Free Redacted Document - District Court of Delaware - Delaware

. Case 1 :05-cr-OOO81-KAJ Document 2 Filed O9/O2/2005 Page 1 of 4 _
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U 'ted States District Court
jg, DISTRICT OF DELAWARE J L X, .
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UNITED STATES OF AMERICA p 5 , ._
v. CRIMINAL COMPLAINT
CASE NUMBER: 05- Il 3 N\
LEWIS THURSTON
aka Louis Dyson
I, the undersigned complainant being duly sworn, state the following is true and correct to the best of my
knowledge and belief. On or about September I, 2005, in New Castle County, in the District of Delaware, defendant
did,
. . . . . . . . t stl]
knowingly transfer, without lawful authority, a means ofidentification of another person, with the intent to comment and to
aid and abet unlawful activity constituting a violation of federal law, to wit, a false statement in an application for a passport
(a violation ofTitle 18 United States Code Section lS42) `
in violation of Title IS United States Code, Sections 1028(a}g7) and tb)jl)(A) & {D), and
I further state that I am a(u) Special Agent of the Department of State Diplomatic Security Service and that this
complaint is based on the following facts:
SEE ATTACHED AFF IDAVIT.
Continued on the attached sheet and made a part hereof: X YES ___NO
Signature of Complainant
Stephen Nagy
Special Agent
Department of State Diplomatic Security Service
Sworn to before me and subscribed in my presence,
52 noe" - ·
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Dale City and State ’
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United States District Court Judge A l { /
District of Delaware _ _ R / A j_ `-_—_
Name& Title ol'Judicial Officer Sig tur o Juclic A

. Case 1:05-cr-00081-KAJ Document 2 Filed O9/O2/2005 Page 2 of 4
AFFIDAVIT
I, Stephen Nagy, a Special Agent of the Department of State Diplomatic Security Service,
having duly sworn, do hereby swear and affirm the following facts as being true to the best of my
knowledge and belief:
l. This affidavit is made in support of an application for a Criminal Complaint against
Lewis Thurston a/k/a Louis Dyson to for violation of Title 18 United States Code, Section 1028
(a)(7) and (b)(1)(A) & (D) (a knowing transfer, without lawful authority, of a means of
identification of another person, with the intent to commit, or to aid or abet, any unlawful activity
` that constitutes a violation of federal law, specifically the making of a false statement in an
application for a passport, a violation of Title 18, United States Code, Section 1542).
2. I am employed as a Special Agent of the Diplomatic Security Service, having been so
employed by the U.S. Department of State since April of 2003. I am presently assigned to the
Washington Field Office in Dunn Loring, VA. I am a graduate of the Criminal Investigative ’
Training Program at the Federal Law Enforcement Training Center in Glynco, GA, and I have
received additional training from the U.S. Department of State in conducting criminal
investigations in regards to passport and visa fraud.
l
3. This affidavit is for the purpose of securing probable cause. Therefore, I have not i
included each and every fact or matter observed by me or known to other government agents. L
4. I am personally familiar with t.he Rrcts and circumstances surrounding this
investigation both from my own investigative activity and from information obtained by other
federal agents for the DSS and for the DEA who are participating in this investigation and have
communicated the results of their observations to me. I
Details Of Investigation
5. On or about June 22, 2005, Special Agents of the United States Department of State
Diplomatic Security Service (DSS) and the United States Drug Enforcement Agency (DEA)
conducted an undercover meeting between a DSS undercover agent (DSS UC) and Lewis
Thurston afk/a Louis Dyson (Thurston). The meeting occurred on the street in front of 200
Wedgefield Circle, New Castle, Delaware. Dining the meeting Thurston explained to the DSS
UC what different types of documents he sold, including identity documents. The DSS UC
agreed to purchase a set of documents, consisting of an altered Delaware birth certificate and two
letters to support the identity of the birth certificate. The DSS UC told Thurston he needed the
documents to get another identity document; Thurston agreed that the documents he would
provide the DSS UC could be used to obtain a State of Delaware driver’s license. A price of
$400.00 United States Dollars (USD) was agreed upon for the documents, and the DSS UC made
a down payment of $250.00 USD. Thurston agreed to call the DSS UC once the documents were
ready.
l

‘ _ ‘ . Case 1 :05-cr-00081-KAJ Document 2 Filed O9/O2/2005 Page 3 of 4
6. On or about June 28, 2005, after a phone call to confirm the time and location of the
meeting, the DSS UC met with Thurston on the street in front of Wilmington,
Delaware. During the meeting Thurston gave the DSS UC an altered Delaware birth certificate
in the name of an individual with the initials M.A.P born 1970, a bill from Christiana
medical center in the same name, and a un-employment benefits statement in the same name. In
rettun the DSS UC paid Thurston the balance of $150.00 USD to complete the transaction.
7. On or about July 14, 2005, after a phone call to confirm the time and location of the
meeting, the DSS UC met wit.h Thurston at T.G.I.Friday’s restaurant on Route 13 in New Castle, l
Delaware. During the meeting the DSS UC expressed interest in obtaining a United States 1
Passport. Thurston offered to sell the DSS UC a set of un-altered, real documents for $1,500.00
USD. Thurston explained that these documents could be used to apply for, and obtain, a United 1
States Passport; Thurston offered to complete and turn in the passport application for the DSS
UC once the DSS UC had obtained a driver’s license. The DSS UC agreed to purchase a set of
real documents for $1,500.00 USD, and made a down payment to Thurston of $700.00 USD.
Thurston agreed to call the DSS UC when the documents were ready.
8. On or about August 5, 2005, after a phone call to confirm the time and location of the ,
meeting, the DSS UC met with Thurston on the street in front of 200 Wedgefield Circle, New
Castle, Delaware. During the meeting Thurston gave the DSS UC one tm-altered Delaware birth p`
certificate of an individual with the initials D.D.P born 'l975 and one social security card
inthe same name. Thurston explained that the DSS UC was to use these documents to apply for l
and obtain a driver’s license in a state other than Delaware. With the driver’s license, and the ’;
documents, Thurston explained that the DSS UC could then apply for and obtain a United States ·"
Passport. In return for the documents the DSS UC paid Thurston $500.00 USD of the remaining
$800.00 USD owed for the documents. The DSS UC explained that he had a friend that was
interested in purchasing a set of documents for the same purpose. Thurston agreed to sell the
DSS UC another set of un-altered identity documents at a future date.
9. On or about September 1, 2005, after a phone call to confirm the time and location of
the meeting the DSS UC, along with a second DSS Agent acting in an under cover capacity, met
with Thurston at Wal—Mart located on Wilton Boulevard at Rte 13 and Rte 40, New Castle,
Delaware. During the meeting Thurston gave the DSS UC an un-altered birth certificate with the
initials S.L.D born ’l978. In return the DSS UC paid Thurston $1,500 USD. During the
meeting, Thurston stated that the documents he was providing were of sufficient quality to allow
the second DSS Agent to obtain a passport and discussed the process by which a passport could
be obtained. Thurston was arrested without incident after the purchase of documents. Thurston
was read his Miranda warnings by law enforcement officers and agreed to speak with law
enforcement. Thurston admitted to participating in the above meetings with DSS UC Agents.
Thurston also admitted that he sells altered and un-altered identity documents for the purposes of
assisting others to obtain state identification documents and passports.
10. Based on these facts your affiant respectfully requests the court to find probable
cause to issue a criminal complaint against Lewis Thurston a/k/a Louis Dyson for violation of
2

Case 1:05-cr-00081-KAJ Document 2 Filed O9/O2/2005 Page 4 of 4
Title 18 United States Code, Sections 1028 (a) (7) and (b)(1)(A) & (D).
Stephen Nagy
Special Agent ofthe Department of State
Diplomatic Security Service
SUBSCRIBED AND SWORN TO
BEFORE ME mrs 2ND DAY OF
SEPTEMBER, 20
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