POLICE CRIMINAL COMPLAINT
COMMONWEALTH OF PENNSYLVANIA COMMONWEALTH OF PENNSYLVANIA
COUNTY OF: LEHIGH vs. — _
Magisterial Dstic Number’ —37-2-00 DEFENOAN {NAME ond ADDRESS)
MOU Heme: Hon JACOB HAMMOND ars ADAM NARCeORT: ™
Adress 3404HAMILTON BLVD. MN
ALLENTOWN PA 19103 Fae ase Nae Taam a
[faze BRovmstown COURT
|TANDSDALE PA 19448
Telephone: (610) 434.207
TSS EXTRADITION CODE TYPE
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(C1) 3-Felony Surrounding States TDAMsdomeano: Full DD. akedemeanor No Exiradison
DEFENDANT IDENTIFICATION INFORMATION
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STEVEN LUKSA
ATIQREY STEVEN LUKSA ao se
I. TPR, GREGORY. NEILL, Tor. Patrick MCGUIRE
of he,Pennsylven.a State Police, Tigop M. Bethlehem
do hereby state: (check appropriate box)
BOE onsen
FEES on
1. [J l accuse the above named defendant who lives at the address set forth above
C1 J accuse the defendant whose name is unknown.
to me but who is described as_
Gl taccuse the defendant whose name and popular designation or nickname is unknown to me and whom | have therefore
designated 2s Johin Doe or Jane Doe.
with violating the penal laws of the Commonweaith of PennsyWvania at
in LEHIGH County 9%" 39.
AOPC 412A-Rev. 07/10
SOUTH-WEST SIDE OF ROADWAY IN PULL
(Blonencacn OFF. ME PRESERVE ROAD,
= AREA ALONG GAME PRESERVE ROAD,
APPROXIMATELY 21/2 MILES FROM SR30o.
con or about WEDNESDAY MARCH 16, 204
Page 1 of __es POLICE CRIMINAL COMPLAINT
Dosket Number Date Filed | OTN/LiveScan Number Complaintincident Number
3221 Mo1-1337109,
First Middle: Last:
DefendantName | pain | ADAM RAPOPORT
2. | ask that a warrant of arrest or a summons be issued and that the defendant be required to answer the
charges | have made.
3. _ | verify that the facts set forth in this complaint are true and correct to the best of my knowledge or
information and belief. This verification is made subject to the penalties of Section 4904 of the Crimes
Code (18 Pa.C.S.§4904) relating to unswom falsification to authorities.
4. This complaint consists of the preceding page(s) numbered __ through _
‘The acts committed by the accused, as listed and hereafter, were against the peace and dignity of the
Commonwealth of Pennsylvania and were contrary to the Act(s) of the Assembly, or in violation of the statutes
cited.
(Before a warrant of arrest can be issued, an affidavit of probable cause must be completed, sworn to
before the issuing authority, and attached.)
; Hi
= O
AND NOW, on this date, ARc4 Zé, 2 Phe | certify that the complaint has been properly
completed and verified. An affidavit cf probable cy complated bers ‘can be issued.
s1-Z- 02 rl,
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1 Lab user fee applies.
AOPC 412A ~ Rev. 07/10 Page _of__tes POLICE CRIMINAL COMPLAINT
Date Filed | OTN/LiveScan Number ‘Compiainvincident Number
eat Mo1-1337108
First Midete: Last:
Defendant Name | Bin ADAM RAPOPORT
The acts committed by the accused are described below with each Act of Assembly or statute allegedly violated, if
ABBE, Whe. erels nor hen one gence, gah olee anid be umnbeed PANDA avon a
‘urenary se, you must ete spect secto(s and naseco) esate») oartnareas) alepe vss The ape cima tte fe arse ay be cate
own. In aden, scl sourty ruber an rancalriomaten a9, is) shold nat elise thm dently of anaccout must een, ony th last eur its. 204 PA Cae
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Ofemek__Secion_ Sibecioh PA Sat (8) Comme Grade NOI Ofees Cate UCRNRS Coos
PenaGOF Data meson
(appcabi) ure Dis nae wer zone
Statute Description (include the name of statue or ordi aA
[Criminal Homicide Be
‘Acts of the accused associated with this Offense:
In that the Defendant did intentionally, knowingly, sly or negligently cause the death of ancther human
lbeing, namely Jeniffer L. SNYDER. The Detend: ionally shoot the victim using a 9 MM handgun in the
lhead and back causing her death.
care Pom CS nan rw
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Gort 2_|2603 Ja tthe _| Tite 18, PA Crimes Code 1 fet [200
Ciense Section Subsecion PA Sa Te Counts Grade NOI Ofer Code UCRNIBRS Code
PenrDoT Daa eater
(Wappicate) urbe: Cl setety zone Clwerk zane
Siatute Desoription (include the name of statute or ordinance):
Criminal Homicide of an Unborn Child
‘Acts of the accused associated with this Offense:
In that the Defendant cid intentionally, knowingly, recklessly or negligently cause the death of an unborn child,
Inamely the fetus of Jennifer L. SNYDER. The Defendant did intentionally shoot the victim using a 9MM handgun
in the head and back causing the death of her unborn child.
AOPC 412A — Rev. 07/10 Page __ofth POLICE CRIMINAL COMPLAINT
Date Filed: | OTN/LiveScan Number ‘Complalnuincident Number
3r2ait Not-1337109
First: Wale Tact,
Davie | Adare RAPOPORT
AFFIDAVIT of PROBABLE CAUSE
4. Your Affiantis @ member of the Pennsylvania Slate Police, Troop M, Bethlehem Criminal Investigation Section.
2, That on 03/17/11 (Thursday) at approximately 0945 Hrs the Pennsylvania State Police et Troop M Bethlehem received a call fom
Dr. FREY's office conceming a suspicious vehicle in the parking lot to the rear of 4155 Independence Or. Schnecksville Pa. (Nort
‘Whitehall Twp Lehigh Couniy). Said vehicle was parked and unattended,
‘3. That Tor. Jason HAINES of Troop M Bethlehom was dispatched to investigate the car. He located the vehicle which is described as
‘2 1998 Plymouth Neon beating Pa registration HKM-39758.
4, That said vehicle was registered to Ms Jennifer SNYDER of 862 Kessler Red Allentown Pa, 16103,
‘5, That Tpr. HAINES examined the vehicle and observed the right side (passenger side) window was shattered and there was what is
believed to be a significant amount of blood inside the vehicle particularly arcund the passenger seat. Tpr. HAINES also observed a
‘spent shell casing on the passenger seat, He was ablo to obsorve a cacond spent shell casing in the rear of the passenger
‘compariment as he looked through the rear window.
riminal Investigations Unit responded to the scene. He
pears {0 be a piece of human tissue on the floor of the
glass on the parking lt indicating the window may have
beeleve the casing may be froma 9 mm pistal
6. That Cpl, Paul S ROMANIG of the Pa State Police Troop M Bethieher
‘spoke with Tpr. HAINES and obsorved the vehicle. He also observed whatapy
‘vehicle also in the passenger side. Additionally there did not appear
been shattered at anothar location. His cbservation of the shell casing |2¢ hi
7. That Col ROMANIC spoke with Mr Kurt WENGER onner of Cmbifdge Search o 4155 independence Dr Ste 4 Schneckovls PA
Te ltd he has neo surcliance othe pasting lel ae wel a5 Fe envarce fo the packing land he may have capture he Veni
being jet atthe location. ¢
12 and observed that the vehicle artived at the location on 03/18/11
&, That pl ROMANIG and WENGER reviewed he vi oct
fiocntenaaponatl ashe a
«. Theis observed pula io eatin fag We Ypres toe exreme rear corer wer the vec backed
five pong apace S
1, IPR. GREGORY O NEILL Tpr. Patrick MCGUIRE, BEING DULY SWORN ACCORDING TO THE LAW, DEPOSE
AND SAY THAT THE FACTS SET FORTH IN THE FOREGOING AFFIDAVIT ARE TRI
BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF.
(Signature of Aen
sworn tome and subscribed before methis yr dayot = MTP OI
3-I2- /t Date
My commission expres first Mondey/of January, 2 /47
. Magisterial District Judge
‘AOPC 4116 - Rev. 07/10 Page 1 ofdeh POLICE CRIMINAL COMPLAINT
AFFIDAVIT CONTINUATION PAGE
Docket Number: Dato Filed: ‘OTNiLiveScan Number: ‘Complaintincident Number
__| saint Mot-1337109
First: ~ Tides Last
Defendant ame: | David Acam RAPOPORT
AFFIDAVIT of PROBABLE CAUSE CONTINUATION
410. The video shows one subject exitng the vehice from the drivers side and the subject appears to be removing something from the
car. The subject then starts to walk south along the back of the parking lot towards a dumpster located near the south east comer of
the parking fot
11. That subject appears to be carrying some items including a white abject in his hands. The subject stops at the dumpster and cpens
the lid. The subject then deposits what he was carrying into the dumpster.
412. After depositing the items into the dumpster the subject is observed leaving the area on foot at a hurtied pace: He is observed
heeded in a southerly diroction and goes out of view as he goes behind the rear of Diebold Security located on independence Drive.
‘The subject is headed towards Levans Road.
13:Te sunject capured on the video appears tobe ight skinned, hin bul of medium fo above average height with dark hi of
red nth ‘
14, That Tpr Richard VIEBE cf Toop Mf Bethlehem ano Tp Greg DIETEoLT;oop M Fogelovile were dete toatl to make
Cortat wits ho rojolored ovner Senafer SNYDER at her osdenoay
46, That on 03/17/11 (Thursday) at approximately 1130 Tprs WEBB and DIETZ spoke with Ms Hilary SCHIAVONE who identified
herselfas the room mate of Jennifer SNYDER
mY
48. Tat Ms SCHIAVONE advised the roopers that she la sa hsbroom mato an 0/1/11 Nethosday at approximately 1100
eS neato tal SHER was o moet boy ring br Ewe RAFOPORT wah wom se ato sper he nigh
117. That SCHIAVONE also advised the troopers RAZOPOR Tis a veterinarian with whom SNYDER worked and that he was a marriod
rman. Nw
48. That SCHIAVONE indicated SNYDER had become pregnant from RAPOPORT and he was very angly. He didn't speak with
SNYDER for a few days however they reportedly had made up.
49. Thet SCHIAVONE informed the troopere SNYDER had her fist Ultra Sound Appointment scheduled for 03/17/11 (Thursday) at
(0800 hrs however she didrit know if she mage it as she had not spoken with her.
20. Ms. SCHIAVONE indicated she had received a text message on 03/17/11 (Thursday) at 3:13 p.m. purportedly from SNYDER. The
moesage read "Dr. Oumbass has to work tonight so | am going to my moms, Thanks. Hi”
21. Ms, SCHIAVONE related that the text was odd and that the wording was not typicel of Mis SNYDER.
22. That as Tprs. WEBB and DIETZ were speaking with Ms, SCHIAVONE she received a text message from RAPOPORT requesting
she have Jennifer cali him later as he doesn't think her cell is working
‘AOPC 411C - Rev. 07/10‘ aah POLICE CRIMINAL COMPLAINT
AFFIDAVIT CONTINUATION PAGE
ber’ | Date Filed: | OTNILiveScan Number: ‘Compiaintlncident Number
Eyal M01-1337109
First: wNiddie Last
Davie Adam
AFFIDAVIT of PROBABLE CAUSE CONTINUATION
23, Thal SCHIAVONE informed the troopers itis odd for RAPOPORT to text her as he never dene £0 in the past.
24. That additional members of the Pa State Police were summoned to the location where the vehicle was located. Cal. Maciean
PEEKE and Tpr. Jason TROUTMAN ot Troop M Bethienem Forensic Services Unit (FSU) were two of those members. Cpl PEEKE in
‘examining the vehicle atthe location said he noticed an odor of bleach coming from the vehicle
25, Thal Cpl, PEEKE and Tpr. TROUTMAN searched the dumpster at the scene and discovered an empty bottle of bleach. The bottle
\Wes white in color and was consistent with the item in the hand of the subject who exited the vehicle. The bottle had what appears 10
bea blood smear on it The bleach bottle indicated it was distnbuted and sold by Target a local retail establishment.
26, Thal in addition to the bleach bottle @ towel was located inside the dumpster. The towel was soaked with bieach,
27. Additionally a clear plastic bag with a zipper on It was located inside the dumpster. The bag had a piece of papericardboard with
the Philadelphia Eagles football team logo on @. There were also some medical documents pertaining to an OBGYN in the name of
Jennifer SNYDER found in the beg,
28, That Tpre. Greg ONEILL and Patrick MCGUIRE wore dotalled to Jocate DiaRAPOPORT at his residence in Lansdale concerning
this matter. They located Dr. RAPOPORT at his residence on 3/ 1ursday) at approximately 4:43 pm.
29. Tprs. O'NEILL and MCGUIRE frst made contact with RAPOPORG and his wife in the driveway oftheir residence. Troopers
‘advised Dr. RAPOPORT and his wife that they wanted to -OPORT regarding a missing person, SNYDER.
RAPOPORT initially denied having any contact with SNY1 revious months.
90. Troopers advised RAPOPORT of known recent him and SNYDER and thet this information was inconeistont with
his statement. RAPOPORT then stated he was in an/ongoingyelationship with SNYDER and he Gidn' want his wife to know.
Gtk
“AOPC 4116 - Rev. 07/10 Page of _Seth POLICE CRIMINAL COMPLAINT
AFFIDAVIT CONTINUATION PAGE
Docket Number: | Date Filed: | OTN/LiveScan Number: ‘Complainvincident Number
anait M01-1337109
First Wide ast
[DefencantName: | David ‘Adam RAPOPORT
AFFIDAVIT of PROBABLE CAUSE CONTINUATION
31. Tpr ONEILL asked RAPOPORT if there was anything betonging to SNYDER in his vehicle, RAPOPORT indicated he wasn't sure
but stated: ‘you can look", RAPOPORT was advised he did not have to allow us to look in his car. However, RAPOPORT continued to
‘agree and was asked if we could fst look in the trunk. Prior to opening the trunk, RAPOPORT asked if we could esk his wife to go
inside. Tpr. MCGUIRE walked across the street and spoke with Elizabeth RAPOPORT. Elizabeth elected to remain outside. Tpr.
MCGUIRE then returned fo the car. While Tpr. MCGUIRE was with Elizabeth RAPOPORT, Dr. RAPOPORT opened the trunk of his car
inthe presence of Tpr. O'NEILL.
32, While atthe rear ofthe vehicle Tpr. O'NEILL asked RAPOPORT ‘where's the gun". RAPOPORT immediately stated "the gun is in
there” and pointed to the forward left portion of the trunk. RAPOPORT reached into the trunk and retrieved a black colored cloth gun
case having a Glock OM, model 17 pistel bearing serial number ASH041US, from underneath aesorted items within tho trurk and
immediately handed the items to Tor. O'NEILL. Addtionaly RAPOPORT relieved a box of PMC 9 MM Lugar ammunition which was
later found be partally full,
33. During continued conversation with RAPOPORT Troopers again asked him if there was any of SNYDER's property in his vehicle
He indicated that there might be and proceeded to the passenger's side of the vehicle. RAPOPORT entered the vehicle, moved the
front passenger's sea forward and crawled into the backseat of the car. Tpr. MCGUIRE went to the drivers side of the car and opened
the driver's side door to view RAPOPORT. RAPOPORT retrieved a box of baby wipes from the rear driver's side floor area. He showed
them to Tpr. O'NEILL and stated he forgot that ne bought them yesterday at Target to be used clean his car as he pointed to the
dashboard. Tpr. ONEILL noticed a emall red-brown colored spot on the lid ofthe bex of wipes.
34, While RAPOPORT was in the rear seat compartment he handled:an.ofange colored backpack, opening the main compartment
‘and reached inside. Tpr. MCGUIRE asked RAPOPORT to stop and.asked ifthere were any weapons in the beg, RAPOPORT
indicated that there were not and Tp. MCGUIRE asked if he could’ cheek the bag. RAPOPORT handed the bag o MCGUIRE who said
“are you sure you don't mind, you don't have to let me". RAPOPQRT jqdicated it was ok
‘Tpr. MCGUIRE opened the bag and observed a roll of duct tape andfticed a red-brown stain on the cardboard portion of the tol.
MCGUIRE placed the backpack an the front crver’s seat of Bar, Shortly thereafter Troopers dosided to stop and havo RAPOPORT
ext the vehicle in order to seek a search warrant. .
36, Tprs ONEILL and MCGUIRE requested RAPOPORTigo Wintliem to continue the interview at the Pa Stete Police barracks at
Skippack. He spoke wih his wife and advised the trabpers hawould like fo speak with an attorney first.
)
A
3-77-11
AOPC 4116 - Rev. 07/40 Page of __ee POLICE CRIMINAL COMPLAINT
AFFIDAVIT CONTINUATION PAGE
[DockstNumber. | Date Filed: | OTN/LiveScan Number: ‘Complainvineidont Number
3/224 | Mo1-1337109
First Middle Last
RetencaneNamns: | and Adam RAPOPORT
AFFIDAVIT of PROBABLE CAUSE CONTINUATION
36, That the troopers ended the intorviow.
37, That your afflant is aware that there is a bagel shop Sam's Bagel locatad at 4041 Ri 309 Schnecksuilla PA. Said shop is south of
the location where the vehicle of Ms. SNYDER was located. Aduitionally tha! would be the direction the subject who exited frem the car
was traveling as he was captured on video fleeing the location,
38, That Or. RAPOPORT Is described zs an average to tall height W-N/M with dark hair which Is consistent withthe image of the
‘subject exiting the vehicle owned by Ms. SNYDER
29. That on 03/16/11 (Thursday) Cpl. Paul S. ROMANIC spoke with Mr Lee BOLAND Asset Protection of Target: He queried Target
records and discovered several recent sales of Bleach at various stores in the area. One such sale was on 03/16/11 (Wednesday) at
0919 Hrs at the Target store located in North Whales (Montgomery County). ‘The purchase incuded Bleach, Duct tape, Baby Wipes,
‘end a towel. The purchase indicatod it was rade with the crodit card of David RAPOPORT. Said target store isin close provimity to
the residence of David RAPOPORT.
40, That on 03/18/11 (Faiday) members of the Pennsylvania State Potce continued o search for Ms. Jenrifer SNYDER. The search
included tho uso of Pa State Police helicopters. At appreximalaly 0245 Hrs Tpr John EDWARDS acting a3 an observer in one ofthe
hhefcopters noticed an object along Game Preserve Ridin North Wistehall Twp Lehigh County, The object vas just nsde te wood line
along the road. The object appeared to be wrapped in something black and, wes the general size and shape of a human body. Upon
furor examination Tp EDNARDS rotor! oper be shades nh sie aoa
41, That Tpr. EDWARDS radioed to Cpl. Andrew CANEPA who wa Patroling the area in a State Police Vehicle and ho diated him to
the etea, Cpl CANEPA examined the object and confrrned I wa @ boGY wrappedin some sort of fleece blanket and stuffed in black
garbage bags. The body was also wrapped with duct tape ~ 4
fr,
42. That the location of the body was along Game Preserdg Road, Ypproximately 2 % miles west of the intersection of Sr 309 n Noth
Whitehall Twp Lenigh County. The location is just a short drive away from the location where the vehicle of Ms. SNYDER was located
as well as Sam's bagel Shop.
43. Matin addon tothe body aso found atthe site Wes a qurtly of shattered glass consistent with automobile glass. Adctionally &
Spent 9 mm round was found amangst ha shateredglags, The rovnd was manactired by PNC
44. That additional members of the Pa State Police were summoned to the scene. Cpl Maclean PEEKE and Tpr. Jason HAINES were
‘surmmoned to process the scene and collect evidence. In so doing Cpl, PEEKE advised that he smelled the ocr of »teaa from the
area where the body was discovered.
GD
3-22~/)
o7it0 Page __ of __tes POLICE CRIMINAL COMPLAINT
AFFIDAVIT CONTINUATION PAGE
Docket Number: | Date Filed: | OTNiLiveScan Number: ‘Compiainvinclcent Number
arpart 101-1337109
f First Wide Last
| Defendant Name: | David __ Adam’ RAPOPORT,
AFFIDAVIT of PROBABLE CAUSE CONTINUATION
45. That Lehigh County Deputy Coroner Daniel BUGLIO was called to the scene and pronounced the victim dead at 1195 Hours. The
body was then removed from the area and transported to the Lehigh Valley Hospital where an autopsy was to be performed,
46, That on 03/19/11 (Saturday) Dr. Marlann HAMEL performed an autopsy on the victim's body. The victim was identified as Jennifer
L. SNYDER, The wrappings of the body were found to be a fleece throw withthe logo of the Philadelphia Eagles football team. The
fleece was soaked with bleach. The victim's body was further covered with two large, dark colored plastic garbage bags and tiaving
duct tape on them,
47. Thatit was determined the victim suffered three gun shot wounds. One wound was fo the center ofthe back exting the abdomen.
The other two other wounds were inflicted inside of the victim's mouth and exited the back of her head,
48, That the examination of the victin’s body confirmed that she was about 2 months pregnant with what appeared to be a healthy
male fetus.
48, That Lehigh County Goroner Scott GRIM was present at the autopsy and ruled the cause of death of the viciim was multiple gun
hot wounds te the head and torso with fractures and brain injury. The manner of death was ruled a homicide,
50. That an 03/19/11 (Saturday) at approximately 1300 hrs. Tpr Louls GOBER, Tpr. Jason TROUTMAN executed a search warrant on
{22005 Toyota Solara commonly used by RAPOPORT. Found insie the wehicle was a roll of cuct tape with what is believed to have
blood on the inside ofthe rell as well as Some hair clinging to the end ofthe ol, Adcitionaly they discovered whats believed to be the
Victim's callular telephone under the drivers coat; s container of babyatigosivth what is belioved fo have bieod on t| and an oponed
box of black gartage bags behind the driver's seat. Said bags are Pete the bags in which the victm was discovered in
51. On 021/11 Sgt. Ku TEMPINSK! ofthe Pernsyivania StaldPolis, Sethetem Region Crime Laboratory, Basics Secon
determined the decharged cartridge casings found ‘nsie the vcs vehice and at the cme scene were datrmined tobe
“scharged in e Clock model 17 Beating sera rumber ASHOATUS,WHleh was tured over Ly RAPOPORT to your affont
‘AOPC 4116 - Rev. 07/10 Pege_of__