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Excerpts of criminal complaint charging Keith D. Nelson

Excerpts of criminal complaint charging Keith D. Nelson

Date: 10/14/99 19:33

Editor's note: The following is a criminal complaint and a supporting affidavit filed with the U. S. District Court in Kansas City. The affidavit has been edited for content because of objectionable material. Ellipses (...) are used when material has been deleted. Boldface text, except when used as headers or sectional dividers, indicates content has been rephrased.

United States District Court

Filed Oct. 14., 1999, in the Western District of Missouri

UNITED STATES OF AMERICA V. KEITH D. NELSON

Case Number: 99-138H-01

(Name and Address of Defendant)

I, the undersigned complainant being duly sworn state the following is true and correct to the best of my knowledge and belief. On or about October 12, 1999 in Jackson County, in the Western District of Missouri defendant did, unlawfully seize, kidnap, abduct and carry away and hold for ransom, reward or otherwise Pamela Butler of Kansas City, Kansas, and willfully transported Pamela Butler in interstate commerce from Kansas to Missouri.

In violation of Title 18 United States Code, Section 1201. I further state that I am a Special Agent, FBI and that this complaint is based on the following facts:

See attached Affadavit.

Continued on the attached sheet and made a part hereof:

(Yes is checked)

(Signed)

Thomas R. Crawford, Special Agent

Federal Bureau of Investigation

Sworn to before me and subscribed in my presence,

October 14, 1999 at Kansas City, Missouri

(Signed)

Sarah W. Hays

UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF MISSOURI

AFFIDAVIT

The undersigned, Thomas R. Crawford, being duly sworn, states as follows:

(1) I, Thomas R. Crawford, am a Special Agent of the Federal Bureau of Investigation (FBI) and I am stationed in Kansas City, Missouri. I have been an agent for approximately four years. The following information is based on information obtained from other federal agents and other law enforcement officers.

(2) I make this affidavit in support of a complaint for arrest warrant for Keith D. Nelson for the kidnapping and abduction of Pamela Butler on October 12, 1999.

(3) Special Agents John Brunell and Dirk Tarpley, FBI, informed me of their interview of a man from DeSoto in Johnson County... who provided the following information. On Wednesday morning, 9/29/99, the man from DeSoto was at A-1 Staffing waiting for employment when he was approached by Keith Nelson, who asked if the man wanted to make $9 an hour doing construction cleaning. The man agreed and he and Nelson left together in white Ford truck. Nelson told him the truck belonged to his boss. They first went to a Home Depot to buy supplies using a check from his boss's checkbook.

The man and Nelson drove around the Grandview, Mo., area, then to Nelson's boss's house, the description of which fits the description of the house of Nelson's employer, David Cunningham. They picked up tools and loaded them into the truck. They left for a job site on Warsaw Road, where broken concrete was loaded into Nelson's truck. While at the job site... Nelson said that he would like to kidnap a girl.... Nelson said that he would buy a plot of land in a secluded area, at least 25 miles from any houses and land having no access to hunters....

At the job site, the man said, Nelson saw a teenage girl and made a salacious remark about her. The man said that Nelson was very talkative and he couldn't go without constantly talking.

The description of the interior of the white Ford truck provided by the man matches the description of the truck owned by Cunningham and driven by Nelson, as observed by FBI agents.

(4) Detectives William Johnson and Mike Vega of the Kansas City, Kan., Police Department interviewed two men at a salvage yard on Pawnee in Kansas City, Kan., one of whom stated stated that Nelson stopped by the salvage yard at around 4 to 5 p.m. on 10/12/99 and that Nelson was driving a white Ford pickup truck. The other man suggested that the detectives check another salvage yard near 12th Street in Kansas City, Kan.

(5) Detectives Johnson and Vega went to another salvage yard, west of 12th Street, near a secluded area... approximately three blocks from the residence of Pamela Butler, the victim of the kidnapping. The detectives and I later spoke with a man there, who stated that he had seen a white male (whom he later identified as Keith D. Nelson) in a white Ford pickup truck parked outside the gate of the salvage yard as he was leaving on 10/12/99 about 10 to 15 minutes before 6 p.m. The white male (Nelson) advised that he was there to purchase a Dodge Colt.... The white male (Nelson), who was wearing a red T-shirt and blue jeans, offered to lock the gate... at least three times. After the man provided a description which matched that of Nelson, the detectives displayed a photo of Nelson... and he positively identified that photo as the white male he had seen on the early evening of 10/12/99 at the salvage yard, which is approximately 3 blocks from the residence of Pamela Butler....

(6) On 10/12/99, at approximately 5:45 p.m., Pamela Butler... was rollerblading in the area of 11th and Scott, Kansas City, Kan., near her residence. Pamela's sister... noticed nearby a white Ford truck with a gold or silver tool box in the back. Inside the truck was observed a white male with a red t-shirt, brown short hair, approximately 20-30 years old, and heavy set lying down in the front seat. The driver's side door to the truck was slightly open and as Pamela was approaching the back of the truck, the white male jumped out, grabbed Pamela around the waist, and threw her into the vehicle. Penny yelled to family members that someone had abducted Pamela as the truck entered the area. The sister could see that Pamela was struggling with the white male while in the front seat of the vehicle.

(7) The white pickup truck was observed by several individuals and is described as a Ford F-250 bearing Missouri license 177-CE2. The vehicle was chased by ... a concerned citizen but was lost in traffic.

(8) At approximately 7:00 p.m. on 10/12/99, the Ford F-250 pickup truck bearing Missouri license 177-CE2, was observed by a church custodian and his wife behind the Grain Valley Christian Church... He was suspicious of the truck and wrote down the truck's license number. She noticed a brown plaid afghan with fringe spread across the front of the truck.

(9) A check of vehicle records and subsequent interviews has determined that the F-250 truck... is registered to Ford Motor Credit, c/o B-Dry Systems, which is a company formerly owned by Mr. David Cunningham, Independence, Missouri.

(10) Mr. Cunningham confirmed that the Ford F-250 truck belongs to him and advised that Mr. Keith D. Nelson, who works for him, has been driving the truck for approximately two weeks while Mr. Nelson's vehicle is being repaired.

(11) On 10/11/99, a day prior to the abduction of Pamela Butler, ...an employee of Wenzle's Field Works, 1124 Scott Avenue, Kansas City, Kansas, observed the white Ford F-250 pickup truck being driven by a white male matching the description of Keith Nelson slowly driving around the area. This is the area of the residence of Pamela Butler. The employee was curious of the vehicle and the driver as he thought the area was being "cased."

(12) On 10/13/99, Ms. Nancy Nelson, mother of Keith Nelson, was interviewed at her residence in ...Kansas City, Missouri, and provided consent to search the premises. Observed in the house was a brown afghan matching the description of that observed in the Ford pick-up truck seen at the Grain Valley Christian Church. Ms. Nelson confirmed that her son had been at the residence on the evening of 10/12/99, and as she had never seen the afghan, believed it to be his. Also observed in the residence's yard were three shovels, two with cement on them and one covered with dirt.

(13) A woman who lives near Nancy Nelson advised that around 10:00 p.m., on 10/12/99, she observed a white male matching the description of Keith Nelson, and another white male exiting the basement of the Nancy Nelson residence. The woman confronted the male who matched the description of Keith Nelson who stated he was working on the plumbing. Additionally, at approximately 11:30 p.m. that same night, the woman observed the white male matching the description of Keith Nelson cleaning the outside of the truck and wiping his hands frequently while nervously looking up and down the street. With respect to the above content search described in paragraph 11 supra, law enforcement officers observed a wet sponge in the area where the truck was cleaned. In addition, at approximately 1:30 a.m.,, the woman heard male voices arguing in the Nancy Nelson residence.

(14) Mr. Cunningham advised that Mr. Nelson had previously contacted him regarding work. Mr. Cunningham told Mr. Nelson that they had a "job to do" and instructed Mr. Nelson to meet him at his residence between 8:00 and 8:30 a.m. on 10/13/99. Mr. Nelson failed to arrive or call regarding his absence.

(15) The Ford F-250 pickup truck was located on the street in the 3000 block of East 14th Street, Kansas City, Missouri, and had been parked there since about midnight on October 13, 1999, according to neighbors, and no one had come to claim it. Residents of the area believed the vehicle to have been parked in this area since approximately 12:00 a.m. on 10/13/99. Visual observation has determined that the brown afghan previously seen inside the truck at the Grain Valley Christian Church was no longer in plain view.

(16) Pursuant to a search warrant the FBI seized the F-250 white Ford truck and towed it to the FBI field office headquarters for processing. As noted, the vehicle had remained parked on the street since midnight of 10/13/99 or thereafter. When found the vehicle was unlocked and the keys were on the floor. Preliminary results of the search reveal that the car had been stripped of any contents and thoroughly cleaned, possibly utilizing cleaning agents, and the interior appeared to have been vacuumed. Luminol is used to test for the presence of blood but will test positive in the presence of certain soap residues. Preliminary luminol results show positive results when applied to the exterior of the driver's door and the rear tail gate in small spots. Without further refined tests, no definite conclusions can be drawn. Through the use of special lighting, it appeared that a cleaning agent had been used on the entire vehicle. When the front seat was removed, agents and lab technicians collected longish, light-colored hair strands caught on the bottom of the bench seat near the floor. Pamela Butler has light-colored longish hair. The afghan which matched the description of the one seen in the truck at the Grain Valley Christian Church, and was later recovered at the home of Ms. Nancy Nelson, mother of Keith Nelson, was exposed to a qualified tracking dog handled by officers at Lansing Prison. Earlier in the day that dog had been exposed to clothing worn by Pamela Butler. The dog was taken to the residence of Ms. Nancy Nelson. The dog walked around initially and then alerted to the afghan which matched the description of the one seen in the pick up truck while parked at the church.

(17) I submit that there is probable cause to believe that Keith D. Nelson kidnapped and abducted Pamela Butler in Kansas and transported her to the state of Missouri, in violation of 18 U.S.C. 1201.

(Signed)

Special Agent Thomas R. Crawford

Federal Bureau of Investigation

Submitted and sworn to before me this 14th day of October, 1999

(Signed)

Sarah W. Hays

United States Magistrate Judge

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