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CLARE E. CONNORS #7936

United States Attorney SEALED FILED IN THE
UNITED STATES DISTRICT COURT
DISTRICT OF HAWAII

District of Hawaii BY ORDER OF THE COURT Jul 21, 2022

Pam Hartman Beyer, Clerk of Court

THOMAS MUEHLECK #3591

Assistant U.S. Attorney
Room 6100, PJKK Federal Building
300 Ala Moana Blvd.
Honolulu, Hawaii 96850
Telephone: (808) 541-2850
Facsimile: (808)541-2958
E-mail: [email protected]

Attorneys for Plaintiff

UNITED STATES OF AMERICA

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF HAWAII

UNITED STATES OF AMERICA, ) MAG. NO. 22-1259 RT

)
Plaintiff, ) CRIMINAL COMPLAINT;
) AFFIDAVIT
vs. )
)
WALTER GLENN PRIMROSE, (01) )
aka "Bobby Edward FORT" )
)
GWYNN DARLE MORRISON, (02) )
aka "Julie Lyn MONTAGUE" )
)
Defendants. )
)

CRIMINAL COMPLAINT

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I, the undersigned complainant, being duly sworn, state the following is true

and correct to the best of my knowledge and belief.

COUNT ONE
(Conspiracy to Commit Offense Against the U.S.)

On or about 28 August 2018, within the District of Hawaii, the defendants,

Walter Glenn PRIMROSE, and Gwynn Darle MORRISON, did knowingly and

willfully conspire and agree with each other to commit an offense against the U.S.

government, that is, to willfully and knowingly make false, fictitious, and

fraudulent statements, and representations in a matter within the jurisdiction of the

U.S. Department of Defense, in violation of 18 U.S.C. § 1001, all in violation of

Title 18, United States Code, Section 371.

COUNT TWO
(Aggravated Identity Theft)

On or about 28 August 2018, within the District of Hawaii, the defendants,

Walter Glenn PRIMROSE (AKA Bobby Edward FORT), and Gwynn Darle

MORRISON (AKA Julie Lyn MONTAGUE), did knowingly possess and use

without lawful authority, a means of identification of another person, during and in

relation to a felony violation enumerated in 18 U.S.C. § 1028A(c), to wit, 18 U.S.C

§ 1001, that is, the defendants knowingly and willfully made materially false,

fictitious, and fraudulent statements or representations in a matter within the

jurisdiction of the U.S. Department of Defense, knowing that the means of

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identification belonged to another actual person, in violation of Title 18, United

States Code, Section 1028A(1).

COUNT THREE
(False statement in application and use of passport)

On or about 04 April 2014, within the District of Hawaii, the defendant

Walter Glenn PRIMROSE (AKA Bobby Edward FORT), did willfully and

knowingly use and furnish to another, a passport that was secured by reasons of

false statements made in the application therefor, which falsely stated that the

person depicted in the passport photograph was Bobby Edward FORT, when in

fact the person was the defendant, which said passport the defendant used to obtain

a Hawaii Driver’s License, in violation of Title 18, United States Code, Section

1542.

COUNT FOUR
(False statement in application for passport)

On or about 08 April 2016, within the District of Hawaii, the defendant,

Gwynn Darle MORRISON (AKA Julie Lyn MONTAGUE), willfully and

knowingly made a false statement in an application for a passport renewal with

intent to induce and secure for her own use, the issuance of a passport under the

authority of the United States, contrary to the laws regulating the issuance of such

passports, and the rules prescribed pursuant to such laws, in that in such

application the defendant identified herself as “Julie Lyn MONTAGUE,” which

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statement she knew to be false, in violation of Title 18, United States Code,

Section 1542.

I further state that I am a Special Agent with the United States Department

of State, Diplomatic Security Service and that this complaint is based upon the

facts set forth in the attached “Agent’s Affidavit in Support of Criminal

Complaint,” which is incorporated herein by reference.

DENNIS K. THOMAS
Special Agent
U.S. Department of State
Bureau of Diplomatic Security Service

Sworn to under oath before me telephonically, and attestation

acknowledge pursuant to FRCP 4.1(b)(2), on this 21st day of July 2022, at
Honolulu, Hawaii.

Andrade
Rom A. Trader
United States Magistrate Judge

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I, Dennis Thomas, being duly sworn, state as follow:

Affiant Background

1. I am a Special Agent with the U.S. Department of State,

Diplomatic Security Service (DSS), currently assigned to the Honolulu

Resident Office. I have been employed with the Department of State as a

Special Agent since March 2011. I have attended and completed the

Criminal Investigative Training Program at the Federal Law Enforcement

Training Center. In addition, I completed the Department of State’s Bureau

of Diplomatic Security Basic Special Agent Training Course. Prior to my

employment with the Department of State, I was a Criminal Investigator in

the United States Army, where I independently conducted criminal

investigations into violations of the Uniform Code of Military Justice, and

federal laws. Furthermore, I am assigned as a Taskforce Officer to the

Honolulu Federal Bureau of Investigation Field Office. I hold a Bachelor of

Science in Criminal Justice. During my employment with the Department of

State, I have investigated violations of, among other things, Title 18, United

States Code, § 1542: False Statement on Application and use of Passport;

Title 18, United States Code, § 1028A: Aggravated Identity Theft, and Title

18, United States Code, § 371: Conspiracy to commit offense or to defraud

United States.

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Purpose

2. This affidavit establishes probable cause to arrest Walter Glenn

PRIMROSE (AKA: Bobby Edward FORT), and Gwynn Darle MORRISON

(AKA Julie Lyn MONTAGUE), for conspiracy to commit an offense against

the U.S. in violation of 18 U.S.C § 371; Aggravated Identity Theft, in

violation of 18 U.S.C. § 1028A; and False statement in application and use

of passport, in violation of 18 U.S.C. § 1542. It is alleged that PRIMROSE

and MORRISON agreed and conspired to make false statements in a matter

within the jurisdiction of the U.S. Department of Defense by unlawfully

assuming the identities of deceased persons Bobby Edward FORT, and Julie

Lyn MONTAGUE, respectively. Using the unlawfully assumed identities,

PRIMROSE and MORRISON applied for and were issued U.S. passports,

DOD identity document cards, and social security account cards, using the

name of the deceased persons, Bobby Edward FORT, and Julie Lyn

MONTAGUE. PRIMROSE and MORRISON both knowingly and willfully

used and possessed, without lawful authority, the means of identification of

another person, in connection with unlawful activity that constitutes a

violation of Federal laws.

3. The facts set forth below are based upon my knowledge and

personal observations, as well as information and documents provided to me

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in my official capacity concerning the activities of a Walter Glenn

PRIMROSE (AKA Bobby Edward FORT and Gwynn Darle MORRISON

(AKA Julie Lyn MONTAGUE). This affidavit does not contain every fact,

piece of information or evidence concerning the alleged violations.

Passports in General and Statutory Authority

4. The Passport Act of 1926, as amended, was in full force and

effect throughout the period of this investigation. This Act, codified in 22

U.S.C. § 211a, authorized the United States Secretary of State to grant and

issue United States passports under rules prescribed by the President and/or

other federal laws. Some of these rules are that a person wanting a United

States passport must complete and submit an application to the State

Department and must submit proof of American citizenship, usually a birth

certificate, and proof of identity, usually a driver’s license, with their

application. Another rule allows designated officers at United States Post

Offices and City Clerk Offices to accept passport applications, and to then

forward them to the State Department for processing. In the event of a

renewal of a U.S. passport, a DS-82, U.S. Passport Renewal Application for

Eligible Individuals is completed and mailed in with the expired passport as

proof of identity and citizenship.

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5. To obtain a U.S. passport, the applicant must be a United States

citizen and legally entitled to receive a U.S. passport. The applicant must

show proof of identity and United States citizenship at the time of the

application. All information and evidence submitted in connection with a

passport application is considered part of the application. Before submitting

the Application for a U.S. Passport, form DS-11, the applicant was required

to read the following statement:

6. “I declare under penalty of perjury all of the following: 1) I am

a citizen or non-citizen national of the United States and have not, since

acquiring U.S. citizenship or nationality, performed any of the acts listed

under "Acts or Conditions" on page four of the instructions of this

application (unless explanatory statement is attached); 2) the statements

made on the application are true and correct; 3) I have not knowingly and

willfully made false statements or included false documents in support of

this application; 4) the photograph attached to this application is a genuine,

current photograph of me; and 5) I have read and understood the warning on

page one of the instructions to the application form.”

7. After reading the statement, the applicant must sign their name

in the space provided immediately under the statement, this act swearing and

affirming that all information on the application is true and correct and that

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they understand the warning. It is only after the applicant signs the form that

the applicant is accepted for processing and a passport issued based on the

information and supporting documents contained within the application

PROBABLE CAUSE

Overview

8. The United States, including the U.S. Department of State,

Bureau of Diplomatic Security Service (DSS) and the Federal Bureau of

Investigation (FBI) is conducting an investigation of Walter Glenn

PRIMROSE (AKA Bobby Edward FORT) and Gwynn Darle MORRISON

(AKA Julie Lyn MONTAGUE) regarding possible violations of Title 18,

United States Code, Section 371 (Conspiracy to commit an offense against

the U.S), Section 1028A (Aggravated identity theft), and Section 1542

(False statement in application and use of passport).

9. During this investigation, your affiant obtained a verification of

birth facts record from the Shelby County Texas Registrar’s office,

associated with Walter Glenn PRIMROSE. Records revealed that Walter

Glenn PRIMROSE was born on XX/XX/1955 in Shelby County, Texas.

PRIMROSE was born to a Betty Marie Hayes, and Cecil Eugene Primrose.

Additionally, your affiant obtained a verification of birth facts associated

with Gwynn Darle MORRISON. Records revealed that Gwynn Darle

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MORRISON was born on XX/XX/1955, in Fort Belvoir, Virginia to a

Cyrial Morrison and Anna Weber.

10. Moreover, your affiant obtained school records from Calhoun

high school, in Port Lavaca, TX that revealed PRIMROSE and MORRISON

both attended the same high school from 1970 to 1973. Further, your affiant

obtained school records associated with Stephen F. Austin University, in

Nacogdoches, TX that revealed Walter Glenn PRIMROSE and Gwynn

Darle MORRISON both attended the university from 1976 to 1979.

11. Your affiant obtained records from Nacogdoches, TX County

Clerk’s office that revealed PRIMROSE and MORRISON married each

other on 19 August 1980, in Nacogdoches, TX. Commercial database

records indicated that PRIMROSE and MORRISON both resided together in

Nacogdoches, TX during this time. FBI obtained open-source records from

the city of Nacogdoches that revealed PRIMROSE and MORRISON

purchased a home together on 21 December 1981 in Nacogdoches, TX and

owned the home until it was foreclosed by the bank on 06 October 1987.

12. Investigation efforts revealed that in 1987, PRIMROSE and

MORRISON both obtained Texas birth certificate records for deceased

American born infants, that they used to unlawfully assume the identifies of

“Bobby Edward FORT” and “Julie Lyn MONTAGUE,” respectively.

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Specifically, PRIMROSE obtained a birth certificate record for Bobby

Edward FORT, born XX/XX/1967, in Dallas, TX, to Charolette Fort.

Furthermore, MORRISON obtained a Texas birth certificate record for Julie

Lyn MONTAGUE, born XX/XX/1968, in Burnet, TX, to John Montague

and Doralene Casey.

13. Records obtained from the Texas Bureau of Vital Statistics

revealed that Bobby Edward FORT, born XX/XX/1967, in Dallas, TX, to

Charolette Fort died on XX/XX/1967. I received a copy of a death certificate

in the name of Bobby Edward FORT. The death certificate revealed that

Bobby Edward FORT died XX/XX/1967, and the listed cause of death was

asphyxia. Also listed on the death certificate was the location of burial,

which was specified as City Cemetery, in Marble Falls, TX.

14. Moreover, records obtained from the Texas Bureau of Vital

Statistics revealed that Julie Lyn MONTAGUE born XX/XX/1968, in

Burnet, TX, to John Montague and Doralene Casey, died on XX/XX/1968,

in Burnet, TX. I received a copy of a death record in the name of Julie Lyn

MONTAGUE. The death certificate revealed that Julie Lyn MONTAGUE

died on XX/XX/1968, and the location of burial was specified as Burnet

Cemetery, in Burnet, TX. Bobby FORT was found to be buried in City

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Cemetery, located in Marble Falls TX, which is approximately 14 miles

from where Julie MONTAGUE is buried.

15. Records obtained from the Texas Department of Public Safety

revealed that on 25 August 1987 PRIMROSE was issued a Texas driver’s

license number XXXX0889 in the Bobby Edward FORT identity. The

records also included copies of the driver’s licenses that were issued to

PRIMROSE over the years in the Bobby FORT identity. The person

depicted in the photograph associated with Texas driver’s license number

XXXX0889, in the Bobby FORT name, strongly resembles PRIMROSE.

16. Additionally, records obtained from the Texas Department of

Public Safety revealed that on 10 September 1987 MORRISON was issued a

Texas identification card number XXXX0253 in the Julie Lyn MONTAGUE

identity. The person depicted in the photograph associated with Texas

identification card number XXXX0253 in the Julie MONTAGUE name,

strongly resembles MORRISON.

17. Records obtained from the Social Security Administration

revealed that on 30 September 1987, PRIMROSE executed an application

for social security card (SS-5) form using the personal identifiable

information belonging to the “Bobby Edward FORT” identity. As a result of

providing false information on the SS-5 form, PRIMROSE was issued social

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security account number XXX-XX-9136, in the “Bobby Edward FORT”

identity.

18. Additionally, records obtained from the Social Security

Administration revealed that on 26 October 1987, MORRISON executed an

SS-5 application form using the personal identifiable information belonging

to the “Julie Lyn MONTAGUE” identity. As a result of providing false

information on the SS-5 form, MORRISON was issued social security

account number XXX-XX-3279, in the “Julie Lyn MONATGUE” identity.

19. Records obtained during this investigation revealed that within

a six-month period, PRIMROSE and MORRISON had successfully assumed

the identities of “Bobby Edward FORT’ and “Julie Lyn MONTAGUE,”

respectively. Further, records obtained by your affiant revealed that

PRIMROSE and MORRISON re-married each other on 08 August 1988

under their respective assumed identities (Bobby FORT and Julie

MONTAGUE), in Austin, TX.

Military Records and Government Employment

20. Your affiant obtained records from the U.S. Coast Guard

Investigative Service, which revealed that PRIMROSE fraudulently enlisted

into the U.S. Coast Guard on XX/XX/1994, in the identity of “Bobby

Edward FORT.” Of note, PRIMROSE represented himself to U.S. Coast

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Guard officials as Bobby Edward FORT, born XX/XX/1967, instead of in

his true identity and date of birth of XX/XX/1955. PRIMROSE represented

himself to be approximately 12 years younger than his true age at time of his

Coast Guard enlistment. Records revealed that PRIMROSE served in the

U.S. Coast Guard from 1994 to 2016, twenty years in the fraudulently

obtained identity of Bobby Edward FORT.

21. Your affiant obtained records that revealed PRIMROSE retired

from the U.S. Coast Guard in 2016, and in that same year began working for

U.S. Company 1, a Department of Defense (DOD) contractor, where he

continues to work currently.

Passport Issuance

22. U.S. Department of State database records revealed that

PRIMROSE has been issued a total of five (5) U.S. passports in the Bobby

FORT identity. Specifically, PRIMROSE has been issued three (3) blue

tourist passport books, and two (2) U.S. government official passport books

in the Bobby FORT identity. Records revealed that PRIMROSE executed

U.S. passport applications using the following personal identifiable

information of Bobby Edward FORT: social security number XXX-XX-

9136, date of birth as XX/XX/1967, and place of birth as Dallas, Texas, but

submitting a picture of his own likeness on the following dates:

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• 08 November 1996

• 28 August 2001

• 03 October 2006

• 19 February 2009

• 12 February 2016

23. PRIMROSE’s most recent U.S. passport, #540772719 was

issued to him on 23 February 2016, in the identity of “Bobby Edward

FORT.” The passport is valid until 22 February 2026.

24. Further, U.S. Department of State records revealed that on 28

April 1987, PRIMROSE was issued U.S. passport number H0930146 in the

name Walter Glenn PRIMROSE, date of birth XX/XX/1955. The person

pictured on U.S. passport number H0930146 strongly resembles the same

person pictured on U.S. passport number 540772719, in the name of “Bobby

Edward FORT.” Additionally, U.S. Department of State records revealed

that on 30 March 1999, PRIMROSE executed a DS-82 Passport Application

using his identity (Walter PRIMROSE) and provided the following personal

identifiable information: social security number XXX-XX-3261, date of

birth as XX/XX/1955, and place of birth as Timpson, Texas. As a result,

PRIMROSE was issued a U.S. passport on 7 April 1999. Of note, at time of

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issuance, PRIMROSE had already been issued a valid U.S. passport in the

identity of “Bobby Edward FORT.”

25. Additionally, U.S. Department of State database records

revealed that MORRISON has been issued a total of three (3) U.S. passports

in the Julie MONTAGUE identity. Specifically, MORRISON has been

issued three (3) blue tourist passport books in the Julie MONTAGUE

identity. Records revealed that MORRISON executed U.S. passport

applications using the following personal identifiable information of Julie

Lyn MONTAGUE: social security number XXX-XX-3279, date of birth as

XX/XX/1968, and place of birth as Burnet, Texas, but submitting a picture

of her own likeness on the following dates:

• 08 November 1996

• 04 October 2006

• 08 April 2016

26. Specifically, on 08 April 2016, in the District of Hawaii,

MORRISON executed a DS-82 (#274423371), U.S. Passport Renewal

Application, and mailed it to the National Passport Center in Portsmouth,

NH. MORRISON used the following personal identifiable information of

Julie Lyn MONTAGUE: social security number XXX-XX-3279, date of

birth as XX/XX/1968, and place of birth as Burnet, Texas, but submitting a

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picture of her own likeness. As result, MORRSION was issued U.S.

passport number 543812582, on 20 April 2016 with an expiration date of 19

April 2026.

Hawaii Driver’s License

27. I received a copy of Bobby Edward FORT’s (PRIMROSE)

Hawaii driver’s license records from the Hawaii Department of

Transportation. Records revealed that on 04 April 2014 PRIMROSE

executed a Hawaii driver's license application renewal form in Honolulu, HI

in the Bobby Edward FORT identity. As part of his renewal application,

PRIMROSE used his fraudulently obtained U.S. passport, issued to him as

Bobby Edward FORT, as proof of his identity. I received a copy of the

biodata page associated with the U.S. passport PRIMROSE used to execute

his Hawaii driver’s license application renewal form in the Bobby Edward

FORT identity.

28. The information contained on the biodata page corresponds

with the information contained in the U.S. Department of State database

associated with the U.S. Passport PRIMROSE used to execute his Hawaii

driver’s license application. Furthermore, the person pictured on the passport

that PRIMROSE submitted with his Hawaii driver's license application

strongly resembles "Bobby Edward FORT," and appears to be the same

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person pictured in U.S. Department of State Database records associated

with U.S. passport information for Bobby Edward FORT, born

XX/XX/1967.

29. Furthermore, records obtained from the Hawaii Department of

Transportation revealed that on 03 March 2022, PRIMROSE executed a

Hawaii driver's license application renewal form in Honolulu, HI in the

Bobby Edward FORT identity. As part of his renewal application,

PRIMROSE used his fraudulently obtained social security account card,

number XXX-XX-9136, issued in the Bobby FORT identity, and his

fraudulently obtained DOD identification card, number 1133731470. As a

result of using the means of identification of another person, PRIMROSE

was re-issued a Hawaii drives license in the Bobby Edward FORT identity.

30. Additionally, records obtained from the Hawaii Department of

Transportation revealed that on 04 January 2017, MORRISON (AKA

MONTAGUE) executed a Hawaii Driver's license application renewal form

in Honolulu, HI. As part of her renewal application, MORRISON used her

fraudulently obtained U.S. passport, issued to her as Julie MONTAGUE, as

proof of identity. I received a copy of the biodata page associated with the

U.S. passport used to execute her Hawaii driver’s license application

renewal form. The information contained on the biodata page corresponds

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with the information contained in the U.S. Department of State database

associated with U.S. Passport MORRISON used to execute her Hawaii

driver’s license. Moreover, as part of her renewal application, MORRISON

used her fraudulently obtained social security account card, number XXX-

XX-3279, issued in the Julie MONTAGUE identity.

DOD Identification card issuance conspiracy

31. It was the object of the conspiracy to fraudulently obtain, use,

and possess a DOD identification card by PRIMROSE and MORRISON, to

which they both conspired and agreed with each other to provide false

statements in a matter within the jurisdiction of the U.S. Department of

Defense, in violation of 18 U.S.C. § 1001, and did use the means of

identification of another person in order to obtain a DOD identification

document, in violation of 18 U.S.C § 371.

Manner and Means of the Conspiracy

32. It was part of the conspiracy that PRIMROSE and MORRISON

engaged in a scheme, by which, they both unlawfully assumed the identities

of deceased United States citizens and obtain the means of identification of

another person. Specifically, PRIMROSE and MORRISON knew that the

names, dates and places of births, and social security numbers of Bobby

Edward Fort and Julie Lyn Montague did not legally belong to them, and

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were otherwise secured unlawfully, with intent to be used for their own

personal use in furtherance of their fraud scheme.

Overt Act

33. Your affiant obtained records and obtained information from

the Hawaii Army National Guard Office, in Kapolei, HI that revealed on 28

August 2018, PRIMROSE and MORRISON presented themselves to the

DOD ID card office located in the Hawaii National Guard building, in

Kapolei, HI where they conspired together to execute an application for

identification card/DEERS (Defense Enrollment Eligibility Reporting

System) enrollment form. In section I of the form, titled “Sponsor/Employee

Information,” PRIMROSE used the personal identifiable information

belonging to Bobby Edward FORT. Specifically, PRIMROSE identified

himself on the form as “Bobby E FORT,” DOB XX/XX/1967, and DOD ID

#1133731470. PRIMROSE signed the form in the presence of a DOD

verifying official. Above the signature block where PRIMROSE signed the

form is the following statement:

“I certify the information provided in connection with the eligibly

requirements of this form is true and accurate to the best of my

knowledge.”

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34. On the same application for identification card/DEERS

enrollment form, in section V of the form, titled “Dependent Information”

MORRISON used the personal identifiable information belonging to Julie

MONTAGUE. Specifically, MORRISON identified herself on the from as

‘Julie L MONTAGUE,” DOB XX/XX/1968, and DOD ID# 1133731489.

MORRISON signed the form in the presence of a DOD verifying official.

35. I believe based on the records and information provided by the

Hawaii Army National Guard office that PRIMROSE and MORRISON

agreed and conspired with each other to knowingly and willfully provide

false information and use the means of identification of another person while

executing an application for identification card/DEERS enrollment form,

and as a result, MORRISON was issued a DOD identification card bearing

the personal identifiable information of “Julie Lyn MONTAGUE,” but

depicting a picture of her own likeness.

Summary

36. Records obtained by your affiant revealed that PRIMROSE and

MORRISON have agreed to assume the identities of deceased American-

born infants and have been fully living in these fraudulently assumed

identities since 1987.

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37. Based on my training, experience, and the facts listed above,

the true Bobby Edward FORT and Julie Lyn MONTAGUE died on

XX/XX/1967, and XX/XX/1968, respectively, and are not the same

individuals who executed an application for identification card/DEERS

enrollment form in the identities of FORT and MONTAGUE. Moreover,

PRIMROSE is not the rightful owner of the personal identifiable

information associated with “Bobby Edward FORT,” which PRIMROSE

has successfully used over the past 30 years to obtain government

documents that he continues to use and possess in the District of Hawaii.

Further, MORRISON is not the rightful owner of the personal identifiable

information associated with “Julie Lyn MONTAGUE,” which MORRISON

has successfully used over the past 30 years to obtain government

documents that she continues to use and possess in the District of Hawaii.

38. From my training and experience, imposters often search

cemeteries for infants with dates of death close to their own birth dates to

more easily assume their identities. PRIMROSE and MORRISON both

obtained a certificate of birth in 1987 and were issued social security

account numbers in 1987 for their respective assumed identities, and have

been perpetrating criminal fraud acts ever since, to include acts committed in

the District of Hawaii.

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Conclusion

39. Based on the information and evidence detailed in this

Affidavit, I believe probable cause exists that Walter Glenn PRIMROSE and

Gwynn Darle MORRISON violated the aforementioned U.S. criminal

statues and as such, I respectfully request a warrant for their arrest. Walter

Glenn PRIMROSE is uniquely and specifically described in Attachment A-

1, and further displayed. Gwynn Darle MORRISON is uniquely and

specifically described in Attachment A-2, and further displayed.

Dennis Thomas
Special Agent
Diplomatic Security Service
Honolulu Resident Office
808-225-0248
This Criminal Complaint and Affidavit in support thereof were presented to, approved by,
and probable cause to believe that the defendant above-named committed the charged
crime found to exist by the undersigned Judicial Officer at 2:56 p.m. on July 21, 2022.

Sworn to under oath before me telephonically, and attestation

acknowledge pursuant to FRCP 4.1(b)(2), on this 21st day of July 2022, at
Honolulu, Hawaii.

Andrade
Rom A. Trader
United States Magistrate Judge

19
SBU -LAW ENFORCEMENT
Case 1:22-mj-01259-RT Document 1 Filed 07/21/22 Page 24 of 25 PageID #: 24

ATTACHMENT A-1

Walter Glenn PRIMROSE aka Bobby Edward FORT

Height: 5 feet 6 inches tall

Hair: Brown hair
Eyes: Brown eyes
Occupation: U.S. Company 1, a DOD Third-party government contractor

SBU -LAW ENFORCEMENT

Case 1:22-mj-01259-RT Document 1 Filed 07/21/22 Page 25 of 25 PageID #: 25

ATTACHMENT A-2

Gwynn Darle MORRISON aka Julie Lyn MONTAGUE

Height: 5 feet 4 inches tall

Hair: Brown hair
Eyes: Blue eyes
Occupation: Unemployed