Case 5:17-mj-00301-CG Document 1 Filed 07/01/17 Page 1 of 13

AO 91 (rev.11/11) Criminal Complaint AUTHORIZED AND APPROVED DAT

dh if-

United States District Court

for the

WESTERN DISTRICT OF OKLAHOMA

United States of America

V.

DANIELLE DANA LAYMAN, Case No: M-17- 301 -CBG

a/k/a Samantha Dowry,
a/k/a Danielle Givati,
a/k/a Dana Abecassis.
FILED
JUL 0 1 2017
CRIMINAL COMPLAINT CARMELITA REEDER SHINN, CLERK
U.S. DIST. COURTj^STERN DIST. OKLA.
I, the complainant in this case, state that the following is true to the best ofmy knX4<nlgb^aud .PfiPUTY
Count 1

On or about April 18, 2017, to on or about May 9, 2017, within the Western District of Oklahoma, the defenciant(s)

Danielle Dana Layman, a/k/a Samantha Dowry, a/k/a Danielle Givati, a/k/a Dana Abecassis violated:

Code Section Offense Description

18:1958(a) Whoever uses or causes another to use the mail or any facility of
interstate or foreign commerce with intent that a murder be committed
in violation of any laws of any state, or the United States, as
consideration for the receipt of, or as consideration for a promise or
agreement to pay, anything of pecuniary value, or who conspires to do
so.

This criminal complaint is based on these facts:

See attached Affidavit of Task Force Officer David M. Otwell, Federal Bureau of Investigation, which is incorporated and
made a part hereof by reference.

Continued on the attached sheet.

Complainant's signature
DAVID M. OTWELL
Task Force Officer
Federal Bureau of Investigation

Sworn to before me and signed in my presence.

Date: _ ^ulf I, Zfflf

Judge's signature
City and State: Oklahoma Citv. Oklahoma CHARLES B. GOODWIN. U.S Magistrate Judge
 Case 5:17-mj-00301-CG Document 1 Filed 07/01/17 Page 2 of 13

IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF OKLAHOMA

AFFIDAVIT

I, David M. Otwell, being duly sworn, depose and state:

AFFIANT'S EXPERIENCE

1. I am a Task Force Officer (TFO) with the Federal Bureau of Investigation

(FBI) Joint Terrorism Task Force (JTTF). I am an investigative or law enforcement officer

of the United States within the meaning of Title 18 U.S.C. 2501(7); that is, an officer ofthe

United States who is empowered to conduct investigations for violations of federal offenses.

I have been employed as a Police Officer with the City of Edmond for approximately 26

years and have been assigned to the Oklahoma City Division of the FBI JTTF as a TFO for

the last 13 and a half years. I have participated in investigations involving individuals

suspected of terrorist activities, assisted in the execution of search and arrest warrants,

conducted physical surveillance, analyzed records and have spoken to informants and

subjects of investigations involving numerous types of federal violations.

2. The facts and information set forth in this affidavit are derived from an

investigation conducted by myself as well as other agents, other law enforcement agents

involved with this case, FBI intelligence analysts and from a review of documents and other

records related to this investigation. Since this affidavit is being submitted for the limited

purpose of establishing probable cause, I have not included each and every fact known to

investigators about this investigation. I have set forth only the facts that I believe are
 Case 5:17-mj-00301-CG Document 1 Filed 07/01/17 Page 3 of 13

necessary to establish probable cause to support the issuance of a criminal complaint.

PURPOSE OF AFFIDAVIT

3. Based on my training and experience and the facts as set forth in this affidavit,

there is probable cause to believe that violations of Title 18, United States Code, Section

1958(a), Use of Interstate Commerce Facilities in the Commission of Murder for Hire,

committed by Danielle Dana Layman, a.k.a Samantha Dowry, a.k.a. Danielle Givati, a.k.a.

Dana Abecassis. Section 1958(a) prohibits using or causing another to use (or conspiring to

use or cause another to use) the mail or any facility of interstate or foreign commerce, with

intent that a murder be committed in violation of the law of any State or the United States as

a consideration for the receipt of, or as consideration for, a promise or agreement to pay

anything of pecuniary value.

FACTS AND CIRCUMSTANCES

4. On May 9, 2017, at 12:58 p.m. Eastern Time, CHS #00083387 (CHS) called

the FBI Public Access Line (PAL) to report having been hired to murder an individual in Tel

Aviv, Israel, using ricin. CHS stated that Samantha Dowry, cellular telephone number XXX-

XXX-9503, craigshst email address nvxnj-6093775010@gigs.craigslist.org, in Ponca City,

Oklahoma, had provided her with ricin.

5. On May 3, 2017, at 3:40 p.m.. Central Standard Time, CHS responded to a

craigslist post (Posting ID# 6093775010) titled: "10 day gig overseas for amateur,

competitive pay!" The body of the post is as follows:

 Case 5:17-mj-00301-CG Document 1 Filed 07/01/17 Page 4 of 13

For production overseas, looking for talent, 30-45 years old.

Doesn't have to be a professional actor. Required: Creative,
outgoing and friendly, positive personality, boldness and bravery
(some stunts may seem risky, although they are completely
safe). Discrete (you must not disclose any information related to
the plot to ANYONE under ANY CIRCUMSTANCES, until
after it premiers, except with explicit permission from
production) valid passport not required but preferred:
Experience in acting. Experience performing in magic shows,
Experience as casino dealer. No need to pass a background
check however, no one with drug related convictions or current
drug use will be hired. Send resume and cover letter by email
and we will contact you to set up interview.

6. After responding to Samantha Dowry (the person who posted Posting ID#

6093775010) via Craigslist Messenger and by text message to discuss the potential job

posting, CHS agreed to meet Samantha Dowry at the Perk Beverage Company, 415 North

14th Street, Ponca City, Oklahoma, on May 9,2017, at approximately 11:30 a.m. CHS later

provided to law enforcement a series of text messages with Samantha Dowry, which I have

reviewed. These text messages corroborate CHS's account of the logistics of the meeting on

May 9, 2017.

7. At the meeting, Samantha Dowry informed CHS she wanted CHS to poison

someone with ricin. CHS was warned if he/she told anyone about this, she and CHS would

both be killed.

8. Samantha Dowry proceeded to show CHS an entire PowerPoint presentation,

which was on a laptop computer brought to the coffee shop by Samantha Dowry concerning

what CHS was being asked to do, where CHS would stay, and how CHS would get there.
 Case 5:17-mj-00301-CG Document 1 Filed 07/01/17 Page 5 of 13

Samantha Dowry advised CHS to use ricin on an individual with the last name of Qasis,

cellular telephone number XXX-XXX-9101, in Tel Aviv, Israel. Samantha Dowry explained

Qasis was a taxi driver for Ashdod Mall Taxi with business telephone *6868. Samantha

Dowry provided CHS with a packet containing codes and instructions on what the CHS

would need and the names of other individuals involved in this endeavor.

9. The instructions, which CHS provided to law enforcement and I have

reviewed, were titled "Operation Insecticide" and were as follows:

A. Preparation for mission:

1) Prepare your body 2 weeks in advancefor an 8 hours' time change

2) Packing list
- clothingfor 10 days at 90 degree weather
- laptop
- lock and key
- vials ofpowder in both carry on and checked baggage.
- money
- passport
- flight ticket

B. communication:

1) Report updates via code 01 01 0000 . 000 000 0000 to Tammy XXXXXX.
2) abort code: 9999 -from Tammy XXXXXX ONLY.
3) no communications unless there is an update

C. Lod2ins:

Any backpackers hostel, prefer in Ashdod or Tel Aviv, check www.Airbnb.com or any other
website
 Case 5:17-mj-00301-CG Document 1 Filed 07/01/17 Page 6 of 13

D. Mission Details:

1) You will be given $1000for your stay expenses. Any unusedportion is yours
to keep.

2) The powder you are carrying is not a drug. If questioned about it at the
airport explain it is a religious relic that is supposed to ward offevil spirits. It
is made ofa plant common in Israel (Castor) and is highly toxic.

3) Whileat the hostel, makefriends and offer them tojoin you on a tour to tourist
attractions. Offer to take a taxi and split the cost. It is recommended to have
at least one 'friend" join you, but not a requirement.

4) Call your mark. His name is XXXXXXXXXX Qasis, his cell number is XXX-
XXX-9101 (local number). He works as a taxi driverfor Ashdod Mall Taxi
(aka Canyon Ashdod). Localphone numberfor the taxi station is *6868. Tell
him you received his phone numberfrom another tourist who recommended
him. Ask him to quote you a price to drive you daily to tourist attractionsfor
one week. You may negotiate the price down. Price negotiations is common
in Israel and is expected.

5) Prepare 2 cups ofcoffee. Addpowder to one ofthem. Asyour mark arrives at

your hostel to pick you up in the morning, offer him a cup ofcoffee. Repeat
every morning and monitor the driver's health. Report if he starts showing
signs of illness, if he is vomiting, and if he fails to come pick you up at the
hostel.

6) Whenyour mark is hospitalized [or] eliminated - move to a different hotel or

motel until yourflight back home.

7) Upon confirmation ofmission success, you will be paid $4,000 in cash. The
money will be given to you via your operator

10. While at the Perk Beverage Company, Samantha Dowry gave CHS a small

package and was told it contained ricin in its plant form and was warned about opening the

package without the use of gloves. CHS had already provided Samantha Dowry with a copy

of his/her passport for proof of identification prior to meeting Samantha Dowry in person.
5
 Case 5:17-mj-00301-CG Document 1 Filed 07/01/17 Page 7 of 13

CHS was told that any further communication with Samantha Dowry was to be about a

modeling job and not the upcoming trip. CHS was told a person identified as Tammy

XXXXXX will reach out to him/her to set up the travel arrangements.

11. Ricin is a poison found naturally in castor beans. Based upon my training and

experience, I understand that ricin is a "toxin" for purposes of Title 18, United States Code

178(1). If ingested, inhaled, or injected, ricin can be fatal. Those knowledgeable in the field

of ricin toxin state that ricin could be extracted using certain common ingredients and

instrumentalities including: castor beans (from which ricin is actually extracted), syringes,

strainers, coffee grinders, coffee filters, latex gloves, and acetone. Properly disseminated, it

could kill numerous people. Ricin poisoning has no known antidote and is extremely

difficult to detect as a cause of death.

12. Samantha Dowry offered CHS $1,000.00 for his/her personal expenses for 10

days in Tel Aviv and another $4,000.00 if he/she was successful. CHS was told this would

take place in the fall of 2017.

13. When CHS departed the meeting, CHS took photographs of the two pieces of

paper that contained the codes and instruction of the operation, the bag containing the glass

vials, and the baggie containing ricin. CHS then sent a text message to an attorney friend.

CHS sent the attorney friend the photographs, details regarding the murder-for-hire proposal

and asked him what CHS should do. The attorney responded via text message to CHS and

told CHS to stop what CHS was doing and call the FBI immediately.
 Case 5:17-mj-00301-CG Document 1 Filed 07/01/17 Page 8 of 13

14. Shortly after CHS contacted his/her attorney friend requesting advice, CHS

called the FBI Public Access Line (PAL) to report the murder-for-hire plot.

15. To corroborate and determine the reliability of CHS, the attorney was

interviewed by FBI agents. The attorney verified the fact that the CHS contacted him via text

message on May 9, 2017, the same day CHS met Samantha Dowry at the Perk Beverage

Company in Ponca City and was requested to conduct the murder using ricin. He also

provided agents with screen shots of the text message exchanges between him and CHS,

including the photos of the two pieces of paper that contained the codes and instruction ofthe

operation, the bag containing the glass vials, and the baggie containing ricin.

16. CHS explained when CHS arrived at CHS's residence, CHS told his/her

roommate about the meeting and showed him/her the pieces of paper containing the codes

and instructions of the operation, the bag that contained the ten glass vials, and the baggie

containing ricin. CHS said the items were then placed in an upper cabinet in his/her laundry

room so children were not able to get to them. CHS said his/her roommate decided to take

the items out of the upper cabinet and dispose of them in a trash dumpster in an apartment

complex in Oklahoma City, Oklahoma.

17. During an interview with the CHS, agents showed the CHS a photograph of

Danielle Dana Layman to see if she was the same person CHS met with at the Perk Beverage

Company in Ponca City, Oklahoma, who identified herself as Samantha Dowry. After
 Case 5:17-mj-00301-CG Document 1 Filed 07/01/17 Page 9 of 13

looking at the photograph for approximately two seconds, the CHS positively identified the

photograph as the female who attempted to hire him/her to commit the murder-for-hire plot.

18. In an attempt to corroborate and determine the reliability of the CHS, agents

interviewed the roommate of CHS. During the interview, the roommate was cooperative and

ultimately verified each detail that CHS provided him/her regarding the murder-for-hire plot.

The roommate explained CHS showed him/her the baggie containing ricin, the glass vials,

and the two pieces of paper detailing the codes and instructions of the operation. The

roommate was extremely scared and upset at CHS for giving out their address to the person

who was attempting to hire CHS for the murder-for-hire plot. The roommate decided to take

the glass vials and the baggie containing the ricin to a dumpster at an apartment complex on

the south side of Oklahoma City, where she discarded them.

19. In an attempt to corroborate and to determine the reliability of CHS, database

queries were conducted on "Samantha Dowry" in an attempt to completely identify her. The

database checks were unsuccessful in identifying "Samantha Dowry" as a true person. A

check ofthe telephone number "Samantha Dowry" provided to CHS, (XXX) XXX-9503, had

returned to an active phone for Danielle Dana Layman, aka: Danielle Givati. A query within

FBI holdings for Danielle Layman, DOB: XX/XX/1980, revealed one non-immigrant visa

(NIV) which listed Danielle Givati as an Israeli national and a lawful permanent resident of

the United States. Your Affiant knows from visa paperwork submitted by Danielle Layman

that she claims to be a former Director of Nursing for the Ministry of Labor in Israel and
 Case 5:17-mj-00301-CG Document 1 Filed 07/01/17 Page 10 of 13

therefore would have some type of a medical and scientific background.

20. When additional queries were conducted through FBI holdings concerning the

telephone number Samantha Dowry provided to CHS to contact Qasis in Israel, XXX-XXX-

9101, there was a NIV application for XXXXXX Abecassis, DOB: XX/XX/1977.

Abecassis' occupation was listed as "taxi driver," with a work number of XXX-XXX-9101.

21. A search for Danielle Givati's NIV application showed she was an Israeli

national. Additionally, an alias for Givati was listed as "Dana Abecassis," the same last

name as the taxi cab driver.

22. Open database searches were conducted using the names "Abecassis" and

"Layman." Numerous Israeli newspaper articles dated in late 2014 appear to indicate

Danielle Layman, described as an American-Israeli woman, was in a battle with her ex-

husband, XXXXXX Abecassis, over visitation rights with their then-13 year-old daughter.

23. According to the open source reporting, Danielle Layman was divorced from

XXXXXX Abecassis in 2003. Danielle Layman later married an American soldier, Jeremy

Layman in 2010. In 2014, while her husband was on a deployment. Layman took her

children on an extended visit to Israel to visit family. While they were there, XXXXXX

Abecassis found out the family was in Israel. Abecassis filed a lawsuit with the Ashdod

Region Rabbinical Courts, demanding visitation rights with his daughter. The daughter was

reportedly prevented from leaving Israel for an undetermined time; however, a search of

social media sites appears to indicate that the daughter is currently back in the United States.
 Case 5:17-mj-00301-CG Document 1 Filed 07/01/17 Page 11 of 13

According to open source reporting, Abecassis' current wife at that time, XXXXX

Abecassis, was serving as XXXXXX Abecassis' attorney.

24. An emergency disclosure request was submitted to Craigslist for any and all

available information related to Craigslist Posting ID# 6093775010, to include but not

limited to IP Addresses, User/Account Owner information, communication records,

responders to the post, etc.

25. Within a short period of time, Craigslist responded and provided the FBI the

original post, including IP address, email address, and the dates and times when individuals

responded to the post. Some of the information is as follows:

postingjd: 6093775010
poster_email: samanthadowry@gmail.com
userjd: 313392304
poster_ip: 70.254.224.177
authjuser_phone: n/a
auth user phone modify: n/a
record_created: Tue Apr 18 2017 12:22:27 PM (Pacific)
posted_date: Tue Apr 18 2017 12:29:27 PM (Pacific)
posting_renewal_dates: n/a
recordjnodified: Sat Jun 03 2017 01:07:17 AM (Pacific)
area_description: stillwater, OK
subarea_description: n/a
neighborhood: n/a
geographic_area: n/a
category_description: talent gigs
categoryJype: gigs
price/age: n/a
invoice_item_id: n/a
privacy: anonymized email address
posted_state: Expired
posting_title: 10 day gig overseasfor amateur, competitive pay!
PostingBody
10
 Case 5:17-mj-00301-CG Document 1 Filed 07/01/17 Page 12 of 13

For a production overseas, lookingfor talent, 30-45 years old. Doesn't

have to be a professional actor.
Required:
Creative
Outgoing andfriendly, positive personality
Boldness and bravery (some stunts may seem risky, although they are
completely safe)
Discrete (you must not disclose any information related to the plot to
ANYONE under ANY CIRCUMSTANCES, until after it premiers, except with
explicit permissionfrom production)
valid passport
not required but preferred:
Experience in acting
Experience performing in magic shows
Experience as casino dealer
No need to pass a background check however, no one with drug related
convictions or current drug use will be hired
send resume and cover letter by email and we will contact you to set up
interview.

26. Based on the information obtained, there were two individuals who responded

to the Craigslist posting, one being CHS.

27. On June 30, 2017, federal agents executed a search warrant at Danielle

Layman's residence in Ponca City, Oklahoma. Agents found several dozen castor beans in

the kitchen. Agents also found a mortar and pestle with residue that could be remnants of

ground castor beans. On the kitchen counter, agents found instructions on how to make ricin,

apparently printed from the internet.

28. In my presence, Danielle Layman made phone calls to her husband to let him

know that federal agents had executed a search warrant at their residence. Ms. Layman knew

that I was able to hear her side of the conversation. During one of the conversations, she
11
 Case 5:17-mj-00301-CG Document 1 Filed 07/01/17 Page 13 of 13

informed her husband that agents were searching for castor beans. She told her husband that

she had ordered castor beans, which she explained is not illegal. She told her husband that

one can turn castor beans into ricin and stated that she knew how to do that. She also told her

husband that she had printed instructions off of the internet on how to make ricin a year and a

half ago and stated that agents would find those printed instructions.

CONCLUSION

29. Based on the facts herein and my training and experience, I submit there is

probable cause to arrest Danielle Dana Layman for an offense in violation of Title 18,

U.S.C., 1958(a), Use of Interstate Commerce facilities in the commission of Murder-for-

Hire.

30. I swear the forgoing is true and correct to the best of my knowledge and belief.

DAVID M. OTWELL
Task Force Officer
Federal Bureau of Investigation

Subscribed and sworn to before me this 1st day of July 2017, in Oklahoma City,
Oklahoma.

CHARLES B. GOODWIN
United States Magistrate Judge
12
 Case 5:17-mj-00301-CG Document 1-1 Filed 07/01/17 Page 1 of 1

CRIMINAL COVER SHEET U.S. District Court, Western District of Oklahoma

Petty Misdemeanor Felony 0 Case No.

Number of Counts 1 Number of Defendants 1 USAOID No. By: LL
COMPLAINT

Sealed: Yes[] No[7] OCDETFiYesD No[Z] Notice ED Summons Writ Warrant [7]to Issue

DEFENDANT: DANIELLE DANA LAYMAN

Alias(es): a/k/a Samantha Dowry, Address:

a/k/a Danielle Givati,
a/k/a Dana Abecassis
Phone:

Age&DOB: 37, xx/xx/1980 SS#: Juvenile: Yes No [7] Interpreter: YesD No[Z]

SEX: M F0 RACE: Language/Dialect:

defendant Status:

Not in Custody Type of Bond Recommended on this Charge:

OR Cash 10% Unsecured Surety

Bond set at: $ Date:
Current Bond on Other Charge Federal State Bond in Amount of: $

[Z1 In Jail at: Logan County Jail Under Prisoner/Register No.: Detention 0
'rior Proceedings or Appearance(s) Before U.S. Magistrate Judge:
Case No. M- Government Motion to Detain: Yes 0 No

Complaint: Yes 0 No O Bond Set: Date:

Related Case Information:

Previous Case No. Rule 20/Rule 5 from District of:

Additional Defendants: Yes No Total Number of defendants:

Attorney Information:
Defense Counsel: AUSA: David P. Petermann / Ashley L. Altshuler

Address: Phone: 405/553-8855/8739 Fax: 405/553-8888

Phone: Fax: Federal Agent/Agency: /FBI

Retained CJA Panel 0 Public Defender Local Agent/Agency:

Count(s) use Citationts) Offense(s) Charged Penalty

1 18 U.S.C. 1958(a) Use of interstate commerce NMT 10 years BOP; $250,000.00 fine; or both;
facilities in the commission of NMT 3 years SR; and $100.00 SA
murder-for-hire

Date : ~=t =r Signature of AUSA

?,0QI6-91