AFFIDAVIT OF SPECIAL AGENT RYAN D, MCGONIGLE
IN SUPPORT OF CRIMINAL COMPLAINT
I, RYAN D. MCGONIGLE, being duly sworn, depose and state as follows:
1 Tam an “investigative or law enforcement officer of the United States” within the
meaning of 18 U.S.C. § 2501(7), and am empowered by law to conduct investigations of, and to
make arrests for, offenses enumerated in 18 U.S.C. § 2516.
2. Lama Special Agent with the Federal Bureau of Investigation (“FBI") assigned to
the Boston Division, Springfield Resident Agency, in Springfield, Massachusetts, having been so
employed since 2017. As an FBI Special Agent, I am responsible for the investigation of federal
criminal offenses. I have completed the FBI Basic Field Training Course in Quantico, VA. Since
2017, I have been assigned to a national security squad and work on the FBI’s Joint Terrorism
Task Force (“ITTF”) to investigate international and domestic terrorism matters. In this regard, 1
routinely work with agents and officers with dozens of years of experience investigating crimes
involving terrorism and national security violations.
3. As an FBI Special Agent, I have conducted and participated in criminal
investigations, witich have resulted in arrests for numerous crimes including child exploitation,
controlled substance violations, and financial crimes. I have personally been involved in the
execution of state and federal search and arrest warrants, which have led to the arrest and
conviction of many individuals.
4. Prior to joining the FBI, I obtained my law degree from Suffolk University Law
School, in Boston, Massachusetts in 2011, From 2012 through 2015, 1 worked with the United
States Citizenship and Immigration Service. From 2015 through 2017, | worked as an Assistant
Chief Counsel for Immigration and Customs Enforcement
5. make this affidavit in support of an application for a Criminal Complaint chargingKevin A. Johnson (“JOHNSON”) with conveying false information and hoaxes, in violation of
Title 18, United States Code, Section 1038, and mailing threatening communications, in violation
of Title 18, United States Code, Section 876(¢)..
6. Title 18, United States Code, Section 1038 makes it i
legal for any person to
engage:
in any conduct with intent to convey false or misleading information under
circumstances where such information may reasonably be beli
where such information indicates that an activity has taken, is taki
take place that would constitute a violation of chapter...10 [biological
weapons], 11B [chemical weapons]
1. Title 18, United States Code, Section 876(c) prohibits any person from knowingly
depositing or causing “to be delivered...any communication” that contains a threat to injure or
kidnap any person.
8 As described in detail below, I have probable cause to believe, and do in fact
believe, that beginning on or about July 23, 2018, and continuing to on or about November 13,
2018, JOHNSON engaged in conduct with intent to convey false and misleading information.
Specifically, I have probable cause to believe that JOHNSON mailed an envelope containing a
‘demeaning and threatening communication and white powder, under circumstances where such
information could reasonably have been believed, that indicated that an activity had taken, was
taking, and would take place, namely that the powder was Anthrax and could hurt those exposed
to it, that would constitute a violation of Title 18, United States Code, chapter 10, which relates to
biological weapons, including Anthrax, in violation of Title 18, United States Code, Section
1038(a)(1)(A).
Further, have probable cause to believe, and do in fact believe, that beginning on
or about July 23, 2018, and continuing to on or about November 13, 2018, JOHNSON knowinglydeposited in an auth
ed depository for mail matter, to be sent and delivered by the Postal
Service, a communication containing a threat to injure the person of another, for the purpose of
issuing a threat and knowing that it would be interpreted as a threat, in violation of Title 18, United
States Code, Section 876(c).
10. The information contained in this affidavit is based upon my own investigation and
information provided to me by other law enforcement officers. Where conversations or statements
of others are related herein, they are related in substance and in part. Moreover, because this
affidavit is submitted for a limited purpose, I have not set forth every fact that I have leamed in
the course of the investigation.
PROBABLE CAUSE
11, Between on or about July 23, 2018, and on or about November 13, 2018, several
federal offices in Springfield, Massachusetts — the FBI Springfield Resident Agency (“FBI
Springfield”), the Springfield Social Security Administration Office (“SSA Springfield”), and the
Springfield Branch Office of the United States Attomey’s Office for the District of Massachusetts,
(USAO Springfield”) - received packages through hand delivery or the mail, containing
threatening communications or substances that appeared to pose a threat to public safety. In total,
four packages were received, Two of these packages contained suspicious white powder, which
the recipients reasonably believed could contain harmful biological agents, including Anthrax.
‘Anthrax is an infection that is spread by a particular bacterium’s spores, through contact with the
skin or inhalation. This infection can cause death in humans.
12, Based on my experience and training, | know that federal law enforcement agencies
have previously investigated envelopes containing Anthrax and other harmful biological or
chemical agents in white-powder form that were sent to persons with the intent to scare and cause