Free Complaint - District Court of Delaware - Delaware

Case ,1 :O7—mrJ;OQ063—lV| PT Document 1 Filed O4/O4/2007 Page 1 of 4
AO 91 (Rev. 12/93) Cx1m1.nal Co laintz O
United States District Court
DISTRICT OF DELAWARE
UNITED STATES OF MVIERICA
v.
PASAHA SANDS Criminal Complaint
‘ CASE NUMBER: 07- __
I, the undersigned complainant, being duly swom, state the following is true and correct to the best of my knowledge and belief. On or
about April 3, 2007 in New Castle County, in the District of Delaware, defendant committed the offense of knowingly possessing and
causing to be present dangerous weapons in a Federal facility, in violation of Title 18 United States Code, Section(s) 930g al .
I further state that I am a(n) Special Agent, United States Department of Homeland Securig and that this
Official Title
complaint is based on the following facts:
See attached Affidavit
Continued on the attached sheet and made a part hereof: Yes _
I Signat fComplainant `
. Kelle . Tufts
Special Agent, United States Department of Homeland Security
Sworn to before me and subscribed in my presence,
April 4, 2007 at Wilmington, DE
Date City and State
Honorable Gregory M. Sleet -
United States District Judge
Name & Title ofludicial Officer Sign ure ofJ dicial Oficer ‘
` F l L E D
l APH -4 zcuil
l Sinner
I U GI Y;T?Il|]T IJl_lEl_;‘·_i*.'?iRE _ ____*

Case 1 :O7—mj-OO063—lV|PT Document 1 Filed O4/O4/2007 Page 2 of 4
AFFIDAVIT K
I, the undersigned complainant, being duly sworn, state that the following is true and correct to the best of
my knowledge and belief;
l. My name is Kelley D. Tufts, and I am a Special Agent with the Department of Homeland
Security, Federal Protective Service ("DHS/FPS"), assigned to the Philadelphia, Pennsylvania,
Field Office, and have been so employed since July 2001. I was previously employed as a Federal
Police Officer with the Department of Treasury, United States Mint from 1993 until 1996 and the
Federal Protective Service from 1996 until 2001. I have received training in criminal
investigations and technical surveillance equipment at the Federal Law Enforcement Training
Center. During my tenure in federal law enforcement, including as an Agent, I have participated
in numerous investigations involving violations of federal law resulting in arrests and convictions
of numerous offenders. The information contained in this affidavit is known to me personally or
has been relayed to me by other law enforcement officers, federal employees, or individuals
assisting law enforcement officers, as indicated below.
2. This affidavit is offered to demonstrate that probable cause exists to support a criminal complaint
· charging PASAHA D. SHANDS with knowingly possessing or causing to be present dangerous
weapons in a Federal facility, pursuant to Title 18, United States Code, Section 930(a).
3. This affiant initiated an investigation on April 3, 2007, after receiving a report that PASAHA D.
SHANDS had entered the lobby of the J. Caleb Boggs Federal Building, located at 844 King
I Street in Wilmington Delaware, with several dangerous weapons. According to law enforcement
witnesses, SHANDS entered the lobby of the Federal Building on the afternoon of April 3, 2007
and proceeded to the security checkpoint area located there. After showing identification to the
Court Security Officers ("CSOs") at the security checkpoint, SHANDS placed the following items

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and type of a personal safety chemical agent. SHANDS next placed both a silver metal briefcase
(containing a Gateway laptop computer) and a black leather bag on the x—ray conveyor for security
screening, " A
4. As those items were being screened, CSO Colon observed on the x-ray’s monitor that the black
leather bag contained an item that appeared to be a pistol. CSO Colon informed CSO Bey of this
discovery. As a result, CSO Bey asked SHANDS whether he had a pistol in his bag. SHANDS
first denied that he had a pistol in his bag, stating that the bag only contained paperwork. A few
moments later, however, SHANDS stated that there was a pistol in the bag. The pistol was
identified as a Desert Eagle CO2 .l77 cal (4.5 mm) Air Pellet Pistol, Serial Number U63596360.
SHANDS was subsequently placed into the custody of and was arrested by Department of
Homeland Security — Federal Protective Service Inspector B. Nicholls.
5. Inspector Nicholls, upon conducting a search incident to arrest of SHANDS’ person, discovered
an operational 950 volt Fire Fly Stun Gun in a nylon holster on his belt. After law enforcement
officers further searched the leather bag, they discovered two (2) silver Nuevo brand single—edge
metal razors located in the bag.
6. On April 3, 2007, this affiant, as part of this investigation, photographed the main lobby area of
the J. Caleb Boggs Federal Building located at 844 King Street in Wilmington Delaware. This
affiant discovered numerous signs to be posted at the lobby entrance, which are visible to all
persons entering the facility. Those signs clearly depict symbols of prohibited items that may not

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be brought into a Federal facility, in plain view of all persons being screened for entry. The signs ‘
advise all visitors of the "Rules and Regulations Governing Conduct on Federal Property," to
including the following: "Federa1 law prohibits the possession of firearms or other dangerous
weapons in Federal facilities and Federal court facilities by all persons not specifically authorized `
_ by 18 United States Code 930. Violators will be subject to fine and/or imprisomnent for periods
up to five (5) years." .
7. Based upon the facts and information presented above, and based upon my investigative training
and experience, I have probable cause to believe that SHANDS committed violations of Title 18,
United States Code, Section 930(a), knowingly possessing or causing to be present dangerous
weapons in a Federal facility.
. /‘\
if fdr 1
KELLEY . TUFTS
Special Agent, DHS/FP
SUBSCRIBED AND SWORN TO
BEFORE ME THIS DAY
OF , 2007.
THE M. SLQT
UNITE STATES DISTRICT IUDGE