AFFIDAVIT

I, RALPH CLAY WOODWARD, Task Force Officer (TFO) with the Federal Bureau of
Investigation (FBI), Beaumont Resident Agency (BMTRA), Beaumont, TX (BMTX),
(hereinafter affiant) being duly sworn, depose and state as follows:
I am an investigative or law enforcement officer of the United States within the
meaning of Title 18, United States Code, Section 2510(7), that is, an officer of the United States
who is empowered by law to conduct investigations of and to make arrest for offenses
enumerated in Section 2516 of Title 18, United States Code (U.S.C.)
Your affiant has been a TFO with the FBI BMTRA since September, 2007. As a result of
the affiants training and experience, the affiant is familiar with Federal Criminal Laws including
18 U.S.C. 844(e), which makes it unlawful for any person to maliciously convey false
information concerning explosive materials.
On or about June 15, 2016 the affiant received information that an unknown individual
placed a telephone call to the Exxon Mobile Plant located in Beaumont, Texas in the Eastern
District of Texas, (hereafter referred to as the Plant) and that the individual who placed the call
communicated information that an explosive device or devices was set to detonate at the building
located at 1795 Burt Street, Beaumont, Texas. Exxon Mobile is the largest global refinery of
crude oil and other feedstocks. The Plant is one of Exxon Mobiles refinery and distribution
centers which provide fuels, lubricants, and other high value products to customers not only
nationally but also worldwide.
On June 15, 2016, at approximately 10:30 a.m., the Plant received a call from telephone
number (281) 804-9516. The call was made by a male who stated that a U.S. Securities
employee known to the affiant had a brother who placed boxes around the outer perimeter of the

Plant and that the boxes were set to explode at 11:00 a.m. The Subject stated that he was
concerned because the employee referenced by the caller had been talking about ISIS.
The FBI, Beaumont Police Department, and ATF immediately responded to the Plant. A
search of the Plants access records identified a specific employee with U.S. Securities Associates
Inc. by name, and the affiant is aware that this employee had access to and was working at the
Plant at the time the phone call was placed. The employee referenced in the phone call
consented to an interview with the affiant and informed the affiant that he/she was familiar with
telephone number (281) 804-9516 and that he/she had received calls from this number from a
person known to this employee as LANCE GIOVANNI FONTENOT. He/she informed the
affiant that FONTENOT had broken into his/her home the night before and stolen personal items
from him/her because of a personal dispute between them. The employee called the telephone
number in the affiants presence, and a male answered the call.
Investigators with BPD located FONTENOT in Beaumont, Texas in the evening hours of
June 15, 2016, and FONTENOT consented to an interview with SA Tony Cattelan. During his
interview FONTENOT admitted to making the threatening telephone call to the plant, and
admitted that he knew the threat he made about the explosive materials was false at the time that
he made it but that he made it anyway because he wanted to hurt the employee referenced in the
phone call. FONTENOT stated that he was aware of the effect his call would have to the
operation of the Plant.
Based on my training, experience and the information provided, I believe that Lance
Fontenot did maliciously convey false information about explosive materials in violation of Title
18, U.S.C. Section 844(e).

I declare under penalty of perjury that the foregoing is true and correct to the best of my
knowledge and belief, and that this declaration was executed on June __, 2016, at Beaumont,
Texas.
Respectfully submitted,
____________________________________
RALPH CLAY WOODWARD
TASK FORCE OFFICER
FEDERAL BUREAU OF INVESTIGATIONS

Sworn to and subscribed before me and I find probable cause.

___________________________
Honorable Keith Giblin
United States Magistrate Judge
Eastern District of Texas