The FBI complaint filed yesterday, alleges Dennis Tadio Jr., 35, repeatedly threatened the witness Sunday morning at the Venus Night Club, calling the person "a rat" and warning, "you better watch your back. I'm gonna kill you."

Tadio also called the witness and left 12 harassing and threatening voicemail messages, the complaint said.

The complaint stated Tadio has a history of violent crime and his convictions include first-degree assault and terroristic threatening.

In 2003, Tadio was hired to provide security for illegal gambling businesses run by Joseph on Atkinson Drive and on Moanalua Road in Pearl City, the complaint said.

He is described as a "close associate" of Ethan Malu Motta. Tadio allegedly told federal agents he knew the person threatened was a witness in a federal case involving Joseph, Motta and eight others, according to the complaint.

Tadio was mad at the witness for calling police after the 2 a.m. confrontation at Venus Night Club, the complaint said.

Joseph, Motta and Kevin "Poncho" Gonsalves are charged in state court with murder in connection with the Jan. 7, 2004 shooting deaths of Lepo Ulu Taliese and Romilius Corpuz, and trying to murder Tinoimalu Sao at the Pali Golf Course.