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
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