Tubbs.information

8/3/2019 Tubbs.information

1/54

IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT O F OREGON

UNITED STATES OF AMERICA 1 CR No. 0 - C*c':C.7ci - i1v. INFORMATION)

KEVIN T UBB S, aka "Bob" and "Dog", ) [18 U.S.C. fjtj 371, 844(f), 844(i),1 1366(a) and 21Defendant.THE UNITED STATES ATTORNEY CH ARGES:

COUNT 1CONSPIRACY TO COM MIT ARSON AND DESTRUCTION OF ENERGY FACILITY

I. OBJECT OF THE CONSPIRACYBeginning in October 1996 and continuing through October 2001, in the District of

Oregon and elsewhere, defendants JOSEPH INE SU NSHINE O VERA KER, KEV IN TUBBS,STANISLAS GREGORY MEYERHOFF, DANIEL GERARD McGO WAN , JOSEPH DIBEE,REBECCA RUBIN, CHELSEA DAWN GERLACH, KENDALL TANKERSLEY, SUZANNESAVOIE, JONATHA N CHRISTOPHER M ARK PAUL, DARREN TOD D THURSTON,NATHAN FRASER BLOCK, and JOYANNA L. ZACHER, and unindicted co-conspirators

Page 1 - INFORMATION


2/54

JACOB JEREMIAH FERGUSO N and WILLIAM C . ROD GER S, and others, willfully andknowingly con spired iind agreed to com mit the following offenses against the United States:

to maliciously damage or destroy, or attempt to damage or destroy, by means offire or an explosive, any building, vehicle or other personal o r real property inwho le or in part owned o r possessed by, or leased to, the United States or anydepartm ent or agency thereof, in violation of Title 18 , United States Code, Section844(f)(l);to maliciously damage or destroy, or attempt to damage or destroy, by means of

fire or an exp losive, any building, vehicle or other real or personal property usedin interstate commerce or in any activity affecting in terstate commerce, inviolation of Title 18, United States Code, Section 844 (i); andto knowingly and willfully damage and attempt to damage the property of an energy

facility of the United States involved in the transm ission and d istribution of electricity, inan amount exceeding or which would have exceeded $100,000, in violation of Title 18,United States Code, Section 136 6(a).11. MANNER AND MEANS OF THE CONSPIRACY

Th e foregoing objects of the conspiracy were to be accom plished in the following mannerand means by the abo ve-listed defendants and others at various times during the course of theconspiracy:

1. Certain of the defendants and others joined together in a group they called the"Family." This "Family" was what is commo nly know n as a "cell" of groups and mo vements



3/54

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

2. Th e general purposes of the conspiracy were to influence and affect the condu ct ofgovernment, commerce, private business and others in the civilian population by means of force,violence, sabotage, mass destruction, intimidation and coercion, and by similar means to retaliateagainst the conduct of government, commerce and private business. To achieve these purposes,the conspirators committed and attempted to commit acts dangerous to human life and propertythat constituted violations of the criminal laws o f the United States and o f individual states.

3. Certain of the defendants and o thers targeted for arson buildings, vehicles andother real and personad property owned, possessed, and leased by the United States and itsdepartments and agencies.

4. Certain of the defendants and others targeted for arson buildings, vehicles andother real and personal property used in interstate comm erce and in activities affecting interstatecommerce.

5 . Certain of the defendants and another person targeted for willful dam age anenergy facility of the United States involved in the transmission and distribution o f 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 damag e of the targeted sites. Several of these meeting s were called "BookClub" meetings by the defendants and others and occurred at distant locations. Th e "Book Club"meetings cov ered sub,jects such as lock-picking, compu ter security, encrypted messaging,



4/54

reconnaissance o f 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 damage.

8. In discussing their actions among themselves, certain of the defendants an d othersused code words, code names, and nicknames.

9. Certairi of the defendants and others designed an d constructed destructive deviceswhich functioned as incendiary bom bs to ignite fires and destroy the targets.

10. Certairi of the defendants and others provided transportation to the sites targetedfor arson and other damage.

11. Certain of the defendants and others dressed in dark clothing, wore m asks andgloves and otherwise disguised their appearance.

12. Certairi of the defendants and others acted as "lookouts" to ensure secrecy as thecrimes were carried out.

13 . Certain of the defendants and o thers placed d estructive devices and accelerants atsites targeted for arson and ignited or attempted to ignite the devices and accelerants.

14. Certain of the defendants and o thers, by means of fire and ex plosives , maliciouslydamaged and destroyed, and attempted to damage and d estroy, buildings, vehicles and other realand personal property owned and possessed by the United States and its departm ents andagencies.

15. Certain of the defendants and others, by means of fire and exp losives, maliciously



5/54

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

16. Certain of the defendan ts and another person willfully damaged and attempted todamage the property of an energy facility of the United S tates involved in the transm ission anddistribution of electricity, in an amount exceeding or which would have exceeded $100,000.

1 7 . In some of 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 oth er crimes, certain of the defenda nts andothers provided transportation away from the sc enes of the crimes.

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

20 . After the arsons, certain of the defendants and others publicized and promoted theresults of the fires by mean s of written press releases and comm uniques attributing the arsons tothe Earth Liberation Front (ELF), the Animal Liberation Fron t (ALF) and related groups, andstating the purposes o f the arson s.

21 . Before, during and after the arsons, attempted arsons and othe r crimes, certain ofthe defendan ts and others agreed and took an oath amon g themselves never to reveal to lawenforcement au thorities or to anyone else outside "the F amily" the identity of the conspiratorsand participants in the arso ns, attempted arsons and other crimes.



6/54

22. Befo re, during and after the arsons, attempted arsons and other crimes, certain ofthe defendants and others agreed among themselves to conceal or d estroy any evidenceconnecting them to the arsons, attempted arsons and other crimes.

23. Before, during and after the arsons, attempted arsons and other crimes, certain ofthe defendants and others possessed andlor used false identification d ocum ents 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 by

law enforcement authorities in the United States.111. OVERT ACTS

In order to canry out the objec ts of the conspiracy, defendan ts and other personscommitted various overt acts within the District of Oregon and elsewhere, including but notlimited to the following:

1. On or about October 28, 1996, in Marion County, Oregon, defendant JOSEPH INESUNSHINE OV ERAKER and JACOB JEREM IAH FERGU SON unlawfully and willfullycaused and aided, abetted, counseled, com manded, induced, and procured the attempt to dam ageor destroy, by me ans o f fire and an explosive, a building and other real an d personal propertyowned and possessed by the United States and the United States Forest Service of theDepartment of Agriculture, located at the Detroit Ranger Station on the Willamette NationalForest.



7/54

l a . At a time prior to October 28, 1996, defendant JOSEPH INE SU NSHINEOVERAKE R and JACOB JEREMIAH F ERGU SON prepared and tested a time-delayedincendiary de vice.

1b. On or about October 28, 1996, defendant JOSEPH INE SUN SHIN E OVE RAK ERand JACO B JEREM L4H FE RGU SON drove to the U.S. Forest Service Detroit Ranger Station inMarion County, Oregon, with an incendiary device which was placed on the roof of a U .S. ForestService building. That incendiary device failed to function.

1c. On or about October 28, 1996, defendant JOSEPH INE SUNS HINE OVE RAK ER

spray-painted graffiti on the sides of a U.S. Forest Service building and vehicles which includedthe words "Earth Liberation Front."

2 . On or about O ctober 28, 1996 in Marion C ounty, Oregon, defendant JOSEP HINESUNSHINE OV ERAK ER and JACO B JEREMIAH FERGU SON unlawfully and willfullycaused and aided, abetted, counseled, comm anded, induced, and procured the m aliciousdamaging and destroying, by means o f a fire and an explosive, a vehicle and other real andpersonal property owned and possessed by the United States and the United States Forest Serviceof the Department of ,4griculture, located at the Detroit Ranger Station on the WillametteNational Forest.

2a . On or about October 28, 1996, defendant JOSEPH INE SUN SHIN E OVE RAKE Rand JACOB JER EML 4H FER GU SON intended and caused fire damage to a U.S . Forest Servicevehicle.

3. On or about October 30, 1996, in Lane County, Oregon, defendants JOS EPHINESUNSHINE OVERAKER, KEVIN TUBBS, and JACOB JEREMIAH FERG USON unlawfully



8/54

and willfully caused and aided, ab etted, counseled, comm anded, induced, an d procured themalicious damaging and destroying, 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 o f Agriculture, located at the Oak ridge Rang er Station on theWillamette National Forest.

3a. On or about October 30, 1996, in Lane County, Oregon, defendants JOS EPHINESUNSHINE OVE RAKER , KEVIN TUBBS, and JACOB JEREMIAH FE RGUS ON drove to theU.S . Forest Se rvice Oakridge Ranger S tation, and set fire to the Range r Station.

3b . On or iibout 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 S tation, threw n ails onto theparking lot in order to slow down responding em ergency vehicles.

3c. On or about October 30, 19 96, in Lane County, Oregon, defendants JOSEPHINESUNSHINE OVERAKER, KEV IN TUBBS, and JACOB JEREMIAH FE RGUS ON, whileleaving the U.S. Forest Service Oakridge Ranger Station and driving westbound on Highway 58towards Eug ene, Oregon, discarded their gloves in a reservoir near the Lowell Bridge.

4. On or about July 2 1, 1997, at Redm ond, Deschu tes Coun ty, Oregon, defendantsKEVIN TUBBS, JOSEPH DIBEE, JONATHAN CHRISTOPHER MA RK PAUL, JENNIFERKOLA R, and JACOB, JEREMIAH FERGU SON 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



9/54

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

4a. Approxim ately one week prior to the July 2 1, 1997 arson at Cavel West, Inc.,defendants KEVIN TUBBS, JONATH AN CHRISTOPHER M ARK PAU L, JOSEPH DIBEE,and JACOB J ER EM LW FERG USON went 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 ATH ANCHRISTOPHER MARK PAUL , and JENN IFER KOL AR prepared a mixture of soap and

petroleum products which was the fuel used in the time-delayed incendiary devices.4c . On or about July 2 1, 1997, defendants KEV IN TU BBS , JOSEPH DIBEE,

JONATHAN CHRISTOPHER MARK PAUL, JENNIFER KOLAR, and JACOB JEREMIAHFERG USON drove to the previously chosen staging area near Cavel W est, Inc., and upon arrivaldressed in dark clothing, masks, and gloves, and dug a hole at the staging area in which to burytheir dark clothing upon completion of the arson.

4d . On or about July 21, 1997, defendants KEVIN T UBBS , JOSEP H DIBE E,JONATHAN CHRISTOPHER M ARK PAUL, JENNIFER KOLAR, and JACO B JEREMIAHFERG USON completed a two-way radio check with one another and confirmed their scannerand radios functioned properly.

4e. On or about July 21, 1997, defendants KEV IN TUB BS, JOSE PH DIBEE,JONATHAN CHRISTOPHER MA RK PAUL, JENNIFER KOLAR, and JACOB JEREMIAHFERGU SON went to the location of Cavel W est, Inc., to place time-delayed incendiary deviceson and about that 1oca.tion.



10/54

4f . On or about July 2 1, 1997, defendant JOSE PH DIBEE 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 TUB BS, JOSEPH DIBE E,JONATHAN CHRISTOPHER MARK PAUL, JENNIFER KOLAR, and JACOB JEREMIAHFERG USON , upon placing the time-delayed incendiary devices at Cavel W est, 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 a

written communique attributing the fire to the Animal Liberation Front (ALF) and the Equineand Zebra Liberation Front. The comm unique was publicized by Craig Rosebraugh of theLiberation Collective in Portland, Oregon.

4i. Appro ~im ate lyhree years after July 2 1, 1997, defendant JOS EPH DIBEE andJENNIFE R LYN N KlOLAR contacted defendant KEVIN TUB BS and told KEVIN TU BBS toreturn to the staging area and retrieve the b uried clothes.

5 . On or (aboutNovember 30 , 1997, in Harney County, Oregon, defendantsJOSEPHINE SUNSHINE OVERAKE R, KEVIN TUBBS, JACOB JEREMIAH FERGUSON,REBEC CA RU BIN, and unindicted co-conspirator WILLIAM C. RODGERS unlawfully andwillfully caused and aided, abetted, counseled, commanded, induced, and procured the maliciousdamaging and destroying, by means of fire and an explosive, of buildings and other real andpersonal property owned and possessed by the United States and the Bureau of LandManagem ent of the Dlepartment of the Interior, located at the W ild Horse and Burro F acility,Bums, Hamey County, Oregon.



11/54

5a . Approxim ately three months prior to November 30, 1 997, defendantsJOSEPHINE S U N SH N E OVERAKER, JACOB JEREMIAH FERGUSON, KEVIN TUBBS,and unindicted co-conspirator WILLIAM C . ROD GER S did a reconnaissance at and near theWild Ho rse and Burro Facility, to prepare themselves for the arson and ho rse release.

5b. Som etime prior to November 30,1 997 , defendant JOSE PHIN E SUNS HINEOVER AKER and JACO B JEREMIA H FER GUSO N obtained five-gallon, white plastic bucketsand the fuel to be used in making time-delayed incend iary devices.

5c. Sometime prior to November 30, 1997, persons known and unknown to the G rand

Jury prepared the five-gallon plastic buckets by w iping the buckets to ensure all fingerprints wereremoved, and painted them w ith black spray paint.

5d. Sometime prior to November 30, 1997, defendants JOSEPH INE SUN SHINEOVERAKER, KEVIN TUBB S, JACOB JEREMIAH FERGUSO N, REBECC A RUBIN, andunindicted co-conspirator W ILLIAM C. RODG ERS obtained additional com ponents andassembled time-delayed incendiary devices, which were com posed o f kitchen timers, matches,sponges, model rocket igniters, one-gallon jugs filled with fuel and five-gallon buckets whichcontained fuel.

5e. On or about November 30, 1997, defendants JOSE PHIN E SUN SHIN EOVERAKER, KEVIN TUBBS, JACOB JEREMIAH FER GUSO N, REBECCA RUBIN, andunindicted co-conspirator WILLIAM C. ROD GERS arrived at the Wild Horse and BurroFacility, cut the lock o n the front g ate, released horses an d burros, placed time-delayed incendiarydevices in and around the facility and left the area.



12/54

5f. On o r about Decembe r 5, 1997, certain defendants in the Wild H orse and BurroFacility arson issued a. comm unique attributing the fire and horse release to the Earth LiberationFront (ELF) and the Aaima l Liberation Front (ALF). The comm unique was publicized by CraigRosebraugh of the Liberation Collective in Portland, Oregon.

6. On or about J une 2 1, 1998, at Olympia, W ashington, in the W estern D istrict ofWashington, defendants JOSEPHINE SUNSH INE OVERAKER , KEVIN TUB BS, JACOBJEREM IAH FERG USO N, JOSEP H DIBEE, and unindicted co-conspirator WILLIAM C.ROD GER S willfully caused and aided, abetted, counseled, comman ded, induced, and procuredthe 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 Service (APH IS) of the Department of Agriculture, located at the NationalWildlife Research Fa d it y , 9701 Blomberg Street SW, Olympia, Washington.

6a . Approximately two w eeks before June 2 1, 1998, defendants KEV IN TU BBS ,JOSEPH DIBEE, and unindicted co-conspirator JACOB JEREMIAH FERGUSON met inOlympia, Washington, to discuss plans for the APHIS arson, and agreed at that time there wouldbe a second and simultaneous arson comm itted when the APH IS arson was to occur.

6b. At a tirne prior to June 2 1, 1998, defendant JO SEPH INE SUN SHINEOVERA KER and unindicted co-conspirator JACOB JEREMIAH FERG USON prepared five-gallon buckets by wip-ing he buckets to rem ove any fingerprints, and obtaine d fuel for theAPHIS arson.

6c . At a tirne prior to June 21, 1998, defendant KEV IN T UBB S utilized falseidentification to acquire a van which w as used in the APHIS arson.



13/54

6d. On or about June 2 1, 1998, defendant JOSEP HINE SUNSH INE OVE RAK ER,while attemp ting to stleal items in preparation for the APHIS arson, wa s arrested by au thoritiesfor shoplifting.

6e . On or about June 21, 1998, defendant KEVIN TUBBS and JACOB JEREMIAHFERG USO N transferred five-gallon buckets of fuel to be used in the APH IS arson from a vanpurchased by KE VIN T UBB 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 JACOB JEREMIAH FERGUSO N and W ILLIAM C. ROD GER S drove to theAPH IS 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 or about June 22, 1998, certain defendants in the APH IS arson issued acommu nique attributing the fire to the Earth Liberation Front (ELF) and the Animal LiberationFront (ALF). The cornmun ique was publicized by Katie Fedor of the North American ALF PressOffice.

6h. At a time after June 22, 1998, defendant KEV IN T LB BS assisted in the disposalof the van used in the APHIS arson.

7. In about Septem ber 19 98, at Rock Springs, Wyoming, in the D istrict of Wyoming,defendants KEV IN TIJBBS, REBE CCA R UBIN, and unindicted co-conspirators JAC OBJEREM IAH FERG USO N, W ILLIAM C. RODG ERS, and others, unlawfully and willfullycaused and aided, abetted, counseled, commanded, induced, and procured the attempt to dam ageor destroy, by means o f fire and an explosive, a building and othe r real and pe rsonal property



14/54

owned and possessed by the United S tates and the Bureau of Land Managem ent o f theDepartment of the Inttxior, located at the Wild Horse Holding Facility, Rock Springs, Wyoming.

7a . In or about September 1998, defendants KEV IN TU BBS, REB ECCA RUBIN,and unindicted co-conspirators JACOB JEREMIAH FERGUSON and WILLIAM C. RODGERSarrived at the staging iuea near Rock Springs, Wyoming, assigned roles, prepared time-delayedincendiary devices, and made preparations for the arson, when a law enforcement officer madeinquiry as to their presence at that location.

7b. In or about September, 1998, defendants KEVIN TU BBS , REB ECC A RUBIN,

and unindicted co-conspirators JACOB JEREMIAH FERGUSON, WILLIAM C. RODGERS,and others, buried the time-delayed incendiary devices in an attempt to avoid detection.

8. On or about October 11, 1998, at Rock Springs, Wyoming, in the District ofWyoming, defendants JOSEPHINE SU NSHINE OVERA KER, KEVIN T UBBS , STANISLASGREGORY M EYERI-IOFF, REBEC CA RUBIN, CHELSEA DAW N GEFUACH, andunindicted co-conspirators JACOB JEREMIAH FERGUSON and WILLIAM C. RODGERSunlawfully and willfully caused and aided, abetted, counseled, commanded, induced, andprocured the attempt to damage and destroy, by means of fire and an explosive, buildings andother real and personal property owned and possessed by the United States 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 SUNS HINEOVERAKER, KEVIN TUBBS, STANISLAS GREGORY MEYERH OFF, REBECCA RUBIN,CHELSEA DAWN GEFUACH, and unindicted co-conspirators JACOB JEREMIAH



15/54

FERGU SON and WILLIAM C. RO DGER S brought digital timers, containers of fuel, two-wayradios and a scanne r, to a staging area near the Wild Horse Ho lding Facility.

8b . On or about October 11, 1998, at Rock Springs, Wyom ing, defendantsJOSEPHINE SUNSHINE OVERAKER, KEVIN TUBBS, STANISLAS GREGORYMEYERHO FF, REBECC A RUBIN, CHELSEA DAW N GERLAC H, and unindicted co-conspirators JACOB JEREMIAH FERG USON and WILLIAM C. ROD GERS went to the WildHorse Holding Facility, and began the release of horses and the placin g of incendiary devices inand about the facility.

8c. On or about October 11, 1998, at Rock Springs, Wyoming, defendantsJOSEPHINE S UN SH N E OVERAKER, KEVIN TUBBS, STANISLAS GREGORYMEYERHO FF, REBEC CA RUBIN, CHELSEA DAW N GER LACH, and unindicted co-conspirators JACOB JEREMIAH FERGUSON and WILLIAM C. RODGERS hid timingdevices in large rock out-croppings near the Wild H orse Holding Fa cility, after hearing on theirscanner that police had been dispatched to their location.

8d. On or about Novem ber 13, 1998, certain defendants in the Wild Horse HoldingFacility attempted arson issued a statement attributing responsibility for the horse release andattempted arson to the Animal Liberation Front (ALF).

9. On or a.bout October 19, 1998, in Eagle Co unty, Colora do, defendantsJOSEPHINE SUNSHINE OVERAKER, KEVIN TUBBS, STANISLAS GREG ORYMEYERHO FF, REBEC CA RUBIN, CHELSEA DAW N GER LACH, and unindicted co-conspirators JAC OB JEREMIAH FERGU SON and W ILLIAM C . RODG ERS unlawfully andwillfully caused and aided, abetted, counseled, commanded, induced, and procured the malicious



16/54

damag ing and destroying, by means of fire and explosives, of buildings and other real andpersonal property used in interstate commerce and in activities affecting interstate comm erce, atthe Vail Ski 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 December 22, 1998, at Medford, Jackson County, Oregon, defendantsKENDALL TAN KERSLE Y, KEVIN TUBBS, REBECCA R UJ IN , and unindicted co-conspirator JACOB J:EREMIAH FERGUSON unlawfully and willfully caused and aided,

abetted, counseled, comman ded, induced, and procured the attempt to damage 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 com merce, namely, an office building an d itscontents at U.S. Forest Industries, 261 1 Whittle Avenue, M edford, Jack son C ounty, Oregon.

10a. A few weeks prior to December 22, 1998, defendants K END ALLTANKERSLEY, KEVIN TUBBS, REBECC A RU BIN, and unindicted co-conspirator JACOBJEREMIA H FERG US ON performed a reconnaissance and "dry run" for the arson at the U.S.Forest Industries building in Medford, O regon.

lob . On or about December 22, 1998, at Medford, Jackson County, Oregon, defendantsKENDALL TANKEFSLEY , KEVIN TUBBS, REBECCA RUBIN, and unindicted co-conspirator JAC OB JER EMIAH FERGUS ON placed time-delayed incendiary devices at andabout the U .S. Forest Industries building.

10c. Prior to December 27, 1998, after placement of the time-delayed incendiarydevices at the U.S. Forest Industries building, defendant KENDAL L T ANK ERS LEY and

Page 16 - 1NFORMA.TION


17/54

unindicted co-conspirator JAC OB JEREM IAH FER GUSO N searched the media and found nomention o f the burniqg of the U.S. Forest Industries building.

10d. Between December 22 and 27, 1998, defendant KEND ALL TANKER SLEY andanother person returned to the U.S. Forest Industries building to check on the destructive devices.

11. On or about December 27, 1998, at Medford, Jackson County, Oregon, defendantKENDALL TANK ERSLE Y and unindicted co-conspirator JACO B JEREM IAH FERGUSO Nunlawfully and willfully caused and aided, abetted, counseled, commanded, induced, andprocured the ma licious damaging and destroying, by means of fire and an explosive, of a building

and other real and per:sonal property used in interstate com merce and used in activities affectinginterstate commerce, namely, an office building and its contents at U.S. Forest Industries, 261 1Whittle A venue, Medford, Jackson C ounty, Oregon.

1 1a. On or about December 27, 1998, defendant KEN DALL TANK ERSLE Y andunindicted co-conspirator JAC OB JER EMIAH FER GU SON returned to the U.S. ForestIndustries building, placed a new time-delayed incen diary device at or about the building, and leftthe area.

1 b . On or about December 27, 1998, defendant KEN DAL L TAN KERSL EY andunindicted co-conspirator JACO B JEREM IAH F ERGU SON traveled to D unsmu ir, California, toavoid detection.

1 c . On or about December 27, 1998, defendant KEN DALL T AN KE RSL EYregistered under the fa.lse name of Teresa Capelli in the Cedar Lodg e Mo tel in Dunsm uir,California.



18/54

1 d . On or about January 16, 1999, certain defendants in the U.S. Forest Industriesarson issued a com mu nique attributing the fire to the Earth Liberation Front (ELF ). Thecommunique was pubslicized by Craig Rosebraugh of the Liberation Collective in Portland,Oregon.

12. On or about May 9 , 1999, at Eugene, Lane County, Oregon, defendantsJOSEPHINE SUNSHINE OVERAKER, KEVIN TUBBS, STANISLAS GREGORYMEYER HOFF, CHELSEA D AW N GERLA CH, and unindicted co-conspirator JAC OBJEREM IAH F ERG USO N, and others, 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 building an d other real and personal prope rty used in interstatecommerce and in activities affecting interstate commerce, at Childers Meat Company, 29476Airport Road, Eugene, Lane C ounty, Oregon.

12a. On or about May 9, 1999, defendants JOSEPHINE SUNSH INE OVERA KER,KEVIN TUBBS, STANISLAS GREGORY MEYERHOFF, CHELSEA DAW N GERLACH,and unindicted co-conspirator JACO B JEREM IAH FE RGU SON and another prepared five-gallon buckets, timers and fuel for the arson which was to occur at the Childers Meat Company,Eugene, Oregon.

12b. On or about May 9, 1999, defendants JOSEPHINE SUNS HINE OVERA KER,KEVIN TUBBS, STANISLAS GREGORY MEYERHOFF, CHELSEA DAWN GERLACH, andunindicted co-conspir,ator JACO B JER EMIA H FER GU SON and another traveled to the ChildersMeat C ompany and placed one time-delayed incendiary device near the front of the officebuilding and placed another such device at the back o f the building near a gas m eter.



19/54

12c. On or about May 27, 1999, certain defendants in the Childers arson issued acomm unique attributiing the fire to the Anima l Liberation Front (ALF). Th e communique w aspublicized b y the ALE; Fron tline Information Service.

13. On or about December 25, 1999, at Monmouth, Polk County, Oregon, defendantsJOSEPHINE SUNSHINE OVERAKER, STANISLAS GREG ORY MEYER HOFF, CHELSEADAWN G ERLACH, and unindicted co-conspirator JACOB JE m M IA H FERGU SONunlawfully and willfullly caused and aided, abetted, counseled, com manded , induce d, andprocured the ma licious dam aging and destroying, by means of fire and an explosive, o f a buildingand other real and personal property used in interstate comm erce and in ac tivities affectinginterstate commerce, at the Boise Cascade Office, 450 North Pacific Avenue, Monmouth, PolkCounty, Oregon.

13a. On or about December 25, 1999, defendants JOSE PHINE SUNSHINEOVERAKER, STANISLAS GREGORY MEYERHO FF, CHELSEA DAW N GERLACH, andunindicted co-conspirator JACOB JEREM IAH FER GUS ON prepared time-delayed incendiarydevices to be used at the Bois e Cascade O ffice, and, after disguising the devices by wrappingthem in Christmas paper, transported the devices to the Boise Cascade Office location.

13b. On or about Decem ber 25, 1999, at Monm outh, Polk County, Oregon, defendantsJOSEPHINE S U NS HN E OVERAKER, STANISLAS GREGORY MEYERH OFF, CHELSEADAW N GERLA CH, and unindicted co-conspirator JACO B JEREM IAH FER GUS ON placed

time-delayed incendiary devices at and about the Boise Cascade O ffice building a nd left the area.13c. On or about Decem ber 30, 1999, certain defendants in the Bo ise Cascade arson

issued a comm unique attributing the fire to the Earth Liberation Front (ELF). The communique



20/54

was publicized by Craig Rosebraugh of the Liberation Collective in Portland, Oregon, and theNorth Am erican ELF Press Office.

14. On or about Decem ber 30, 1999, in Deschutes County, Oregon, defendantsJOSEPHINE SUNSHINE OV ERAKER, STANISLAS GREGORY M EYERHOFF, CHELSEADAW N G ERLACH, and unindicted co-conspirator JACO B JEREM IAH FER GUSO N willfullydamaged and attempted to damage the p roperty of an energy facility of the U nited S tates, namely,a Bonneville Power A dministration tow er, involved in the transmission and distribution o felectricity near the City of Bend, Oregon, in an am ount exceeding or which would have exceeded

$100,000.15. During 2000 and 2001, several of the defendants and others met in what the

participants called "Book Club" meetings. These meetings occurred in Eugene, Oregon; Tucson,Arizona; Santa Cmz, California; and Sisters, Oregon. The participants conduc ted classes at thesemeetings in clandestine methods of comm itting direct actions, including the manufacture ofmechanical and electrical timing devices for setting off improvised incendiary devices,reconnaissance of targets, lock-picking, and computer security.

16. On or about September 6, 2000, at Eugene, Lane County, O regon, defendantsSTANISLAS GREGO RY MEYERHOFF, KEVIN TUBBS and CHELSEA DAW N GERLACHunlawfully and willfully caused and aided, abetted, counseled, commanded, induced, andprocured the malicious damaging and destroying, by mean s of fire and an explosive, of a buildingand other real and personal property used in interstate commerce and in activities affectinginterstate commerce, at the Eugene Police Department W est University P ublic Safety Station,79 1 East 13thAvenue, Eugene, Oregon.



21/54

16a. On or about September 6,2 00 0, defendants STANISLAS GR EGO RYMEYERHOFF, KEVIN TUBBS and CHELSEA DAW N GER LACH traveled to the EugenePolice Department West University Public Safety Station and placed time-delayed incendiarydevices at and about the police station.

17. On or abo ut January 2, 200 1, at Glendale, Douglas County, O regon, defendantsSTANISLAS GREG ORY MEYERHOFF, KEVIN TUBBS, DANIEL GERA RD McGOWAN,SUZANNE SAV OIE.,and unindicted co-conspirator JACOB JER EM IAH FERG USO Nunlawfully 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 and used i n activities affectinginterstate com merce, namely, a building and its contents located at Superior Lumber Company,2695 Glendale Valley Road, Glendale, Douglas County, Oregon.

17a. On or about January 2, 20 0 1, defendants STANISLAS GREG ORYMEYERHOFF, KEVIN TUBBS, DANIEL GERARD McGOWAN , SUZA NNE SAVOIE, andunindicted co-conspir,ator JACO B JEREMIAH FER GUS ON traveled in separate vehicles to apredetermined staging, area at a rest area located just north o f the town o f Glendale, O regon, onInterstate 5, where they dressed in dark clothing and put on their radio earpieces and masks.

17b . On or about January 2, 20 0 1, defendants STANISLAS GREG ORYMEYERHOFF, KEVIN TUBBS, DANIEL GERARD McGOWA N, SUZA NNE SAVOIE, and

unindicted co-conspirator JACOB JEREMIAH FER GUS ON 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 a rea.

Page 2 1 - INFORMATION


22/54

17c. On or about January 2,2001, defendants STANISLAS GREGORYMEYERHO FF, KEVIN TUBBS, DANIEL GERARD M cGOW AN, SUZAN NE SAVOIE, andunindicted co-conspirator JACO B JEREM IAH FER GUS ON , 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 unique attributing the fire to the Earth Liberation Front (ELF). Thecommunique was publicized by C raig Rosebraugh of the North Am erican ELF Press O ffice.

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

STANISLAS GREG ORY MEYERHOFF, KEVIN TUBBS, NATHAN FRASER BLOCK ,JOYANNA L. ZACH ER, and unindicted co-conspirator WILLIAM C . ROD GER S, unlawfullyand willfully caused and aided, abetted, counseled, commanded, induced, and procured themalicious dam aging and destroying, by mean s of fire and an explosive, of vehicles and otherpersonal property used in interstate commerce and in activities affecting interstate commerce, atJoe Rom ania C hevrolet Truck Center, 1425 Walnut Street, Eugene, Oregon.

18a. On or about March 30,2001, defendants STANISLAS GREGORYMEYERHO FF, KEVIN TUBBS, NATHAN FRASER BLOC K, JOYAN NA L. ZACHER, andunindicted co-conspirator W ILLIAM C. RO DGE RS traveled to Joe Rom ania Chevrolet TruckCenter and stationed KEVIN TUB BS and JOYA NNA L. ZACHER as lookouts, while the othersplaced an incendiary device and plastic containers filled with gasoline underneath the vehiclesand connected the vehicles and containers with rolled-up sheets soaked in gasoline.



23/54

18b. On or about March 31,2 00 1, certain defendants in the Rom ania Chevrolet arsonissued a communique which w as publicized by Craig Rosebraugh of the North American ELFPress Office.

19. On or about May 21 ,2 00 1, at Clatskanie, Colum bia County, Oregon, defendantsSTANISLAS GREGORY M EYERHOFF, KEVIN TUBBS, DANIEL GERARD M cGOWAN,CHELSEA DAWN GERLACH, NATHAN FRASER BLOCK, JOYAN NA L. ZACHER,SUZA NNE SAVO IE., and unindicted co-conspirator WILLIAM C . RODG ERS unlawfully andwillfully caused and aided, abetted, counseled, comm anded, induced, and procured the m alicious

dama ging and destroying , by means of fire and an exp losive, of buildings, vehicles and other realand personal property used in interstate commerce and in activities affecting interstatecommerce, at Jefferson Poplar Farm, 791 14 Collins Road, Clatskanie, Colum bia County,Oregon.

19a. At a tirne prior to May 21,2 001 , defendants STANISLAS GREGOR YMEYERHOFF, NATHAN FRASER BLOCK, JOYANNA L. ZACHER, CHELSEA DAWNGERLACH , DANIEL GER ARD M cGOWA N, and unindicted co-conspirator WILLIAM C.ROD GER S participated in a meeting in which it was decided by those present that two arsonswould be carried out at the same time, one at the Jefferson Poplar Farm in Clatskanie, Oregon,and the other at the U niversity of W ashington Horticulture Center in Seattle, Washington.

19b. At a tirne prior to May 21 , 2 0 01, defendants STANISLAS GREG ORY

MEYERHOFF, CHELSEA DAW N GERLACH, DANIEL GERARD McGO WAN , KEVINTUBBS, SU ZANNE SAVOIE, and unindicted co-conspirator JACOB JEREMIA H FERGU SONperformed a reconnaissance for the arson at the Jefferson Poplar Farm.



24/54

19c. On or about May 2 1, 20 01, defendants STANISLAS G REGO RY M EYERHOFF,DAN IEL GER AR D PVlcGOWAN, NATH AN FRA SER BLOC K, JOYAN NA L. ZACH ER, andSUZA NNE SAVO IE traveled to Jefferson Poplar Farm.

19d. On or about May 2 1 , 2 0 01, defendants STANISLAS GR EGOR Y M EYERHOFF,DANIEL GERARD M cGOWA N, 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 , 2 0 01, certain defendants in the Jefferson P oplar Farm arsonspray-painted graffiti at the site attributing the action to the Earth Liberation F ront (ELF ).

19f. On or about June 1,2 00 1, certain defendants in the Jefferson Poplar Farm arsonissued a commu nique attributing the fire, along with the University of Wash ington fire describedbelow, to the Earth Liberation Front (ELF). The comm unique was publicized by CraigRosebraugh of the North Am erican ELF Press O ffice.

20 . On or about May 2 1, 2001, at Seattle, Washington , in the W estern District ofWashington, defendants STANISLAS GREGO RY MEY ERHOFF, CH ELSEA DA WNGERLA CH, unindictled 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 o f fire and an explosive, of a building and otherreal and personal property used in interstate commerce an d in activities affecting interstate

commerce, at the University of Washington Horticulture Center, Seattle, Washington.20a. At a time prior to May 2 1,2 00 1, defendant STANISLAS G REGO RY

MEY ERHO FF, unindicted co-conspirator WILLIAM C. ROG ERS and other persons performed



25/54

one or more reconnaissances of the University of Washington Horticulture Center, Seattle,Washington.

20b. On or about June 1, 20 01 , certain defendants in the University of Washingtonarson issued a communique attributing the fire, along with the Jefferson Poplar Farm firedescribed above, to the Earth Liberation Front (ELF). The comm unique was publicized by CraigRosebraugh of the North American ELF Press Office.

2 1. On or before May 28 ,20 0 1, defendant STAN ISLAS GREG ORY MEYERHO FFand unindicted co-conspirator W ILLIAM C. ROD GERS authored and published a document

entitled "Setting Fire with Electrical Time rs, an Earth Liberation Front Guide" in order to exposeto a widespread audience their methods of 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 enforcement.

22. On or about O ctober 15, 2001, at Litchfield, California, in the Eastern D istrict ofCalifornia, defendants STANISLAS GREGORY MEYERHOFF, JOSEPH DIBEE, REBECCARUBIN, KEVIN TUB;BS, CHELSEA DAW N GERLA CH, DARREN T ODD TH URSTON,unindicted co-conspirator WILLIAM C. RODGERS, and other persons unlawfully and willfullycaused and aided, abetted, counseled, commanded, induced and procured the malicious damagingand destroying, by means o f fire and explosives, of buildings and other real and personal propertyowned and possessed by the United States and the Bureau of Land Management of theDepartment of the Interior, located at the Wild Horse Facility, Litchfield, Califomia.



26/54

22a. On or about October 15 ,20 01 , defendant STANISLA S GRE GO RYMEYERHOFF and other persons placed time-delayed incendiary devices at and about theLitchfield Wild Horse Facility.

22b. On or abou t October 30, 2001, certain defendants in the Litchfield W ild HorseFacility arson issued a communique attributing the fire to the Earth Liberation Front (EL F). Thecommunique was publicized by David Barbarash at the North American ALF Press Office.

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

ARSON - OAKRIDGE RANGER STATIONOn or abo ut October 30, 1996, in Lane Coun ty, Oregon, in the District of Oregon,

defendants JOSEPHINE SUNS HINE OVERA KER and KEVIN TUB BS, and another personknown to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,comm anded, induced,, and procured the malicious dam aging and destroying, by m eans o f fire andan explosive, of a building and other real and personal property owned an d possessed by theUnited States and the United States Forest Service of the Department o f Agriculture, located atthe Oakridge Ranger Station on the Willamette National Forest; all in violation o f Title 18,United States Code, S ections 844(f) and 2.

COUNT 3ARSON - CAVEL WEST

On or about July 2 1, 1997, at Redm ond, D eschutes Coun ty, Oregon, in the District ofOregon, defendants KEVIN TUBBS, JOSEPH DIBEE, and JONATHAN CHRISTOPHERMARK PAU L, and other persons known to the Grand Jury, unlawfully and willfully caused and



27/54

aided, abetted, counseled, commanded, induced, and procured the malicious damaging anddestroymg, by mean s of fire and an explosive, of a building and other real and personal propertyused in interstate com merce and in activities affecting interstate com merce, at Cave1 West, Inc.,1607 SE Railroad, Redm ond, O regon; all in violation of Title 18, United States Code , Sections844(i) and 2.

COUNT 4ARSON - BLM WILD HORSE FACILITY, BURNS, OREGON

On or about November 30, 1997, in Harney County, Oregon, in the District of Oregon,

defendants JOSEPHINE SUNSHINE OVERAKER, KE VIN TUBBS and REBECCA RUBIN,unindicted co-conspirator WILLIAM C. ROD GER S, and another person known to the GrandJury, unlawfully and willfully caused and aided, abetted, counseled, commanded, induced, andprocured the ma licious damaging and destroying, by means of fire and an explosive, of buildingsand other real and personal property owned and possessed by the United S tates and the Bureau ofLand Managem ent of the Department o f the Interior, located at the W ild Horse and BurroFacility, Bu ms, Harney Coun ty, Oregon; all in violation of Title 1 8, United States Code , Sections844(f), 844(i) and 2.

COUNT 5ATTEMPTED ARSON - U.S. FOREST INDUSTR IES

On or about Decem ber 22, 1998, at Medford, Jackson C ounty, Oregon, in the District ofOregon, defendant KENDALL TANKERSLEY, KEVIN TUBBS, and REBECCA RUBIN, andanother person known to the Grand Jury, unlawfully and willfully caused and aided, abetted,counseled, comm anded, induced , and procured the attempt to damage or destroy, by means of



28/54

fire and an explosive, a building and other real and personal property used in interstate commerceand used in activities affecting interstate commerce, namely, an office building and its contents atU .S. Forest Industries, 261 1 Whittle Avenue, Medford, Jackson County, Oregon; all in violationof Title 18, United States Code, Se ctions 844(i) and 2.

COUNT 6ARSON - CHILDERS MEAT COMPANY

On or about May 9, 1999, at Eugene, Lane County, Oregon, in the District of Oregon,defendants JOSEPHINE SUNSHINE OVERA KER, KEVIN TUBBS, STAN ISLAS GREGORY

MEYE RHOFF and CHELSEA D AW N G ERLACH , and other persons known to the Grand Jury,unlawfully and willfully caused and aided, abetted, counseled, commanded, induced, andprocured the malicious damaging and destroying, by means of fire and an explosive, of a buildingand other real and personal property used in interstate com merce and in ac tivities affectinginterstate commerce, at Childers Meat Company, 29476 Airport Road, Eugene, Oregon; all inviolation o f Title 18, United States Code, S ections 844(i) and 2.

COUNT 7ARSON - EPD PUBLIC SAFETY STATION

On or about S eptember 6, 20 00 , at Eugene, Lane County, Oregon, in the District ofOregon, defendants STANISLAS GREG ORY M EYERHO FF, KEVIN TUBBS and CHELSEADAW N GER LACH unlawfully and willfully 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 building and other real and personal property used in interstate commerce and in activitiesaffecting interstate commerce, at the Eugene Police Department West University Public Safety



29/54

Station, 79 1 East 13thAven ue, Eugene, Lane County, Oregon; all in violation of Title 18, UnitedStates Code, Sections 844(i) and 2.

COUNT 8ARSON - SUPERIOR LUMB ER COMPANY

On or about January 2, 2001, at Glendale, Douglas County, in the District of Oregon,defendants STANISLAS GREGORY MEYER HOFF, KEVIN TUBBS, DANIEL GERARDMcGO WA N and SUZA NNE SAVOIE, unlawfully and willfully caused and a ided, abetted,counseled, commanded, induced, and procured the m alicious damaging and destroying, by m eans

of fire and an explosive, of a building and other real and personal property used in intersta tecommerce and used in activities affecting interstate commerce, namely, a building and itscontents located at Superior Lumber Company, 2695 Glendale Valley Road, G lendale, DouglasCounty, Orego n; all in violation of Title 18, United S tates Code, Sectio ns 844(i) and 2.

COUNT 9ARSON .- ROMANIA CHEVROLET TRUCK CENTER VEHICLE

On or about March 3 0,2 001 , at Eugene, Lane County, in the District of Oregon,defendants KEVIN TUBBS, STAN ISLAS GREGORY MEYERHO FF, 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 meansof fire and an explosive, of a vehicle used in interstate comm erce and used in a ctivities affectinginterstate com merce, namely, a 2001 Suburban, bearing Vehicle Identification Number3GNG K26U41G 209163, located at Rom ania Chevrolet Truck Center, 1425 Walnut Street,



30/54

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

COUNT 10ARSON -.ROMANIA CHEVROLET TRUCK CENT ER VEHICLE

On or about March 3 0,2 00 1, at Eugene, Lane County, in the District of Oregon,defendants KEVIN TUBBS, STANISLAS GREGORY MEYERHOFF, N ATHA N FRASERBLOCK, 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 comme rce and used in activities affectinginterstate commerce, namely, a 2001 Tahoe, bearing Vehicle Identification Number1GNEK13T7 1Rl 548 66, 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.


On or about March 30 ,20 01 , at Eugene, Lane County, in the District of Oregon,defendants KEVIN TUBBS, STANISLAS GREGORY M EYERHOFF, NATHAN FRASERBLOCK, and JOYANN A 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 Number3GNGK26G8 1G235050, located at Romania Chevrolet Truck Center, 1425 Walnut Street,



31/54

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

COUNT 12ARSON - ROMANIA CHEVROLET TRUCK CENTER VEHICLE

On or about March 3 0,2 00 1, at Eugene, Lane County, in the District of Oregon,defendants KEVIN TIJBBS, STANISLAS GREGO RY MEYERHOFF, NATHAN FRASERBLOCK, and JOYANN A L. ZACHER, unlawfully and willfully caused and aided, abetted,counseled, commanded, induced, and procured the malicious damaging and d estro yng , 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 Number3GNGK 26G81G203 103, located at Roma nia Chevrolet Truck Center, 1425 Walnut Street,Eugene, La ne County., Oregon; all in violation of T itle 18, United States Code, Sec tions 844(i)and 2.

COUNT 13ARSON ,- ROMANIA CHEVROLET TRUCK CENTER VEHICLE

On or about M .arch 30, 2001, at Eugene, Lane County, in the District o f Oregon,defendants KEVIN TUBBS, STANISLAS GREGORY M EYERHOFF, NATHAN FRASERBLOC K, and JOY ANN A 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 activities affectinginterstate commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number3GNFK16T3 1Gl974;72, located at Romania Chevrolet Truck Center, 1425 Walnut Street,



32/54

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

COUNT 14ARSON - ROMANIA CHEVROLE T TRUCK CENTER VEHICLE

On or about Ma rch 30, 2001, at Eugene, Lane County, in the District of Oregon,defendants KEVIN TlJBBS, STANISLAS GREGORY M EYERHOFF, NATHA N FR ASERBLOC 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 activities affectinginterstate commerce, namely, a 2001 Tahoe, bearing Vehicle Identification Number1GNE Kl3TO l J18 1082, located at Romania Chevrolet Truck Center, 1425 Walnut S treet,Eugene, Lane Co unty, Oregon; all in violation of Title 1 8, United States Code, S ections 844(i)and 2.

COUNT 15ARSON .- ROMANIA CHEVROLET TR UCK CENTER VEHICLE

On or about March 30, 2001, at Eugene, Lane County, in the District of Oregon,defendants KEVIN TTJBBS, STANISLAS GREGORY MEYERHOFF, NATHAN FRASERBLOC K, and JOYA NNA L. ZACHE R, 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 Tahoe, bearing Vehicle Identification Number1GNEK 13T4 1R110162, located at Romania Chevrolet Truck Center, 1425 Walnut Street,

Page 32 - INFORMATlON


33/54

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 FRASERBLOCK, and JOYANN 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 comm erce and used in activities affectinginterstate commerce, namely, a 2001 Tahoe, bearing Vehicle Identification Number1GNEK 13T3 1 150960, located at Rom ania 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 17ARSON - ROMAN IA CHEVROLET TRUCK CENTER VEHICLE

On or about March 30, 2001, at Eugene, Lane County, in the District of Oregon,defendants KEVIN TIJBBS, STANISLAS GREGORY M EYERH OFF, NATHAN FRA SERBLOC K, and JOYA hMA L. ZACHER , unlawfully and willfully caused and aided, abetted,counseled, commanded, induced, and procured the malicious damaging and destroying, by meansof fir e and an explosive, o f a vehicle used in interstate comme rce and used in activities affectinginterstate commerce, namely, a 200 1 Suburban, bearing Vehicle Identification Num ber3GNFK16T71G 228593, located at Romania Chevrolet Truck Center, 1425 Walnut Street,



34/54

Eugene, Lane County,, Orego n; all in violation of Title 18, United States Co de, Sec tions 844(i)and 2.

COUNT 18

ARSON - ROMANIA CHEVROLET TRUCK CENTER VEHICLEOn or about March 3 0,2 001 , at Eugene, Lane County, in the District of Oregon,

defendants KEVIN TUBBS, STAN ISLAS GREGORY MEYER HOFF, NATHAN FRASERBLOCK , 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 means

of fire and an explosive, of a vehicle used in interstate comm erce and used in a ctivities affectinginterstate commerce, namely, a 2001 Tahoe, bearing Vehicle Identification NumberlGN EK1 3T51R 148547, 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 19ARSON -- ROMANIA CHEVRO LET TRUCK CENTER VEHICLE

On or about March 3 0,2 001 , at Eugene, Lane County, in the District of Oregon,defendants KEVIN TIJBBS, STANISLAS GREG ORY M EYERHOFF, NA THAN FR ASERBLOCK, and JOYANNA L. ZAC HER , unlawfully and w illfully 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 and used in ac tivities affectinginterstate com merce, namely, a 2001 Suburban, bearing Vehicle Identification Number3GNFK16T7 1G226598, located at Romania Chevrolet Truck Center, 1425 Walnut Street,

Page 34 - INFORMA'TION


35/54

Eugene, Lane Cou nty, 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 Coun ty, in the District of Oregon,defendants KEVIN TUBB S, STANISLAS GREGORY MEY ERHO FF, NATH AN FRA SERBLOC K, and JOY AN NA L. ZACHER, 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 explosive, of a vehicle used in interstate commerce and used in activities affectinginterstate commerce, nam ely, a 2001 Suburban , bearing Vehicle Identification Num ber3GNFK16T7 1G23O 1'79, located at Ro mania Chevrolet Truck Center, 1425 Walnut Street,Eugene, Lane County, Oregon; all in violation of T itle 18, United States Code , Sections 844(i)and 2.

COUNT 21

ARSON -- ROMANIA CHEVROLET TRUCK CENTER VEHICLEOn or about M arch 30 ,200 1, at Eugene, Lane County, in the District of O regon,

defendants KEVTN TU BBS, STANISLAS GREG ORY MEY ERHO FF, NATH AN FRASERBLOCK , and JOY AN NA L. ZACHER , unlawfully and willfully caused and aided, abetted,counseled, commanded , induced, and procured the malicious da mag ing 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 ber1GN EK l3T 8 lRl694!JO, located at Rom ania Chevrolet Truck Center, 1425 Walnut Street,



36/54

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

COUNT 22

ARSON - ROMANIA CHEVROLET TRUCK CENTER VEHICLEOn or about March 30 ,20 01 , at Eugene, Lane County, in the District of Oregon,

defendants KEVIN TUBBS, STAN ISLAS GREG ORY MEYE RHOFF, NAT HAN FRASERBLOCK, and JOYAhW A L. ZAC HER , unlawfully and willfully caused and aided, abetted,counseled, commanded, 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 c omm erce, namely, a 2001 Suburban, bearing Vehicle Identification Num ber3GNGK26G2 1G201069, located at Romania C hevrolet Truck C enter, 1425 Walnut Street,Eugene, Lane County, O regon; all in violation of Title 18, United States Code, S ections 844(i)and 2.

COUNT 23ARSON - ROMANIA CHEVROLET TRUCK CEN TER VEHICLE

On or about M arch 30, 2001, at Eugene, Lane County, in the District of Oregon,defendants KEVIN TIJBBS, STANISLAS GREG ORY MEY ERHO FF, NATHA N FRASERBLOC K, and JOY AN NA L. ZAC HER , 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 comm erce and used in activities affectinginterstate comm erce, namely, a 2001 Suburban, bearing Vehicle Identification Num ber3GN FK1 6TX l G206720, located at Rom ania Chevrolet Truck Center, 1425 Walnut Street,



37/54

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

COUNT 24ARSON -. ROMANIA CHEVROLET TRUCK CENTER VEHICLE

On or about March 3 0,2 00 1, at Eugene, Lane County, in the District of Oregon,defendants KEVIN TIBBS, STANISLAS GREGORY MEYERHOFF, NATHAN FRASERBLOC K, and JOY ANN 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 Number3GNFK16T91G 226.585, located at R omania Chevrolet Truck Center, 1425 Walnut Street,Eugene, Lane County, Oregon; all in violation of Title 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 MEYERHO FF, NATHA N FRASERBLOCK, and JOYANN A 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 200 1 Suburban, bearing Vehicle Identification Number3GNFK16T6 1G2298 16, located at Romania Chevrolet Truck C enter, 1 425 Wa lnut Street,



38/54

Eugene, Lane C ounty., Oregon ; all in violation of Title 18, United States Co de, Sec tions 844(i)and 2.


On or about March 30, 2001, at Eugene, Lane County, in the District of Oregon,defendants KEVIN TlJ JB S, STANISLAS GREGORY MEYERHOFF, 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 means

of fire and an explosive, of a vehicle used in interstate comm erce and used in a ctivities affectinginterstate commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number3GNG K26U21G180066, located at Romania Chevrolet Truck Center, 1425 Walnut Street,Eugene, Lane County, Oregon; all in violation of Title 1 8, 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 TIJBBS, STANISLAS GREGOR Y MEYER HOFF, NATHA N FRASERBLOCK, and JOYAN NA L. ZACHE R, 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 commerce, namely, a 200 1 Suburban, bearing Vehicle Identification Number3GNGK26U8 1G181349, located at Romania Chevrolet Truck Center, 1425 Walnut Street,



39/54

Eugene, Lane County., 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 TIJBBS, STANISLAS GREGORY M EYERH OFF, NATH AN FRASERBLOCK, and JOYANNA L. ZAC HER , unlawfully and willfully caused and aided, abetted,counseled, com manded, induced , and procured the m alicious damaging a nd 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 Tahoe, bearing V ehicle Identification Num ber1GNEKl3T8 1R l60 80 6, located at Rom ania 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 March 3 0,2 00 1, at Eugene, Lane County, in the District of Oregon,defendants KEVIN TTB BS, STANISLAS GREGORY MEYERH OFF, NATHAN FRASERBLOC K, and JOYA NNA L. ZACHE R, unlawfully and willfully caused and aided, abetted,counseled, comman ded, 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 Suburban, bearing Vehicle Identification Number3GNFK16TOlG1556.50, located at R omania C hevrolet Truck Center, 1425 Walnut Street,



40/54

Eugene, Lane C ounty,, Oregon; all in violation o f Title 18, United States Co de, Sections 844(i)and 2.


On or about M arch 30 ,20 01 , at Eugene, Lane County, in the District of Oregon,defendants KEVIN TUBBS, STANISLAS GREGORY MEY ERHO FF, NATHAN FRASERBLOC K, and JOY AN NA L . ZACHER, unlawfully and willfully caused and aided, abetted,counseled, command ed, 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 commerce, namely, a 2001 Suburban, bearing Vehicle Identification Num ber3GN FK1 6TOlG 2068:38, located at Rom ania Chevrolet Truck Center, 1425 Walnut Street,Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, Sections 8 44(i)and 2.

COUNT 31

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

defendants KEVIN TLTBBS, STANISLAS GREG ORY M EYERH OFF, NA THA N FRASE RBLOCK , and JOY AN NA L. ZACHER , unlawfully and willfully caused and aided, abetted,counseled, commanded , induced, and procured the malicious d amaging and d estroymg, by meansof fire and an explosive, o f a vehicle used in interstate comm erce and used in activities affectinginterstate comm erce, namely, a 2001 Sub urban, bearing Vehicle Identification Num ber3GN FK1 6T31G195205, located at Rom ania Chevrolet Truck Center, 14 25 Walnut S treet,



41/54

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


On or about March 30 ,20 01 , at Eugene, Lane County, in the District of Oregon,defendants KEVIN TTJBBS, STANISLAS GREGOR Y MEY ERHOFF, NA THA N FRASE RBLOC K, and JOYA NNA L. ZACH ER, unlawfully and willfully caused and aided, abetted,counseled, commande:d, induced, and procured the malicious d amaging and destroying, by m eans

of fire and an e xplosive, of a vehicle used in interstate commerce and used i n activities affectinginterstate comm erce, namely, a 2001 Suburban, bearing Vehicle Identification Num ber3GNFK16TX1G225834, located at Romania Chevrolet Truck Center, 1425 Walnut Street,Eugene, Lane County,, Oregon; all in violation o f Title 18, United States C ode, S ections 844(i)and 2.

COUNT 33ARSON ,- ROMANIA CHEVROL ET TRUCK CENTER VEHICLE

On or abou t M:arch 30, 2001, at Eugene, Lane C ounty, in the District of Oreg on,defendants KEVIN TTJBBS, STANISLAS GREGOR Y MEY ERHOFF, N ATH AN FR ASERBLOC K, and JOYA NN A L. ZACHE R, unlawfully and willfully caused and aided, abetted,counseled, commande:d, induced, and procured the malicious damaging and destroying, by meansof fire and an e xplosive, of a vehicle used in interstate commerce and used in activities affectinginterstate comm erce, namely, a 2001 Suburban, bearing Veh icle Identification Num ber1GNFK16T2 15242612, located at Roma nia Chevrolet Truck Center, 14 25 Walnut Street,



42/54

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


On or abou t March 30, 2001, at Eugene, Lane County, in the District of Oregon,defendants KEVIN TUBB S, STANISLAS GREGORY M EYERHOFF, NATH AN FRA SERBLOC K, and JOY AN NA L. ZACHER, 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 explosive, o f a vehicle used in interstate comm erce and used in activities affectinginterstate comm erce, namely, a 20 0 1 Suburban, bearing Vehicle Identification Nu mber3GNGK26U8 1G I9 26 12, located at Rom ania Chevrolet Truck Center, 1425 Walnut Street,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 TUBBS, STANISLAS GREGORY MEYERHO FF, NATHA N FRASERBLOCK , and JOYA NN A L. ZACHER, 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 commerce and used in activities affectinginterstate comm erce, nam ely, a 2001 Taho e, bearing Vehicle Identification Nu mber1G N E Kl3 T7 l R l l 6 389, located at Rom ania Chevrolet Truck Center, 142 5 Walnut Street,



43/54

Eugene, Lane Coun ty, Oregon; all in violation of Title 18, United States Code, Sections 8 44(i)and 2.

COUNT 36

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

defendants KEVIN TIJBBS, STANISLAS GREGORY MEY ERHO FF, NATH AN FRA SERBLOC K, and JOY AN NA L. ZACHER, unlawfully and willfully caused and aided, abetted,counseled, comman ded, 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 comm erce, namely, a 2001 Sub urban, bearing Vehicle Identification Numb er3GNFK16T91G189098, located at Romania Chevrolet Truck Center, 1425 Walnut Street,Eugene, Lane Co unty, 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 TIJBBS, STANISLAS GREGORY MEYERHO FF, NATH AN FRASERBLOCK , and JOY AN NA L. ZACHER , unlawfully and willfully caused and aided, abetted,counseled, comm anded, induced, and procured the malicious da mag ing and destroying, by meansof fire and an explo sive, of a vehicle used in interstate comm erce and used in activities affectinginterstate comm erce, namely, a 2001 Suburban, bearing Vehicle Identification Num ber3GNFK16TO 1G1984 03, located at Romania Chevrolet Truck Center, 14 25 W alnut Street,



44/54

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 ,20 01 , at Eugene, Lane County, in the District of O regon,defendants KEVIN TIJBBS, STANISLAS GREGORY MEY ERHO FF, NATH AN FRA SERBLOCK, and JOYANN A L. ZAC HER , unlawfully and willfully caused and aided, abetted,counseled, command ed, induced, and procured the malicious dam aging and destroying, by means

of fire and an explo sive, of a vehicle used in interstate comm erce and used in activities affectinginterstate comm erce, namely, a 2001 Taho e, bearing V ehicle Identification Num ber1GN EKl3TO l Jl8 33 20 , located at Romania Chevrolet Truck Center, 1425 Walnut Street,Eugene, Lane Cou nty, Oregon; all in violation of Title 18, United States Code , Sections 844(i)and 2.

COUNT 39ARSON - ROMANIA CHEVROLET TRUCK CENTER VEH ICLE

On or about March 3 0,2 00 1, at Eugene, Lane County, in the District of O regon,defendants KEVIN TTJBBS, STANISLAS GREGORY MEYERHOFF, NATHAN FRASERBLOC K, and JOY AN NA L. ZACHER , unlawfully and willfully caused and aided, abetted,counseled, commanded , 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 commerce, namely, a 2001 Subu rban, bearing Vehicle Identification Nu mber3GNFK16T9 1G2O7 194, located at Romania Chevrolet Truck Center, 1425 Walnut Street,



45/54

Eugene, Lane County, Oregon; all in violation of Title 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 FRASERBLOC K, 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 exp losi \~e , f a vehicle used in interstate commerce and used in activities affectinginterstate comm erce, namely, a 2001 Suburban, bearing Vehicle Identification Num ber3GNFK 16T8 lG l9 32 41 , located at Rom ania 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.


On or about March 3 0,2 00 1, at Eugene, Lane County, in the District of O regon,defendants KEVIN TT33BS, STANISLAS GREGORY MEYERH OFF, NA THAN FRASERBLOCK, and JOYAN NA L. ZACH ER, unlawfully and willfully caused and aided, abetted,counseled, commanded, induced, and procured the m alicious da maging and destroying, by meansof fire and an explosive, of a vehicle used in interstate commerce and used in activities affectinginterstate commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number3GNFK16T 1 1 6 1056:29, located at Roma nia Chevrolet Truck Center, 1425 Walnut S treet,



46/54

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


On or abou t March 30, 2001, at Eugene, Lane County, in the District of Oregon,defendants KEVIN TTJBBS, STANISLAS G REGORY MEY ERHO FF, NATHAN FRASERBLOCK , and JOY AN NA L. ZACHER , unlawfully and willfully caused and aided, abetted,counseled, comm anded, induced, and procured the malicious d amaging and d estroymg, by means

of fire and an explosive , of a vehicle used in interstate commerce and used in activities affectinginterstate commerce, nam ely, a 2001 Sub urban, bearing Vehicle Identification Nu mber3GNGK26U8 1Gl79567, located at Romania Chevrolet Truck Center, 1425 Walnut Street,Eugene, Lane C ounty,, Oregon; all in violation of T itle 1 8, United States Cod e, Sections 84 4(i)and 2.


On or about March 3 0,20 01, at Eugene, Lane County, in the District of Oregon,defendants KEVIN TTJBBS, STANISLAS GREGORY MEY ERHO FF, NATHAN FRASERBLOCK , and JOY AN NA L. ZACHER , unlawfully and willfully caused and aided, abetted,counseled, comm anded, induced, and procured the malicious da mag ing 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 Sub urban, bearing Veh icle Identification Num ber3GNGK26G2 1G2 15392, located at Romania C hevrolet Truck Center, 1425 Walnut S treet,



47/54

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

COUNT 44ATTEMPTED ARSON - JEFFERSON POPLAR FARM MAIN OFFICE

On or about May 21, 2001, at Clatskanie, Columbia County, in the District of Oregon,defendants STANISL'4S G REGORY MEYE RHOFF, KEVIN TUBBS, DAN IEL GERARDMcGOWAN, CHELSEA DAW N GERLACH, NATHAN FRASER BLOCK, JOYANNA L.ZAC HER , and SUZ ANN E SA VOIE, and other persons known to the Grand Jury, unlawfully and

willfully caused and aided, abetted, counseled, commanded, induced, and procured the attempt todamage o r destroy, by means of fire and an explosive, a building an d other real and personalproperty used in interstate commerce and used in activities affecting interstate commerce,namely, the main of fk e building and its contents located at Jefferson Poplar F arm, 791 14 CollinsRoad , Clatskanie, Colum bia County, Oregon; all in violation of Title 18, United States Code,Sections 844(i) and 2.

COUNT 45ARSON - JEFFERSON POPLAR FARM - VEHICLE SHOP

On or about May 2 1, 2001, at Clatskanie, C olumbia County , in the District of Oregon,defendants STANISLAS GREGOR Y MEY ERHOFF, KEVIN TUBBS, DANIEL GERA RDMcGOWAN, CHELSEA DAWN GERLACH, NATHAN FRASER BLOCK, JOYANNA L.ZAC HER , and SUZ ANN E SAV OIE, and other persons known to the Grand Jury, unlawfully andwillfully caused and arded, abetted, counseled, comm anded, induced, and procured the maliciousdamaging and destroying, by m eans o f fire and an explosive, of a building and other real and



48/54

personal property used in interstate commerce and used in activities affecting interstatecomm erce, namely, a vehicle shop and its contents located at Jefferson Poplar Farm , 791 14Collins Road, Clatskanie, Columbia C ounty, Oregon; all in violation of Title 18, United StatesCode, Sections 844(i) and 2.

COUNT 46ARSON - JEFFERSON POPLAR FARM - SHOP & OFFICE

On or about M.ay 2 1, 200 1, at Clatskanie, Colum bia County, in the D istrict of Oregon,defendants STANISL.4S GREGO RY M EYERHO FF, KEVIN TUBBS, DANIEL GE RARD

McGOWAN, CHELSEA DAW N GERLACH, NATHAN FRA SER BLOCK, JOYANNA L.ZAC HER , and SUZ ANN E SA VOIE, and other persons known to the Grand Jury, unlawfully andwillfully caused and aided, abetted, counseled, comm anded, induced, and procured the maliciousdamaging and destroying, by means of fire and an explosive, of a building and other real andpersonal property used in interstate commerce and used in activities affecting interstatecomm erce, namely, a shop and office building and its contents located at Jefferson Poplar Farm,791 14 Collins Road, C latskanie, Colu mbia C ounty, Oregon; all in violation of Title 18, UnitedStates Code, Sections 844(i) and 2.

COUNT 47A:RSON - JEFFERSON POPLAR FARM - VEHICLE

On or about May 21, 2001, at Clatskanie, C olumbia County, in the District of Oregon,defendants STANISL.AS GREGO RY M EYERHO FF, KEVIN TUBBS, D ANIEL GER ARDMcGOWAN, CHELSEA DAW N GERLACH, NATHAN FRASER BLOCK, JOYANNA L.ZAC HER, and SUZA NNE SA VOIE, and other persons known to the Grand Jury, unlawfully



49/54

and willfully caused and aided, abetted, counseled, commanded, induced, and procured themalicious damag ing and destroying, by means of fire and an ex plosive, of a vehicle used ininterstate commerce and used in activities affecting interstate comm erce, name ly, a 19 97 Fordtruck bearing Oregon license num ber VH Q 660 , located at Jefferson Poplar F arm , 791 14 CollinsRoad, Clatskanie, Columbia County, Oregon; all in violation of Title 18, United States Code,Sections 844(i) and 2.

COUNT 48ARSON - JEFFERSON PO PLAR FARM - VEHICLE

On or about May 21, 2001, at Clatskanie, Colum bia County, in the District of O regon,defendants STANISLAS GREG ORY M EYERHOFF, KEVIN TUBBS, DANIEL GERARDMcGOWAN, CHELSEA DAWN GERLACH, NATHAN FRASER BLOCK, JOYANNA L.ZACH ER, and SUZA NNE SAVO IE, 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 com merce and used in activities affecting interstate com me rce, namely, a 1984 Fordtruck bearing Oregon license number CXR 901, located at Jefferson Poplar Farm , 791 14 CollinsRoad, Clatskanie, Columbia County, Oregon; all in violation of Title 18, United States Code,Sections 844(i) and 2.

COUNT 49ARSON - JEFFERSON POPLAR FARM - VEHICLE

On or about M ay 21, 2001, at Clatskanie, Columbia County, in the District of Oregon,defendants STANISLAS GREGORY M EYERHOFF, KEVIN TUBB S, DANIEL GERA RD



50/54

McGOWAN, CHE LSEA DAWN GERLACH , NATHAN FRASER B LOCK, JOYANNA L.ZAC HER , and SUZ ANN E SAV OIE, and other persons know n to the Grand Jury, unlawfully andwillfully caused and aided, abetted, counseled, comm anded, induced, and procured the m aliciousdamaging and destroying, by means o f fire and an explosive, of a vehicle used in interstatecomm erce and used in activities affecting interstate commerce, namely, a 1997 Ford truckbearing Oregon license number V HQ 661, located at Jefferson Poplar Farm, 791 14 Collins Road,Clatskanie, Columbia County, Oregon; all in violation of Title 18 , United States Code, Sections844(i) and 2.

COUNT SOARSON - JEFFERSON POPLAR FARM - VEHICLE

On o r about M ay 2 1, 2001, at Clatskanie, Colum bia County, in the District of Oregon,defendants STANISL AS GREG ORY MEY ERHOFF, KEV IN TUBB S, DANIEL GERAR DMcGOWAN, CHELSEA DAW N GERLACH, NATHAN FRASER BLOCK, JOYANNA L.ZAC HER , and SUZA NNE SAV OIE, and other persons known to the Grand Jury, unlawfully andwillfully caused and aided, abetted, counseled, comman ded, induced, and procured the maliciousdamaging and destroying, by m eans of fire and an explosive, of a vehicle used in interstatecomm erce and used in activities affecting interstate comm erce, namely, a 1997 Ford truckbearing Oregon license numbe r VN S 404, located at Jefferson Poplar Farm, 791 14 Collins Road,Clatskanie, Colum bia County, Oregon; all in violation o f Title 1 8, United States Code, Sections844(i) and 2.i l i

/ I /

Page 50 - INFORMA.TION


51/54


On o r about May 2 1, 200 1, at Clatskanie, Colum bia County, in the D istrict o f Oregon,defendants STANISLAS GREGORY MEYERHOFF, KEVIN TU BBS, DANIEL GER ARDMcGOWAN, CHELSEA DAW N GERLACH, NATHAN FRASER BLOCK, JOYANNA 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 maliciousdamaging and destroying, by means of fire and an explosive, of a vehicle used in interstatecommerce and used in activities affecting interstate commerce, namely, a 1996 Ford truckbearing Oregon license number UMZ 923, located at Jefferson Poplar Farm, 791 14 Collins Road,Clatskanie, Colu mbia C ounty, Oregon; all in violation of Title 18, United States Code, Sections844(i) and 2.

COUNT 52AIRSON - JEFFERSON POPLAR FARM - VEHICLE

On or about May 2 1 , 2001, at Clatskanie, Columbia C ounty, in the District o f Oregon,defendants STANISL,$S GREGOR Y M EYERHOFF, KEV IN TUBBS, DANIEL GERAR DMcGOWAN, CHELSEA DAW N GERLACH, NATHAN FRASER BLOCK, JOYANN A L.ZACH ER, and SU ZA NN E SAVOIE, and other persons known to the Grand Jury, unlawfully andwillfully caused and aided, abetted, counseled, commanded, induced, and procured the m alicious

damaging and destroying, by m eans o f fire and an explosive, of a vehicle used in interstatecomm erce and used in activities affecting interstate comm erce, namely, a 1 990 Ford truckbearing Oregon license number 283 ACE, located at Jefferson Poplar Farm, 791 14 Collins Ro ad,



52/54

Clatskanie, Colum bia County, Oregon; all in violation of Title 18, United States Cod e, Sections844(i) and 2.


On or about M ay 21, 2001, at Clatskanie, Colum bia County, in the District of Oregon,defendants STANISL AS GREGORY MEYERHO FF, KEVIN TU BBS, DANIEL GERA RDMcGOWA N, CHELSEA DAWN GERLACH, NATHAN FRASER BLOCK, JOYANNA L.ZACH ER, and S UZA NN E SAV OIE, and other persons known to the Grand Jury, unlawfully and

willfully caused and aided, abetted, counseled, comm anded, induced, and procured the maliciousdamaging an d destroying, by means of fire and an explosive, of a vehicle used in interstatecomm erce and used in activities affecting interstate commerce, nam ely, a 1 990 Ford truckbearing Oregon license number 282 A CE, located at Jefferson Po plar Farm, 791 14 Collins Road,Clatskanie, Colum bia County, Oregon; all in violation of Title 18, United States Code, Sections844(i) and 2.

COUNT 54A.RSON - JEFFERSON POPLAR FARM - VEHICLE

On or about May 21, 2001, at Clatskanie, Co lumb ia County, in the District of Oregon,defendants STANISL.AS GREG ORY M EYERH OFF, KEVIN TUB BS, DANIEL GERA RDMcGOWAN, CHELSEA DAW N GERLACH, NATHAN FRASER BLOCK, JOYANNA L.ZACH ER, and S UZA NN E SAVO IE, and other persons known to the G rand Jury, unlawfully andwillfully caused and aided, abetted, counseled, comm anded, induced, and procured the maliciousdamaging and destroying, by means o f fire and an explosive, of a vehicle used in interstate



53/54

comm erce and used in activities affecting interstate com merce, namely, a 1990 Ford truckbearing Oregon license number 361 ACC , located at Jefferson Poplar Farm, 791 14 Collins Road,Clatskanie, Columbia County, Oregon; all in violation o f Title 18, United States Code, S ections844(i) and 2.


On or about May 2 1, 200 1, at Clatskanie, Columbia County, in the District of Oregon,defendants STANISL,4S GREGO RY ME YERHO FF, KEVIN TUBBS, DANIEL GERAR D

McGOWAN, CHELSEA DAW N GERLACH, NATHAN FRASER B LOCK, JOYANNA L.ZAC HER , and SUZA NNE SAV OIE, and other persons known to the Grand Jury, unlawfully andwillfully caused and aided, abetted, counseled, commanded, induced, and procured the maliciousdamaging and destroying, by mea ns of fire and an explosive, of a vehicle used in interstatecommerce and used in activities affecting interstate commerce, namely, a 1981 GMC truckbearing Oregon license numbe r NA 41574, located at Jefferson Poplar Farm , 791 14 Collins Road,Clatskanie, Colum bia County, Oregon; all in violation o f Title 18 , United States Code, Sections844(i) and 2.


On or about M ay 21, 2001, at Clatskanie, C olumbia C ounty, in the District of Oregon,defendants STANISLAS GREGO RY MEY ERHOFF, KEVIN TUBBS, DANIEL GERAR DMcGOWAN, CHELSEA DAWN GERLACH, NATHAN FRASER BLOCK, JOYANNA L.ZAC HER , and SUZA NNE SAV OIE, and other persons know n to the Grand Jury, unlawfully and



54/54

willfully caused and aided, abetted, counseled, command ed, induced, and procured the m aliciousdamag ing and destroying, by means of fire and an explosive, of a vehicle used in interstatecommerce and used in activities affecting interstate comm erce, namely, a 1989 Ford truckbearing Oregon license number PW V 249, at Jefferson Poplar Farm, 79 114 Collins R oad,Clatskanie, Columbia C ounty, Orego n; all in violation of Title 18, United States Code, Sections844(i) and 2.

Dated this ~ n x a ~ o f- d+ ,2006.I KARIN J. IMMERGUTUnited S tates Attorney

District of Oregon

KIRK A. E N G D A L ~Assistant United S tates Attorney

Documents

Tubbs.information