Professional Documents
Culture Documents
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91 (Rev.
20)5J(JL 214
fl
t:
AM 9:57
>. tr.
-:
Case No.
1:15-MJ-
)
)
)
Defendant(s)
CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the
Western
District of
Texas
Code Section
in the county of
,
in the
18 USC 1073
cy2/L
Complainant s signature
Date:
07/24/2015
Judge 's
Austin, Texas
------------------------ )
Plaintiff
vs.
No. 1:15-MJ-
Defendant
)
am a Special Agent of the Federal Bureau of Investigation (FBI) and have been
so employed for eight (8) years. I am currently assigned to the San Antonio Division, Austin
Resident Agency, working with the Central Texas Violent Crime Fugitive Task Force. In that
capacity, I have been assigned to work violent crime/fugitive investigations in the Western
Page
2.
warrant for VONTREY JAMAL CLARK ("CLARK") for Unlawful Flight to Avoid Prosecution,
in violation
of 18 U.S.C.
well as my conversations with other law enforcement officers and my review of various law
enforcement documents.
issuance of an arrest warrant; so this affidavit does not contain all of the information
know
On or about July 21, 2015 Texas Ranger Brent Barina, assigned to Bastrop
Victim Services Specialist, was found deceased in Bastrop County, Texas. Dean's body was
behind a vacant shopping center and had three small-caliber bullet wounds to the head. An
autopsy revealed that Dean was approximately seven months pregnant at the time of her death.
b.
CLARK was the father of Dean's unborn child, and that CLARK's likely motivation to commit
murder was Dean's unwillingness to abort the child.
c.
Department (APD). On or about February 5, 2015 APD placed CLARK on paid restricted duty
due to the possibility of CLARK's involvement in the Dean homicide. As part of paid restricted
duty, CLARK must remain at his residence during the day, during regular work hours. CLARK
must request approval through his chain of command for any deviation from that requirement.
Examples of a deviation would be a medical appointment during normal work hours or any
Affidavit
Page 2
On May 12, 2015, in connection with the Dean murder investigation, law
On July 13, 2015 both of the aforementioned search warrants were unsealed and
released to the media. I believe that CLARK then became aware of the full scope of the Dean
murder investigation and the evidence against him on July 13, 2015, either through the media or
On July 15, 2015 American Airlines issued a round-trip ticket for CLARK to
travel on July 17, 2015 to Soekarno-Hatta International Airport, West Jakarta, Indonesia.
6.
On July 16, 2015 APD Sergeant Lee Rogers directed CLARK to report, in person,
to APD headquarters on July 18, 2015. At no time did CLARK ask APD for permission to leave
the State of Texas, and he did not report in person to APD headquarters on July 18, 2015.
7.
On July 21, 2015 a state district court in Bastrop County, Texas, issued an arrest
warrant for CLARK, based on a charge of capital murder, a felony, in violation of Texas Penal
On July 22, 2015 the Bastrop County District Attorney requested the FBI's
assistance in apprehending CLARK and returning him to Bastrop County. The District Attorney
also indicated that Bastrop County will extradite CLARK from wherever he may be found.
Affidavit
Page 3
10.
fugitive investigations,
CLARK fled the State of Texas to avoid prosecution for the crime of capital murder.
JUS'yTI/E. NOBLE
Agent, FBI
Spel
Subscribed and sworn before me this 24th day of July 2015 at Austin, Texas.
MARK LANE
UNITED
STATGISTTE JUDGE
Affidavit
- Page 4
F LF
i
forthe
Western District of Texas
OLEK
AK 9:58
[TP.C1 f:)LFT
CaseNo.
1:15-MJ-
De/ndant
ARREST WARRANT
Any authorized law enforcement officer
To:
YOU ARE COMMANDED to arrest and bring before a United States magistrate judge without unnecessary delay
(name ofperson to he arrested)
Indictment
Superseding Indictment
information
Superseding information
Violation Notice
Complaint
Order of the Court
Date:
07/24/2015
Issuing q9k?;/v signature
Austin, Texas
Mark Lane, U
states MgjateJg
name and title
(c/tv
and state)
Date
Arresting officer 's signa/ure