ariFinql a^m^lq;nr

UNrrBo Srares DIsrrucr Counr

GOPY

for the

Middle District of Florida
United States of America
v.

caseNo.

3: l5-l\.j -1110-J-JPK

JOSHUA RYNE GOLDBERG

DeJendon(s)

CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best

On or about the date(s)

Middle

of

District

"l9in91u-9l9!!91!--

-ry1s/l!ll.!9ll
Florida
of

Clay

of

the defendant(s) violated:

Ofense DescriPtion

Code Section

Title 18, United States Code,
Section 842(p)

,

in the county

ofmy knowledge and belief'

Distribution of information relating to explosives, destructive devices, and
weapons of mass destruction

This criminal complaint is based on these facts:
See Attached Affidavit

d

Continued on the attached sheet.

C o m p I a i na n l.t/6)Ena I u rc

William J. Berry, Jr., SPecial Agent
Pfinted name and litle

Swom to before me and signed in my presence.

o","'

to\ri
1\
-

City and state:

Jacksonville, Florida

Honorable James R. Klindt
Printed name and litle

in the

 A.FFIDAVIT IN SUPPORT OF A CRIMINAL COM"PLAINT
l, William J. Berry Jr, being duly sworn, state as follows:
INTRODUCTION

1.

I am a Supervisory Officer with U.S. Customs and Border Protection and

have been sg employed since March 1993. Since March 2010   have been assigned to

the Federal Bureau of Investigation (FBl), Northeast Florida Joint Tenorism Task Force
(JTTF) where I conduct a variety of investigations in the area of counterterrorism. In the

performance

of my duties, I have investigated and assisted in the

investigation of

matters involving violations of federal law related to domestic terrorism, international
terrorism, weapons of mass destruction, and bombing matters. I have been involved in

searches pertaining to the possession, purchase, manufacture, and/or distribution of
weapons of mass destruction and explosive materials through the execution of search
warrants. I have conferred with colleagues who have received specialized training from

the FBI in investigating crimes related to bombing matters.

2.

I have investigated and assisted in the investigation of criminal

matters

involving explosives and other weapons of mass destruction, including the distribution of

information relating

to

explosives, destructive devices, and weapons

of

mass

destruction in violation of 18 U.S.C. $ 842(p).

3.

I submit this affidavit in support of a criminal complaint for Joshua Ryne

Goldberg (Goldberg) charging him with
information relating

to

a

violation

of the illegal distribution of

explosives, destructive devices, and weapons

of

mass

destruction, namely that on or about August 19, 2015 through and including August 28,
2015, in Clay County, in the Middle District of Florida, Goldberg distributed information
pertaining to the manufacturing of explosives, destructive devices, or weapons of mass
destruction in furtherance of an activity that constitutes a Federal crime of violence by

 sending to a person five website links for websites that provided instructions that could

be utilized to construct or make explosives, destructive devices, or weapohs of mass
destruction, as part of a plot to explode a bomb on September 13,2015 at a memorial

ceremony

in

Kansas City, Missouri that commemorates the terrorist attacks of

September 11,2001 , in violation of Title 18, United States Code, Section 842(p).

4.

The statements contained in this affidavit are based in part on my

personal knowledge as well as on information provided to me by other law enforcement
officers and civilians. This affidavit is being submitted for the limited purpose of securing

a criminal complaint, and I have not included each and every fact known to

me

concerning this investigation. I have set forth only the facts which I believe are

necessary to establish probable cause to believe a criminal violation

of 18 U.S.C.

$

842(p) has been committed.
STATUTORY AUTHORITY

5.

This investigation concerns alleged violations of 18 U.S.C. S 8a2(p),

relating to the illegal distribution of information relating to explosives, destructive
devices, and weapons of mass destruction. Based upon my training and experience,

I

know the following:

a.

18 U.S.C. $ 842(p) in pertinent part prohibits a person from

teaching or demonstrating the making or use of an explosive, a destructive device, or a
weapon of mass destruction, or to distribute by any means information pertaining to, in
whole or in part, the manufacture or use of an explosive, destructive device, or weapon
of mass destruction, with the intent that the teaching, demonstration, or information is to
used for, or in furtherance of, an activity that constitutes a Federal crime of violence.

 b.

18 U.S.C. $ 841 in pertinent part defines the term "explosives" as

any chemical compound mixture, or device, the primary or common purpose of which is
to function by explosion; the term includes, but is not limited to, dynamite and other high

explosives, black powder, pellet powder, initiating explosives, detonators, safety fuses,
squibs, detonating cord, igniter cord, and igniters.

c.

18 U.S.C. S 921 in pertinent part defines the term "destructive

device" as (a) any explosive, incendiary, or poison gas to include a bomb, grenade,
rocket having a propellant charge of more than four ounces, missile having an explosive

or incendiary charge of more than one-quarter ounce, mine, or device similar to any of
the devices described in the preceding clauses; (b) any type of weapon (other than a
shotgun or a shotgun shell which the Attorney General finds is generally recognized as
particularly suitable for sporting purposes) by whatever name known which will, or which
may be readily converted to, expel a projectile by the action of an explosive or other
propellant, and which has any barrel with a bore of more than one-half inch in diameter;

and (c) any combination of parts either designed or intended for use in converting any
device into any destructive device described in subparagraph (a) or (b) and from which
a destructive device may be readily assembled.

d.

18 U.S.C. $ 2332a in pertineni part defines the term "weapon of

mass destruction" as a) any destructive device as defined in section 921 of Chapter 44;
b) any weapon that is designed or intended to cause death or serious bodily injury
through the release, dissemination, or impact of toxic or poisonous chemicals, or their
precursors, c) any weapon involving a biological agent, toxin, or vector; and d) any
weapon that is designed to release radiation or radioactivity at a level dangerous to
human life.

 e.

18 U.S.C. S 16 defines a crime of violence as (1) an offense that

has as an element the use, attempted use, or threatened use of physical force against

the person or property of another, or (2) any other offense that is a felony and that, by
its nature, involves a substantial risk that physical force against the person or property
of another may be used in the course of committing the offense.

ISLAMIC STATE OF IRAQ AND THE LEVANT

6.

Qn October 15,2004, the United States Secretary of State designated al-

Qa'ida in lraq (AQl), then known as Jam'at al Tawhid wa'al-Jihad, as a Foreign Terrorist
Organization (FTO) under Section 219 of the lmmigration and Nationality Act and as a
Specially Designated Global Terrorist under section 1(b) of Executive Older 13224.

7.

On May 15,2014, the Secretary of State amended the designation of al-

Qa'ida in lraq (AQl) as a Foreign Terrorist Organization under Section 219 of the
lmmigration and Nationality Act and as a Specially Designated Global Terrorist entity
under section 1(b) of Executive Order 13224 to add the alias lslamic State of lraq and

the Levant (lSlL) as its primary name. The Secretary also added the following aliases
to the lSlL listing: the lslamic State of lraq and al-Sham (lSlS), the lslamic State of lraq

and Syria (lSl), ad-Dawla al-lslamiyya fi al-'lraq wa-sh-Sham, Daesh, Dawla al lslamiya,

and Al-Furqan Establishment for Media Production. Although the group has never
called itself "Al-Qaeda in lraq (AQl)," this name had frequently been used to describe it
through its history.

 8.

Based on my training and experience I know that the lslamic State of lraq

and the Levant (lSlL) and its supporters' innovative use of social media and on-line
messaging has played a key role in motivating young US-based persons to travel to join

the self-declared "lslamic State" or allegedly attempt to conduct attacks in the US on
behalf of lSlL.

BACKGROUND OF INVESTIGATION AND
FACTS ESTABLISHING PROBABLE CAUSE

9.

The FBI Joint Tenorism Task Force is investigating JOSHUA RYNE

GOLDBERG as a suspect involved in the illegal distribution of information relating to
explosives, destructive devices, and weapons of mass destruction, in violation of Title
18, United States Code, Section 842(p).

10. I

reviewed open sourcel news articles describing the attack at the

"Muhammad Art Exhibit and Contest" on May 3,2015 in Garland, Texas. Based on this

review I learned that on May 3,2015 the "Muhammad Art Exhibit and contest" was held
at the Curtis Culwell Center in Garland, Texas. During the event, two armed gunmen, in

a dark-colored sedan, approached a police patrol car that had blocked their entrance to

the event. The two gunmen, later identified as Elton Simpson and Nadir Hamid Soofi,
stopped their sedan, stepped from their vehicle and opened fire on a police officer and a

security officer, using the back of the car as cover. Elton Simpson and Nadir Hamid
Soofi wore body armor and fired assault rifles at the officers. Police officers shot and
killed both men. Following the attack, the lslamic State of lraq and the Levant (lSlL) also
known as the lslamic State of lraq and Syria (lSlS) claimed responsibility for the attack

I The term "reviewed open source" refers to reviewing public documents that were located online through
Internet

searches

a

 in its news bulletin. lSlL identified the two gunman as "two soldiers from the soldiers of

the Caliphate."

11.

lalso reviewed open source reports from Australian and UK media outlets

that discussed the Garland, Texas attack. Based on my review, I determined that prior

to the attack, Twitter user "Aushali Witness" posted tweets calling for an attack on the
Muhammad Art Exhibit and Contest in Garland, Texas. The media outlets also reported

that Twitter user "Aushali Witness" posted a map of the Curtis Culwell Center prior to

the attack and urged anyone in the area to attack "with your weapons, bombs, or
knives."

12. I reviewed open source documents that showed communication

from

Twitter user "Australi Witness" in reference to the Garland, Texas attack. Based on my
review I determined that on or about May 3,2015, Twitter user "Australi Witness" used

Twitter screen name "@AusWitness3" to tweet,

'l'M BACK KUFFAR! DIE lN YOUR

RAGEI" On the morning of the attack in Garland, Texas, attacker Elton simpson, using
Twitter handle @atawaakul with screen name "shariah is Light" retweeted the "Australi

witness" message. Based on my training and experience, I know that "kuffar" is an
Arabic term that refers to non-Muslims or non-believers and that the term is used by
lslamic extremists as a derogatory term for non-Muslims.

13.

I conducted an open source internet

search on August 26' 2015

for "Australi Witness" which revealed a website at

I

http:i/justpaste.ivauswitness'

reviewed the JustPaste.it website (http://iustpaste.iVipabout) and determined that

Justpaste.it is a website that allows users to paste text and distribute the resulting link.
Open source internet searches regarding the website also revealed that supporters of

lSlL used the website to publish a threat to Twitter employees who had repeatedly shut

 down lSlL-link Twitter accounts. lSlL also used this website to publish a list of names
and , addresses

of US military

personnel.

I

reviewed the referenced website at

http://justpaste.iVauswitness and it contained a statement dated June 9, 2015, portions
of which are quoted verbatim below:
Hello, this is Australi Witness. You might know me for inspiring the

attacks in Garland, Texas, where two mujahideen entered an
event mocking the Prophet Muhammad (PBUH) with intent to
slaughter the kuffar in it. When I encouraged the attacks in Texas,

my biggest inspiration was the Australian Muslim human rights
activist...[M.V.]..., who has worked tirelessly and diligently to
outlaw blasphemy against lslam in Australia Any true Muslim
knows that blasphemy against the Prophets of Allah (SWT) is a
caoital crime which cannot be tolerated under any circumstances,
and... [M.V.'s]...work

inspiration.
crushed.

has provided me with

a

great deal of

All who defame the Prophet (PBUH) must be

...

Recently, I have met two mujahideen online - one in Los Angeles
and one in Melbourne - and I have successfully encouraged them

to

carry out jihad in their respective cities Both of these

mujahideen will, using guns, shoot up local synagogues when the
maximum amount of Jews are praying. The entire thing was my

idea, and I helped them every step of the way

l

gave them the

to local synagogues,

I

provided them with copious amounts of encouragement, and

I

idea in the first place,

I

pointed them

 helped them coordinate the attacks. All of this was done over the
Internet.
For those wondering about me: I currently live in Perth. I came to

Australia as

a

refugee from Lebanon, and my parents are

coconuts who have no idea of my involvement with jihad.

For many years, lworked

at.... In my last year

working at ...,

I

met some Muslim brothers who introduced me to the lslamic
State.

I was immediately enamoured with the lslamic State's

ideology, and

I

quickly became

a

mujahid. After becoming a

mujahid, I have dedicated my life to striking fear into the hearts of
the kuffar and coordinating acts of jihad around the world.

I cannot disclose where I

currently work, but

human rights organisation much like

it is a respected

.... I present myself as a

moderate in real life, and the police have absolutely no idea who

I

am. I am widely upheld as a pillar of my community, and nobody

would EVER suspect me for anything. You have no chance of
finding me....
To the Jews: you killed the Rasul (SAW) and he died a Shaheed.

Any Muslim who truly loves the Prophet (PBUH) will engage in
jihad against Jews in order to avenge his death. The Jews are the
worst enemies of Allah (SWT). When lslam conquers Australia,
every single Jew will be slaughtered like the filthy cockroaches
that thev are.

 Finally, I would like to state with absolute authority ... is a religion

of violent conquest.

...

Auskalia's defeat

..

. is inevitable. The

more you try to fight it, the harder it will be for you. Give up and
accept your future as an lslamic nation - a member of the global
lslamic caliphate that the lslamic State will create..

..

I have a vast network of mujahideen around the world, and lwill
continue to inspire and coordinate jihad attacks around the world.

There is absolutely nothing that you can do to stop me. I am an
expert in computer security who uses multiple proxies, and I am
also an expert in Australian law due to my extensive work with
human rights organisations. Chase me all you want, but you will

never find me, and you will also never stop the wrath of Allah
(SWT) on the decadent West
Perish in Your rage, kuffar!

14.

Based on a review of FBI records I determined that beginning on July 26,

2015, a FBI confidential human source (cHS) at the direction of the FBI exchanged
messages with an individual using the name AusWitness on a direct messaging

application. The individual was unknown to the cHS, but of interest to the FBl. since
the exchange of messages thai started on July 26, 2015 the CHS and Auswitness have
communicated nearly every day and continue to communicate on an almost daily basis'
The communications are received by the FBl, reviewed, and documented. I reviewed all
of the communications in preparing this affidavit. What is contained in this affidavit are

portions of certain conversations between the CHS and AusWitness that took place on
a direct messaging application, unless othen^/ise indicated. on July 26,2015 through

 July 28, 2015, AusWitness stated, in substance and among other things, that he was
attempting to get an individual in Melbourne, Australia to carry out a terrorist attack.
Listed below are portions of the conversation:

July 26,
CHS

-

2015

2015
July 27, 2015
CHS -

July 26,
AusWifness

2015
JulY 28, 201 5
CHS -

July 27,
AusWitness

July 28,
CHS

-

2015

22:04
Salaam, brother. What's up?
06:51

Nothing much ahki. It's nice to talk with
you. You've gotten kind of famous lately
Iol -SMILE*
19:41

Really? Where am lfamous?
15:07
t read a news afticle after garland and it
had your name in it
15:08

So / sa,d Alhamdulillah maybe we can

chat *Smile*

28,2015

JulY
Au'sWitness

06:57
A salaam alaikum brother

-

22:02
Yes, the kuffer media did cover me after
Garland

July 28, 2015 22:04
Right now, I'm trying to get a muiahid in
AusWfness Melboume to carry out iihad, but he
keeps delaying it. He has a gun already,
but he lnsisfs on making a video
message to the kuffar with a black
shahada flag. He a/so tnsisfs on getting
his fiend to carry out iihad with him. I
am afraid he'll get caught before he can
do it.

15.

As referenced above a FBI CHS is communicating on-line with an

individual using the name AusWitness. As outlined in paragraph #13, an open source
internet search for "Australi Witness" revealed a website at http://iustoaste.iVauswitness'
10

 The name of the website was http://iustpaste. iUauswitness. The beginning part of the
content on the website states "Hello, this is Australi Witness. You might know me for
inspiring the attacks in Garland, Texas, where two mujahideen entered an event
mocking the Prophet Muhammad (PBUH) with intent to slaughter the kuffar in it. when
encouraged the attacks in Texas

...."

I

On July 28, 2015 while communicating with the

CHS AusWitness stated "Yes, the kuffer media did cover me after Garland." Based on

the similarities between the spelling of AusWitness and Australi Witness, the statements
on the JustPaste.it website regarding the Garland attacks, and the July 28' 2015'

statement by AusWitness regarding the Garland attacks, I believe that the Australi

witness referenced in paragraph 14 and 15 is the same individual that posted the
content to http://iustpaste.iVauswitness and that "Auskali Witness" is also AusWitness.

16.

AusWitness and the CHS a so communicated between Ju y 30, 2015 and

August 1, 2015, during which AusWitness provided his Twitter account. A portion of the
conversation is as follows:
JulY

30,2015

21:54
Are you in Australia, brother?

'
JulY 31 , 2015 05:29
No, l'm in the states ahki
CHS JulY 31, 2015 22:17
Did we speak to each other on Twitter,
Aust4litness -

AusWtness

brother?

August 1,2015 05:32
No what's Your twitter?
CHS August 1,2015 22:27
Right now, it's @aussecret'
AusMfness -

17.

I reviewed records provided by Twitter, lnc. to the FBI for Twitter screen

name @Aussecret. Based on the review, I determined that Twitter screen name
11

 @AusSecret is associated with Twitter account id 3194951334 and was created on
May 14,2015. The records also listed an email address of beno3rrison@mailinator.com
associated with the account when it was created. The internet protocol (lP) for log-ins
to this account showed that the account was accessed from lP address 76.106.245.93
eight times between May 14, 2015 and May 26,2015:

Account lD: 3194951334
Created At 2015-05-26 't2:23:35 +0000
Last Login lP: 76.106.245.93
Account lD: 3194951334
Created At 2015-05-25 04:31:50 +0000
Last Login lP: 76,106.245.93
Account lD: 3194951334
Created At 201 5-05-24 00: 54:42 +0000
Last Login lP: 76.106.245.93
Account lD: 3194951334
Created At 2015-05-21 11:19:47 +0000
Last Login lP: 76.106.245 93
Account lD: 3194951334
Created At: 2015-05-19 13:40:55 +0000
Last Login lP: 76.106.245.93
Account lD: 3194951334
Created At: 2015-05-18 07:07:58 +0000
Last Login lP: 76.106.245'93
Account lD: 3194951334
Created At 2015-05-16 05:34:34 +0000
Last Login lP: 76.106.245.93
Account lD: 3194951334
Created At: 2015-05-14 11 04:27 +0000
Last Login lP: 76.', 06.245.93

18.

I searched an

online lP look-up service which revealed that lP address

76.106.245.g3 is associated with comcast cable communications, Inc. (Comcast
Cable).
12

 I reviewed records provided by Comcast Cable to the FBI for lP address

19.

76.106.245.93 and also spoke to Comcast Cable personnel in reference to the records.
The records involved the subscriber account information to include MAC addresses
between May 16,2015andMay26,2015for lP address76.106.245.93 atthefollowing

dates and times: 2015-05-16 05:34:34 +0000, 2015-05-18 07:07:58 +0000, 2015-05-19
13:40:55 +0000, 2015-05-21 11'.19:47 +0000, 2015-05-24 00:54:42 +0000, 2015-05-25
04:31:50 +0000, and 2015-05-26 12:23:35 +0000.

20.

Based on the review of the Comcast Cable records and dialogue with

Comcast Cable personnel I determined that lP address 76.106.245.93 is assigned to
R. Goldberg, the mother of JOSHUA RYNE GOLDBERG' at 3119 Pine Rd, Orange

park. Florida 32065, as the subscriber on the account. lP address 76.106.245.93 is
assigned to R. Goldberg to include from May 16,2015 through May 26, 2015 on the

dates and times indicated in paragraph 27. As of september 4,2015, the lP address
remains assigned to R. Goldberg and was assigned to her from at least from May 16,

2015 up to and including september 4,2015. The Comcast cable account which
includes high speed internet service is associated with among other email user id's
"metropolisforever".
21

.

My review of communication that occurred between AusWitness and the

cHS on August 5, 2015 and August 6, 2015, revealed that Auswitness told the cHS in
substance that he (AusWitness) was concerned about his contact in Melbourne,

Australia, as his contact had not communicated with him recently. Auswitness was
worried that he (Auswitness) was responsible for the arrest of the Melbourne contact'

AusWitness stated that he posted about his Melbourne contact on an internet
discussion board for "muhajideen". Listed below are portions of the conversation:
13

 August 5,2015
AusWitness -

13:10

lf he was captured, it would be my fault.
I mentioned him in a post on a
discusslon board for mujahideen. I feel
so guilty about this. I am so wonied
about him.

August 5, 2015
AusWitness -

44.44

If the kuffar captured him with his gun, it
would be on the news, ight?

August
CHS

6,2015

August
CHS

6,2015

-

-

Iwould assume?

August6,2015
Aust/yifness

22.

07:40

-

07:42
I don't know what to tell you bro
11:08
The thread I posted about him was on
Sch.net/islamicstate. Do you think the
kuffar could capture him iust from that
thread?

On August 14 and August 15, 2015, Auswitness and the CHS

communicated and AusWitness again discussed his concern that his Melbourne contact
had been arrested. During this timeframe a discussion began between the cHS and

Auswtness about the planning of a tenorist attack. Listed below are portions of the
conversation:

August

14,2015

AusWitness

August
CHS

-

-

14,2015

07:07
I iust can't get over this, akhi. The kuffar
govemment could be tofturing him for
info ight now, and all because I made
the stupid mistake of talking about our
plans on 8chan. If I find out he got
caught because of me, liust don't know
what l'il do. I teel like I have failed as a
Muslim'
07:30

Eest to get that out of your head ahki.
stafted
planning. We all do.

He knew the risks when he
14

 August
CHS

-

14,2015

07:41

Why Australia bro? Just cuious. Are
they as bad as the US?

15,2015

August

AusWitness

-

00:37
But, if I hadn't made a thread about our
plans, he wouldnT have been caught.
And yes, Australiais as bad as fhe US'

August
CHS

15,2015

07:40
But you don't know he's been caught.

August
CHS

15,2015

20:26

-

-

Where did you find him

in the first

place?

August

15,2015

22:39
I first met him on Twifter, but we never
talked until he emailed me.

August
CHS

15,2015

07:27
I don't know what else to say ahki.

AusWitness -

-

August
CHS

-

15,2015 07:33

Maybe we can Put some more t irons in
the fire bro. I think we're on the same

Page as far as ideas go.

August
AW -

16,2015

21:02
What do You mean, brother?

August
CHS

16,2015

22:40

-

Sounds like you're trying to do some
planning Australia. I'm trying to do the
same here' I have to get some sleeP
c/asses start again tomonow but let's
talk about this more tomonow night

August
CHS

-

August
CHS

-

16,2015

22:40
Night for me anway lol

16,2015

22:40
Salaam bro

4F

 August
AW -

23.
17

,

2O1S

16,2015

23:39
Salaam' brother.

AusWitness and the cHS continued their communication during August

through August 10, 201 5 about terrorist attacks in the West. Listed below are

oortions of the conversation:

August 17,2015 22:58
Did you hear the kuffar media talking
Auit4litness
about how lslamic State muiahideen
were su11osed gonna blow uP the
Queen of England a few daYs ago2

-

August

CtS -

17,2015

22:59

I heard something of it but didn't read
much of it.

August 17, 2015 23:07
I was actually really disappointed when
AusWifness it didn't haq7en. The UK needs a new
7/7. They kill our brothers and sisters a//
over the world.

August 17,
CHS

2015

23:08
The IJK is one of many that deseNe it.
We were suPPosed to have a few oPs
here on July 4 that didn't happen. lt was
so disaPPointing'

August 17,
CHS

2015

23:15

-

-

Hey bro I'm going to bed. We'll talk
more tomorrow. Hit me uP in the daY if
you want maybe I'll be around. Salaam'

August 17,2015 23:34
Hopefully there will be some jihad on the
Auiwitness
anniversary of 9/1 1 .

-

August 17, 2015 23:34
Alight, brother, Salaam.
AusWifness -

16

 August 18,
CHS -

2015

08:46
We could probably figure something out.
I leamed a lot planning with the Syrian
brother.

August 18, 2015 20:12
Salaambro
ul.to -

24. On August 19, 2015, AusWitness indicated that he was agreeable to working
with the CHS, as indicated below:

August

19,2015

AuiMfness

-

00:58
That sounds good. What do you have in
mind? Do you have anY bombs readY?

After some additional communications about the individual in Melbourne
being potentially arrested the CHS replied, as indicated below:

August

cHs

19,2015

-

05:34

I

don't have any bombs.

I don't

know

how to make them.

25.onAugustlg,20l5,AusWitnessbeganaskingCHSquestionsrelatedto
p anningaterroristattack.Listedbelowareportionsoftheconversation:
August

19,2015

AuiMfness

-

06:28

What weapons do you have brother? I
can send You guides on how to make
bombs if You need helP making them'

August
C/jS -

19,2015

06:29

t only have the one weapon but I do

t

think that is what Allah wants for me' I
was anested iust before with the one
weaPon. Guides would be great 'ahki
something bigger than iust a gun aftack
alhamdulillah.

August 19,2015 06:44
Atight, akhi. I'm gonna send you some
AuiWfness bomb-making guides on Twitter soon'
August
CHS

-

19,2015

06:44
Mashallah izk bro
17

 August 19,

2015

AusWitness -

07:14
Did you get my messages, akhi?

August
CHS

19,2015

07:15

August

19,2015

07:18

-

AusWitness'

Yes izk looking through them now Ahki

Let me now

if you need any

more,

brother. I'll help as much as I can.

26. I reviewed a message that was sent on Twitter on or about August

19'

2015, from AusWitness, who used Twitter screen name AusSecret with account id
31 94951

334 to send the message to the

cHS. Based

on the review of the message

I

determined that Auswitness (using Twitter screen name AusSecret) stated:

Akhihere are some guides on how to make bombs:
how to construct
After the colon, five website links that contained instructions on
are listed AusWitness
explosives, including pipe bombs or incendiary devices
concludes the message bY stating:
Letme know if you need any more, brother'
FBI Explosives Unit
27. As described more fully in paragraph 51' a review by the
by Aussecret to the cHS on
of the material listed on each of the five websites sent

Twitterdeterminedthatthewebsitesprovidedaccurateinstructionsthatcou dbe
and improvised explosive devices'
utilized to construct or make explosives, detonators

28. I reviewed records provided

by Twitter'

lnc to the FBI for Twitter screen

name@AusSecretwithaccountid3194951334'Basedonthereview,Ideterminedthat
showed that the account was
on August 19,2015, the lP for log-ins to this account
The timeframe of the access
accessed from lP address 76.106.245.93 two times'

correspondstothetimeframeinwhichtheCHsreceivedthemessagefromAusSecret
18

 containing the five website links to bomb making instructions. As outlined above, lP
address 76.106.245.93 is assigned to R. Goldberg at 31 19 Pine Rd., Orange Park,
Florida 32065.

29.

I reviewed additional communication between AusWitness and the CHS

on August 20,2015. I determined that on August 20,2015, AusWitness asked the CHS
in substance what kind of attack the CHS wanted to carry out, and stated that he
(AusWitness) was thinking of pipe bombs at a large public event. AusWitness later said

that a pressure cooker bomb may be even better. When AusWitness learned that the
CHS was located in the Midwest, AusWitness asked the CHS if he would be able to
drive to Kansas City to carry out an attack. Listed below are portions of the
conversation:

August 20, 2015 07:03
Have you decided what kind of attack to
AusWitness
carry out on 9/11, akhi? I was thinking a
bombina.

-

August 20, 2015
AusWitness -

August 20, 2015
CHS -

07:06

We could make pipe bombs

and
public
event.
detonate them at a large
07:06

Yes I'm leaning towards that too. I've
been getting excited about this. l've
been having trouble with the planners in
the dawlah who want me to just do a
gun attack. But that doesn't seem big
enough to bing true glory to Allah. Look
at Chaftanooga the kuff have already
forgetten

August 20, 2015
AusWitness -

07:O7

Exactly, brother. lt needs to be big. Do
you live in NYC? I'm in Perth. There are
lots of places to target here

19

 August 20,
CHS

-

2015

07:07

Do you know the directions you gave
me work? I've never made a bomb
before lol sorry

August 20, 2015 07:08
AusWitness
They wofu, akhi. But a pressure cooker
bomb might be even better. Let me ask
one of my brothers in the dawlah for
instructions.

-

August 20,
CHS

-

2015

07:10
Ok. ahki.

August 20, 2015 07:13
AusWitness
What city are you in, akhi? We need to
find the best place to place the
explosive.

-

August
CHS

-

20,2015

07:13

l'm in the Midwest fhe c/osesf place is
Kansas City if you're familiar

August
CHS

-

20,2015

07:13
But I can travel I'm just a student

August 20, 2015 07:14
Nnght, so will you be able to drive to
AusWifness
Kansas City to carry out the aftack?
August 20, 2015 07:14
Yes Easily
CHS

-

-

30.

I reviewed additional communication exchanged between AusWitness and

the CHS on August 24, 2A15 and determined that on August 24, 2015, AusWitness told
the CHS that he (AusWitness) found the "perfect place" to target in Kansas City on
September

11

,2015 and sent the CHS a link to kansascitystairclimb.com. Listed below

are portions of the conversation:

24,2015
-

Aug
AusWitness

00:56

What did you think

cooker instructions?

20

of the

pressure

 24,2015
-

Aug
CHS

24,2015
-

Aug
AusWitness

24,2015
Aug 24,2015
CHS Aug 24,2015
AusWitness -

Aug
CHS

08:30

Yeah that makes sense. What kind of
targets are you thinking? How will we
publicize it too
08:36

lMere will the most people be in
Kansas City on 9/11? That's
where we need to target08:37
No ideal I'm about an hour west
08:37
I don't go that often
08:42
I found the peiect p.lace. Go to
ka n s a sc itv st a i rc I i m b. c o m.

24,2015
CHS Aug 24,2015
CHS Aug 24,2015
AusMfness -

Aug

24,2015
-

Aug
CHS

08:43
Yes that's peffect I'm looking at it.
08:46
Alhamdulillah
08:49
Do you have the bomb ready,akhi?

08:51
No I haven't even started gefting

mateials

24,2015
-

08:55
Be careful, brother. Don't buy all the
materials at once or the kuffar will know
You're uP to something. BUY them at
different stores.

24,2015
-

10:24
Yeah that's what I was thinking

Aug
AusWitness

Aug
CHS

21

 31.

My review of the website showed that the Kansas City Stair Climb is a

memorial event where firefighters from the Kansas City region and members of the
community participate in a stair climb to honor New York City's first responders who

were killed in the September 11,2001 attacks. Although the event is a memorial for
New York City's first responders who were killed in the September 11,2001 attacks, the
actual date of the memorial event in Kansas City is September 13, 2015 according to
my review of the website.

32.

I reviewed additional communication between AusWitness and the cHS

on August 27,2015 and determined that Auswitness and the cHS continued their

discussion regarding the construction of a pressure cooker bomb. Auswitness

instructedtheCHStop acethebombnearthecrowdatthe9/. lmemoria event.Listed
below are portions of the conversation:

Aug 27, 2015
AusWitness -

08:22

Be careful, akhi. When You go
there to place the bomb, make
sure the bomb is VERY well
hidden.

Aug 27, 2015
cHs -

08:22
sometimes overheats I want to
make sure on the daY of I can get
there no problems

Aug 27, 201 5
CHS -

08:23

It

Yes t'm going to Put

it in the

backpack
Aug 27,2015
CHS -

08:23

Where do you think would be
best near the fire fighters or the

crowd
Aug 27, 201 5
AusWilness -

08:24

Good thinking, akhi. Put
backpack near the crowd.
22

the

 Aug 27, 2015
AusWtness -

08:24

But make sure lf 's in a place
where the kuffar won't think
anything of it.

33.

I reviewed additional communication exchanged between AusWitness and

the CHS on August 28,2015 and determined that AusWitness provided the CHS a list
of items to use in the pressure cooker bomb including nails, glass, and metal.

AusWitness then instructed the CHS to dip the screws and other shrapnel in rat poison
in order to inflict more casualties. As described more fully in paragraph 50, the addition

of items such as nails, glass, and metal would increase the lethality of the pressure
cooker bomb. Dipping the items in rat poison increases the chances of killing those

impacted by the nails, glass, and metal by possibly preventing any resulting wounds
from clofting. Listed below are portions of the conversation:
Aug 28,2015

cHs

-

Aug 28,2015
cHs -

07:49

I'n

going to Walmaft after
c/ass fhrs aftemoon and gefting
the rest of what I need

Hey

07:49

The instructions you have me
said to put something in the
pressure cooker that will act as

like a shrapnel

Aug 28, 2015
AusMfness -

07:50

Well, he could be telling other
mujahideen a bunch of lies about
me so they won't trust me.

Aug 28, 2015

cHs

-

Aug 28, 2015
AusWifness -

07:50
lMhat do you think for this bro?,
What will cause the most damage
07:50

Hold on, let me ask
mujahideen.
z5

some

 28,2015
Aug 28,2015
AusWitness Aug 28,2015
CHS Aug 28,2015
AusWitness Aug
CHS

Aug
CHS

28,2015
-

07:50
Jzk
07:58
Use shards of metal and nails, akhi.
07:58
Ok I'll get a bunch of screws and stuff
08:00
Broken glass would probably work too. Just put
as much sharp stuff as you can in there.
08:00

Have you made these before? How far away
do I have to get to be safe?? l'm thinking of
filming and shouting allahu ahkbar ight before
it goes off

28,2015
AusWrfness Aug

28,2015
Aug 28,2015
CHS -

Aug
CHS

28,2015
-

Aug
AulWitness

08:02

I

haven't made one before, but I've studied
how to make them. Get FAR away from the
bomb, brother. There's going to be chaos when
lf goes off . Shrapnel, blood, and panicking
kuffar will be everwhere.
08:02
Subhanallah
08:03

We will put the video online and
muiahideen will be heroes
08:04

lf you can, dip the screws and
other shraPnel in rat Poison

before Putting them in. That waY,
the kuffar who get hit bY them will
be more likelY to die.

28,2015
-

Aug
Auswitness

08:04

Indeed, akhi. The kuffar will
sPeak our names with tenor in
their voices.

34.

On or about August 10, 2015, the FBI received information from the

Australian Federal Police (AFP) which I reviewed. The AFP advised that on or about
24

the

 May 21,2015, Twitter user "Australi Witness," using screen name @AusWitnessT sent
a message as listed below:

Brothers, in case the kuffar suspend me again, you can email me at
auswitness@vahoo. com.

35.

Yahool Inc. provided records to the FBl, which I have reviewed. Based on

the review, I determined that the Yahoo! Account auswitness@yahoo.com was created
on May 9, 2015. The full name for the account was listed as Australi Witness and an
alternate email address of maymayposter@gmail.com was provided.

36.

Google provided records to the FBl, which I have reviewed. Based on the

review, I determined that Google account maymayposter@gmail.com was created on
January 4,2015 from lP address 76.106.245.93 and listed a subscriber name of M.S.

The account had been accessed from lP address 76.106.245.93 as recently as June

25,2015.

37.

As noted above, lP address 76.106.245.93 is associated with a Comcast

cable account subscribed to by R. Goldberg at 3119 Pine Rd., orange Park, Florida
32065.

38.

I reviewed research thai was conducted on the Clay County Property

Appraiser'swebsiteonAugust 24,2015 which produced a record of ownershipfor3'1 19
Pine Rd., Orange Park, Florida 32065 by F. Goldberg, the father of JOSHUA RYNE
GOLDBERG, and R. Goldberg.

39.

I reviewed the Florida Department of Motor Vehicles Driver and Vehicle

lnformation Database to include photographs of the below listed four individuals which
revealed that the following individuals list their residence as 3119 Pine Rd., orange

25

 Park, Florida 32065: F. Goldberg, R. Goldberg, D.Goldberg, and Joshua Ryne
Goldberg.

40.

I reviewed communications from FBI employee(s) whom conducted

physical surveillance of 3119 Pine Road, Orang Park, Florida 32065 on August 22 and

23,2015. Based on their observations and descriptions, I determined that F. Goldberg
and R. Goldberg were observed at this address. Two male minor children of elementary
school age were also observed by FBI employee(s) and are believed to be living at the
residence.

41.

I communicated

with FBI employee(s) regarding attempts to identify

JOSHUA RYNE GOLDBERG at 3119 Pine Road. I was advised of the following:

a.

Since August 20,2015 the FBI has been conducting surveillance of

the PREMISES.

b.

On or aboutAugust 24, 2015, FBI employees observed all other

persons identified as residing at 3119 Pine Road, except JOSHUA RYNE GOLDBERG,
leave the residence. Thereafter, FBI employees observed the shadow of a person
moving around the inside of the residence. They also observed a light in the vicinity of
the front door turn on. The FBI employees were unable to observe anything beyond the
shadow.

c.

On August 25,2015, FBI agents conducted a ruse wherein they

pretended to be employees of a fictitious company that conducts surveys on community

issues. After ensuring that all occupants of 31 19 Pine Road except for JoSHUA RYNE
GOLDBERG had left the residence, agents acting as employees of the fictitious
company approached the residence's front door. After knocking on the door and ringing
the doorbell, no one answered the door.

zo

 d.

On or about August 27, 2015, FBI employees observed

F. G. and R. G. leave 3119 Pine Road. Thereafter, FBI employees observed the
shadow of a person moving around the inside of the residence. They also observed a
light at the residence turn off. The FBI employees were unable to observe anything
beyond the shadow.

e.

On or about September 3,2015, FBI employees observed all

residents of 3119 Pine Road except for JOSHUA RYNE GOLDBERG leave the
residence. Thereafter, FBI employees observed the shadow of a person moving around

the inside of the residence. The FBI employees were unable to observe anything
beyond the shadow.

f.

On or about September 8, 2015, FBI employees observed all

residents of 31'19 Pine Road except for JOSHUA RYNE GOLDBERG leave the
residence. Thereafter, at approximately 9:00 A.M. FBI employees observed an unknown
male exit a van and approach the front door of the residence. Shortly thereafter' FBI

employees observed who they believe is JOSHUA RYNE GOLDBERG open the door
and talk with the unidentified male. After a brief conversation, the unidentified male

accompanied JOSHUA RYNE GOLDBERG into the residence. Shortly thereafter, the
unidentified male exited the residence unaccompanied by JOSHUA RYNE
GOLDBERG. The unidentified male then talks with someone in the van. A second
vehicle parks at 3119 Pine Road and another unidentified male exits his vehicle. Three
unidentified males then enter through the front door of the residence and the garage
door to the residence opens a short time later. Based on the observations and

descriptions of the FBI employee(s) conducting surveillance, it appears the three

27

 unidentified males are involved with a home construction and / or repair project at 3119
Pine Road.

42.

lwas advised by an FBI employee that between August 26 and27,2015,

FBI agents in the Tampa Division determined that D.Goldberg, the sister of JOSHUA
RYNE GOLDBERG, is a recently enrolled full-time student in the fall semester at a

college in South Florida and that law enforcement saw her on the campus on August 27,
2015.

43.

I reviewed records provided by Twitter, Inc. to the FBI for Twitter account

3194951 334 and determined that Twitter screen name Aussecret with account id

of
3194951334 continues to log into the accountfrom lP address 76.106.245.93 as
September 1,2015.

44.

on September 4,2015, the FB  received additiona  information from the

Australian Federal Police (AFP) that referenced a July 2015 interview of an individual
in substance and
who worked in Australia with the initials of L.M. L.M. advised the AFP,
"Australi witness",
among other things, that L.M. identified the on-line personas of
,,MoonMehoplis," and "lslamicstateAU" as belonging to JOSHUA GOLDBERG' DOB:

Florida) L M' explained
05/14l1995, at the PREMISES (31 19 Pine Road, orange Park,
"proponent of radical free
that JosHUA GOLDBERG was an "online troll" and a

the internet to
soeech." JOSHUA GOLDBERG was responsible for "hoax events" on
the identity of
include taking over individual's personas on-line. L.M. determined

JosHUAGoLDBERGthroughL.M.,sonlineworkandbycombiningpartsof
the various on-line
information that L.M. found listed on the profiles associated with

oersonas.L.M.statedthatL.M.hadmu tipleon- inedirectcommunicationswith
provided AFP with
oersonas that L.M. believed were in fact JOSHUA GOLDBERG and
z6

 various screen shots of conversations that purport to be with JOSHUA GOLDBERG.
From my review of the information provided to the FBI by the AFP, it does not appear

that L.M. provided the AFP with documents relating to the information on the
aforementioned profiles that resulted in L.M. ideniifying JOSHUA GOLDBERG with
various on-line personas.

45.

In one communication L.M. provided to the AFP, L.M. stated that L.M. was

in an lnternet Relay Chat (lRC) forum on May

26,2015. 1.M., using the moniker

"MoonLeftNut" communicated with "circ-user-BMFvi' whom L.M. believed was JOSHUA
GOLDBERG. The conversation, captured in a screenshot and provided by L.M. to the

AFP, stated:
MoonLeft Nut
Are you not all at concerned by the way that some of these
jihardi nutcases might actually kill someone at your behest?
Circ-user-BMFVi
These guys are pussy keyboard warriors.

MoonLeft Nul
ProbablY

Later in the conversation the following dialogue takes place:
Circ-user-BMFVi
You knew I was a troll from the start?

MoonLeft Nul
I was suspect ... I did not know.
Circ-user-BMFVi
And what led You to me?

Moonleft Nut
THE POWER OF MY MIND! Lol You did ... you led me to
you.

46.

L.M. also explained to the AFP that L.M. observed a conversation in an

IRC forum on May 22,2015. L.M. took a screen shot that purports to capture part of a
ZY

 conversation between JOSHUA GOLDBERG, using screen name "circ-user-tneQ7",
with an unknown individual using the screen name "@cicada". The conversation
captured in the screenshot and provided by L.M. to the AFP stated:
circ-user-tneQ7
Shit, lt's almost 10. Where is darkmage? We need to troll
some kikes. Wait ... you're part of CtrlSec?
@cicada
"used to be 4"
circ-user-tneQ7

You're not gonna turn me into the feds for pretending to be
lSlS, are you?
@cicada
so fuck them
no way manl>:(

47.

I

am not relying on any of the information provided by L M. to the AFP for

the establishment of probable cause for the issuance of a criminal complaint. Nor am

I

commenting on the credibility of the information provided by L.M to the AFP. This
information is provided to the Court out of an abundance of caution and the

aforementioned information regarding the hoax was not known to the FBI at the
beginning of the investigation.

48.

I reviewed a FBI Explosive Unit Technical Threat Assessment

(assessment). This assessment reviewed the content on the five websites that were
sent as internet links from AusSecret to the CHS on August 19,2015. The assessment
determined that all of the "sites or a combination of them could be utilized to construct

or make explosives, detonators and lEDs" and that "[t]he guidance offered by the
suspect would enable the CHS to gain the knowledge necessary to obtain the materials
to manufacture explosives and construct an lED." The assessment stated that "[i]n the

30

 immediate vicinity of a properly constructed and initiated IED the resulting effect would

cause property damage, personal injury and/or death."

49.

I reviewed records provided by Twitter, Inc. to the FBI for Twitter screen

name @AusSecret with account id 3194951334. Based on the review, I determined that

the lP for log-ins to this account showed that the account was accessed from lP
address 76.106.245.93 nine times between August 24, 2015, and September 1,2015.

50.

As referenced above I determined that lP address 76.106.245.93 is

assigned to R. Goldberg at 31 19 Pine Rd., Orange Park, Florida 32065, as the
subscriber on a Comcast Cable account.

51.

I reviewed surveillance reports provided by an FBI surveillance team

member, which confirmed that R. Goldberg, Frank Goldberg, and the two young

children had already left the residence when Twitter account 3194951334 was
accessed on four occasions between August 27, 2015, and September 1 , 2015.

52.

On September 9, 2015, the Honorable Magistrate Judge James R. Klindt

issued a search warrant for the residence located at 31 19 Pine Rd, Orange Park,
Florida 32065, which warrant is under seal. Upon making entry into the residence,
members of the FBI Joint Terrorism Task Force (JTTF) encountered JOSHUA
GOLDBERG and he was detained. JTTF Task Force Ofiicer SA William Berry then
spoke to JOSHUA GOLDBERG. Prior to any questioning, SA Berry advised JOSHUA
GOLDBERG of his constitutional rights. After being advised of his constitutional rights,

JOSHUA GOLDBERG voluntarily waived his rights and spoke to law enforcement.
Goldberg initially denied any involvement with distributing information on how to
manufacture a bomb as part of a plot to detonate a bomb at an upcoming memorial that
was commemorating the September 11,2001 attacks. However, JOSHUA
31

 GOLDBERG stated in substance, and among other things, that he was the individual on
Twitter known as "@Aussecret", "@AusWitness", and "Australi Witness". JOSHUA
GOLDBERG also stated that he sent out messages on Twitter using these and other

on-line personas. JOSHUA GOLDBERG stated that he sent out a message on Twitter
calling for an attack on the Muhammad Art Exhibit and Contest in Garland, Texas.

JOSHUA GOLDBERG stated that he created and posted the message on the
JustPast.it website that is referenced earlier in this affidavit.

53.

JOSHUA GOLDBERG stated that he was in contact via recent on-line

communications with an individual, who law enforcement knew to be the CHS. In fact,

JOSHUA GOLDBERG was in direct communication with the CHS immediately before
law enforcement made entry into the residence. JOSHUA GOLDBERG admitted that
he provided that individual with information on how to manufacture bombs. JOSHUA
GOLDBERG further admitted that he believed the information would create a genuine

bomb. Specifically, JOSHUA GOLDBERG stated that he provided the individual with
instructions on how to create a pressure cooker bomb. When creating the pressure
cooker bomb, JOSHUA GOLDBERG admitted that he instructed the individual to
include nails and to dip the nails in rat poison. JOSHUA GOLDBERG also admitted that
he instructed the individual to place the bomb at an upcoming memorial in Kansas City,
Missouri that was commemorating the September 11,20Q1 attacks. JOSHUA
GOLDBERG stated that he believed that the individual did intend to create functioning
bombs and would actually attempt to use them to kill and injure persons. During the
course of the interview, however, JOSHUA GOLDBERG made varying statements in an
attempt to explain his actions in providing bomb making information to the individual. In

general, JOSHUA GOLDBERG claimed that he intended for the individual to either kill
32

 himself creating the bomb or, if not, that he intended to alert law enforcement just prior
to the individual detonating the bomb, resulting in JOSHUA GOLDBERG to receive
credit for stopping the attack.
CONCLUSION

54.

Based on the facts and circumstances described above, there is probable

cause to believe that Joshua Ryne Goldberg (Goldberg) illegally distributed information
relating to explosives, destructive devices, and weapons of mass destruction, namely

that on or about August 19, 2015 through and including August 28, 2015, in clay
County, in the Middle District of Florida, Goldberg distributed information pertaining to
the manufacturing of explosives, destructive devices, or weapons of mass destruction in
furtherance of an activity that constitutes a Federal crime of violence by sending to a
person five website links for websites that provided instructions that could be utilized to
construct or make explosives, destructive devices, or weapons of mass destruction, as

part of a plot to explode a bomb on september 13, 2015 at a memorial ceremony in
2001,
Kansas city, Missouri that commemorates the terrorist attacks of September 11'
in violation of Title 18, United States Code, Section 842(p)'

U.S. Customs and Border Protection

Subscribed and sworn to before me this

R, KLINDT