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ler
AO 91 (Rev< 5185) Criminal Complaint
United States District Court
NORTHERN DISTRlCT OF GEORGIA
UNITED STATES OF AMERICA
v. CRIMINAL C O M P ~ r'Ltfj IN CLERK'S OFFICE
FREDERlCK W. THOMAS CASE NUMBER: 2: I 1-J'tiBf Gainesville
(UNDER SEAL)NOV 01 2011
(Name and Address of Defendant) B
I, the undersigned complainant being duly sworn state the following is true and correct to the best of my knowledge and belief
Beginning on date unknown, and continuing until on or about November 1,2011, in White and Stephens Counties, Georgia and
elsewhere, in the Northern District ofGeorgia defendant did,
combine, conspire, confederate, agree and have a tacit understanding with Emory Dan Roberts and others known and unknown, to
knowingly receive and possess firearms, specifically, a destructive device and a silencer not registered to them in the National
Firearms Registration and Transfer Record in violation of Title 26, United States Code, 5861(d) and 5871
in violation ofTitle 1Ji United States Code, Section(s) 371.
I further state that I am a Special Agent of Federal Bureau ofInvestigation and that this complaint is based on the following facts:
See attached affidavit.
Continued on the attached sheet and made a part hereof
David W. Wylie
Based upon this complaint, this Court finds that there is probable cause to believe that an offense has been committed and that
the defendant has committed it. Sworn to before me, and subscribed in my presence
"-N,.,,0'-'-v=em=be"'r'-'I"",..::2""O...o.I-=-I____________ at Gainesville, Georgia
Date City and State
SUSAN S. COLE
United States Magistrate Judge
Name and Title of Judicial Officer Signature of Judicial OfficerAUSA Jeffrey A. Brown
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AFFIDAVIT
II David Wyl being f i r s t duly sworn I do hereby depose
and Sta te :
1 . I am a Special Agent with the Fede Bureau of
Invest iga t ion (FBI) and have been so employed fo r approximately
twenty f ive years . I am current ly assigned to the FBI 's
off ice in Gainesvi l Georgia. My inves t iga t ive responsibi l i ty
includes inves t iga t ing di f fe ren t federa l crimes such as bank
robberyI
bank fraud mortgage fraud and domestic t e rror i sm. I
have been involved in inves t iga t ions re la t ing to domestic
t e rror i sm and have part ic ipated in the execut ion of search
warrants and se ized evidence tha t re la tes to vio la t ions of
domestic t e rror i sm s ta tu tes . I know the following principal ly
based on information obtained from my inves t iga t ion and from
other la w enforcement of f i ce r s .
2. As a federa l agent I am authorized to inves t iga te
v io la t ions laws of the United States and to execute warrants
issued under the author i ty of the United Sta tes .
3. This af f idav i t i s in support of a request fo r a federa l
search warrant to be served upon and executed a t the residence
of Frederick W. Thomas 2265 Dean Mountain Road Cleveland l
Georgia 30528 1 more ful ly descr ibed as a two s tory s ingle
1
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family residence with a basement located wi th in White County.
The exter ior i s brown plank s id ing . The proper ty consis t s of
tw o acres which includes the main residence and an outbui ld ing
separa ted from the main residence. The proper ty i s recorded on
the White County tax map as parcel number 088 091; to search fo r
evidence, contraband and f ru i t s of a crime as se t for th in
Exhibi t B (a t tached hereunto and express ly incorpora ted herein
by th i s reference) , as well as any vehic les located on the
proper ty and any out bui ld ings located on the proper t i e s . I am
also reques t ing author i ty to search the proper t i e s referenced in
paragraph 3 and any computers, and computer media located
there in where the i tems speci f ied in Attachment B may be found,
and to se ize a l l i tems l i s t ed in Attachment B as
ins t rumenta l i t i e s , f ru i t s , and evidence of a conspiracy to
possess an unregis tered s i lence r and dest ruct ive device in
v io la t ion of Ti t le 26, United States Code, Sect ions 5861 (d) ,
5871, a l l in v io la t ion of Ti t l e 18, United States Code, Sect ion
371, Conspiracy to murder federa l of f i a ls in vio la t ion of
Ti t l e 18, United States Code, Sect ion 1117, Theft of Government
Property and Ti t l e 18, United States Code, Sect ion 641.
4. This a f f i dav i t i s also being submitted for the purpose
of secur ing a complaint and warrant fo r the a r r e s t s of Freder ick
W. Thornag (THOMAS) for conspiring to posseBs an unregiBtered
2
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s i l e n c e r and des t ruc t ive device i n v io l a t i o n o f Ti t l e 26 United
S t a t e Code, Sect ions 5861 (d) I 5871 1 a l l in v io l a t i o n o f Ti t l e
18 1 United S t a t e Code, Sect ion 371. I have not inc luded each
and every known f a c t concerning t h i s i n v e s t i g a t i o n ; r a th e r , I
have se t fo r th only th e f ac t s bel ieved necessary to e s t a b l i sh
probab le cause fo r the i s suance o f th e r eq u es t ed s ea rch warran t
compla int and a r r e s t warran t . However I even though I have not
inc luded every f a c t known to date in t h i s i n v e s t i g a t i o n , I do
not b e l i ev e anything has been omi t ted which would v i t i a t e th e
probab le cause s e t fo r th h e re i n .
BACKGROUND OF THE INVESTIGATION
5 . On March 17, 2011 1 th e government ' s c o n f i d e n t i a l human
source (CHS1) consensual ly recorded a c l an d es t i n e meet ing
invo lv ing members o f a f r inge group of a known m i l i ti a
o rg an i za t i o n l with the f r inge group c a l l i n g i t s e l f th e "co v er t
group. II The meet ing occur red a t th e r e s id en ce o f F red e r i ck W.
Thomas (THOMAS) l o ca t ed a t 2265 Dean Mountain Road, Cleveland,
Georg ia , 30528 1 and a t t endees a t th e meet ing inc luded THOMAS I
Emory Dan Rober ts (ROBERTS), and othe rs . At th e o u t s e t o f t h i s
meet ing, th e a t t en d ees began discuss ing and then disp lay ing
var ious weapons each one was car ry ing on h is person . THOMAS
mentioned to th e group t h a t he had enough weapons to arm
everyone a t th e t a b l e . ROBERTS and CHSl e i t h e r d id no t have
3
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weapons, o r did not make them vis ib le .
6. THOMAS became the primary speaker for the meeting and
began discussing overt and covert operat ions fo r the group. He
mentioned a f i c t iona l novel he had read on-l ine in which an ant i
government group ki l led a l a rge number of federa l Department of
Jus t ice at torneys , and then he s ta ted , "Now of course, t ha t ' s
jus t f i c t ion , but t ha t ' s a damn good idea . 1I THOMAS descr ibed a
scenar io in which he f e l t would be the " l ine in the sand" tha t
would resu l t in the act iva t ion of mil i t i a s . THOMAS bel ieved tha t
soon, during a pro t e s t act ion , a protes tor would be shot . I t i s
h is opinion the mil i t i as would ac t and respond by openly
at tacking the pol ice . He then openly discussed having compiled
what he ca l led the IIBucket Lis t l which i s a l i s t of government
employees, pol i t i c ians , corporate leaders and members of the
media he fee ls needed to be "taken out II to "make the country
r i gh t again ." THOMAS to ld the group he sen t the l i s t to a web
blog .
7. During the meeting, THOMAS made the fol lowing
statements:
a. "The r i gh t people have to be taken down, and taken
down soon."
b. "There i s no way for us, as mil i t iamen, to save
th i s country, to save Georgia, without doing something
4
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t ha t ' s highly highly i l l e g a l . Murder. That ' s fucking
i l l ega l , but it's go t t a be done."
c . "When it comes t ime to saving the Cons t i tu t ion ,
t ha t means some people go t t a d ie . "
8. When murder was mentioned, ROBERTS sa id he knew people
in Habersham County [Georgia] who had a substance tha t could k i l l
people with a very small amount. CHS1 suggested ROBERTS was
t a lk ing about r i c i n , and someone e l se agreed, adding t ha t r i c in
i s made from cas to r beans . The conversa t ion then went in to a
discuss ion about cas to r beans and poss ib le ways to obta in them.
9. THOMAS spoke of the need for the group to acqui re more
weapons, ammo, food, and survival gear and then discussed the
need fo r th e group to es tab l i sh a s i l en t means of taking people
ou t . THOMAS suggested s i l encers fo r handguns, s t a t i ng , "In orde r
to do what we want to do, t ake out the r i g h t people , we have to
have some s i l e n t means of doing it. That means suppressors on
handguns."
10. THOMAS s ta ted they needed to f ind a machinist wi th the
a b i l i t y to manufacture s i l encers and not r e g i s t e r them with the
ATF. THOMAS sa id t h i s was necessary to prevent them from being
t raced back to an owner i f they were l o s t .THOMAS
also mentioned
a gun s to re near the Georgia/South caro l ina border t ha t
manufactures s i l encers and he commented tha t they should consider
5
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"hi t t ing the t ruck ," meaning they should s t ea l the s i lence rs from
the t rucks .
11. On Apr i l 3, 2011, CHSI consensual ly recorded a meeting
with THOMAS and ROBERTS a t a res t au ran t in nor theas t Georgia. The
at tendees ta lked about acqui r ing ammunition and equipment,
par t i cu l a r l y s i lence rs fo r f i rearms. THOMAS suggested tha t they
buy, s t ea l , make, or at tack a manufac turer ' s t ruck in order to
obta in the s i lence rs . THOMAS also ta lked again about h is "Bucket
Lis t" of people he thought should be ki l l ed . During the meeting,
THOMAS s ta ted tha t he thought they could " f igh t off a SWAT team."
He also s ta ted , " I ' ve been to war, and I ' ve taken l i f e before ,
and I can do it aga in ."
12. On Apr i l 16, 2011, CHSI consensual ly recorded another
meeting of the "covert group, /I again a t the residence of THOMAS
located a t 2265 Dean Mountain Road, Cleveland, Georgia, 30528.
Attendees included CHSl, THOMAS, ROBERTS and others . During the
meeting THOMAS discussed the need fo r the group to s t a r t moving
forward with taking act ion in some of t h e i r previous ly discussed
plans , inc luding a number of assass inat ions on var ious government
of f ic ia l s .
13. THOMAS also explained to the others present tha t he
in tended to model t he i r act ions on the p lo t of an onl ine novel
ca l l ed Absolved. The p lo t of Absolved involves small groups of
6
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c i t i z e n s a t t ack ing United Sta te s f ed e ra l law enforcement
r e p re s e n t a t i v e s and f ed e ra l judges . THOMAS expressed h is b e l i e f
t h a t they should conduct a number o f a s s a s s i n a t i o n s on var ious
government o f f i c i a l s , and he p a r t i c u l a r l y expressed a d e s i r e to
k i l l Department o f J u s t i c e (DOJ) and In t e rn a l Revenue Serv ice
(IRS) employees.
14. During th e meet ing, THOMAS made th e fol lowing
s ta tements :
a . "Civ i l i an government o p e ra t i v es i s who we ' re going to be
shoo t ing a t : IRS, ATF, FBI, and th e COpS."
b. "Who i s th e primary t op ic s , t a rg e t s ? DOJ. Everybody in
DOJ. That inc ludes j udges , ATF, IRS, and th e hierarchy
t he reof . II
c . " I could shoot ATF and IRS a l l day l ong . A ll the judges
and th e DOJ and t h e a t t o rn ey s and p ro secu t o r s . II
15. On Ap r i l 29, 2011 and Ap r i l 30, 2011, CHS1 consensual ly
recorded co n v ersa t io n s between, CHS1, THOMAS and ROBERTS while
t r ave l ing to and from a meet ing held in south Georgia on
04/30/2011. During a conversa t ion on A p r i l 30, 2011, THOMAS
ment ioned t h a t , while a t th e meet ing, he spoke to a second
c o n f i d e n t i a l source (CHS2) about acqu i r ing s i l en ce r s . THOMAS
r e i t e r a t e d th e need fo r th e group to o b t a i n s i l en ce r s to shoo t
people q u ie t l y . THOMAS sugges ted they o b t a i n u n reg i s t e r ed , .22
7
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ca l iber long r i f l e s , cut them down and thread them to accommodate
a s i lence r . During the r ide , THOMAS asked ROBERTS whether he
(ROBERTS) thought they should t ry to grow t he i r group la rger , "or
s t ick to what we are planning on, assass inat ing 4 or 5 guys and
t ha t ' s i t ?" ROBERTS rep l ied , "I think probably we need both."
16. On May 17, 2011, CHS1 met with THOMAS and ROBERTS to
fur the r discuss the group 's plans. (This meeting was not
recorded. ) CHS1 reported tha t THOMAS indicated the group was
ready to move forward with acquir ing s i lence rs . At some poin t in
the conversat ion, explosives were mentioned and THOMAS became
very exci ted and sa id the group rea l ly needed to get some
explosives. THOMAS mentioned tha t he i s very disgrunt led with
the IRS and the Bureau of Alcohol Tobacco and Firearms (ATF).
THOMAS ind ica ted tha t he was consider ing driving to the Atlanta
area to survey/ locate IRS and ATF bui ld ings .
17. ROBERTS mentioned he had recent ly been ta lking to an
individua l in Stephens County [Georgia], he descr ibed as a nloose
cannon, n who has manufactured r i c in . ROBERTS sa id tha t he had
personal ly seen the r i c in in powder form.
18. On May 21, 2011, CHS1 reported tha t THOMAS was
scheduling a t r ip to Atlan ta to conduct survei l lance on the IRS
and ATF bui ld ings on May 24, 2011. THOMAS invi ted ROBERTS and
CHS1 to r ide with him during the survei l lance .
8
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19. On May 24, 2011, THOMAS and CHS1 drove to Atlanta in
THOMAS's 2006 Red GMC Canyon Pickup Truck, l i cense pla te Georgia
BMB 0821. CHS1 consensual ly recorded the t r i p . THOMAS and CHS1
planned and conducted survei l lance on the ATF (2600 Century
Parkway, Atlanta, Georgia 30345) and the IRS (401 West Peachtree
St ree t NW, Atlanta, Georgia 30308) bui ld ings to plan and assess
fo r poss ib le at tacks .
While dr iv ing , THOMAS discussed with CHS1 the types of weapons
they wanted to acquire i l l ega l ly . While driv ing home a f t e r
conducting the reconnaissance, THOMAS and CHS1 discussed how to
conduct fur the r survei l lance ins ide and how to a t tack the
bui ld ings with explosives .
20. During the t r ip to Atlanta , THOMAS made the following
s tatements :
a. "Let ' s shoot the bas tards tha t we discover are ant i
American
or enemies of America, t reasonous. And to me the eas i e s t and
bes t way to do tha t i s to walk up behind them with a suppressed
.22. I am of the, uh, o ld school , Mafia; one behind the ear with
a .2 2 i s a l l you need.
b. "Of course a .40 Smith and Wesson or .45 ACP i s jus t as
good, even be t t e r , cause makes the whole head explode."
c. "Now of course this t r ip is reconnoitering. There's two
9
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schools of thought on t h i s : go fo r the feds o r go fo r the locals_
And 11m inc l ined to consider both_II
d. "Weld have to blow the whole bui ld ing l l ike Timothy
McVeigh. II
e . " If we were gonna blow the bui ld ings would be smart
to h i t 'em both a t the same t ime_II
f . "Plant the explos ive r igh t up agains t the wall a
shaped charge. We can do it. OkaYI l e t / s do it then.1I
g. "We can so do our own homework on making from scra tch l
I Iortars what the he l l / s t ha t claymores and grenades. 1I
l
h. "We/ve got ta have a lo t of explos ives . 1I
21. On Apri l 30 1 2011 1 CHS2 consensual ly recorded a meeting
with THOMAS a t a r e s t s top near Macon, Georgia. THOMAS expressed
an i n t e re s t in acqui r ing weapons s i l encers and explosives from
CHS2 1 and he provided CHS2 with a handwri t t en list of 28 i tems he
would l ike to acquire fo r the cover t group. The l i s t consis t s of
f i rearms s i lence rs , and explos ives . THOMAS was under the
impression t ha t CHS2 could obta in the i tems fo r the group.
THOMAS informed CHS2 t ha t the covert group was looking fo r ways
to conduct assass ina t ions .
22. On June 9, 2011 1 an undercover employee (UCE)
consensual ly recorded a meeting with THOMAS and ROBERTS a t a
res t au ran t in Lavonia Georgia. (The UCE had been in t roduced to
10
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THOMAS by CHS2 as an acquaintance who deals in blac::k market
weapons.) During the meeting, THOMAS to ld the UCE t ha t the group
would l ike to purchase s i lence rs and explosives from the UCE. The
UCE advised tha t he could probably obta in the requested mater ia l s
fo r them. THOMAS explained to the UCE tha t the "covert group II
was planning to carry out the act ions of the main characters from
the book Absolved. THOMAS to ld the UCE tha t he considered
himself to be expendable a t h is age, and was prepared to d ie i f
necessary. Both THOMAS and ROBERTS to ld the UCE tha t they have
speci f ic t a rge t s in mind. THOMAS added t ha t they had al ready
conducted survei l lance in support of t h e i r plan . THOMAS
discussed the manufacture of shape charges and e lec t ron ic
detonators , saying, "I can make a detonator , e lec t ronica l ly . I
At one po in t during the meeting, THOMAS also s ta ted "We know what
we wanna do. We know how to do it. But we need (unin te l l ig ib le)
prepared to do i t , so t ha t ' s what we're doing now . . . Making the
preparat ions , ge t t ing what we need so tha t when we go about doing
it, we are equipped. Don' t know when t ha t ' s gonna be i wi th in a
year I 'm sure ." Later in the meeting the UCE asks about t he i r
proposed t ime fo r acquir ing explosives and s i lence rs being
about a year, and ROBERTS responds, "a little l ess . "
23. THOMAS so made the fol lowing s ta tements during the
described meeting:
11
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a. "Yea, uh, claymore mines, we can make these th ings, but
I 'd
ra ther have s tore bought, a rea l one."
b. "I could go to the guy 's house, I could f ind h is house,
okay, and shoot him in his back yard, as fa r as tha t goes."
c. "We need to place wi th in an ATF o r DEA big black van.
When they f i l l up the i r people, we're gonna take 'em a l l out a t
once."
d. "I a i n ' t worried about dying."
24. On June 24, 2011, CHS1 consensual ly recorded a meeting
with THOMAS and ROBERTS northeast Georgia to discuss br inging
another indiv idual in to the cover t group. During the meeting,
THOMAS t a lks about having "reconnoitered" government bui ld ings in
Atlanta. THOMAS then says, "And uh, they ' re surrounded by off i ce
bui ld ings . Now tha t doesn ' t mean we can ' t get a t the bui ld ing .
We can blow the bui ld ings up. It's doable. But uh, it also
means t ha t i f you're s ta t ioned somewhere in another building
nearby, or on, not on a roof , but ins ide , you can take out
se lec ted people with a sn iper r i f l e and suppressor ."
25. On June 28, 2011, CHS2 made a consensual ly recorded
phone ca l l to THOMAS. THOMAS expressed i n t e r e s t in obtaining
weapons and equipment for the "cover t group" from the UCE.
THOMAS s ta ted tha t he and the othe r members of the group have
12
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begun physica l t r a in ing and f i tness to prepare fo r the physical
demands tha t t he i r plans may requi re .
26. On July 13 1 2011, UeE placed a consensual ly recorded
ca l l to THOMAS. THOMAS informed the ueE tha t the "covert groupl l
was still in te res ted in obta ining handgun and f Ie s i lencers
s ta t ing , "We still need a couple of the , urn, noise cancel lers
and we're gonna decide how we're gonna pay for t ha t so wei l l be
back to you on tha t . II THOMAS and the ueE discussed poss ib le
opt ions to bar t e r fo r the i tems tha t THOMAS would l ike to acqui re
from the ueE. Options discussed were THOMAS t rad ing homemade
bomb detona tors and unregis tered handguns t ha t he owns.
27. On July 16 1 2011 1 THOMAS rep l i ed v ia email to a July
IS , 2011 email tha t had been sent to THOMAS by the ueE. The
or ig ina t ing email from the ueE included two at tached videos , the
f i r s t video was for ty (40) seconds and the second was f i f t y - f ive
(55) seconds. The at tached videos displayed a cont ro l led
explosion t ha t was conducted under the supervis ion of an FBI
Spec Agent Bomb Technician (SABT) , and showed the detona t ion
o f an FBI SABT-built improvised explosive device. The ueE to ld
THOMAS t ha t the video was of th e type of product the ueE could
ge t fo r THOMAS. THOMAS sent the fol lowing response from h is
email account([email protected]) :
"Wonderful. Imagine! I used to do that for a l iving, and never
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thought to put any aside. Helluva 'n e f fec t for so small a
package! In teres ted? You bet !!! 1111 show th i s to Cobra
(ROBERTS) 1 and then wei l l work out what we might be able to swap
for some. Thanks! II
28. During the course of the ins tan t inves t iga t ion CHS1,
CHS2 and VCE communicated with THOMAS v ia e-mai l . On April 41
2011, agents received records showing there was a Windstream
communications account a t THOMAS/s res idence l i s t ed in paragraph
3 in the name of Charlot te J . Thomas. Agents also learned tha t
THOMAS/s e-mail address([email protected]) i s associa ted
with the telephone b i l l associated with THOMAS/s res idence
located a t 2265 Dean Mountain Road Cleveland, Georgia 30528.
Also CHS1 reported tha t he observed a computer a t THOMAS/s
res idence while at tending the meeting on March 17, 2011 and a t
h is l a s t v i s i t to the res idence on August 20 1 2011. 29.
During the course of the inves t iga t ion of ROBERTS, THOMAS and
others af f i l i a t ed with the "cover t group," they have communicated
with each other ut i l iz ing emai l t ex t messaging and ce l lu l a r
te lephones for purposes of fur ther ing the i r agenda as out l ined in
th i s af f idav i t . Several of the emails exchanged between THOMAS
([email protected] , [email protected] ROBERTS
([email protected] ) and CHS1 discuss meeting places and
t imes, t ra ining agendas, equipment needs and other issues
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per t inent to achieving the goals of both t he i r over t and cover t
mission. Fur ther , during the course of the i nves t iga t ion , THOMAS
has emailed CHS1 hundreds of open source a r t i c le s he obtained
from the in te rne t . Some the recent e-mails from ROBERTS and
THOMAS include an e-mai l from l [email protected] on October
25 1 2011 1 in response to CHS1's e-mai l about whether ROBERTS had
everything he needed fo r the upcoming meeting t ha t was held on
October 29, 2011. On October 18, 2011, CHS1 received an e-mai l
from THOMAS using email address [email protected] concerning
THOMAS's reques t for ass i s tance with es tab l i sh ing a new mil i t i a
group.
30. On July 18, 2011, CHS2 placed a consensual ly recorded
c a l l to THOMAS. CHS2 asked THOMAS who was in charge of the
"cover t groupll and THOMAS aff i rmed tha t he was in charge. Later
in the ca l l THOMAS s ta ted , "Am I the guy t ha t ' s leading? Yes, I
am. II THOMAS also to ld CHS2 t ha t the "cover t groupll in tended to
meet with the UCE about acqui r ing Itsupplies" and to discuss
potent ia l pr ices , re fer r ing to t he i r des i re to obta in mil i ta ry
grade equipment and weapons.
31. On July 18, 2011 1 UCE placed a consensual ly recorded
ca l l to THOMAS. THOMAS mentioned the emailed videos of a
detonated explosive t ha t the UCE had sent to THOMAS, saying tha t
he had showed i t to Cobra (ROBERTS) and t ha t ROBERTS had sa id 1
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"Wow! II The UCE then asked " Is tha t what you guys are looking
for?U and THOMAS rep l ied , uYep, exact ly . U THOMAS discussed
t rad ing or bar ter ing some of h is unregis tered weapons fo r i tems
from the UCE. THOMAS also indica ted t ha t ROBERTS might have some
proper ty to swap fo r i tems from the UCE, ind ica t ing tha t he
(THOMAS) would l e t the UCE know about the poss ib le t rades "As
soon as I can get word from Cobra (ROBERTS) about what he wants
to swap. I had him put together a l i s t of what he ' s got so I can
g ive tha t to you, and then you can pick and choose. II THOMAS
reaff irmed his des i re to acqui re s i lence rs fo r 7.62 mil l imeter
r i f l e s . THOMAS to ld the UCE tha t the "cover t group" s t i l l had an
i n t e re s t in smal ler ca l iber s i lencers , but t ha t they were
pr io r i t i z ing the 7.62 r i f l e .
32. On August 1, 2011, CHS1 consensual ly recorded a meeting
with THOMAS, ROBERTS and another indiv idual in nor theas t Georgia.
They ta lked about acquir ing TNT and building t he i r own explosive
devices . They discussed var ious types of detonators , but seemed
to focus pr imar i ly on using pre-paid ce l l phones.
33. On August 13, 2011 CHS1 consensual ly recorded a meeting
with ROBERTS a t a res taurant in Cornel ia , Georgia. THOMAS was
supposed to a t tend , but jus t p r ior to the meeting, THOMAS cal led
to advise he would not be able to make i t . THOMAS s ta ted tha t
ROBERTS was fully briefed and could brief CHSI. At the meeting
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ROBERTS provided CHS1 with an ICOM two way radio for team
communications. ROBERTS al leged tha t the radios had been s tolen
from the United States Army in Afghanistan.
34. A visual inspect ion of the radio provided to CHS1 by
ROBERTS revealed the exter ior se r i a l numbers and i den t i f i e r s have
been del ibera te ly ob l i t e ra ted . Upon powering up the radio the
t ex t i den t i f i e r s assigned to the channels ind ica te mil i ta ry uni t
nomenclature. At th i s time ef for t s are underway to determine the
s ta tus of the radio v ia the assigned elec t ronic se r ia l number.
35. On August 20, 2011, CHS1 consensual ly recorded a
meeting with THOMAS and ROBERTS a t THOMAS's res idence. During
the meeting, THOMAS made the following sta tement: "We need high
explosives , not j u s t run of the mil l explosives . Because we have
to make, fabr ica te , any number of weapons types: claymores,
grenades, shaped charges, RPG rockets , or bazooka rockets tha t
are shaped charges."
36. On September 11, 2011, UCE placed a consensual ly
recorded ca l l to THOMAS. THOMAS ta lked about wanting a s i l encer
for a r i f l e . The UCE asked, "Is tha t something you plan on
using?" THOMAS repl ied, "Oh yea, oh yea. Defini te ly ."
37. On September 20, 2011, CHS1 consensual ly recorded a
meeting with THOMAS and the UCE a t a res taurant in Lavonia,
Georgia. Prior to the arrival of the UCE, THOMAS talked to CHSI
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about wanting a s i lence r , and he s ta ted , " l id love it fo r the M1A.
I f you ' re gonna use it as a sn iper r i f l e and actual ly k i l l
somebody, which I in tend to do, your bes t bet i s to clean the
weapon, u l t ra clean, load it with 5 rounds, put the suppressor on,
wipe it down clean, then put the rubber gloves on so when you pick
it up you a in / t l eavin ' pr i n t s . "
38. During the meeting with the UCE I THOMAS agreed to buy a
s i lence r and conversion par t s (to make a r i f l e fu l ly automatic)
from the UCE fo r himself in exchange fo r a gun t ha t he wil l t rade
to the UCE. THOMAS also agreed to purchase an explosive device
from the UCE fo r $1,000 with the cost being s p l i t between THOMAS I
ROBERTS and CHS1. THOMAS and the UCE agreed to conduct the
t ransac t ion in about 30 days from t he i r meeting.
39. Also during the meeting, the UCE asked THOMAS, "So you/re
more in te res ted in the o ther th ing ( referr ing to s i lencer) f irs t?/I
THOMAS rep l ied , "Yea, we have uhl a mission in mind l and I want to
get it carr ied out . /I The UCE also sa id to THOMAS, "I mean, you
obviously have a t a rge t because l ive t a lked to you about i t . "
THOMAS rep l i ed , "I do. 1I
40. On September 25, 2011, UCE placed a consensual ly recorded
ca l l to THOMAS. The conversat ion included the fol lowing:
UCE: "Now my quest ion i s , urn, as fa r as, I meanl potency I l ike
what do you, I mean do you want to take off a p i l l a r a t a bui ld ing ,
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a car , what?/I
THOMAS: "A car . "
DCE: "Okay, you want to be able to take a ca r off . /I
THOMAS: "Yea./I
VCE: "So something l ike you saw in tha t video i s gonna be good./I
THOMAS: "Oh yea. Perfect . / I
41. On October 15, 2011, CHSl consensual ly recorded a meeting
with THOMAS, ROBERTS and others a t 558 Lakeside Drive, Toccoa,
Georgia. CHSl met with THOMAS and ROBERTS to discuss th e purchase
of the explosive device from the DCE. The fol lowing conversa t ion
occurred:
CHSl : "You sent me an email, we pushed t h i s back to November
1s t, so we're good. Okay. A ll r igh t , I got , I got my money. You
got yours Dan?
(unin te l l ig ib le)
ROBERTS: "I'll be okay./I
CHS1: "Do you want me to br ing it to you?/I (d i rected to
THOMAS)
THOMAS: "Yea."
42. On October 18, 2011 CHSl corresponded v ia email with
THOMAS. In the email exchange it was decided t ha t THOMAS, ROBERTS
and CHSl wi l l meet l a t e r in the week to pool t he i r money together
to buy an explosive device from veE.
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43. On October 21, 2011, CHS1 met with THOMAS and ROBERTS a t
a
res t au ran t in Lavonia, Georgia. Before the a r r i va l of THOMAS,
ROBERTS expressed some concern about buying the explosive device
from the VCE because ROBERTS i s concerned the VCE could be a "cop",
but ROBERTS advised he i s still going through with the deal and
t ha t he would be with THOMAS a t the t ransact ion . Afte r THOMAS
arr ived and a f t e r they ate , CHS1 gave THOMAS h is share of the cos t
for the device being purchased. ROBERTS advised tha t he would ge t
h is share to THOMAS th i s week. ROBERTS also s ta ted tha t the next
group meeting on October 29, 2011 wi l l be a t h is res idence , which
i s located a t 1171 Jordan Road, Toccoa, Georgia, 30577.
44 . When THOMAS has driven to the var ious meetings descr ibed
in t h i s a f f i dav i t , he has usual ly driven h is 2006 Red GMC Canyon
Pickup Truck, l i cense p la t e Georgia BMB 0821 which i s reg i s t e red to
THOMAS a t h is residence located a t 2265 Dean Mountain Road,
Cleveland, Georgia.
Rel iab i l i ty o f the Sources of Information
45. During the course of the inves t iga t ion of ROBERTS, THOMAS
and others a f f i l i a t e d with the Covert Group, the FBI as ut i l i zed to
confident ia l human sources. The c red ib i l i t y of CHS1 and CHS2 has
been demonstrated by the sources ' accura te recount ing of the
conversat ions recorded during meetings with ROBERTS I THOMAS I when
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compared to the audio and video recordings of the meetings and
physica l survei l lance of those meetings conducted by law
enforcement agents. Law enforcement agents ass i s t i ng with the
ins tan t inves t iga t ion have l i s tened to and/or viewed consensually
recorded telephone ca l l s and video recordings.
46. CHS1 i s current ly on bond fo r pending felony s ta te
charges . The FBI adminis tered a polygraph t e s t to CHS1 during the
inves t iga t ion of a mil i t i a group. The FBI polygrapher determined
t ha t CHS1 gave l ess than t ru thfu l responses concerning the
ac t iv i t i e s of the mil i t i a group.
COMPUTERS, ELECTRONIC STORAGE, AND FORENSIC ANALYSIS
47. As descr ibed above and in Attachment B, t h i s appl ica t ion
seeks permission to search fo r records tha t might be found on the
PREMISES, in whatever form they are found. One form in which the
records might be found i s data s tored on a computer 's hard drive or
other storage media. Thus, the warrant appl ied for would author ize
the se izure of elec t ronic s torage media or, potent ia l ly , the
copying of e lec t ronica l ly s tored informat ion, a l l under Rule
41 (e) (2) (B ) .48. I submit tha t i f a computer or storage medium i s found a t
the residences l i s t ed in paragraph 3, there i s probable cause to
bel ieve those records wil l be s tored on tha t computer or storage
medium, fo r a t l ea s t the fol lowing reasons:
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a . Based on my knowledge, t r a in ing , and exper ience and
consul t a t ion with FBI forensic computer exper ts , I know
tha t computer f i l e s or remnants such f i l e s can be
recovered months or even years a f t e r they have been
downloaded onto a storage medium, dele ted , or viewed v ia
the In te rne t . Elect ronic f i l e s downloaded to a s torage
medium can be s tored fo r years a t little or no cost .
Even when f i l e s have been dele ted , they can be recovered
months or years l a t e r using forens ic too l s . This i s so
because when a person "dele tes ll a f i l e on a computer, the
data contained in the f i l e does not ac tua l ly disappear;
ra the r , t ha t data remains on the s torage medium un t i l it
i s overwri t ten by new data .
b . Therefore , eted f i l e s , or remnants of dele ted f i l e s ,
may res ide in f ree space o r s lack space- that i s , in space
on the s torage medium tha t i s not cur ren t ly being used by
an act ive f i l e - fo r long per iods of t ime before they are
overwr i t ten . In addi t ion , a computer ' s operat ing system
may also keep a record of dele ted data in a "swapll or
"recoveryll f i l e .
c . Wholly apar t from user-generated f i l e s , computer storage
media- in par t i cu lar , computers ' in te rna l hard dr ive s
contain e lec t ronic evidence of how a computer has been
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used, what it has been used for , and who has used it. To
give a few examples, th i s forens ic evidence can take the
form of operat ing system conf igurat ions , a r t i f a c t s from
opera t ing system or appl ica t ion opera t ion , f i l e system
data s t ruc tures , and v i r t ua l memory "swap" or paging
f i l e s . computer users typ ica l ly do not erase or dele te
th i s evidence, because specia l sof tware i s typ ica l ly
required for tha t t ask . However, it i s t echn ica l ly
poss ib le to dele te t h i s informat ion.
d. Similar ly , f i l e s tha t have been viewed v ia the In te rne t
are sometimes automat ica l ly downloaded in to a temporary
In te rne t d i rec to ry or "cache."
49. Forensic evidence. As fu r the r described in Attachment B,
t h i s appl ica t ion seeks permission to locate not only computer f i l e s
t ha t might serve as d i rec t evidence of the crimes described on the
warrant , but also fo r forensic e lec t ron ic evidence tha t es tab l i shes
how computers were used, the purpose of t h e i r use, who used them,
and when. There i s probable cause to bel ieve t ha t t h i s forens ic
elec t ronic evidence wil l be on any computer in the PREMISES
because:
a . Data on the storage medium can provide evidence of a f i l e
tha t was once on the storage medium but has s ince been
de le ted o r ed i ted , o r of a dele ted por t ion of a f i l e
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(such as a paragraph tha t has been dele ted from a word
processing f i l e ) . Vir tual memory paging systems can leave
t races of informat ion on the s torage medium tha t show
what t asks and processes were recent ly act ive . Web
browsers, e-mai l programs, and chat programs s tore
conf igurat ion informat ion on the storage medium tha t can
reveal informat ion such as online nicknames and
passwords. Operat ing systems can record addi t ional
informat ion, such as the at tachment of periphera ls , the
at tachment of USB f lash storage devices or o ther ex ternal
storage media, and the t imes the computer was in use.
Computer f i l e systems can record informat ion about the
dates f i l e s were created and the sequence in which they
were created .
b. Forensic evidence on a computer or s torage medium can
also indica te who has used or cont ro l led the computer or
s torage medium. This "user a t t r ibu t ion" evidence i s
analogous to the search fo r "indic of occupancy" while
execut ing a search warrant a t a res idence . For example,
reg i s t ry informat ion, configurat ion f i l e s , user pro f i l e s ,
e-mail , e-mail address books, "chat ," ins tan t messaging
1ogs , photographs, the presence o r absence of malware,
and correspondence (and the data associated with the
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foregoing, such as f i crea t ion and l as t -accessed dates)
may be evidence of who used or cont led the computer o r
s torage medium a t a re levant t ime.
c . A person with appropr ia te famil ty with how a computer
works can, a f t e r examining t h i s forens ic evidence in i t s
proper context , draw conc lus ions about how computers were
used, the purpose of t h e i r use , who used them, and when.
d . Th e process iden t i fy ing the exact f i l e s , blocks ,
r e g i s t ry e n t r i e s , logs , or o ther forms of forens ic
evidence on a s torage medium t h a t are necessary to draw
an accura te conclusion i s a dynamic process . While it i s
poss ib le to speci fy advance the records to be sought ,
computer evidence i s not always data tha t can be merely
reviewed by a review team and passed a long to
inves t iga to rs . Whether data s tored on a computer i s
evidence may depend on o ther informat ion s tored on the
computer and the app l ica t ion of knowledge about how a
computer behaves. Therefore , contextua l informat ion
necessary to understand o ther evidence also f a l l s within
the scope of the warrant .
e . Further , in f inding evidence of how a computer was used,
the purpose o f i t s use , who used it, and when, sometimes
it i s necessary to es tab l i sh tha t a par t i cu l a r thing i s
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not presen t on a s torage medium. For example, the
presence o r absence of counter - forens ic programs o r an t i
vi rus programs (and associa ted data) may be re levant to
es t ab l i sh ing the use r ' s in ten t .
50. Necessi ty of se iz ing or copying ent i re computers or
s torage media. In most cases, a thorough search of a premises fo r
informat ion t ha t might be s tored on s torage media often requires
the se izure of the physica l s torage media and l a t e r o f f - s i t e review
consis ten t with the warrant . In l i eu of removing s torage media
from the premises , it i s sometimes poss ib le to make an image copy
of s torage media. General ly speaking, imaging i s the taking of a
complete e lec t ron ic pic ture of the computer ' s datal including a l l
hidden sec to rs and dele ted f i l e s . Either se izure or imaging i s
often necessary to ensure the accuracy and completeness of data
recorded on the s torage media, and to prevent the loss of the data
e i the r from accidenta l or in ten t ional des t ruct ion . This i s t rue
because of the fol lowing:
a . The t ime required fo r an examination. As noted above, not
a l l evidence takes the form of documents and f i l e s tha t
can be eas i ly viewed on s i t e . Analyzing evidence of how
a computer has been used, what it has been used for , and
who has used it requires considerable t ime, and taking
tha t much time on premises could be unreasonable. As
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explained above, because the warrant ca l l s for forensic
elec t ronic evidence, it i s exceedingly l ike ly tha t it
wil l be necessary to thoroughly examine s torage media to
obtain evidence. Storage media can s tore a l a rge volume
of informat ion. Reviewing tha t informat ion fo r things
descr ibed in the warrant can take weeks or months,
depending on the volume of data s tored , and would be
imprac t ica l and invasive to attempt on-s i t e .
b. Technical requirements. computers can be configured in
severa l di f fe ren t ways, fea tur ing a var ie ty of di f fe ren t
opera t ing systems, appl ica t ion software , and
conf igurat ions . Therefore , searching them sometimes
requi res tools o r knowledge tha t might not be presen t on
the search s i t e . The vast a rray of computer hardware and
software avai lab le makes it d i f f i c u l t to know before a
search what too l s or knowledge wil l be requi red to
analyze the system and i t s data on the Premises.
However, taking the storage media of f - s i t e and reviewing
it in a cont ro l led environment wil l al low i t s examination
with the proper too ls and knowledge.
c . Var ie ty of forms of elec t ronic media. Records sought
under t h i s warrant could be s tored in a var ie ty of
storage media formats tha t may requi re o f f - s i t e reviewing
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with specia l ized forensic too l s .
51. Nature of examination. Based on the foregoing and
consis ten t with Rule 41(e) (2) (B) when persons executing the
warrant conclude tha t it would be impract ica l to review the media
on-s i t e l the warrant I am applying for would permit se iz ing or
imaging s torage media tha t reasonably appear to conta in some or a l l
of the evidence descr ibed in the warrant thus permit t ing i t s l a t e r
examination consis ten t with the warrant. The examination may
require techniques including but not l imi ted to computer-assis ted
scans of the ent i re mediuml
tha t might expose many par t s of a hard
d r i ve to human inspect ion in order to determine whether it i s
evidence descr ibed by the warrant.
CONCLUSION
52. Based on the aforementioned fac tual information l your
af f ian t re spec t fu l ly submits tha t tha t there i s probable cause to
bel ieve tha t there i s now concealed evidence as descr ibed in
de ta i l in Attachment BI of evidence of the commission of criminal
offenses namelYI vio la t ion of Ti t le 26, United Sta tes Code I
Sect ions 5861(d) I 5871 1 a l l in violat ion of Ti t le 181
United Sta tes
Code Sect ion 3711
Conspiracy to murder federa l of f ic ia l s in
vio la t ion of Ti t l e 18 1 United Sta tes Code Sect ion 1117 and Theft
of Government Proper ty and Ti t l e 18 1 United Sta tes Code Sect ion
641 is located in the residences more ful ly described in paragraph
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3, and t h i s evidence , l i s t ed in Attachment B to t h i s a f f i dav i t ,
which i s incorporated herein by re fe rence , i s contraband, the
f ru i t s of crime, or things otherwise cr iminal ly possessed, or
proper ty which i s or has been used as the means of committing the
foregoing offenses .
53. Based on the aforementioned f ac tua l informat ion, your
a f f i an t re spec t fu l ly submits tha t there i s probable cause to
bel ieve t ha t THOMAS and ROBERTS conspired to possess an
unregis tered s i lence r and dest ruct ive device in v io la t ion of Ti t l e
26, United State Code, Sect ions 5861(d), 5871, a l l in vio la t ion of
t I e 18, United State Code, Sect ion 371.
54. Final ly , because of the ongoing nature of the
i nves t iga t ion , and to ensure th e safe ty of the confident ia l source
and law enforcement off i cers involved, I reques t tha t the search
warrants , appl ica t ions , complaints , a r r e s t warrants and af f idavi t s
in support thereof , be SEALED un t i l fu r the r order of t h i s Court.
29
Case 2:11-mj-00102-SSC Document 1 Filed 11/01/11 Page 30 of 30