Approved: SARAH L. KUSHNER ASsistant United States Attorney Before: THE HONORABLE JAMES L. COTT United States Magistrate Judge Southern District of New York UNITED STATES OF AMERICA WILLIE DENNIS, Defendant. SOUTHERN DISTRICT OF NEW YORK, ss.: X X SEALED COMPLAINT Violations of 18 U.S.C. §S 2261A and 2 COUNTY OF OFFENSE: NEW YORK ELISABETH WHEELER, being duly sworn, deposes and says that she is a Special Agent with the Federal Bureau of Investigation ("FBI"), and charges as follows: COONT ONE (Cyberstalking) 1. Since at least in or about 2018, up to and including the present, in the Southern District of New York and elsewhere, WILLIE DENNIS, the defendant, with the intent to injure, harass, and intimidate another person, used the mail, interactive computer services and electronic communication services and electronic communication systems of interstate commerce, and other facilities of interstate and foreign commerce, including electronic mail, phone calls, text messages, and faxes, to engage in a course of conduct that caused, attempted to cause, and would be reasonably expected to cause substantial emotional distress to a person, to wit, DENNIS has engaged in an unrelenting campaign of harassment, intimidation, and threats against an individual ("Victim-1") in New York, New York, including sending harassing and threatening smalls and text messages to Victim-1. (Title 18, United States Code, Sections 2261A(2)(B) and 2.) Commented [KR* an Na 'Cuter. Sarah (USANYS) 2020.10.141022:00 EFTA01659633