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IINITED STATES DISTRICT COURT


EASTERN DISTRICT OF NEW YORK
X
1?H? !.8
I.INITED STATES OF AMERICA COMPLAINT

- against - (18 u.S.c. $ 1s12(bX1))

PATRICIA ADAMS,
also known as "Pat,"

Defendant.

EASTERN DISTRICT OF NEW YORK, SS:

ANDREW CAMPBELL, being duly sworn, deposes and states that he is a

Special Agent with the Federal Bureau of Investigation, duly appointed according to law and

acting as such.

Upon information and belief, on or about and between May 4,2017 and May

18,2017, both dates being approximate and inclusive, within the Eastern District of New

York and elsewhere, the defendant PATRICIA ADAMS, also known as "Pat," together with

others, did knowingly and intentionally use intimidation and threats toward another person,

to wit: Victim-1's father ("VF"), an individual whose identity is known to the undersigned

and is described more fully below, and did knowingly, intentionally and corruptly attempt to

persuade another person, to wit: VF, and did engage in misleading conduct toward another

person, to wit: VF, with intent to influence, delay and prevent the testimony of a person, to

wit: Victim-1, an individual whose identity is known to the undersigned and is described
2

more fully below, in an official proceeding, to wit: a Federal bail revocation hearing relating

to Robert Pisani in the Eastern District ofNew York.

(Title 18, United States Code, Section 1512(bX1))

The source of your deponent's information and the grounds for his belief are

as follows:l

1. I am a Special Agent with the Federal Bureau of Investigation ("FBI")

and have worked in this capacity for approximately a year and a half. Before that, I worked

as a police officer for approximately six years. I am currently assigned to an FBI squad that

investigates the Genovese, Bonanno and Colombo organized crime families of La Cosa

Nostra. During my tenure with the FBI, I have participated in organized crime investigations

that have utilized, among other investigative techniques, consensual recordings, physical

surveillance, search warrants, and debriefings of confidential sources and cooperating

witnesses. Through my training, education, and experience, I have become familiar with

organized crime activities and efforts of persons involved in such activity to avoid detection

by law enforcement. I am familiar with the facts and circumstances set forth below from my

participation in the investigation, which includes, but is not limited to, my review of the

investigative file, my review of audio recordings and telephone records, interviews with

witnesses and conversations with other law enforcement officers involved in the

investigation.

I 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.
a

I. Backsround

2. Over approximately the last five years, a federal grand jury sitting in

the Eastern District of New York has been investigating the criminal activities of a Howard

Beach, Queens-based crew of the Bonanno organized crime family of La Cosa Nostra (the

"Bonanno family"). As a result of this investigation, on or about March 28,2017, an

indictment was unsealed charging ten members and associates of the Bonanno family with,

among other offenses, racketeering conspiracy (the "Indictment"). One of the defendants

named in the Indictment is Robert Pisani, who was charged with racketeering conspiracy, in

violation of 18 U.S.C. $ 1962(d), operation of an illegal gambling businesses, in violation of

18 U.S.C. $ 1955, and extension and collection of an extortionate debt, in violation of l8

U.S.C. $$ 892(a) and 894(a). See United States v. Robert Pisani. et al., Criminal Docket No.

17 -r ss (DLr) (E.D.N.Y.).

3. On March 28,2017, Robert Pisani was arrested and arraigned on the

Indictment before Magistrate Judge Vera M. Scanlon. That same day, Pisani was released on

a $500,000 bond, co-signed by his wife, Jamie Pisani, and two friends (the "Bond"). The

Bond was also secured by two properties. As part of the conditions of his pre-trial release,

Magistrate Judge Scanlon ordered Pisani to remain on home confinement with GPS

monitoring with permission to work at two stores he operated. Magistrate Judge Scanlon

also ordered Pisani to abide by all the standard conditions of the Bond, which, among other

things, prohibited him from violating any federal, state or local law while on release.
4

U. Pisani's Sexual Assault and Bail Revocation Hearine

4. After he was arrested, arraigned on the Indictment, and ordered

released by Magistrate Judge Scanlon, on May 4,2017, Robert Pisani was arrested by New

York City Police Department ("NYPD") detectives and charged in New York State Criminal

Court, Queens County, with (1) forcible touching, in violation of New York Penal Law

("NYPL") g 130.52(1); (2) sexual abuse in the third degree, in violation of NYPL $ 130.55;

and (3) harassment, in violation of NYPL 5 240.26(l). These new charges stemmed from an

incident alleged to have occurred on April 28,2017, in which Pisani sexually abused Victim-

1, an employee at All American Bagel and Barista Company, one of the stores Pisani

operates and was permitted to work at under the terms of his Bond. According to Victim-1,

on April 28,2017,without her consent and despite her protests, Pisani, among other things,

grabbed Victim-1's buttocks, snapped her bra-strap and placed her hand on his exposed

penis. Victim-1 also advised that Pisani had previously made sexually suggestive comments

toward her.

5. Due to Pisani's misdemeanor arrest, which is a violation of the

conditions of the Bond, on May 5,2077, the Pretrial Services Agency for the Eastern District

of New York ("Pretrial") requested a bail violation hearing. On May 8,2017, the United

States Attomey's Office for the Eastem District of New York (the "Office") filed a letter

moving the Honorable Chief Judge Dora L.Il,izarry to revoke Pisani's release on bond and

enter a permanent order of detention pending trial. The Offrce further sought an entry of a

default judgment against Pisani and his wife to permit the government to collect the

$500,000 owed through, among other sources, the entry ofjudgment and subsequent sale of
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Pisani's home.

6. On May 10,2017, Chief Judgebizarry scheduled a bail violation

hearing for May 16,2017 ("Bail Revocation Hearing").

III. The Defendant's with Pisani

7. Based upon my participation in the investigation, I am aware that the

defendant PATRICIA ADAMS is associated with the Bonanno family, including, among

others, Pisani and Ronald Giallanzo, who was also charged in the Indictment and is identified

as an acting captain in the Bonanno family. In addition, a cooperating witness ("CW-1";z

has advised that as of February 2014, ADAMS owed money to individuals associated with

the Bonanno family due to her gambling habits, which resulted in losses of up to $1,500 per

week from sports betting and card games controlled by the Bonanno family. CW-1, who was

a Bonanno family associate around Giallanzo at the time, regularly met with ADAMS to

settle gambling debts, and Giallanzo accompanied CW-l on at least one occasion. CW-l

further advised that ADAMS played cards at a social club controlled by the Bonanno family

in Ozone Park, and that ADAMS also associated with Bonanno family associate and Pisani's

co-defendant Christopher Boothby at the social club. Finally, CW-1 advised that ADAMS is

the publisher of The Forum, a Queens-based newspaper.

8. The defendant's association with Pisani is also evidenced by their

2 CW-1 pled guilty to racketeering conspiracy, including predicate acts of


Hobbs Act robbery and illegal gambling, pursuant to a cooperation agreement in the Eastern
District of New York. CW-l's prior crimes include insurance fraud. CW-l is cooperating in
the hope of obtaining leniency in sentencing. CW-1's information has been corroborated by
surveillances, as well as the testimony of other cooperating witnesses, consensual recordings,
phone records and other materials.
6

telephone communications. Pisani's cellular phone was seized incident to his arrest and

searched pursuant to a court-ordered warrant. A review of the Pisani phone data shows: (1)

a cellular telephone associated with ADAMS (the "ADAMS Cell Phone") is listed under the

contact name "Forum Pat Adams," and (2) numerous text messages between Pisani and

ADAMS in which ADAMS's connection to Pisani is clear. For example, Pisani and

ADAMS discussed a restaurant venture that Pisani was helping ADAMS with, and the

correspondence between the two indicates that ADAMS views Pisani as a boss-like figure.

During one exchange, ADAMS describes her financial situation relatdd to her business,

writing, "sooner than later I have to choose between a gun or a bottle of Zatax [sic]." In

another exchange with Pisani, ADAMS stated:

Rob, I don't know what to do. I feel like blowing my brains out.
I feel like I created something that was a huge succbss and now
it's all a waste[.] And I also feel like I got screwed on many
ends. I guess I was in over my head. But I want you to know I
know what you tried to do for me and I really appreciate it.

In another text, on March 24,2017, ADAMS told Pisani that she wanted to call someone

back about a potential business deal, but "I wanted to know if you think I should." When

Pisani directed ADAMS to wait, she responded, "it might not be a bad idea if I speak to him

eventually but I won't do anything without talking to 'the boss.' Hat [sic] would be you."

ADAMS left a voicemail for Pisani on March 25,2017 similarly expressing her desire for his

direction and approval in which ADAMS stated:

Hey Rob, it's Pat. Listen, I wanted to know if you heard from
Anthony yet because Mickey is calling, ya know. I don't know
what to say to this guy, and I don't want to answer the phone,
uh, you know, and and do anything wrong. So, let me know.
Thanks.
l
9. According to a website for "The Forum," it is a community newspaper

that covers the Howard Beach, Ozone Park, Broad Channel, Richmond Hill and Woodhaven

neighborhoods of Queens, New York. A search of The Forum news site foTADAMS reveals

that she has authored many articles and has also taken photographs. A search of The Forum

news site for "Pisani" reveals a number of positive articles written about Pisani and his

businesses. For example, an article authored by ADAMS on April 18, 2013, entitled "The

All American Dream (Come True)," included a photograph of Pisani and his family, and it

trumpeted the re-opening of one of Pisani's delis after Hurricane Sandy.

IV. The Defendant's Witness Tampering

10. According to telephone records, on or about May 12,2017-two days

after Chief Judge lrizalry scheduled the Bail Revocation Hearing, and four days before the

Hearing-a cellular telephone number associated with Pisani called the ADAMS Cell Phone.

Telephone records also reveal that the following day, on or about May 13, 2017,the

ADAMS Cell Phone called a cellular telephone associated with Victim-1's father ("VF").

(VF had previously met ADAMS in the course of ADAMS's work as publisher of The

Forum.) VF has advised that ADAMS contacted him and asked to meet, but would not say

what she wanted to meet about. VF further advised that when asked. ADAMS stated that she

did not want to speak over the telephone or meet at VF's residence; she said, however, that

the meeting was "sort of'about Victim-1, VF's daughter. VF agreed to meet ADAMS at a

local Starbucks and decided to record the meeting with ADAMS, which lasted approximately

two and one-half hours.


8

1 1. Based upon my participation in the investigation and my review of the

audio recording of ADAMS's May 14,20L7 meeting with VF,3 during the meeting with VF,

the defendant PATRICIA ADAMS repeatedly threatened, intimidated, harassed and

corruptly attempted to persuade VF to cause Victim-1 not to cooperate with federal law

enforcement in connection with Pisani's upcoming Bail Revocation Hearing. In sum and

substance, ADAMS threatened that if Victim-l cooperated with federal law enforcement and

testified at the Bail Revocation Hearing, ADAMS would humiliate Victim-l and disseminate

embarrassing information about Victim-1. ADAMS further stated that if Victim-l did not

cooperate with federal law enforcement, then ADAMS would not report an1'thing about the

story.

12. During the recording ADAMS made clear to VF that she was closely

associated with Pisani by referencing, among other things, a conversation with Pisani's

lawyer, her knowledge of Pisani's criminal case, her review of video recordings from inside

the deli showing Victim-1's actions after the alleged incident between Victim-l and Pisani

and her close relationship with Pisani. During one portion of the recording, ADAMS stated:

Let me put it to you this way: here's a guy . . . here's a guy out
of ten defendants who is the only one that stands a shot for
getting probation 'cause they have nothing on tape, they have
nothing on the phone, they have zero involvement - zero
involvement on him. They went back as far as 2012 - they have
nothing on him. Okay? Unfortunately for him, he gave
someone a job, one of the other defendants, and they
automatically associate. I had dinner with them on a regular
basis, I'm surprised I wasn't in the lineup. Okay? But he's the
only guy that stands a shot to get off. as per his lawver. Okay?
You think that a guy in the middle of being on the frying pan, in

3
All of the references to the transcript of the May 74,2017 meeting between
ADAMS and VF contained herein are in draft form and subject to revision.
9

the fire, who knows that he's gotta watch every single thing and
behave like a perfect person. You think he's gonna try and get a
blow job? Common sense tells me, absolutely not.

Based upon my training, experience and participation in the investigation, I believe that

when ADAMS stated that "they" have nothing on tape, she meant that the federal

govemment did not have recordings of the defendant Pisani committing crimes. I further

believe that when ADAMS stated that "he" gave "someone" a job, ADAMS meant that

Pisani gave one of the other defendants a job at one of his businesses and that ADAMS

socialized with Pisani and his co-defendant ("I had dinner with them on a regular basis."). I

believe that when ADAMS stated "But he's the only guy that stands a shot to get off, as per

his lawyer," she was referring to statements made by Pisani's lawyer about Pisani's potential

exposure in his criminal racketeering case given the lack of recording evidence.

13. During the consensual recording, ADAMS further stated:

I'm telling you, and look, I have my own interest in the case.
My own association with the case. But I am in a positiol-['rn
being very honest-I am in a position wh
to expose the whole situation-if we get to that point. I'm
hoping that you and I during this conversation can find a way
not to reach that position. This-I don't know who got to your
daughter. I'm a very shrewd bettor. But I would bet that
somebody, very possibly, could have put her up to this, because
what they're looking to do is to not let him get off on the other
thing, he is the only defendant in that case that they have
absolutely this on. And they're looking, these feds, listen, one
day, they're your friend and they'll take you in, they'll tell your
daughter, "Oh [victim], you gotta help us, it's the right thing to
do, you gotta do this, we'll protect you." Let me tell you
something right now. Protect you? They will sell your ass out
quicker again and again, they are the worst scum of the earth.
The worst. I've had my own personal experience. I spent two
days and two nights in a filthy cell. I did nothing, nothing, but
they thought they were going to crack me. I'm not an idiot.
Definitely not. You wanna do something to me? Be my guest.
l0

I'm gonna get through it. But making a deal with them is
making a deal with the worst devil.

Based upon my training, experience and participation in the investigation, I believe that

when ADAMS stated that she had her own "interest" in the case, she was referring to her

relationship with the Bonanno family and Pisani. Indeed, in another part of the recording,

ADAMS stated, "I'm telling you that I know Rob (a reference to Pisani) and this is not his

character." I further believe that when ADAMS suggested that "somebody" "put her up to

this" and described "making a deal" with "the worst devil," she was trying to persuade VF

that his daughter should not cooperate with law enforcement.

14. To fuither intimidate Victim-1 and scare VF's father about the potential

consequences if Victim-l testified, ADAMS stated the following, in relevant part:

a. "[Victim-1] is going to hurt herself. That's the truth. I'm going


to hurt her and, and I don't want you to. You know, I gotta put
out what I have to put out. . . . And then everybody is going to
come on the fucking bandwagon, and it's going to be a fucking
. . . there's no way, listen there's no winners. . . . There's no
winners. You should talk to her again, and see what she says to
you. . . ."

b "[I]fthey get her - and she signs these statements and she goes
up before the lawyers - they're going to shred her like they put
her through a Cuisinart."

c "It only matters once she crosses the threshold and signs the
paper that says she is going through with it- none of it matters
anymore."

d. "I'm going to tell you what is going to happen. If she chooses


to follow the direction of the agents and the FBI and sign these
papers . . . [i]t's not going to be good for her publicly."

e. "I won't hurt you, if you don't deserve - that's for my enemies.
I will not hurt you . . . but in the newspaper, thoroughly
thoroughly objective . . . For my good, for everybody's good -
ll
I'm hoping that she'll decide to drop it."

f. After telling VF that she had reviewed evidence in the case,


ADAMS stated: "I would never in a million years come talk to
you unless my arsenal was fully loaded. . . . It is my position,
and I don't fuck with it. I don't make empty promises, and I
don't make empty threats. I never tell you, 'Oh, I got this, and I
got that'-l got it."

o ADAMS also told VF that Pisani's other employees would


dispute the alleged assault, stating, "[E]veryone that tells me
that, tells me, never in a million years. Never, in a million
years. I love him, this, that, and the other thing. Never would
he ever do that. Never. . . . I mean you're talking about,
conservatively speaking, 18 to 20 girls - they're all wrong?"

15. The defendant PATRICIA ADAMS also told VF that Victim-1 would

suffer publicly even if it was true that Pisani had sexually abused Victim-1:

a. "It's one big malicious circus, that is what it is, and there are no
winners, least of all her. She could be 100% right - he could
have unsnapped her bra, tried to push her head down, whatever,
she can't win. There are no winners. But like I said, completely
separate from the fact that personally, I don't know, I don't
believe that it happened."

b "[S]he's gonna put herself in a very bad position. Even if she's


- and I'm not saying that she is - but even if she's 1 00 percent
right, and it happened, I wouldn't deal with it either way.
Because the ramifications for her, publicly - meaning, it's - we
don't live in a world where somebody tries to force you to do
something, and you tell about it, and you're proven right -
right? . . . Even if that happens, you're never gonna be - not that
I'm saying this is her objective - but you're never gonna be
elevated, you're never gonna win, you're never gonna be
popular, you're never gonna achieve anlthing. And then, ain't
it horrible to think - that you could be proven right, and then
you go out into the world, and you think you're a [UI] with your
mouth, with this, with that, with the other thing. It's a no win -
it's a winless situation - whichever way you choose."

c "[A]s a completely unqualified, casual observer, if what she said


gets out and what she actually did follows it, she's gonna be
12

ruined. Obviously, nobody is going to believe that and they're


gonna look at her like, 'What the fuck did you do that for?"'
After VF stated that his daughter was not a"liar," ADAMS
replied, "She doesn't have to be a liar."

d. "[T]here's a number of reasons why she could be nervous. The


whole situation, it would make me nervous. Whether she's
lying or she's not - and if she's not, I would be very nervous -
if that happened. That's a horrible thing to happen. On
whatever level [UI]."

ooNow
e. always when I look into someone other things come up
. . this person told me there's proof fVictim-1] was with
somebody . . . .[i]n the car, doing coke off the dashboard."

f. "[]n my experience, if she goes through with this - she's not


gonna work anywhere around here."

16. The defendant PATRICIA ADAMS also revealed that the purpose of

her meeting with VF was for VF to encourage Victim-1 not to testify:

a. "I agreed with myself to have a conversation with you. . . . If I


didn't think that you were a reasonable man, I wouldn't talk to
you, because, because what I will I accomplish . . . . I'd be
wasting my time."

b. "[W]ait until tomorrow, don't do it today. Don't upset your


wife, don't upset your daughter today - but just have a word
with her. If she wants at any point to speak with me, I am more
than happy to talk with her. Not that I think she would want to."

c. "Just talk to her, and give me abuzz.. . . And, like I said, if she
wants to talk to me I'11 be huppy to talk with her."

d. "Ihave one objective - very honestly. For my good, for


everybody's good - I'm hoping that she'll decide to drop it."

17. To further dissuade Victim-l from cooperating, the defendant

PATRICIA ADAMS repeatedly claimed that federal law enforcement officials were
13

untrustworthy and would not protect Victirn- l. For instance, ADAMS stated, in relevant

part

a. "And they're looking, these feds. Listen: one day, they're your
friend and they'll take you in, they'll tell your daughter, 'Oh
[victim], you gotta help us, it's the right thing to do, you gotta
do this, we'll protect you.' Let me tell you something right
now. Protect you? They will sell your ass out quicker again
and again. They are the worst scum of the earth. The worst."

b. "Federal law enforcement agents, U.S. Attorney, any number of


- they are the most deceitful misleading bunch of tyrants on the
face of the earth. And that's the truth. You don't have to take
my word for it."

c "And if you think that those motherfuckers on the other side


[i.e., law enforcement] are going to protect her, you're out of
your mind. . . .They got what they wanted."

18. Throughout the May 14,2017 meeting, the defendant PATRICIA

ADAMS also revealed that she was acting on behalf of the Bonanno family and not as a

neutral reporter. For instance, early in the conversation, ADAMS explained her motivation

for the meeting: "I have a personal, personal liability, personal. . . . And it's aside from the

fact of what I have to do with the newspaper. I'm on the verge of been trying to get
-I've
out for two years. But because of certain obligations, I'm forced to stay on. I'm kind of

under their . . . thumb." Based upon my training, experience and participation in the

investigation, I believe that ADAMS was likely describing her obligations to the Bonanno

family as a result of her gambling and business relationships.

19. Later, ADAMS recounted a conversation she had after Pisani was

arrested for the alleged sexual abuse, which was published in local newspapers and stated: "I

haven't written anything about it. . . It was The Post and The News. And when I got the
t4

phone call, [deeper voice] 'You better fucking fix this!' 'I better fix it? What are you? .. .

Hang on. You mind if I figure out what the fuck happened?' 'You got a week.' 'Thank you'

[noise hitting the table]. So then, I went into, uh, investigative mode and, you know." Based

upon my training, experience and participation in the investigation, I believe that when

ADAMS stated, "I got the phone call," she was referring to the phone call from Pisani to

Adams on May 12,2017, the day before ADAMS reached out to VF to arrange the meeting.

Thereafter, during the consensual recording, ADAMS reiterated that her own personal

interests are being served by trying to dissuade Victim-1 from cooperating against Pisani:

"Listen, I'm not making any mistake about the fact that I'm here to try and help myself . . .

I'm worried about this one, and who I have to answer to."

20. VF explained, in sum and substance and in part, that he believed

ADAMS initiated the meeting with him not out of a concem for Victim-1, but rather at the

behest of Pisani andlor someone associated with Pisani. VF further believed based on

ADAMS's conduct that she was, among other things, threatening reputational harm to

Victim-1 if Victim-1 testified.

V. Conclusion

21. Based on my knowledge of the investigation, including but not limited

to my review of the May 14,2017 audio recording, among other sources of information, I

believe that on or about and between May 4,2017 ard May 18,2017, both dates being

approximate and inclusive, within the Eastern District of New York and elsewhere, the

defendant PATRICIA ADAMS, also known as "Pat," together with others, did knowingly

and intentionally use intimidation and threats toward another person, to wit: VF, and
15

knowingly, intentionally and comrptly attempt to persuade another person, to wit: VF, with

intent to influence, delay and prevent the testimony of a person, to wit: Victim-1, in an

official proceeding, to wit: a Federal bail revocation hearing relating to Robert Pisani in the

Eastem District of New York.

WHEREFORE, your deponent respectfully requests that an arrest warrant be

issued for the defendant PATRICIA ADAMS, also known as "Pat," so that she may be dealt

with according to law. Furthernore, I respectfully request that this affidavit and any arrest

warrant be filed under seal to prevent ADAMS from fleeing or attempting to tamper with the

goveflrment' s investigation.

ANDREW CAMPBELL
Special Agent
Federal Bureau of Investigation

Sworn to before me this


14th of

HONO V HRELSKY
TINITED STATES MAGI E
EASTERN DISTRICT OF NEW YORK
AO 442 (Rev. I l/ll) ArrestWarrant

Umrso Srarps Drsrrucr CoURT


for the

Eastern District of New York

United States of America


V. )
PATRICIA ADAMS, ) Case No
also known as "Pat," )
)
)

Defendant
)
TryM? T8
ARREST WARRANT
To: Any authorized law enforcement officer

yOU ARE COMMANDED to arrest and bring before a United States magistrate judge without unnecessary delay

(name of person to be arrested) PAT ADAMS, also known as "Pat,"

who is accused of an offense or violation based on the following document filed with the court:

E Indictment 0 Superseding Indictment D Information D Superseding Information C Complaint


il probation Violation Petition il Supervised Release Violation Petition D Violation Notice D Order of the Court
This offense is briefly described as follows:
Tampering with a Witness, in violation of 18 U.S.C. S 1512(bX1)

Date: 0811712017
/,M /
Issuing officer's

City and state: Brooklyn, New York Viktor V. Pohorelsky


Printed name and title

Return

This warrant was received on (date) , and the person was arrested on (date)
at (city and state)

Date:
Arresting fficer's signature

Printed name and tille


AO 442 (Rev. I l/l I ) Anest Warrant (Page 2)

This second page contains personal identifiers provided for law-enforcement use only
and therefore should not be filed in court with the executed warrant unless under seal.

(Not for Pub lic Disclosure)

Name of defendant/offender :

Known aliases
Last known residence:
Prior addresses to which defendant/offender mav still have ties

Last known employment:


Last known telephone numbers
Place of birth:
Date of birth:
Social Security number:
Height: Weight
Sex: Race:
Hair: Eyes:
Scars, tattoos, other distinguishing marks

History of violence, weapons, drug use:

Known family, friehds, and other associates (name, relation, address, phone number)l

_,r -
FBI nr-rmber:
Complete
\
l

Investigative agency and address

Name and telephone numbers (office and cell) of pretrial services or probation officer (if applicabte)

Date of last contact with pretrial services or probation officer (if applicabte)

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