+AO 91 (Rev.

02/09) Criminal Complaint

tlmitedl States Drstrnct Court

for the
Western District of New York

United States of America

Case No.

16-M-

J<7-)

v.
i... !

JOSEPH CONRAD GOODE

I !:,-)

CRIMINAL COMPLAINT

I,

is true to the best of my knowledge and

following
the
that
state
case,
this
in
complainant
the

belief.

york, the above named

western District of New
the
in
7,2016,
April
about
or
on
Beginning
upon the
ttre life of and to inflict bodily harm
defendant did knowingry and willtully make ljg.uJjo.tatce States Code, section 871; to.take the life of
president of the united states, r, uioiution of ritle tg, uniiea
president o, u *.r"uer of the immediate family of a former
and to inflict bodily harm upon a former
879; ard to take the life of and to inflict
president, in violation of ritle 1g, u;i;a states code, s..rio"
of ritle
6ffi.. of ttre piesident of the united States, in violation
bodily harm upon

a maJor.canaraate'ror;.

18, United Statis Code, Section 879'

facts:
This Criminal Complaint is based on these

Continued on the attached sheet'

Eugene King, SP-ecial Agent

UniteO States Secret Sewice
Printed name and title

presence'
Sworn to before me and signed in my
Date: Aprtl ',s.2076

H. KENNETH SCHROEDER, JR.

Ciry and State: Buffalo. New York

Printed name and title

AFFIDAVIT
STATE OF NEW YORK )
)
COUNTY OF
CITY OF BUFFLAO )

EzuE

SS:

I, EUGENE RYAN KING, being duly swom' state

as

follows:

i.laroaSpecialAgentoftheLrnitedStatesSecretService,andhavebeenso
employed since June ,2015.

my duties
am assigned to the Buffalo Field Office' where

protected individuars, including, but not limited

include the investigation of threats against
of the United States' and major
to, the President of the United States, former Presidents
president or vice president of the united States, and facilities
candidates for the office of the

underthedirectprotectionoftheUnitedStatesSecretService.

2'

As part of my current duties,

I am conducting

an investigation of suspected

871 and 879by Joseph Conrad Goode

violations of Title 18, United States Code, Sections
,,GOODE"). This affidavit is submitted in support of a criminal
(hereinafter referred to as
life
and willfully make a threat to take the
complaint charging that GOODE did knowingly
of the United States' namely Barack
of and to inflict bodily harm upon the President
and to
Code, Section 871; to take the life of
obama, in violation of Title 18, United States
a member of the immediate family of a
or
President
former
a
upon
harm
inflict bodily

and Hillary Clinton'

former President, namely William Clinton

in violation of Title 18'

UnitedStatesCode,sectionSTg;andtotakethelifeofandtoinflictbodilyharmupona
president of the united States, in violation of ritle 18,
major candidate for the office of the

sanders, Hilary Clinton'

United States Code, Section 879, oamely candidates Bernie
Donald TrumP, and Ted Crvz'

3.

upon information I have

The information contained in this affidavit is based

my personal observations' my training

gathered during the ongoing criminal investigation,
other law enforcement officers and
and experience and/ or information relayed to me by
this affidavit is being submitted for the
orlagents in involved in this investigation. Since
have not included every fact known to
limited purpose of securing a criminal complaint, I
only facts that I believe are necessary to
me concerning this investigation. I have set forth
1g, united States Code, sections 87L and879,
establish probabre cause to believe thatTitre
have been violate bY GOODE'

PROBABLE CAUSE

4.onApriiT,2ol6,theUnitedStatesSecretServiceBuffaloFieldoffice
("ECMC") to
personnel at Erie County Medical Center
received information from medical
Clinton,
to injure and kin Barack obama, william
the effect that GOODE had threatened
Crvz'
Donald Trump, Hillary Clinton, and Ted

5.

personnel were assigned to the

Your undersigned and other Secret Service

your
to conduct an investigation' Thereafter'
ECMC
to
went
thereafter,
and
investigation
undersigned andanotherageltconductedinterviewsofECMCpersonnelandobtained

signed statements concerning the facts at issue on April

l,

20L6' During the course of the

were provided:
interviews of the ECMC personnel, the following information/statements

A.

on

was going to get a

04/07 /1.6, GOODE stated to ECMC personnel that

,,high powered rifle and

kill all the presidential candidates,"

and that "is the

kind of person ready to snap and shoot up a public place'"

B.

On 04/07/16, GOODE was heard by ECMC

personnel stating that "Bill

kill him along

Clinton is only a couple hours away and I am going to fucking
also was heard
with Donald Trump, Ted Ctvz and all of the FBI." GOODE

to get
stating that he had a sniper rifle and was going

it when he got out of

here [meaning ECMC].

C.

on

04/07

/L6, GOODE made numelous statements heard by

ECMC

personnel about wanting to

Comprehensive Psychiatric Emergency Program

killHillary Clinton and Donald Trump'

D.

on04/07/16,GooDEstatedandwasheardbyECMCpersonnelthat
and kill the presidential
desire to acquire a long lange sniper rifle

GOODE

burn'"
candidates because he wants to "see the world

E.

on

04/07

/16, GooDE was heard by ECMC

personnel stating that he was

going to kiIl President Obama and Donald Trump'

F.

on

04/07

/16, GOODE

made numerous statements heard by ECMC CPEP

rifle and kill 8il1 Clinton'

personnel that he wanted to acquire a high powered
Ted Cruz and Donald TrumP'

6.

in an interview
Additionally, on April 7, 2016, GOODE was interviewed

to him by another Secret Service

room at ECMC after Miranda warnings were administered
the Miranda wamings' wished to
agent in my presence. GOODE stated that he understood
declined to sign a written waiver of
waive those rights, and to speak with agents. GOODE
things, that "everything they
Miranda wamings. GooDE thereafter stated, among other
as your undersigned and the other
said [meaning the ECMC personnel] was true," and
I felt like
leaving, GooDE stated that "I fett like killing Trump,
Secret Service agent were

killing Clinton, I felt like killing

7.

Sanders but

I said it out of anger'"

United States' William Clinton

Barack Obama is the curent President of the

Hillary Clinton is the wife of William Clinton'

is a former president of the United States and
and Ted Cruz are major candidates for the
Bernie Sanders, Hillary clinton, Donald Trump,
upcoming presidential election in
office of the president of the United states in the
November,2016.

S.Asnotedinthepresscoverageconcemingthe2016Presidentialcampaign,
in the Buffalo' New York area'
and Bemie Sanders ale expected to arrive

Hillary Clinton

namelywithinthewesternDistrictofNewYork,onApril0s'2Ot6andAprilL7'2016'
the 2016 Presidential campaign'
respectively. As noted in the pless coverage concerning

Donald Trump is expected to arrive in the Rochester, New York and Albany, New York
areas on

April 10,2016 and April 17,2016, respectively.

CONCLUSION

g.

Based on the foregoing, your affiant respectfully submits that there is probable

cause to believe that JOSEPH CONRAD GOODE did knowingly and

willfully make a

threat to take the life of and to inflict bodily harm upon the President of the United States,
namely Barack Obama, in violation of Title 18, United States Code, Section 871; to take the

life of and to inflict bodily harm upon a former President or a member of the immediate
family of a former President, nameiy William Clinton and Hilary Clinton, in violation of

Title 1g, United States Code, Section 879; and to take the life of and to inflict bodily harm
upon a major candidate for the Office of the President of the United States, in violation of

Title 18, United States Code, Section 879, namely candidates Bernie
Ciinton, Donald Trump, and Ted Cruz.

Eugene Ryan
United States

swom to before me this

ru

day of Aprn2076.

tI: ixr,NNETH SCHRoEDER, JR.

United States Magistrate Judge

Sanders, Hillary