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AO 91 (Rev. 11/11) Criminal Complaint
UNITED STATES DISTRICT COURT
for the
United States of America,
Plaintiff
Vi
Mark Domingo,
Defendant
Central District of California loaari201 9
FILEDCLERK,U.S. DISTRICT COURT
CENTRALDISTRICT OF CALIFORNIA
BY: DEPUTY Case No. 2:4 9-MJ-01751-DUTY
CRIMINAL COMPLAINT
I, the complainantin this case, state that the following is true to the best of my knowledge andbelief.
Beginning on an unknowndate and continuing until April 26, 2019, in the county of Los Angeles in the Central
District of California, the defendantviolated:
Code Section
18 U.S.C. § 2339A
This criminal complaintis based onthese facts:
Please see attached affidavit.
Continued on the attached sheet.
Offense Description
Providing and Attempting to Provide
Material Support to Terrorists
Complainant's signature
Tasha Coolidge, Special Agent
Sworn to before me andhal in my presence.
Date: Y V] A
Cityand state: _Los Angeles, California
ry ted nameandtitle
& Wiiw—4 aa
{ Judge's signature
Hon. Michael R. Wilner, U.S. Magistrate JudgePrinted nameandtitle
AFFIDAVIT
I, Tasha Coolidge, being duly sworn,
follows:
I.
1. I am a Special Agent
Investigation (“FBI”), and have
2018. I am currently assigned
(“JTTE”) of the Los Angeles Fi¢
Special Agent, I was on active
Force Security Forces, serving
overall mission to deter, deted
terrorist activity. During thi
responsibilities such as, prote¢
dignitary support, anti-terrori
missions. ‘In total, I have bee
United States for nearly ten yé¢
gained a broad expertise coveri
enforcement, operational terronx
measures. Through the course
the FBI, I have used a variety
resources, including, surveilla
warrants, evidence seizures, an
familiar with strategy, tactics
techniques of criminals, terroy
my employment with the FBI, I a
Training at the FBI Academy in
received both formal and inform
declare and state as
INTRODUCTION
with the Federal Bureau of
been so employed since March
to the Joint Terrorism Task Force
id Division. Before becoming a
duty in the United States Air
eight years overseas, with an
t and mitigate criminal and
s time I had numerous
cting high-valued U.S. assets,
sm measures, and fly-away
n sworn to protect and serve the
I havears. During my career,
ng weapon systems, law
ist cells, and counter-insurgency
f my training and employment with
of investigative techniques and
nee, confidential sources, search
d telephone toll analysis. I am
methods, tradecraft, and’
ists, and their agents. During
attended 21 weeks of New Agent
Quantico, Virginia. I have
al training from the FBI
1
regarding criminal and countert
also attended training concerni
communications and computers in
II. PURPOSE
errorism investigations. I have
ng the use of electronic
n furtherance of crime.
OF THE AFFIDAVIT
2. This affidavit is suk
complaint charging defendant Ma
with Providing and Attempting {
Terrorists, in violation of Tit
(the “Subject Offense”) .1
IIIT. SUMMARY
3. In March and April 2¢
steps to manufacture and use a
order to commit mass murder. gd
purchased several hundred nails
explosive device, and provided
DOMINGO believed to be a collak
undercover law enforcement offi
for the purpose of having the U
destruction for DOMINGO to use
adiscussed below, on April 26, Z
inspected the items DOMINGO bel
destruction (but unbeknownst tc
finalized plans to commit the 4
1 Title 18, United Statesunlawful to provide or attempt
resources, knowing or intendingpreparation for, or in carryingspecified offenses, including TSection 2332a (Use of a Weapon
mitted in support of a criminal
rk Steven Domingo (“DOMINGO”)
o Provide Material Support to
le 18, United States Code, 2339A
OF PROBABLE CAUSE
19, DOMINGO planned and took
weapon of mass destruction in
m April 23 and 24, 2019, DOMINGO
to be used as shrapnel inside an
the nails to a person whom
orator, but who was in fact an
cer (“UC”) working for the FBI,
C manufacture weapons of mass
in an upcoming attack. As
019, DOMINGO met the UC,
lieved were weapons of mass
him were actually inert), and
ttack on Sunday April 28, 2019.
Code, Section 2339A, makes itto provide material support orthat they are to be used inout, a violation of certain
itle 18, United States Code,
of Mass Destruction).
2
Iv. STATEMENT OF PROBABLE CAUSE
4, The facts set forth |
part on: information provided t
officers; law enforcement repor
witnesses; my personal observat
training, and background as an
affidavit is intended to show 4
probable cause for the requesteé
search warrants, and does not 4
knowledge of or investigation ]j
specifically indicated otherwis
statements described in this af
and in part only with quoted la
only, and all dates and times a
A.
Committing a Large-Scale 7
5. According to reports
employee (“OCE”), in March 2019
online platform (hereinafter Ug
On March 2,group. 2019, USERN
which he introduced himself as
shahada.?
6. FBI Agents reviewed J
Motor Vehicles records, and saw
appeared to be DOMINGO. FBI Aq
2 Based on my training andshahada is the profession of fa“There is no god but Allah, and
Allah.”
n this affidavit are based in
o me by other law enforcement
ts; information obtained from
ions; and my experience,
FBI Special Agent. This
exely that there is sufficient
d complaint, arrest warrant, and
urport to set forth all of my
nto this matter. Unless
e, all conversations and
fidavit are related in substance
nguage appearing in draft form
re approximate.
DOMINGO Posts About His Support for Violent Jihad anderrorist Attack
provided by an FBI online covert
, the OCE identified a user of an
ERNAME 1) in a private message
AME 1 posted a link to a video in
“o“Mark Domingo,” and declared the
OMINGO’s California Department of
that the person in the video
ents also reviewed records
experience, I am aware that theith and the first tenet of Islam:Muhammad is the messenger of
provided by the platform, whicl
account was associated with ema
[email protected], and
According to records provided 4
with the m.domingo2014@hotmail
Domingo.”
7. According to Departme
was also previously an active d
was assigned to Fort Campbell,
Afghanistan from September 10,
8. FBI agents have revig
OCE in which DOMINGO described
his aspiration to conduct an at
a. On March 3, 2019
another vegas event tbh? someth
-] and its not about winning th
america giving them a taste of
over the world.” Based on my t
that DOMINGO’s description of *
reference to the October 1, 201
Nevada, which killed 59 people,
b. On March 14, 201
mosque shootings in new Zealand
mustbe retribution.” Based on
3 Based on my training andis used in electronic communica
honest.” “ ing to kick off civil unrest [.
n showed that the USERNAME 1
il address
telephone number 931-249-5283.
y Microsoft, the name associated
com e-mail address is “Mark
nt of Defense records, DOMINGO
uty U.S. Army Infantryman. He
Kentucky, and then deployed to
2012 to January 16, 2013.
wed online posts provided by the
his support for violent jihad and
tack in the Los Angeles area.
DOMINGO posted, “america needs'
e civil war its about weakening
the terror they gladly spread all
raining and experience, I believe
another vegas event” is a
7 mass shooting in Las Vegas,
“there were9, DOMINGO posted,
[sad emoji] [ . ,.] there
my training and experience and
experience, I am aware that “tbh”tions as shorthand for “to be
knowledge of this investigation,
to the March 13, 2019 mass sho
Christchurch, New Zealand, whid
Also on March 14, 2019, DOMINGd
make a christians life miserab]
[.
+]
sis in new Zealand .] mayk
shed our blood [. no Musli
a message needs to be sent.”
B. DOMINGO Expresses His Inte
I believe DOMINGO was referring
tings at two mosques in
h killed 50 people.
posted, “I feel like I should
e tomorrow for our fallen bros n
[.e a jews life idk‘ .] they
m should have to experience this,
nt to Kill Americans to Retaliatefor the Mass Shooting in New Zealand
9. According to the OCE,
observing DOMINGO’s posts regar
Zealand mass shooting, the OCE
conversation with DOMINGO, in Ww
about that mass shooting. [In t
jus enraged atm [. .] these
one way or another.” The OCE qd
would be ready the next day, an
response would require planning.
many people DOMINGO would like
wrote: “one [individual]? was 4
a bunch of jews around this ond
theyre forced to find parking a
4 “Idk” “I do5 Based on my training and
is short for “at the moment.”
is short for fuckers do need to bleed [.
m
on March 14, 2019, after
ding retaliating for the New
initiated a private online
hich they discussed their anger
waim
-]
hose messages, DOMINGO wrote,
autioned DOMINGO that police
d that any sort of retaliatory
In discussing with the OCE how
to kill in retaliation, DOMINGO
hinking more like a group theres
street not alot of parking so
nd walk to the synagogue.” Later
't know.”
experience, I am aware that “atm”
in the conversation, DOMINGO wt
saturday for their worship,” ar
had a lot of businesses and sur
10. On March 16, 2019, afr
(“CHS”), who also maintained an
same private message group as J]
private message to DOMINGO askji
responded, “still mad -][- 4
watched the vid.” Based on my
knowledge of this investigation
reference to live footage of th
the perpetrator streamed onling
subsequently been reposted on t
“h11. DOMINGO continued,
took my ak out [. .] its been
training and experience, I know
reference to a Kalashnikov-manu
commonly known model of which i
According to a law enforcement
firearms registered to him: a qd
semi-automatic rifle (WASR 10),
Tulski-Korovin SKS semi-automat
bolt-action rifle.
6 Based on my training andis an Arabic word for Jews.
7 The CHS has worked with2013. In total, the CHS has be
The CHS does not have a crimina Ly
rote that “the yahud® go on
nd that the area was upscale and
rveillance cameras.
h FBI Confidential Human Source’?
online account and was in the
OMINGO and the OCE, sent a
ng how he was feeling. DOMINGO
ven more so [. .] since I
training and experience and
I believe “the vid” was a
e New Zealand shootings, which
during the attacks and which has
he Internet.
ow my bros n sis died [.
by my bed.” Based on my
that “ak” is a common shorthand
factured assault rifle, the most
s referred to as an AK-47.
database, DOMINGO has three
entury Arms Wassenaar Arrangement
which is an AK-47 style rifle; a
ic rifle; and a Zastava M 48
experience, I am aware that Yahud
the FBI since approximately Augusten paid approximately $304,524.1 history. :
6
12. Later in their convei
and the CHS meet in person, an
following week.
c. DOMINGO Meets CHS on Marck
Committing a Terrorist Att
13. On the evening of Mat
met in person to eat dinner ang¢
meeting was audio recorded. Du
below, DOMINGO discussed with t
attack, including Jews, police
military facility.
14. DOMINGO and the CHS d
Syria, and the activities of Al
Iraq and al-Sham (“ISIS”). Aft
A.“not doing anything,” DOMINGO
plant IEDs.” Based on my train
that “IEDs” is a reference to I
DOMINGO characterized Al-Qa’ida
run [. -] They’11 shoot, the
the Americans get mad. Then th
This is why I like - I like al-
direct stance [. .] victory qd
training and experience, I beli
to Abu Bakr al-Baghdadi, the le
® Based on my training andviolent Islamic extremists, the
for Islam through violent jihad.
rsation,
rch 18,
i attend a prayer service.
tiring that meeting,
DOMINGO suggested that he
they agreed to meet the
a 18, 2019 and Proposes Ideas fortack
2019, the CHS and DOMINGO
The
as detailed
he CHS different targets for an
officers, churches, anda
iscussed the wars in Iraq and
-Qa’ida and the Islamic State of
er the CHS said Al-Qa’ida was
aid, “Well, they’ll, they’11l
ling and experience, I believe
mprovised Explosive Devices.
’s tactics as “sort of hit and
n they’11 run away [. .] then
[. -]
‘cuz he took the
ey go murder Muslims
Baghdadi, yeah,
r martyrdom.”® Based on my
eve “al-Baghdadi” was a reference
ader of ISIS.
experience, I know that among
term martyr means one who dies
15. Throughout their driv
targets to the CHS, including gz
National Guard Armory. At one
the business street [. -] the
They’ re all up and down the stiz
everywhere. I mean it’s a busi
“if you really want to do it, y
online and do it, you know? Yq
DOMINGO interrupted the CHS and
replied, “No. They going to pu
“If they catch me alive.” The
go shahid?? You going to kill
tell me [. -] You have a pla
has to be done.”
16. Moments later, DOMING
saying. We should plan.” The
to get caught. Your plan is ju
your plan.” DOMINGO replied “Mv
“It’s better not to get caught)
taken alive. But [. -] I hay
he had nine “AK magazines,” fiv
described to the CHS the guns t
‘They’ re all legally under my n
going to work.
[. +]
We’re going to
Well to be fair, yeah,
9 Based on my training andfacts, “go shahid” is used here
ve,
reet,
fou can’t just,
DOMINGO pointed out possible
olice cars, churches, anda
point, DOMINGO stated “This is
Yahud come here on Saturday.
but there’s cameras
ness you know.” The CHS said,
you can’t just go
u’re going to end up like-”
The CHSsaid, “A martyr.”
t you in jail.” DOMINGO replied,
CHS replied, “okay, you going to
one or two? What’s the plan? You
n?” DOMINGO replied, “something
O said “I know what you’re
CHS replied “I mean I don’t want
st to go and get caught. That’s
artyrdom, bro.” The CHS said,
a" DOMINGO said “Better not to be
e many magazines.” DOMINGO said
e of which were loaded, and
hat he owned. After DOMINGO said
ame,” the CHS said “That’s not
The CHS said, “No
[
get caught.”
[. -] Okay. So we plan
experience and the totality theto mean “become a martyr.”
8
-] We plan. We take our time You know we just, we cruise.
We chill. We chill for a bit.
17. During the meeting, POMINGO pointed out a church and
said “there’s another one [. .|.] I mean this is the land of
kuffar,}° brother.” The CHS sajid “You want to go after church?
What do you want to hit? Chur¢hes or like the military base?
Which one do you want to show me?” DOMINGO replied “We can
always hit the cops.” The CHS|again expressed concern about
DOMINGO conducting an attack using guns registered in his own
name, and asked if the bullets|were also registered in his name.
DOMINGO said the bullets were not registered, and he used gloves
to handle the bullets so his fingerprints would not appear on
them.
18. The CHS then said that he knew someone who “used to
make IEDs.” DOMINGO replied “That’s even better.” The CHS
described how an IED could be placed under a car and detonated
with a timer. The CHS and DOMINGO then arrived at the mosque
and went inside for several minutes to pray. When they left the
mosque, the CHS said the CHS would talk to “the brother, and
see.” DOMINGO replied “He can|make IEDs?” The CHS replied that
the brother could not make IEDs, but the CHS would see if the
brother knew someone else who dould. The CHS drove DOMINGO back
to DOMINGO’s house, and DOMINGO said, “We’1l keep in touch [.
.] You have my number. I have |/yours.”
10 Kuffar is the plural form of an Arabic word referring tonon-believers or infidels, likely used by DOMINGO to refer tonon-Muslims.
D. DOMINGO Proposes Conductir
19. On March 20, 2019, D
message of a photograph of an 3
of paper with a handwritten cag
3/20/2019.” The rifle depicted
feature a foldable metal stock
detachable high-capacity ammuni
at his house. DOMINGO explaing
q“foldable stock for drive by”
[. -] replaced it with wire
on my training and experience 4d
investigation, I believe DOMING
rifle’s wooden stock with wire
DOMINGO modified his rifle so 4
more easily from inside a vehid
20. Later that day, DOMIN
containing a similar photograph
OCE to send a timestamped photd
what I did with my ak [. -] i
know its mine [. -) and i ain
configuration is illegal af!1)
there may be a “snitch” in the
assured DOMINGO that everyone H
“inshallah [. J
-]
responded, q
[. -] go dark [. forak
11 AF is slang for “as fuc
hg a Drive-By Shooting
MINGO sent the CHS a private
\K-style rifle alongside a piece
tion, “USERNAME 1 [. -]
in the photograph appeared to
an attached sling, and a
tion magazine that DOMINGO keeps
nd that he
-] cuz wire can fold.”
nd knowledge of this
O’s reference to replacing the
for a “drive by” means that
le.
GO sent a message to the OCE
of his rifle.
graph in return and stated “like
time stamped it [. -]
“d
DOMINGO said he thought
so u
t fed [. (cuz my ak
Lol.”
message group. When the OCE
ad to be invited, DOMINGO
ho if I do, do anything that is
it [. -] and I’1il1 see you up
k,” meaning very.
10
d to the CHS that the rifle hada
“took off wooden stock
Based
hat it could be handled and fired
DOMINGO asked the
there [. -] if allah wills 1
experience,
heaven, and DOMINGO expects to
dying through violent jihad.
E. DOMINGO Meets with the
His Intent to Commit a
21. On the evening of
met again to eat dinner and att
meeting was audio recorded. Dv
below, DOMINGO discussed with t
committing an attack.
22. DOMINGO asked the CHS
apparently referencing the phot
of his rifle. DOMINGO spoke ak
the rifle and added “So when we
to act, I can keep it, like, yo
gonna be like, you know, it’s gq
the car [. With the wire,-d
23. The CHS replied that
a”Islam and was “so pure,” and st
_ don’t have to do this. You kne¢
DOMINGO responded by pointing qd
the police,” and describing ho
glass but police officers “roll
122 “Lol” is short-hand forstated he had to “show off,” bu
[heart-eye emojis].” DOMINGO I]believer who was “mad atm.” Aq
I believe “up there”
March 22,
wi21. Based on my training and
is a reference to paradise, or
earn his’ place in paradise by
CHS on March 22, 2019 and Discusses
Terrorist Attack
2019, the CHS and DOMINGO
end a prayer service. The
ring that meeting, as detailed
he CHS different plans for
if the CHS saw his “AK,”
ograph DOMINGO had sent the CHS
out some modifications he made to
decide to act or when I decide
u know when it’s the wood, it’s
onna be uncomfortable [. -] in
you can fold it.”
DOMINGO had just converted to
ated “You don’t need to, like you
w that, right? You’re pure.”
ut a police car, stating “That’s
police cars have bullet proof
their window down sometimes.”
“laugh out loud.” DOMINGO alsot added, “martyrdom to me is like
ater stated he was just aain, “atm” means “at the moment.”
11
24. DOMINGO and the CHS
prayers, and the CHS again sai
replied “To be fair though, mo
Everyone I know are like, they
always said that’s fine, I’m j
about them.
the deen.”13 The CHS replied t
being patient, and DOMINGO replied “But you know [.
of the times,
right?” The CHS said, “Yeah,
“So you know, if they start it
one way or another I’m gonna finish it.
by fighting. We can handle it
They don’t care about me.
it’s a fucking th
t
then discussed practicing Islamic
1 how DOMINGO was “pure.” DOMINGO
st people here are shit [. -]
re like fake, you know [. -] I
ust like, fuck ’em. I don’t care
They don’t care about
hat Allah would reward DOMINGO for
-] A lot
nese Kuffar that start the beef,
hey do, yeah.” DOMINGO replied,
I’m gonna finish it. You know,
Like we can handle it
throwing bullets at each other, what you wanna do bro, like murder me, kill me, I’11 die
Shahid.”
F. DOMINGO Speaks with the CHS on March 27, 2019 to DiscussHis Plans to Conduct a Te
25. On March 27, 2019,
platform to tell the CHS that f
wanted to kill him.
of the “Ummah”’!4 and said that
13 Based on my training anthe term the deen is an Arabicreligion.
14 Based on my training anUmmah is an Arabic word referri
community of Muslims.
15 Based on my training anterm “halal” is an Arabic wordDOMINGO also made reference to
neighbor involving trash on DOM
rorist Attack
DOMINGO called the CHS via the
e was upsét with his neighbor and
DOMINGO identified the neighbor as an enemy
his blood was “halal.”15 The CHS
il experience, I understand that
word referring to one’s faith or
1 experience, I understand that
ng the worldwide nation or
i experience, I am aware that the
meaning religiously permissible.a personal dispute with theINGO’s lawn.
12
repeatedly tried to calm DOMIN
were in the “heart of the enemy
around the corner,” there is n
26. DOMINGO said he coul
burglary, and that murders go
said they needed to “start smal
attack of a larger scale, beca
the first time.
would test the response time of the police,
response time would likely be ¢
Base. G. DOMINGO Meets With the CH
50 down.
insolved all the time.
DOMINGO said 4
DOMINGO said that they
“on and that if “martyrdom is just
Dthing DOMINGO can do.
A stage the attack like a
DOMINGO
1,” before building up to an
hse they were bound to “fuck up”
£ he killed his neighbor, it
and that the
lower than at a National Guard
on April 3, 2019 and ProposesUsing IEDs and Firearms to Attack Police Officers andMilitary Service Members
27.
met in person. The meeting was
During that meeting, as detaile
intent to commit a large-scale
and described using firearms ay)
28. DOMINGO told the CHS
they both spoke to on the platf
The CHS said the person “was ta
yand DOMINGO told that person,
That would do damage. [. -]
.] blows up on the freeway, h
citizens injured.” When the CH
said “Then the fun starts.”
On the evening of April 3,
nm Los Angeles
2019, the CHS and DOMINGO
audio and video recorded.
d below, DOMINGO reaffirmed his
attack in the Los Angeles area,
d IEDs to do so.
that he was jealous of a person
orm who had more guns than he.
liking about like IEDs and stuff,”
an IED here, on the freeway?
An IED, like the ones in Iraq [.
undreds and maybe thousands of US
S asked “And then what?” DOMINGO
13
29. DOMINGO stated he war
Ramadi” and “Fallujah.” DOMIN
get, like, that will get like t
you bro, just the one IED that
nest, bro.”
30. DOMINGO reiterated hi
“our brothers in Christchurch 4d
slaughtered.” DOMINGO also sai
martyr.”
31. DOMINGO said his plan
rather than engage in a battle
DOMINGO said he intended to “ki
a"we flee,” similar to the “insur
they caused “small casualties H
the stress” on America and lead
32. DOMINGO said that alt
was more like the tactics used
prefer to operate like “al-Bagh
was not feasible because he and
manpower to succeed in such a 4
for ISIS and said if ISIS “came
to ISIS.
33. The CHS said law enfg
Turkish man who had recently ki
Netherlands. DOMINGO replied %
16 Based on my training anis a reference to Ayman al-Zawa
bO said,
i experience,
nted to “make ‘em bleed, like in
“a dead police that will
he police riled up. But I need
s going to stir up the hornet’s
s intent to conduct an attack for
nd our sisters who were
dhe was “not afraid to die a
was to “go in fast” and “raid,”
and try to “hold positions.”
1l enemies here and there, then
gency” in Iraq. DOMINGO said if
ere and there,” that would “put
to martial law.
hough such a hit-and-run strategy
by “Zawahiri,”1® and he would
dadi” and fight a “battle,” that
the CHS did not have enough
attle. DOMINGO expressed support
here,” he would swear allegiance
rceement in Europe had caught the
lled three people in the
hat he “had a feeling they were
saI believe “Zawahiri
hiri, the leader of Al-Qa’ ida.
14
gonna catch him,” and explaine
and crowded, and “he probably
said “you have to be patient.”
you know, I want to do it.”
want to do, show me.”
34.
small.” DOMINGO then drew a dj
scenarios for how he could atta
described a scenario in which f
also described another scenari¢
ballsy,” in which he and the CEH
car stopped at a red traffic 14
shoot into the car. DOMINGO sa
its windows down while he and t
car in their first meeting, on
clarified that, in this scenari
his car to “burn the vehicle, 1
oil, [or] gasoline,” in order +
police car, causing a longer ir
little more difficult.”
that’s all I can do to
35. Later during the meet
diagram!® he had drawn, and tol
17 Based on my training an“dawla” is commonly used by vida
18 The CHS later recovered
law enforcement was able to rea
DOMINGO said “So what I’m thinking is,
DOMINGO then stated “Inshallah,
these ka
i that the Netherlands is small
didn’t plan it right.” The CHS
DOMINGO replied “Oh I know but
The CHS replied “Show me how you
yea, we start
Lagram and explained multiple
ack police officers. He then
ne could attack LAPD officers. He
, which he described as “really
iS would pull alongside a police
ght with its windows down and
id he had seen a police car with
he CHS were riding in the CHS’s
2019.March 18, DOMINGO later
o, he would want to get out of
ike dawla”)? with “lighter fluid,
o destroy the cameras in the
vestigation and making “life a
if
I’m down.”ffir, then wallahi,
ing, DOMINGO ripped up the
i the CHS they had “just talked
i experience, I know that the termlent extremists to refer to ISIS.
the pieces of the diagram, andssemble them.
15
about some serious shit,” incl
“murdering people.” DOMINGO be
with the CHS would result in “¢
warned that the CHS was in “dee
discussion with the CHS could 3:
and told the CHS
can’t expect to do these kind gq
forever [. .] At some point
be a man and you gotta stand yq
out that they could get caught
we’ re gonna die shahid.”
H.
36.
with the CHS. DOMINGO arrived
holding a backpack containing
covered by what appeared to be
the CHS expressed surprise that he
DOMINGO replied “If we’re going
commence fighting, jihad, yeah,
remain.” The CHS said the CHS
caught carrying a gun, and DOMINGO
Los Angeles to carry a gun.
remarked again that when DOMING
19 Fi sabillillah is an ArGod/jihad in the way of God,” oathe cause of God.”
“We broke fede
DOMINGO Meets With the CHSUsing IEDs and Firearms tq
On the evening of Apux
4
La
nding “murdering police” and
=lieved what he had just discussed
a2 lot of charges already” and
2p shit.” DOMINGO believed his
result in a “conspiracy charge”
ral law.” DOMINGO said “You
f things and remain anonymous
they’ re gonna know and you gotta
ur ground.” When the CHS pointed
eventually, DOMINGO replied “Then
on April 19, 2019 and Discusses
Attack an Upcoming Rally
il 19, 2019, DOMINGO again met
wearing camouflage pants and
n AK-47 style rifle partially
a shirt. Upon DOMINGO’s arrival,
had brought the rifle, and
to commit-- if we’re going to
fi sabilillah,1% you gotta
did not want DOMINGO to get
replied that it was common in
the CHSter in the night,
O arrived with the rifle, the CHS
abic term meaning “In the way ofr “for the sake of God,” or “for
16
thought he was crazy, and DOMI}
you that I’m serious.”
37. DOMINGO asked about
refer to individuals located ot
said “If you want, you know wha
ready, huh? You’re not ready.”
“really thinking about it” for
see how serious” DOMINGO was.
added, “if you’re not ready tor
“you want to do it tonight?
know,
for Christians, who were
CHS said, “so that’s it?
where?” DOMINGO said,
serious.
-]
Are you serious?”
sooner or later,
38.
DOMINGO said,
brothers and sister across the
39. During the meeting,
like, IEDs?” DOMINGO said,
you want to,
know someone,
make it?”
20 Based on my training an
the facts,shooting homeless people.
Wh
and was tired, but that i
celeby
You wW
“Anywhey
DG
this was gq
The CHS and DOMINGO t
“We don’t have td
the CHS said,
“You want to?”
I might know somedne.
that’s perfect [,
The CHS said he did.
DOMINGO seemed to su
1GO replied “I just wanted to show
nomeless people (appearing to
htiside the meeting location), and
[. +]
The CHS said the CHS had been
at I’m saying2°® You're not
the past two weeks and “wanted to
DOMINGO said he was serious, and
ight, then okay.” The CHS said
ere?” DOMINGO said he did not
t was a “holy day for yahud” and
ating Passover and Faster. The
anna do it? You have, like,
“one. The CHS replied, “You’re not
MINGO replied, “I’m serious [.
nna happen.”
hen prayed and ate, after which
do this. But we do this for our
world, oppressed, yeah?”
“So you remember,
The CHS said, “if
“DOMINGO replied “If you
-] but does he know how to
DOMINGO said “So he can write
A experience and the totality ofggest an attack in the form of
17
down instructions on how to ma
“Probably.” The CHS said the yj
said “Okay, tell him this.
clearly, and then wallahi. Yo
masse, you know that [. . .]
The CHS said “He
[.
buying guns.”
buy it little by little |
CHS said, “but where can you bu
e it?” The CHS replied,
erson was from Iraq. DOMINGO
Write down the instructions,
h can’t buy these ingredients en
because that’s more suspicious than
w then?” DOMINGO replied, “We'll
so it’s not suspicious.” The
y it from?” DOMINGO replied by
naming three home improvement stores and said “They’ re
everywhere. Here’s the thing,
explosives.” The CHS said, “th
it’s easy. It’s not easy, but
time into it, everyone can maké
wallahi, they don’t want to.
Only a terrorist would want to,
40. During the meeting, BD
more damage and would be better
make it, I just don’t know how,
history but I failed chemistry:
So if that brother is willing t
“Should I talk to him?said, WwW
replied, “Talk to him, if not m
make it, don’t force him. But
Fucking to the letter details.
41. DOMINGO then asked, *
you think he’1ll tell the feds?”
guarantee he’s not going to.”
Because,
the average person can make
ey can?” DOMINGO said, “Yeah,
it’s not hard. If they put the
explosives. But obviously,
you know, why would you?
right?”
OMINGO said, “The IEDs would do
to transport [. . .] We’ll both
I’il be honest. I’m smart in
Science is not my forte [. . .]
“"o make it for us. .. The CHS
hat do you think?” DOMINGO
ake it. If he doesn’t want to
ask him how. Details. [. . .]
Ask him.”
Do you think he’s a snitch? Do
The CHS replied, “I can
DOMINGO replied, “If he’s not
18
gonna tell the feds, then you
“put he’s not gonna, like,
replied that was OK, and “if h
make him take part. But that
and we should ask him, if you’
least teach me how?”
42. DOMINGO instructed th
what was happening to Muslims.
you know, like, bro, al-Sunnah
I know you have a family and I
asked how the CHS knew the ass¢q
at the same Mosque and the assq
“does fiAmerica. DOMINGO said,
have the same ideas.”
can talk to him.” The CHS said,
DOMINGO
a doesn’t want to take part, don’t
is an avenue we shouldn’t waste,
re not gonna help, can you at
ne CHS to remind the associate
DOMINGO stated “just remind him,
wal-Jummah is under attack. And
m not gonna force you.” DOMINGO
ciate, and the CHS said they were
ciate had been criticizing
ne hate kuffar?” The CHS said “He hates kuffar, but because he has a family, he doesn’t want to
get involved.” DOMINGO replie
Talk to him some more [. -]
you ever made explosives? Like
and pieces.”
43. DOMINGO also brought
“That’s understandable [. -]
ou can be casual about it. Have
, haha, a joke. You can get bits
up an upcoming April 28, 2019
rally in Long Beach organized by a “white nationalist” group,
and told the CHS it was going t
CHS asked, “So what’s the plan?
scope out the area.
about the rally, because at any point they can cancel it.”
CHS asked DOMINGO how he heard
he heard about it on the news and online.
DOMINGO wanted to carry out the
We’1l have
o take place at Bluff Park. The
“ao DOMINGO said, “We'll have to
to keep up everyday updates
The
about the rally, and DOMINGO said
The CHS asked how
attack, and DOMINGO said,
19
“Parking’s gonna be an issue, We could do hit and run [. . .]
We drive by, we empty a magazine or two. An AK. And we book
it.”
44. The CHS asked “but y
damage?” DOMINGO replied that
and “we can make it before. Ii
[. . .] ask your brother. Ask
u said the IED will do more
“the IED will do more damage,”
‘s coming up. We have two weeks
the brother.” The CHS said “so
if we make it before, we can actually-[.]” DOMINGO interrupted
and said “Detonate. Yes we car
would be perfect.”
45. DOMINGO then reiterat
make the IED himself, and said,
I need you to make sure he’s ng
detonate it in a crowd. Which
ed that he did not know how to
“I need you to talk to him, and
t a snitch.” DOMINGO instructed
the CHS to “have him write it down, and then we’ll see. We can
make it. Even a small IED woul
The human body is very easy to
damage, but a big IED just in d
looking at least 20 people dead
so around 50 at least.” The CH
headline.” DOMINGO replied, “]
are going to storm. Remember t
bombers, it stirred up a hornet
is going to be locked down.”
46. The CHS said “are you
serious are you serious?” DOMI
to do the IED route, which is gs
will do a lot more damage crowd
d do damage in a crowd. [. . .]
break. A grenade can do a lot of
backpack, in a crowd? You’re
, Maybe, maybe 30 people injured,
S said, “That’s going to be the
think if we do the IED route we
he Tsarnaev brothers, the Boston
s nest [. . .] If we do this, LA
sure you want to do this, I am
NGO replied “I am serious, I want
omewhat the better idea. An IED
wise. We bring it and leave it
20
in the car. We each bring ad
we can escape [. -] we can
we possibly can change in the
injured and take off clothes and change.
one in plain sight. So if the
serious and a better plan than
47.
different clothes, and DOMINGO
leave the IED in a crowded spot.
have an IED and they cancel?”
ifferent set of clothes [. . .]
crowd.
so
change in the car, be honest bro
We can pretend we are
The best disguise is
IED thing is sounding more
going spraying and praying.”
The CHS asked if they would be able to change into
replied “Perhaps, we are going to
a The CHS asked “what if we
DOMINGO replied “OK now we have
an IED that we can use at our disposal.”
lies Materials to Create and Use
e CHS wrote in a private message
I. DOMINGO Purchases and Supfa Weapon of Mass Destruction
48. On April 22, 2019, th
to DOMINGO “I talk to the broth
help us but we have to get him
to come tomorrow to pick it up,
“get it all,” and the CHS said
purchasing different parts of t
The CHS said “I wildetection.
[. . .] So your part is: Chri
shrapn[el] We have to buy the
to come tomorrow to pick it up
the pressure cooker and a remot
about nails?” The CHS said “Li
whatever goes inside.” er and he said he’s willing to
the stuff tonight And he’s going
” DOMINGO asked if the CHS could
no, they should split up
he IED so they could avoid
1 buy some and you will buy some
stmas lights but no LEDs And
part tonight because he’s going
so he can build it And I will buy
DOMINGO asked “whate control.”
ke nails or [screw] driver
21
49. Shortly thereafter,
DOMINGO drive to multiple home
officers saw DOMINGO purchase
a self-service kiosk using a debit card.
closed-circuit television vide
store, which showed that DOMIN
law enforcement officers observed
improvement stores. At one store
several large boxes of nails from
Agents later obtained
and transaction records from the
bO purchased approximately eight
pounds of three-and-a-half-inch and longer nails using his debit
card.
50. Later that day,
“u wanna try n pick up what I &k
said “Maybe today because we hd
DOMINGO replied “got nails look
CHS would look for the lights t
“I can reimburse you tomorrow.’
51. On the evening of Apr.
with the CHS. The meeting was
DOMINGO walked in with a bag cq
had purchased the day before.
control race cars that the CHS
table.
52. The CHS told DOMINGO
this.” DOMINGO said that the é¢
cancelled, and proposed attacki
Nationalist” rally in Huntingt¢
April 27, 2019. DOMINGO said t
be on the beach, which may maké
many people because it was a wi
DOMINGO
wrote the CHS again and asked
uy today or tomorrow.” The CHS
ve to give it to him tomorrow.”
in for lghts.” The CHS said the
he next day, and DOMINGO replied
il 23, 2019, DOMINGO again met
audio and video recorded.
ntaining the boxes of nails he
DOMINGO examined boxes of remote
had obtained and placed on the
that they “don’t have to do
vent in Long Beach may be
ng a different “White
nm Beach, California, on Saturday,
he Huntington Beach rally would
it more difficult to kill as
de open space. DOMINGO said the
22
Santa Monica Pier would provide a better space for an attack,
particularly during the summer
was a more enclosed space and 4
from a blast.
on the Santa Monica Pier would
53.
to provide to the UC to use in
specifically bought three-inch
enough to penetrate the human k
54. DOMINGO examined the
had purchased and saw that the
up to a distance of 100 feet.
the blast radius would extend kh
perhaps the remote controls cou
work from a distance of more th
that if they conducted the atta
would remain on the pier and de
should stay further away and le
detonated. DOMINGO said he wou
afraid to die a martyr.
55. DOMINGO showed the CH
on his phone, and pointed out ]
near the entrance to the pier.
56. After about 45 minutes,
when it was crowded, because it
eople would not be able to escape
DOMINGO said that detonating an IED with a timer
cause a lot of casualties.
DOMINGO confirmed that he had bought three-inch nails
making IEDs. DOMINGO said he
nails because they would be long
ody and puncture internal organs.
remote control cars that the CHS
remote controls would work only
DOMINGO expressed concern that
eyond 100 feet. The CHS said
ld be modified so that they would
an 100 feet. DOMINGO then said
ck at the Santa Monica Pier, he
tonate the IED, but the CHS
ave the scene after the IED
ld bring his gun, and was not
S a map of the Santa Monica Pier
ocations-where they could stand
the UC arrived. DOMINGO asked
the UC if the remote control cquld be modified to detonate the
IED from up to three quarters cf a mile away.
the UC the boxes of three-inch
DOMINGO showed
nails he had bought, and told the
23
uc the nails were
long as the nails
57. DOMINGO explained to
discussing a very
a crime. DOMINGO asked the UC
the IED, and the UC said it wou
58.
remote control, and the UC sug¢
instead of a remote control to
replied that “would be perfect
bail” and watch the blast from
s59. DOMINGO said they
operation because he wanted to
experience Ramadan, which would
UC again said they should all 4d
other.
60. DOMINGO gave the UC
get back in touch in a few days.
should talk only on the platfoy
that what they were talking abd
offered to buy more parts for t
said he would let them know whe
0.the operation and when the UC
asked how he would know when Dd
complete the IED. DOMINGO said
4dcontaining a photograph, like
ahead” for the operation.
long enough to kill their intended victims,
serious matter,
so
did not get bent in the blast.
the CHS and the UC that they were
and even talking about it was
how long it would take to make
ld take a few days.
DOMINGO asked again about the 100-foot reach of the
ested they could use a timer
detonate the device. DOMINGO
” because with a timer “we can
a safe distance.
hould consider delaying the
finish reading the Quran and
2019.be starting on May 5, The
gree they would not pressure each
is phone number and said he would
DOMINGO stressed that they
m, and cautioned the CHS and UC
a”ut were “federal charges. He
he IED if the UC needed them, and
n he was ready to proceed with
hould complete the IED. The UC
MINGO was ready for him to
he would send the UC a message
“meme,” which would be the “go
24
J.
61. On the evening of Ap
CHS online. DOMINGO said was
The CHS said the UC had said p
the Long Beach rally so it seer
happening, and they could exec
planned.
62. DOMINGO replied that
DOMINGO Finalizes His Attack Plans
ril 24, 2019, DOMINGO spoke to the
angry and had a rough day at work.
sople were talking about going to
ned the rally was really
hte the operation as previously
he did not want to rush into the
operation, and since they had talked about waiting until after
Ramadan,
finish making thé IED. DOMING
that the event was going to go
proceed with the operation.
the IED could be ready in time
he did not want to cal 1 the UC now and rush the UC to
said if he had known yesterday
forward, he would have wanted to
The CHS replied that the UC said
for the event, and they could use
the timer to detonate it and watch the explosion from a safe
distance. DOMINGO said,
not rush into this headfirst.
one of us will have to drive td
completed IED from the UC,
63.
explosion from a distance, and
to watch it but “ideally we shg
would be panicking and their ca
“the timer is great,” but said,
or g
“Lets
If I give the go ahead [. . .]
Victorville” to collect the
erhaps meet the UC halfway.
The CHS replied it would be great to watch the
DOMINGO agreed it “would be cool”
uld be gone” because everyone
lm demeanor may arouse suspicion.
The CHS said they could set the timer and then go home and watch
the blast on television,
publicity,
and DOMINGO said he did not need
and would “rather just hear about it on 4chan.”
25
DOMINGO said, “I know it’s gony
sleep on it.”
64. The CHS said the CHS
operation,
complete the IED. The CHS saic
net contact the UC over the phd it’s a good opportunity.
he was worried they were “rush
wanted to act while they were all
to be “calculated.” He contin
on it. If [the UC’s] down, I
na be big.
and DOMINGO asked if
1 no,
But let
[. +] Let me just
was ready to go forward with the
the CHS already told the UC to
and DOMINGO said they should
me. DOMINGO continued, “Fuck,
me sleep on it.” DOMINGO said
ng into this too hastily,” and he
“motivated,” but also wanted
ed “I say me and you we’ll sieep
dont have a problem with it.”
The CHS said they could proceed with the operation and still
conduct more attacks after Rama
Let’s just sleep on it. If we’
the go-ahead. I’11 give the gq
65. The CHS suggested the
but DOMINGO Abefore the event,
because people might see it. If
in a trash can to conceal it, &
attendees would be unlikely to
putting the IED in a trash can
deaths. DOMINGO proposed inste
it’s happening” and place the I
The CHS offered to carry the IB
replied, “I was thinking I'd de
said the UC also could blend in
was Caucasian. DOMINGO replied
dan, and DOMINGO replied “We can.
re still as motivated, we’ll give
-ahead.”
y could place the IED the night
aid that would be too risky
he CHS suggested placing the IED
ut DOMINGO said the rally
gather near a trash can, so
would not result in a lot of
ad that they go to the event “as
ED where people were gathering.
D into the event, but DOMINGO
it. I’d blend in.” The CHS
with the “Nazis” because the UC
he was “ready,” but “this shit
26
we're talking about isn’t easy
they sleep on it, and if “we’r
then DOMINGO would contact the
66. The next day, at appi
sent the UC a message containirz
and skyline. Based on my trair
of this investigation, I beliey
“ao DOMINGO suggested again that
= still feeling pumped by lunch,”
UC to proceed with the operation.
roximately 12:00 p.m., DOMINGO
ng a photograph of a crescent moon
1ing and experience and knowledge
ve this was the “go ahead” meme
that DOMINGO had told the UC he would send when he was ready to
proceed with the operation.
67. The UC responded, “O
wrote “im waiting for the homie
gonna be on the weekend?” The
presents to make them fit in at
“okk do what you need to do the
didn’t have to do all this toda
OK and “the presents will be ready tomorrow morning.”
replied “if ur sure ok then kee
with em.”
68. The UC asked DOMINGO
”tay I hear and obey. DOMINGO
s text, I think the kick back is
UC replied “I need to wrap the
the party spot.” DOMINGO wrote
party is on the weekend tho u
y.” The uc responded that it was
DOMINGO
p em somewhere no one will fuck
for help with wrapping the
“presents” and asked “do you know what the party spot looks
like? I want to match the wrap ping with what’s natural.”
DOMINGO replied “you don’t have something like convenient like a
bag y go thru the trouble.”
69.
uc, “are you coming to LA?”
finish the last. piece of the py
the presents somewhere safe lol.
The next morning, Apyil 26, 2019, DOMINGO wrote to the
The UC replied “Yeah akhi after I
esents.” DOMINGO replied “keep
ao The UC said the UC wanted to
27
“stay in la for the party” and
sure [the CHS’s] couch is good
70. DOMINGO said he was ¢
someone and the UC replied “we
sha Allah heading to [Victor] vi
idea.” DOMINGO replied “I‘1l t
platform] considering our scheg
find the parties address and sh
times so we’ll jus say hin go
place is crucial Youre good at
‘im just practical albeit blunt
71. DOMINGO said he was g
groceries, pray, then “ill be ¢
wrote “u want me to pick u up?
mean I think the party is on su
“”kno. The UC wrote that they n
DOMINGO replied “if you insist
aagreed to méet the UC and CHS
72. At approximately 7:15
and CHS to finalize plans for t
audio and video recorded. The
what DOMINGO thought were comp]
should set the timer on the IED
73. DOMINGO then drove th
Long Beach to surveil the locat
drive, DOMINGO said the plan wa
on Sunday, before too'many peop
DOMINGO replied “ok no prob im
“"
yoing to Victorville to see
need to plan the party today in
lle after the party is a good
alk with [the CHS] on [the
is it shud be simple [. -] tho
10W up but like I said the prayer
“ The UC said “Ok inshaAllah
this akhi,” and DOMINGO replied
as shit.”
oing to work out, shower, get
n my way afternoon.” DOMINGO
Is that what u had in mind??
+]
I
nday [. so we got time ya
eeded to meet that day and
prolly later tonight then,” and
t 7:00 p.m.
p.m., DOMINGO met with the UC
he operation. The meeting was
UC showed DOMINGO how to operate
eted IEDs. DOMINGO said they
s for 5 to 30 minutes.
e UC and the CHS to Bluff Park in
ion for the attack. During the
s to arrive early in the morning
le showed up for the rally, and
28
disguise themselves as counter;protestors.
past the Port of Long Beach, D
they survived the attack on Sunday,
attacks, including at the Long
would significantly disrupt the U.S.
discussed initiating an attack
74. When they arrived at
the location with the UC and CHS.
to find the most “crowded” area
people in the attack. DOMINGO
after they detonated the explos
the event in separate el
leave the scene without being
75. After surveilling the
and CHS back to their previous
again inspected the IEDs in adv
then carried one of the IEDs ou
UC’s vehicle,
//
//
//
at which point he
As DOMINGO drove
MINGO told the UC and CHS that if
they could conduct further
Beach Port, which DOMINGO said
economy. DOMINGO also
on a train.
Bluff Park, DOMINGO walked around
DOMINGO said they should try
s in order to kill the most
instructed the UC and CHS that
ives, they should walk away from
s and get in separate cars to
etected.
location, DOMINGO drove the UC
meeting location, where they
ance of their attack. DOMINGO
t of the location to put into the
was arrested by the FBI.
29
Vix CONCLUSION
76. For the reasons described above, I respectfully submit
there is probable cause to issue the requested criminal
complaint and arrest warrant.
a ; etts,TASHA COOLIDGE, Special AgentFEDERAL BUREAU OF INVESTIGATION
methis(ito and sworn before
me this Faasy of April, 2019.
i5! NalaUNITED STATES MAGISTRATE JUDGE
30