Meyerhoff.information

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IN THE UNITED STATE S DISTRICT COURTFOR THE DISTRICT OF OREGO N

UNITED STATES O F AMERICA CR No. 06 bW7&l-A A)v. INFORMATION

STANISLAS GREGO RY ) [18 U.S.C. $ 5 371, 844(f), 844(i),MEY ERHO FF, aka '"Country Boy" ) 1366(a) and 21and "Jack", ))Defendant.

THE UNITED STATES ATTORNEY CHARGES:COUNT 1

CONSPIRACY TO COM MIT ARSON AND DESTRUCTION OF ENERGY FACILITYI. OBJECT OF THE CONSPIRACY

Beginning in October 1996 and continuing through October 2001, in the District ofOregon and elsewhere, defendants JOSEPHINE SUNSHINE O V E F W R , KEVIN TUBBS,STANISLAS GREGORY M EYERHOFF, DANIEL GERARD McGOW AN, JOSEPH DIBEE,REBECCA RUBIN, CHELSEA DAWN GERLACH, KENDALL TANKERSLEY, SUZANNESAVOIE, JONAT HAN CHRISTOPHER MARK PAUL, DARREN TODD THURSTON,NATH AN FRA SER EILOCK, and JOYANNA L. ZACHER, and unindicted co-conspirators

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JACOB JEREMIAH FERGU SON and WILLIAM C . RODGERS, and others, willfully andknowing ly conspired and agreed to comm it the following offenses against the United States:

to maliciously damage o r destroy, or attempt to dam age or destroy, by means offire or an explosive, any building, vehicle or other personal or real property inwhole o r in part owned o r possessed by, or leased to, the United States or anydepartment or agency thereof, in violation o f Title 18 , United States Code, Section

to maliciously damage or destroy, or attempt to dam age or destroy, by mean s of

fire or a n exp losive, any building, vehicle or other real or personal p roperty usedin interstate commerce o r in any activity affecting interstate commerce, inviolation of Title 18, United States Code, Section 844(i); andto knowingly and w illfully damage and attempt to d amage the property of an energy

facility of the United States involved in the transmission and distribution of electricity, inan amount exceeding or which would have exceeded $100,000, in violation of Title 18,United States Code, Section 1366(a).11. MANN ER AND MEANS OF THE CONSPIRACY

The foregoing objects of the conspiracy were to be accompliished in the following mannerand means by the above-listed defendants and others at various times during the co urse of theconspiracy:

1. Certain of the defendants and others joined together in a group they called the"Family." This "Family" was what is comm only known as a "cell" of groups and movemen ts



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publicly named and described by certain of the defendan ts and others as the Earth LiberationFront (ELF), the Animal Liberation Front (ALF), and other names.

2. The general purposes of the conspiracy were to influence and affect the conduct ofgovernment, commerce, private business and others in the civilian population by means of force,violence, sabo tage, mass destruc tion, intimidation and coercion, and by similar mea ns to retaliateagainst the conduct of government, commerce and private business. To a chieve these purposes,the conspirators committed and attempted to comm it acts dangerous to human life and propertythat constituted violations of the criminal laws of the United S tates and of individual states.

3. Certain of the defendants and others targeted for arson buildings, vehicles andother real and personal property owned, possessed, and leased by tlhe United Sta tes and itsdepartments and agencies.

4. Certain of the defendants and others targeted for arson buildings, veh icles andother real and personal prope rty used in interstate co mm erce and in activities affecting interstatecommerce.

5 . Certain of the defendants and another person targeted for willful damage anenergy facility of the United States involved in the transm ission and distribution of electricity, inan amount exceeding or which would have exceeded $100,000.

6. Certain of the defendants and others conducted and participated in meetings toplan arsons and other dama ge of the targeted sites. Seve ral of these mee tings were called "BookClub" mee tings by the defendants and others and occurred at distant locations. Th e "Book Club"meetings covered subjects such as lock-picking, computer security, encrypted messaging,



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reconnaissance of targets, and manufacture of timing devices to initiate improvised incendiarydevices.

7. Certain of the defendants and others conducted research and surveillance of sitestargeted for arson and other dam age.

8. In discussing their actions among themselves, certain of the defendants and othersused code words, code names, and n icknames.

9. Certain of the defendants and others designed and constructed destructive deviceswhich functioned as incendiary bomb s to ignite fires and destroy the targets.

10. Certain of the defendants and others provided transportation to the sites targetedfor arson and other dam age.

11. Certain of the defendan ts and others dressed in dark clothing, wore masks andgloves and otherwise disguised their appearance.

12. Certain of the defendants and others acted as "lookouts" to ensure secrecy as thecrimes were carried o ut.

13. Certain of the defendan ts and others placed destructive devices and accelerants atsites targeted for arson and ignited or attempted to ignite the devices and accelerants.

14. Certain of the defendants and others, by means of fire and explosives, maliciouslydamaged and destroyed, and attempted to damage and destroy, buildings, vehicles and other realand personal property owne d and possessed by the U nited States and its departments andagencies.

15. Certain of the defendants and others, by means o f fire and explosives, maliciously



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damaged and destroyed, and attempted to damage and destroy, buildings, vehicles and o ther realand personal property used in interstate commerce and in activities affecting interstatecommerce.

16. Certain of the defendants and another person w illfully damaged and attempted todamage the property o f an energy facility of the United States involved in the transmission anddistribution of electricity, in an amou nt exceeding or which w ould have exceeded $10 0,000.

17. In some o f the arsons and attempted arsons, certain of the defendants and otherspainted messages on the walls of the targets, including "Earth Liberation Front," "ELF" andrelated names and statements concerning the purposes of the crimes.

18. After the arsons, attempted arsons and other crimes, certain of the defendants andothers provided transportation away from the scenes of the crimes.

19 . After the arsons, attempted arsons and other crimes, certain of the defendants andothers destroyed, buried, hid and otherwise disposed o f physical evidence used in thecomm ission of the crirnes.

20. After the arsons, certain of the defendants and others publicized and promoted theresults of the fires by rneans of written press releases and co mm uniques attribu ting the arsons tothe Earth Liberation Front (ELF), the Animal Liberation Front (ALI;) and related groups, andstating the purpo ses of'the arsons.

2 1. Before, during and after the arsons, attempted arsons and other crimes, certain of

the defendants and others agreed and took an oath amo ng themselves never to reveal to lawenforcement authorities or to anyone else outside "the Family" the identity of the conspiratorsand participants in the arsons, attempted arsons and other crimes.



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22 . Before, during and after the arsons, attempted arsons and other crimes, certain ofthe defendants and others agreed among themselves to conceal or destroy any evidenceconnecting them to the arsons, attempted arsons and o ther crimes.

23 . Before, during and after the arsons, attempted arsons and o ther crimes, certain ofthe defendants and others possessed and/or used false identification documents in order toconceal their true identities.

24. After the arsons, attempted arsons and other crimes, certain of the defendants andothers fled and secreted themselves in foreign countries in order to avoid detection and arrest bylaw enforcement authorities in the United States.111. OV ER T AC TS

In order to c an y out the ob jects of the conspiracy, defendants and other personscommitted various ovlert acts within the District of Oregon and elsewhere, including but notlimited to the following:

1. On or about O ctober 28, 1996, in Marion Cou nty, Oregon, defendant JOSEPHINESUNSHINE OV ERAKER and JACOB JEREMIAH FERGU SON unlawfully and willfullycaused and aided, abetted, counseled, commanded, induced, and procured the attempt to dam ageor destroy, by means of fire and an explosive, a building and o ther real and personal propertyown ed and possessed lby the United States and the United States Forest Serv ice of theDepartment of Agriculture, located at the Detroit Ranger Station on the W illamette National

Forest.



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l a . At a time prior to October 28, 1996 , defendant JOSEP HINE S UNS HINEOVER AKER and JACOB JERE MIAH FERGUS ON prepared and tested a time-delayedincendiary device.

lb . On or about October 28, 1996, defendant JOSE PHINE SUNSH INE OVER AKERand JACOB JERE MIA H FER GUS ON drove to the U.S. Forest Service Detroit Ranger Station inMarion County, Oregon, with an incendiary device which was placed o n the roof of a U.S. ForestService building. That incendiary device failed to function.

lc . On or about October 28, 1996, defendant JOSEPHINE SUNSH INE OVE RAKERspray-painted graffiti on the sides of a U.S. Forest Serv ice building and vehicles which includedthe words "Earth Liberation Front."

2. On or about October 28, 1996 in Marion County, Oregon, defendant JOSEPH INESUNSHINE OVERAKER and JACOB JEREMIAH FERGUSON unlawfully and willfullycaused and aided, abetted, counseled, commanded, induced, and procured the maliciousdamag ing and destroymg, by means of a fire and an explosive, a vehicle and other real andpersonal property owned and possessed by the United States and the United S tates Forest Serviceof the Department of Agriculture, located at the D etroit Ranger Station on the W illametteNational Forest.

2a . On or about October 28, 1996, defendant JOSEPHINE SUNSH INE OVE RAKE Rand JACOB JEREMIAH FERG USO N intended and caused fire darnage to a U.S. Forest Service

vehicle.3. On or about October 30, 1996, in Lane County, Oregon, defendants JOSEPHINE

SUNSHINE OVERAK ER, KEVIN TUBBS, and JACOB JEREMIAH FERGUSO N unlawfully



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and willfully caused and aided, abetted, counseled, comm anded, induced, and procured themalicious dam aging and destroymg, by means of fire and an explosive, of a building and otherreal and personal property own ed and possessed by the United States and the United S tatesForest Service of the Department of Agriculture, located at the Oakridge Ranger Station on theWillamette National Forest.

3a. On or about October 30, 1996, in Lane County, Oregon, defendants JOSE PHIN ESUNSHINE OVERAISER, KEVIN TUB BS, and JACOB JEREMIAH FERGU SON drove to theU.S . Forest Service Oakridge Ranger Station, and set fire to the Rang er Station.

3b. On or albout October 30, 1996, in Lane County, Oregon, defendants JOSE PHIN ESUNSHINE OVERAKER, KEVIN TUBBS, and JACOB JEREMIAH FERG USON , whileleaving the parking lot of the U.S. Forest Service Oakridge Ranger Station, threw nails on to theparking lot in order to slow down responding em ergency vehicles.

3c. On or about October 30, 1996, in Lane County, Oregon, defendants JOSE PHIN ESUNSHINE OV ERA KJR , KEVIN TUBBS, and JACOB JEREMULH FERGUSON , whileleaving the U.S. Forest Service Oakridge Ranger S tation and driving westbound on Highway 58towards Eugen e, Oregon, discarded their gloves in a reservoir near the Lowell Bridge.

4. On or albout July 21, 1997, at Redm ond, Deschutes County, O regon, defendantsKEVIN TUBBS, JOSEPH DIBEE, JONATHAN CHRISTOPHER MA RK PAUL, JENNIFERKOLA R, and JACOB JEREMIAH FER GUSO N unlawfully and willfully caused and aided,abetted, counseled, comm anded, induced, and procured the malicious dam aging and destroying,by means o f fire and an explosive, of a building and o ther real and personal property used in



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interstate commerce and in activities affecting interstate commerce, at Cavel West, Inc., 1607 SERailroad, Redm ond, Oregon.

4a . Approximately one week prior to the July 21, 1997 arson at Cavel West, Inc.,defendants KEVIN TUBBS, JONATHA N CHRISTOPHER MA RK PAU L, JOSEPH DIBEE,and JACOB JE REM IAH FE RGU SON w ent on a reconnaissance in order to locate a staging areawhere the participants could complete final preparations prior to committing the arson.

4b . Prior to the July 21, 1997 arson at Cavel West Inc., defendants JON AT HA NCHRISTOPHER MA RK PAU L, and JENNIFER KOLAR prepared a m ixture of soap and

petroleum products which was the fuel used in the time-delayed incendiary devices.4c. On or about July 21, 1997, defendants KEV IN TUBB S, JOSE PH DIBEE,

JONATHAN CHRISTOPHER M ARK PAUL, JENNIFER KOLAR, and JACOB JEREMIAHFERG USON drove to the previously chosen staging area near Cavel West, Inc., and upon arrivaldressed in dark clothing, mask s, an d gloves, and dug a hole at the staging area in wh ich to burytheir dark clothing upon completion of the arson.

4d. On or (aboutJuly 21, 1997, defendants KEVIN TUB'BS, JOSE PH D IBEE,JONATHAN CHRISTOPHER M ARK PAUL, JENNIFER KOL&R, and JACOB JEREMIAHFERGUSON completed a two-way radio check with one another aind confirmed their scannerand radios functioned properly.

4e. On or about July 2 1, 1997, defendants KEV IN TUBB S, JOSE PH DIBEE,JONATHAN CHRISTOPHER MARK PAUL, JENNIFER KOLAR, and JACOB JEREMIAHFERGUSON went to the location of Cavel West, Inc., to place time-delayed incendiary deviceson and about that location.



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4f. On or about July 21, 1997 , defendant JOSEPH D IBEE drilled holes through thewall of the Cavel West, Inc. facility so as to allow fuel to be poured directly into the building.

4g. On or about July 21, 1997, defendants KEVIN TU BBS, JOSEPH D IBEE,JONATHAN CHRISTOPHER MARK PAUL, JENNIFER KOLAR, and JACOB JEREMIAHFERG USO N, upon placing the time-delayed incendiary devices at Cav el West, Inc., traveledback to the staging area, removed their dark clothes and shoes, placed them in the hole, pouredacid on the clothing in the hole and then buried the items.

4h. On or about July 26, 1997, certain defendants in the Cavel West arson issued awritten com munique attributing the fire to the Animal Liberation Front (A LF) and the Equineand Zebra Liberation Front. Th e communique was publicized by Craig Rosebraugh of theLiberation Collective in Portland, Oregon.

4i . Approx imately three years after July 21, 19 97, defendant JOSEP H D IBEE andJENNIFER LYNN KOLAR contacted defendant KEVIN TUB BS and told KEVIN TUBBS toreturn to the staging area and retrieve the buried clothes.

5 . O n or about Novem ber 30, 1997, in Harney County, Oregon, defendantsJOSEPHINE SUNSHINE OVERAKER, KEVIN TUBBS, JACOB JEREMIAH FERGUSON,REBE CCA RU BIN, and unindicted co-conspirator WILLIAM C . RO DG ERS unlawfully andwillfully caused and aided, abetted, counseled, comman ded, induced, and procured the m aliciousdamaging and destroying, by means o f fire and an explosive, of buildings and other real and

personal property ow ned and possessed by the United S tates and the Bureau o f LandManagement of the Department of the Interior, located at the Wild Horse and Burro Facility,Bum s, Harney County, Oregon.

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5a . Approximately three months prior to November 30, 1997, defendantsJOSEPHINE SUNSHINE OVERAKER, JACOB JEREMIAH FER GUSON, KEVIN TUBBS,and unindicted co-conspirator WILLIAM C. ROD GER S did a reconnaissance at and near theWild Horse and Burro Facility, to prepare themselves for the arson and horse release.

5b. Sometime prior to November 30,1 997 , defendant JOSEPHINE SUNSHINEOVERA KER and JACO B JEREM IAH FER GUSON obtained five-gallon, white plastic bucketsand the fuel to be used in making time-delayed incendiary devices.

5c . Sometim e prior to Novem ber 30, 1997, persons known a nd unknown to the Grand

Jury prepared the five-gallon plastic bu ckets by wiping the bucke ts to ensure all fingerprints wereremoved, and painted them with black spray paint.

5d . Sometim e prior to November 30, 1997, defendants JOSEP HINE SUN SHINEOVERAKER, KEVIN TUBBS, JACOB JEREMIAH FERGUSON, R EBECC A RUBIN, andunindicted co-conspirator WILLIAM C. ROD GER S obtained additional components andassembled time-delayed incendiary devices, which were com posed of kitchen timers, matches,sponges, model rocket igniters, one-gallon jugs filled with fuel and five-gallon buckets whichcontained fuel.

5e. On or about Novem ber 30, 1997, defendants JOSEP HINE SUN SHINEOVERAKER, KEVIN TUBBS, JACOB JEREMIAH FERGUSON, REBEC CA RUBIN, andunindicted co-conspirator WILLIAM C . RODGE RS arrived at the Wild H orse and BurroFacility, cut the lock on the front gate, released horse s and burros, placed time -delayed incend iarydevices in and around the facility and left the area.



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5f. On or about Decem ber 5, 1997, certain defendants in the Wild Horse and BurroFacility arson issued a comm unique attributing the fire and horse release to the Earth LiberationFront (ELF) and the Animal Liberation Front (ALF). The comm unique was publicized by CraigRosebraugh of the L iberation C ollective in Portland, Oregon.

6. On or about Ju ne 2 1, 1998, at Olympia, W ashington, in the W estern District ofWashington, defendants JOSEPHINE SUNSHINE OVE RAKE R, KEVIN TU BBS, JACOBJERE MIAH FERG USON , JOSEP H DIBEE, and unindicted co-conspirator WILLIAM C.ROD GER S willfully caused and aided, abetted, counseled, commanded, induced, and procured

the malicious dam aging and destroying, by means o f fire and an explosive, of a building andother real and personal property leased and possessed by the United States and the Animal, Plantand Health Inspection( Servic e (APHIS) of the Departm ent of Agricultu re, located at the NationalWildlife R esearch Facility, 9701 B lomberg Street SW , Olympia, Vrashington.

6a. Approximately two weeks before June 21, 1998, defendants KEVIN TU BB S,JOSEPH D IBEE, and unindicted co-conspirator JACOB JEREMIAH FER GUS ON met inOlympia, Washington, to discuss plans for the APHIS arson, and agreed at that time there wouldbe a second and simultaneous arson committed when the APHIS arson was to occur.

6b. At a tiime prior to June 2 1, 1998, defendant JO SEPH INE SUN SHINEOVERA KER and unindicted co-conspirator JACOB JEREMIAH FER GUSO N prepared five-gallon buckets by wiping the buckets to remove any fingerprints, and obtained fuel for theAPHIS arson.

6c. At a time prior to June 21, 1998, defendant KE VIN TU BBS utilized falseidentification to acquire a van which was used in the APHIS arson.



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6d. On or about June 2 1, 1998, defendant JOSEPHINE SUN SHIN E OVERA KER,while attempting to steal items in preparation for the APHIS arson, was arrested by authoritiesfor shoplifting.

6e. On or about June 21, 1998, defendant KEVIN TUBBS and JACO B JEREMIAHFERG USO N transferred five-gallon buckets of fuel to be used in the APH IS arson fro m a vanpurchased by KEV IN TU BB S to a vehicle owned by unindicted co-conspirator WILLIAM C.RODGERS.

6f. On or about June 21, 1998, defendant KEVIN TUB BS and unindicted co-conspirators JACO B JEREMIAH FERGU SON and WILLIAM C. ROD GERS drove to theAPHIS facility and placed five-gallon buckets filled with fuel at locations at and around thefacility, and ignited the fuel-filled buckets by hand.

6g . On o r about June 22, 1998, certain defendants in the APHIS arson issued acomm unique attributing the fire to the Earth Liberation Front (ELF) and th e Anima l LiberationFront (ALF). The cornmunique was publicized by Katie Fedor of the North American ALF PressOffice.

6h. At a time after June 22, 1998, defendant KEVIN T UBB S assisted in the disposalof the van used in the APHIS arson.

7. In about Septemb er 1998, at Rock Springs, Wyoming, in the D istrict of Wyom ing,defendants KEVIN TU BBS, REB ECCA RUBIN, and unindicted co-conspirators JACOBJEREMIAH FERGUSON, WILLIAM C. RO DG ERS, and others, unlawfully and willfullycaused and aided, abetted, counseled, comm anded, induced, and procured the attempt to damageor destroy, by m eans of fire and an explosive, a building and other real and personal property

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owned and possessed by the United States and the Bureau of Land Management of theDepartment of the Interior, located at the W ild Horse Holding Facility, Rock Springs, Wyoming.

7a. In or about September 1998, defendants KEV IN TUBB S, REBEC CA RU BIN,and unindicted co-conspirators JACO B JEREMIAH FERGU SON and WILLIAM C. RO DGERSarrived at the staging area near Rock Springs, Wyoming, assigned roles, prepared time-delayedincendiary devices, and m ade preparations for the arson, when a law enforcement officer madeinquiry as to their presence at that location .

7b . In or about September, 1998, defendants KEV IN TUB BS, REBEC CA RU BIN,and unindicted co-conspirators JA COB JEREMIAH FE RGU SON, W ILLIAM C. RODG ERS,and others, buried the time-delayed incendiary devices in an attempt to avoid detection.

8. On o r about October 11, 1998, at Rock Springs, Wyom ing, in the District ofWyoming, defendants JOSEPHINE SUNSHINE OVERA KER, KEVIN TU BBS, STANISLASGREGORY MEYERIIOFF, REBECCA RUBIN, CHELSEA DAW N GERLACH, andunindicted co-conspirators JACOB JEREM IAH FER GU SON and 'WILLIAM C. RODGE RSunlawfully and willfully caused and aided, abetted, counseled, com mand ed, induced, andprocured the attempt to damage and destroy, by mean s of fire and an explosive, buildings andother real and personal property owned and possessed by the U nited S tates and the Bureau ofLand Management of the Department of the Interior, located at the Wild Horse Holding Facility,Rock Springs, Wyoming.

8a . On or about October 11, 1998, defendants JOSEPHINE SUN SHINEOVERAKER, KEVIN TUBBS, STANISLAS GREGORY MEYERHOFF, REBECCA RUBIN,CHELSEA D AW N G ERLAC H, and unindicted co-conspirators JACO B JEREM IAH



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FERG USON and WILLIAM C . ROD GER S brought digital timers, containers of fuel, two-wayradios and a scanner, to a staging area near the Wild Horse Holding Facility.

8b. On or about October 11, 1998, at Rock S prings, Wyom ing, defendantsJOSEPHINE SU NS HN E OVERAKER, KEVIN TUBBS, STANISLAS GREGORYMEYERH OFF, REBECCA RUBIN, CHELSEA DAW N GERLA CH, and unindicted co-conspirators JACO B JEREMIAH FERGUSON and WILLIAM C . RODGE RS went to the WildHorse Holding Facilit:~, nd began the release o f horses and the placing of incendiary devices inand about the facility.

8c. On or about October 11, 1998, at Rock Springs, Wyoming, defendantsJOSEPHINE SU NS HN E OVERAKER, KEVIN TUBBS, STANISLAS GREGORYMEYER HOFF, REBECCA RUBIN, CHELSEA DAW N GERLA CH, and unindicted co-conspirators JACOB JEREMIAH FERGUSON and WILLIAM C . IiODGE RS hid timingdevices in large rock out-cropping s near the W ild Horse Ho lding Facility, after hearing on theirscanner that police had been disp atched to their location.

8d . On or a~boutNovember 13, 1998, certain defendants in the W ild Horse HoldingFacility attempted arson issued a statem ent attributing responsibility for the horse release andattempted arson to the Animal Liberation Front (ALF).

9. On or a.bout Octob er 19, 1998, in Eagle County, Co lorado, defendantsJOSEPHINE SUNSHINE OVERAKER, KEVIN TUBBS, STANISLAS GRE GOR Y

MEYER HOFF, REBECCA RUBIN, CHELSEA DAW N GERLA CH, and unindicted co-conspirators JACOB JEREMIAH FERGUSON and WILLIAM C. ROD GERS unlawfully andwillfully caused and a~ d ed , betted, counseled, commanded, induced, and procured the malicious



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damaging and destroying, by means of fire and explosives, of buildings and other real andpersonal property used in interstate commerce and in activities affecting interstate commerce, atthe Vail S ki Facility.

9a. On or about October 21, 1998, certain defendants in the Vail arson issued acomm unique attributing the fire to the Earth Liberation Front (ELF).

10. On or about D ecember 22, 1998, at Medford, Jackson County, Orego n, defendantsKENDALL TANKERSLEY, KEVIN TUBBS, REBECCA RUBIN, and unindicted co-conspirator JACO B JEREM IAH FERGUSO N unlawfully and willfully caused and aided,abetted, counseled, comm anded, induced, and procured the attempt to dam age or destroy, bymeans of fire and an explosive, a building and other real and personal property used in interstatecomm erce and used in activities affecting interstate co mmerce, namely, an office building and itscontents at U.S. Forest Industries, 261 1 Wh ittle Avenue, M edford, Jackson County, Oregon.

10a. A few weeks prior to December 22, 1998, defendants KEN DAL LTANK ERSLEY, KEVIN TUBBS, REBECCA R UBIN, and unindicted co-conspirator JACOBJEREM IAH FER GU SON performed a reconnaissance and "dry n m " for the arson at the U.S.Forest Industries building in M edford, Oregon.

l o b . On or a~boutDecemb er 22, 1998, at Medford, Jackson County, O regon, defendantsKENDALL TANKER SLEY, KEVIN TUBBS, REBECCA R UBIN, and unindicted co-conspirator JACOB JEREMIAH FERG USO N placed time-delayed incendiary devices at andabout the U.S. Forest Industries building.

10c. Prior to Dec emb er 27, 1998, after placement of the time-delayed incendiarydevices at the U.S. Forest Industries building, defendant KEND ALL TA NK ERSLE Y and



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unindicted co-conspirator JACO B JERE MIAH F ERG USO N searched the media and found nomention of the burning of the U.S. Forest Industries building.

10d. Between December 22 and 27, 1998, defendant KENDALL TANKERSLEY andanother person returned to the U.S . Forest Industries building to check on the destruc tive devices.

11. On or about Dec ember 27, 1998, at Medford, Jackson County, Oregon, defendantKENDALL TANK ERSLEY and unindicted co-conspirator JACO B JEREMIAH FERGUSO Nunlawfully and willfully caused and aided, abetted, counseled, commanded, induced, andprocured the m alicious damaging and destroying, by mea ns of fire ;and an ex plosive, of a building

and other real and personal property used in interstate comm erce arid used in activities affectinginterstate com merce, iiamely, an office building and its contents at U.S. Forest Industries, 261 1Whittle Aven ue, Medford, Jackson County, Oregon.

11a. On or about Decem ber 27, 1998, defendant KEN DAL L TAN KER SLEY andunindicted co-conspirator JAC OB JER EM IAH FE RGU SON returned to the U.S. ForestIndustries building, placed a new time-delayed incendiary device a1 or about the building, and leftthe area.

I 1b. On or about December 27, 1998, defendant KEND ALL TA NKE RSLE Y andunindicted co-conspirator JACOB JE REM IAH FE RGU SON traveled to Dunsm uir, California, toavoid detection.

11c. On or about December 27, 1998, defendant KEND ALL T ANKER SLEYregistered under the false name of T eresa Capelli in the Ceda r Lodge Motel in D unsmuir,California.

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1 d . On or about Janua ry 16, 1999, certain defendants in the U.S. Forest Indu striesarson issued a comm uniqu e attributing the fire to the Earth Liberation Front (ELF). Thecommunique was publicized by Craig Rosebraugh of the Liberation Collective in Portland,Oregon.

12. On or about M ay 9, 1999, at Eugene, Lane County, Oregon, defendantsJOSEPHINE SUNSHINE OVERAKER, KEVIN TUBBS, STANISLAS GREGORYMEYER HOFF, CH ELSEA D AW N GE RLACH, and unindicted co-conspirator JACOBJEREM IAH FERGU SON, and others, unlawfully and willfully caused and aided, abetted,

counseled, commanded, induced, and procured the m alicious dam aging and destroying, by meansof fire and an explosive, o f a building and other real and personal prop erty used in interstatecommerce and in activities affecting interstate commerce, at Childers Meat Company, 29476Airport Road, Eugene., Lane County, Oregon.

12a. On or about May 9, 1999, defendants JOSEPHINE SUNSH INE OVERAK ER,KEVIN TUBBS, STANISLAS GREGORY MEYERHOFF, CHELSEA DAW N GERLACH,and unindicted co-conspirator JACO B JERE MIAH FER GU SON arid another prepared five-gallon buckets, timers and fuel for the arson which was to occur at the Ch ilders Meat Company,Eugene, Oregon.

12b. On or about May 9, 1999, defendants JOSEPHINE SUNSH INE OVERAKER,KEVIN TUBBS, STANISLAS GREGORY MEYERHOFF, CHELSEA DAWN GERLACH, andunindicted co-conspirator JACO B JER EMIAH FERG USON and another traveled to the ChildersMeat Company and placed one time-delayed incendiary device near the front of the officebuilding and placed another such device at the back of the building near a gas meter.



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12c. On or about May 27 , 1999, certain defendants in the Ch ilders arson issued acomm unique attributing the fire to the Animal Liberation Front (ALF). Th e comm unique waspublicized by the ALF Frontline Information Service.

13 . On or about December 25, 1999, at Monmouth, Polk County, Oregon, defendantsJOSEPHINE SUNSHINE OVERAKER, STAN ISLAS GREG ORY MEYER HOFF, CHELSEADAWN GERLACH, and unindicted co-conspirator JACOB JEREMIAH FERGUSONunlawfully and willfully caused and aided, abetted, counseled, commanded, induced, andprocured the malic ious damaging an d destroying, by means o f fire and an explosive, of a buildingand other real and personal property used in interstate comm erce arid in activities affectinginterstate commerce, at the Boise Cascade Office, 450 North Pacific Avenue, Monmouth, PolkCounty, Oregon.

13a. On or about December 25, 1999, defendants JOSEPHINE SUNSHINEOVERAKER, STANISLAS GREGORY MEYERHOFF, CHELSEA DAW N GERLACH, andunindicted co-~onspir~atorACOB JEREMIAH FERGUSON prepared time-delayed incendiarydevices to be used at the Boise Cascade Office, and, after disguising the devices by wrappingthem in Christmas paper, transported the devices to the Boise C ascade Office location.

13b. On or about December 25, 1999, at Monmouth, Polk County, Oregon, defendantsJOSEPHINE SU NS HN E OVERAKER, STANISLAS GREGORY M EYERHOFF, CHELSEADAW N GER LAC H, and unindicted co-conspirator JACOB JER Eh4IAH FER GUS ON placed

time-delayed incendiary devices at and about the Boise C ascade Offic e building a nd left the area.13c. On or albout December 30, 1999, certain defendants in the B oise Cascade arson

issued a com mu nique attributing the fire to the Earth Liberation Front (ELF). Th e communique



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was publicized by C raig Rosebraugh o f the Liberation Collective in P ortland, O regon, and theNorth American ELF Press Office.

14. On or about December 30, 1999, in Deschutes County, Oregon, defendantsJOSEPHINE SUNSHINE OVERAKER, STANISLAS GREGORY MEYERHOFF, CHELSEADAW N GER LACH , and unindicted co-conspirator JACO B JEREMIA H FE RG USO N willfullydamaged and attempted to dam age the property of an energy facility of the United States, namely,a Bonneville Power A dministration tower, involved in the transmission and distribution ofelectricity near the City of Bend, O regon, in an amoun t exceeding or which w ould hav e exceeded$100,000.

15 . During 2000 and 2001, several of the defendants and others met in what theparticipants called "Book C lub" meetings. These meetings occurred in Eugene, Oregon; Tucson,Arizona; San ta Cruz , California; and Sisters, Oregon. The participants condu cted classes at thesemeetings in clandestine methods of committing direct actions, including the manufacture ofmechanical and electrical timing devices for setting off improvised incendiary devices,reconnaissance of targets, lock-picking, and com puter security.

16. On or about September 6,2 00 0, at Eugene, Lane County, Oregon, defendantsSTANISLAS GREGORY M EYERHOFF, KEVIN TUBBS and CHELSEA DAW N GERLACHunlawfully and willfully caused and aided, abetted, counseled, commanded, induced, andprocured the malicious dam aging and destroying, by means o f fire and an explosive, of a buildingand other real and personal property used in interstate comm erce and in activities affectinginterstate commerce, at the Eugene Police Department West University Public Safety Station,79 1 East 13thAvenue, Eugene, Oregon.



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16a. On or about September 6,20 00 , defendants STANISLAS GREGO RYMEYE RHOFF, KEVIN TU BBS and CHELSEA D AW N GERL ACH traveled to the EugenePolice Department West U niversity Public Safety Station and placed time-delayed incendiarydevices at and about the police station.

17. On or about January 2, 20 01 , at Glendale, Douglas County, Oregon, defendantsSTANISLAS GREGORY M EYERHOFF, KEVIN TUBB S, DANIEL GERA RD McGOWAN ,SUZANN E SAVO IE, and unindicted co-conspirator JAC OB JER EMIAH FERG USONunlawfully and w illfully caused and aided, abetted, counseled, commanded, induced, and

procured the malicious dam aging and destroying, by mean s of fire and an explosive, of a buildingand other real and personal property used in intersta te comm erce arid used in activities affectinginterstate comm erce, namely, a building and its contents located at Superior Lumbe r Company,2695 Glendale Valley Road, Glendale, Douglas County, Oregon.

17a. On or about January 2,20 01 , defendants STANISLAS GR EGO RYMEYERHOFF, KEVIN TUBBS, DANIEL GERAR D McGOW AN, SUZANNE SAVOIE, andunindicted co-conspirator JAC OB JER EMIA H FERG USO N traveled in separate vehicles to apredetermined staging area at a rest area located just north of the town of Glendale, Oregon, onInterstate 5, where they dressed in dark clothing and put o n their radio earpieces and masks.

17b. On or about January 2,2 001 , defendants STANISLAS GREGOR YMEYERHOFF, KEVIN TUBBS, DANIEL GERARD M cGOWAN, SUZANNE SAVOIE, andunindicted co-conspirator JACO B JEREM IAH FE RGU SON traveled to the Superior LumberCom pany building , set up lookouts, positioned the "pick-up" vehicle , placed the time-delayedincendiary devices, and returned to the staging area.



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17c. On or about January 2,2001, defendants STANISLAS GREGORYMEYERHO FF, KEVIN TUBBS, DANIEL GERARD McGO WA N, SUZANN E SAVOIE, andunindicted co-conspirator JA COB JEREMIAH FERGU SON, upon returning to the staging area,changed their clothing and disposed of their dark clothing.

17d. On or about January 6 ,20 01 , certain defendants in the Superior Lumber Companyarson issued a comm uniqu e attributing the fire to the Earth Liberation Front (EL F). Thecommunique was publicized b y Craig Rosebraugh of the North A merican ELF Press O ffice.

18. On or about March 30, 2001, at Eugene, Lane County, Oregon, defendants

STANISLAS GREG ORY MEYERHO FF, KEVIN TUBBS, NATH AN FRASER BLO CK,JOYAN NA L. ZACHER, and unindicted co-conspirator WILLIAM C. RODGERS, unlawfullyand willfully caused and aided, abetted, counseled, comman ded, induced, and procured themalicious damaging and destroying, by means of fire and an explosive, of vehicles and otherpersonal property used in interstate comm erce and in activities affecting interstate com merce, atJoe Romania Chevrolet Truck Center,1425 Walnut Street, Eugene, Oregon.

18a. On or about March 30,20 01, defendants STAN ISLAS GREGO RYMEYERHOFF, K E V N TUBBS, NATHAN FRASER BLOCK, JOYANNA L. ZACHER, andunindicted co-conspirator W ILLIAM C . RODGERS traveled to Jot: Rom ania Chevrolet TruckCenter and stationed KEVIN TU BBS and JOYA NN A L. ZACHER as lookouts, while the othersplaced an incendiary dev ice and plastic con tainers filled with gaso line underneath the vehiclesand connected the vehicles and containers with rolled-up sheets soaked in gasoline.



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18b. On or about March 31,2 00 1, certain defendants in the Romania C hevrolet arsonissued a comm unique which was publicized by Craig Rosebraugh o f the North A merican ELFPress Office.

19. On or about May 2 1,2 00 1, at Clatskanie, Colum bia County, Oregon, defendantsSTANISLAS GREGOR Y MEYERHOFF, KEVIN TUBBS, DANIEL GE RARD M cGOWAN,CHELSEA DAWN GERLACH, NATHAN FRASER BLOCK, JOYANNA L. ZACHER,SUZA NNE S AV OIE, and unindicted co-conspirator WILL IAM C. ROD GER S unlawfully andwillfully caused and aided, abetted, counseled, commanded, induced, and procured the malicious

damaging and destroying, by means o f fire and an explosive, of buildings, vehicles and other realand personal property used in interstate comm erce and in activities affecting interstatecomm erce, at Jefferson P oplar Farm, 791 14 Collins Road, C latskanie, Colum bia County,Oregon.

19a. At a time prior to May 2 1,20 01, defendants STANISLAS GREG ORYMEYERHOFF, NATHAN FRASER BLOCK, JOYANNA L. ZACHER, CHELSEA DAW NGERLACH , DANIEL G ERAR D McGO WAN , and unindicted co-conspirator W ILLIAM C.ROD GERS participated in a meeting in which it was decided by those present that two arsonswould be carried out iit the same time, one at the Jefferson Poplar Farm in Clatskanie, Oregon,and the other at the University of Washington Horticulture Center in Seattle, Washington.

19b. At a time prior to M ay 2 1, 20 01, defendants STANISLAS GREG ORYMEYERHOFF, CHELSEA DAWN GERLACH, DANIEL GERARD M cGOWAN , KEVINTUBBS, SUZANNE SAVOIE, and unindicted co-conspirator JACOB JEREMIAH FERGUSONperformed a reconnaissance for the arson at the Jefferson Poplar Farm.



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19c. On or about May 2 1,2 00 1, defendants STANISLAS GREG ORY M EYERHO FF,DANIEL GERARD McGOWAN , NATHAN FRASER BLOCK, JOYANNA L. ZACHER, andSUZA NNE SAV OIE traveled to Jefferson Poplar Farm.

19d. On or about May 2 1, 20 01, defendants STANISLAS GR EGORY MEYE RHOFF,DANIEL GERA RD McGOW AN, NATHAN FRASER BLOCK, and JOYANNA L. ZACHERplaced time-delayed incendiary devices at several locations at and around the facility, with one ofthe locations being adjacent to a large propane gas tank.

19e. On or about May 21 ,20 01 , certain defendants in the: Jefferson Poplar Farm arson

spray-painted graffiti at the site attributing the action to the Earth Libe ration Front (ELF).19f. On or ;about Jun e 1, 200 1, certain defen dants in the .Jefferson Poplar F arm arson

issued a communique attributing the fire, along with the University of Washington fire describedbelow, to the Earth Liberation Front (ELF). Th e com mun ique wa s publicized by CraigRosebraugh of the North Am erican ELF Press O ffice.

20 . On or about M ay 21, 2001, at Seattle, Washington, in the We stern District ofWashington, defendants STAN ISLAS GREGOR Y MEYERH OFF., CHELSEA DAW NGER LAC H, unindicted co -conspirator WILLIAM C . ROD GER S, and other persons unlawfullyand willfully caused and aided, abetted, counseled, commanded, induced, and procured themalicious damaging and destroying, by means of fire and an explosive, of a building and otherreal and personal property used in interstate commerce and in activities affecting interstatecomm erce, at the University of Washington H orticulture Center, Seattle, Washington.

20a. At a time prior to May 2 1,2 00 1, defendant STAN ISLAS GRE GOR YME YER HOF F, uninclicted co-conspirator WILLIAM C. ROG ERS and other persons performed



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one or m ore reconnaissances of the University o f Washington Hortnculture Center, Seattle,Washington.

20b. On or about June 1, 20 01 , certain defendants in the University of Washingtonarson issued a comm unique a ttributing the fire, along with the Jefferson Poplar Farm firedescribed above, to the Earth Liberation Front (ELF). The com munique w as publicized by CraigRosebraugh of the North A merican ELF Press Office.

21. On or before May 28,2 001 , defendant STANISLAS GREG ORY MEY ERHOFFand unindicted co-conspirator WILLIAM C. ROD GER S authored and published a document

entitled "Setting Fire with Electrical Timers, an Earth Liberation Front Guide" in order to exposeto a widespread audience their methods o f operation and the design of the "Cat's Cradle"incendiary device so that it would no longer be unique to the arsons committed by "the Family,"thereby hindering detection by law en forcement.

22 . On o r about October 15, 2001, at Litchfield, California, in the Eastern District ofCalifornia, defendants STANISLAS GREGOR Y MEY ERHOFF, JOSEPH DIBEE, REBECC ARUBIN, KEVIN TUEIBS, CHELSEA DAWN GERLACH, DARR EN T ODD THURSTON,unindicted co-conspirator WILLIAM C . RODG ERS , and other persons unlawfully and willfullycaused and aided, abetted, counseled, comm anded, induced and procured the m alicious damagingand destroying, by me ans o f fire and explosives, o f building s and other real and personal propertyowned and possessed by the United States and the Bureau of Land M anagement o f theDepartment of the Interior, located at the Wild Horse Facility, Litchfield, California.



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22a. On or about October 1 5,20 01, defendant STANISLAS GR EGOR YME YER HOF F and other persons placed time-delayed incendiary devices at and about theLitchfield Wild Horse Facility.

22b. On or about October 30, 2001, certain defendants in the Litchfield Wild HorseFacility arson issued a comm unique attributing the fire to the Earth Libera tion Front (ELF). Th ecomm unique was publicized by David B arbarash at the North Ame rican ALF Press Office.

All of the above conduct violated Title 18, United States Code, Section 371.COUNT 2

ARSON - C HIL DE RS M E AT C O M P r WOn o r about M ay 9, 1999, at Eugene, Lane County, Oregon., in the D istrict of Oregon,

defendants JOSEPHINE SUNSHINE OVERA KER, KEVIN TUBBS, STAN ISLAS GREG ORYMEYE RHOFF and CHELSEA DAW N GERLACH, and other persons known to the Grand Jury,unlawfully and w illfully caused and aided, abetted, counseled, comm anded, induced, andprocured the m alicious d am aging and destroying, by mea ns of fire (and an explos ive, of a buildingand other real and personal property used in interstate commerce arid in activities affectinginterstate comm erce, at Childers Meat Company, 29476 A irport Road, Eugene, Oregon; all inviolation of Title 18, lJnited States Code, Sections 844(i) and 2.

COUNT 3ARSON - BOISE CASCADE

On or about Dece mber 25, 1999, at Monmouth, Polk County, Oregon, in the District ofOregon, defendants JOSEPHINE SUNSHINE OVER AKER, ST ANISLAS GREG ORYMEYE RHOFF and CH ELSEA DA WN GERLA CH, and another person known to the Grand



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Jury, unlawfully and willfully caused and aided, abetted, counseled, commanded, induced, andprocured the malicious damaging and destroying, by means o f fire and an explosive, of a buildingand other real and personal property used in interstate comm erce and in activities affectinginterstate commerce, at the Boise Cascade Office, 450 North Pacific Avenue, Monrnouth, PolkCounty, O regon; all in violation of Title 1 8, United States Code, Se ctions 844(i) and 2.

COUNT 4DESTRUC TION OF AN ENERGY FACILITY - BPA TOWER

On or about Decem ber 30, 1999, in Deschutes Coun ty, Oregon, in the District of Oregon,defendants STANISLAS GREG ORY MEYERHO FF, JOSEPHINE SUNSH INE OVERAKER,CHEL SEA DA W N GER LACH , and others both known and unknown to the Grand Jury,know ingly and willfully dam aged and attempted to dam age the property of an energy facility ofthe Untied States, namely, a Bonneville Power Ad ministration tower, involved in thetransmission and distribution of electricity near the C ity of Bend, O regon, in an amountexceeding or which wou ld have ex ceeded $100,00 0; all in violation of T itle 18, United StatesCode, Section 1 366(a).

COUNT 5ARSON - EPD PUBLIC SAFETY STATION

On or about September 6, 2000, at Eugene, Lane County, Oregon, in the District ofOregon, defendants S'TANISLAS GREGORY MEYER HOFF, KE VIN TU BBS and CHELSEADAWN GERLACH unlawfully and willfully caused and aided, abetted, counseled, commanded,induced, and procured the malicious damaging and destroying, by means of fire and an explosive,of a building and other real and personal p roperty used in interstate comm erce and in activities



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affecting interstate commerce, at the Eugene P olice Department W est University Public SafetyStation, 791 East 13thAvenue, Eu gene, Lane County, Oregon; all in violation of T itle 18, UnitedStates Code, Sections 844(i) and 2.

COUNT 6ARSON - SUPERIOR LUMBER COM PANY

On or about January 2, 2001, at Glendale, Douglas County, in the District of Oregon,defendants STANISLAS GREGORY MEYE RHOFF, KEVIN TUWBS, DANIEL G ERAR DMcG OW AN and SU ZAN NE SA VOIE, unlawfully and willfully caused and aided, abetted,

counseled, commanded, induced, and procured the m alicious damaging and destroying, by meansof fire and an explosive, of a building and other real and personal property used in interstatecomm erce and used in activities affecting interstate comm erce, namely, a building and itscontents located at Su perior Lumber Company, 2695 G lendale Valley Road, Glendale, DouglasCounty, Oregon; all in violation of Title 18, United States Code, S ections 844(i) and 2.

COUNT 7ARSON .- ROMANIA CHEVROLET TRUCK CENTER VEHICLE

On or about March 30, 20 01 , at Eugene, Lane County, in the District of Oregon,defendants KEVIN TUBBS, STANISLAS GREGO RY MEYERH OFF, NATHAN FR ASERBLOC K, and JOYA NNA L. ZACHE R, unlawfully and willfully caused and aided, abetted,counseled, com mande:d, induced, and procured the malicious damaging and destroying, by meansof fire and an e xplosive, of a vehicle used in interstate comm erce and used in activities affectinginterstate comm erce, namely, a 2 001 Su burban, bearing Vehicle Identification Number3GNGK26U4 1G2O9 163, located at Ro ma nia Chevrolet T ruck C enter, 1425 Walnut Street,



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Eugene, Lane C ounty, Oregon; all in violation of Title 18, United States Code, S ections 844(i)and 2.

COUNT 8

ARSON - ROMANIA CHEVROLET TRUCK CENTER VEHICLEOn or about M arch 30, 2001, at Eugene, Lane County, in the District of Oregon,

defendants KEVIN TUBBS, STANISLAS GREGORY MEYERHOFF, N ATHAN FRASERBLOC K, and JOYA NN A L. ZACHE R, unlawfully and willfully caused and aided, abetted,counseled, commanded, induced, and procured the malicious damaging and des troyn g, by means

of fire and an explosive, of a vehicle used in interstate comm erce and used in activities affectinginterstate comm erce, namely, a 2001 T ahoe, bearing V ehicle Identification Number1GN EK l3T 7lR l54 86 6, located at Romania Chevrolet Truck Center, 1425 Walnut Street,Eugene, Lane C ounty, Oregon; all in violation of Title 18, United States Code, Sections 844(i)and 2.

COUNT 9ARSON .- ROMANIA CHEVRO LET TRUCK CENTER VEHICLE

On or about M arch 30, 2001, at Eugene, Lane County, in the District of Oregon,defendants KEVIN TUBBS, STANISLAS GREGORY MEYERH OFF, NATHA N FRASERBLOC K, and JOY AN NA L. ZACH ER, unlawfully and willfully caused and aided, abetted,counseled, comm anded, induced, and procured the malicious dam aging and destroying, by meansof fire and an explosive, of a vehicle used in interstate com merce and used in activities affectinginterstate c omm erce, namely, a 2001 Suburban, bearing Vehicle Identification Num ber3GNG K26G8 lG235 050, located at Romania Chevrolet Truck Center, 1425 Walnut Street,



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Eugene, Lane C ounty, Oregon; all in violation of Title 18, United States Code, Sections 844(i)and 2.

COUNT 10ARSON - ROMANIA CHEVROLET TRUCK CENTER VEHICLE

On or about M arch 30, 2001, at Eugene, Lane County, in the District of Oregon,defendants KEVIN TUBBS, STANISLAS GREGORY MEYER HOFF, NATHAN FRASERBLOCK, and JOYANNA L. ZAC HER , unlawfully and willfully caused and aided, abetted,counseled, commanded, induced, and procured the m alicious damaging and destroying, by means

of fire and an e xplosive, of a vehicle used in interstate commerce and used in activities affectinginterstate comm erce, namely, a 2001 Suburban, bearing Vehicle Identification Num ber3GNGK26G81G2O3 103, located at Rom ania Chevrolet Truck Cen ter, 1 425 W alnut Street,Eugene, Lane C ounty, Oregon; all in violation of Title 18, United States Code, Sections 844(i)and 2.


On or about March 30 ,20 01 , at Eugene, Lane County, in the District of Oregon,defendants KEVIN TUBBS, STANISLAS GREGORY MEYERHOFF, NATHA N FRASERBLOC K, and JOYANlVA L. ZAC HER , unlawfully and willfully caused and aided, abetted,counseled, comm anded, induced, and procured the m alicious damaging and destroying, by meansof fir e and an explosive, of a vehicle used in interstate commerce a nd used in activities affectinginterstate com merce, namely, a 2001 Suburban, bearing Vehicle Identification Number3GNF K16T3 lG19 7472, located at Rom ania Chevrolet Truck Center, 1425 Walnut Street,



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Eugene, Lan e County, Oregon ; all in violation of Title 18, United States Cod e, Sections 844(i)and 2.


On or about March 30, 2001, at Eugene, Lane County, in the District of Oregon,defendants KEVIN TUBB S, STANISLAS GREGORY M EYER HOFF, NATHAN FRA SERBLO CK, and JOYA NNA L. ZACHER , unlawfully and willfully caused and aided, abetted,counseled, commanded, induced, and procured the malicious damaging and destroying, by means

of fire and an explosive, of a vehicle used in interstate commerce and used in activities affectinginterstate commerce, namely, a 2001 Tahoe, bearing Vehicle Identification Number1GNEK l3TO 1 18 1082, located at Romania Chevrolet Truck Center, 1425 Walnut Street,Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, Sections 844(i)and 2.

COUNT 13ARSON .- ROMANIA CHEVROLET TRUCK CENTER VEHICLE

On or abo ut M:arch 30 ,2 00 1, at Eugene, Lane County, in thle District of Oreg on,defendants KEVIN TIJBBS, STANISLAS GREGORY MEY ERHOFF, NATHAN FRASERBLOCK, and JOYAN NA L. ZACH ER, unlawfully and willfully caused and aided, abetted,counseled, commanded, induced, and procured the malicious damaging and destroying, by meansof fire and an explosive, of a vehicle used in interstate commerce and used in activities affectinginterstate commerce, namely, a 2001 Tahoe, bearing Vehicle Identification N umber1GNEK 13T41R110162, located at Romania Chevrolet Truck Center, 1425 Walnut Street,

Page 3 1 - INFORMATION


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Eugene, Lane C ounty, Oregon; all in violation of Title 18, United States Code, Sections 844(i)and 2.


On or about M arch 30, 2001, at Eugene, Lane County, in the District of Oregon,defendants KEVIN TUBBS, STANISLAS GREGORY MEYERHOFF, N ATHAN FRASERBLOCK, and JOYANN A L. ZAC HER , unlawfully and willfully caused and aided, abetted,counseled, comm anded, induced, and procured the malicious dam aging and destroying, by means

of fire and an explosive, of a vehicle used in interstate comm erce and used in activities affectinginterstate comm erce, namely, a 2001 Tahoe, bearing V ehicle Identification Num ber1GNE K13T3 1 150960, located at Romania Chevrolet Truck C enter, 1425 Walnut Street,Eugene, Lane C ounty, Oregon; all in violation of Title 18, United States Code , Sections 844(i)and 2.


On or about March 30 ,20 01 , at Eugene, Lane County, in the District of Oregon,defendants KEVIN TTITBBS, STAN ISLAS GR EGO RY M EYE RHO FF, NAT HAN FRA SERBLOC K, and JOY ANN A L. ZAC HER , unlawfully and willfully caused and aided, abetted,counseled, comma nded, induced, and procured the m alicious damaging and destroying, by meansof fire and an explo sive, of a vehicle used in inte rstate comm erce aind used in a ctivities affectinginterstate comm erce, namely, a 2001 Suburban, bearing Vehicle Identification Num ber3GNFK16T7 1G228593, located at Roman ia Chevrolet T ruck Center, 1425 Walnut Street,



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Eugene, Lane County, Oregon; all in violation of Title 18, United S tates Code, S ections 844(i)and 2.


On or about March 30, 2001, at Eugene, Lane County, in the District of Oregon,defendants KEVIN TUBBS, STANISLAS GREGORY MEY ERHOFF, NA THAN FRASE RBLOCK, and JOYANNA L. ZACH ER, unlawfully and willfully caused and aided, abetted,counseled, commanded, induced, and procured the malicious damaging and destroying, by means

of fire and an explosive, of a vehicle used in interstate comm erce and used in activities affectinginterstate commerce, namely, a 2001 Tahoe, bearing Vehicle Identification Number1GNE K13T5 lR1485 47, located at R omania C hevrolet Truck Center, 1425 Walnut Street,Eugene, Lane County, O regon; all in violation of Title 18, United States Code, S ections 844(i)and 2.

COUNT 17ARSON a- ROMANIA CHEVROLET TRUCK CENTER VEH ICLE

On or about March 30 ,20 01 , at Eugene, Lane County, in the District of Oregon,defendants KEVIN TIJBBS, STANISLAS GREGORY M EYERHOFF, NA THAN FRASERBLOCK, and JOYA NN A L. ZACH ER, unlawfully and willfully caused and aided, abetted,counsele d, comm anded, induc ed, and procured the malicio us dama,ging and destroying, by meansof fire and an explosive, of a vehicle used in interstate com merce and used in activitie s affectinginterstate commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number3GNFK16T71G226.598, located at Romania Chevrolet Truck Center, 1425 Walnut Street,

Page 33 - 1NFORMA.TION


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Eugene, Lane C ounty, Oregon; all in violation of Title 18, United States Code, S ections 844(i)and 2.


On or about M arch 30, 2001, at Eugene, Lane County, in the District of Oregon,defendants KEVIN TUBBS, STANISLAS GREGORY M EYERHOFF, NATH AN FRASERBLOC K, and JOY AN NA L . ZACHE R, unlawfully and willfully caused and aided, abetted,counseled, comman ded, induced, and procured the malicious dam aging and destroying, by means

of fire and an explosive, of a vehicle used in interstate commerce and used in activities affectinginterstate comm erce, namely, a 2001 Suburban, bearing Vehicle Identification Numb er3GNFK16T71G230179, located at Romania Chevrolet Truck Center, 1425 Walnut Street,Eugene, Lane C ounty, Oregon; all in violation of T itle 18 , United States Code, Sections 844(i)and 2.

COUNT 19ARSON - ROMANIA CHEVROLET TRUCK CENTER VEH ICLE

On or about March 3 0,2 00 1, at Eugene, Lane County, in the District of Oregon,defendants KEVIN TlJBBS , STANISLAS GREGOR Y MEYERH OFF, NATHA N FRASERBLOC K, and JOYA NNA L. ZACHE R, unlawfully and willfully caused and aided, abetted,counseled, com manded, induced, and procured the m alicious damaging and destroying, by meansof fire and an explosive, of a vehicle used in interstate commerce an d used in activities affectinginterstate c omm erce, namely, a 2001 T ahoe, bearing V ehicle Identification Number1GN EK l3T 8 lR l69 49 0, located at Romania Chevrolet Truck Center, 1425 Walnut Street,



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Eugene, Lane County, O regon; all in violation of Title 18 , United States Code, S ections 844(i)and 2.


On or about M arch 30, 200 1, at Eugene, Lane County, in the District of Oregon,defendants KEVIN TUBBS, STAN ISLAS GREGORY MEY ERHOFF, NA THAN FR ASERBLOC K, and JOY AN NA L. ZACH ER, unlawfully and willfully caused and aided, abetted,counseled, comm anded, induced, and procured the malicious damag ing and destroying, by means

of fire and an ex plosive, of a vehicle used in interstate comm erce and used in activities affectinginterstate comm erce, namely, a 2001 S uburban , bearing Vehicle Identification Num ber3GNGK26G2 1G20 1069, located at Roma nia Chevrolet Truck Ce nter, 1 425 Walnut S treet,Eugene, Lane C ounty., Orego n; all in violation o f Title 18, United States Cod e, Sections 844(i)and 2.


On or about M[arch 30, 2001, at Eugene, L ane County, in the D istrict of Oregon ,defendants KEVIN TIJBBS, STANISLAS GREGO RY M EYERHOFF, NA THAN FRASERBLOCK, and JOYANNA L. ZACHER, unlawfully and willfully caused and aided, abetted,counseled, comm anded, induce d, and procured the malicious dam aging and destroying, by meansof fire and an explosive, of a ve hicle used in interstate comm erce aind used in activities affectinginterstate comm erce, namely, a 2001 Su burban, bearing Vehicle Iden tification Num ber3GN FK1 6TX lG2067 20, located at Romania Chevrolet Truck Center, 1425 Walnut Street,



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Eugene, Lane Co unty, Oregon; all in violation of Title 18, United States Code, Sections 844(i)and 2.


On or about M arch 30, 2001, at Eugene, Lane C ounty, in the District of Oregon,defendants KEVIN TUBBS, STANISLAS GREGORY MEY ERHOFF, NATHA N FRASERBLOC K, and JOYA NNA L. ZACH ER, unlawfully and willfully caused and aided, abetted,counseled, comma nded, induced, and procured the malicious dam aging and destroying, by means

of fire and an explosive, of a vehicle used in interstate comm erce and used in activities affectinginterstate co mm erce, namely, a 2001 Suburban, bearing Vehicle Identification Number3GNFK16T9 1G226585, located at Romania C hevrolet Truck C enter, 1425 Walnut Street,Eugene, Lane C ounty, Oregon; all in violation of Title 18, United States Code, Sections 844(i)and 2.

COUNT 23ARSON ,- ROMANIA CHEVROLET TRUCK CENTER VEHICLE

On or about M[arch 30 ,20 01 , at E ugene, Lane County, in th'e District of Oregon,defendants KEVIN TUBBS, STAN ISLAS GREGO RY MEYER HOFF, NATHAN FR ASERBLOCK, and JOYANNA L. ZAC HER , unlawfully and willfully ca.used and aided, abetted,counseled, comman ded, induced, and procured the malicious dam aging and destroying, by meansof fire and an explosive, of a vehicle used in interstate comm erce and used in activities affectinginterstate comm erce, namely, a 2001 Suburban, bearing Vehicle Identification Numb er3GNFK16T6 1G2298 16, located at Rom ania Chevrolet Truck Center, 1425 Walnut Street,



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Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, S ections 844(i)and 2.

COUNT 24ARSON - ROMAN IA CHEVRO LET TRUCK CENTER VEHICLE

On or about March 3 0,2 001 , at Eugene, Lane County, in the District of Oregon,defendants KEVIN T IJBBS, STANISLAS GREGORY MEY ERHOFF, NA THAN FRASERBLOCK, and JOYANNA L. ZAC HER, unlawfully and willfully caused and aided, abetted,counseled, commanded, induced, and procured the malicious damaging and destroying, by meansof fire and an explosive, of a vehicle used in interstate comm erce and used i n activities affectinginterstate commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number3GNG K26U21 Gl8OO66, located at Roman ia Chevrolet Truck C enter, 1 425 Walnut Street,Eugene, Lane County., Oregon ; all in violation o f Title 1 8, United States Code, Se ctions 844(i)and 2.

COUNT 25ARSON - ROMA NIA CHEVROLET TRUCK CENTER VEHICLE

On or about h4arch 30 ,20 01 , at Eugene, Lane County, in the District of Oregon,defendants KEVIN T1;JBB S, STAN ISLAS GR EGO RY M EYER HOFF, NAT HAN FRASERBLOCK, and JOYANNA L. ZACH ER, unlawfully and willfully caused and aided, abetted,counseled, commanded, induced, and procured the malicious damaging and destroying, by meansof fire and an explosive, of a vehicle used in interstate comm erce and used in a ctivities affectinginterstate co mm erce, nam ely, a 2001 Subu rban, bearing V ehicle Idlentification Num ber3GNGK26U8 1G I 8 1349, located at Romania Chevrolet Truck C enter, 1425 Walnut Street,



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Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, S ections 844(i)and 2.


On or about March 3 0,2 001 , at Eugene, Lane County, in the District of Oregon,defendants KEVIN TUBBS, STAN ISLAS GREGOR Y MEYE RHOFF, NATH AN FRASE RBLOCK , and JOY AN NA L. ZAC HER, unlawfully and willfully caused and aided, abetted,counseled, commanded, induced, and procured the malicious damaging and destroying, by meansof fire and an explosive, of a vehicle used in interstate com merce an d used in activitie s affectinginterstate com merce, namely, a 2001 Tahoe, bearing Vehicle Identification Number1GNEK 13T8 lR l6 08 06 , located at Romania Chevrolet Truck Center, 1425 Walnut Street,Eugen e, Lane County, Oregon; all in violation of Title 1 8, United States Cod e, Sections 844(i)and 2.


On or about M:arch 30, 2001, at Eugene, Lane County, in thle District of Oregon,defendants KEVIN T IJBBS, STANISLAS GREGORY MEY ERHOFF, NATH AN FRASERBLOCK, and JOYA NN A L. ZAC HER , unlawfully and willfully caused and aided, abetted,counseled, commanded, induced, and procured the malicious damaging and destroying, by m eansof fire and an explosive, of a vehicle used in interstate comm erce and used i n activities affectinginterstate commerce, namely, a 2001 Suburban, bearing V ehicle Identification Number3GNFK 16TOlG155650, located at Romania Chevrolet Truck C enter, 1425 Walnut Street,



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Eugene, Lane County, O regon; all in violation of Title 18, United States Code, Sections 844(i)and 2.

COUNT 28

ARSON - ROMANIA CHEVROLET TRUCK CENTER VEHICLEOn or about March 30, 2001, at Eugene, Lane County, in the District of Oregon,

defendants KEVIN TIJBBS, STANISLAS GREGORY MEY ERHO FF, NATH AN FRASERBLOCK , and JOY AN NA L. ZACHER , unlawfully and willfully caused and aided, abetted,counseled, command ed, induced, and procured the malicious damaging and destroying, by means

of fire and an explosive, of a vehicle used in interstate comm erce and used in activities affectinginterstate commerce, nam ely, a 2001 Su burban, bearing Vehicle Identification N umber3GNFK16TOlG206838, located at Romania Chevrolet Truck Center, 1425 Walnut Street,Eugene, Lane County, Oregon; all in violation of Title 18, United States Cod e, Sections 844(i)and 2.


On or abo ut March 30 , 2001, at Eugene, Lane County, in the District of Oregon,defendants KEVIN TIJBBS, STANISLAS GREGORY M EYERHOFF, NATHA N FRASERBLOCK , and JOYA NN A L. ZAC HER, unlawfully and willfully caused and aided, abetted,counseled, comm anded, induced, and procured the malicious d amaging and destroying, by meansof fire and an explosive, of a vehicle used in interstate commerce aind used in activities affectinginterstate comm erce, namely, a 2001 Suburban, bearing Veh icle Identification Num ber3GNFK16T31G195205, located at Romania Chevrolet Truck Center, 1425 Walnut Street,



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Eugene, Lane Coun ty, Oregon; all in violation of Title 18, United States Code, Sections 844(i)and 2.


On or about March 30 ,20 01 , at Eugene, Lane County, in the District of Oregon,defendants KEVIN TUBBS, STANISLAS GREGORY M EYERHOFF, NATH AN FRASERBLOC K, and JOYA NNA L. ZACHE R, unlawfully and willfully caused and aided, abetted,counseled, comma nded, induced, and procured the m alicious damaging and destroying, by means

of fire and an ex plosive, of a vehicle used in interstate comm erce and used in activities affectinginterstate comm erce, namely, a 2 001 Suburban, bearing Vehicle Identification Number3GNFK16TX1G225834, located at Romania Chevrolet Truck Center, 1425 Walnut Street,Eugene, Lane County. Oregon; all in violation of Title 18, United States Code, Sections 844(i)and 2.

COUNT 31ARSON - ROMANIA CHEVROLET TRUCK CENT ER VEHICLE

On or about M arch 30, 2001, at Eugene, Lane County, in the District of Oregon,defendants KEVIN TIJBBS, STANISLAS GREGORY MEY ERHOFF, NA THA N FRASERBLOC K, and JOY AN NA L. ZAC HER , unlawfully and willfully caused and aided, abetted,counseled, command ed, induced, and procured the malicious dam aging and destroying, by meansof fire and an explosive, of a vehicle used in interstate commerce and used in activities affectinginterstate com merce, namely, a 2001 Suburban, bearing Vehicle Identification Num ber1GNFK16T2 15242612, located at Romania C hevrolet Truck C enter, 1425 Walnut Street,



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Eugene, Lane C ounty, O regon; all in violation of T itle 18, United States Code, Sections 844(i)and 2.


On or about March 30, 2001, at Eugene, Lane County, in the District of Oregon,defendants KEVIN TIJBBS, STANISLAS GREGORY ME YERHOFF, NAT HAN FR ASERBLOCK , and JOY AN NA L. ZAC HER , unlawfully and willfully caused and aided, abetted,counseled, commanded, induced, and procured the m alicious damaging and destroying, by means

of fire and an explosive, of a vehicle used in interstate commerce and used in activities affectinginterstate com merce, namely, a 2001 Suburban, bearing Vehicle Identification Number3GNGK26U8 1G I9 26 12, located at Romania Chevrolet Truck Center, 1425 Walnut Street,Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, S ections 844(i)and 2.


On or about M arch 30, 2001, at Eugene, Lane County, in the District of Oregon,defendants KEVIN TlIJBBS, STANISLAS GREGORY MEYER HOFF, NAT HAN FRASERBLOCK , and JOYAN NA L. ZACHE R, unlawfully and willfully caused and aided, abetted,counseled, com manded, induced, and procured the m alicious damaging and destroying, by meansof fire and an explosive, of a vehicle used in interstate commerce and used in activities affectinginterstate comm erce, namely, a 2001 Tahoe, bearing Vehicle Identification Num berlGN EK 13T7 1R11 6389, located at Roma nia Chevrolet Truck Center, 1425 Walnut Street,



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Eugene, Lane Coun ty, Oregon; all in violation of Title 18, United States Co de, Sections 844(i)and 2.


On or about March 3 0,2 00 1, at Eugene, Lane County, in the District of Oregon,defendants KEVIN TIJBBS, STANISLAS GREGORY M EYERH OFF, NATHAN FRASERBLOC K, and JOYAN NA L. ZACHER , unlawfully and willfully caused and aided, abetted,counseled, commanded, induced, and procured the malicious damaging and destroying, by means

of fire and an explosive, of a vehicle used in interstate comm erce and used in activities affectinginterstate commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number3GNFK16T9 1Gl8 909 8, located at Romania Chevrolet Truck Center, 1425 Walnut Street,Eugene, Lane County , Oregon; all in violation of Title 18, United States Co de, Sections 844(i)and 2.


On or about Mrarch 30,2 00 1, at Eugene, Lane County, in the District of Oregon,defendants KEVIN TIJBBS, STANISLAS GREGORY M EYER HOFF, NATHAN FRASERBLOC K, and JOY ANN A L . ZACHE R, unlawfully and willfully ca.used and aided, abetted,counseled, commanded, induced, and procured the malicious damaging and destroying, by meansof fire and an explosive, of a vehicle used in interstate comm erce and used in activities affectinginterstate comm erce, ]namely, a 2001 Suburban, bearing Vehicle Iden tification Numbe r3GN FKl6 T01 G I 984O3, located at Romania Chevrolet Truck Center, 1425 Walnut Street,



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Eugene, La ne County, Oregon; all in violation of Title 18, United S tates Code , Sections 844(i)and 2.


On or about March 3 0,2 00 1, at Eugene, Lane County, in the District of Oregon,defendants KEVIN TUBBS, STAN ISLAS GREGORY ME YERH OFF, NATHAN FR ASERBLOC K, and JOYA NN A L. ZACHER , unlawfully and willfully caused and aided, abetted,counseled, commanded, induced, and procured the malicious damaging and destroying, by means

of fire and an explosive , of a vehicle used in interstate com merce a nd used in activities affectinginterstate comm erce, namely, a 200 1 Tahoe, bearing Vehicle Identification Num berlG NE Kl3 TO l Jl8 33 20 , located at Rom ania Chevrolet Truck Center, 1425 Walnut Street,Eugene, Lane C ounty, Oregon; all in violation of Title 18, United S'tates Cod e, Section s 844(i)and 2.


On or about March 30, 2001, at Eugene, Lane County, in the District of Oregon,defendants KEVIN TIJBBS, STANISLAS GREG ORY MEYERH OFF, NATH AN FRASERBLOCK, and JOYAN NA L. ZACHER, unlawfully and willfully caused and aided, abetted,counseled, commanded, induced, and procured the malicious damaging and destroying, by meansof fire and an explosive , of a vehicle used in interstate comm erce and used in activities affectinginterstate commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number3GNFK16T9 1G2O7 194, located at Rom ania Che vrolet Truck Center, 1425 Walnut Street,



44/53

Eugene, Lan e County, Oregon; all in violation of Title 18, United S tates Cod e, Sections 844(i)and 2.


On or about March 30, 2001, at Eugene, Lane County, in the District of Oregon,defendants KEVIN T IB B S , STANISLAS GREGORY MEYER HOFF, NATHAN FRASERBLOC K, and JOYA NN A L. ZACH ER, unlawfully and willfully caused and aided, abetted,counseled, commanded, induced, and procured the malicious damaging and destroying, by means

of fire and an explosive, of a vehicle used in interstate comm erce and used in activities affectinginterstate commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number3GNFK16T81G 193241, located at Romania C hevrolet Truck Cent~er, 4 25 Walnut Street,Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, Sections 844(i)and 2.

COUNT 39ARSON - ROMA NIA CHEVROLET TRUCK CENTER VEHICLE

On or about March 30, 2001, at Eugene, Lane Cou nty, in the District of Oregon,defendants KEVIN T'LBBS, STANISLAS GREGORY M EYERHOFF, NATH AN FRASERBLOCK, and JOYAINNA L. ZACHER, unlawfully and willfully caused and aided, abetted,counseled, comm anded, induced, and procured the malicious dam a~gin g nd destroying, by meansof fire and an explosive, o f a vehicle used in interstate commerce and used in activities affectinginterstate commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number3GNFK16T11 GlO5629 , located at Rom ania Chevrolet Truck Cenler, 1425 Walnut Street,



45/53

Eugene, Lane Cou nty, Oregon; all in violation of Title 18, United States Cod e, Sections 844(i)and 2.


On or about M arch 30, 2001, at Eugene, Lane County, in the District o f Oregon,defendants KEVIN TUBB S, STANISLAS GREGORY MEYE RHOFF, NATHAN FRASERBLOC K, and JOYA NNA L. ZACHER , unlawfully and willfully caused and aided, abetted,counseled, commanded, induced, and procured the malicious damaging and destroying, by means

of fire and an explosive, of a vehicle used in interstate comm erce and used in ac tivities affectinginterstate commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number3GNGK26U8 1G I 79567, located at Romania Chevrolet Truck Center, 1425 Walnut Street,Eugene, Lane County., Oregon; all in violation of Title 18, United States Cod e, Sections 844 (i)and 2.


On or about March 30,2001, at Eugene, Lane County, in the District of Oregon,defendants KEVIN T'UBBS, STANISLAS GREGORY MEYERHOFF, NATHAN FRASERBLOC K, and JOYAN NA L . ZACHER , unlawfully and willfully caused and aided, abetted,counseled, commanded, induced, and procured the malicious damaging and destroying, by meansof fire and an explosive, of a vehicle used in interstate comm erce and used in activities affectinginterstate commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number3GNGK26G2 1G2 15392, located at Rom ania Chevrolet Truck Center, 1425 Walnut Street,



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Eugene, Lane County, O regon; all in violation of T itle 18 , United States Code, Sections 844(i)and 2.

COUNT 42ATTEMPTED ARSON - JEFFERSON POPLAR FARM MAIN OFFICE

On or about May 2 1, 2001, at Clatskanie, Columbia County, in the District o f Oregon,defendants STANISLAS GREGORY MEYERH OFF, KEVIN TUBBS, DANIEL GERARDMcGOWAN, CHELSEA DAWN GERLACH, NATHAN FRASER BLOCK, JOYANNA L.ZACH ER, and SU ZAN NE SAV OIE, and other persons known to the Grand Jury, unlawfully and

willfully caused and aided, abetted, counseled, commanded, induced, and procured the attempt todamage or destroy, by means of fire and an explosive, a building and other real and personalproperty used in interstate commerce and used in activities affecting interstate commerce,namely, the main office building and its contents located at Jefferson Poplar Farm, 791 14 CollinsRoad, Clatskanie, C olumbia Co unty, Oregon; all in violation of Title 18, United S tates Code,Sections 844(i) and 2.

COUNT 43ARSON - JEFFERSON POPLAR FARM - VEHICLE SHOP

On or about h4ay 21, 2001, at Clatskanie, Columbia County, in the District of Oregon,defendants STANISLAS GREGORY MEYERH OFF, KEVIN TUIjBS, DANIEL GERARDMcGOW AN, CHELSIEA DAW N GERLACH, NATHA N FRASEK BLOCK, JOYA NNA L.

ZACH ER, and SU ZAN NE SAV OIE, and other persons known to the Grand Jury, unlawfully andwillfully caused and aided, abetted, counseled, commanded, induced, and procured the m aliciousdamaging and destroying, by means of fire and an explosive, of a building and other real and



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personal property used in interstate commerce and used in activities affecting interstatecommerce, namely, a vehicle shop and its contents located at Jefferson Poplar Farm, 791 14Collins Road, Clatskanie, Colum bia County, Oregon; all in violation of Title 18, United S tatesCode, Sections 844 (i) and 2.

COUNT 44ARSON - JEFFERSON POPLAR FARM - SHOP & OFFICE

On or about May 21, 20 01, at Clatskanie, Columb ia County, in the District of Oregon,defendants STANISL'4S GREGO RY MEY ERHOFF, KEVIN TUBBS, DANIEL GERAR D

McGOWAN , CHELSEA DAW N GERLACH, NATHAN FRASER BLOCK, JOYANNA L.ZAC HER , and SUZA NNE SAV OIE, and other persons know n to the Grand Jury, unlawfully andwillfully caused and aided, abetted, counseled, commanded, induced, and procured the m aliciousdamaging and destroying, by means o f fire and an explosive, of a building and other real andpersonal property used in interstate commerce and used in activities affecting interstatecom merce , namely, a sho p and office buildin g and its co ntents 1oca.ted at Jefferson Popla r Farm,791 14 Collins Road, Clatskanie, Colum bia County, Oregon; all in v iolation of Title 18,UnitedStates Code, Sections 844(i) and 2.

COUNT 45ARSON - JEFFERSON POPLAR FARM - VEHICLE

On or abou t May 2 1, 20 01 , at Clatskanie, C olumbia County, in the District o f Oregon,defendants STANISLAS GREGOR Y M EYERHO FF, KEVIN TUHBS, DANIEL GERARDMcGOWA N, CHELSEA DAWN G ERLACH, NATHAN FRASER BLOCK, JOYANNA L.ZACHER, and SUZANNE SAV OIE, and other persons known to the Grand Jury, unlawfully



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and willfully caused and aided, abetted, counseled, commanded, induced, and procured themalicious damagin g arid destroymg, by m eans of fire and an ex plosive, of a vehicle used ininterstate commerce and used in activities affecting interstate comm erce, namely, a 1997 Fordtruck bearing Oregon license number VH Q 660, located at Jefferson Poplar Farm , 791 14 CollinsRoad, Clatskanie, Columb ia County, Oregon; all in violation of Title 18, United States Code,Sections 844(i) and 2.

COUNT 46ARSON - JEFFERSON POPLAR FARM - 17EHICLE

On or about M ay 2 1,2 00 1, at Clatskanie, Columb ia County, in the District of Oregon,defendants STANISLAS GREGORY M EYERHO FF, KEVIN TUBBS, DANIEL GERARDMcGOWAN, CHELSEA DAW N GERLACH, NATHAN FRASER BLOCK, JOYANNA L.ZACH ER, and SUZA NN E SAVOIE, and other persons known to the Grand Jury, unlawfullyand willfully caused and aided, abetted, counseled, commanded, induced, and procured themalicious damaging and destroying, by means of fire and an explosive, of a vehicle used ininterstate commerce and used in activities affecting interstate commerce, namely, a 1984 Fordtruck bearing Oregon license number C XR 90 1, located at Jefferson Poplar Farm, 79 1 14 CollinsRoad, Clatskanie, Colum bia County, Oregon; all in violation of T itle 18 , United States Code,Sections 844(i) and 2.

COUNT 47

ARSON - JEFFERSON POPLAR FARM - VEHICLEOn or about M ay 2 1, 2001, at C latskanie, Columbia County, in the D istrict of O regon,

defendants STANISLAS GREGORY M EYERHOFF, KEVIN TUB BS, DANIEL GERARD



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McGOW AN, CHELSEA DAWN GERLACH, NATHAN FRASER BLOCK, JOYANN A L.ZAC HER , and SUZ AN NE SAV OIE, and other persons known to the Grand Jury, unlawfully andwillfully caused and aided, abetted, counseled, commanded, induced, and procured the m aliciousdamaging and destroying, by me ans of fire and an explosive, o f a vehicle used in interstatecommerce and used in activities affecting interstate commerce, namely, a 1997 Ford truckbearing Oregon license num ber VH Q 661, located at Jefferson Poplar Fa rm, 791 14 Collins Road,Clatskanie, Columbia Cou nty, Oregon; all in violation of Title 18, United States Code, Sections844(i) and 2 .

COUNT 48ARSON - JEFFERSON POPLAR FARM - b7EHICLE

On or about May 2 1,2 00 1, at Clatskanie, Columbia County, in the District of Oregon,defendants STANISL,$S GREG ORY MEYER HOFF, KEV IN TUEIBS, DAN IEL GERARDMcGOW AN, CHELSEA DAW N GERLACH , NATH AN FRASEF: BLOCK, JOYAN NA L.ZACH ER, and SU ZAN NE SA VO IE, and other persons known to the Grand Jury, unlawfully andwillfully caused and aided, abetted, counseled, comm anded, induced, and procured the maliciousdam aging and destroying, by m eans o f fire and an explosive, o f a vlehicle used in interstatecomm erce and used in activities affecting interstate commerce, namely, a 1997 Ford truckbearing Oregon license number V NS 4 04, located at Jefferson Poplar F ann , 791 14 Collins Road,Clatskanie, Columbia C ounty, Oregon; all in violation of Title 18, United States Code, Sections844(i) and 2.I / '

1 1 1



50/53


On or about M ay 2 1, 2001, at Clatskanie, C olumbia C ounty, in the District of Oregon,defendants STANISLAS GRE GORY M EYERHOFF, KEVIN TUBB S, DANIEL GERARDMcGOW AN, CHELSEA DAWN GERLACH, NATHAN FRASER BLOCK, JOYANNA L.ZACHER , and SUZANN E SAVOIE, and other persons known to the Grand Jury, unlawfully andwillfully caused and aided, abetted, counseled, commanded, induced, and procured the maliciousdamaging and de stroying, by means of fire and an explosive, of a vehicle used in interstate

comm erce and used in activities affecting interstate comm erce, namely, a 1996 Ford truckbearing Oregon license num ber UM Z 923, located at Jefferson Poplar Farm , 791 14 Collins Road,Clatskanie, Colu mbia County, Oregon; all in violation of Title 18, United States Code , Sections844(i) and 2.


On or about May 2 1,2 00 1, at Clatskanie, Columbia County, in the District of Oregon,defendants STANISLAS GREGO RY ME YERHO FF, KEVIN TUI3BS, DANIEL GE RARDMcGOWAN, CHELSEA DAW N GERLACH, NATHAN FR ASE li BLOCK, JOYANNA L.ZACHER, and SUZANNE SAVOIE, and other persons known to the Grand Jury, unlawfully andwillfully caused and aided, abetted, counseled, commanded, induced, and procured the malicious

damaging and destroying, by mea ns of fire and an explosive, of a vehicle used in interstatecomm erce and used in activities affecting interstate commerce, nam ely, a 1990 Ford truckbearing Oregon license num ber 283 A CE, located at Jefferson Poplar Farm , 791 14 Collins Road,



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Clatskanie, Colu mbia County, O regon; all in violation of Title 18, United States Code, Sections844(i) and 2.


On or about May 21 ,20 01 , at Clatskanie, Columbia County, in the District of Oregon,defendants STANISLAS GREGORY MEYERHOFF, KEVIN TUB BS, DANIEL GERARDMcGOWAN, CHELSE A DAW N GERLACH, NATHAN FR ASER BLOCK, JOYANNA L.ZACHE R, and SUZANN E SA VOIE, and other persons known to the Grand Jury, unlawfully and

willfully caused and aided, abetted, counseled, commanded, induced, and procured the maliciousdamaging and destroying, by means of fire and an explosive, of a vehicle used in interstatecomm erce and used in activities affecting interstate commerce, namely, a 1990 Ford truckbearing Oregon license number 282 ACE, located at Jefferson Poplar Farm, 79114Collins Road,Clatskanie, Colum bia County, Oregon; all in violation of Title 18, lJnited States Code , Sections844(i) and 2.


On or about May 2 1, 2001, at Clatskanie, Columbia County, in the District of Oregon,defendants STANISLAS GREGO RY MEYERHOFF, KEVIN TU 3BS , DANIEL GERARDMcGOWAN, CHELSEA DA WN GERLACH, NATHAN FRASEIR BLOCK, JOYANNA L.

ZACHE R, and SUZA NNE SA VOIE, and other persons known to the Grand Jury, unlawfully andwillfully caused and aided, abetted, counseled, commanded, induced, and procured the maliciousdamaging and destroying, by means of fire and an explosive, of a vehicle used in interstate



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comm erce and used in activities affecting interstate commerce, nam ely, a 1990 Ford truckbearing Oregon license num ber 361 A CC, located at Jefferson Poplar F arm, 791 14 Collins Road,Clatskanie, Colu mbia County, Oregon; all in violation of Title 18, United States Code, Sections844(i) and 2.


On or about May 2 1,2001, at Clatskanie, Columbia County, in the District of Oregon,defendants STANISLAS GR EGORY M EYERHOFF, KEVIN TUB BS, DANIEL GERARD

McGOWAN, CHELSEA DA WN GERLACH, NATHAN FRASER BLOCK, JOYANNA L.ZACHER, and SUZANNE SAVOIE, and other persons known to the Grand Jury, unlawfully andwillfully caused and aided, abetted, counseled, commanded, induced, and procured the maliciousdamaging and destroying, by means of fire and an explosive, of a vehicle used in interstatecommerce and used in activities affecting interstate com merce, n amely, a 198 1 GMC truckbearing Oregon licens8e um ber NA41574, located at Jefferson Poplar Fa rm, 791 14 Collins Road,Clatskanie, Co lumb ia County, Oregon; all in violation o f Title 18 , 'United States Code, Sections844(i) and 2.


On or about hla y 21, 2001, at Clatskanie, Colum bia County, in the District of Oregon,defendants STANISL.ASGREGO RY MEYERHOFF, KEVIN TUBBS, DANIEL GERARDMcGOWAN, CHELSEA DAWN GERLACH, NATHAN FRASER BLOCK, JOYANNA L.ZACHE R, and SUZA NNE SAVOIE, and other persons known to the Grand Jury, unlawfully and



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willfully caused and aided, abetted, counseled, commanded, induced, and procured the maliciousdamaging and destroying, by means of fire and an explosive, of a vehicle u sed in interstatecomm erce and used in activities affecting interstate comm erce, namely, a 1989 Ford truckbearing Oregon license number PWV 249, at Jefferson Poplar Farm, 791 14 Collins Road,Clatskanie, Colum bia County, Oregon; all in violation of Title 18, United States Code, Sections844(i) and 2.

Dated this of 3 2 0 0 6 .KARIN J. IMMERGU TUnited States AttorneyDistrict of Oregon

KIRK A. ENGDA*Assistant United States Attorney

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