FBI affidavit - Main Justice

Case 1:10-cr-00109-AJT Document 2 Filed 03/05/10 Page 1 of 6IN THE UNITED STATES DISTRICT COURT FOR THEEASTERN DISTRICT OF VIRGINIAAlexandria DivisionLUNITED STATES OF AMERICA )CLERK, U.S. DISTRICT COURTALEXANDRIA. VIRGINIAv. ) Criminal No. 1:10-MJ-))Brenna Marie Reilly ))Defendant )AFFIDAVIT IN SUPPORT OFCRIMINAL COMPLAINT AND ARREST WARRANTI, Kari Alexa Parker, a Special Agent with the Federal Bureau of Investigation ("FBI"),Washington Field Division, Washington, D.C., being duly sworn, depose and state asfollows:1. I am a Special Agent with the FBI and have been since April 26, 2009. Ihave been assigned to investigate a variety of criminal and national security matters. Ihave received training in a variety of investigative and legal matters, including FourthAmendment searches, the drafting of affidavits in support of criminal complaints, searchwarrants, and arrest warrants, and I am trained to analyze the existence of probable cause.2. As a federal agent, I am authorized to investigate violations of the laws ofthe United States and Iam a law enforcement officer with authority to execute warrantsissued under the authority of the United States.3. This affidavit is submitted in support of an arrest warrant and criminalcomplaint charging Brenna Marie REILLY with impersonating a United StatesFederalemployee, specifically an employee of the Federal Bureau of Investigation (FBI), inviolation of Title 18, United States Code, Section 912.

Case 1:10-cr-00109-AJT Document 2 Filed 03/05/10 Page 2 of 64. The facts and information contained in this affidavit are based upon mytraining and experience, participation in impersonation investigations, personalknowledge and observations, and the observations of other agents involved in thisinvestigation. All observations not personally made by me were related to me by theindividuals who made them or were conveyed to me by my review of records,documents, and other physical evidence obtained during the course of this investigation.This affidavit contains information necessary to support probable cause and is notintended to include each and every fact and matter observed by me or known to theGovernment.5. Beginning in or about August, 2009, and continuing to the present, Reillyhas falsely represented herself to others as an employee of the FBI.In particular, Reillytold one of her neighbors, Witness 1("Wl"), that she had been working for the FBI sinceshe was eighteen years old and that she started as an intern and worked her way up tobecome a director of the FBI's Forensic Division. Reilly told another neighbor, Victim 1("VI"), that she was Director of Special Division, and that she was subsequentlypromoted to the position of Assistant Director of the FBI as well as FBI Director ofForensics. Reilly represented herself as an FBI employee to the parents of VI, Witness 2("W2"), Witness 3 ("W3"), and to numerous other people who lived at her apartmentcomplex, including but not limited to Victim 2 ("V2"), Witness 4 ("W4") and Witness 5("W5").6. In or around November 2009, Reilly informed VI, V2 and W5 that shewas looking for an assistant and offered each of them the opportunity to apply for aposition with the FBI, Administrative Division.VI and V2 each applied for the position.Reilly offered VI and V2 the position. While Wl declined the offer, VI and V2accepted. Using her brenna.reilly@gmail.com e-mail account, Reilly e-mailed VI V2Forms SF-86 and SF-85 and requested that VI print the forms for V2. VI forwarded this2

Case 1:10-cr-00109-AJT Document 2 Filed 03/05/10 Page 3 of 6email from Rielly to V2. After VI and V2 filled out the forms by hand, Reilly collectedthe forms. Standard Form 86, which is required for any person applying for a positionwith the FBI, asks for detailed information, including but not limited to the applicant'sSocial Security number, date and place of birth, education, employment and credithistory, and names, addresses, places and dates of birth of the applicant's parents,siblings and references.7. On or about December 7, 2009, Reilly asked VI to sign what they calledan "affidavit" detailing the conditions of his employment with the FBI. The documenthad a seal of the Department of Justice on it. Both Reilly and VI signed the document.Reilly refused to provide VI with a copy of the "affidavit," but took a picture of theaffidavit using her cellular telephone and sent the picture to VI. According to thedocument, Vl's employment with the FBI was to begin on December 15, 2009. VIresigned from his managerial position at National Trade Productions on December 11,2009 so that he could begin working for the FBI as Director of Administration and asReilly's administrative assistant.8. During subsequent weeks, VI performed various tasks for Reilly as part ofhis duties purportedly for the FBI. Some of the duties involved transcribinginterrogations supposedly conducted by Reilly. VI worked with Reilly at Reilly'sapartment and used Reilly's computer, a Macintosh laptop, to transcribe theinterrogations dictated by Reilly. Reilly claimed she was permanently on duty,constantly answering telephone calls and text messages that she claimed to be from hercolleagues and that she claimed were related to her position with the FBI.Reilly had twotelephones, one personal cellular telephone and one other cellular telephone, which sheclaimed was her FBI telephone.Vl's other duties included editing condolence letters tothe families of the United States Central Intelligence Agency (CIA) officers who died inthe January 2010 bombing in Afghanistan; Reilly claimed the CIA officers were working3

Case 1:10-cr-00109-AJT Document 2 Filed 03/05/10 Page 4 of 6for her. Reilly sent a draft of the letter to VI and V2 using her Google, Inc. Gmailaccount, brenna.reillv@«mail.com.Following Reilly's direction, VI also created variousPower Point presentations and charts using Wl's personal computer. VI used thecomputer inside Reilly's apartment on several occasions and he frequently saw thecomputer inside Reilly's apartment.9. Reilly did not pay VI any money due to him pursuant to the documentdescribed above that they both signed. Reilly did, however, buy VI approximately$800.00 worth of Christmas presents for Wl, Vl's fiance at the time. Reilly took VI totwo gun shops inChantilly, Virginia, and Manassas, Virginia, purportedly to buy him aweapon. Reilly claimed that she possessed and carried weapons. Sometimes Reillyclaimed her weapons were in the trunk of her car, a gold Saturn, ION, Virginia licenseplate XST5595. In her Christmas card to VI, Reilly promised him her "first servicerevolver ... a 9mm Berreta [sic] special." At the gun shops, instead of buying a weapon,Reilly purchased a Smith & Wesson knife for VI. Reilly used two credit cards topurchase these items, one issued by Bank of America and one issued by SunTrust.Bothcards included the name "Brenna Marie Reilly" as the card holder.10. In or around December 2009, Reilly informed VI that they were to travelto Germany and then to Iraq for FBI business on or about January 1, 2010. Reillyshowed VI what appeared to be an official document that had FBI/CIA headings andcontained their itinerary for the trip.While VI was visiting his parents in New Jersey forChristmas, Reilly drove to their house purportedly to pick up VI to go to Germany.Sheintroduced herself to W2 and W3 and explicitly stated that she was as an FBI employee.W2 and W3 presented to Reilly, and Reilly accepted, a gift of a silk scarf, black, red, andmulticolor, worth approximately $50 purchased at the Rockefeller Center in New YorkCity, New York, and a set of engraved cards in their appreciation for helping VI obtain aposition with the FBI.On January 3, 2010, Reilly called W2 and W3 and informed them4

Case 1:10-cr-00109-AJT Document 2 Filed 03/05/10 Page 5 of 6VI was in Germany and, although they were not allowed to contact him, they should notworry about VI. On January 10, 2010, VI called W2 and W3 and informed them henever went to Germany and that he stayed at Reilly's apartment and then at a hotel, allunder the threat that if he were to contact and tell anybody that he was actually in theUnited States, Reilly would terminate his employment.On January 20,2010, W3 filed acomplaint with the FBI regarding Reilly's impersonation of an FBI employee.11. Reilly appears to maintain contact with W4. In February 2009, whenasked by W4 how the FBI was via Facebook chat, Reilly stated that she quit.Reilly hasnot been seen at or near her Arlington, Virginia residence, which is within the EasternDistrict of Virginia, since approximately February 5, 2010. On March 2, 2010, Reillyinformed W4 that she is with her cousin in Norfolk, Virginia and will be coming back toVirginia sometime during the week of March 8, 2010. According to the assistantmanager of the Wellington apartment complex, Reilly gave notice via email at the end ofFebruary 2010, that she will not renew her lease term, which ends in March 2010.According to the United States Postal Inspection, Reilly requested that, beginning on orabout January 2010, the United States Postal Service forward her mail from herArlington, Virginia, residence to her parents' residence in Holyoke, Massachusetts. Themail is scheduled for forwarding through July 2010.12. Based on the foregoing, probable cause exists to believe that REILLY hasimpersonated an employee of the FBI in violation of Title 18, United States Code,Section 912.WKari Alexa ParkerSpecial AgentFederal Bureau of Investigation

Case 1:10-cr-00109-AJT Document 2 Filed 03/05/10 Page 6 of 6Sworn to and subscribed before me on the ^Tday of March, 2010, in Alexandria,Virginia./s/John F. AndersonUnited States MagistrateJudge