AUSAs: Dominic A. Gentile,
Jun Xiang, Alexandra Messiter
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
SEALED COMPLAINT
Violations of
18 U.S.C. §§ 2261A, 2261(b), 924(j), and 924(c)
COUNTY OF OFFENSE:
NEW YORK
SOUTHERN DISTRICT OF NEW YORK, ss.:
GARY W. COBB, being duly sworn, deposes and says that he is a Special Agent with the Federal Bureau of Investigation, and charges as follows:
COUNT ONE
(Stalking – Travel in Interstate Commerce)
1. From at least in or about November 24, 2024 to in or about December 4, 2024, in the Southern District of New York and elsewhere, LUIGI NICHOLAS MANGIONE, the defendant, traveled in interstate commerce with the intent to kill, injure, harass, intimidate, and place under surveillance with intent to kill, injure, harass, and intimidate another person, and in the course of, and as a result of, such travel engaged in conduct that placed that person in reasonable fear of the death of, and serious bodily injury to, that person, and in the course of engaging in such conduct caused the death of that person, to wit, MANGIONE, traveled from Georgia to New York, New York for the purpose of stalking and killing Brian Thompson, and while in New York, MANGIONE stalked and then shot and killed Thompson in the vicinity of West 54th Street and Sixth Avenue.
(Title 18, United States Code, Sections 2261A(1)(A) and 2261(b)(1).)
COUNT TWO
(Stalking – Use of Interstate Facilities)
2. From at least in or about November 24, 2024 to in or about December 4, 2024, in the Southern District of New York and elsewhere, LUIGI NICHOLAS MANGIONE, the defendant, with the intent to kill, injure, harass, intimidate, and place under surveillance with intent to kill, injure, harass, and intimidate another person, used an electronic communication service and electronic communication system of interstate commerce, and a facility of interstate or foreign commerce, to engage in a course of conduct that placed that person in reasonable fear of the death of and serious bodily injury to that person, and in the course of engaging in such conduct caused the death of that person, to wit, MANGIONE used a cellphone, interstate wires, interstate
