Case 1:24-mj-00364-GMH Document 1 Filed 11/21/24 Page 1 of 1
AO 91 (Rev. 11/11) Criminal Complaint
UNITED STATES DISTRICT COURT
for the
District of &ROXPELD
United States of America )
v. )
) Case No.
Dane Christoffer Thompson
)
DOB: XXXXXX )
)
)
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 January 6, 2024 in the county of in the
LQ WKH 'LVWULFW RI &ROXPELD , the defendant(s) violated:
Code Section Offense Description
18 U.S.C. § 111(a)(1)- Assaulting, Resisting, or Impeding Certain Officers
18 U.S.C. § 231(a)(3)- Civil Disorder
18 U.S.C. § 1752(a)(1)- Entering and Remaining in a Restricted Building or Grounds
18 U.S.C. § 1752(a)(2)- Disorderly and Disruptive Conduct in a Restricted Building or Grounds
18 U.S.C. § 1752(a)(4)- Engaging in Physical Violence in a Restricted Building or Grounds
40 U.S.C. § 5104(e)(2)(D)- Disorderly Conduct in a Capitol Building
40 U.S.C. § 5104(e)(2)(F)- Act of Physical Violence in the Capitol Grounds or Buildings
This criminal complaint is based on these facts:
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Date: 11/21/2024
Judge’s signature
City and state: :DVKLQJWRQ '& G. Michael Harvey, U.S. Magistrate Judge
Printed name and title
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STATEMENT OF FACTS
Your affiant, , is a Special Agent with the Federal Bureau of
Investigation (“FBI”) assigned to the Sacramento Field Office and has been so employed for over
a decade. I received training at the FBI Academy in Quantico, Virginia, from October 2012 to
March 2013. During my tenure with the FBI, I have worked in the areas of white-collar crime,
domestic terrorism, counterintelligence, and violent crime. I have served as a Supervisory Special
Agent at FBI Headquarters in Washington, D.C., and presently work on a violent crime squad in
the Eastern District of California. Before joining the FBI, I practiced law for approximately five
years. I am an “investigative or law enforcement officer” of the United States within the meaning
of 18 U.S.C. § 2510(7), in that I am an officer of the United States empowered by law to conduct
criminal investigations and make arrests for offenses enumerated in 18 U.S.C. § 2516.
This affidavit is based upon my own personal knowledge but also information I have
obtained from other law enforcement officers and/or third parties (for example, information from
an FBI Intelligence Analyst and United Airlines). Where I describe statements made by other
people, information contained in reports and/or other documents or records in this affidavit, that
information is described in sum, substance, and relevant part. Where I quote portions of
conversations, they are verbatim or near verbatim quotes. Where I insert images below, they are
screen captures pertaining to the incident or evidence being described.
The U.S. Capitol is secured 24 hours a day by U.S. Capitol Police (“USCP”). Restrictions
around the U.S. Capitol include permanent and temporary security barriers and posts manned by
U.S. Capitol Police. Only authorized people with appropriate identification were allowed access
inside the U.S. Capitol. On January 6, 2021, the exterior plaza of the U.S. Capitol was also closed
to members of the public.
On January 6, 2021, a joint session of the United States Congress convened at the United
States Capitol, which is located at First Street, SE, in Washington, D.C. During the joint session,
elected members of the United States House of Representatives and the United States Senate were
meeting in separate chambers of the United States Capitol to certify the vote count of the Electoral
College of the 2020 Presidential Election, which had taken place on November 3, 2020. The joint
session began at approximately 1:00 p.m. Shortly thereafter, by approximately 1:30 p.m., the
House and Senate adjourned to separate chambers to resolve a particular objection. Vice President
Mike Pence was present and presiding, first in the joint session, and then in the Senate chamber.
As the proceedings continued in both the House and the Senate, and with Vice President
Mike Pence present and presiding over the Senate, a large crowd gathered outside the U.S. Capitol.
As noted above, temporary, and permanent barricades were in place around the exterior of the U.S.
Capitol building, and U.S. Capitol Police were present and attempting to keep the crowd away
from the Capitol building and the proceedings underway inside.
At such time, the certification proceedings were still underway and the exterior doors and
windows of the U.S. Capitol were locked or otherwise secured. Members of the U.S. Capitol Police
attempted to maintain order and keep the crowd from entering the Capitol; however, around 2:00
p.m., individuals in the crowd forced entry into the U.S. Capitol, including by breaking windows
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and by assaulting members of the U.S. Capitol Police, as others in the crowd encouraged and
assisted those acts.
Shortly thereafter, at approximately 2:20 p.m. members of the United States House of
Representatives and United States Senate, including the President of the Senate, Vice President
Mike Pence, were instructed to—and did—evacuate the chambers. Accordingly, the joint session
of the United States Congress was effectively suspended until shortly after 8:00 p.m. Vice
President Pence remained in the United States Capitol from the time he was evacuated from the
Senate Chamber until the sessions resumed.
During national news coverage of the events, video footage which appeared to be captured
on mobile devices of persons present on the scene depicted evidence of violations of local and
federal law, including scores of individuals inside the U.S. Capitol building without authority to
be there.
AFO # 292’s Participation in the January 6th Riot
Following the January 6, 2021 Capitol riot the FBI identified an unknown subject, AFO #
292. (“AFO” stands for “assault on a federal officer.”) Based on my review of video footage from
the vicinity of the Capitol on January 6, 2021, AFO # 292 wore a navy-blue beanie with the letters
“TRUMP” in white, a dark-colored hoodie with beige fleece-like lining and beige piping, blue
jeans, a red neck buff, and what appeared to be a Timex Ironman watch. He also carried a dark-
colored backpack. (Image 1)
Image 1: AFO # 292 at the Capitol on January 6, 2021
On the morning of January 6, 2021, AFO # 292 attended then-President Trump’s “Stop the
Steal Rally” near the National Mall. (Image 2)
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Image 2: Excerpt from open-source footage of AFO # 292 (yellow box) near the Washington
Monument.
Following the rally, AFO 292 walked with the crowd along Pennsylvania Avenue to the
Capitol. (Image 3).
Image 3: Excerpt from open-source video footage showing AFO # 292 (yellow circle) travelling
from the Stop the Steal Rally.
AFO # 292 initially arrived on the Capitol’s West Front. He moved through the crowd to
the front of the mob where police officers had arranged bicycle rack barricades near the Inaugural
Stage. Open-source images and videos captured AFO # 292 directly in front of these barricades,
adjacent to a media tower that had been erected for the upcoming presidential inauguration. At this
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location, AFO # 292 joined other rioters in their attempts to bypass police and the barricades and
physically interfered with officers as he attempted to breach the police line at this location. (Image
4)
Image 4: AFO # 292 in front of the bike racks on the West Plaza
Open-source footage captured AFO # 292 grabbing a bike rack at the front of the police line
and wrestling it away from an officer. (Image 5)
Image 5: Photograph showing AFO # 292 grabbing the barricade.
At approximately 2:28 p.m., the police line on the West Plaza collapsed after rioters
overcame officers, forcing officers to fall back toward the Capitol building. AFO # 292 surged
forward with other rioters. During this surge, at approximately 2:29 p.m., open-source and body
worn camera (“BWC”) captured AFO # 292 physically interacting with police officers.
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provided me with information indicating that THOMPSON traveled to or from the following
places at the following times:
1) Frankfurt Airport (December 2023)
2) Vaclav Havel Airport Prague (December 2023)
3) Munich International Airport (December 2023)
4) Budapest Ferenc Liszt International Airport (December 2023)
5) Singapore Changi Airport (March 2024)
6) Kuala Lumpur International Airport (March 2024)
7) Hong Kong International Airport (March 2024)
8) Hong Kong International Airport (April 2024)
THOMPSON’s wife maintains a blog that chronicles trips that the Thompson family took
(“Website-2”). On Website-2, there are posts corresponding with these locations and mentioning
that the family traveled via United Airlines.
On November 6, 2024, I attempted to interview THOMPSON at his residence in Granite
Bay, California with one of my colleagues. After identifying ourselves, I asked THOMPSON if he
had a couple of minutes to talk. THOMPSON said he did not. I advised THOMPSON that his
name came up in connection with the January 6 case and asked if he was sure he could not take
approximately five to ten minutes to speak with me and my partner. THOMPSON responded, “No.
I don’t want to talk.” I then asked THOMPSON if he was indicating that he did not want to talk at
all (as opposed to at that time), to which THOMPSON replied: “Ah, yeah.” I then asked if
THOMPSON would say whether he was in Washington D.C. on January 6, to which he responded:
“Um, I would, I would just like you guys to, uh, please exit my property.” I wished Thompson a
good evening and my partner and I left THOMPSON’s residential lot. The entire conversation
lasted approximately 50 seconds.
Based on the totality of my investigation in this matter – including the review of
information obtained from United Airlines, video/images from the U.S. Capitol, images of
THOMPSON from social media and on the internet, and my attempted interview of THOMPSON
at his residence – I assert that THOMPSON is AFO # 292, and committed the conduct depicted above.
Based on all of the above, your affiant submits there is probable cause to believe that
DANE CHRISTOFFER THOMPSON violated 18 U.S.C. § 111(a)(1), which makes it a crime to
forcibly assault, resist, oppose, impede, intimidate, or interfere with any person designated in
section 1114 of Title 18 while engaged in or on account of the performance of official duties,
where such acts involve physical contact with the victim or the intent to commit another felony.
Persons designated within section 1114 of Title 18 include federal officers such as USCP officers,
and include any person assisting an officer or employee of the United States in the performance of
their official duties.
I also submit there is probable cause to believe that DANE CHRISTOFFER THOMPSON
violated 18 U.S.C. § 231(a)(3), which makes it unlawful to commit or attempt to commit any act
to obstruct, impede, or interfere with any fireman or law enforcement officer lawfully engaged in
the lawful performance of his official duties incident to and during the commission of a civil
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disorder which in any way or degree obstructs, delays, or adversely affects commerce or the
movement of any article or commodity in commerce or the conduct or performance of any
federally protected function. For purposes of Section 231 of Title 18, a federally protected function
means any function, operation, or action carried out, under the laws of the United States, by any
department, agency, or instrumentality of the United States or by an officer or employee thereof.
This includes the Secret Service’s protection of the Vice President and his family and the Capitol
Police’s protection of the U.S. Capitol.
I further submit there is probable cause to believe that DANE CHRISTOFFER
THOMPSON violated 18 U.S.C. §§ 1752(a)(1), (2), and (4) which makes it a crime to (1)
knowingly enter or remain in any restricted building or grounds without lawful authority to do so;
(2) knowingly, and with intent to impede or disrupt the orderly conduct of Government business
or official functions, engage in disorderly or disruptive conduct in, or within such proximity to,
any restricted building or grounds when, or so that, such conduct, in fact, impedes or disrupts the
orderly conduct of Government business or official functions; (4) knowingly engage in any act of
physical violence against any person or property in any restricted building or grounds; or attempt
or conspire to do so. For purposes of Section 1752 of Title 18, a “restricted building” includes a
posted, cordoned off, or otherwise restricted area of a building or grounds where the President or
other person protected by the Secret Service, including the Vice President, is or will be temporarily
visiting; or any building or grounds so restricted in conjunction with an event designated as a
special event of national significance.
In addition, I submit there is probable cause to believe that DANE CHRISTOFFER
THOMPSON violated 40 U.S.C. §§ 5104(e)(2)(D) and (F) which makes it a crime to willfully
utter loud, threatening, or abusive language, or engage in disorderly or disruptive conduct, at any
place in the Grounds or in any of the Capitol Buildings with the intent to impede, disrupt, or disturb
the orderly conduct of a session of Congress or either House of Congress, or the orderly conduct
in that building of a hearing before, or any deliberations of, a committee of Congress or either
House of Congress; and (F) engage in an act of physical violence in the Grounds or any of the
Capitol Buildings.
FEDERAL BUREAU OF INVESTIGATION
Attested to by the applicant in accordance with the requirements of Fed. R. Crim. P. 4.1
by telephone, this 21st day of November 2024.
___________________________________
HONORABLE G. MICHAEL HARVEY
U.S. MAGISTRATE JUDGE
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