USA V Trapp
USA V Trapp
DMP:FJN
F.#2020R00621
Special Agent with the Federal Bureau of Investigation, duly appointed according to law and
acting as such.
On or about July 17, 2020, within the Eastern District of New York and
elsewhere, the defendant JEREMY TRAPP did willfully, with the intent to endanger the
safety of any person on board and anyone whom he believed would board, and with a
reckless disregard for the safety of human life, damage, disable, destroy, tamper with, and
attempt to damage, disable, destroy, and tamper with a motor vehicle that was used,
operated, and employed in interstate and foreign commerce, to wit: a New York City Police
The source of your deponent’s information and the grounds for his belief are
as follows: 1
assigned to the Joint Terrorism Task Force (“JTTF”). I have been a Special Agent for
approximately three years. As a Special Agent, I have investigated numerous matters during
the course of which I have conducted physical and electronic surveillance, interviewed
witnesses, executed court-authorized search warrants and used other investigative techniques
to secure relevant information regarding a variety of crimes. I am familiar with the facts and
circumstances set forth below from my personal review of records, documents and other
physical evidence obtained during this investigation, and from communications and
demonstrations in Brooklyn, New York to protest the death of George Floyd, an African-
American man who died during an arrest by Minneapolis, Minnesota police officers.
obstructed the flow of vehicle traffic on city streets and refused lawful commands from New
York City Police Department (“NYPD”) officers. Some individuals and groups of
individuals vandalized vehicles and businesses with graffiti and by smashing the vehicles and
windows of the businesses with heavy objects. Some individuals and groups of individuals
1
Because the purpose of this Complaint is to set forth only those facts necessary
to establish probable cause to arrest, I have not described all the relevant facts and
circumstances of which I am aware.
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targeted the NYPD, assaulting officers, vandalizing NYPD vehicles that had responded to the
protests, and in some cases, attempting to gain access to NYPD stationhouses without
authorization, thus interfering with and obstructing the NYPD’s efforts to maintain and
restore order.
law enforcement gathered in Dyker Heights and Bay Ridge, Brooklyn to express support for
law enforcement in light of the George Floyd demonstrations. Other individuals confronted
the proclaimed pro-law enforcement demonstrators, leading to violent clashes between some
members of the two groups. These clashes resulted in injuries and multiple arrests by
NYPD officers.
the Brooklyn Criminal Court building in downtown Brooklyn, New York. The
demonstrators were shouting at police officers and objecting to the arrests of individuals who
had confronted the pro-law enforcement demonstrators in Bay Ridge, Brooklyn. As the
(“TRAPP”) spoke with an individual who was a confidential source for the NYPD (the
“CS”). 2
5. During the conversation, TRAPP stated that the police were racist, that
he wanted to harm police officers and their supporters, and that he had previously been
involved in destroying property and burning a police car. TRAPP also stated that he wanted
2
The CS is a paid informant for the NYPD. The information provided by the CS has
proven reliable in the past and has been corroborated by independent investigative
techniques.
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to cut the brake lines on police cars. TRAPP and the CS exchanged telephone numbers so
telephone calls and text messages, and arranged to meet. On or about the night of July 15,
2020, the CS picked up TRAPP at TRAPP’s home in Brooklyn, New York. TRAPP and the
CS talked as they drove around Brooklyn in the CS’s vehicle during the evening of July 15,
2020 and into the early morning hours of July 16, 2020. The CS recorded a portion of this
conversation. TRAPP told the CS that he wanted to “burn the [Verrazzano-Narrows] bridge
down” so that “white supremacists” could not use it to get to Brooklyn from Staten Island.
TRAPP also told the CS that he wanted to conduct reconnaissance of the Verrazzano-
Narrows Bridge.
Specifically, TRAPP stated that the way to deal with police cars was to “cut their brakes off.”
TRAPP questioned the point of burning police cars because the end result was only a burned
car, but encouraged the CS that they needed to burn down NYPD precincts instead. TRAPP
and the CS agreed to meet later that day to take pictures of the Verrazzano-Narrows Bridge.
8. Later in the day on or about July 16, 2020, the CS and TRAPP drove to
the Brooklyn side of the Verrazzano-Narrows Bridge in the CS’s vehicle, and TRAPP took
look for police cars so that TRAPP could cut their brake lines. While driving, TRAPP and
the CS saw various police cars but did not see any unattended ones, and ceased their search.
When the CS later dropped TRAPP off at TRAPP’s home in Brooklyn, they discussed
Case 1:20-mj-00626-SMG Document 1 Filed 08/04/20 Page 5 of 8 PageID #: 5
meeting at a demonstration scheduled for the next day in Bay Ridge, Brooklyn. TRAPP told
the CS that the demonstrations were too non-violent and were not accomplishing anything.
TRAPP told CS that he wanted to cut the brake lines on police cars instead of going to the
demonstration.
10. On or about July 17, 2020, TRAPP and the CS communicated via
telephone calls and text messages. The CS again drove to TRAPP’s home in Brooklyn and
picked him up in the CS’s vehicle. NYPD officers established surveillance of TRAPP and
the CS in advance of the meeting. While in the CS’s vehicle, TRAPP showed the CS his
backpack, which contained, among other things, a scissor-like tool that could be used to
11. At approximately 4:00 p.m. on July 17, 2020, TRAPP and the CS
approached a marked NYPD 2014 Chevrolet Express Van (the “NYPD Van”) that was
parked near 4th Avenue and 42nd Street in Brooklyn. The NYPD Van was marked
“NYPD” and “POLICE” in multiple areas, and bore visible police lights. TRAPP crawled
under the NYPD Van and reached for something near one of the vehicle’s wheel wells. The
CS stood nearby acting as a purported “lookout.” TRAPP then crawled out from under the
NYPD Van and left the area with the CS. Both the CS and the NYPD officers conducting
surveillance captured this incident on video. An image of TRAPP under the NYPD Van is
shown below.
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12. TRAPP and the CS then got into the CS’s vehicle, and the CS drove
away from the NYPD Van. The NYPD officers that had been surveilling TRAPP and the
severed the brake line on the NYPD Van and stated that he wanted to do the same to more
police cars. TRAPP and the CS drove around Brooklyn looking for other police vehicles to
sabotage, and eventually drove to an encampment of protestors located near City Hall in
Manhattan. TRAPP and the CS walked around the encampment, returned to the CS’s
vehicle, and drove back to Brooklyn. The same NYPD officers kept TRAPP under constant
surveillance during this entire time, and arrested TRAPP shortly thereafter TRAPP and the
CS returned to Brooklyn.
13. At the time of his arrest, TRAPP was wearing the same clothes he was
wearing when he crawled under the NYPD Van. A search incident to arrest of TRAPP
14. The NYPD transported the NYPD Van to a nearby facility for
inspection shortly after TRAPP emerged from under the vehicle. An inspection of the
NYPD Van revealed that a line for a wheel speed sensor had been partially severed. An
NYPD automobile mechanic has informed the FBI that the partially severed line is part of
the NYPD Van’s anti-lock braking system. A malfunctioning anti-lock braking system
would adversely impact a driver’s ability to stop and maintain control of the NYPD Van in
an emergency. The NYPD mechanic also informed the FBI that the wheel speed sensor line
looks similar to the NYPD Van’s brake line and that it is located in the same area of the
NYPD Van. If the brake line had been severed in the same manner as the wheel speed
sensor line, the driver of the NYPD Van would have been unable to use the vehicle’s brakes.
15. The NYPD Van is the property of the NYPD and the New York City
government. Both the NYPD and New York City government conduct business in interstate
commerce, for instance by purchasing vehicles and other equipment and supplies in interstate
commerce. The activities of the NYPD and the New York City government in enacting and
enforcing laws also affect interstate commerce. The NYPD and the New York City
government are also the recipients of financial assistance from the federal government,
____________________________________________
_______________
THE HONORABLE STEVEN
ST M. GOLD
UNITED STATES MAGISTRATE JUDGE
EASTERN DISTRICT OF NEW YORK