cautioning that only the specified individual should open the package that ONUOHA had left; (c) in the same phone call with TSA, advising that LAX should be evacuated immediately, starting with Terminal 2; (d) subsequently calling the TSA manager for whom he had left the envelope and stating that Terminals 2, 3, and 6 needed to be evacuated immediately, and that TSA was running out of time; and (e) calling LAX police and stating that they should evacuate the entire airport. 8. According to a TSA official, ONUOHA was employed as a From July 21, 2013, through July

TSA screener beginning in 2006.

27, 2013, ONUOHA was suspended from his employment as a TSA screener following an incident wherein he reportedly commented to a 15-year old girl that she should cover up. 9. On September 10, 2013, at approximately 9:00 a.m., at

TSAs LAX headquarters, ONUOHA resigned his position with TSA. 10. Several hours later, at approximately 12:45 p.m.,

ONUOHA returned to TSAs LAX headquarters and left a sealed express-mail envelope addressed to a TSA screening manager. 11. A few minutes after leaving the package, ONUOHA called

the TSA checkpoint at Terminal 3 at LAX.

ONUOHA told the

screener who answered the phone that he had left a package for the manager at TSA headquarters and that the manager should read it immediately because it was important. ONUOHA then stated that

he had visited Terminal 6 and Terminal 2, and that TSA should begin evacuating the airport, starting at Terminal 2. Because of

ONUOHAs strong accent, the screener asked ONUOHA to repeat that statement, which ONUOHA did. ONUOHA then told the screener that

he would be watching to see if TSA was evacuating the terminals as he had directed. The screener who took the call subsequently

told me that he believed that ONUOHA was conveying a bomb threat. 12. The envelope that ONUOHA left for the TSA manager was It did not

cleared by the bomb squad at approximately 2:00 p.m.

contain any explosives, powders, or other suspicious substances. The envelope contained an eight-page document entitled, The End of America, The End of satan, we were not defeated. The

document expressed ONUOHAs thoughts on the incident leading to his suspension. 13. A few minutes after 2:00 p.m. that same afternoon,

ONUOHA called the TSA manager to whom he had addressed the envelope. The TSA manager conferenced me into that phone call, I heard ONUOHA tell the

and I heard the last part of the call.

manager that Terminals 2, 3, and 6 needed to be evacuated immediately, and that TSA was running out of time. The TSA

manager subsequently told me that he believed that ONUOHA was conveying either a bomb threat or another threat of violence to the airport. The TSA manager told me that he believed the most

credible scenario was an active-shooter situation at the airport. 14. On the afternoon of September 10, 2013, ONUOHA called

the LAX police department and advised that they needed to evacuate the whole airport, starting with Terminals 2, 3, and 6, and that he was going to deliver a message to America and the whole world. 15. Agents went to ONUOHAs last known residence, a ONUOHA was not present

veterans housing complex in Los Angeles.

and the side of the shared room identified by the housing manager as ONUOHAs was completely empty, with all possessions having been removed. Taped to the closet door was a paper with the

following handwritten message: 09/11/2013 THERE WILL BE FIRE! FEAR! FEAR! FEAR! 16. After waiving his Miranda rights in a post-arrest

interview, ONUOHA told me that this paper meant that he intended to start preaching in the streets on September 11, 2013. 17. ONUOHA further told me that he did not intend for the

statements in the above-described calls to be threats, and that he had no intent to engage in any violent conduct. 18. Based on the foregoing, I believe there is probable

cause to believe that NAA ALPHA ONUOHA engaged in conduct with intent to convey false or misleading information under circumstances where such information may reasonably be believed and where such information indicates that an activity has taken, is taken, or will take place that would constitute a violation of Title 18, United States Code, Section 37 (Violence at International Airports), namely, that a person using a device, substance, or weapon, would destroy or seriously damage the facilities of LAX, an airport serving international civil aviation, or disrupt the services of the airport, in a manner that would endanger or likely endanger safety at the airport. ____________ _______________________ David Gates Special Agent-FBI

Sworn and subscribed to before me this 11th day of September, 2013.

____________________________________________________ UNITED STATES MAGISTRATE JUDGE