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Arrest on Out-of-District Offense
UNITED STATES DISTRICT COURT
. t3 30 M" 9: 50
SOUTHERN DISTRICT OF CALIFORNIA
ARREST ON OUT-OF-DISTRICT OFFENSE
Magistrate Case 7
The person charged as_A_n_iru_d_d_h_a_S_h_er_b_ow _________nowappears before this United States
District Court for an initial appearance as a result ofthe following charges having been filed in the United States
District Court for the District District of Columbia
with Transmission of Threats in Interstate Commerce
in
violation of TITLE 18. U.S.C.. SECTION 875(c)
The charging documents and the warrant of the arrest of the defendant which was issued by the above
United States District Court are attached hereto.
I hereby swear under penalty of perjury that the foregoing is true and correct to the best of my
knowledge, information and belief.
DATED: 8/30/13
SA William C. McNamara
(Name)
FEDERAL BUREAU OF INVESTIGATION
Reviewed and Approved:
Dated: 1/1'11);

Assistant United States Attorney
Case 3:13-mj-03267-WMC Document 1 Filed 08/30/13 Page 1 of 7
AO 91 (Rev. 08109) Criminal Complaint
UNITED STATES DISTRICT COURT
for the
District of Columbia
United States of America )
v. )
Aniruddha Sherbow ) Case: 1:13-mj-0627
-.-.-.
Deftndanl(3}
)
)
)
Assigned To : Magistrate Judge Alan Kay
Assign. Date: 08/14/2013
Description: Criminal Complaint and Arrest
CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
On or about the date(s) of August 1. 2013 & August 3,2013 in the county of in the
District of __ ___ the defendant(s) violated:
Code Section Offense Description
18 U.S.C. 875(c} Transmission of Threats in Interstate Commerce
This criminal complaint is based on these facts:
See attached Affidavit in Support of a Criminal Complaint and Arrest Warrant.
if Continued on the attached sheet.
Sworn to before me and signed in my presence.
Date: 08/14/2013
District of Columbia
City and state:
-_.. _-._._---
Case 3:13-mj-03267-WMC Document 1 Filed 08/30/13 Page 2 of 7
Case: 1:13-mj-0627
Assigned To : Magistrate Judge Alan Kay
AFFIDAVIT IN SUPPOF
Assign. Date :08/14/2013
CRIMINAL COMPLAINT AND AD Description: Criminal Complaint and Arrest
I, Lauren M. Vieth, am a Special Agent with the United States Capitol Police,
Investigations Division, 'Threat Assessment Section, 119 D. Street, N.R, Washington, D.C. I
submit this Statement of Facts in support of a complaint charging ANIRUDDHA SHERBOW
with transmission of threats in interstate commerce in violation of 18 U.S.C. 875(c).
1. I have been a Special Agent with United States Capitol Police since February
2008, and am currently assigned to the 'Threat Assessment Section. The United States Capitol
Police is, among other duties, responsible for investigating threats made against members of
Congress. In 2006, I obtained a Bachelor's Degree in Criminology and Justice Studies from The
College ofNew Jersey in Ewing, New Jersey. I attended Uniformed Police Training in 2008 and
Criminal Investigations Training .in 2013 at the Federal Law Enforcement Training Center in
Brunswick, Georgia, and have received other relevant training regarding Criminal Investigations.
2. 'Ibe facts set forth herein are based on information that I have obtained from my
personal involvement in this investigation and from other law enforcement officers who have
been involved in this investigation, on documents that I have reviewed, and on my training and
experience. Because this affidavit is being submitted for a limited purpose, I have not set forth
all of the information known to me concerning this investigation. Instead, I have set forth
information that I believe to be sufficient to establish probable in support of the government's
application for a complaint.
3. Since approximately February 2011, Aniruddha Sherbow has been harassing
Congresswoman Tulsi Gabbard, including making threats via email and telephone.
4. On August l ~ 2013, at approximately 8:30 a.m., Sherbow called the cellular
telephone of Congresswoman Gabbard. He left a voicemail message in which he stated, in part:
Case 3:13-mj-03267-WMC Document 1 Filed 08/30/13 Page 3 of 7
"So let me make something very fucking clear to you, you stupid little bitch. what's gOIlllR
happen is that I'm gonna find you, I'm gonna mash your fucking face into a fucking pulp, and
then I'm gonna fucking kill you." Congresswoman Gabbard was able to identify the caller who
left the voicemail message as Sherbow. as she was familiar with his voice from previous
interactions. Congresswoman Gabbard was in Washington, D.C., when she received the
threatening message. Sherbow's parents have reported that he was in Mexico at the time of the
call, and this is corroborated by his PayPaJ transactional records.
S. On August 5, 2013, Sherbow's mother, Arlene Sherbow, listened to a recording
of Sherbow's voicemail message of August 1.2013. Ms. Sherbow stated that the caller
~ ~ s o u n d e d like Rudy." Ms. Sherbow refers to her son as "Rudy."
6. On August 3, 2013, Sherbow, identifying himself by name, sent an e-mail to
mUltiple media outlets and the FBI, some of which are located in Washington, D.C. The subject
of the e-mail was "Cutting Off Tulsi Gabbard's Head." The body of the e-mail included the
following:
In the first vow to kill Tulsi, it was only if she came back to the mainland US.
She was cool in Hawaii, or anywhere else in the world. After my two-and-half
year pounding, however, I think I am ready to tighten that vow up, so that it
includes everywhere. Resistance is futile. So here it is:
"1, Aniruddha Sherbow, with the Divine as my witness, do hereby solemnly vow to
find Tulsi Gabbard, wheresoever she may be, and to sever her head from her
body."
Sherbow's email of August 3, 2013 (emphasis added).
On August 5, 2013. Sherbow's father, Paul Sherbow. stated that he received the email of
August 3, 2013, and confinned that it had been sent by his son.
2
Case 3:13-mj-03267-WMC Document 1 Filed 08/30/13 Page 4 of 7
~ ( / - / P ~
L . . Vieth
Special Agent
United States Capitol Police
United
/ ALAN KAY ,
U.S, MAGISTRATE ,mOGE
3
Case 3:13-mj-03267-WMC Document 1 Filed 08/30/13 Page 5 of 7
C'
, ,.. ~ ;
FILED
- ( $ IN THE UNITED STATES DISTRICT COURT AUG 1 " 2013
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... Y FOR THE DISTRICT OF COLUMBIA Clerk. U.S. District & Bankruptcy
'2'
..p Coorls for1h. District of Columbia
UNITED STATES OF AMERICA ) Case: 1:13-mj-0027
) Assigned To : Magistrate Judge Alan Kay
v.
) Assign. Date : 08/1412013
) Description: Criminal Complaint and Arrest
ANffiUDDHA SHERBOW )
)
ORDER TO SEAL
Upon motion of the United States to Seal Complaint and Related Documents, and for
good cause shown therein, the Court
FINDS that sealing the complaint and related docwnents in the above-captioned matter
will further legitimate governmental interests in apprehending the defendant, protecting a
Member of Congress, preserving evidence and conducting an ongoing threats investigation; and
further
FINDS that the United States has considered alternatives less drastic than sealing and has
found none that would suffice to protect the aforementioned legitimate governmental interests;
and further
FINDS that under Washington Post v. Robinson. 935 F.2d 282. 289 n.lO (D.C. Cir.
1991), these facts present an extraordinary situation and a compelling goveinmental interest
which justifY the requested sealing.
WHEREFORE, based upon the foregoing Findings ofFact, the Motion is hereby
GRANTED, and it is hereby
Case 3:13-mj-03267-WMC Document 1 Filed 08/30/13 Page 6 of 7
: .....
(
,
.. '
,
.... ~ .
ORDERED that, in the above-captioned matter, the Complaint and related
documents, including the Arrest Warrant, Motion to Seal and this Order to Seal, shall be sealed
by the Clerk ofthe Court. except that the United States Government may disclose the existence
and/or contents of the Complaint and related documents, includ,ing the Arrest Warrant, Motion to
Seal and this Order to Seal, to appropriate law enforcement, diplomatic, intelligence, military,
INTERPOL or other personnel, both in the United States and internationally, to the 'extent that
such disclosure is in furtherance of the protection ofa Member ofCongress, efforts to obtain
custody of or to detain the defendant, or discussions relating to the defendant's custodial status or
detention.
It is FURTHER ORDERED that the Clerk's office shall not make any entry on the public
docket in this case ofthe Complaint and related documents, including the Arrest Warrant,
Motion to Seal and this Order to Seal, until further order of this Court.
It is FURTHER ORDERED that the Complaint and related documents, including the
Arrest Warrant, Motion to Seal and this Order to Seal, shall be unsealed upon oral motion of the
Government to this Court or to any Court where the defendant is first presented.
It is FURTHER ORDERED that the Clerk of the Court shall provide to the United States
Attorney's Office certified copies ofthe Complaint and related documents, including the Arrest
Warrant, and the instant Motion to Seal and Order, upon request.
Copy: Jolm Crabb Jr.
National Security Section
United States Attorney's Office
55541& Street, N.W. (lIcit Floor)
Washington. D.C. 20530
john.d.crabb@usdoj.gov
Case 3:13-mj-03267-WMC Document 1 Filed 08/30/13 Page 7 of 7