1
2
3
4 UNITED STATES DISTRICT COURT
5 DISTRICT OF NEVADA
6 -o0o-
7 MAG-98-2042-M-RLH
8 UNITED STATES OF AMERICA, ) Case No.
)
9 Plaintiff, ) CRIMINAL COMPLAINT
10 VS. ) Violations: Title 18, United States Code,
) Section 175 - Conspiracy to Possess
11 LARRY WAYNE HARRIS, Biological Agent for Use as a Weapon;
WILLIAM JOB LEAVITT, Jr., ) Title 18, United States Code, Section
12 175 - Possession of Biological Agent for
Defendants, ) Use as a Weapon: Title 18, United States
13 Code, Section 2 - Aiding and Abetting.
14 Before the United States Magistrate Judge, District of Nevada, the undersigned
15 complainant, being duly sworn, states:
16 COUNT 1
17 On or about February 18, 1998, within the State and Federal District of Nevada,
18 LARRY WAYNE HARRIS, and
19 WILLLIAM JOB LEAVITT, Jr.,
20 defendants herein, knowingly conspired to possess a biological agent and toxin, to wit:
2 1 anthrax and anthrax precursors, for use as a weapon, in violation of Title 18, United
22 States Code, Section 175.
23 //
2 4 //
2 5 //
2 6
2 On or about February 18, 1998, within the State and Federal District of Nevada,
3 LARRY WAYNE HARRIS, and
4 WILLIAM JOB LEAVITT, Jr.,
5 defendants herein, knowingly possessed a biological agent and toxin, to wit: anthrax and
6 anthrax precursors, for use as a weapon, in violation of Title 18, United States Code,
7 Section 175 and Section 2.
8 As and for probable cause, complaint states as follows:
SNIPPETS:
14 Before the United States Magistrate Judge, District of Nevada, the undersigned
20 defendants herein, knowingly conspired to possess a biological agent and toxin, to wit: 2
anthrax precursors, for use as a weapon, in violation of Title 18, United States Code,
14 Leavitt, who wanted to use the source's equipment to test vials of Bacillus anthracis,
Harris and Leavitt had the anthrax in the trunk of a Mercedes16 Benz automobile.
18 with the FBI in the investigation of possible possession of biological warfare agents.
21 spores is almost always fatal to an unvaccinated and untreated person.
23 anthrax bacteria, and that its most common use is as a bacteriological warfare agent.
26 convictions for conspiracy to commit extortion in 1981 and 1982.
currently on probation after a 1995 felony conviction for wire fraud in fraudulently
vials of bubonic plague toxins, which he had in the glove compartment of his car.
Harris had stated that the New York subway
February 17,1998, that Harris and Leavitt had other organisms to test as well.
organisms turned out to be Bacillus licheniformis, Bacillus Anthracis, and the above5
11 to ten black leather fight-bag type bags in the trunk of the Mercedes-Benz.
13 1998, Leavitt telephoned the source and set a meeting for 7:00 p.m. at a local restaurant,
18 and Harris leave Room 921 of the Gold Coast Hotel and Casino.
19 white styrofoam cooler, which he placed into the Mercedes-Benz automobile.
When agents arrived at Building "3," they placed Leavitt and Harris under arrest
|
