AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT AND ARREST WARRANT IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA UNITED STATES OF AMERICA v. JOHN EARLE SULLIVAN, Defendant. VIOLATIONS: 18 U.SC. §§ 231(a)(3), 2 : (Civil Disorders) 18 U.S.C. § 1752(a) : (Restricted Building or Grounds) 40 U.S.C. § 5104(e)(2) : (Violent Entry or Disorderly Conduct)

 

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AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT AND ARREST WARRANT 

IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF COLUMBIA 

UNITED STATES OF AMERICA 

v. 

JOHN EARLE SULLIVAN, Defendant. 

VIOLATIONS: 

18 U.SC. §§ 231(a)(3), 2 : (Civil Disorders) 

18 U.S.C. § 1752(a) : (Restricted Building or Grounds) 

40 U.S.C. § 5104(e)(2) : (Violent Entry or Disorderly Conduct) 

Case: 1:21-mj-00050 

Assigned To: Meriweather, Robin M. 

Assign. Date: 1/13/2021 

Description: Complaint w/ Arrest Warrant 

SPECIAL AGENT MATTHEW B. FOULGER 

FEDERAL BUREAU OF INVESTIGATION 

Attested: HON. ROBIN M. MERIWEATHER 

UNITED STATES MAGISTRATE JUDGE 

13th day of January, 2021 

  CONCLUSIONS OF AFFIANT 

24. Based on the foregoing, your affiant submits that there is probable cause to believe that SULLIVAN violated: 

a. 18 U.S.C. §§ 231(a)(3) & 2, which makes it a crime to commit or attempt to commit, any act to obstruct, impede, or interfere with any fireman or law enforcement officer lawfully engaged in the lawful performance of his official duties incident to and during the commission of a civil disorder which in any way or degree obstructs, delays, or adversely affects the performance of any federally protected function; 

b. 18 U.S.C. § 1752(a), which makes it a crime to (1) knowingly enter or remain in any restricted building or grounds without lawful authority to do; (2) knowingly, and with intent to impede or disrupt the orderly conduct of Government business or official functions, engage in disorderly or disruptive conduct in, or within such proximity to, any restricted building or grounds when, or so that, such conduct, in fact, impedes or disrupts the orderly conduct of Government business or official functions; (3) knowingly, and with the intent to impede or disrupt the orderly conduct of Government business or official functions, obstruct or impede ingress or egress to or from any restricted building or grounds; or (4) knowingly engage in any act of physical violence against any person or property in any restricted building or grounds; or attempts or conspires to do so. For purposes of Section 1752 of Title 18, a restricted building includes a posted, cordoned off, or otherwise restricted area of a building or grounds where the President or other person protected by the Secret Service is or will be temporarily visiting; or any building or grounds so restricted in conjunction with an event designated as a special event of national significance; and 

c. 40 U.S.C. § 5104(e)(2)(D), which makes it a crime for an individual or group of individuals to willfully and knowingly (A) enter or remain on the floor of either House of Congress or in any cloakroom or lobby adjacent to that floor, in the Rayburn Room of the House of Representatives, or in the Marble Room of the Senate, unless authorized to do so pursuant to rules adopted, or an authorization given, by that House; (B) enter or remain in the gallery of either House of Congress in violation of rules governing admission to the gallery adopted by that House or pursuant to an authorization given by that House; (C) with the intent to disrupt the orderly conduct of official business, enter or remain in a room in any of the Capitol Buildings set aside or designated for the use of— (i) either House of Congress or a Member, committee, officer, or employee of Congress, or either House of Congress; or (ii) the Library of Congress; (D) utter loud, threatening, or abusive language, or engage in disorderly or disruptive conduct, at any place in the Grounds or in any of the Capitol Buildings with the intent to impede, disrupt, or disturb the orderly conduct of a session of Congress or either House of Congress, or the orderly conduct in that building of a hearing before, or any deliberations of, a committee of Congress or either House of Congress; (E) obstruct, or impede passage through or within, the Grounds or any of the Capitol Buildings; (F) engage in an act of physical violence in the Grounds or any of the Capitol Buildings; or (G) parade, demonstrate, or picket in any of the Capitol Buildings; and 

25. As such, I respectfully request that the court issue an arrest warrant for SULLIVAN. 

The statements above are true and accurate to the best of my knowledge and belief. 

SPECIAL AGENT MATTHEW B. FOULGER 

FEDERAL BUREAU OF INVESTIGATION 

Attested: HON. ROBIN M. MERIWEATHER 

UNITED STATES MAGISTRATE JUDGE 

13th day of January, 2021