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Case 3:18-mj-04035-NLS Document 1 Filed 07/16/18 PageID.1 Page 1 of 4
JUL 1 6 2018
UNITED STATES DISTRICT COURT
CLERK US DISTRiC r COURT
SOUTHEflN DISTRICT Or CALIFORNIA
SOUTHERN DISTRICT OF CALIFORNIA BY DEPUTY

18MJ4035
Case No.
UNITED STATES OF AMERICA
---------
COMPLAINT
Plaintiff
TITLE 18 U.S.C. § 1542
v. FALSE STATEMENT IN APPLICATION
AND USE OF PASSPORT (Felony)
FRANK JOHN SELAS.
aka John Frank Szeles

Defendant

The undersigned complainant, being duly sworn, states:

On July 11, 2014, within the Southern District of California, the defendant,
FRANK JOHN SELAS , aka John Frank Szeles, did willfully and knowingly make
false statements in an application for a passport, with the intent to induce and
secure the issuance of a passport under the authority of the United State, for his
own use, contrary to the laws regulating the issuance of passports and the rule
prescribed pursuant to such laws, in violation of Title 18, United States Code,
Section 1542.

The complainant further states that this complaint is based on the attached
statement of facts, which is incorporated herein by reference.

)A~~
KURT A vO\l/specia!Agent
U.S. Department of State
Diplomatic Security Service

/6a?
SWORN AND SUBSCRIBED TO before me
this

~ ~
,7- of July, 2018.

NITA L. STORMES
United States Magistrate Judge
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PROBABLE CAUSE STATEMENT & STATEMENT OF FACTS

I, Kurt A. Vogeley, being duly sworn, declare under penalty of perjury that the
following statement is true and correct:

1. I am a Special Agent (SA) with the U.S. Department of State, Diplomatic

Security Service (DSS) assigned to the San Diego, California Resident Office. I
have investigated or assisted in the investigation of numerous federal violations.

2. During the performance of my duties, I have obtained evidence that FRANK

JOHN SZELES (hereinafter referred to as DEFENDANT) did willfully and knowingly
make false statements in an application for a passport.

3. On June 5, 1979, an arrest warrant was issued for the DEFENDANT in the
name of FRANK JOHN SELAS, DEFENDANT's true birth name, from the Rapides
Parrish Sheriff's Office in Alexandria, Louisiana for two counts of violating state
statute R.S. 14:81, Obscene Behavior with a Juvenile.

4. According to Rapides Parrish Sheriff's Office Detective Stephen Phillips'

supplemental report of investigation, dated January 27, 2016, on June 5, 1979
DEFENDANT contacted the Rapides Parrish District Attorney's Office and inquired
if he would be prosecuted in regards to the arrest warrant in his name.
DEFENDANT was informed he would be arrested and prosecuted on the arrest
warrant in his name.

5. According to Detective Stephen Phillips' supplemental report of

investigation, dated January 27, 2016, law enforcement officers were unable to
locate DEFENDANT to execute the arrest warrant.

6. According to Detective Stephen Phillips' supplemental report of

investigation, dated January 27, 2016, it was determined DEFENDANT had left
the country on June 7, 1979.

7. On July 31, 1992, DEFENDANT was granted a civil order to change his name
from FRANK JOHN SELAS to John Frank Sze/es by the Superior Court of California
in San Diego Country, California.

8. It was reported in an Arrest Warrant Addendum, sworn on January 22,

2016, by Sheriff William E. Hilton of the Rapides Parish Sheriff's Department that
on an unknown date in 1994 an individual identifying himself as an Attorney from
California called the Rapides Parrish Sheriff's Office. The individual stated he was
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calling on the behalf of DEFENDANT and inquired if Law Enforcement still

intended to prosecute DEFENDANT if apprehended. The individual was informed
DEFENDANT would still be prosecuted and the conversation ended.

9. On July 11, 2014, DEFENDANT executed DS-82 #760436133, U.S. Passport

Renewal Application For Eligible Individuals, via mail. In block 9, "List all other
names you have used", DEFENDANT did not write his previous name, Frank John
SELAS, or any other aliases.

10. On July 11, 2014, DEFENDANDT executed DS-82 #760436133, U.S.

Passport Renewal Application For Eligible Individuals, via mail. In block 1, "Name,
Last, First, Middle" DEFENDANT wrote his name as Sze/es, Frank John.

11. On July 11, 2014, the DEFENDANDT signed DS-82 #760436133, U.S.
Passport Renewal Application For Eligible Individuals, acknowledging the "Acts or
Conditions" that state the applicant is "not the subject of an outstanding federal,
state, or local warrant of arrest for a felony".

12. On July 15, 2014, U.S. Passport #520572262 was issued by the U.S.
Passport Agency in San Diego, California, to DEFENDANT in the name of Frank
John Sze/es based off of DS-82 #760436133.

13. From July 28, 2014, to August 1, 2014, DEFENDANT used U.S. Passport
#520572262 as proof of U.S. citizenship on a roundtrip cruise from the United
States to Mexico.

14. On September 7, 2015, DEFENDANT used U.S. Passport #520572262 as

proof of U.S. citizenship to enter the United States from Mexico at the San Ysidro
Port of Entry.

15. On January 25, 2016, DEFENDANT was arrested by the U.S. Marshals for
one felony count of being a Fugitive from Justice for the outstanding 1979 arrest
warrant in the name of FRANK JOHN SELAS from Rapides Parrish Sheriff's Office.

16. According to Detective Stephen Phillips' Report of Investigation, undated,

when arrested on January 25, 2016 DEFENDANT initially identified himself to the
U.S. Marshals as "FRANK JOHN SZELES" with a date of birth of 09/16/1939.
DEFENDANT later stated he had spelled his name in the past as "SELAS."

17. According to Detective Stephen Phillips' Report of Investigation, undated,

when arrested on January 25, 2016, DEFENDANT "nodded his head in
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agreement" when informed by the U.S. Marshals that they were aware of
DEFENDANT's 1979 arrest warrant.

18. According to Detective Stephen Phillips' Report of Investigation, undated,

during a search warrant executed on January 28, 2016, an undated letter was
seized that was written by DEFENDANT stating "When my father went to school
they changed the spelling of his name. I'm thinking of going to the original
spelling. It used to be Szeles .. .I think you can understand why I want to change."

19. On January 18, 2018, DEFENDANT pied guilty under the name of FRANK
JOHN SELAS to one count of violating Louisiana state statute R.S. 14:81, Indecent
Behavior with a Juvenile based on the 1979 arrest warrant.