Filing of This Complaint
APPROVED: ____________________________________________________ SAMUEL S. ADELSBERG / MATTHEW HELLMAN / SIDHARDHA KAMARAJU Assistant United States Attorneys BEFORE: THE HONORABLE STEWART D. AARON United States Magistrate Judge Southern District of New York 20 MAG 5884 - - - - - - - - - - - - - - - - - - - - - - x : SEALED COMPLAINT UNITED STATES OF AMERICA : : Violations of - v. - : 18 U.S.C. §§ 956, : 1114, 1117, 2339A, ETHAN PHELAN MELZER, : 3238, and 2 a/k/a “Etil Reggad,” : : Defendant. : : - - - - - - - - - - - - - - - - - - - - - - x STATE OF NEW YORK ) COUNTY OF NEW YORK : ss.: SOUTHERN DISTRICT OF NEW YORK ) FAYE STEPHAN, being duly sworn, deposes and says that she is a Special Agent of the United States Air Force (the “Air Force”), currently assigned to the New York Joint Terrorism Task Force (the “JTTF”) as a Task Force Officer, and charges as follows: COUNT ONE CONSPIRACY TO MURDER U.S. MILITARY SERVICE MEMBERS 1. In or about May 2020, in an offense begun and committed outside of the jurisdiction of any particular State or district of the United States, ETHAN PHELAN MELZER, a/k/a “Etil Reggad,” the defendant, and others known and unknown, at least one of whom is expected to be first brought to and arrested in the Southern District of New York, knowingly and intentionally combined, conspired, confederated, and agreed together and with each other to violate Section 1114 of Title 18, United States Code. Page 1of 19 2. It was a part and an object of the conspiracy that ETHAN PHELAN MELZER, a/k/a “Etil Reggad,” the defendant, and others known and unknown, would and did kill and attempt to kill an officer and employee of the United States -- which killing is murder as defined in Title 18, United States Code, Section 1111(a) -- including any member of the uniformed services, while such officer and employee was engaged in and on account of the performance of official duties, and any person assisting such an officer and employee in the performance of such duties and on account of that assistance.
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