COUNT ONE: On or about May 15, 2025, in the Eastern District of North Carolina, the defendant, JAMES BRIEN COMEY JR , did knowingly and willfully make a threat to take the life of, and to inflict bodily harm upon, the President of the United States, in that he publicly posted a photograph on the internet social media site Instagram which depicted seashells arranged in a pattern making out "86 47",which a reasonable recipient who is familiar with the circumstances would interpret as a serious expression of an intent to do harm to the President of the UnitedStates. In violation of Title 18, United States Code, Section 871(a).
COUNT TWO: On or about May 15, 2025, in the Eastern District of North Carolina, the defendant, JAMES BRIEN COMEY JR , knowingly and willfully did transmit in interstate and foreign commerce a communication that contained a threat to kill the President , Donald J. Trump , specifically, by publicly posting a photograph on the internet social media site Instagram which depicted seashells arranged in a patternmaking out "86 47 ", which a reasonable recipient who is familiar with the circumstances would interpret as a serious expression of an intent to do harm to President Trump. In violation of Title 18, United States Code, Section 875(c).