Read the Criminal Complaint and Affidavit Charging Cole Tomas Allen

Case 1:26-mj-00080-MJS Document 1-1 Filed 04/27/26

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involved in the investigation of numerous types of offenses, including crimes of terrorism (domestic and international).

VENUE

Acts in furtherance of the offenses alleged herein occurred within the District of

5.

Columbia. See 18 U.S.C. § 3237.

PROBABLE CAUSE

6.

On April 25, 2026, the White House Correspondents’ Association Dinner (“the Dinner”) was held at the Washington Hilton hotel located at 1919 Connecticut Avenue, NW, Washington, D.C. Multiple high-ranking U.S. government officials attended and were featured at the Dinner, including President of the United States Donald J. Trump, the Vice President of the United States, and multiple Cabinet Secretaries.
7. More than seven weeks earlier, on March 2, 2026, President Trump publicly announced that he would attend the Dinner, posting on his Truth Social account: “The White House Correspondents Association has asked me, very nicely, to be the Honoree at this year’s Dinner, a long and storied tradition since it began in 1924, under then President Calvin Coolidge.” President Trump added that it would be his honor to accept the invitation. The March 2, 2026 post was publicized by various media outlets.
8. On or about April 6, 2026, ALLEN made a hotel reservation at the Washington Hilton hotel for three nights, from April 24 to April 26, 2026.

9.

On or about April 21, 2026, ALLEN traveled by train from his home near Los Angeles, California, to Chicago, Illinois. ALLEN arrived in Chicago on or about April 23, 2026.
10. That same day, ALLEN boarded a train in Chicago, Illinois, which arrived in Washington, D.C. on April 24, 2026, at approximately 1:00 p.m.

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