March 19, 2003 Criminal Complaint by cln12100

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									AO 91 (Rev. 5/85) Criminal Complaint



                              United States District Court
                                               For The District of Columbia

          UNITED STATES OF AMERICA                                                CRIMINAL COMPLAINT
                              V.

          DWIGHT W. WATSON
          DOB: 9/28/52                                                               CASE NUMBER:
          PDID: 548-610


                 (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                  March 17, 2003            in       Washington, D.C.            county, in the

__________________ District of              Columbia    defendant(s) did, (Track Statutory Language of Offense)




in violation of Title        18    United States Code, Section(s)            844(e)         .

I further state that I am Todd C. Reid, Detective with the United States Park Police , and that this complaint is
based on the following facts:

       See Attached Affidavit



Continued on the attached sheet and made a part hereof:                              : Yes                 9 No
                                                                          Signature of Complainant
AUSA, Jay I. Bratt (202) 353-3602                                         Todd C. Reid, Detective
Sworn to before me and subscribed in my presence,                         United States Park Police


                                                               at             Washington, D.C.
Date                                                                                 City and State




_______________________________                                           _______________________________________
Name & Title of Judicial Officer                                          Signature of Judicial Officer
                    AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT
                               DWIGHT WARE WATSON
                                     DOB: 9/28/52


        I, Todd C. Reid, being first duly sworn, depose and state as follows:

        1.       I am a Detective with the United States Park Police (“USPP”). I have been a member

of the USPP for approximately 16 years. For the last 7 years, I have been assigned to the Major

Crimes Unit, where my responsibilities include the investigation of crimes that occur on National Park

Service property in the Washington, D.C., metropolitan area. Among the offenses I investigate are

homicides, rapes, assaults, robberies, destruction of property, and bomb threats. Before becoming a

Detective, I first spent 3 years as a patrol officer with the USPP and then 5 years as an Investigator

with the Narcotics and Vice Unit. I have received extensive training in criminal investigation procedures

and criminal law at the Federal Law Enforcement Training Center in Glynco, Georgia, and from other

law enforcement organizations. In the course of my work, I have obtained approximately 100 search

warrants and 50 arrest warrants.

        2.       The information contained in this affidavit is based on my personal knowledge and

observations made during the course of this investigation; on information conveyed to me by other law

enforcement officials; and on my review of records, documents, and other physical evidence obtained

during the investigation.

        3.       This affidavit is in support of a criminal complaint charging DWIGHT WARE

WATSON with, in or affecting interstate commerce, willfully making a threat and maliciously conveying

false information knowing the same to be false, concerning an attempt or alleged attempt to kill, injure,

or intimidate an individual, or unlawfully to damage or destroy a building, vehicle, or other property by
means of an explosive, in violation of 18 U.S.C. § 844(e). This affidavit is not intended to include each

and every fact and matter observed by me or known to the government, but is offered solely as a basis

for probable cause for the complaint.

        4.       On March 17, 2003, at approximately 12:34 p.m., a white male entered the National

Mall area driving a green John Deere farm tractor with an enclosed cab and pulling an orange Jeep type

of vehicle with a yellow trailer attached to it. Two witnesses, both private citizens, observed the male,

who was later identified as DWIGHT WARE WATSON, drive the tractor and attached vehicles into

the body of water at Constitution Gardens located in the general vicinity of 17th Street and Constitution

Avenue, NW, Washington, D.C., on the National Mall. Witness 1 reported observing WATSON

unhook the jeep and trailer from the tractor. Witness 2 reported observing WATSON driving the

tractor in circles in the water.

        5.       WATSON communicated with a USPP officer who responded to the scene and

provided two cellular telephone numbers and his first name, Dwight. WATSON advised the USPP

officer that he didn’t want to hurt anyone but if he saw SWAT (Special Weapons and Tactics)

personnel, he would take action. WATSON claimed to have organic phosphates, a fertilizer that can

be used as an explosive. WATSON stated that the items he possessed would explode when mixed

with water. WATSON warned authorities that he would detonate the explosives in the tractor and on

the trailer if anyone attempted to approach his vehicles. WATSON expressed discontent with the

United States Government’s treatment of Gulf War veterans and the United State’s Government’s

tobacco policy toward farmers. The authorities learned that WATSON had traveled to Washington,

D.C., from Whitakers, North Carolina.

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        6.      Over the next approximately 48 hours, WATSON made several statements to USPP

negotiators similar to those described in the preceding paragraph concerning his possession of

explosives and his intent to detonate them. He repeatedly told negotiators that his tractor and the trailer

contained organic phosphates that were set to explode if anyone approached him. On January 18,

2003, WATSON told negotiators that he planned to damage the National Mall, and he demanded that

Washington, D.C., be evacuated within 82 hours. WATSON further advised the USPP negotiators

that he had placed explosive items on Interstate 95 near the Phillip Morris Sign in Richmond, Virginia,

on Columbia Island in Washington, D.C., and behind the Marine Corps Museum in Washington, D.C.

WATSON stated that these items would explode if mixed with water.

        7.      On March 19, 2003, at approximately 8:00 a.m., WATSON informed the USPP

negotiators that he was through with his action and would surrender at 12:00 p.m. At approximately

11:41 a.m. on March 19, 2003, WATSON drove the tractor to the edge of the pond, left the cab, and

surrendered to the authorities. There were no explosives in either the tractor, the trailer, or the Jeep.

Inside the cab of the tractor, there was an inert hand grenade replica similar to those commonly

available from military surplus stores. The authorities also did not find any explosives at the other

locations described in the preceding paragraph.

        8.      As a result of WATSON’S actions, law enforcement authorities closed the following

streets in the District of Columbia for approximately 48 hours: Constitution Avenue, NW, between 15th

and 23rd Streets; 17th Street, between C Street, NW, and Independence Avenue, SW; 18th Street,

NW, between Constitution Avenue and C Street; and 19th Street, NW, between Constitution Avenue

and C Street. These closures seriously disrupted the morning and evening commutes in the national

                                                    -3-
capital. Constitution Avenue, in particular, is a major thoroughfare connecting the District of Columbia

with the State of Virginia, feeding into both the Memorial Bridge and Roosevelt Bridge. In addition,

WATSON’S activities forced the closure of several institutions, including the Organization of American

States and the Department of Interior – South Building. Each day, between two shifts, approximately

200 law enforcement officers were present in the vicinity of Constitution Gardens. They represented

the following law enforcement agencies: USPP, FBI, ATF, Secret Service, Capitol Police, and the

Metropolitan Police Department. The authorities in North Carolina were also involved in assisting the

investigation of WATSON’S activities.

        9.      Based on the foregoing facts, your affiant respectfully submits that probable cause exists

to believe that DWIGHT WARE WATSON, in or affecting interstate commerce, willfully made a

threat and maliciously conveyed false information, knowing the same to be false, concerning an attempt

or alleged attempt to kill, injure, or intimidate an individual, or unlawfully to damage or destroy a

building, vehicle, or other property by means of an explosive, in violation of 18 U.S.C. § 844(e).




                                                           Todd C. Reid, Detective
                                                           United States Park Police


Subscribed and sworn before me this 20th day of March, 2003.




                                                  United States Magistrate Judge




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