Case 1:15-mj-00345-ML Document 1 Filed 07/24/15 Page 1 of 5

A0

91 (Rev.

11/Il) Criminal Complaint

UNITED STATES DISTRICT COURT

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Western District of Texas

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United States of America

V.

Case No.
1:15-MJ-

Vontrey Jamal Clark

)
)
)

Defendant(s)

CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the

On or about the date(s) of

Western

District of

July 17, 2015

Texas

Code Section

best of my knowledge and belief

Travis

in the county of
,

in the

the defendant(s) violated:

Offense Description

18 USC 1073

Unlawful Flight to Avoid Prosecution (UFAP)

This criminal complaint is based on these facts:

Please see attached affidavit.

Continued on the attached sheet.

cy2/L
Complainant s signature

SA Justin E. Noble, FBI

Printed name and title

Sworn to before me and signed in my presence.

Date:

07/24/2015
Judge 's

City and state:

Austin, Texas

Mark Lane, United

a$s Magistrate Judge

Printe na/ic and title

Case 1:15-mj-00345-ML Document 1 Filed 07/24/15 Page 2 of 5

UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF TEXAS
AUSTIN DIVISION

------------------------ )

UNITED STATES OF AMERICA,

Plaintiff
vs.

No. 1:15-MJ-

VONTREY JAMAL CLARK,

Defendant
)

AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT

I, Justin E. Noble, Special Agent, Federal Bureau

of Investigation, Austin, Texas, being

duly sworn, depose and state the following:

1.

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

District of Texas and elsewhere.

have participated in all aspects of violent crime/fugitive

investigations, including but not limited to conducting surveillance, analyzing information

obtained from court ordered pen registers and trap and trace devices, analyzing telephone toll
information obtained via subpoenas, interviewing subjects and witnesses, and conducting court
authorized wire intercepts.
Affidavit

Page

Case 1:15-mj-00345-ML Document 1 Filed 07/24/15 Page 3 of 5

2.

respectfully submit this affidavit in support of a criminal complaint and arrest

warrant for VONTREY JAMAL CLARK ("CLARK") for Unlawful Flight to Avoid Prosecution,
in violation

of 18 U.S.C.

1073. The information herein is based on my own investigation, as

well as my conversations with other law enforcement officers and my review of various law

enforcement documents.

The sole purpose of this affidavit is establishing probable cause for

issuance of an arrest warrant; so this affidavit does not contain all of the information

know

about this matter.

3.

On or about July 21, 2015 Texas Ranger Brent Barina, assigned to Bastrop

County, Texas, advised me of the following facts.

a.

On or about February 3, 2015, Samantha Dean, a Kyle Police Department

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.

Through the investigation that followed, law enforcement officers

determined that CLARK conspired with others to murder Dean.

Officers determined that

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.

CLARK is employed as a Police Officer with the Austin Police

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

Case 1:15-mj-00345-ML Document 1 Filed 07/24/15 Page 4 of 5

travel outside the City of Austin.

d.

On May 12, 2015, in connection with the Dean murder investigation, law

enforcement officers executed a search warrant at CLARK's residence.

On that same day

officers executed a search warrant for CLARK's DNA.

4.

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

through his attorney.

5.

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.

Based on information provided by American Airlines, I believe that CLARK did

in fact travel to West Jakarta, Indonesia on July 17, 2015.

8.

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

Code Section 19.03.

9.

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

Case 1:15-mj-00345-ML Document 1 Filed 07/24/15 Page 5 of 5

10.

Based on the information set forth above and my experience in conducting

fugitive investigations,

respectfully submit that there is probable cause to conclude that

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

Case 1:15-mj-00345-ML Document 2 Filed 07/24/15 Page 1 of 1

AO

442 (Rev 11/li) Arrest Warrant

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i

UNITED STATES DISTRICT COURT

2O15JUL2L+

forthe
Western District of Texas

OLEK

AK 9:58

[TP.C1 f:)LFT

United States of America

V.

CaseNo.

1:15-MJ-

Vontrey Jamal Clark

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)

Vontrey Jamal Clark

who is accused of an offense or violation based on the following document filed with the court:

Indictment

Superseding Indictment

Probation Violation Petition

information

Superseding information

Supervised Release Violation Petition

Violation Notice

Complaint
Order of the Court

This offense is briefly described as follows:

Violation of 18 USC 1073
Unlawful Flight to Avod Prosecution (UFAP)

Date:

07/24/2015
Issuing q9k?;/v signature

City and state:

Austin, Texas

Mark Lane, U

states MgjateJg
name and title

This warrant was received on (date)

at

(c/tv

and the person was arrested on (date)

and state)

Date
Arresting officer 's signa/ure

Printed ,iame and title

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