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IN THE UNITED STATES DISTRICT COURT FOR THE

DISTRICT OF COLUMBIA

AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT AND ARREST WARRANT

I, Bradley Gilmore, Special Agent of the United States Department of State, Diplomatic

Security Service, being duly sworn, state:

INTRODUCTION

1. I submit this affidavit in support of an arrest warrant and criminal complaint charging

KEVIN BRUCE ZEESE (“ZEESE”), MARGARET ANN FLOWERS (“FLOWERS”),

ADRIENNE PINE (“PINE”), and DAVID VERNON PAUL (“PAUL”) (pictured in Exhibit A),

all located in the Embassy of the Bolivarian Republic of Venezuela in Washington, D.C., (the

“Venezuelan Embassy”), with Interference with Protective Functions of the Department of State,

in violation of 18 U.S.C. § 118 which provides: whoever knowingly and willfully obstructs, resists,

or interferes with a Federal law enforcement agent engaged, within the United States or the special

maritime territorial jurisdiction of the United States, in the performance of the protective functions

authorized under section 37 of the State Department Basic Authorities Act of 1956 (22 U.S.C.

2709) or section 103 of the Diplomatic Security Act (22 U.S.C. 4802) shall be fined under this

title, imprisoned not more than 1 year, or both.

2. I am employed as a Special Agent of the Diplomatic Security Service (“DSS”),

U.S. Department of State at the Office of Protection, Protective Liaison Division (“DS/P/PL”).

My duties include serving as the primary security and law enforcement liaison conduit between

the U.S. Department of State and foreign embassies and consulates in the United States,

specifically foreign missions within the Western Hemisphere Affairs (“WHA”) region. I also

coordinate with federal and local law enforcement entities as it pertains to domestic and

international protective functions. I provide escort and coordination for DSS protective details to

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airports in the Washington, D.C. area, the White House, and the U.S. Capitol. Finally, I coordinate

investigations of criminal incidents committed by and or perpetrated against the foreign diplomatic

community. I have served in the DSS for thirteen years and one month and with DS/P/PL for one

year and eight months. Previously, I held overseas assignments with the DSS as the Assistant

Regional Security Officer-Investigator in Sao Paulo, Brazil, Special Assistant to the Senior

Regional Security Officer in Baghdad, Iraq, and Assistant Regional Security Officer in Ankara,

Turkey. Within the United States, I held assignments with DSS’s Criminal Fraud Investigations in

Washington, D.C., and in the DSS New York Field Office. During the course of my law

enforcement career, I have investigated cases of visa fraud and passport fraud and protected foreign

diplomats. In addition, in preparation for my duties as a Special Agent, I completed the Criminal

Investigator Training Program at the Federal Law Enforcement Training Center in July 2006,

Basic Special Agent Course at the Diplomatic Security Training Center, Regional Security Officer

Course at the Diplomatic Security Training Center, High Threat Tactical Operations Course at the

Diplomatic Security Training Center, and Basic Consular Course at the Foreign Service Institute.

3. The facts and information contained in this affidavit are based upon my training

and experience, personal knowledge, and observations during the course of this investigation, as

well as the observations of other law enforcement officials whom I know to be reliable and

trustworthy. All observations not personally made by me were related to me by the individuals

who made them or were conveyed to me by my review of records, documents, and other physical

evidence obtained during the course of this investigation. This affidavit contains information

necessary to support probable cause for a criminal complaint and arrest warrants and is not

intended to include each and every fact and matter observed by me or known to the Government.

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4. This affidavit is submitted in support of a criminal complaint and arrest warrants

charging ZEESE, FLOWERS, PINE, and PAUL, with knowingly and willfully obstructing,

resisting, and interfering with a federal law enforcement agent engaged, within the United States,

in the performance of the protective functions authorized under section 37 of the State Department

Basic Authorities Act of 1956 (22 U.S.C. 2709) or section 103 of the Diplomatic Security Act (22

U.S.C. 4802) in violation of 18 U.S.C. § 118.

STATEMENT OF FACTS SUPPORTING PROBABLE CAUSE

Recognition of Interim President Juan Guaidó and

Accreditation of Ambassadors Vecchio and Tarre

5. On January 23, 2019, President Donald J. Trump officially recognized the President

of the Venezuelan National Assembly, Juan Guaido, as the Interim President of Venezuela. 1

President Trump released an official statement on January 23, 2019, stating: “Today, I am

officially recognizing the President of the Venezuelan National Assembly, Juan Guaido, as the

Interim President of Venezuela. In its role as the only legitimate branch of government duly

elected by the Venezuelan people, the National Assembly invoked the country’s constitution to

declare Nicolas Maduro illegitimate, and the office of the presidency therefore vacant.”

6. On January 23, 2019, Secretary of State Michael R. Pompeo released an official

press statement recognizing Juan Guaidó as the new interim President of Venezuela, stating “[t]he

United States recognizes Juan Guaido as the new interim President of Venezuela.”

7. By notification dated January 24, 2019, Juan Guaidó informed the United States

Government that Mr. Carlos Alfredo Vecchio was accredited as Chargé d’Affaires of the Embassy

1
See Zivotofsky v. Kerry, 135 S. Ct. 2076, 2086, 2096 (2015) (stating, inter alia, that “[t]he text and
structure of the Constitution grant the President the power to recognize foreign nations and governments”
and that “[t]his case is confined solely to the exclusive power of the President to control recognition
determinations, including formal statements by the Executive Branch acknowledging the legitimacy of a
state or government and its territorial bounds.”) (emphasis added).

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of Venezuela in the United States. The notification stated: “I, Juan Guaidó, interim President of

the Bolivarian Republic of Venezuela, accredit Mr. Carlos Alfredo Vecchio as Chargé d’Affaires

of the Embassy of Venezuela in the United States. As the representative of the Government of

Venezuela in the United States, Mr. Vecchio has authority to take actions on behalf of Venezuela,

including to provide a certification indicating who is the person with the full authority to receive,

control, and dispose assets of the Government of Venezuela, including of the Central Bank of

Venezuela.” The notification was initialed by President Juan Guaidó above his signature block.

(Exhibit B)

8. The United States accepted interim President Juan Guaidó’s notification of

accreditation of Mr. Carlos Alfredo Vecchio as the Chargé d’Affaires of the Embassy of the

Government of Venezuela to the United States on January 25, 2019. The Department of State

released a press statement that stated: “Mr. Vecchio will have authority over diplomatic affairs in

the United States on behalf of Venezuela.”

9. On January 29, 2019, interim President Juan Guaidó sent a letter to President Trump

appointing Mr. Carlos Alfredo Vecchio as Ambassador of the Bolivarian Republic of Venezuela

to the United States of America. (Exhibit C). On February 5, 2019, the United States accepted the

accreditation of Mr. Carlos Alfredo Vecchio as Venezuela’s Appointed Ambassador to the United

States.

10. On April 11, 2019, the Permanent Council of the Organization of American States

(“OAS”) released a resolution (CP/RES. 1124 (2217/19) rev. 1) accepting “the appointment of Mr.

Gustavo Tarre as the National Assembly [of Venezeula’s] designated Permanent Representative,

pending new elections and the appointment of a democratically elected government.”

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11. Ambassador Tarre presented his credentials to the Organization of American States

on April 10, 2019, which notified the Department of State of that presentation on or before April

26, 2019.

Code Pink, the Embassy Protection Collective, and Popular Resistance’s Entry into the
Embassy of the Bolivarian Republic of Venezuela and the Permanent Mission of Venezuela to
the Organization of American States

12. Members of a group called Code Pink, individuals calling themselves the Embassy

Protection Collective, and members of a group called the Popular Resistance, began occupying the

Venezuelan Embassy and the Permanent Mission of Venezuela to the Organization of American

States on or about April 10, 2019. On May 13, 2019, ZEESE sent an email to the United States

Department of State, copying among others, FLOWERS, and Medea Benjamin. In that email,

ZEESE stated that “[t]his is the 34th day of our living in the Venezuelan embassy in Washington,

DC.”

13. As explained more fully below, ZEESE, FLOWERS, PINE, and PAUL, along with

other persons identifying as members of Code Pink, the Embassy Protection Collective, and the

Popular Resistance, were not granted authorization by the Venezuelan government to be present

at the Venezuelan Embassy. ZEESE claims to act as the spokesperson for the Embassy Protection

Collective and the Popular Resistance and FLOWERS is one of the co-directors of the Popular

Resistance. 2

14. Code Pink was founded by Medea Benjamin, among others. Code Pink describes

itself as “a women-led grassroots organization working to end U.S. wars and militarism, support

2
See https://popularresistance.org/embassy-protection-collective-were-still-here-and-were-staying/;
https://www.washingtonpost.com/local/50-americans-are-living-in-venezuelas-dc-embassy-amid-a-
standoff-venezuelans-say-they-want-it-back/2019/05/01/3ee9cae4-6c2b-11e9-a66d-a82d3f3d96d5_story
.html? Utm_term=. b1dd1d166ed3; https://www.washingtonpost.com/local/were-not-going-to-leave-
three-arrested-activists-face-dwindling -supplies-on-day-3-of-venezuelan-embassy-protests-in-dc/2019
/05/02/a0dc0728-6d0a-11e9-a66d-a82d3f3d96d5_story.html?utm_term=.77d1a93065c0

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peace and human rights initiatives, and redirect our tax dollars into healthcare, education, green

jobs and other life-affirming programs.” 3 Representatives of Code Pink claim that they received

key cards for access to the Venezuelan Embassy and the Permanent Mission of Venezuela to the

Organization of American States from departing Venezuelan diplomats of the former Maduro

regime, and that members of Code Pink, the Embassy Protection Collective, and the Popular

Resistance are therefore permitted to occupy the Venezuelan Embassy and the Permanent

Mission. 4

Request for Protective Services at the Embassy of the Bolivarian Republic of Venezuela
and the Permanent Mission of Venezuela to the Organization of American States

15. Two Venezuelan diplomatic missions are located at 1099 30th Street N.W.,

Washington, D.C., 20007: (1) the Embassy of the Bolivarian Republic of Venezuela in

Washington, D.C.; and (2) the Permanent Mission of the Bolivarian Republic of Venezuela to the

Organization of American States.

16. On April 26, 2019, Venezuelan Ambassador Carlos Vecchio sent a diplomatic note

to the U.S. Department of State, requesting the support of the Government of the United States for

the Venezuelan Embassy’s efforts to take occupancy of the premises of the Venezuelan Embassy

in Washington, D.C. In the diplomatic note, Ambassador Vecchio requested the assistance of U.S.

law enforcement officials in the removal of any person on the premises of the Venezuelan Embassy

who is not authorized by the Venezuelan government to be present. Ambassador Vecchio provided

his consent for appropriate U.S. law enforcement or health and safety officials, together with

Department of State officials, to enter the premises of the Venezuelan Embassy to support the

Venezuelan government’s plans to retake occupancy of the Venezuelan Embassy. He waived the

3
See https://www.codepink.org/about
4
See https://www.codepink.org/venezuela_embassy_protection_collective_defies_unlawful_no_trespass
_order

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inviolability of Venezuelan Embassy’s premises for the purpose of supporting the Venezuelan

Embassy staff’s occupancy of the premises and for ensuring the safety of the Venezuelan Embassy

premises. The waiver also “requests protective services in ensuring that the Embassy premises is

free from trespassers” and notes that Venezuelan government “considers any persons in or on the

Embassy premises without the express consent of the Embassy led by Ambassador Vecchio to be

trespassing.” (Exhibit D)

17. On April 26, 2019, Ambassador Tarre sent a diplomatic note to the U.S. Department

of State requesting the support of the Government of the United States for the Permanent Mission

of the Bolivarian Republic of Venezuela’s efforts to take occupancy of the premises of the

Permanent Mission’s premises in Washington, D.C. In the diplomatic note, Ambassador Tarre

requested the assistance of U.S. law enforcement officials in the removal of any person on the

premises who is not authorized by the Venezuelan government to be present. Ambassador Tarre

provided his consent for appropriate U.S. law enforcement or health and safety officials, together

with Department of State officials, to enter the premises of the Permanent Mission. He waived the

inviolability of Permanent Mission premises for the purpose of supporting the Permanent Mission

staff’s occupancy of the premises and for ensuring the safety of the Permanent Mission premises.

The waiver also “requests protective services in ensuring that the Permanent Mission property is

free of trespassers” and notes that Venezuelan government “considers any persons in or on the

Permanent Mission property without the express consent of the Permanent Mission to be

trespassing.” (Exhibit E)

18. On May 1, 2019, I was present when Ambassador Vecchio delivered a speech in

Spanish in front of the Venezuelan Embassy. In that speech, Ambassador Vecchio stated that the

Venezuelan government considered the persons currently inside the Venezuelan Embassy to be

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occupiers or usurpers who were inside the Venezuelan Embassy unlawfully and without the

permission of the Venezuelan government. He further stated that it was the intention of the

Venezuelan government to retake possession of the Venezuelan Embassy from the occupiers and

to restore the Venezuelan Embassy’s functions for the people of Venezuela.

19. On May 8, 2019, Ambassador Vecchio sent a message from his official and verified

Twitter account, describing those persons living in the Venezuelan Embassy as “invaders” and

stating that the next step would be their exit from the Venezuelan Embassy. 5

20. On May 13, 2019, Ambassador Vecchio sent a message from his official and

verified Twitter account that displayed the May 13, 2019 Trespassing notices described below and

which stated, in part: #Now: Authorities notify the illegal invaders of our #Venezuelan Embassy

in #Washington that they must vacate diplomatic headquarters. 6

Diplomatic Security’s Protective Authorities

21. The Bureau of Diplomatic Security (“DS”) “is the security and law enforcement

arm of the U.S. Department of State.” U.S. DEP’T OF STATE, THE MISSION OF THE

BUREAU OF DIPLOMATIC SECURITY (Aug. 18, 2015), http://www.state.gov/m/ds/about/

overview/246177.htm. With more than 1,000 full-time law-enforcement officers with federal

arrest authority and “authorized . . . to carry firearms while on duty,” see Office of Justice

Programs, Federal Law Enforcement Officers, 2008, DEP’T OF JUSTICE 2, 10 (June 2012), the

principal function of DS is law enforcement. DS exercises this authority pursuant to the delegation

of the security functions of the Secretary of State. See 22 U.S.C. § 4802(a); Department of State

Delegation of Authority No. 214, dated October 4, 1994, 59 FR 50790. These security and

5
See https://twitter.com/carlosvecchio/status/1126285926668414976. Ambassador Vecchio’s Twitter
messages were issued in Spanish and translated here.
6
See https://twitter.com/carlosvecchio/status/1128068221947588608. Ambassador Vecchio’s Twitter
messages were issued in Spanish and translated here.

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protective functions of the Secretary of State enumerated under 22 U.S.C. 4802(a) include the

“protection of foreign missions, international organizations, and foreign officials and other foreign

persons in the United States,” and the “[c]onduct of investigations relating to protection of foreign

officials and diplomatic personnel and foreign missions in the United States.”

22. Further, Special Agents of the Department of State and the Foreign Service have

the authority to “protect and perform protective functions directly related to maintaining the

security and safety of . . . foreign missions (as defined in section 4302(a)(4) of this title) and

international organizations (as defined in section 4309(b) of this title), within the United States.”

22 U.S.C. 2709(a)(3).

Delivery of Trespassing Notice

23. On Monday, May 13, 2019, at 6:22 p.m., the DSS posted trespassing notices (the

“Trespassing Notices”) upon the property and building of the Venezuelan Embassy, located at

1099 30th Street NW, Washington, D.C., 20007. (Exhibit F)

24. Between 6:26 p.m. and 6:29 p.m., DSS Special Agents posted the Trespassing

Notices on the main door of the Venezuelan Embassy garage and aluminum roll-up door, on the

card reader/camera area of the ramp to the garage door, and on the second story courtyard door

and windows.

25. Between 6:34 p.m. and 6:40 p.m., DSS Special Agents posted additional

Trespassing Notices on the east and north side windows and on the front doors facing 30th street,

and west side of the Venezuelan Embassy and adjacent glass windows.

26. At 6:44 p.m., law enforcement on scene at the Venezuelan Embassy read the

Trespass Notice verbatim via loudspeaker.

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27. At 6:52 p.m., Medea Benjamin and another representative of Code Pink were hand

delivered Trespass Notices in person and verbally advised of the notice to vacate.

28. At 7:14 p.m., three occupants voluntarily departed the Venezuelan Embassy from

the side exit of the embassy (facing south), and DSS Special Agents escorted them to 29th Street,

NW, Washington, D.C.

29. At 8:05 p.m., law enforcement on scene at the Venezuelan Embassy read verbatim

the Trespass Notices verbally via loudspeaker. At the time of the reading, four occupants, later

identified as ZEESE, FLOWERS, PINE, and PAUL, remained in the Venezuelan Embassy and

refused to vacate the premises.

30. At 8:21 p.m., members of the Washington, D.C., Fire Department used hydraulic

bolt cutters to remove chain locks and a bicycle lock from the main entrance to the Venezuelan

Embassy on 30th Street. At the time of the lock removal, four occupants, later identified as

ZEESE, FLOWERS, PINE, and PAUL, were standing in the main lobby area of the Venezuelan

Embassy observing the process.

31. At 8:21 p.m., Special Agent-in-Charge (“SAC”) James Gottshall opened the

exterior front door to the Venezuelan Embassy and the interior lobby door. Special Agents

illuminated the lobby space with flashlights. Special Agent (“SA”) Bradley Gilmore identified

ZEESE and FLOWERS, and a third individual later identified as PINE, as being present in the

Venezuelan Embassy. A fourth individual, PAUL, was observed but not identified. SA Gilmore

read the Trespass Notice aloud to the four occupants—identified as ZEESE, FLOWERS, PINE,

and PAUL, who are the same individuals depicted in Exhibit A—who were standing in the

Venezuelan Embassy lobby approximately ten feet away. At the time of the reading, ZEESE,

began yelling at SA Gilmore, claiming that he was not trespassing. ZEESE stated that Ambassador

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Carlos Vecchio was a puppet of the U.S. government and that U.S. law enforcement did not have

the authority to enter the Venezuelan Embassy.

32. Between approximately 8:21 p.m., and 9:00 p.m., ZEESE, FLOWERS, PINE, and

PAUL, refused to depart the Venezuelan Embassy after multiple requests by SAC Gottshall. SA

Gilmore asked to hand-deliver paper copies of the Trespass Notices to the four occupants, and

ZEESE told SA Glimore to leave the Trespass Notices on the floor of the Venezuelan Embassy.

SA Gilmore left four copies of the notice on the floor just feet from the lobby entrance.

33. ZEESE, FLOWERS, PINE, and PAUL’s refusal to leave the Venezuelan Embassy

interfered with the Department of State’s protective service of maintaining the security of the

Venezuelan Embassy and the Permanent Mission of Venezuela to the Organization of American

States.

CONCLUSION

Based on the foregoing information, I respectfully submit that there is probable cause to

believe that between May 13, 2019, and May 15, 2019, ZEESE, FLOWERS, PINE, and PAUL

committed Interference with Certain Protective Functions, in violation of 18 U.S.C. § 118.

_____________________________
Bradley Gilmore
Special Agent
U.S. Department of State
Diplomatic Security Service

Subscribed and sworn before me this day of May 2019.

_____________________________
The Honorable G. Michael Harvey
United States Magistrate Judge

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Attachments

A) Photograph of remaining four trespassers at 1099 30th Street NW, Washington, DC

B) Notification of Carlos Vecchio’s Accreditation as Chargé d’Affaires of the Embassy of

Venezuela in the United States, dated January 24, 2019

C) Letter to President Donald J. Trump appointing Carlos Vecchio as Ambassador of the

Bolivarian Republic of Venezuela to the United States of America, dated January 29,
2019

D) Waiver of Inviolability from Ambassador Carlos Vecchio, dated April 26, 2019

E) Waiver of Inviolability from Ambassador Gustavo Tarre, dated April 26, 2019

F) Trespass Notice, May 13

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EXHIBIT
A
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EXHIBIT
B
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Caracas, 24 de enero de 2019

Yo, Juan Guaidó, Presidente Encargado de la República Bolivariana de Venezuela, acredito a el Sr.
Carlos Alfredo Vecchio como Encargado de Negocios de la Embajada de Venezuela en los Estados
Unidos. Como el representante del Gobierno de la República Bolivariana de Venezuela en Estados
Unidos, el Sr. Vecchio tiene la autoridad de tomar decisiones en nombre de Venezuela, incluyendo
proveer una certificación indicando quien es la persona con la autoridad plena para recibir, controlar, y
disponer de los activos del gobierno de Venezuela, incluyendo los del Banco Central de Venezuela.

Caracas, January 24th, 2019

OFFICIAL TRANSLATION

I, Juan Guaidó, interim President of the Bolivarian Republic of Venezuela, accredit Mr. Carlos Alfredo
Vecchio as Chargé d’Affaires of the Embassy of Venezuela in the United States. As the representative
of the Government of Venezuela in the United States, Mr. Vecchio has authority to take actions on
behalf of Venezuela, including to provide a certification indicating who is the person with the full
authority to receive, control, and dispose assets of the Government of Venezuela, including of the
Central Bank of Venezuela.

Juan Guaidó
Presidente de la Asamblea Nacional
Presidente (E) de la República Bolivariana de Venezuela
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EXHIBIT
C
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Caracas, January 29, 2019

The Honorable Donald J. Trump

President of the United States of America
The White House
1600 Pennsylvania Avenue, NW
Washington, DC 20500

Dear Mr. President,

To continue fostering the historical close relations that exist between the Bolivarian
Republic of Venezuela and the United States of America, exercising the powers I am vested in by
our Constitution and acting with the authorization of the National Assembly, I hereby appoint
Mr. Carlos Vecchio as Ambassador of the Bolivarian Republic of Venezuela to the United
States of America.

Mr. Carlos Vecchio has all the qualifications to fully comply with the important
mission that has been assigned to him. I trust that he will strengthen the ties that historically
link both countries in this momentous time.

The region recognizes the leadership that you and your Administration have shown to
promote a free and democratic Venezuela. I definitely believe that, without it, the humanitarian
crisis that we face would continue to deteriorate with no end in sight.

I ask you that, under the provisions of the Vienna Convention on Diplomatic Relations of
1961 and international laws in the matter, Mr. Carlos Vecchio be accepted as Chief of the
Diplomatic Mission of the Bolivarian Republic of Venezuela in the United States of America for
all purposes.
Sincerely yours,

Juan Guaidó
President National Assembly
President (I) of the Bolivarian Republic of Venezuela
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EXHIBIT
D
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EXHIBIT
E
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Scanned with CamScanner

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Scanned with CamScanner

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EXHIBIT
F
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Embassy and OAS Mission:

TRESPASSING NOTICE

This property, located at 1099 30th St NW, Washington, D.C. 20007, belongs to
the Bolivarian Republic of Venezuela (Venezuela), a foreign government.
Additionally, a portion of this property is utilized by Venezuela as its Permanent
Mission to the Organization of American States, an international
organization. This property is used for official business and diplomatic purposes.
The United States of America recognizes Ambassadors Vecchio and Tarre as the
representatives of Venezuela with lawful control over the property.

Accordingly, the United States recognizes these ambassadors as foreign officials

who are authorized to ask individuals to depart from this property and not return.
The United States does not recognize the authority of the former Maduro regime,
or any of its former representatives, to allow any individuals to lawfully enter,
remain on this property, or take any other action with respect to this property.

Ambassadors Vecchio and Tarre have requested and directed anyone who is
present on this property to depart from it immediately, and to not return without
these ambassadors’ express authorization. Additionally, individuals with law
enforcement powers are requesting and directing anyone who is on this property
to depart from it immediately, and have delivered this written notice of their
request while present on this property. Any person who refuses to comply with
these requests and orders to depart from this property will be trespassing in
violation of federal and District of Columbia law and may be arrested and
criminally prosecuted.

May 13, 2019