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AO 91 (Rev. 11/11) Criminal Complaint

UNITED STATES DISTRICT COURT FILED

for the
12:46 pm Dec 08 2021
NorthernDistrict
__________ Districtof
of__________
Ohio
Clerk U.S. District Court
United States of America ) Northern District of Ohio
v. ) Cleveland
) Case No. 0-
Chelsea Perkins
)
)
)
)
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 March 6, 2021 in the county of Cuyahoga in the
Northern District of Ohio , the defendant(s) violated:

Code Section Offense Description

18 USC 1111(a) Murder

This criminal complaint is based on these facts:

SEE ATTACHED AFFIDAVIT

✔ Continued on the attached sheet.

u

Complainant’s signature

Lynn Bilko, FBI Task Force Officer

6ZRUQWRYLDWHOHSKRQHDIWHUVXEPLVVLRQE\UHOLDEOH Printed name and title
HOHFWURQLFPHDQV)HG5&ULP3 G DQG

Date: Dec 8, 2021

Judge’s signature

City and state: Cleveland, Ohio 'DYLG$5XL],USMagistrateJudge

Printed name and title
 Case: 1:21-mj-02385-DAR Doc #: 1-1 Filed: 12/08/21 1 of 9. PageID #: 2

0-
Affidavit

I, Lynn Bilko (“Affiant”), a Task Force Officer (TFO) with the Federal Bureau of

Investigation (FBI), Cleveland Division, being duly sworn, depose and state as follows:

1. I am a Federal Task Force Officer (TFO) with the Federal Bureau of Investigation

(FBI) and have been since June 2009, assigned to the FBI Violent Crime Task Force

(VCTF) Cleveland (Ohio) Division. I have been a sworn Law Enforcement Officer

with the State of Ohio, employed by the City of Cleveland (Ohio), Division of Police

since August 1999. I have the authority to make both Federal and State arrests and

have received training in the investigation of criminal violations of the United States

Code and the Ohio Revised Code. I have received training in and conducted

investigations of numerous Federal and State criminal offenses including but not

limited to kidnappings, robberies, homicides, narcotic offenses, crimes against

children, and other violent crimes. I have gained experience through training at the

State of Ohio Peace Officers Training Academy (OPOTA) and everyday work related

to these types of investigations.

2. I am an “investigative or law enforcement officer” of the United States within the

meaning of Title 18, United States Code Section 2510(7), and am empowered by law

to conduct investigations of, and to make arrests for, offenses enumerated in Title 18,

United States Code Section 2516.

3. This affidavit is being submitted for the limited purpose of establishing probable

cause that Chelsea Perkins, age 31, of Pensacola, Florida, has violated Title 18,

United States Code Section 1111(a), Murder. The statements contained in this

affidavit are derived from information provided to me by members of the National

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Park Service Police Department, Ohio Bureau of Criminal Investigation (BCI), and

the Valley View Police Department (VVPD), as well as my own investigation of this

matter. This affidavit includes only those facts that I believe are necessary to

establish probable cause and does not include all the facts uncovered during the

investigation.

4. The court has jurisdiction to issue the complaint and arrest warrant because it is a

“court of competent jurisdiction” as defined in 18 U.S.C. § 2711. Specifically, the

Court is in the Northern District of Ohio, a district court of the United States that has

jurisdiction over the offense being investigated, see 18 U.S.C. § 2711(3)(A)(i).

JURISDICTION

5. This investigation concerns violations of 18 U.S.C. §§ 7(3) and 1111(a) and (b),

relating to the murder of the victim identified below.

a. 18 U.S.C. § 7(3) defines “special maritime and territorial jurisdiction of the

United States” to include “any lands reserved or acquired where the use of the

United States, and under the exclusive or concurrent jurisdiction thereof.”

b. 18 U.S.C. §§ 1111(a) and (b) together prohibit any individual within the

special maritime and territorial jurisdiction of the United States from

committing the unlawful killing of a human being with malice aforethought.

PROBABLE CAUSE

6. On Tuesday, March 9, 2021, at approximately 11:00 a.m., the VVPD responded to

the Terra Vista Natural Study Area within the Cuyahoga Valley National Park

regarding the discovery of a deceased male. The deceased male was located by a

group of hikers near the “Terra Vista Cemetery.” This location is on fee simple lands

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owned by the United States Government and managed and controlled by the U.S.

Department of the Interior, National Park Service. Cuyahoga Valley National Park is

within the “territorial jurisdiction” of the United States Government as defined in 18

U.S.C. § 7(3) and is located within the Northern District of Ohio, Eastern Division.

7. Officers found the decedent’s identification card in his pocket and identified the male

as M.J.D. (initials used to protect the decedent's identity). He was wearing black

fingerless gloves, black leather jacket, black hoodie, black jeans, and black boots.

Police also located a plastic Aquafina water bottle next to M.J.D.’s body.

8. M.J.D.’s body was taken to the Cuyahoga County Medical Examiner’s Office for an

autopsy, where it was determined that the manner of death was a single gunshot

wound to the back of his head. The cause of death was ruled a homicide.

9. Affiant’s investigation revealed that on March 5, 2021, four days before his body was

discovered, M.J.D. was out with co-workers at a bar and restaurant called the Tiki

Underground, which is located at 5893 Akron Cleveland Road, Hudson, Ohio. While

there, M.J.D. told his supervisor that he was going to meet a girl who was staying the

weekend in the area.

10. At approximately 5:46 p.m., video surveillance from the Ohio Turnpike toll plaza

shows a white Smart Car exit the Ohio Turnpike (Interstate 80) through the Akron toll

plaza at Exit 180. This exit leads to State Route 8, which is a road that heads south

toward the direction of the Tiki Underground Bar.

11. At approximately 6:00 p.m. on March 5, M.J.D. received a text and said to his co-

workers, “she’s here.” M.J.D. and his supervisor walked out of the Tiki

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Underground, and the supervisor watched M.J.D. enter a small white or silver car.

M.J.D.’s supervisor described the driver of the car as a woman with brown hair.

12. Affiant’s review of the video surveillance footage from Tiki Underground confirmed

M.J.D.’s presence that evening, and it showed the vehicle that M.J.D.’s supervisor

reported seeing was a white Smart Car with an unknown license plate.

13. At approximately 6:13 p.m., video surveillance from a nearby BP gas station located

at 16 West Streetsboro Street in Peninsula, Ohio showed a small white vehicle with a

black stripe arrive at the station. M.J.D. is observed on surveillance video entering the

store and purchasing cigarettes, a red colored canned beverage, and a clear bottle of

water with blue label, later determined to be Aquafina brand water.

14. Affiant reviewed information related to M.J.D.’s Google account, which enabled

Affiant to track M.J.D.’s GPS location and path of travel from the Tiki Underground,

in Hudson, Ohio. Using M.J.D.’s GPS data, investigators were able to determine that,

on March 5, 2021 at approximately 6:37 p.m., M.J.D. traveled near a license plate

reader (LPR) near Cedar and Richmond Roads in Cleveland, Ohio. The LPR captured

a photograph of the rear of a white Smart Car, bearing a Virginia license plate no.

UPG-2702, that passed the intersection at approximately the same time that GPS data

from M.J.D.’s phone indicated he was in that area. The LPR photograph also shows

stickers on the rear of the vehicle, specifically a “U.S. Coast Guard” sticker in the top

center of the rear back glass, a “Bauhaus” sticker located on the bottom center of the

rear back glass, and a “Virginia is for Lovers” sticker below the license plate.

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15. The owner of the white Smart Car was John Robert Perkins of Arlington, Virginia, a

member of the United States Coast Guard. His wife, Chelsea Perkins, matched the

description provided by M.J.D.’s supervisor as the female who picked up M.J.D. from

the Tiki Underground Bar as described above in Paragraph 9.

16. GPS data from M.J.D.’s phone showed that he arrived in the area near 1433 Ashbury

Avenue, in Cleveland, Ohio. Affiant learned of an Airbnb at that location. Affiant

learned the reservation for the room was made for March 5, 2021, under the name

Chelsea Perkins, and reserved using a credit card belonging to Chelsea Perkins.

17. GPS data from M.J.D.’s phone then showed, at approximately 8:00 p.m., movement

from the AirBnb at 1433 Ashbury Avenue to a nearby Potbelly Sandwich shop on

Euclid Avenue. Surveillance footage from a Verizon Wireless store on Euclid Avenue

shows a woman with dark hair wearing dark clothes and dark colored knee-high boots

walking east on Euclid Avenue next to a male wearing black clothes with patches on

his jacket. The images in this surveillance footage appear to match the descriptions

for Chelsea Perkins and M.J.D.

18. GPS from M.J.D.’s phone later showed that he returned to the Airbnb at 1433

Ashbury Avenue that evening, where he stayed until the following morning. That

evening, Chelsea Perkins used Facebook messenger to communicate with her tattoo

artist about her plan to travel to Detroit, Michigan the following day. In making this

plan, Perkins told her tattoo artist that she was at an Airbnb in Cleveland and that

check out was at 10:00 a.m. on March 6, 2021. Perkins said she was making a stop

first, then heading to Detroit, where the artist was located, to get the tattoo. Perkins

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also posted a photo of herself on Twitter that shows the interior of the Airbnb at 1433

Ashbury Avenue, Cleveland, Ohio.

19. On the morning of March 6, 2021, M.J.D. texted his girlfriend, identified herein as

“A.W.,” that he had just woke up, was going to donate plasma, and would come back

to their apartment. M.J.D. asked A.W. not to be upset and said he did not “sleep with

her.” At approximately 8:39 a.m., M.J.D. texted A.W. again saying that he was

“guessing” that she (his girlfriend) did not miss him and was mad at him last night.

M.J.D. said further: “Well I pissed this chick off anyway so I hope yer happy.”

20. On March 6, 2021, at approximately 9:03 a.m., GPS data from M.J.D.’s phone

showed movement from the Ashbury Avenue location. M.J.D. travelled south on

Brecksville Road. At approximately 9:11 a.m., M.J.D.’s phone searched Google for

the location of Terra Vista Natural Study Area. At approximately 9:45 a.m., GPS

data showed that M.J.D.’s phone arrived at Terra Vista Natural Study Area in

Cuyahoga Valley National Park. GPS records obtained by law enforcement from

Perkins’ phone revealed that Perkins’ phone pinged off a tower just to the east of the

Terra Vista Natural Study Area at approximately 9:59 a.m. At approximately 10:29

a.m., M.J.D. sent a text to his girlfriend saying “OK. I’ll see you in a little while.”

21. At approximately 10:30 a.m., another couple, “Couple 2”,1 interviewed but not

identified herein, arrived at the Terra Vista National Study area parking lot. Couple 2

noticed a white Smart Car with a military bumper sticker (among other bumper

stickers) parked, unoccupied, in the parking lot. Couple 2 reported hiking in the area.

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This couple is identified as “Couple 2” as M.J.D. and Perkins were also together in the same area at this
time and would be considered collectively as “Couple 1.”

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Between 11:30 a.m. and 11:50 a.m., Couple 2 heard a gunshot. Couple 2 decided to

leave the area. At approximately 12:10 p.m., Couple 2 returned to the Terra Vista

National Study parking lot, where they saw the same white Smart Car still parked in

the same place as before. Around the same time that Couple 2 reported returning to

their vehicle, Perkins’ cell phone pinged off a cell tower just west of the Terra Vista

Study Area.

22. Another couple, “Couple 3,” 2 interviewed but not identified herein, was hiking near

the Terra Vista Study Area on March 6, 2021, where they encountered a young

woman in the woods. She told Couple 3 that she was looking for the cemetery and

became lost. Couple 3 found it odd that the woman was not dressed in hiking attire;

rather she was wearing all black clothing, black knee-high boots, and a black hoodie.

Couple 3 further described the woman as having dark shoulder length hair. Couple 3

also stated that the woman seemed confused and expressed no emotion. Couple 3

stated that they walked with the woman a short distance until their path split. Couple

3 reported that the woman headed toward the direction of the cemetery.

23. Turnpike E-Z Pass records show that, on March 6, 2021 at approximately 1:00 p.m.,

the same white Smart Car entered the Ohio Turnpike (Interstate-80) at the North

Ridgeville, Ohio entrance. The records show the car headed west toward Toledo. In

Toledo, the white Smart Car turned north toward Michigan and ultimately arrived at

“Family Ink,” a tattoo parlor, located at 4219 Highland Road in Waterford Twp.,

Michigan, 48328.

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“Couple 3” are separate individuals from those previously identified as Couple 2 and Couple 1 (M.J.D.
and Perkins).

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24. E-Z Pass records show the white Smart Car register at Turnpike toll plazas heading

east from Michigan in the early morning hours of March 7, 2021. The same car

registered at toll plazas heading east through Ohio. On March 7, 2021, at

approximately 4:45 a.m., the car registered as exiting the Turnpike in Sommerset,

Pennsylvania.

25. BCI analyzed M.J.D.’s body and other evidence collected near where the body was

found. BCI’s testing identified the presence of each of Perkins’ and M.J.D.’s DNA on

the mouth and exterior cap of the Aquafina bottle found next to M.J.D.’s body.

Perkins’ DNA was the major contributor on M.J.D.’s pubic hair, and her DNA was

also present in his fingernails.

26. The autopsy report following the medical examiner’s office examination of M.J.D.’s

body and other collected evidence revealed that M.J.D. died as a result of a gunshot

wound to the back of his head. The autopsy report stated that the manner of death was

homicide. The report concluded that the bullet recovered from M.J.D.’s head was a

9mm caliber round of ammunition.

27. On March 17, 2021, agents with the United States Park Services conducted

surveillance at the home of Chelsea and John Perkins in Arlington Virginia. Agents

located the white Smart Car parked in front of their apartment complex and noticed

that two of the distinctive bumper stickers had been removed, including the “Virginia

is for Lovers” sticker.

28. On March 30, 2021, investigators executed a search warrant of Perkins’ home in

Arlington, Virginia. Pursuant to the search warrant, law enforcement recovered three

9mm pistols (one Glock and two Springfield Armory). One of the Springfield

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Armory pistols was recovered inside a woman’s purse/backpack, which also

contained an identification card for Chelsea Perkins. Each of these firearms was test-

fired by BCI and examined for DNA.

29. A second report issued by BCI determined that Perkins’ DNA was the major source

of DNA on the 9mm Springfield Armory pistol recovered the purse/backpack during

the March 30, 2021 execution of the search warrant.

30. BCI issued a ballistics report that compared the markings on the bullet recovered

from M.J.D.’s head with the test fired bullets from the recovered Glock pistol and the

two Springfield Armory pistols. The report determined that the markings on the

bullet recovered from M.J.D.’s head had similar characteristics as the markings from

rounds fired from the Springfield Armory pistols, but not the same characteristics as

the markings from rounds fired from the Glock pistol.

Conclusion

31. Based on the preceding, I believe that probable cause exists that Chelsea Perkins has

violated Title 18 USC Section 1111(a), Murder.

_____________________________
Lynn Bilko
Task Force Officer
Federal Bureau of Investigation

This affidavit was sworn to by the affiant by telephone after a PDF was transmitted by email, per
8th day of December 2021.
Crim. R. 41(d)(3) this ____

William H. Baughman, Jr.