Free Complaint - District Court of Delaware - Delaware

AO (Rev- 12/93)Cg[a§e_a1:QO§6par{r00é16-GMS Document 1 Filed 10/20/2006 Page 1 of 4
United States District Court
DISTRICT OF DELAWARE
UNITED STATES OF AMERICA
v.
Criminal Complaint 06- I M .. p|f‘]"
DENNIS D. CARSON
(Name and Address of Defendant)
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 October I0, 2006, in Kent County, in the District of Delaware, and elsewhere,
defendant(s), (Track Statutory Language of Offense):
With the intent to extort any money or other thing of value, transmitted in interstate commerce a communication containing a threat to
injure the person of another,
in violation of Title 18 United States Code, Section(s) 875gb) and gc) .
I further state that I am a(n) Special Agent, Federal Bureau of Investigation and that this complaint is based
Official Title
on the following facts:
SEE ATTACHED AF FIDAVIT
Continued on the attached sheet and made a part hereof: YES G _ · Q
F | L E U . ./
Signature of Complainant
Taneka S. Harris
OCT 2 U 2006 Special Agent
Federal Bureau of Investigation
us. BISTRIGT COURT
DISTRICT Of DELAWARE
Sworn to before me and subscribed in my presence,
October 20, 2006 at Wilmington, DE
Date City and State
Honorable Mary Pat Thynge , M
United States Magistrate Judge AL _ JL; . I ..L
Name & Title of Judicial Officer w ature of Judicial ffic

Case 1:06-cr-00116-GIVIS Document 1 Filed 10/20/2006 Page 2 of 4
AFFIDAVIT OF TANEKA S. HARRIS
I, Taneka S. Harris, having been duly sworn, do hereby depose and state:
1. I am a Special Agent with the Federal Bureau of Investigation (FBI) and have
been so employed for approximately two years. I have been assigned to the FBI office located in
Wilmington, Delaware since May 2005. During my employment with the FBI, I have
investigated a variety offenses within the criminal program.
2. This affidavit is submitted in support of a Criminal Complaint charging DENNIS
D. CARSON (CARSON) with a violation of Title 18, United States Code, Section 875(b)
(Interstate Communications), which makes it a crime for a person, with intent to extort from any
person any money or other thing of value, to transmit in interstate commerce any communication
containing any threat to injure the person of another. Additionally, this affidavit is submitted in
support of a Criminal Complaint charging CARSON with a violation of Title 18, United States
Code, Section 875(c) (Interstate Communications), which makes it a crime for a person to
transmit in interstate cornrnerce any communication containing any threat to injure the person of
another.
3. I have personally participated in this investigation since its inception in October
2006, and am familiar with the facts contained in this affidavit. The information contained in
this affidavit was obtained by reviewing a letter written by CARSON and interviewing victims of
these offenses. The information contained in this affidavit is not a complete recitation of the
facts and evidence discovered during this investigation.
4. James E. Wallace, Jr., Esquire (Wallace), a partner at Bowditch and Dewey, LLP
(B&D, LLP), has advised that Christine Collins, Esquire is an associate with B&D, LLP. B&D,
LLP provides legal representation for Springfield College (Springfield). Springfield's main
campus is located in Massachusetts, and one of its satellite campuses is located in Wilmington,
Delaware.
5. CARSON enrolled at the Wilmington, Delaware campus of Springfield in fall
2004. Circa March 2005, CARSON was dismissed from Springfield for violations of the Code
of Student Conduct. Thereafter, CARSON filed a civil suit against Springfield in October 2005.
6. In 2006, Collins was assigned to handle the defense of the lawsuit against
Springfield brought by CARSON. On October 10, 2006, CARSON faxed Collins at her B&D,
L-LP fax number a four—page letter dated October 7, 2006, from a Staples Copy and Print Center
(Store Number 0301) located at 1041 North Dupont Highway, Dover, Delaware 19901.
CARSON sent the letter from fax number (302) 736-5886. A representative from Staples Copy
and Print Center confirmed that fax number printed on the cover sheet utilized by CARSON
belonged to Store Number 0301. Said lcttcr was received by Collins in Worcester,
Massachusetts on the same date.

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training, he was "in a very unique position to state my opinion" about the massacre. CARSON
went on to make specific suggestions about particular weapons the Columbine High School
shooters should have used, including a Springfield Armory M—l4, which he termed "the finest
combat weapon there ever was" and noted that his girlfriend had, among other weapons.
Additionally, CARSON wrote that the Columbine High School shooters should have shot each of
the victims twice, and utilized ammonia nitrate bombs for greater devastation. In the context of
the letter, CARSON's references to the Columbine High School shooting massacre suggested that
if his current lawsuit against Springfield was not resolved in his favor, similar events might
result.
8. CARSON advised in the letter that he "is sitting on a lot of hatred" because of his
dismissal from Springfield. Moreover, in response to his dismissal and litigation with
Springfield, CARSON wrote the following, "l will not rest until I complete my objectives and I
will use the same tenacity to insure that l receive justice from Springfield College one way or
another and that is not a threat either."
9. CARSON continued by writing the following statements:
My position is that when Springfield College kicked me out
of the college they shot their load. VVhen your law firm
answered my complaint and stated that I was not kicked
out of the college fora breach of contract but because of
a behavior problem you all shot your load. I have not shot
my load yet, but ifl have to it will be the grand daddy of
them all.
l0. Ultimately, CARSON made the following monetary demands;
Vlfhat I want is $75,000 and free tuition at Springfield
College until 1 complete the mental health counseling
program or $102,237. I will not take one Penney less! !!
I can only promise you that Springfield College, one way
or another will pay for the injustice they perpetuated
against me.
ll. On October l9, 2006, I telephonieally interviewed Collins. Collins advised that
upon reading CARSON's letter she was "speeehless" and she felt her "heart drop to the bottom of
her stomach." Collins believed the letter to be "cold and ruthless" and said the contents of the
letter made her shake. Moreover, Collins felt threatened by the words CARSON wrote in his
letter.
l2. On October 19, 2006, l interviewed Wallace telephonically. Wallace advised that
he supervises Collins at B&D LLP, and oversees the defense of the CARSON case for

Case 1:06-cr-00116-GIVIS Document 1 Filed 10/20/2006 Page 4 of 4
Springfield. Upon reviewing CARSON's letter, Wallace advised that he did not take the letter as
a joke, and believed the contents of the letter constituted serious threats.
13. Wallace advised that based upon the severity of the statements in CARSON’s
letter, Springfield's Wilmington, Delaware campus was closed to the faculty and students from
October 12, 2006 to October 18, 2006. The campus reopened on October 19, 2006, when
Springfield officials were assured that CARSON had been arrested and detained to face pending
state charges related to the letter.
WHEREFORE, your affiant avers that there is probable cause to believe that on or about October
10, 2006, DENNIS D. CARSON committed a violation of18 U.S.C. § 875 (Interstate
Communications), by faxing a letter containing threats I rom Dover, Delaware to Worcester,
Massachusetts.
__ _ Q gf Qi _
* ‘ »‘ · ' ..4 ` 'E
Taneka S. Harris
Special Agent
Federal Bureau of Investigation
Sworn and subscribed before me this Oy_ day of October, 2006.
J __i
ra le May hynge
Uni ·+ tates Magistrate Judge
District of Delaware