Criminal Complaint UNITED STATES DISTRICT COURT for the Western District of Michigan
Case 1:20-mj-00416-SJB ECF No. 1 filed 10/06/20 PageID.1 Page 1 of 1 AO 91 (Rev. 11/11) Criminal Complaint UNITED STATES DISTRICT COURT for the Western District of Michigan United States of America ) v. ) Adam Fox, Barry Croft, Ty Garbin, Kaleb Franks, ) Case No. Daniel Harris and Brandon Caserta ) 1 :20-mj-416 ) ) ) Defendant(s) CRIMINAL COMPLAINT I, the complainant in this case, state that the following is true to the best of my knowledge and belief. On or about the date(s) of June 2020 to the present in the county of Kent and elsewhere in the Western District of Michigan , the defendant(s) violated: Code Section Offense Description 18 U.S.C. § 1201(c) Conspiracy to commit kidnapping This criminal complaint is based on these facts: ,/ Continued on the attached sheet. 4-;:If} aznant ..s signature RICHARD TRASK, Special Agent Printed name and title Sworn to before me and signed in my presence. October 6, 2020 Date: -----~ --- City and state: Grand Rapids, Michigan Sally J. Berens, U.S. Magistrate Judge Printed name and title Case 1:20-mj-00416-SJB ECF No. 1-1 filed 10/06/20 PageID.2 Page 1 of 15 CONTINUATION OF A CRIMINAL COMPLAINT I, Richard J. Trask II, being first duly sworn, hereby depose and state as follows: 1. I am a Special Agent with the Federal Bureau of Investigation (FBI), and have been since April 2011. As a Special Agent with the FBI, I have participated in, and conducted numerous investigations under the Domestic Terrorism, Counterterrorism, and Counterintelligence programs, to include espionage, terrorism, and domestic extremism investigations.
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