ANDREA T.

MARTINEZ, Acting United States Attorney (#9313)

CAROL A. DAIN, Assistant United States Attorney (#10065)
Attorneys for the United States of America
Office of the United States Attorney
111 South Main Street, Suite 1800
Salt Lake City, Utah 84111-2176
Telephone: (801) 524-5682

IN THE UNITED STATES DISTRICT COURT

DISTRICT OF UTAH

UNITED STATES OF AMERICA, Case No. 2:21-mj-00747 CMR

Plaintiff, COMPLAINT

vs. VIO. 18 U.S.C. § 2250(a), FAILURE TO

REGISTER.
JOHN F. COLT,

Defendant. Judge Cecilia M. Romero

Before the Honorable Cecilia M. Romero, United States Magistrate Judge for the

District of Utah, appeared the undersigned, who on oath deposes and says:

COUNT I
(18 U.S.C. § 2250(a))
Failure to Register

Between on or about August 12, 2021 and continuing through September 27,

2021, in the District of Utah,

JOHN F. COLT,

the defendant herein, an individual required to register under the Sex Offender

Registration and Notification Act, who traveled in interstate commerce, did knowingly
fail to update a registration as required by the Sex Offender Registration and Notification

Act; all in violation of 18 U.S.C. § 2250(a).

Elements of 18 U.S.C. § 2250(a)

1. The defendant was required to register under the Sex Offender Registration
and Notification Act; and
2. The defendant traveled in interstate and foreign commerce; and
3. The defendant knowingly failed to register or update my registration as
required by the Sex Offender Registration and Notification Act.

This complaint is made on the basis of an investigation consisting of the

following:

I, Jason Pizza, being duly sworn state the following is true and correct to the best

of my knowledge and belief:

1. I am a Deputy with the United States Marshals Service and have been so

since June 2016, and as such, I am charged with enforcing all laws in all jurisdictions of

the United States, its territories, and possessions. My primary duty and assignment

obligates me to apprehend state and federal felony fugitives.

2. I have personally participated in the investigation set forth below. I am

familiar with the facts and circumstances of the investigation through my personal

participation; from discussions with other agents of the United States Marshals Service

and other law enforcement agencies; from my discussions with witnesses involved in the

investigation; and from my review of records and reports relating to the investigation.
 Probable Cause

3. On July 14, 2021, The US Marshals Service adopted a case from Pawnee

County Sheriff King involving John F. COLT.

4. COLT was convicted on an original charge of Aggravated Sexual Battery

and Aggravated Burglary in 2002 in Shawnee County (Kansas) District Court Case 00-

CR-2802. This charge was from an incident where COLT broke into a woman's

apartment, sexually assaulted her while holding his hand over her mouth, preventing her

from screaming. COLT was sentenced to five years in prison and was required to register

as a sex offender for life.

5. After COLT's sentence was completed, in 2006, the District Court in

Shawnee County deemed him a violent sexual predator and a danger to society. COLT

was committed to the custody of the Secretary of the Department of Social and

Rehabilitation Services for control, care, and treatment until such time as it was

determined that he is safe to be at large. COLT was remanded to the custody of the

Larned State Mental Hospital.

6. COLT was assigned to the Sexual Predator Unit at Larned State Hospital

and registered as a Sex Offender with the Pawnee County Sheriff's Office. While at

Larned State Hospital, COLT has said that his hostility towards women is escalating, and

if he ever gets out he will go on a "Rape Spree." The clinical psychologist testified in

court that COLT has become too dangerous to be released as he would be at high risk of

committing a future sex offense.

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 7. On June 30, 2021, COLT escaped from the Larned State Hospital.

8. COLT appears to have been aided in his escape by an employee at Larned

State Hospital. Communications discovered by law enforcement reveal COLT had

established an intimate relationship with the employee and discussed plans for his escape

months in advance. COLT was seen repeatedly mentioning Colorado in messages with

the employee.

9. In communications with the employee, COLT discussed his intent to camp

in rural areas specifically discussing the Rocky Mountains to avoid contact with persons

that could identify him. COLT outlined his plan to travel to Mexico after law

enforcement interest waned. COLT’s planning included obtaining an accurate counterfeit

hospital ID, clothing, a tent, a solar cell phone charger, other camping equipment, and a

motorcycle.

10. Following his escape, COLT traveled west towards Colorado and made

purchases in Scott City, Kansas, 70 miles from the Colorado border. COLT’s activity was

captured on surveillance video. While in Scott City, COLT asked for direction to Garden

City, Kansas.

11. Escape flyers of COLT were distributed to Federal, State, and Local Law

Enforcement in the Rocky Mountains in Colorado and Utah. Law enforcement received

multiple tips about COLT having a tent site near Wayne County. Wayne County Sheriff’s

Officers staged at a nearby parking lot to arrest COLT. While there they observed COLT

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drive by on the blue motorcycle and initiated a traffic stop. COLT was arrested after a brief

high speed pursuit.

12. After COLT’s arrest a new Facebook alias was identified. COLT posted

numerous photos of his campsite, tent, motorcycle, and COLT posing with a shotgun

having a pistol grip and a magazine fed rifle with a folding stock. On the “Jason Holt”

alias Facebook page, COLT posted about: living in Utah (August 21, 2021). D. A.,

whose parents own the “Chuckwagon (General) Store and Deli,” located at 12 W. Main

Street Torrey, Utah 84775, stated that COLT began working in the store around August

12th, 2021.

13. Following his escape, COLT has remained non-compliant with his Kansas

Sex Offender Registration. A check of the National Sex Offender Registry shows that

COLT has not reported his updated residence or location information that he

acknowledged was required on his sex offender registration form dated June 20, 2017. A

check of the Utah Department of Corrections Sex Offender Notification and Registration

website showed that COLT has not registered as required in Utah.

14. Based on the foregoing facts, I assert there is probable cause to believe

COLT is an individual required to register as a sex offender and has traveled in interstate

commerce, from Kansas to Utah, and knowingly failed to update his registration, in

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violation of 18 U.S.C. § 2250(a), and your affiant respectfully requests that an arrest

warrant be issued for JOHN F. COLT for a violation of 18 U.S.C. § 2250(a).

DATED this 28th day of September, 2021.

/s/ Jason Pizza

JASON PIZZA
Deputy United States Marshal
United States Marshals Service

Attested to by the applicant in accordance with the requirements of Fed. R. Crim.

P. 4.1 on this 28th day of September, 2021.

CECILIA M. ROMERO
United States Magistrate Judge

APPROVED:

ANDREA T. MARTINEZ
Acting United States Attorney

CAROL A. DAIN
Assistant United States Attorney