USA Vs Karol J Chwiesiuk

Case: 1:21-cr-00373 Document #: 1 Filed: 06/11/21 Page 1 of 21 PageID #:1

AO 91 (Rev. 11/11) Criminal Complaint
UNITED STATES DISTRICT COURT

for the
District of &ROXPELD
United States of America )

v. )
) Case No.
)
)
.$52/-&+:,(6,8. )
DOB: ;;;;;; )
Defendant
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 January 6, 2021 in the county of in the
LQWKH'LVWULFWRI &ROXPELD , the defendant(s) violated:
Code Section Offense Description

18 U.S.C. § 1752(a)(1)²Knowingly Entering or Remaining in any Restricted Building or Grounds
Without Lawful Authority
40 U.S.C. § 5104(e)(2)&L'*²Violent Entry and Disorderly Conduct on Capitol Grounds
This criminal complaint is based on these facts:

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9
u Continued on the attached sheet.
Complainant’s signature
-RKQ-&ROHPDQ, Special Agent

Printed name and title
$WWHVWHGWRE\WKHDSSOLFDQWLQDFFRUGDQFHZLWKWKHUHTXLUHPHQWVRI)HG5&ULP3E\WHOHSKRQH
\ S
Date: -XQH
Judge’s signature
City and state: :DVKLQJWRQ'& 5RELQ00HULZHDWKHU, U.S. Magistrate Judge

STATEMENT OF FACTS
Your affiant, John J. Coleman, is a Special Agent with the Federal Bureau of
Investigation (FBI). As a Special Agent, I am authorized by law or by a Government
agency to engage in or supervise the prevention, detention, investigation, or
prosecution of a violation of Federal criminal laws. Currently, I am tasked with
investigating criminal activity in and around the United States Capitol (the Capitol)
grounds on January 6, 2021.
The U.S. Capitol is secured twenty-four hours a day by U.S. Capitol Police
(USCP). Restrictions around the Capitol include permanent and temporary security
barriers and posts manned by USCP. Only authorized people with appropriate
identification are allowed access inside the Capitol. On January 6, 2021, the exterior
plaza of the Capitol was also closed to members of the public.
On January 6, 2021, a joint session of the United States Congress convened at

the Capitol, which is located at First Street, SE, in Washington, D.C. During the joint
session, elected members of the United States House of Representatives and the United
States Senate were meeting in separate chambers of the Capitol to certify the vote
count of the Electoral College of the 2020 Presidential Election, which had taken place
on Tuesday, November 3, 2020. The joint session began at approximately 1:00 PM
Shortly thereafter, by approximately 1:30 PM, the House and Senate adjourned to
separate chambers to resolve a particular objection. Vice President Mike Pence was
present and presiding, first in the joint session and then in the Senate chamber.
As the proceedings continued in both the House and the Senate, and with Vice
President Pence present and presiding over the Senate, a large crowd gathered outside
the Capitol. As noted above, temporary barricades and permanent barricades were in
place around the exterior of the Capitol. USCP were present and attempting to keep
the crowd away from the Capitol building and the proceedings underway inside.
At such time, the certification proceedings were still underway, and the exterior
doors and windows of the Capitol were locked or otherwise secured. Members of the
USCP attempted to maintain order and to keep the crowd from entering the Capitol.
However, around 2:00 PM, individuals in the crowd forced entry into the Capitol.
Some members of the crowd gained access and entry to the Capitol by breaking
windows and assaulting members of the USCP. Others in the crowd encouraged and
assisted those acts.
Shortly thereafter, at approximately 2:20 PM, members of the House of

Representatives and Senate, including the President of the Senate, Vice President
Pence, were instructed to—and did—evacuate the chambers. Accordingly, the joint
session of the United States Congress was effectively suspended until shortly after 8:00
PM. Vice President Pence remained in the Capitol from the time he was
evacuated from the Senate Chamber until the sessions resumed.
During national news coverage of the aforementioned events, video footage

which appeared to be captured on mobile devices of persons present on the scene
depicted evidence of violations of local and federal law, including scores of individuals
inside the Capitol without authority to be there.
Since January 6, 2021, the FBI has been investigating and identifying those who
were inside of the Capitol without authority and disrupted the proceedings. During
that investigation, and pursuant to legal process, the FBI learned that a device
associated with the Google account @gmail.com (the subject account)
was present near or inside of the Capitol between approximately 2:37 PM and 3:24
PM (EST) on January 6, 2021. The subject account is associated with the name
kchwiesiuk and a recovery telephone number of +1 (the subject
telephone number). Legal process to the service provider of the subject telephone
number identified the name of the individual to whom that number is registered as the
defendant—Karol J. CHWIESIUK—and identified the defendant’s address as
Chicago, IL .
A search of publicly available resources identified the defendant as an employee

of the Chicago Police Department (CPD). The FBI confirmed with CPD that the
defendant is currently employed as a Police Officer with the CPD—badge # 7156.
CPD employment records show that the defendant listed the subject telephone number
as his home phone number.
Through legal process, your affiant obtained and reviewed geolocation and
communication records associated with the subject account. Notably, on Tuesday,
January 5, 2021, at approximately 10:46 PM, defendant received an email from an
account that identified itself as Ali Alexander, Stop The Steal <Ali@stopthesteal.us>.
The subject line of the email is: Tomorrow is going to be a historic day in
Washington DC. The text of the email is as follows:
Patriots,
Tomorrow is going to be a historic dai in Washington DC. There are going to be millions of
likeminded patriots attending the Stop The Steal events that we have scheduled.
Please pay close attention to the following event details:
Venue Address #1
The Ellipse w/ Your President Donald J Trump
Constitution Ave NW between 15th St NW & 17th St NW
Washington, DC 20230
Doors open at 7:00 AM EST. The event will begin at 9:00 AM EST.
Parking
There is no designated parking are for this event. Arriving on foot or via ride share is strongly
encouraged. There are many local lots in downtown D.C. Please see below for road closure
information.
Guest Arrival Information

Gates open at 7:00 AM EST. The event will begin at 9:00 AM EST.
First Come First Serve
** Expect heavy traffic delays and plan to arrive early **
Please enter Constitution Ave NW by foot from the National Mall (south of Constitution Ave
NW).
Venue Address #2
US Capitol
Capitol Hill North East by Constitution Avenue Northeast
Washington, DC 20230
Begins at 1:00 PM
Our presence outside of the US Capitol building will let Members of Congress know that we stand
with Rep. Mo Brooks and his colleagues in the House of Representatives who will bravely object
to the certification of the Electoral College.
This will be one of the most historic events of our lifetime.
I look forward to making history with you,
Ali Alexander – Founder of Stop The Steal
The subject account’s geolocation data shows that the defendant left Chicago
on January 4, 2021, and arrived in Washington, D.C., on January 5, 2021. The
defendant departed Washington, D.C., on January 7, 2021, and returned to Chicago
on January 8, 2021.
IMAGE 1: A screenshot of the defendant’s geolocation data showing him traveling from Chicago, IL, to Washington, D.C.
Once the defendant arrived in Washington, D.C., the defendant’s geolocation

data shows that he spent a significant amount of time in and around a location that
your affiant has identified as The Mayflower Hotel. Your affiant has confirmed that
The Mayflower Hotel had a reservation under the name of an individual who has been
identified as the defendant’s sister.
IMAGE 2: A screenshot of the defendant’s geolocation data on a map of Washington, D.C., with a cluster of location data
points at The Mayflower Hotel during a period that covers January 5-7, 2021.
A further review of the defendant’s geolocation data during the period of

January 5, 2021, shows that the defendant traveled from The Mayflower Hotel to the
Capitol and back
IMAGE 3: A screenshot of the defendant’s geolocation data on a map of Washington, D.C., during a period that covers
January 5, 2021.
As can be seen in IMAGE 3, the defendant traveled to the vicinity of the Capitol
the night before the attack on the Capitol. According to the geolocation data, the
defendant arrived in the vicinity of a location known as the Peace Monument at
approximately 9:06 PM. As stated above, the defendant would not have been able to
get any closer to the Capitol at that time because of the USCP security barricades that
were already in place. Accordingly, the geolocation data shows the defendant traveling
south along the barricade line and past the Garfield Monument to Independence Ave
SW. According to the geolocation data, the defendant then traveled east to an area in
the vicinity of the Longworth House Office Building, arriving there at approximately
9:27 PM. The defendant then appears to have backtracked and returned to The
Mayflower Hotel.
IMAGES 4, 5: (top) A screenshot of the defendant’s geolocation data in the vicinity of the Capitol, during the period of
January 5, 2021, from approximately 9:00 PM to approximately 9:45 PM; (bottom) a screenshot of a satellite-view map of
approximately the same area.
Further, The New Yorker photographer Balazs Gardi took a photo inside of
Sen. Merkley’s office that was published as part of Luke Mogelson’s article Among the
Insurrectionists.4 Although the defendant cannot be seen in Gardi’s photo, the
defendant’s selfie appears to have been taken at approximately the same time.
IMAGE 12: (left) A photograph taken by Balazs Gardi published in The New Yorker magazine in a location identified as
Sen. Merkley’s office (S140) as compared to IMAGE 10 (right), the selfie photograph of the defendant. The flagpole and wall
hangings appear to be identical, and many of the individuals in the photos appear to be in the same or similar locations.
The FBI reviewed additional open source videos, including a livestreamed

video recorded and simulcast by the separately charged defendant Anthime Joseph
Gionet (AKA Tim, AKA Baked Alaska).5 An individual that appears to be the
defendant is seen at approximately 7:27 just inside the Senate Wing doors in the DLive
broadcast.
4
https://www.newyorker.com/magazine/2021/01/25/among-the-insurrectionists
5
U.S. v. Gionet, 21-mj-14 (Dist. of Columbia).
the Capitol, the defendant sent forty-four images to three individuals. The next day,
the defendant went to the White House at approximately the same time that then-
President Trump was giving a speech, and texted the subscriber that he “met j,” a likely
reference to then-President Donald J. Trump.
The defendant then walked approximately the same route as the evening before,
but this time he walked past the barricades that he had seen the previous evening.
Together with a large group—many of whom were climbing through broken windows
as seen in IMAGE 14 and many of whom were screaming and chanting—the
defendant entered the Capitol.
Once inside, the defendant proceeded to S140, Senator Merkley’s office where
at least two individuals are seen smoking what appear to be cigars at approximately
the same time that the defendant is in S140. While inside S140, the defendant stopped
to take a picture and brag to the subscriber that he was “inside the capital [sic] lmfao.”
After leaving S140, the defendant walks through the Capitol Crypt, then returns
to the Senate Wing door and appears to leave through a broken-out window.
Your affiant submits there is probable cause to believe that Karol J.

CHWIESIUK violated 18 U.S.C. §§ 1752(a)(1) and (2), which make it a crime to (1)
knowingly enter or remain in any restricted building or grounds without lawful
authority to do; and (2) knowingly, and with intent to impede or disrupt the orderly
conduct of Government business or official functions, engage in disorderly or
disruptive conduct in, or within such proximity to, any restricted building or grounds
when, or so that, such conduct, in fact, impedes or disrupts the orderly conduct of
Government business or official functions; or attempts or conspires to do so. For
purposes of 18 U.S.C. § 1752, a “restricted building” includes a posted, cordoned off,
or otherwise restricted area of a building or grounds where the President or other
person protected by the Secret Service, including the Vice President, is or will be
temporarily visiting; or any building or grounds so restricted in conjunction with an
event designated as a special event of national significance.
Your affiant submits there is also probable cause to believe that Karol J.
CHWIESIUK violated 40 U.S.C. §§ 5104(e)(2)(C)(i), (D), and (G) which make it a
crime to willfully and knowingly (C) with the intent to disrupt the orderly conduct of
official business, enter or remain in a room in any of the Capitol Buildings set aside or
designated for the use of—(i) either House of Congress or a Member, committee,
officer, or employee of Congress, or either House of Congress; (D) utter loud,
threatening, or abusive language, or engage in disorderly or disruptive conduct, at any
place in the Grounds or in any of the Capitol Buildings with the intent to impede,
disrupt, or disturb the orderly conduct of a session of Congress or either House of
Congress, or the orderly conduct in that building of a hearing before, or any
deliberations of, a committee of Congress or either House of Congress; and (G) parade,
demonstrate, or picket in any of the Capitol Buildings.
Special Agent John J. Coleman

Federal Bureau of Investigation
Attested to by the applicant in accordance with the requirements of Fed. R.

Crim. P. 4.1 by telephone, this 10th day of June 2021.
ROBIN M. MERIWEATHER
U.S. MAGISTRATE JUDGE
AO 442 (Rev. 11/11) Arrest Warrant
UNITED STATES DISTRICT COURT

for the
District of&ROXPELD
United States of America

)
v.
) Case No.
)
)
)
.$52/-&+:,(6,8. )
Defendant
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) .DURO-&KZLHVLXN ,
who is accused of an offense or violation based on the following document filed with the court:
u Indictment u Superseding Indictment u Information u Superseding Information ;

u Complaint
u Probation Violation Petition u Supervised Release Violation Petition u Violation Notice u Order of the Court
This offense is briefly described as follows:
18 U.S.C. § 1752(a)(1)²Knowingly Entering or Remaining in any Restricted Building or Grounds Without
Lawful Authority
40 U.S.C. § 5104(e)(2)&L'*²Violent Entry and Disorderly Conduct on Capitol Grounds
Date: -XQH
Issuing officer’s signature
City and state: :DVKLQJWRQ'& 5RELQ00HULZHDWKHU, U.S. Magistrate Judge

Return
This warrant was received on (date) , and the person was arrested on (date)
at (city and state) .
Date:
Arresting officer’s signature

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Case: 1:21-cr-00373 Document #: 1 Filed: 06/11/21 Page 1 of 21 PageID #:1

Case: 1:21-cr-00373 Document #: 1 Filed: 06/11/21 Page 2 of 21 PageID #:2

UNITED STATES DISTRICT COURT

United States of America )

Code Section Offense Description

This criminal complaint is based on these facts:

-RKQ-&ROHPDQ, Special Agent

City and state: :DVKLQJWRQ'& 5RELQ00HULZHDWKHU, U.S. Magistrate Judge

On January 6, 2021, a joint session of the United States Congress convened at

Shortly thereafter, at approximately 2:20 PM, members of the House of

During national news coverage of the aforementioned events, video footage

A search of publicly available resources identified the defendant as an employee

Please pay close attention to the following event details:

Guest Arrival Information

This will be one of the most historic events of our lifetime.

I look forward to making history with you,

Ali Alexander – Founder of Stop The Steal

Once the defendant arrived in Washington, D.C., the defendant’s geolocation

A further review of the defendant’s geolocation data during the period of

The FBI reviewed additional open source videos, including a livestreamed

Your affiant submits there is probable cause to believe that Karol J.

Special Agent John J. Coleman

Attested to by the applicant in accordance with the requirements of Fed. R.

UNITED STATES DISTRICT COURT

United States of America

u Indictment u Superseding Indictment u Information u Superseding Information ;

This offense is briefly described as follows:

City and state: :DVKLQJWRQ'& 5RELQ00HULZHDWKHU, U.S. Magistrate Judge

Printed name and title

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-RKQ-&ROHPDQ, Special Agent

City and state: :DVKLQJWRQ'& 5RELQ00HULZHDWKHU, U.S. Magistrate Judge

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