Case 1:26-mj-00041-AJ Document 1 Filed 02/24/26 Page 1 of 1

AO 91 (Rev. 11/11) Criminal Complaint

UNITED STATES DISTRICT COURT

for the
District ofDistrict
__________ New Hampshire
of __________

United States of America )

v. )
) Case No.
BLU ZEKE DALY ) 1:26-mj- 41-01-AJ
a/k/a )
CULLAN ZEKE DALY )
)
Defendant(s)

CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
On or about the date(s) of February 22, 2026 in the county of Coos in the
District of New Hampshire , the defendant(s) violated:

Code Section Offense Description

18 U.S.C. § 1114(a)(3) - Attempted Murder of a Federal Officer

18 U.S.C. § 111(a) & (b) - Assaulting a Federal Officer with a Dangerous Weapon

This criminal complaint is based on these facts:

Please see the attached affidavit.

✔ Continued on the attached sheet.

u

/s/ Paul Mullen

Complainant’s signature

S.A. Paul Mullen, FBI

Printed name and title

7KHDIILDQWDSSHDUHGEHIRUHPHE\WHOHSKRQLFFRQIHUHQFHRQWKLVGDWHSXUVXDQWWR)HG5&ULP3DQGDIILUPHGXQGHU
RDWKWKHFRQWHQWRIWKLVFRPSODLQWDQGDIILGDYLW

Date: February 24, 2026

Judge’s signature

City and state: Concord, New Hampshire Hon. Andrea K. Johnstone, U.S. Magistrate Judge
Printed name and title
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AFFIDAVIT OF FBI SPECIAL AGENT PAUL MULLEN

I, Paul Mullen, being first duly sworn, hereby depose and state as follows:

INTRODUCTION

1. Since November 2008, I have been employed as a Special Agent of the Federal Bureau of

Investigation (“FBI”). I am currently assigned to the Boston Division, Hampton, New

Hampshire Resident Agency. I work criminal matters and primarily focus on violent crimes,

often in conjunction with other law enforcement officers from local, county, state, and federal

agencies throughout the state of New Hampshire and elsewhere. Prior to being a Special Agent

with the FBI I worked for approximately a year as a Trooper with the New Hampshire State

Police.

2. I have investigated both national security and criminal matters. I acquired experience in

these investigations through training at the FBI Academy in Quantico, Virginia, and by

conducting investigations in the field. I am also a trained member of the FBI Evidence Response

Team. My investigations have included the use of a variety of investigative techniques, including

but not limited to: subject, victim, and witness interviews; analysis of telephone and financial

records; physical surveillance; handling of cooperating sources and witnesses; exploitation of

cellular, social media, and Internet Protocol (“IP”) based communications data; execution of

search and seizure warrants; wire, electronic, and oral wiretaps; and the execution of arrest

warrants.

3. Based on the following information, there is probable cause to believe that BLU ZEKE

DALY, a/k/a CULLAN ZEKE DALY, has committed the offenses of Attempted Murder of a

Federal Officer in violation of 18 U.S.C. § 1114(a)(3) and Assaulting a Federal Officer with a

Dangerous Weapon in violation of 18 U.S.C. § 111(a) & (b).

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4. This affidavit is submitted for the limited purpose of establishing probable cause to

support the issuance of a complaint. Accordingly, while this affidavit contains all the material

information pertinent to the requested complaint, it does not include each and every fact known

to me or other law enforcement agents concerning this investigation.

5. The information contained in the Affidavit is based on my personal knowledge and

information provided by other FBI agents and U.S. Customs and Border Protection (“CBP”)

agents.

STATUTES

6. Title 18, U.S.C., Section 1114 provides, in relevant part:

(a) Whoever kills or attempts to kill any officer or employee of

the United States or of any agency in any branch of the
United States Government (including any member of the
uniformed services) while such officer or employee is
engaged in or on account of the performance of official
duties, or any person assisting such an officer or employee
in the performance of such duties or on account of that
assistance, shall be punished—

(3) in the case of attempted murder or manslaughter, as

provided in section 1113.

7. Title 18, U.S.C., Section 111 provides, in relevant part:

(a) Whoever

(1) forcibly assaults, resists, opposes, impedes, intimidates, or

interferes with any person designated in section 1114 of
this title while engaged in or on account of the performance
of official duties . . .

shall . . . where such acts involve physical contact with the victim
of that assault or the intent to commit another felony, be fined
under this title or imprisoned not more than 8 years, or both.

(b) Enhanced Penalty

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Whoever, in the commission of any acts described in subsection

(a), uses a deadly or dangerous weapon (including a weapon
intended to cause death or danger but that fails to do so by reason
of a defective component) or inflicts bodily injury, shall be fined
under this title or imprisoned not more than 20 years, or both.

FACTS

8. Officer 1 is a Border Patrol Agent with U.S. Customs and Border Protection (CBP). At

all relevant times, Officer 1 was on duty and patrolling the area near the border between the

United States and Canada.

9. At approximately 11:30 pm on February 21, 2026, Officer 1 encountered a gray 2012

Honda Civic, bearing New Hampshire registration 5639767 (the “SUBJECT VEHICLE”), in

Stewartstown, New Hampshire.

10. DALY was the driver and sole occupant of the SUBJECT VEHICLE.

11. DALY provided Officer 1 a New Hampshire driver’s license with an address of

Manchester, NH 03101.

12. The SUBJECT VEHICLE is registered to (DOB /2004), also

at , Manchester, NH 03101.

13. During the stop, Officer 1 asked whether DALY had used any other names.

14. DALY immediately drove away in the SUBJECT VEHICLE. Officer 1 followed the

SUBJECT VEHICLE at a distance.

15. Shortly after midnight on February 22, 2026, DALY drove the SUBJECT VEHICLE to

the Pittsburg Port of Entry located at 6293 North Main Street, Pittsburg, NH, and pulled the

SUBJECT VEHICLE up to the closed gate.

16. Officer 1 activated his emergency lights and exited his vehicle.

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17. DALY did not exit the SUBJECT VEHICLE and proceeded to attempt to turn around and

drive away.

18. DALY fired a handgun at Officer 1 as Daly was turning the SUBJECT VEHICLE.

19. Officer 1 returned fire with his service weapon. During the incident, Officer 1 shot

DALY. DALY lost control of the SUBJECT VEHICLE, which ran onto a snowbank near the

Pittsburg Port of Entry.

20. On February 22, 2026, the United States District Court for the District of New Hampshire

granted warrants to search, among other things, the SUBJECT VEHICLE.

21. A search of the SUBJECT VEHICLE recovered a Smith & Wesson SD9 2.0 handgun and

assorted ammunition.

22. A search of Officer 1’s vehicle recovered a round of expended ammunition that appears

to have been fired by Daly.

23. Based on the foregoing, there is probable cause to believe that BLU ZEKE DALY, a/k/a

CULLAN ZEKE DALY, has committed the offenses of Attempted Murder of a Federal Officer in

violation of 18 U.S.C. § 1114(a)(3) and Assaulting a Federal Officer with a Dangerous Weapon

in violation of 18 U.S.C. § 111(a) & (b).

/s/ Paul Mullen

Paul Mullen
FBI Special Agent

Sworn and subscribed to me, telephonically, this 24th day of February 2026, at Concord,
New Hampshire.

/s/ Andrea K. Johnstone

_____________________________
Hon. Andrea K. Johnstone
United States Magistrate Judge