Case 2:21-mj-00071-DM Document 1 Filed 06/18/21 Page 1 of 4

AO 91 (Rev. 11/11) Criminal Complaint

UNITED STATES DISTRICT COURT

for the
Eastern District
__________ Districtofof
Louisiana
__________

United States of America )

v. )
) Case No.
RUSSELL VENNELL ) 21-mj-71
)
)
)
Defendant(s)

CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
On or about the date(s) of June 13, 2021 in the county
parish of Jefferson in the
Eastern District of Louisiana , the defendant(s) violated:

Code Section Offense Description

18 U.S.C. § 875(c) Transmission in interstate or foreign commerce of any communication
containing any threat to injure the person of another.

This criminal complaint is based on these facts:

see attached Affidavit.

✔ Continued on the attached sheet.

u

s/Brock Flint
Complainant’s signature

Special Agent Brock Flint, Federal Bureau of Investigation

Printed name and title

Sworn to before me and signed in my presence.

Date: June 18, 2021

Judge’s signature

City and state: New Orleans, Louisiana Honorable Janis van Meerveld, U.S. Magistrate Judge
Printed name and title
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UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF LOUISIANA

UNITED STATES OF AMERICA * NO. 21-mj-71

v. *

RUSSELL VENNELL *

* * *

AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT

I, BROCK FLINT, being duly sworn, depose and state:

1. I am a Special Agent (SA) with the Federal Bureau of Investigation (FBI), and

assigned to the New Orleans Field Office. I have been employed as a Special Agent for two years,

and have participated in numerous investigations. Previous to my employment with the FBI I was

an Explosive Ordnance Disposal specialist with United States Air Force specializing in Improvised

Explosive Devices. I have an undergraduate degree in Security and Intelligence focused on

terrorism. I have studied terrorist attacks and the radicalization process prior to them. I am

presently assigned to the Joint Terrorism Task Force, based in New Orleans, Louisiana. The task

force is currently investigating an individual who threatened to kill S.H. and that he would wipe

the entire Brookings Institution off the face of the earth. The subject furthermore stated that they,

the Brookings Institution, deserved death in the most heinous way.

2. I am familiar with the circumstances of the offenses described in this affidavit

though a combination of personal knowledge of the facts; discussions with other FBI SAs;

discussions with other law enforcement officials; and, other investigative activities conducted and

investigative materials obtained during the investigation.

3. I make this affidavit in support of a criminal complaint charging RUSSELL

VENNELL with violating Title 18, United States Code, Section 875(c), communications
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transmitted in interstate or foreign commerce containing any threat to injure the person of another.

This affidavit does not include all facts known to me, but rather contains facts sufficient to support

the issuance of an arrest warrant.

4. On March 3, 2021, an appellate attorney representing N.N., received a phone call

from telephone number (504) 335-7651. The caller stated that “If [N.N.] was not deported, I intend

to hunt him down and torture him myself.” At the time, the appellate attorney was representing

N.N. in a case before the United States Supreme Court. Through the course of an investigation,

(504) 335-7651 was found to be subscribed to RUSSELL VENNELL, who resides at xxx Terrace

Street, Jefferson, LA 70121.

5. FBI Special Agents interviewed VENNELL about the conversation with the

attorney on March 3, 2021. VENNELL admitted to making the phone call.

6. On June 13, 2021, at approximately 2:08 a.m. ET, a person called the Brookings

Institution, 1775 Massachusetts Avenue NW, Washington, DC 20036, from telephone number

(504) 335-7651, the same number used in the March 3, 2021 call and found to be subscribed to

VENNELL. The subject told a Special Police Officer with the Brookings Institution that he was

going to kill S.H., a person employed by the Brooking Institution at the time of the call. The subject

later left a voicemail reiterating the previous threat he made to kill S.H., and wipe the Brookings

Institution off the face of the earth. The subject specifically stated “I called you a little while ago

telling you I was going to kill S.H. I gotta (sic) revamp that. I am going to wipe the entire

Brookings Institution off the face of the fucking earth. You are scum sucking evil motherfuckers

and you all deserve death in the most heinous way and it’s coming at you.”

7. Through the course of this investigation, the cell phone (504) 335-7651 was found

to be subscribed to VENNELL.

2
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8. Through the course of the investigation, FBI SAs identified VENNELL’s Chevy

Silverado Z71 parked outside his residence at xxx Terrace Street, Jefferson, LA 70121.

9. For the foregoing reasons, I respectfully submit that there is probable cause to

believe that on June 13, 2021, VENNELL did, through the use of a telephone, willfully make a

threat, regarding an attack to kill S.H. and cause willful destruction of the Brookings Institution,

in violation of 18 U.S.C. § 875(c).

Respectfully submitted,

s/Brock Flint
Special Agent Brock Flint
Federal Bureau of Investigation

Pursuant to Federal Rules of Criminal Procedure 4.1 and 41(d)(3), the undersigned judicial
officer has on this date considered the information communicated by reliable electronic means in
considering whether a complaint, warrant, or summons will issue. In doing so, I have placed the
affiant under oath, and the affiant has confirmed that the signatures on the complaint, warrant, or
summons and affidavit are those of the affiant, that the document received by me is a correct and
complete copy of the document submitted by the affiant, and that the information contained in the
complaint, warrant, or summons and affidavit is true and correct to the best of the affiant’s
knowledge.

Subscribed to and sworn before me,

this ______ day of June, 2021,
New Orleans, Louisiana.

____________________________________
Honorable Janis van Meerveld
United States Magistrate Judge