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1
IIP ILiIN THE UNITED STATES DISTRICT COURT FOR THE fir I .M$ 3 I 2015
EASTERN DISTRICT OF VIRGINIA .' 1CLfcHK, U.S. UlSTRlcfcou
Alexandria Division !^^A
UNITED STATES OF AMERICA ) Criminal Case 1:15-mj- I2*i)
v. ))
WOSSEN ASSAYE, )
)Defendant )
AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT
I, Timothy Alley, being duly sworn, state:
1. I am a Deputy United States Marshal with the United States Marshal Service. I
have been a Deputy United States Marshal since 2009.
2. The facts and information contained in this affidavit are based upon my training
and experience, participation in investigations, personal knowledge and observationsduring the
course of this investigation, as well as the observations of other agents and police officers
involved in this investigation. All observations not personally made by me were relayed to me
by the individuals who made them or are based on my review of records, documents and other
physical evidence obtained during the course of this investigation. This affidavit contains
information necessary to support probable cause. It is not intended to include each and every
fact and matter observed by me or known to the United States.
3. On March 20, 2015, law enforcement agents arrested WOSSEN ASSAYE in
connection with the robbery that day of the Apple Federal Credit Union, a federally insured
financial institution, located at 6831 Sir Viceroy Drive in the Alexandria area of Fairfax County,
Virginia. Later on March 20, 2015, the Honorable Theresa C. Buchanan, United States
Case 1:15-mj-00184-IDD Document 2 Filed 03/31/15 Page 1 of 3 PageID# 2
Magistrate Judge, United StatesDistrict Court for the Eastern District of Virginia, issued a
criminal complaint in the case United States v. WossenAssaye (l:15-mj-163), charging ASSAYE
with possession of a firearm in furtherance of a crime of violence, in violation of 18 U.S.C.
924(c).
4. On March 23,2015, ASSAYE appeared before the Honorable Michael S.
Nachmanoff and was ordered detained pending a preliminary hearing and remanded to the
custody of the United States Marshal Service.
5. On March 25, 2015, the Honorable Michael S. Nachmanoff, United States
Magistrate Judge, United States District Court for the Eastern District of Virginia, dismissed the
complaint without prejudice upon motion of the United States and issued a new criminal
complaint in the case UnitedStates v. WossenAssaye (l:15-mj-171), charging ASSAYE with
bank robbery, in violation of 18 U.S.C. 2113(a).
6. On March 26, 2015, Judge Nachmanoff found the offense charged in that
complaint was supported by probable cause and ordered ASSAYE detained pending further
proceedings.
7. On March 27,2015, ASSAYE was transported from the Alexandria Detention
Center to Inova Fairfax Hospital, located at 3300 Gallows Road, Falls Church, Virginia, for
medical treatment.
8. On March 31, 2015, while still receiving hospital care at Inova Fairfax Hospital
while under the custody of the United States Marshal Service, ASSAYE overpowered a guard,
took her service weapon, and fled the hospital.
Case 1:15-mj-00184-IDD Document 2 Filed 03/31/15 Page 2 of 3 PageID# 3
CONCLUSION
9. Based on the foregoing, I believe probable cause exists to conclude that
WOSSEN ASSAYE has violated 18 U.S.C. 751(a), escaping from the custody of the Attorney
General and his authorized representative, and from an institution and facility in which he is
confined by direction of the Attorney General, and from custody under and by virtue of process
issued under the laws of the United States by a court, judge, and magistrate judge, and from the
custody of an officer and employee of the United States pursuant to lawful arrest, where the
custody and confinement is by virtue of an arrest on a charge of felony, to wit: Robbery of the
Apple Federal Credit Union, in the Alexandria area of Fairfax County, and I respectfully request
the issuance of a complaint and arrest warrant charging him with that offense.
Timothy Alley "N.United States'MatshaLService
SWORN TO AND SUBSCRIBED BEFORE ME THIS 3/ DAY OF MARCH 2015.
^jQ_/s/_Ivan D. Davis
United States Magistrate Judge
Case 1:15-mj-00184-IDD Document 2 Filed 03/31/15 Page 3 of 3 PageID# 4