Zacher.2nd.superseding.indictment.or

8/3/2019 Zacher.2nd.superseding.indictment.or

1/65

UNITED STATES OF AMERICA ) CR N O. 06-6001 1-AAv. 1JOSEPH DIBEE, aka "Seattle" ) SECOND SUPERSEDINGCHELSEA DAWN GERLACH, ak a ) INDICTMENT"Country Girl," 1KENDALL TANKERSLEY, aka "Sarah ) [ l 8 U.S .C. $5 371,Kend all Harvey", aka "Kendall," ) 844(f), 844(i), 844(n),DANIEL GERARD McGOWAN, aka "Sorrell" ) 924(c)(l)(A)(i) & (B)(ii) &and "Jamie," ) (C)(ii), 136 6(a), and 21STANISLAS GREGORY MEYERHOFF, )akaaCo untry Boy" and "Jack," )JOSEPHINE SUNSHINE OVERAKER, ak a )"Maria," 1JONATHAN CHRISTOPHER MARK PAUL, )aka "J.P.," )REBECCA RUBIN, aka "Kara," 1SUZANNE SAVOIE, aka "India," )DARREN TODD THURSTON, )KEVIN TUBBS, aka "Bob" and "Dog", )NATHAN FRASER BLOCK, aka "Exile" and )"Hasan," and 1JOYANNA L. ZACHER, aka "Sheba" and"Sabina," 11Defendants.

THE GRAND JURY CHARGES:COUNT 1

CONSPIRACY TO COMMIT ARSONI. OBJECT OF THE CONSPIRACY

Beginning in O ctober 1996 and continuing through D ecember 2005, in the District ofOregon and elsewhere, defendants JOSEPHINE SUNSH INE OVERA KER, KEV IN TUBBS,

Page 1 - SECOND SUPERSEDING INDICTMENT


2/65

STANISLAS GREGORY MEYERHOFF, DANIEL GERARD M cGOWAN, JOSEPH DIBEE,REBECCA RUB IN, CHELSEA DAWN GERLACH, KENDALL TANKERSLEY, SUZANNESAVOIE, JONATHAN CHRISTOPHER MARK PAUL, DARREN TODD THURSTON,NATHAN FRASER BLOCK, and JOYANNA L. ZACH ER, and un indicted co-conspiratorWILLIAM C. RODG ERS, and other persons known and unknown to the G rand Jury, willfullyand knowing ly conspired and agreed to comm it the following offenses against the United States:

to m aliciously damage or destroy, or attempt to damage or destroy, by me ans offire or an explosive, any building, vehicle or other personal o r real property inwhole o r in part owned or possessed by, or leased to, the United States or anydepartmen t or agency thereof, in violation of Title 18, United States Code, Se ction844 (f)(l); andto maliciously damage or destroy, or attempt to damage o r destroy, by m eans offire or an explosive, any building, vehicle or other real or personal property usedin interstate commerce or in any activity affecting interstate com merce, inviolation of Title 18, United States Code, Section 844 (i).

11. MANNER AND MEANS OF THE CONSPIRACYThe foregoing objects of the conspiracy were to be accomplished in the following manner

and means by the above-listed defendants and others at various times during the cou rse of theconspiracy:

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

Page 2 - SECON D SUPERSEDING INDICTMENT


3/65

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. The general purposes of the conspiracy were to influence and affect the conductof government, comm erce, private business and others in the civilian population by means offorce, violence, sabotage, mass destruction, intimidation and coercion, and by similar means toretaliate against the conduct of government, comm erce and private business. To achieve thesepurposes, the conspirators comm itted and attempted to com mit acts dangerous to hum an life andproperty that constituted violations of the criminal laws of the United States and of individual

states.3. Certain of the defendants and others targeted for arson buildings, vehicles and

other real and personal 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 ac tivities affec ting interstatecommerce.

5 . Certain of the defendants and others conducted and participated in meetings toplan arsons of the targeted sites. Severa l of these meetings were called "book club" m eetings bythe defendants and others and occurred at distant locations. The "book club" meetings coveredsubjects such as lock-picking, computer security, reconnaissance of targets, and manufacture oftiming devices to set off improvised incendiary devices.

6 . Certain of the defendants and others conducted research and surveillance of sitestargeted for arson.

Page 3 - SECOND SUPERSEDING INDICTM ENT


4/65

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

8. Certain of the defendants and others designed and constructed destructive deviceswhich functioned as incendiary bombs to ignite fires and destroy the targets.

9. Certain of the defendants and others provided transportation to the sites targetedfor arson.

10. Certain of the defendants and others dressed in dark clothing, wore masks andgloves and otherwise disguised their appearance.

11. Certain of the defendants and others acted as "look-outs" to ensu re secrecy as thecrimes were carried out.

12. Certain of the defendants and others placed destructive dev ices and accelerants atsites targeted for arson and ignited or attempted to ignite the devices and accelerants.

13. Certain of the defenda nts and others, by mean s of fire and explosives, maliciouslydamag ed and destroyed, and attempted to dam age and destroy, buildings, vehicles an d other realand personal property ow ned and possessed by the United S tates and its departments andagencies.

14. Certain of the defendants and others, by means of fire and explosives, maliciouslydama ged and destroyed, and attemp ted to damage and de stroy, buildings, vehicles and other realand personal property used in interstate commerce and in activities affecting interstatecommerce.



5/65

15. 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.

16. After the arsons and attempted arsons, certain of the defendants and othersprovided transportation away from the scenes of the crimes.

17 . After the arsons and attempted arsons, certain of the defendants and othersdestroyed, buried, hid and otherwise disposed of physical evidence used in the commission of thecrimes.

18 . After the arsons, certain of the defendants and others publicized and promoted theresults of the fires by means of written press releases and communiques attributing the arsons tothe Earth Liberation Front (ELF), the Animal Liberation Front (ALF) and related groups, andstating the purposes of the arsons.

19. Before, during and after the arsons and attempted arsons, certain of the defendantsand others agreed and took an oath among themselves never to reveal to law enforcementauthorities or to anyone else outside "the Family" the identity of the conspirators and participantsin the arsons and attempted arsons.

20. Before, during and after the arsons and attempted arsons, certain of the defendantsand others agreed among themselves to conceal or destroy any evidence connecting them to thearsons and attempted arsons.

21. Before, during and after the arsons and attempted arsons, certain of the defendantsand others possessed andor used false identification documents in order to conceal their trueidentities.

Page 5 - SECO ND SUPERSEDING INDICTMENT


6/65

22. After the arsons and attempted arsons, certain of the defendants and others fledand secreted themselves in foreign countries in order to avoid detection and arrest by lawenforcement authorities in the United States.111. OV ERT AC TS

In order to carry out the objects of the conspiracy, defendants 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 JOSEPHINE

SUNSHINE OVERAKER and other persons known to the Grand Jury, unlawhlly and willfullycaused and aided, abetted, counseled, commanded, induced, and procured the attempt to damageor destroy, by means of fire and an explosive, a building and other real and 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.

1a. At a time prior to October 28,1996, JOSEPHINE SUNSHINE OVERAKER andanother person known to the Grand Jury prepared and tested a time-delayed incendiary device.

lb. On or about October 28,1996, JOSEPHINE SUNSHINE OVERAKER and otherpersons known to the Grand Jury 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.Forest Service building. That incendiary device failed to function.



7/65

lc. On or about October 28,1996, JOSEPHINE SUNSHINE OVERAKER andanother person known to the Grand Jury spray-painted graffiti on the sides of a U.S. ForestService building and vehicles which included the words "Earth Liberation Front."

2. On or about October 28, 1996 in Marion County, Oregon, defendant JOSEPHINESUNSHINE OVERAKER and other persons known to the Grand Jury, unlawfully and willfullycaused and aided, abetted, counseled, commanded, induced, and procured the maliciousdamaging and destroying, 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 States Forest Serviceof the Department of Agriculture, located at the Detroit Ranger Station on the WillametteNational Forest.

2a. On or about October 28 , 1996, JOSEPHINE SUNSHINE OVERAKER andanother person known to the Grand Jury intended and caused fire damage to a U.S. ForestService vehicle.

3. On or about October 30, 1996, in Lane County, Oregon, defendants JOSEPHINESUNSHINE OVERAKER and KEVIN TUBBS, and another person 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 owned and possessed by the United States and the UnitedStates Forest Service of the Department of Agriculture, located at the Oakridge Ranger Station

on the Willamette National Forest.



8/65

3a. On or about October 30, 1996, in Lane County, Oregon, defendants JOSEPHINESUNSHINE OVERAKER and KEVIN TUBBS, and another person known to the Grand Jury,drove to the U.S. Forest Service Oakridge Ranger Station, and set fire to the Ranger Station.

3b. On or about October 30, 1996, in Lane County, Oregon, defendants JOSEPHINESUNSHINE OVERAKER and KEVIN TUBBS, and another person known to the Grand Jury,while leaving the parking lot of the U.S. Forest Service Oakridge Ranger Station, threw nailsonto the parking lot in order to slow down responding emergency vehicles.

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

SUNSHINE OVERAKER and KEVIN TUBBS, and another person known to the Grand Jury,while leaving the U.S. Forest Service Oakridge Ranger Station and driving westbound onHighway 58 towards Eugene, Oregon, discarded their gloves in a reservoir near the LowellBridge.

4. On or about July 21, 1997, at Redmond, Deschutes County, Oregon, defendantsKEVIN TUBBS, JOSEPH DIBEE and JONATHAN CHRISTOPHERMARK PAUL, and otherpersons known to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,commanded, induced, and procured the malicious damaging and destroying, by means of fire andan explosive, of a building and other real and personal property used in interstate commerce andin activities affecting interstate commerce, at Cavel West, Inc., 1607 SE Railroad, Redmond,Oregon.

4a. Approximately one week prior to the July 21, 1997 arson at Cavel West, Inc.,Defendants KEVIN TUBBS and JONATHAN CHRISTOPHERMARK PAUL and others



9/65

known and unknown to the G rand Jury went on a reconnaissance in order to locate a staging areawhere the participants could complete final preparations prior to comm itting the arson.

4b . Prior to the July 21, 1997 arson at Cavel West Inc., defendant JONAT HANCHRISTOPHER MARK PAU L and another person known to the G rand Jury prepared a mixtureof soap and petroleum products which was the fuel used in the time-delayed incendiary devises.

4c. On or about July 21, 1997, defendants KEV IN TUBB S, JOSE PH DIBEE andJONATHAN CHRISTOPHER MARK PAU L, and other persons known to the Grand Jury, droveto the previously chosen staging area near Cav el West, Inc., and upon arrival dressed in dark

clothing, masks, and glov es, and dug a hole at the staging area in which to bu ry their darkclothing upon completion of the arson.

4d . On or about July 2 1, 1997, defendants KEV IN TUB BS, JOSE PH DIBEE andJONATHAN CHRISTOPHER MARK PAUL , and other persons known to the Grand Jury,completed a two-way radio check with o ne another and confirmed their scanner and radiosfunctioned properly.

4e . On or about July 2 1, 1997, defendants KEV IN TUBB S, JO SEP H DIBE E andJONATHAN CHRISTOPHERMARK PAU L, and other persons know n to the Grand Jury, wentto the location of Cavel West, Inc., to place time-de layed incendiary device s on and about thatlocation.

4f . On or about July 21, 1997, defendant JOSEPH DIBEE drilled holes through thewall of the C avel W est, Inc., facility so as to allow fue l to be poured directly into the building.

4g . On or about July 2 1, 1997, defendants KEV IN TUBB S, JOS EPH D IBEE andJONATHAN CHRISTOPHERMARK PAU L, and other persons known to the Grand Jury, upon



10/65

placing the time-delayed incend iary devices at Cavel W est, Inc., traveled back to the staging area,remov ed their dark clothes and sh oes, placed them in the hole, poured acid o n the clothing in thehole and then buried the items.

4h . On o r about July 26, 1997, certain defendants in the C avel West arson issued awritten comm unique attributing the fire to the Anim al Liberation Front (AL F) and the Equineand Zebra Liberation Front. The comm unique was publicized by Craig Rosebraugh of theLiberation Collective in Portland, Oregon.

4i . Approximately three years after July 2 1, 1997, defendant JO SEP H D IBEE

contacted defendant KEVIN TUB BS and told KEV IN TUB BS to return to the staging area andretrieve the buried clothes.

5 . On o r about November 30, 1997, in Harney County, Oregon, defendantsJOSEPHINE SUNSHINE OVER AKER, KEVIN TUBBS, and REBE CCA RU BIN, unindictedco-conspirator WILLIAM C. RODG ERS, and another person know n to the G rand Jury,unlawfu lly and willfully caused and aided, abetted, counseled, comman ded, induced , andprocured the malicious dam aging and destroying , by means o f fire and an explosive, of buildingsand other real and personal property ow ned and possessed by the Un ited States and the Bureau ofLand Managem ent of the Department of the Interior, located at the Wild H orse and BurroFacility, Bum s, Harney County, Oregon.

5a. Approximately three months prior to Novem ber 30, 1997, defendantsJOSEPHINE SU NSHINE OVERA KER and KEVIN TUBBS , unindicted co-conspiratorWILLIAM C . ROD GERS , and another person known to the Grand Jury, did a reconnaissance at



11/65

and near the W ild Horse and Burro Facility, to prepare themselves for the arson and horserelease.

5b. Sometime prior to November 30,19 97, Defendant JOSEPHINE SUNSH INEOVE RAK ER and another person kn own to the Grand Jury, obtained five-gallon, white plasticbuckets and the fuel to be used in m aking time-delayed incendiary devices.

5c . Sometime prior to November 30, 1997, persons know n and unknow n to the GrandJury, prepared the five-gallon plastic bucke ts by wiping the buckets to e nsur e all fingerprintswere removed, and painted them with black spray paint.

5d. Sometime prior to Novemb er 30, 1997, defendants JOS EPH INE SUN SHIN EOVERAKER, KEVIN TUBBS and REBECCA RUBIN, unindicted co-conspirator WILLIAM C.ROD GER S, and another person known to the Grand Jury, obtained additional components andassembled time-delayed incendiary devices, which were composed of kitchen timers, m atches,spong es, model rocket igniters, one-gallon jugs filled with fuel and five-gallon buckets whichcontained &e l.

5e . On or about November 30,1 997 , defendants JOSEPHINE SUNSH INEOVERA KER, KEV IN TUBBS and REBECCA RUBIN, unindicted co-conspirator W ILLIAM C.ROD GERS , and another person known to the G rand Jury, arrived at the W ild Horse and BurroFacility, cut the lock on the front gate, released horses and bu rros, placed time-delayed incendiarydevices in and around the facility and left the area.

Sf. On or about December 5, 199 7, certain defendants in the W ild Horse and Bum sFacility arson issued a comm unique attributing the fire and horse release to the Earth Liberation

Page I 1 - SECOND SUPERSEDING INDICTMENT


12/65

Front (ELF) and the Animal Liberation Front (ALF). The comm unique was publicized by C raigRosebraugh of the Liberation Collective in Portland, Oregon.

6. On or abou t June 21, 1998, at Olympia, Washington, in the W estern District ofWashington, defendants JOSEPHINE SUNSH INE OVERA KER, KEVIN TU BBS and JOSEPHDIBEE, unindicted co-conspirator W ILLIAM C. RODG ERS, and another person known to theGrand Jury, willfully caused and aided, abetted, counseled, com manded, induced , and procuredthe malicious damag ing 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 A nimal, Plant

and Health Inspection Service (APHIS ) of the Departmen t of Agriculture, located at the NationalWildlife Research Facility, 9701 B lomberg Street SW, O lympia, Washington.

6a. Approximately two weeks before June 2 1,19 98 , defendants KEVIN TUBB S andJOSEPH D IBEE, and other persons known and unknown to the Grand Jury, met in Olympia,Washington, to discuss plans for the APHIS arson , and agreed at that time there would be asecond and simultaneous arson committed when the APH IS arson was to occur.

6b. At a time prior to June 2 1,1 99 8, defendant JOSEPHINE SUNSHINEOVER AKER and other persons known to the Grand Jury prepared five-gallon buckets bywiping the buckets to remove any fingerp rints, and obtained fuel for the APHIS arson.

6c . At a time prior to June 2 1, 1998, defendant KEVIN T UBBS utilized falseidentification to acquire a van which was used in the APHIS arson.

6d. On or about June 2 1,19 98 , defendant JOSEPHINE SUN SHINE O VERAKER,while attempting to steal items in preparation for the APHIS arson, was arrested by au thoritiesfor shoplifting.

Page 12 - SECOND SUPER SEDING INDICTMENT


13/65

6e. On or about June 21, 1998, defendant KEVIN TUBB S and another person knownto the Grand Jury transferred five-gallon buckets of fuel to be used in the APHIS arson from avan purchased by KEV IN TUBB S to a vehicle owned by unindicted co-conspirator WILLIAM C.RODGERS.

6f. On or about June 21 , 1998, defendant KEVIN TUBB S, unindicted co-conspiratorWILLIAM C. ROD GERS, and another person known to the G rand Jury, drove to the APHISfacility and placed five-gallon buckets filled with fuel at locations at and aroun d the facility, andignited the fuel-filled buckets by hand .

6g . On or about June 22, 1998, certain defendants in the APHIS arson issued acomm unique attributing the fire to the Earth Liberation Front (EL F) and the Animal LiberationFront (ALF). The com mun ique was publicized by Katie Fedor of the North American ALF PressOffice.

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

7. In about September 1998, at Rock S prings, Wyom ing, in the District of Wyoming,defendants KEVIN TUB BS and REBEC CA R UBIN, and unindicted co-conspirator WILLIAMC. ROD GERS, and o ther persons known and unknown to the Grand Jury, unlawfully andwillfully caused and aided, abetted, counseled, commanded, induced, and procured the attempt todamag e or destroy, by means of fire and an explosive, a building and other real and personalproperty owned and possessed by the U nited States and the Bureau o f Land M anagement of theDepartm ent of the Interior, located at the Wild Horse Holding Facility, Rock Springs, Wyom ing.



14/65

7a. In or about September 19 98, defendants KEVIN T UB BS and REB ECCA R UBIN,unindicted co-conspirator WILLIAM C. RODG ERS, and other persons known and unknown tothe Grand Jury, arrived at the staging area near Rock Springs, Wyoming , assigned roles, preparedtime-delayed incendiary devices, and made preparations for the arson, when a law enforcem entofficer made inqu iry as to their presence at that location.

7b . In or about September, 1998, defendants KEVIN T UBB S and REB ECCARUB IN, unindicted co-conspirator WILLIAM C . RODGER S, and o ther persons known andunknown to the Grand Jury, buried the time-delayed incendiary device s in an attempt to avoid

detection.8. On o r about October 11, 1998, at Rock Springs, Wyom ing, in the District of

Wyom ing, defendants JOSEPHINE SUN SHINE OVEKA KER, KEV IN TUBB S, STANISLASGREGORY MEYERH OFF and CHE LSEA DAW N GERLACH, unindicted co-conspiratorWILLIAM C. RODG ERS, and other persons known to the G rand Jury, unlawfully and willfullycaused and aided, abetted, counseled, comm anded, induced, and procured the attempt to damageand destroy, by means of fire and an explosive, buildings and other real and personal propertyowned and possessed by the United States and the Bureau of Land M anagem ent of theDepartm ent of the Interior, located at the W ild Horse Holding Facility, Rock S prings, Wyoming.

8a. On or about October 11, 1998, defendants JOSEPHINE SUNSH INEOVERAKER , KEVIN TUBBS, STANISLAS GREGORY MEYER HOFF and CHELSEADAW N G ERLA CH, unindicted co-conspirator WILLIAM C. RO DGE RS, and other personsknow n and unknown to the G rand Jury, brough t digital timers, containers of fuel, two-wa y radiosand a scanner, to a staging area near the Wild H orse Holding Facility.



15/65

8b . On or about October 11, 1998, at Rock Sp rings, W yoming, defendantsJOSEPHINE SUNSHINE OVERAK ER, KEVIN TUBBS, STANISLAS GREGORYMEY ERHO FF and CHELSE A DAW N GER LACH , unindicted co-conspirator WILLIAM C.ROD GERS, and other persons known to the Grand Jury, went to the W ild Horse HoldingFacility, and began the release of horses and the placing o f incendiary devices in and about thefacility.

8c . On or about October 11, 1998, at Rock Springs, Wyom ing, defendantsJOSEPHINE SUNSHINE OVERAKER, KEVIN TUBBS, STANISLAS GREGORY

MEY ERHO FF and CHEL SEA DAW N GER LACH , unindicted co-conspirator WILLIAM C.RODG ERS, and other persons know n to the G rand Jury, hid timing devices in large rock out-croppings near the Wild H orse Holding Facility, after hearing on their scanner that police hadbeen dispatched to their location.

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

9. On or about October 19, 1998, in Eagle County, Colorado, defendantsJOSEPHINE SUNSHINE OVERAK ER, KEVIN TUBBS, STANISLAS GREGOR YMEYERHO FF and CHEL SEA DA WN GERLACH, unindicted co-conspirator W ILLIAM C .ROD GERS, and other persons known and unknown to the Grand Jury, unlawfully and willfullycaused and aided, abetted, counseled, commanded, induced, and procured the ma liciousdamaging and destroying, by means of fire and exp losives, of buildings and other real and



16/65

personal property used in interstate commerce and in activities affecting interstate commerce, atthe Vail S ki Facility.

9a . On or about O ctober 2 1, 1998, certain defendants in the Vail arson issued acommunique attributing the fire to the Earth Liberation Front (ELF).

10. On or about Decem ber 22, 1998, at Medford, Jackson County, Oregon, defendantsKEND ALL TANKE RSLEY, KEVIN TUB BS and REBECCA RUBIN, and another personknown to the Grand Jury, unlawfklly and willfully caused and aided, a betted, counseled,comm anded, induced, and procured the attempt to damage or destroy, by means of fire and an

explosive, a building and other real and personal property used in interstate commerce and usedin activities affecting interstate com merce, name ly, an office building and its con tents at U.S.Forest Indu stries, 26 11 Whittle Avenue, M edford, Jackson County, Oregon.

lOa. A few weeks prior to Decem ber 22, 1998, defendants KEN DAL LTANK ERSLEY, KEVIN TUB BS and REBECCA RU BIN, and another person known to theGrand Jury, performed a reconnaissan ce and "dry run" for the arson at the U.S. Forest Industriesbuilding in Medford, Oregon.

lob . On or about December 22, 1998, at Medford, Jackson County, Oregon, defendantsKEND ALL TANKE RSLEY, KEVIN TUB BS and REBECCA RUB IN, and another personknown to the Grand Jury, placed time-delayed incendiary devices at and about the U.S. ForestIndustries building.

10c. Prior to Decem ber 27, 1998, after placement of the time-delayed incendiarydevices at the U.S . Forest Industries building, defendant KEN DAL L TAN KER SLEY , and



17/65

another person known to the G rand Jury searched the ~ n e d ia nd found no m ention of the burningof the U.S. Forest Industries building.

10d. Between December 22 and 27, 1998, defendant KEND ALL TA NKER SLEY andanother person know n to the G rand Jury returned to the U.S. Forest Industries building to checkon the destructive devices.

11. On or about December 27, 1998 , at Med ford, Jackson Cou nty, Oregon, defendantKEND ALL TAN KERSL EY and another person known to the G rand Jury unlawfully andwillfully caused and aided, abetted, counseled, comm anded, induced, and procured the maliciousdamaging and destroying, by me ans of fire and an explosive, of a building and o ther real andpersonal property used in interstate comm erce and used in activities affecting interstatecomm erce, namely, an o ffice building and its contents at U.S. Forest Industries, 261 1 WhittleAvenue, Medford, Jackson C ounty, Oregon.

1 a . On or about December 27,1 998, defendant KENDALL TANKERSLEY andanother person known to the Gran d Jury returned to the U.S . Forest Industries building, placed anew time-delayed incendiary d evice at or about the building an d left the area.

11b. On or about December 27, 1998, defendant KEND ALL TA NKER SLEY andanother person know n to the G rand Jury, traveled to Dunsm uir, California, to avoid detection.

11c. On or about December 27, 1998, defendant KENDALL TANKERSLEYregistered under a false nam e in the Cedar Lodge Motel in Dunsm uir, California.

1 d . On or ab out January 16, 1999, certain defendants in the U.S. Forest Industriesarson issued a communique attributing the fire to the Earth Liberation Front (ELF). The



18/65

communique was publicized 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 GREGORYMEYERHOFF, CHELSEA DAWN GERLACH, 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 commerce and in activities affecting

interstate commerce, at Childers Meat Company, 29476 Airport Road, Eugene, Lane County,Oregon.

12a. On or about May 9, 1999, defendants JOSEPHINE SUNSHINE OVERAKER,KEVIN TUBBS, STANISLAS GREGORY MEYERHOFF and CHELSEA DAWN GERLACH,and other persons known to the Grand Jury, prepared five-gallon buckets, timers and he1 for thearson which was to occur at the Childers Meat Company, Eugene, Oregon.

12b. On or about May 9, 1999, defendants JOSEPHINE SUNSHINE OVERAKER,KEVIN TUBBS, STANISLAS GREGORY MEYERHOFF and CHELSEA DAWN GERLACH,and other persons known to the Grand Jury, traveled to the Childers Meat Company and placedone time-delayed incendiary device near the front of the office building and placed another suchdevice at the back of the building near a gas meter.

12c. On or about May 27, 1999, certain defendants in the Childers arson issued acommunique attributing the fire to the Animal Liberation Front (ALF). The communique waspublicized by the ALF Frontline Information Service.



19/65

13. On or about December 25, 1999, at Monmouth, Polk County, Oregon, defendantsJOSEPHINE SUNSHINE OVERAKER, STANISLAS GREGORY MEYERHOFF andCHE LSEA DA WN GER LAC H, and another person known to the G rand Jury, unlawfully andwillfully caused and aided , abetted, counseled, com mand ed, induced, and procured the maliciousdamag ing and destroying, by means of fire and an explosive, of a building and other real andpersonal property used in interstate comm erce and in activities affecting interstate com merce, atthe Boise Cascade Office, 450 North Pacific Avenue, Monmouth, Polk County, Oregon.

13a. On or about December 25,19 99, defendants JOSEPHINE SUNSHINE

OVERAKER, STANISLAS GREGORY M EYERHOFF and CHELSEA DAWN GERLACH,and another person know n to the Grand Jury, prepared time-delayed incend iary devices to beused at the Boise Cascad e Office, and, after disguising the devices by wrapping them inChristmas paper, transported the devices to the Boise Cascad e Office location.

13b. On or about December 25, 1999, at Monm outh, Polk Cou nty, Oregon, defendantsJOSEPHINE SUNSHINE O VERAKER, STANISLAS GREGORY MEYERHOFF andCHE LSEA DA WN GER LAC H, and another person known to the Grand Jury, placed time-delayed incendiary dev ices at and about the Boise C ascade O ffice building and left the area.

13c. On or about December 30, 1999, certain defendants in the Boise Cascade arsonissued a comm unique attributing the fire to the Earth Liberation Front (EL F). The com mun iquewas pu blicized by C raig Roseb raugh of the L iberation C:ollective in Portland, Orego n, and theNorth American ELF Press O ffice.

14. During 2000 and 2001, several of the defendants and others known and unknown



20/65

to the grand jury m et in what the participants called "book club" meetings. These meetingsoccurred in Eugene, Oregon; Tuscan, Arizona; Santa Cmz, California; and Sisters, Oregon. Theparticipants conducted classes at these meetings in clandestine methods, including th emanu facture of mechan ical and electrical timing dev ices for setting off impro vised incendiarydevices, reconnaissance o f targets, lock-picking, and computer se curity.

15. On or about September 6,2 00 0, at Eugene, Lane County, Oregon, defendantsSTANISLAS GREGORY MEYERHOFF, KEVIN TUBBS and CHELSEA DAWN GERLACH,unlawfully and willfully caused and aided, abetted, counseled, comm anded, induced, and

procured the malicious damaging and destroying, by m eans o f fire and an explosive, of a buildingand other real and personal property used in interstate comm erce and in activities affectinginterstate comm erce, at the Eugen e Police Departm ent W est University Pub lic Safety Station,791 East 13thAvenue, Eugene, Oregon.

15a. On or about September 6,2 00 0, defendants STAN ISLAS GREGO RYMEY ERHOFF, KEVIN TUB BS and CHELSEA DAW N G ERLACH traveled to the EugenePolice Departmen t West University Public Safety Station and placed time-delayed incendiarydevices at and about the police station.

16. On or about January 2,20 01 , at Glendale, Douglas C ounty, Oregon, defendantsSTANISLAS GREGORY M EYERHOFF, KEVIN TUBBS, DANIEL GERARD M cGOWANand SUZ AN NE SA VO IE, and another person known to th e Grand Jury, unlawfully and willfullycaused and aided, abetted, counseled, commanded, induced, and procured the maliciousdamag ing and destroying, by mean s of fire and an explosive, of a building and other real andpersonal property used in interstate comm erce and used in activities affecting interstate



21/65

comm erce, namely, a building and its contents located at Superior Lumber Company, 2695Glendale Valley Road, Glendale, Douglas County, Oregon.

16a. On or about January 2,2001 , defendants STANISLAS GREGO RYMEYERHOFF, KEVIN TUBBS, DANIEL GERARD McGOWAN and SUZANNE SAVOIE,and another person known to the Grand Jury, traveled in separate vehicles to a predeterm inedstaging area at a rest area located just north of the town of Glendale, O regon, on Interstate 5,where they dressed in dark clothing and put on their radio earpieces and m asks.

16b. On or about January 2,200 1, defendants STANISLAS GREGOR YMEYERHOFF, KEVIN TUBBS, DANIEL GERARD McGOWAN and SUZANNE SAVOIE,and another person know n to the G rand Jury, traveled to the S uperior Lumber C ompany building,set up lookouts, positioned the bbpick-up" ehicle, placed the time-delay ed incendiary devices,and returned to the staging area.

16c. On or about January 2,20 01, defendants STAN ISLAS GREGO RYMEYERHOFF, KEVIN TUBBS, DANIEL GERARD McGOWAN and SUZANNE SAVOIE,and another person know n to the Grand Jury, upon returning to the staging area, change d theirclothing and disposed o f their dark clothing.

16d. On or about January 6,2 00 1, certain defendants in the Superior Lumber Com panyarson issued a com munique attributing the fire to the Earth Liberation Front (EL F). Thecomm unique was publicized by Craig Rosebraugh of the North American EL F Press Office.

17 . On or about March 30, 200 1, at Eugene, Lane County, Oregon, defendantsSTANISLAS GREGORY MEYERHOFF, KEVIN TUBBS, NATHAN FRA SER BLOCK, andJOYAN NA L. ZAC HER , and unindicted co-conspirator WILLIAM C. ROD GER S, unlawfully



22/65

and willfully caused and aided, abetted, counseled, commanded, induced, and procured themalicious damaging and destroying, by means 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 S treet, Eugene, Oregon.

17a. On or about March 30,2001 , defendants STANISLAS GREGO RYMEYER HOFF, KEVIN TUBB S, NATHAN FRASER BLOCK , and JOYANNA L. ZACHER,and unindicted co-conspirator WILLIAM C. ROD GER S, traveled to Joe Rom ania ChevroletTruck Center and stationed KEVIN TU BBS and JOYA NNA L. ZACH ER as lookouts, while the

others placed an incendiary device and plastic containers filled with gaso line underneath thevehicles and connected the vehicles and containers with rolled-up sheets soaked in gasoline.

17b. On or about March 3 1,2 001 , certain defendants in the Romania C hevrolet arsonissued a communique which w as publicized by Craig Rosebraugh of the North American ELFPress Office.

18. On or about May 21,20 01, at Clatskanie, Columbia County, Oregon, defendantsSTANISLAS GREGORY MEYERHOFF, KEVIN TUHBS, DANIEL G ERARD McGOW AN,CHELSEA DAWN GERLACH, NATHAN FRASER R LOCK, JOYANNA L. ZACHER andSUZA NNE SAV OIE, unindicted co-conspirator WILLIA M C. ROD GER S, and other personsknown to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,comm anded, induced, and procured the malicious damaging and destroying, by m eans of fire andan explosive, of buildings, vehicles and othe r real and personal property used in interstatecommerce and in activities affecting interstate commerce, at Jefferson Poplar Farm, 79114Collins Road, Clatskanie, Columbia County, Oregon.



23/65

18a. At a time prior to M ay 2 1,2 001 , defendant STANISLAS G REGORYMEYERHOFF, NATHAN FRASER BLOCK, JOYANNA L. ZACHER, CHELSEA DAWNGERLAC H, DANIEL GERA RD McGOW AN, unindicted co-conspirator WILLIAM C.ROD GERS , and other persons known and unknown to the Grand Jury, participated in a meetingin which it was decided by those present that two a rsons would be ca rried out at the same time,one at the Jefferson Poplar Farm in Clatskanie, Oreg on, and the other at the University ofWashington Horticulture Center in Seattle, Washington.

18b. At a time prior to May 21, 200 1, defendants STANISLAS GREGORY

MEYE RHOFF, CHELSEA DAW N GERLACH , and SUZANNE SAV OIE performed areconnaissance for the arson at the Jefferson Poplar Farm.

18c. On or about May 21,2001 , STANlSLAS GREG ORY MEYERH OFF, DANIELGERARD McGOWAN, NATHAN FRASER BLOCK, JOYANNA L. ZACHER, andSUZANNE SAVOIE , and another person know n to the Grand Jury, traveled to Jefferson PoplarFarm.

18d. On or about May 2 1, 20 01, STANISLAS GREGORY ME YERHOFF, DA NIELGERA RD McG OW AN and others known and unknown to the Grand Jury, placed time-delayedincendiary devices at seve ral locations at and around the facility, with o ne of the locations beingadjacent to a large propane gas tank.

18e. On or about May 2 1,2 00 1, certain defendants in the Jefferson Poplar Farm arsonspray-painted graffiti at the site attributing the action to the Ea rth Liberation Front (E LF).

18f. On or about June 1 ,20 01 , certain defendants in the Jefferson Poplar Farm arsonissued a commun ique attributing the fire, along with the University of Washington fire described



24/65

below, to the Earth Liberation Front (ELF). The com mun ique was publicized by CraigRosebraugh of the North A merican ELF Press Office.

19 . On or about May 21, 2001, at Seattle, Washington, in the W estern District ofWashington, defendant STANISLAS GREGORY MEY ERHOFF, C HELSEA DA WNGERLA CH, unindicted co-conspirator WILLIAM C. RODGE RS, and other persons known andunknown to the G rand Jury, unlawfully and willfully caused and aided , abetted, counseled,commanded, induced, and procured the m alicious damaging and destroying, by means o f fire andan explosive, of a building and other real and personal property used in interstate com merce andin activities affecting interstate comm erce, at the University o f Washington Horticulture Cen ter,Seattle, Washington.

19a. At a time prior to May 2 1,2 00 1, defendant STANISLA S GREG ORYMEY ERHO FF, unindicted co-conspirator WILLIAM C'. ROG ERS, and other persons known tothe grand jury, performed one o r more reconnaissances of the University of WashingtonHorticulture Center, Seattle, Washington.

19b. On or about June 1,2 00 1, certain defendants in the University of Washingtonarson issued a comm unique attributing the fire, along with the Jefferson Po plar Farm firedescribed above, to the Earth Liberation Front (ELF). The com munique was pu blicized by C raigRosebraugh of the North American ELF Press O ffice.

20 . On or before May 28,2 001 , defendant STANISLAS GREGOR Y MEYER HOFFand unindicted co-conspirator WILLIAM C . RODGER S authored and published a documententitled "Setting Fire with Electrical Timers, an Earth Ljberation Front G uide" in order to exposeto a widespread audience their methods of operation and the design of the "Cat's Cradle"



25/65

incendiary device so that they would no longer be unique to the arsons com mitted by "theFamily," thereby hindering detection by law enforcement.

21 . On or about O ctober 1 5,2 001 , at Litchfield, California, in the Eastern District ofCalifornia, defendants STAN ISLAS GREGO RY M EYERH OFF, JOSEPH DIBEE, REBECC ARUBIN, KEVIN TUBBS, CHELSEA DAW N GERLACH and DARREN TODD THUR STON,unindicted co-conspirator W ILLIAM C. ROD GER S, and other persons known and unknown tothe Grand Jury, unlawfully and willfully caused and aided, abetted, counseled, comm anded,induced and procured the m alicious damaging and destroying, by means of fire and explosives,

of buildings and other real and personal property owned and possessed by the U nited States andthe Bureau o f Land Managem ent of the Department of the Interior, located at the W ild HorseFacility, Litchfield, California.

2 1a. On or about October 1 5,2 001 , defendant STANISLAS GREGOR YME YER HOF F and persons known and unknown to the Grand Jury placed time-delayedincendiary devices at and about the Litchfield Wild H orse Facility.

2 1b. On or about October 30,2 001 , certain defendants in the Litchfield Wild HorseFacility arson issued a comm unique attributing the fire to the Earth Liberation Front (ELF). Thecomm unique was publicized by David Barbarash at the North A merican ALF Press O ffice.

22 . On or about November 25, 2005, unindicted co-conspirator WILLIAM C .ROD GER S attempted to recruit a person known to the Grand Jury to participate in future directactions and stated: ". . .I'll be really energized and ready to set up. . .activities in ways thathaven't been seen before."



26/65

23. On or about December 21 ,20 05, defendants CHELSEA D AW N G ERLACH andDA RREN TOD D THU RSTO N possessed books and documents containing instructions on howto engage in unlawful activities, including a book en titled "Advanced Anarch ist Arsenal: Recipesfor Improvised Incendiaries and Explosives".

24 . In order to conce al evidence and to hinder the investigation and prosecu tion of theabove-described crimes, and to facilitate the flight and concealmen t of certain o f the defend ants,a num ber o f overt acts occurred, including but not limited to the following:

24a. Defendants CHELSEA DAW N GERLAC H and DARREN TODD THURSTO N

possessed and used false identification docum ents, including those found in their possession onDecember 7 ,20 05 , and discovered at their Portland residence on December 21, 20 05 .

24b. On December 21,20 05, defendants CHELSEA DA WN GERLAC H andDA RREN TOD D T HUR STON possessed in their residence books and informational materialswith respect to manufacturing false identity documents.

24c. On December 21,2005 , defendants CHELSEA DAW N G ERLACH andDA RREN TOD D TH URS TON possessed in their residence large amounts of information on theidentities of other individuals, including many dece ased persons.

24d. On December 7,20 05 , defendant KEVIN TUB BS possessed in a locked safefalse identity documents.

24e. Sometime after the Fall of 2001, defendant JOSEPH INE SUN SHINEOVE RAK ER left the United States and fled to Europe.

24f. In or about the Spring of 2005, defendant REBE CCA RUB IN returned to Canada.



27/65

24g. On or about December 11, 200 5, defendant JOSEPH D IBEE left the United Statesfollowing contact by federal law enforcement agents.

All o f the above conduct violated Title 18, United S tates Code, Section 844(n).COUNT 2

CONSPIRACY TO COMM IT ARSON ANDDESTRUCTION OF AN ENERGY FACILITYI. OBJECT OF THE CONSPIRACY

Beginning in O ctober 1996 and continuing through Decem ber 2001, in the District ofOregon and elsewhere, defendants JOSEPHINE SUNSHINE OVERAKER, KEVIN TUBBS,STANISLAS GREGORY MEYERHO FF, DANIEL GERARD M cGOWAN, JOSEPH DIBEE,REBECCA RUBIN, CHELSEA DAWN GERLACH, KENDALL TANKERSLEY, SUZANNESAVOIE, JONATHAN C HRISTOPHER MARK PAUL, DARREN TODD THURSTON,NATHAN FRASER BLOCK , and JOYANNA L. ZACHER, and unindicted co-conspiratorWILLIAM C. ROD GER S, and other persons known and unknown to the Grand Jury, willfkllyand knowingly conspired and agreed to commit the following offenses against the United S tates:

to maliciously damage or 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 or possessed by, or leased to, the United States or anydepartment or agency thereof, in violation of Title 18, United States Code, Section844(f)(l);to maliciously damage or destroy, or attempt to dam age or destroy, by means offire or an explosive, a ny building, vehicle or other real or personal prope rty used



28/65

in interstate commerce o r in any activity affecting interstate commerce, inviolation o f Title 18, United States Code, Section 84 4(i); andto knowing ly and willfully damage and attempt to dam age the property of anenergy facility of the United S tates involved in the transmission and distributionof electricity, in an amoun t exceeding or which would have exceeded $100,000, inviolation of Title 18, United S tates Code, Section 1366(a).

11. MANNER AND MEANS O F THE CONSPIRACYThe foregoing objects of the conspiracy were to be accomplished in the following manner

by the above-listed defendants and others at various times during the cou rse of the conspiracy:1. Certain of the defendants and others joined together in a group they called the

"Family." This "Family" w as what is commonly know n as a "cell" of groups and movem entspublicly nam ed and described by certain of the defendants and others as the Earth LiberationFront (ELF ), the Anim al Liberation Front (A LF), and ofher names.

2 . The general purposes o f the conspiracy were to influence and affect the conductof government, comm erce, private business and others in the civilian popu lation by means offorce, violence, sabotage, mass destruction, intimidation and coercion, and by similar means toretaliate against the conduct of governme nt, commerce and private business. To achieve thesepurposes, the conspirators comm itted and attempted to comm it acts dangerous to hum an life andproperty that constituted violations of the criminal laws of the United States and o f individualstates.



29/65

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

4. Certain of the defendants and another person targeted for willful damage anenergy facility of the United S tates involved in the transmission and distribution o f electricity, inan amount exceeding or which would have exceeded $1 00,000.

5 . Certain of the defendants and others targeted for arson buildings, veh icles andother real and personal prop erty used in interstate comm erce and in activities affecting interstatecommerce.

6. Certain of the defendants and others conducted and participated in meetings toplan arsons and o ther damage of the targeted sites. Several of these meetings were called "bookclub" meetings by the defendants and others, and occurred at different locations. The "bookclub" meetings covered subjects such as lock-picking, reconnaissance o f targets, andman ufacture of timing dev ices to set off improvised incendiary devices.

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 and othersused code words, code nam es, and nicknames.

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

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

Page 29 - SECOND SUPERSE DING INDICTMENT


30/65

11. Certain of the defendants and o thers dressed in dark clothing, wore masks andgloves and otherwise disguised their appearance.

12. Certain of the defendants and others acted as "look-outs" to ensure secrecy as thecrimes were carried out.

13. Certain of the defendants 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, maliciouslydamag ed and destroyed, and attempted to damage and destroy, buildings, ve hicles and other realand personal property ow ned and possessed by the United S tates and its departments andagencies.

15. Certain of the defendants and others, by means of fire and explosives, maliciouslydamag ed and destroyed, and attempted to damage and destroy, buildings, vehicles and othe r realand personal property used in interstate comm erce and in activities affecting interstatecommerce.

16 . Certain of the defendan ts and another person willfully damag ed and attempted todamag e the property of an energy facility of the United States involved in the transm ission anddistribution of electricity, in an amount exceeding or which would have exceeded $100,000.

17. In som e of the arsons and attempted arsons, certain of the defendan ts and otherspainted message s on the walls of the targets, including "Earth L iberation Front," "ELF" andrelated names and statements concerning the purposes of the crimes.

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



31/65

19. After the arsons, attemp ted arsons, and other crimes, certain of the defendan ts andothers destroyed, buried, hid and otherwise disposed of physical evidence used in thecommission of the crimes.

20. After the arsons, certain of the defendants and others publicized and promoted theresults of the fires by means of w ritten press releases an d comm uniques attributing the arsons tothe Earth Liberation Front (ELF), the Animal Liberation Front (ALF) and related groups, andstating the purposes o f the arsons.

21 . Before, during and after the arsons, attempted arsons and other crimes, certain ofthe defendan ts and others agreed and took an oath among 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.

22 . Before, during an d after the arsons, attemp ted arsons and oth er crimes, certain ofthe defendants and others agreed am ong themselves to conceal or destroy any evidenceconnecting them to the arsons, attempted a rsons and other crimes.

23. Before, during and after the arsons, attempted a rsons and othe r crimes, certain ofthe defendants and others possessed andlor 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 enforcem ent authorities in the United S tates./ I /

/ / /



32/65

111. OVE RT AC TSIn order to carry out the objects of the conspiracy, defendants and other persons

committed various overt acts within the District of Oregon and elsewhere, including but notlimited to the following:

1. All overt acts in Count 1 above are hereby realleged and incorporated into Count2.

2. As a further overt act in Count 2, on or about December 30, 1999, in DeschutesCounty, Oregon, defendants JOSEPHINE SUNSHINE OVERAKER, STANISLAUSGREGORY MEYERHOFF and CHELSEA DAWN GERLACH, and another person known tothe Grand Jury, willfully damaged and attempted to damage the property of an energy facility ofthe United States, namely, a Bonneville Power Administration tower, involved in thetransmission and distribution of electricity near the City of Bend, Oregon, in an amountexceeding or which would have exceeded $100,000.

All of the above conduct violated Title 18 , United States Code, Section 371.COUNT 3

ATTEMPTED ARSON - DETROIT RANGER STATIO NOn or about October 28, 1996, in Marion County, Oregon, in the District of Oregon,

defendant JOSEPHINE SUNSHINE OVERAKER and other persons known to the Grand Jury,unlawfully and willfully caused and aided, abetted, counseled, commanded, induced, andprocured the attempt to damage or destroy, by means of fire and an explosive, a building andother real and personal property owned and possessed by the United States and the United StatesForest Service of the Department of Agriculture, located at the Detroit Ranger Station on the



33/65

Willamette National Forest; all in violation of Title 18, United States Code, Sections 844(f) and

COUNT 4ARSON - DETROIT RANGER STATION VEHICLE

On or about October 28, 1996, in Marion County, Oregon, in the District of Oregon,defendant JOSEPHINE SUNSHINE OVERAKER 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, of a vehicle and other real and

personal property owned and possessed by the United States and the United States Forest Serviceof the Department of Agriculture, located at the Detroit Ranger Station on the WillarnetteNational Forest; all in violation of Title 18 , United States Code, Sections 844(f) and 2.

COUNT 5ARSON - OAKRIDGE RANGER STATION

On or about October 30, 1996, in Lane County, Oregon, in the District of Oregon,defendants JOSEPHINE SUNSHINE OVERAKER and KEVIN TUBBS, and another personknown to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,commanded, induced, and procured the malicious damaging and destroying, by means of fire andan explosive, of a building and other real and personal property owned and possessed by theUnited States and the United States Forest Service of the Department of Agriculture, located atthe Oakridge Ranger Station on the Willamette National Forest; all in violation of Title 18,United States Code, Sections 844(f) and 2.1 / /



34/65

COUNT 6ARSON - CAVEL WEST

On or about July 21, 1997, at Redmond, D eschutes County, Oregon, in the District ofOregon, defendants KEVIN TU BBS, JOSEPH DIBEE, and JONATHAN CHRISTOPHERMARK PAUL, and other persons known to the Grand Jury, unlawfully and willfully caused andaided, abetted, counseled, commanded, induced, and procured the malicious dam aging anddestroying, by means of fire and an explosive, of a building and other real and perso nal propertyused in interstate com merce and in activities affecting interstate comm erce, at Cave1 W est, Inc.,

1607 SE Railroad, Redm ond, O regon; all in violation of Title 18, United States Code, Sections844(i) and 2.

COUNT 7ARSON - BLM W ILD HORSE FACILITY, BURNS, OREGON

On or about November 30, 1997, in Harney County, Oregon, in the District of Oregon,defendants JOSEPHINE SUNSHINE OVER AKER, KEVIN 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 m alicious damaging and destroying, by means o f fire and an explosive, of buildingsand other real and personal property owned and possessed by the United States and the Bureau ofLand Managem ent of the Department of the Interior, located at the W ild H orse and B urroFacility, Bum s, Harney Co unty, Oregon; all in violation of Title 18, United States Code, Sec tions844(f) and 2./ / /



35/65

COUNT 8ATTEMPTED ARSON - U.S. FOREST INDUSTR IES

On or about Decem ber 22, 1998, at Medford, Jackson County, Oregon, in the District ofOregon, defendants KENDALL TA NKER SLEY, KEVIN TUBBS, and REBECC A RUBIN, andanother person known to the Grand Jury, unlawfully and willfully caused and aided, abetted,counseled, commanded, induced, and procured the attempt to dam age or destroy, by m eans offire and an exp losive, a building and other real and personal property used in interstate commerceand used in activities affecting interstate comm erce, namely, an office building and its contents at

U.S. Forest Industries, 261 1 Wh ittle Avenue, Medford, Jackson Coun ty, Oregon; all in violationof Title 18, United States Code, Sections 844(i) and 2.

COUNT 9ARSON - U.S. FOREST INDUSTRIES

On or about Decem ber 27, 1998, at Medford, Jackson Coun ty, Oregon, in the District ofOregon, defendant KEND ALL TAN KERSL EY and another person know n to the Grand Jury,unlawfully and willfully caused and aided, abetted, counseled, comm anded, induced, andprocured the m alicious damag ing and destroying, by means o f fire and an explosive, of a buildingand other real and personal property used in interstate comm erce and used in activities affectinginterstate commerce, nam ely, an office building and its contents at U.S. Forest Industries, 261 1Whittle Avenu e, Medford, Jackson County, Oregon; all in violation of Title 18 , United S tatesCode, Sections 844(i) and 2.I / /

/ / /



36/65

COUNT 10ARSON - CHILDERS MEAT COM PANY

On or about May 9, 1999, at Eugene, Lane County, Oregon, in the District of Oregon,defendants JOSEPHINE SUNSHINE OVERAKER,KEVIN TUBBS, STANISLAS GREGORYMEYERHOFF and CHELSEA DAWN GERLACH, 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 commerce and in activities affecting

interstate commerce, at Childers Meat Company, 29476 Airport Road, Eugene, Oregon; all inviolation of Title 18, United States Code, Sections 844(i) and 2.

COUNT 11ARSON - BOISE CASCADE

On or about December 25, 1999, at Monmouth, Polk County, Oregon, in the District ofOregon, defendants JOSEPHINE SUNSHINE OVERAKER, STANISLAS GREGORYMEYERHOFF and CHELSEA DAWN GERLACH, and another person known to the GrandJury, 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 commerce and in activities affectinginterstate commerce, at the Boise Cascade Office, 450 North Pacific Avenue, Monmouth, PolkCounty, Oregon; all in violation of Title 18,United States Code, Sections 844(i) and 2./ I

I / /



37/65

COUNT 12DESTRUCTION OF AN ENERGY FACILITY - BPA TOWER

On or about Decem ber 30, 19 99, in Deschutes Coun ty, Oregon, in the District of Oregon,defendants STANISLAS GREGORY ME YERHOFF, JOSEPHINE SU NSHINE OV ERAKER,CHELSEA D AW N GE RLA CH, and others both known and unknown to the Grand Jury,know ingly and willfully dam aged and attempted to d amage the property o f an energy facility ofthe Untied States, namely, a Bonnev ille Pow er Adm inistration tower, involved in thetransmission and distribution of electricity near the City of Bend, O regon, in an am ountexceeding or which w ould have ex ceeded $100,00 0; all in violation of Title 18, United S tatesCode, Section 1366(a).

COUNT 13ARSON - EPD PUBLIC SAFETY STATION

On or about September 6,20 00 , at Eugene, Lane County, Oregon, in the District ofOregon, defendants STANISLAS GREGORY MEYE RHOFF, KEVIN TUBBS and CHELSEADAW N GER LACH unlawfully and willfully caused and aided, abetted, counseled, comm anded,induced, and procured the malicious damaging and destroying, by means of fire and an explosive,of a building and other real and personal property used in interstate commerce and in activitiesaffecting interstate com merce, at the Eugene Po lice Department W est University Public SafetyStation, 791 East 1 3 ' ~ venue, Eugene, Lane County, Oregon; all in violation of Title 18, UnitedStates Code, Section s 844(i) and 2.I / /

/ / 1



38/65

COUNT 14ARSON - SUPERIOR LUMBER COM PANY

On or about January 2, 20 01 , at Glendale, Douglas C ounty, in the District of Oregon,defendants STANISLAS GREGO RY MEYE RHOFF, KEVIN TUBBS, DANIEL GERA RDMcG OW AN and SUZAN NE SA VOIE, 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 and o ther real and personal property used in interstatecommerce and used in activities affecting interstate commerce, namely, a building and itscontents located at Superior Lumber C ompany, 2695 Glendale V alley Road , Glendale, DouglasCounty, Oregon; all in violation of T itle 18, United States C ode, Section s 844(i) and 2.

COUNT 15USING AND CARRYING A DESTRUCTIVE DEVICEIN RELATION TO A CRIM E OF VIOLENCE - SUPERIOR LUMBER COM PANY

On or about January 2,20 01 , at Glendale, Douglas County, in the District of Oregon,

defendants STANISLAS GREG ORY M EYERH OFF and DANIEL GERA RD McGO WAN , andothers known and unknown to the G rand Jury, unlawfully and knowingly used and carried one ormore destructive devices, namely, on e or more incendiary bombs, during and in relation to acrime of violence, namely, arson, in violation of Title 18, United States Code, Section 844(i), ascharged in Count 14 of this indictment, a nd possessed such destructive dev ices in furtherance ofsuch crime; all in violation of T itle 18, United States Code, S ections 924(c)(l)(A)(i) & (B)(ii) &(C)(ii) and 2./ I /



39/65

COUNT 16ARSON - 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 TUBBS, STAN ISLAS GREGO RY MEYERH OFF, NATHAN FRASERBLOCK, and JOYANN A L. ZAC HER , unlawfully and w illfully caused and aided, abetted,counseled, comm anded, induced, and procured the malicious damaging and destroying, by meansof fire and an explosive, of a vehicle used in interstate commerce an d used in a ctivities affectinginterstate commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number

3GNGK26U4 1G2O9 163, located at Rom ania Che vrolet Truck Center, 142 5 W alnut Street,Eugen e, Lane C ounty, Oregon; all in violation of Title 18, United States Code, S ections 844(i)and 2.


On o r about M arch 30, 2001, at Eugene, Lane County, in the D istrict of Oregon,defendants KEVIN TU BBS, STANISLAS GREGO RY MEYER HOFF, NATHAN FRASERBLOCK , and JOY AN 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 comm erce and used in activities affectinginterstate com merce, nam ely, a 2001 Tahoe, bearing Vehicle Identification Num ber1GN EK13T 7 lR l5 48 66 , located at Romania C hevrolet Truck Center, 1425 Walnut Street,Eugene, Lane C ounty, Orego n; all in violation of Title 1 8, United States Code, S ections 844(i)and 2.



40/65


On or about March 30, 200 1, at Eugene, Lane County, in the District of Oregon,defendants KEVIN TUBBS, STANISLAS GREGORY MEYERHOFF, NATHAN FRASERBLO CK, and JOY ANN A L. ZAC HER , unlawfully and willfully caused and aided, abetted,counseled, commanded, induced, and procured the ma licious 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 Number

3GNGK26G8 1G235050, 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.


On or about March 3 0,2 001 , at Eugene, Lane County, in the District o f Oregon,defendants KEVIN TUBBS, STANISLAS GREGORY MEYERHOFF, NATHAN FRASERBLO CK, and JOYA NNA 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 comm erce, namely, a 2001 Suburban, bearing Vehicle Identification Number3GNGK26G8 1G203 103, located at Romania Chevrolet Truck C enter, 1425 Walnut Street,Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, Sections 844(i)an d 2.

Page 40 - SECOND SUPERSEDING INDICTMEN T


41/65


On or about March 3 0,20 01 , at Eugene, Lane County, in the District of Oregon,defendants KEVIN TUBBS, STANISLAS GREGORY MEYERHO FF, NATHAN FRASERBLOCK , and JOYA NN A L. ZACHE R, unlawfully and willfully caused and aided, abetted,counseled, commanded, induced, and procured the m alicious dam aging and destroying, by meansof fire and an ex plosive, of a vehicle used in interstate comm erce and used in activities affectinginterstate comm erce, name ly, a 2001 Subu rban, bearing Vehicle Identification Number

3GNFKl6T3 1Gl 97 47 2, located at Romania Chevrolet Truck Center, 1 425 Walnut Street,Eugen e, Lane Cou nty, Oregon; all in violation of Title 18, United States Cod e, Sections 844(i)and 2.


On or about March 30 ,20 01 , at Eugene, Lane County, in the District of Oregon,defendants KEVIN TUBBS, STAN ISLAS GREGO RY MEYERH OFF, NATHAN FRASERBLOCK , and JOYAN NA L. ZACHER, unlawfully and willfully caused and aided, abetted,counseled, comm anded, induced, and procured the m alicious dam aging and destroying, 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 Tahoe, bearing Vehicle Identification NumberlGNEK13TO 1J18 1082, located at Rom ania C hevrolet Truck Center, 1425 Walnut Street,Eugene, Lane County, Oregon; all in violation of Title 18 , United S tates Code, Sections 84 4(i)and 2.



42/65


On or about March 30 ,20 01 , at Eugene, Lane County, in the District of Oregon,defendants KEVIN TUBB S, STANISLAS GREGORY M EYERHO FF, NA THA N FRASERBLO CK, and JOYA NNA L. ZACHE R, unlawfidly and willfully caused and aided, abetted,counseled, commanded, induced, and procured the malicious damaging and destroying, by meansof fire and an exp losive, of a vehicle used in interstate comm erce and used in activities affectinginterstate commerce, namely, a 2001 Tahoe, bearing Vehicle Identification Number

lG N EK l3 T4 lR llO l6 2, located at Romania Chevrolet Truck Center, 1425 Walnut Street,Eugene, Lane County, Oregon; all in violation o f 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, STAN ISLAS GREGO RY MEYER HOFF, NATH AN FRA SERBLOC K, and JOYA NN A L. ZACHE R, unlawfully and willfully caused and aided, abetted,counseled, commanded, induced, and procured the malicious damaging and destroying, by m eansof fire and an explosive, o f a vehicle used in interstate comm erce and used in activities affectinginterstate commerce, namely, a 2001 Tahoe, bearing Vehicle Identification Number1GN EK13T3 1 150960, located at Romania Chevrolet Truck Center, 1425 W alnut Street,Eugene , Lane Cou nty, Oregon ; all in violation of Title 18, United States Co de, Se ctions 844(i)and 2.



43/65


On or about March 30 ,20 01 , at Eugene, Lane County, in the District of Oregon,defendants KEVIN TUBBS, STANISLAS GREGORY M EYERHO FF, NATHAN FR ASERBLO CK, and JOYA NNA L. ZACHE R, unlawfully and w illfully caused and aided, abetted,counseled, comm anded, induced, and procured the malicious damag ing and destroying, by meansof fire and an explosive, of a vehicle used in interstate comm erce and use d in activities affectinginterstate com merce, namely, a 2001 Sub urban, bearing Vehicle Identification Num ber3GNFK16T7 1G228593, located at Romania C hevrolet Truck Center, 1425 Walnut Street,Eugen e, Lane County, Oregon ; all in violation of 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 GREGO RY M EYERHO FF, NATHA N FRASERBLO CK, and JOY ANN A L. ZACH ER, unlawfully and w illfully caused and aided, abetted,counseled, commanded, induced, and procured the malicious dam aging and destroying, by m eansof 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 NumberlGN EK1 3T51 R148 547, located at Romania C hevrolet Truck Center, 1425 Walnut Street,Eugen e, Lane C ounty, Oregon; all in violation of Title 18, United States Co de, Sections 844(i)and 2.

Page 43 - SECO ND SUPERSEDING INDICTMENT


44/65

COUNT 26ARSON - ROMA NIA CHEVROLET TRU CK CENTER VEHICLE

On or abo ut March 30, 2001, at Eugene, Lane Coun ty, in the District of Oregon ,defendants KEVIN TUBBS, STANISLAS GREGORY MEYERHOFF, NATHAN FRASERBLO CK, and JOY AN NA L. ZACHER , unlawfully and willfully caused and aided, abetted,counseled, commanded, induced, and procured the m alicious damaging and destroying, by meansof fire and an ex plosive, of a vehicle used in interstate co mm erce and used in activities affectinginterstate comm erce, namely, a 2001 Subu rban, bearing V ehicle Identification Num ber

3GNFK16T71G22 6598, located at Rom ania Chevrolet Truck Center, 14 25 Walnu t Street,Eugene, Lane Coun ty, Oregon; all in violation of Title 18, United S tates Code, Sections 8 44(i)and 2.

COUNT 27ARSON - ROMA NIA CHEVROLET TRUC K CENTER VEHICLE

On or about March 3 0,20 01, at Eugene, Lane C ounty, in the District of Oregon,defendants KEVIN TUBBS, STANISLAS GREGORY MEYER HOFF, NAT HAN FRASERBLOCK, and JOYA NNA L. ZACH ER, unlawfully and willfully caused and aided, abetted,counseled, command ed, induced, and procured the malicious damag ing and destroying, by meansof fire and an explosive, o f a vehicle used in interstate com merce and used in activities affectinginterstate comm erce, namely, a 2001 Suburban, bearing Vehicle Identification Num ber3GNFK16T71G23 Ol79, located at Rom ania Chevrolet Truck Center, 14 25 Walnu t Street,Eugene, Lane Coun ty, Oregon; all in violation of Title 18, United States Code, S ections 844(i)and 2.



45/65


On or about March 3 0,2 00 1, at Eugene, Lane County, in the District of Oregon,defendants KEVIN TUBBS, STANISLAS GREGORY MEY ERHOFF, NATHA N FRASERBLO CK, and JOY AN 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 explos ive, of a vehicle used in interstate commerce and used in activities affectinginterstate comm erce, namely, a 2001 Tahoe, bearing Vehicle Identification Number1GN EK13T8 lR l6 94 90 , located at Romania Chevrolet Truck Center, 142 5 Walnut Street,Eugen e, Lane Co unty, Oregon; all in violation of Title 1 8, United States Code, S ections 844(i)and 2.

COUNT 29ARSON - ROMAN IA CHEVROLET TRUCK CENTER VEHICLE

On or about M arch 30 ,20 01 , at Eugene, Lane County, in the District of Oregon,defendants KEVIN TUBBS, STANISLAS GREGORY MEYERHOFF, NATHAN FRASERBLOCK , and JOYA NNA L. ZAC HER , unlawfully and willfully caused and aided, abetted,counseled, comm anded, induced, and procured the malicious damaging an d destroying, by meansof fire and an explosive, o f a vehicle used in interstate comm erce and used in activities affectinginterstate commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number3GNGK26G2 1G201069, located at Rom ania Chevrolet Truck Center, 14 25 Walnut Street,Eugen e, Lane C ounty, Oregon; all in violation of Title 18, United States Code, Sections 8 44(i)and 2 .



46/65


On or about March 30 ,20 01 , at Eugene, Lane County, in the District of Oregon,defendants KEVIN TUBBS, STANISLAS GREGORY M EYERHO FF, NATHA N FR ASERBLOCK , and JOY AN 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 N umber

3GN FK 16TX lG206 720, located at Romania Chevrolet Truck Center, 1425 Walnut Street,Eugene, Lane County, Oregon; all in violation of T itle 18, United S tates Code, Sections 844(i)and 2.


On or about M arch 30 ,20 01 , at Eugene, Lane County, in the District of Oregon,defendants KEVIN TU BBS, STANISLAS GREGO RY MEYER HOFF, NATH AN FRA SERBLOC K, and JOY ANN A L. ZACH ER, 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 vehicle used in interstate comm erce and used in activities affectinginterstate com merce, namely, a 2001 Sub urban, bearing Vehicle Identification Number3GNFK16T9 1G226585, located at Romania Chevrolet Truck Center, 1425 Walnut Street,Eugen e, Lane Co unty, Oreg on; all in violation of Title 1 8, United S tates Code, Sec tions 844(i)and 2.



47/65


On or about March 30 ,20 01 , at Eugene, Lane County, in the District o f Oregon,defendants KEVIN TUBBS, STANISLAS GREGOR Y MEYERH OFF, NATHA N FRASERBLOCK, and JOYANN A L. ZAC HER , unlawfully and willfuIly 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 and used in activities affectinginterstate com merce, namely, a 2001 Suburban, bearing V ehicle Identification Num ber3GNFK 16T6 1G2298 16, 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.


On or about March 30 ,20 01 , at Eugene, Lane County, in the District of Oregon,defendants KEVIN TUBBS, STANISLAS GREGORY MEYERH OFF, NATHAN FRASERBLO CK, and JOY ANN A L. ZAC HER , 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 comm erce, namely, a 2001 Suburban, bearing Vehicle Identification Num ber

3GNGK26U2 1G I 80066, located at Romania Chevrolet Truck Center, 1 425 Walnut Street,Eugene, Lane C ounty, Oregon; all in violation of Title 18, United S tates Code, Sections 844(i)an d 2.



48/65


On or abou t March 30 ,20 01 , at Eugen e, Lane Clounty, in the District of Oregon,defendants KEVIN TUBBS, STANISLAS GREGORY M EYERHO FF, NATH AN FR ASERBLO CK, and JOY AN 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 commerce and u sed in activities affectinginterstate com merce, namely, a 2001 Subu rban, bearing Vehicle Identification Num ber

3GNGK26U8 1G18 1349, located at Romania Chevrolet Truck Center, 1425 Walnut Street,Eugene , Lane C ounty, Orego n; all in violation of Title 1 8, United S tates Code, Sections 84 4(i)and 2.


On o r about March 30 ,200 1, at Eugene, Lane County, in the District of Oregon,defendants KEVIN TUBB S, STANISLAS GREGO RY M EYERHO FF, NATHA N FRASERBLOCK , and JOYA NNA L. ZAC HER , 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 vehicle used in interstate com merce and used in activities affectinginterstate comm erce, namely, a 200 1 Tahoe, bearing V ehicle Identification Numbe r1GN EK l3T 8 lR l60 80 6, located at Romania Chevrolet Truck Center, 1425 Walnut Street,Eugen e, Lane C ounty, Oreg on; all in violation of Title 18, United States Code, Sections 844(i)and 2.



49/65


On or about March 30, 200 1, at Eugene, Lane County, in the District of Oregon,defendants KEVIN TUBBS, STANISLAS GREGORY MEYERHOFF, NATHAN FRASERBLOCK, and JOYANNA 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 commerce and used in activities affectinginterstate commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number

3GNFK16TOlG155650, 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 30,2001, at Eugene, Lane County, in the District of Oregon,defendants KEVIN TUBBS, STAMSLAS GREGORY MEYERHOFF, NATHAN FRASERBLOCK, and JOYANNA 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 commerce and used in activities affectinginterstate commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number

3GNFK16TO1G206838, 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.



50/65

COUNT 38ARSON - ROMANIA CHEVROLET TRUCK CEN TER VEHICLE

On or about March 30, 2001, at Eugene, Lane County, in the District of O regon,defendants KEVIN TUBBS, STANISLAS GREG ORY MEYERH OFF, NATHAN FRASERBLOCK, and JOYAN NA L. ZAC HER , 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 comm erce and used in activities affectinginterstate com merce, namely, a 2001 Subu rban, bearing Vehicle Identification Nu mber3GNFK16T3 1G l95 20 5, located at Romania Chevrolet Truck Center, 14 25 Walnut Street,Eugen e, Lane County, Oregon; all in violation o f Title 1 8, United States Cod e, Sections 844(i)and 2.


On o r about March 30 ,20 01 , at Eugene, Lane County, in the District of Oregon,defendants KEVIN TUBBS, STANISLAS GREGORY MEYERHOFF, NATHAN FRASERBLO CK, and JO YAN NA L. ZACHER , unlawfully and w illfully caused and aided, abetted,counseled, commanded, induced, and procured the malicious dam aging and destroying, by m eansof fire and an ex plosive, of a vehicle used in interstate commerce and u sed in activities affectinginterstate commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number3GN FK 16TX lG225 834, located at Romania Chevrolet Truck Center, 142 5 Walnut Street,Eugen e, Lane Coun ty, Oregon; all in violation of Title 18 , United States Co de, Sections 844(i)and 2.



51/65


On or about March 3 0,2 00 1, at Eugene, Lane C ounty, in the District of Oregon,defendants KEVIN TUBB S, STANISLAS GREGO RY MEYER HOFF, NATH AN FRA SERBLO CK, and JOYA NN A L. ZACH ER, unlawfully and willfill y caused and aided, abetted,counseled, commanded, induced, and procured the malicious damaging and destroying, by meansof fire and an exp losive, of a vehicle used in interstate comm erce and used in activities affectinginterstate commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number

1GN FKl6T 2 15242612, located at Rom ania Chev rolet Truck Center, 14 25 Wa lnut Street,Eugen e, Lane County, Orego n; all in violation of Title 18, United States Code, S ections 844(i)an d 2.

COUNT 41ARSON - ROMANIA CHEVROL ET TRUCK CENTER VEHICLE

On or about March 3 0,2 00 1, at Eugene, Lane County, in the District of Oregon,defendants KEVIN TUB BS, STANISLAS GREGORY MEY ERHOFF, NATHA N FRA SERBLO CK, 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 meansof fire and an explosive, o f a vehicle used in interstate comm erce and used in activities affectinginterstate comm erce, namely, a 2001 Suburban , bearing V ehicle Identification Num ber3GNGK26U8 1G19 26 12, located at Rom ania C hevrolet Truck Ce nter, 142 5 Walnu t Street,Eugen e, Lane Co unty, Oregon; all in violation of Title 1 8, United S tates Code, Sections 844(i)and 2.



52/65

COUNT 42ARSON - ROMANIA CH EVROLET TRUCK CENTER VEHICLE

On or about March 30 ,20 01 , at Eugene, Lane County, in the District of Oregon,defendants KEVIN TUBBS, STANISLAS G REGOR Y MEYERHOFF, NATH AN FR ASERBLOCK , 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 ex plosive, of a vehicle used in interstate comm erce and used in activities affectinginterstate commerce, namely, a 2001 Tahoe, bearing Vehicle Identification Number

1GN EK13T7 1R116389, located at Ro mania Chevrolet Truck Center, 1425 Walnut Street,Eugen e, Lane Coun ty, Orego n; 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 TUBBS, STANISLAS GREGORY MEY ERHOFF, NATHA N FRASERBLO CK, 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 m eansof fire and an exp losive, of a vehicle used in interstate comm erce and used in activities affectinginterstate commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number3GNFK16T9 1G18 9098, located at Ro ma nia Chev rolet 'Truck Center, 142 5 Walnu t Street,Eugen e, Lane Coun ty, Orego n; all in violation of Title 18 , United S tates Code, Sections 8 44(i)an d 2.



53/65

COUNT 44ARSON - ROMANIA CH EVROLET TRUCK CENTER VEHICLE

On or about March 30 ,20 01 , at Eugene, Lane County, in the District of Oregon,defendants KEVIN TUBBS, STAN ISLAS GREGORY MEY ERHOFF, NATH AN 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 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 Number

3GNF K16TO lG198403, located at Romania C hevrolet Truck Center, 1425 Walnut Street,Eugen e, Lane County, Oregon ; all in violation of Title 18, United States Code, S ections 844(i)and 2.


On o r about March 3 0,20 01 , at Eugene, Lane County, in the District of Oregon,defendants KEVIN TUBB S, STANISLAS GREGO RY MEYER HOFF, NATH AN FR ASERBLO CK, 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 Number1GN EKl3TO 1 183320, located at Romania C hevrolet Truck Cen

Documents

Zacher.2nd.superseding.indictment.or