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AO91(Rev.08/0
.
9).2CriminalComplAint
EE..EL. ' - -- ........ . - .
UnitedStatesofAmerica )
V, ) q0-
) caseNo.< -5002-SNOw
)
YuhaoW ang andJielunZhang, )
)
Defendantl
s)
Thiscriminalcomplaintisb%edon thesefacts:
SEEAU ACHED AFFIDAVI T, '
W Continuedontheattachedsheet.
Complainant'
sâ'
fgalfure
Chrls Kl
ettheimer.SnecialAcent,FBI
Printednameand title
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oate: & ':
Judge'
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p ltz/l
fre
AFFIDAVIT
investigative or 1aw enforcem ent ofticer within the m eaning of Titlt 18,United States Code,
mycareertoincludeNationalSecurity,TransnationalOrganizedCrime,EconomicCrimes,Major
Theh and ViolentCrimes.
1make this affidavitin supportofan arrestwarrantforY ahao W ang and Jielua
officers and civilian witnesses who have first-hand knowledge ofthe events described herein.
Because thisaffidavitissubm itted forthe Iimited pum ose ofestablishing probable cause,itdoes
Case 4:20-mj-05002-LSS Document 1 Entered on FLSD Docket 01/06/2020 Page 3 of 4
approached the guard station atSigsbee Annex,NavalAir Station,K ey W est,M onroe County,
drove up to theguard station attheentranceto Sigsbee Annex.Y uhao W ang and Jielun Zhang
spokewithU.S.NavySecurityForcesMasteratArms(M A),whowaspostedattheentrancegate.
The M A requested military identification, which Yuhao W ang and Jielun Zhang could not
provide.The M A com municated to Yuhao W ang and Jielun Zhang they were notauthorized to
Jielun Zhang provided the licenseto theM A. TheM A re-iterated thatthey m ustm ake aU-tum .
7. However,Y uhao W ang and Jielun Zhang,proceeded to drive forward and continued
onto Sigsbee Annex in contradiction to the instructionsfrom the M A. In thatthe M A could not
leavethe post,she radioed to ptherNavy Security Forcesto locate the vehicle. Sigsbec Annex
Forceswereable to ûnally locate the vehicle. Atthattim e,they approached Yuhao W ang and
Jielun Zhang. W hen they approached,Yuhao W ang and Jielun Zhang were in possession of
cellular telephones and Jielun Zhang also had a N ikon camera.U .S.N avy Security Forces
obtained consentto look atthe devices and observed photographs taken on the Sigsbee Annex
2
Case 4:20-mj-05002-LSS Document 1 Entered on FLSD Docket 01/06/2020 Page 4 of 4
Yuhao W ang and Jielun Zhang were interviewed by youraffiant. Yuhao W ang
and Jielun Zhang both told the agentsthatthey read and understand English.
m ilitary clothing form ilitary identification andwhenthey could notprovideany,w ere directed to
m ake a U-turn. Yuhao W ang advised he did not make a U-turn and drove onto the property
eventually stopping,parking the vehicle and taking photographs with his cellulartelephone.
Yuhao W ang voluntarily showed agentsthephotographshetook whileon SigsbeeA nnex,
provided hisM ichigan driver's license. Jielun Zhang also confirm ed they w ere asked to make a
l
around untilthey stopped,parked the vehicle and took photographsw ith his camera and videos
CON CLUSION
12. Basedentheforegoingfacts,IsubmitthereisprobablecausetobelieveYuhaoW angand
JielunZhanghaveviolated 18U.S.C.j1382(EnteringMilitary,NavalorCoutGuardProperty)forthe
purposeoftakingphotographs,whichisaviolationof18U.S.C.j 795.
J. risKlettheim er,SpecialAgent
Y
M NA S.SNOW
UNITED STATES M AGISTRATE JIJDGE