Case 6:08-cr-00147-WSS Document 1 Filed 09/04/2008 Page 1 of 5

--------~UNITED STATES DISTRlCT COURTWESTERN DISTRICT OF TEXAS

UNITED STATES OF AMERICAv. v y

CRIMINAL COMPLAINTWILLIAM H. FOSTER

CASE NUMBER:

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

to the best of my knowledge and belief.

Beginning on or about August 24.2008 and continuing until the present time, in the

Western District Texas, on Fort Hood Military Reservation, a place within the special

maritime and territorial jurisdiction of the United States, defendants did knowingly, willfully.

and unlawfully conspire and agree together with other person(s) to murder Kailey

Foster. contrary to Title 18, United States Code, Section 1111. and one or more such

person(s) did an overt act to effect the object of the conspiracy, and in violation of Title

18, United States Code, Section(s) 1117.

I further state that I am a(n) Special Agent, Federal Bureau of Investigation, and that

this complaint is based on the following facts:

SEE ATIACHED AFFIDAVIT

Continued on the attached sheet and made a part hereof: YES

Sworn to before me and subscribed in my presence,

September 4, 2008Date

Jeffrey C. Manske, u.s.Magistrate JudgeName & Title of Judicial Officer

Case 6:08-cr-00147-WSS Document 1 Filed 09/04/2008 Page 2 of 5

AFFIDAVIT

I, Daniel W. Chadwick, having been duly sworn, depose and say the following is true

according to my knowledge and belief:

1. Your Affiant is a Special Agent (SA) of the Federal Bureau oflnvestigation (FBI), San

Antonio Division, Waco Resident Agency. I have been employed as a Special Agent with the

FBI for over nineteen years and my duties and responsibilities include the investigation attempted

murder, a violation of Title 18, United States Code (USC) Section 1113. Your Affiant is

currently investigating a conspiracy to commit a murder on the Fort Hood Military Reservation,

in an area within the special maritime and territorial jurisdiction of the United States and under

exclusive jurisdiction of the United States.

2. Your Affiant is conducting a joint investigation with the US Army Criminal

Investigation Division (CID) regarding a conspiracy to commit murder. Investigation to date has

determined that William Foster has engaged two other individuals, Adam Watson and

Christopher Gardner to kill his wife, Kailey Foster. William Foster is a US soldier currently

deployed overseas in Iraq. Adam Watson, also a US soldier deployed overseas in Iraq, is

currently back in the United States on R&R leave. Christopher Gardner is a civilian that has

known William Foster for years.

3. Your Affiant received information from cm that a Cooperating Witness (CWl) has

advised them that William Foster is involved in a conspiracy to kill his wife, Kailey Foster.

CWI advised the following: On approximately August 24, 2008, Gardner received an email

from William Foster that he arranged with another individual to kill his wife but that the

individual would need intelligence on the daily activities of his wife. Gardner is currently

staying at the Foster residence, , Fort Hood, Texas which is located within

the special maritime and territorial jurisdiction of the United States, waiting for William Foster to

come back on 'R&R leave. William Foster advised Gardner to contact the individual that was to

carry out the murder. William Foster provided Gardner with an email contact for this individual.

Case 6:08-cr-00147-WSS Document 1 Filed 09/04/2008 Page 3 of 5

Gardner contacted William Foster again via email and advised that he had attempted to contact

this individual a couple oftimes with no success. William Foster then advised Gardner that the

individual was Adam Watson and provided his telephone number. At this point, Gardner was in

contact with Adam Watson via email. Gardner asked Adam Watson if he was the one that

William Foster wanted him to talk to about the "mission". Adam Watson advised that he was

and that he would need some gear. Adam Watson advised Gardner that he would need gloves,

ride, clean cloths, shower, rubbing alcohol, rags, etc. In one email William Foster advised

Gardner that some of the gear that Adam Watson will need is to "work on the house", which in

your Affiant's opinion, based on his training and experience, means to break in and or commit a

crime or clean up a crime scene.

4. cm has verified this information by obtaining copies of most of the emails containing

the above information in paragraph 3. cm has provided copies ofthese emails to your Affiant.

cm also have verified the identities of the individuals involved through a court order for

myspace records, the CW and Kailey Foster.

5. cm advised your Affiant that Kailey Foster advised that she felt that she was being

watched and that unknown person(s) has broke into her residence on at least two occasions in the

last week or so, however, nothing appears to be missing.

6. Further investigation by CID and your Affiant determined that on or about August 27,

2008, Adam Watson decided to get the gear that he would need. Adam Watson and Chaniell

Watson drove to Kailey Foster's residence Where it appeared that they were scouting out the

residence and checking out Kailey Foster's vehicle which was at her residence. They then went

to the site where the CW advised that Gardner would drop off the gear needed for the murder

scheme. They exited the vehicle and to look for the gear, ie gloves, clean cloths, rubbing alcohol,

and rags. Adam Watson located the gear and picked it up. These events were witnessed by CID

agents who were conducting a surveillance.

7. Once cm detained Adam and Chantell Watson, and Christopher Gardner, Chantell

Case 6:08-cr-00147-WSS Document 1 Filed 09/04/2008 Page 4 of 5

Watson provided a statement where she admitted she was aware that Adam Watson was working

with William Foster in the effort to kill Kailey Foster, which in emails they referred to as "the

job". Chantell advised that she was aware that they would get $75,001 for killing Kailey Foster

and that her husband was suppose to slit Kailey Foster throat to accomplish the murder of Kailey

Foster. Chantell Watson advised that on or about August 25,2008, she used Yahoo Instant

Messenger to communicate with William Foster. William Foster advised Chantell Watson that

Kailey Foster has a roommate and which point Chantell Watson asked him if that would make

his mission harder. IWilliam Foster advised her not to worry about it.

8. Adam Watson provided a statement where he admitted to conspiring with William

Foster to kill Kailey Foster, When asked why he joined the conspiracy to kill Kailey Foster,

Adam Watson advised that William Foster had offered him $75,000 to kill Kailey Foster and that

he needed the money. He also stated that William Foster would not stop pushing him about

killing Kailey Foster.

9. William Foster provided a statement where he admitted that he offered Adam Watson

$75,000 to kill his wife, Kailey Foster. William Foster also advised that Adam Watson agreed to

it once he was back home on R&R leave from Iraq. William Foster advised that Adam Watson

told him that he could get away with it without getting caught by going to the Foster residence,

kill Kailey Foster and then leave the house. William Foster also advised that he wanted Adam

Watson to get his vehicle so Kailey Foster would not be able to leave the house.

IV. Your Affiant respectfully requests authorization for an arrest warrant for Adam R.

Watson for his participation in a conspiracy to commit murder, a violation of Title 18, United

States Code, Section 1117.

Case 6:08-cr-00147-WSS Document 1 Filed 09/04/2008 Page 5 of 5

Daniel W. Chadwick, SA, FBI

Subscribed to and sworn before me on this the 4th day of September, 2008