UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

CASE NO. 22-20449-CR-MOORE/LOUIS 

UNITED STATES OF AMERICA 

vs. 

MATTHEW LEON CHILCUTT, 

Defendant. 

I 

FACTUAL PROFFER 

The United States of America (the "United States") and Defendant MATTHEW LEON 

CHILCUTT (hereinafter referred to as "Defendant") agree that, were this case to proceed to trial, 

the United States would prove beyond a reasonable doubt the following facts, among others, which 

occurred in the Southern District of Florida: 

1. The premises located at 299 East Broward Boulevard, Fort Lauderdale, Florida 

(hereinafter, the "Premises"), including the U.S. Federal Building and Courthouse located thereon 

(hereinafter, the "Courthouse"), is property of the United States. 

2. On September 5, 2022, the Courthouse was closed in observance of the Labor Day 

federal holiday, and all public entrances to Courthouse were locked. On that day, at 

approximately 9:03 a.m., Defendant forced his way into the Courthouse by physically pulling and 

forcibly opening the locked doors at the main entrance of the Courthouse. Defendant's forcible 

entry into the Courthouse was captured on surveillance video at the Courthouse. 

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3. While on the Premises, Defendant willfully injured and committed a depredation 

against United States property, including smashing glass windows; breaking and destroying 

interior and exterior doors; causing water damage; and breaking and destroying other United States 

property located on the Premises within the interior and exterior of the Courthouse. Surveillance 

video at the Courthouse recorded Defendant damaging and destroying United States property, 

including smashing glass and other objects. 

4. While Defendant was on the Premises, private security personnel assigned to the 

Courthouse observed, by physical inspection and viewing of surveillance video, damage to the 

interior and exterior of the Courthouse, including broken glass. The private security personnel 

observed Defendant inside the Courthouse, made contact with Defendant inside the Courthouse, 

and called 911. 

5. At approximately 10:00 a.m., law enforcement officers with the Fort Lauderdale 

Police Department ("FLPD") arrived at the Premises and entered the Courthouse. While 

searching the Courthouse, FLPD officers found Defendant inside the Courthouse and arrested him. 

FLPD officers observed small cuts on Defendant's back, consistent with the broken glass .found 

throughout the Courthouse. 

6. Following Defendant's arrest by FLPD, law enforcement performed a protective 

sweep of the interior and exterior of the Courthouse, including the use of canine units, and found 

no other unauthorized persons on the Premises. 

7. While in custody, Defendant was advised of his Miranda rights, waived his right to 

remain silent, and made statements in response to questions from law enforcement establishing 

that Defendant had caused the damage to the Courthouse and that Defendant had acted alone. 

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8. As a result of Defendant willfully injuring and committing a depredation against 

the Courthouse on September 5, 2022, Defendant caused damage to United States property in the 

approximate amount of $71,933.20. 

9. The United States would prove the facts set forth in this proffer, among others, with 

documentary and testimonial evidence admissible at trial under the Federal Rules of Evidence, 

including, but not limited to: surveillance video footage from the Courthouse; FLPD body worn 

Camera video and audio recording of Defendant's arrest inside the Courthouse, including 

Defendant's spontaneous statements; crime scene photographs at the Courthouse; testimony of law 

enforcement officers, including FLPD responding officers, FLPD detectives, and special agents 

and officers of the Federal Protective Service of the U.S. Department of Homeland Security; 

Defendant's post-Miranda recorded statements; 911 calls and radio traffic; Defendant's social 

media postings; and testimony of witnesses from the General Services Administration (GSA) and 

GSA records. 

[Remainder of Page Intentionally Blank] 

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10. The United States and Defendant agree that these facts, which do not include all 

facts known to the United States and Defendant, are sufficient to prove beyond a reasonable doubt 

the elements of depredation against any property of the United States, causing damage exceeding 

$1 ,000, in violation of Title 18, United States Code, Section 1361 , and that Defendant is in fact 

guilty of that offense as charged in the Indictment in this case. 

Date: By: 

Date: 

Date: 

MARKENZY LAPOINTE 

u~=:;: __ 

D~G-7" 

ASSISTANT UNITED STATES ATTORNEY 

BUNMILOMAX 

ASSIST ANT FEDERAL PUBLIC DEFENDER 

ATTORNEY FOR DEFENDANT 

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