Read the criminal complaint against Jack Teixeira

Case 1:23-mj-04293-DHH Document 3-1 Filed 04/14/23 Page 2 of 8

and witnesses. This affidavit is intended to show merely that there is sufficient probable cause for TEIXEIRA’s arrest and does not set forth all of your affiant’s knowledge about this matter.

both.

4. For the reasons set forth below, I submit that there is probable cause to believe that TEIXEIRA committed a violation of Title 18, United States Code, Sections 793(b) and (d) and Title 18, United States Code, Section 1924.

Pursuant to 18 U.S.C. § 793(b), “[w]hoever . . . copies, takes, makes, or obtains, or attempts to copy, take, make or obtain, any sketch, photograph, photographic negative, blueprint, plan, map, model, instrument, appliance, document, writing, or note of anything connected with the national defense” shall be fined or imprisoned not more than ten years, or

5.

STATUTORY AUTHORITY AND DEFINITIONS

6.

Pursuant to 18 U.S.C. § 793(d), “[w]hoever, lawfully having possession of, access to, control over, or being entrusted with any document . . . or note relating to the national defense, or information relating to the national defense which information the possessor has reason to believe could be used to the injury of the United States or to the advantage of any foreign nation, willfully communicates, delivers, transmits or causes to be communicated, delivered, or transmitted or attempts to communicate, deliver, transmit or cause to be communicated, delivered or transmitted the same to any person not entitled to receive it, or willfully retains the same and fails to deliver it on demand to the officer or employee of the United States entitled to receive it” shall be fined or imprisoned not more than ten years, or both.

7. Pursuant to 18 U.S.C. § 1924, it is illegal for any officer, employee, contractor, or consultant of the United States, who, by virtue of his/her office, employment, position, or contract, becomes possessed of documents or materials containing classified information, to