A0 91 (Rev. 1 ill 1) Criminal Complaint UNITED STATES DISTRICT COURT for the Northern District of Ohio United States of America V- TERRENCE JOSEPH MCNEIL case NO- Defendanf?v) CRIMINAL COMPLAINT I, the complainant in this case, state that the following is true to the best of my knowledge and belief. On or about the date(s) of September 24, 2015 in the county of Summit in the Northern District of Ohio the defendant(s) 'Violated: Code Section 1 Offense Descriplion Title ?18, United States Code, Solicitation to Commit a Crime of Violence Section 373(8) This criminal complaint is based on these facts: SEE ATTACHED AFFIDAVIT Eli Continued on the attached sheet. I 1 . . Complainant 3 Signature Shawn S. Hare, Special Agent Printed name and rifle Sworn to before me and signed in my presence. w) i ., - DateJudge '3 silgnarure City and state; Akron, Ohio Kathleen B. Burke, U.S. Magistrate Judge Printed name and title AFFIDAVIT IN SUPPORT or CRIMINAL COMPLAINT AND AN APPLICATION FOR A SEARCH WARRANT I, Shawn S. Hare, being ?rst duly sworn, hereby depose and state as follows: INTRODUCTION AND BACKGROUND I make this af?davit in support of a criminal complaint and an application for a search warrant for the residence at 86 Bastgay Drive, Apaitment C, Akron, Ohio 44313, and further described in Attachment A, to seize the items listed in Attachment B. 2. I am a Special Agent of the Federal Bureau of Investigation, and, as such, am an investigative or law enforcement of?cer of the United States within the meaning of Rule 41 of the Federal Rules of Criminal Procedure. I am engaged in the enforcement of criminal laws and am within a category of of?cers authorized by the Attorney General to request . and execute search warrants pursuant to Title 18, United States Code, Section 3052 and 3107; and DOJ regulations set forth at. Title 28, Code of Federal Regulations, Sections 0.85 and 3. have investigated national security cases involving individuals seeking to travel overseas to commit violent jihad and who participated in terrorist fundraising, Additionally, I have completed administered counterten'orism classroorn'and online training, at the FBI . Academy, and at other Bl facilities. 4. The facts in this af?davit come from my personal observations, my training and experience, and information obtained from other-agents and witnesses. This affidavit is intended to show that there is suf?cient probable cause for the requested warrant and does not set forth all of my knowledge about this matter. A 5. Based on my training and experience as a Special Agent with the FBI, as well as the facts as set forth in this af?davit, there is probable cause to believe that a violation of Title 18, United States Code, Section 373, Solicitation to Commit a Crime of Violence, has been committed by Terrence Joseph McNeil (hereafter referred to as ?McNeil?). There is also! I probable cause to search the location described in Attachment A for evidence of these crimes," as described in Attachment B. 6. This Court is advised that there are items within the Probable Cause section of this affidavit that have been translated from Arabic into (English. In each instance, said translations were completed by an Arabic?speaking member of the Cleveland ointTen?orism Task Force (JTTF) and an FBI linguist for the purpose of accurately representing the statements made by McNeil. ?Moreover, for ease of review, the translated material will be limited to that which is enclosed within brackets at the end of each numbered paragraph. Where there are multiple instances of a particular term or phrase, I will only include a translation for the initial - occurrence. JURISDICTION 7. This Court has jurisdiction to issue the requested Warrant because it is ?a court of competent jurisdiction? as defined by 18 United States Code 2711 and 18 United States code 2703(3), Speci?cally, the Court is ?a district court of the United States has jurisdiction over the offense being investigated.? 18 United States Code 2711(3)(A)(i). BACKGROUND AND PROBABLE CAUSE 8. . I Title 18, United States Code, Section 373(a) makes it a crime for: ?Whoever, with intent that another person engage in conduct constituting a felony that has as an element the use, attempted use, or threatened'use of physical force against property or against the person of another in violation of the laws of the United States, and under circumstances strongly corroborative of that intent,'solicits, commands, induces, or otherwise endeavors to persuade such other person to engage in such conduct.? The felonies solicited consisted of the following: a. Title 18, United'States Code, section 1114 makes it a crime for: ?Whoever kills or attempts to kill any of?cer or employee of the United States or of any agency in any branch of the United States Government (including any member of the uniformed services) while such of?cer or employee is engaged in or on account of the performance of official duties, or any person assisting such an officer or employee in the performance of such duties or on account of that assistance.? b. Title 18, United States Code, Section 1389makes it a crime for: ?Whoever knowingly assaults or batters United States serviceman or an immediate family member of a United States serviceman, or who knowingly destroys Or injures the property of such serviceman or immediate family member, on account of the military service of that serviceman or status of that individual as a United States serviceman, or-Who attempts or conspires to do so.? 9. 1 On October 15, 2004, the United States Secretary of State designated al?Qaeda in Iraq known as Jam'at a1 Tawhid wa'al?Iihad, as a Foreign Terrorist Organization under Section 219 of the and Nationality Act and as a Specially Designated Global Terrorist entity under section 1(b) of Executive Order 13224. 10. On May 15, 2014, the Secretary of State amended the designation of al?Qaeda in Iraq as a Foreign Terrorist Organization under Section 219 of theImmigration and Nationality Act and as a Specially Designated Global Terrorist entity under section 1(b) of Executive Order 13224 to add the alias ?Islamic State of Iraq and the Levant? (ISIL) as its primary name. The Secretary also added the following aliases for ISIL: the Islamic State of Iraq and a1;~Sham, the Islamic State of Iraq and Syria (ISIS), adeawla aluIslamiyya f1 a?l-?Iraq wa-sh-Sham, Daesh, Dawla a1 Islamiya, and Al?Furqan Establishment for Media Preduction. ISIL has remained continuously designated since the ?rst designation of AQI in 2004. In an audio recording publicly released on or about June 29, 2014, ISIL announced a formal change of its name to the Islamic State. 11. In January 2015, ISIL released a video via social networking websites advocating lone offender attacks in western countries. The video contained material from a September 2014 message attributable to Abu Muhammad ial-qunani (spokesperson for ISIL), wherein he advocated for lone offenders in the West to attack law enforcement and military personnel. I Additionally, the video contained material from the September 2014 message wherein al?Adnani specifically referenced the targeting of American ?disbelievers.? 12. Terrence Joseph McNeil is a United States citizen currently living in Akron, Ohio. McNeil has no criminal history. On June '12, 2015, McNeil declared his support of ISIS, also referred to as ISIL, in a on the internet. McNeil posted a response to an anonymous user?s question ?If 1U [sic] support ISIS just admit it coward.? McNeilresponded, ?lmao I don?t support Egyptian idols you mean the Islamic State I have stated many times that I do support them.? . 13. On or about August 3, 2015, law enforcement requested Twitter to provide information for Twitter pro?le ?1 lLoneWolfe? (Twitter account The request was made based on two tweets made by Twitter account #1 on July 25, 2015 and July 27, 2015 that read ?@jundhullath @MusaGharieb19 @Backup_10_2 @AbuZaeemm?i I support Dawlah and I live in the and ?Just thinking about getting martyred puts a smile on my face. One day soon inshallah,? respectively. 14. Twitter?s response noted the creatioan address for Twitter account #1 was 184.561 13.43 (IP address The service provider for IP address #1 was identi?ed as Time Warner Cable. Additional 11? addresses associated with Twitter account #1 (TP addresses #2 through were provided by Twitter. The service provider for IP addresses #2 through #9 were identi?ed as Verizon Wirelessi 15. On or about August 4, 2015, Time Warner Cable provided basic subscriber - information for IP address The subseriber for IP address #1 at the time and date used by Twitter account #1 was Jodi Broadway, 86 Eastgay Drive Apartment C, Akron, Ohio. Commercial database and open source searches identi?ed McNeil as a resident of 86 Eastgay Drive Apartment C, Akron, Ohio. 16. ?On or about August 5, 2015, Verizon Wireless provided telephone. numbers accessed by IP addresses #2 through #9 at the speci?c dates and times accessed by Twitter account The common telephone number that accessed IP addresses #2 through #9 was 330- 807?0107. 17. On or about August 5, 2015, Verizon Wireless provided basic subscriber information for 330?807?0107. The subscriber listed was Terrence McNeil, 86 Eastgay'Drive Apartment C, Akron, Ohio. 1 18. A review of publicly accessible banner information for Twitter account #1 shoned a thumbnail image, also known as?an avatar, of several masked individuals wearing ballistic vests and carrying assault ri?es, as well as the phrase ?And the disbelievers planned, but Allah planned. And Allah is the best of planners 19. On or about August 11, 2015, Twitter account #1 was suspended. ?On or about August 11, 2015, Twitter pro?le ?12LoneWolfe? (Twitter account was created. A review of publicly accessible banner information forTwitter account #2 showed the same thumbnail image and quote as Twitter account #1 along With a screenshot of Twitter account #1 with the phrase ?Another another one.? Based on my review of the posted screenshot, it appears the screenshot was taken on a desktop computer. i 20. On or about August 21, 2015, Twitter account #2 was suspended. On or about August 22,2015, Twitter pro?le ?Lone_Wolfe13? (Twitter account was created. A review of publicly accessible banner information for Twitter account #3 showed the same thumbnail image and quote as Twitter accounts #1 and along with a screenshot of Twitter account #2 with the phrase ?Back again.? Based on my review of the posted sereenshot, it appears the screenshot was taken on a desktop computer. 21. On or about September 1, 2015, Twitter account #3 was suspended. On or about September 1, 2015, Twitter pro?le ?Lonel4Wolfe? (Twitter account was created. A review cf publicly accessible banner information for Twitter account #4 showed the same thumbnail image and quote as Twitter accounts and along with a screenshot of Twitter account #3 with the phrase ?Back like I neverleft..? Based on my review of the posted screenshot, it appears the screenshot was taken on a desktop computer. 22. On or about September 2, 2015, Twitter account #4 was suspended. On or about September 2, 2015, Twitter pro?le ?LoneWolt?e__1 5? (Twitter account was created. reyiew of publicly accessible banner information for Twitter account #5 showed the same thumbnail image and quote as Twitter accounts and along with a screenshot of Twitter account #4 with the phrase ?Back at. it.? I 23. On or about September 16, 2015, Twitter account #5 was suspended. On or about September 16, 2015,'Tw'itter pro?le ?LoneWolfe_16? (Twitter account was created. A review of publicly accessible banner information for Twitter account #6 showed the same thumbnail image and quote as Twitter accounts and along with aiscreenshot of Twitter account The account also wrote ?Egg block? in reference to the default avatar indicates he is suspicious of newly created accounts that do not customize their display.- 24 Onormmut' September 17-, 2015, Twitter pro?le ?Lone_\lVolfel7? (Twitter account was created. A retriew Of publicly accessible banner information for Twitteraccount #7?showed same. I ?5 thumbnail image and quote as Twitter accounts and along with a screenshot of Twitter account #6 withthe phrase ?Not going to stop me.? Based on my review of the posted screenshot, it appears the scr?eenShot was taken on a mobile phone. 25. On or about October 7, 20l5, Twitter account #7 was suspended, On or about October 7, 2015, Twitter pro?le ?LoneWolfe_18? (Twitter account was created. A review of publicly accessible banner information for Twitter account #8 showed the same quote as Twitter accounts and a screenshot of Twitter account along with the phrase #8 is a picture of a bearded white male with a green hat, which is different than the pier/ions avatar images used for the aforementioned Twitter accounts. Through open source searches 1 determined thepicture is ofTarkan 'Tayumurazovich Batirashvili, also known as Abu Omar al? Shishani, a ?eld commander for in Syria and a former sergeant in the Georgian Army. Based on my review oftlie posted screenshot, it appears the screenshot was taken on a mobile phone. 26. On or about August 26, 2015, and on or about September 1 and 2, 2015, I reviewed the Facebook account ?Terrence Joseph Broadway? with the URL of On May 21, 2013, the user posted ?Happy birthday to my mother Jodi Van As noted in paragraph 16, the subscriber for the Time Warner Cableaccount forlP address #1 was Jodi Broadway, 27. On or about September 1, 2, and 3, 2015 and on or about October 6, 2015, I reviewed the Tumblr account ?Abu-fil?i with the The account?s featured. quote on the home page is ?And the disbelievers planned, but Allah planned.? i This quote is similar to the quotes noted in paragraphs 19 through 26. 28. On or about June 12, 2015, account ?Aha-til? posted, Birthday? September 21 Based on a review?of information from the Ohio Law Enforcement Gateway (OHLEG), a system that provides Ohio Bureau of MotorVehicles data to law enforcement, 1 am aware McNeil?s birthday is September 215?. 29. On or about July 22, 2015, Tumblr account ?Ahu?fll? posted. ?So I need a letter from an Islamic center, or Masjid telling my job why I can?t cut my bread. The problem is I don?t live near one and 1 can?t afford to lose my job.? On July 22, 2015, Twitter account #1 tweeted, need a letter from an Islamic center or Masjid telling my job why 1 can?t cut my bread. The problem is I don?t live near one and I can?t afford to lose my job.? 30. 1 On or about August 26, 2015, the Tumblr account ?Abu-fil? posted ?Does the seriousness of dayn apply when the d?ayn is owed to a ka?r.? On or about August 26, 2015,. Twitter account #3 tweeted ?Does the seriousness of dayn apply to dayn owed to a ka?r?? [The term ?dayn? translates to ?debt? and the term ?ka?r? translates to ?non?believer.?] 31. On or about September 4, 2015, Tumblr account ?Abu?til? posted a picture to the account of a black male in hospital scrubs with the face partial obstructed. Based on a review of - the picture and a known picture of McNeil viewed on OHLEG, 1 believe the person in the Tumblr account picture is McNeil. I 32. On or about September 20, 2015, target account Twitter pro?le ?LonemWolfel 7? tweeted, my tumblr?.. In this tweet, ?Lone_Wolfe1 7? is providing the URL for the Tumblr page ?abu?fil? to a Twitter user named 33. On or about October 15, 2015, Twitter provided information pertaining to Twitter account #7 and other accounts. Twitter?s response identified the IP address Lised to create I Twitter account #7 as IP address which is the same 1P address used to create Twitter account i 7 I 34. Based on these facts and circumstances, believe McNeil is the user of Twitter pro?les ?11LoneWolfe,?A?12LoneWolfe,? ?Lone_Wolfel ?Lonel 4Wolfe,? ?LoneWolfe_15,? ?LoneWolfej ?Lone_Wolfe17,? and account ?Abu?til,? and Facebookaccount ?Terrence Joseph Broadway.? 35. On or about August 7, 11, and 26,2015, and on or about September 1 and 2, 2015 and on Or about October 5, 2015, I conducted a review of Facebook account ?Terrence Joseph Broadway.? The information and posts on this account are available to-any and all registered Facebook users. I reviewed available content from the period of February 2013 through September 2, 2015. Relevant observations in support of referenced statutory violations are as follows: 36. On or about May 11, 2014?, using Facebook account ?Terrence Joseph I Broadway,? McNeil posted, can?t wait for another 9/11, Boston bombing, or- Sandy'l-look! 1? On or about May12, 2014, following another user?s reply to this?comment, McNeil posted,??l?m American by birth not choice. Easily I?m .african anterican'and native american so this country has made my people suffer years. Casualty of war. I would gladly take part in an attack on this murderous regime and the poeple On or about May 12, 2014, following another user?s reply to this comment, McNeil posted, ?I?ll be proud when sled [sic] american blood.? 37.? On or about May 14, 2014, using Facebook account ?Terrence Joseph Broadway,? McNeil posted, ?Somebody should park a car bomb in front of a church, school, or mall.? I 38. On or about June 12, 2014, using Facebook account ?Terrence Joseph Broadway,? McNeil posted, ?Death to Israel. Death to America. Free Syria. Free Palestine.? 2 39. On or about July 2014, using Facebook acconnti?f?Terrence oseph'Broadway,? McNeil posted, ?Death to 40. On or about July 20, 2014, using acebook account ?Terrence Joseph Broadway,? McNeil posted, ?1 ?lsraeli soldiers killed today, if that?s not cause for celebration 1 don?t know what is.? i 41. .On or about August 20, 2014, using Facebook account ?Terrence oseph Broadway,? McNeil posted a link to a LiveLeakcom Video of the execution of James Foley, an American journalist who went missing in Syria and was beheaded by ISIL ?ghters, 42. On or about February 3, 2015, using Facebook account ?Terrence Joseph Broadway,? McNeil posted, ?This is what happens when you bomb women and children and get caught. Alhumdullilah was worried for a while they might let that murderer go.? Attached with this post were three pictures of Jordanian pilot Muath Safr Yousef al?Kasasbeh, who was burned to death by ?ghters. The pictures were of al?Kasasbeh before, during, and after his death, showing al~Kasasbeh engulfedin ?ames. 43. On or about June 285 2015, using Facebook account ?Terrence Joseph Broadway,? McNeil posted, ?232 killed in #Kobane 27 killed in #Kuwait 1 killed in #Francel39 killed in #Tunisia Dawlatul Islamiya Baqiyai Allahu [The phrase ?Dawlatul lslamiya Baqi?ya? translates to .?Nation of Islam remains strong,? and the termr?allahu akbar? translates to ?God is great.?] 44. On or about September 1, 2, and 3, 2015 and on or about October 5 and 26, 2015, I conducted a review of publicly available information on Tumblr account ?Aha?til.? I reviewed 7 available content from March 2015 through October 26, 2015. Relevant observations in support of referenced statutory violations are as follows: 45. On or about March 30, 2015, using Tumblr account McNeil posted, ?Hijrah from dar al kufr to dar al islarn or jihad in dar a1 kufr.? [The term ?hijrah? translates to ?voyage?; the term ?dar al kufr? translates to ?land of disbelief?; the term ?dar al islam? translates to ?land ofislam.?] 46. On orlabout April 20, 2015, using Tumblr account ?Abu?fil,? McNeil posted, hate living in Dar-u] [sic] anr, I want to make hijrah to be with the true believers. I?m sick of. being surrounded by the ignorance, the propaganda, and the fitnah. 1 want to help my suffering brothers and sisters but I can to [sic] anything to help here. My only options are to stay in the US and endure, trying to go to Iraq or Syria (probably get arrested before 1 step foot on the plane), live in a Muslim country ruled by a taghut US puppet regime, or live in a small house in the middle of nature.? [The term ?fitnah? translates to ?trial? or ?test.?] 47. Based on McNeil?s use of ?dar al kufr? in paragraph 45 and ?Dar-u] Kufr? in paragraph 46, I interpret his use oi this statement to mean the United States. 48. On or about April 21, 2015, using Tumblr account McNeil posted, ?No American citizen is safe, ?sabilillah they are all valid target. Until our brothers and sisters are free from imprisonment, harassment, torture, bombs, and bullets American will bleed inshallah.? [The term ??sabilillah? translates to ?eyes of Allah? and the term ?inshallah? translates to ?God willing.?] 49. On or about May 10, 2015, using Tumblr account McNeil posted, ?One day soon I will be with my brothers on the frontline inshallah.? 50. On or about June 29, 2015 using Tumblr account McNeil posted, ?There is a gay imam in the US, it?s time for me to 51. On or about July 6, 2015, using Tumblr account McNeil posted, support all the Mujahideen groups. I don?t pick and choose which groups I support. Unlike some. Muslims who label them misguided or khwarij. It?s not my role to criticize them, I?ll support them and let Allah (SWT) guide them. I won?t support a groups [sic] if there [sic] actions are clearly not Islamic or there [sic] actions are kufr.? [The term ?nan ahideen? is plural for ?mujahid? and translates to ?one engaged in jihad.?] - 52. On or about July 7, 2015 using Tumblr account ?Abudil,? McNeil posted, ?Too many homicidal thoughts.? - 53. On or about July 7, 2015 using Tumblr account ?Alan-til,? McNeil responded to an anonymous user?s question. The anonymous user?s question read ?Wallami shame on you for calling these people Uleema. BTW you?re biggest problem is that you put jihad over tawhed. Having correct aqeed'a is 100x times better than fighting kuffar, While you?re maybe a ka?r yourself.? [The term ?Wallami? is likely intended to read ?Wallahi? and translates to swear by God?; the term ?Uleema? refers to ?people recognized as scholars?; the term ?tawhed? translates to ?belief [in oneGod?; the term ?aqeed? refers to ?doctrine?; the term ?kuffar? is a plural form of ?ka?r? and translates to ?unbeliever.?] McNeil posted a response that read, ?If that was true 1 would have made hijrah a long time ago or 1 would have fought the ltuffar here and in the west. 1 support the mujahideen mostly because they are ?ghting to protect our brothers and sisters arid Islam.? 54. On or about July 1 1, 2015, using Tumblr account McNeil posted, ?The doctors who have made hijra to Dawlah 1 have the most respect for. They left the really good pay behind in the ,west, risking death and prison to help our brothers and sisters in Syria.? [The term ?dawlah? translates to Based on the context through which McNeil uses the word ?Dawlah? here, along with the alias for ISIL as noted in paragraph 10, I believe McNeil?s use of ?Dawlah? is meant to mean the Islamic State in Iraq- and Syria, 55. On or about July 15, 2015 using Tumblr account McNeil responded to 'a post that read ?Would you say your Tumblr is a fair representation of the ?real you?? McNeil - responded, ?somewhat about if it was 100% I would be in jail.? i 56. On or about July 16, 2015 using Tumblr account McNeil posted, ?11 just heard the news Allahu Akbar! May Allah (SWT) accept our brother Muhammad Youssef Abdulazeez.? I am aware that on July 16, 2015, Muhammad HYoussef Abdulazeez opened ?re on - two military installations located in Chattanooga, Tennessee. Four Marines and one Navy sailor were killed, and Abdulazeez was killed by authorities. 57.. On or about July 1-6, 2015, using Tumblr account McNeil posted a response to a questionnaire that asked ?What is your favorite act of worship?? McNeil posted, ?jihad nsabilillah.? 58'. On or about July 20, 2015, using Tumblr account ?Aha?til,? McNeil posted, ?1 had a dream that I was martyred ?ghting Russians. . interesting. . 5 9. On or about July 26', 2015, using Tumblr account ?Aha-til,? McNeil posted, don?t understand how sisters are arrested for trying to make hij rah. They were going to the Islamic state to live not ?ght. Make Dua for our sisters and brothers who were arrested while trying to make hijrah.? [The term.?dua? translates to ?support?? 60. On or about July 26, 2015, usingTumblr account McNeil reblogged a photograph entitled ?heads of featured three bodiless heads in a large pool of blood. 0 61. On or about August 3, 2015, using Tumblr account McNeil posted, will be with my. brothers on the front lines or in jail inshallah.? 62. On or about August 7, 2015, using Tumblr account ?Abu?iil,?McNeil posted, ?I?m native American, German, and black the US has been killing my ancestors for awhile.? 63. On or about August 13, 2015, using Tumblr account McNeil posted a response to an anonymous user?s question of ?Things I want in the next 5 years.? McNeil responded, a shaheed, jihad?sabilillah, or a doctor/nurse in the land of the khilafa.? [The term . ?shaheed? translates to ?martyr? and the term ?khilafa? translates to ?land of holy one.?] 64. On or about August 14, 2015, using Tumblr account ?Aha-til,? McNeil posted a photograph of a black handgun with the caption YOU ONLY DIE ONCE WHY NOT MAKE IT 65. On or about-August 15, 2015, using Tumblr account ?Abu?fil,? McNeil posted, . ?The Islamic State is still making gains against ASsad while the whole world is at war with them. May Allah protect the mujahideen of Danah and grant them many more victories.? 66. On or about August 15, 2015, using Tumblr account ?Abu?fil,? McNeil made a post entitled would have been reported to the-feds? that read ?Coworker I hope Donald - trurnp doesn?t win. Coworker I hope he wins. Me: I hope he wins too. Me: So?he can go to war in Syria and I can fight. Ll. Me: let me shut up.? On or about August 31, 2015, using Tumblr account McNeil posted, ?Before I embraced Islam, I supported the Mujahideen for my hatred of the IIS. Now I support the ijahideen for my love of the Muslim ummah.? [The term ?ummah? translates to ?nation.?] 68. On? or about September 6, 2015, using Tumblr account McNeil posted, lot of brothers and sisters posting about refugees and civilians being by [sic] Assad. Are the same people who slander the Mujahideen and say now is not the time for jihad. They want the huffar and taghout governments to help. No the Khilafah has been reestablished. Help it expand worldwide so no Muslim will suffer never again [sic] inshallah. The Khilafah isn?t perfect yet it, it needs your help [sic]. Instead of trying fix [sic] a democracy from the inside. Why not help create a true Islamic state.? [The term ?taghout? translates to ?big? or ?powerful.?] '69. On or about September 24, 2016, using Tumblr account ?Aha?til,? McNeil reblogged a ?le with the banner ?Islamic State Hacking Division,? followed by ?Target: United States Military? and ?Leak: Addresses of 100 US Military Personnel.? The file type is a .gif ?le, which allows multiple still images to be looped in one file, with a timed delay between each photograph being displayed. The text of the first photograph reads,?O Brothers in America, know that the jihad against the crusaders is not limited to the lands of the Khilafah, it is a world? wide jihad and their war is not just a war against the Islamic State, it is a war against Islam. . .Know that it is wajib for yon-to kill these kuffar! and now we have made it easy for you I by giving you addresses, all you need to do is take the final step, so what, are youwaiting for? Kill them in their own lands, behead them in their own homes, stab them to death as they walk their streets thinking that they are The file then loops several dozen photographs that purport to be of United States military personnel, along with their respective name, address, and military branch. The final photograph loop contains a picture of a handgun and a knife with text that reads . .and kill them wherever you find them. . [The term ?wajib? translates to I. ?necessaryf?l 70. On or about September 28, 2015, using Tumblr account ?Abu?l?il,? McNeil. pested, ?1 don?t think I?m going to experience true brotherhood until I leave the US. . One Tumblr user responded to McNeil?s post, and McNeil responded ?One day ak?hi inshallah.? [The term ?akhi? translates to ?brother? and is a statement made in support of an individual.] 71. On or about August 7, 10, and 11, 2015, I conducted a review of publicly available information on Twitter account I reviewed available content from the period of July 22, 2015, through August 11, 2015. Relevant observations in support of referenced statutory violations are as follows: 72. On or about July 22, 2015, using Twitter account McNeil uploaded an image depicting soldiers wearing-ballistic vests holding automatic weapons. 73. On or about July 25, 2015, using Twitter account McNeil tweeted, support Dawlah and 1 live in the - 74. On or about July 27, 2015, using Twitter account McNeil tweeted, ?Just thinking about getting martyred puts a smile on my face. One day soon inshallah.? ?75. On or about July 30, 2015, using Twitter account McNeil retyveeted a post that read ?Sunni tribal sheikhs in Iraq?s Anbar province have Renew [sic] there [sic] Baya to the I Islamic State.? The post was accompanied by four photographs,including one photograph of individuals standing in front of the ISIS ?ag. [The term ?baya? translates to ?allegiance.?] 76. On or about August 4, 2015, using Twitter accOunt McNeil retweeted a post that read ?The implementation of Hadd upon those cursing Allah ?Azza wa alla in Wilayat #Raqqah.? The post was accompanied by a photograph of a masked man with a sword'beheading a person in an orange jumpsuit. [The term ?hadd? translatesto ?restriction? and in the context of .. 77. On or about August 5, 2015 using Twitter account McNeil tweeted, ?The kuffar fear anyone who invites Muslims to the Haqq #FreeAnjemChoudary #FreeAbuBaraa.? 78. On or about August 7, 2015, using TWitter account McNeil tweeted, ?Being 'Muslim, black, and native american in the US, I feel like it?smy duty to burn AmeriCa.? 79.. On or about October 5 and 6, 2015, I conducted a review of publicly available information on Twitter account 1 reviewed available content from the period of September 17, 2015, through October 7, 2015. Relevant observations in support of referenced statutory violations are as follows: 80. tweet that read. ?@Lone_Wolfel 7 @Bint_Crackeriya what 1 don?t get you. I don?t advise any muslim to Stay in the USA or any kufar country.? in response, McNeil tweeted, ?1 agree 100%. The only Muslims that should. come to the US are ones that carry black banners looking to . conquer.? 81. On or about October 13, 2015, physical surveillance was conducted in the vicinity of 86 Eastgay Drive, Akron, Ohio (the residence.) At'approximately McNeil was 'aobserved exiting the residence. McNeil was then observed boarding an Akron Metro bus, which he stayed on until arriving at the Akron Transit Center. McNeil was observed changing buses and boarded another Akron Metro bus, which departed the Akron Transit Center. At approximately McNeil was observed exiting the Akron Metro bus at approximately Adolph Avenue and East Market Street in Akron, Ohio. At approximately McNeil was observed entering Akron City Hospital through employee entrance IV 82. On or about September 17, 2015, PNC Bank provided documents related to three bank accounts in the name of Terrence McNeil ending in x9967, x9975, and x9983, including one signature card and bank statements for each of the aforementioned accounts. I reviewed the signature card, which listed an address for McNeil of 86 Eastgay Drive, ApartmentC, Akron, Ohio. A review of the bank statements listed two direct deposits from Summa Health Systems and five transactions for Cafe and Starbucks.? Based on the physical surveillance noted in paragraph 83 and the direct deposits noted above, I believe the ?ve transactions are for Akron City Hospital Cafe. 83. As previously noted in paragraph 32, McNeil posted a picture of himself in hospital scrubs to his Tumblr page ?Aha-til.? When? combined with the information in . paragraphs 83 and 84, I conclude McNeil took this picture on his cellular phone at Akron City Hospital. I i 84. Based on information in paragraphs 18 20 through 22, 25, 26, and 85, I believe McNeil uses both his cellular phone and desktop computer to access a variety of social media accounts through his cellular phone service provider and home internet service provider. COMPUTERS AND OTHER DIGITAL-STORAGE MEDIA CELLULAR TELEPHONES) 85. As described in Attachment B, this application see-ks permission to search for records and other evidence that might be found 0n the premises described in Attachment A, in whatever form they are found, One form in which the records or other evidence may be found is data stored on a computer's hard driveor other storage media, including cellular telephones. Indeed, due to McNeil?s use of socialmedia and the Internet to communicate with others regarding lSlL, his use of a computer in his possession as described above, and Affiant's training and experience investigating national security matters, Affiant anticipates that evidence will be found in digital form on computers or other digital storage media, including cellular telephones. Thus, the warrant applied for would authorize the seizure of electronic storage media, or, potentially, the copying of electronically stored information, all under Rule 41 86. Affiant submits that if a computer or storage medium is found on the premises, there is probable cause to believe records or other evidence will be stored on that computeror storage medium, for the following reasons: 87. Based on my knowledge, training, and experience, I know that computer files or remnants of such files can be recovered months or even years after they have been downloaded onto a storage medium, deleted, or viewed via the Internet. Electronic files downloaded to a. storage medium can be stored for years at little or no cost. Even when the files have been deleted, they can be recovered months or years later using forensic tools. This is so because when a person deletes a file on a computer, the data contained in the file does not actually? disappear; rather, that data remains on the storage medium until it is overwritten by new data. I 88. Therefore, deleted files, or remnants of deleted files, may reside in free space or - slack space?that is, in space on the storage medium that is not currently being used by'an active file-for long periods of time before they are cverwritten. In addition, a computer's operating system may also keep a record of deleted data in a ?swap? or "recovery" file. i 89. Wholly apart from user?generated files, computer storage media?in particular, computers' internal hard drives?contain electronic evidence of how a computer has been used, what it has been used for, and who has used it. To give a few ekamples, this forensic evidence can take the form of operating system con?gurations, artifacts from operating system or application operation, file system data structures, and virtual memory "swap" or paging files. Computer users typiCally do not erase or delete this evidence, because special software is normally required for that task. However, it is technically possible to delete this information. i 90. Similarly, files that have been viewed via thelnternet are sometimes automatically downloaded into a temporary Internet directory or ?cache.? 91. Forensic Evidence. As further described in Attachment B, this application seeks permission to locate not only computer files that might serve as direct evidence of the crimes described on the warrant, but also for forensic electronic evidence that establishes how computers were used, the purpose of their use, who used them, and when. There is probable cause to?believe that this electronic evidence will be on any storage medium inthe premises because: 92. Data on the storage medium can provide evidence of a file that was once on the storage medium but has since been deleted or edited, or of a deleted portion of a as a paragraph that has been deleted from a word processing file). Virtual memory paging systems can leave traces of information on the storage medium that show what tasks and processes were recently active. Web browsers, e-mail programs, and chat programs store configuration information on the storage medium that can reveal information such as online nicknames and passwords. Operating systems can record additional information, such as the attachment of peripherals, the attachment of USB flash storage devices or other external storage media, and the times the computer was in use.'Computer file syStems can record information about the dates ?les were created and the sequence in which they were created, although this information can later be falsified. I i 93. As explained'herein, information stored within a computer and other electronic storage. media may provide crucial evidence of the "who, what, why, when, where, and how? of the criminal conduct under investigation, thus enabling the United States toestablish and prove . each element Or alternatively, to exclude the innocent from further suspicion. In my training and I experience, informationstored within a computer'or storage media registry information, communications, images and movies, transactional information, records of session times and durations, internet history, and anti-virus, spyware, and malware detection programs) can indicate whohas used or controlled the computer or storage media. This ?user attribution" evidence is analogous to the search for ?indicia of occupancy? while executing a'search warrant at a residence. 94. Necessity of seizing or copying entire computers or storage media. In most cases, a thorough search of a'premises for information that might be stored on storage media often requires the seizure of the physical storage media and later off?site review consistent with the warrant. In lieu of removing storage media from the premises, it is sometimes possible to make an image copy of storage media. Generally-speaking, imaging is the taking of a complete electronic picture of the computer's data, including all hidden sectors and deleted files. Either seizure or imaging is often necessary to ensure the aecuracy and completeness of data recorded on the storage media, and to prevent the loss of thedata either from accidental or intentional destruction. This is true because of the following: - 95. The time required for an examination. As noted above, not all evidence takes the form of documents-and files that can be easily viewed on site. Analyzing evidence of how a computer hasbeen used, what it has been used for, and who has used it requires considerable time, and taking that much time on premises could be unreasonable. As explained above, because the warrant calls for forensic electronic evidence, it is exceedingly likely that it will be necessary to thoroughly examine the storage media to obtain evidence. Storage media can store ?a - large volume of information. Reviewing that information for things described in the warrant can take weeks or months, depending on the volume of data stored, and would be impractical and invasive to attempt on-site. 96. Technical requirements. Computers can be con?gured in several different ways, featuring a variety of different operating systems, application software, and configurations. Therefore, searching them sometimes requires tools or knowledge that might not be present on the search site. The vast array of computer hardware and software available makes it dif?cult to know before a search what tools or knowledge will be required to analyze the system and its data on the premises. However, taking the storage media off?site and reviewing it in a controlled environment will allow its examination with the proper tools and knowledge. 97. Variety of forms of electronic media. Records and evidence sought under this warrant could be stored in a variety of storage media formats that may require off?site reviewing with specialized forensic tools. 98.? Nature of examination. Based on the foregoing, and consistent with Rule 41 the warrant sought would permit seizing, imaging, or otherwise copying storage media that reasonably appear to contain some or all of the evidence described in the warrant, and would authorize a later review of the media or information consistent with the warrant. The later review may require techniques, including but not limited to computer?assisted scans of the entire medium, that might expose many parts of a hard drive to human inspection in order todetermine whether it is evidence described by the warrant. CONCLUSION 99. 1 Based upon the above statements of fact, your Af?ant believes there is probable cause to show McNeil has made solicitations to commit a crime of violence, to wit, Title 18, Untied States Code, Section 1114, and/or Title 18, United States Code, Section 1389, in violation of Title 18, United States Code, Sections 373. 100. Based on the foregoing facts and circumstances, there is probable cause to believe that on the premises described above and in Attachment A, there is now concealed property, as set forth in Attachment B, that constitutes the fruits, instrumentalities,and evidence of the . violation of Title 18, United States Code, Section 373, Solicitation to Commit a Crime of Violence. Therefore, I respectfully request a search warrant be issued for the location identified in Attachment A, and to seize the items identi?ed in Attachment B. 101. This Court has jurisdiction to issue the requested warrant because it is ?a court of competentjurisdiction? as de?ned by 18 U.S.C. 2711. 18 U.S.C. 2703(a), Speci?cally, the Courtis ?a district court of the United States . . that has - jurisdiction over the offense being investigated.? 18 U.S.C. REQUEST FOR SEALING 102. I further request that the Court order that all papers in support of this application, including the af?davit and search warrant, be sealed until further order of the Court. These documents discuss an ongoing criminal investigation that is neither public nor known to all of the targets of the investigation. Accordingly, there is good cause to seal these documents because their premature disclosure may seriously jeopardize that investigation. Respectfully submitted, 4% Shawn S. Hare Special Agent Federal Bureau of Investigation Subscribed and sworn to before me on . I) 2015 . UNITED STATES MAGISTRATE JUDGE ATTACHMENT A Property to Be Searched 86 Eastgav Drive, Apartment C, Akron, Ohio 44313 The apartment located at 86 Eastgay Drive, Apartment C, Akron, Ohio 44313 and. further described as within a twoustory, red brick building, with attic space, and with an entrance facing north and an? entrance facing south. ATTACHMENT - Particular Things to be Seized Evidence of violation of Title 18, United States Code, Section 373, Solicitation to Commit a Crime of Violence, including the following: 1. All records relating to who created, used, or communicated with the social media accounts known to be utilized. by McNeil, including records about their identities and whereabouts 2. Communications, and other - ?from/to/in the possession of McNeil (to include, but not limited to, those between McNeil'and other individuals) regarding the conduct or incitement of violent jihad. in or outside the United States, against-its citizens, its military personnel,- and/or its interests; 3. - Communications, and other from/to/in possession of McNeil (to include, but not?limited to, those between McNeil and other individuals) regarding recruitment/pledge of allegiance to/membership of support for Islamic State in Iraq and Syria (ISIS), Islamic State in the Levant (ISIL), or the Islamic State 4. All??ags, banners, tapestries, wall coverings, plaques, photos, videos, literature, songs, movies, websites visited, and/or other artwork, as these'pertain to any of the matters described in the foregoing; 5. I Any communications or attempts to communicate with members ot?lSlL in the United States or other countries; 6. Any descriptions, plans, sketches, maps, drawings, photos, audio recordings, - videos, websites visited, and/or writings related to attacks to be committed in the United States or elsewhere; 7. Firearms and ammunition, including but not limited to handguns, pistols, revolvers, shotguns, machine-guns, assault ri?es, and other weapons, or parts/accessories associated therewith, and any records, receipts, or communications pertaining to ?rearms and I ammunition; I 8. Tactical knives and other bladed combat weapons to include, but not limited to, "machete" or "sword" style weapons, or parts/accessories associated therewith, and any records, receipts, or communications pertaining to these items; Holsters, sheathes, cases, boxes, bags, concealment shirts, and any other garments/items used to conceal, hold, transport ?rearms or knives or parts/accessories associated therewith, and any records, receipts, or communications pertaining to said items; 10. Tactical head coverings, including but not limited to ski-masks, shemaghs, and scarves and any records, receipts, or communications pertaining to said items; I 11. United States Currency in, excess of $500.00, precious metals and gems, gold coins, jewelry and financial instruments, including stocks and bonds, deeds of trust, sales contracts, vehicle instruments and artwork; 12. Books, records, receipts, bank statements and records, cancelled checks, money drafts, letters of credit, money orders and check receipts, passbooks and all other items evidencing the obtaining, secreting safety deposit keys and records], transfer and/or concealment of money; 13. Paper tickets, notices, vehicle rental receipts, hotel records, travel agency invoices and tickets, credit card receipts and invoices, travel schedules, records oflong distance telephone calls, passports or passport applications, and/or records and other items relating to domestic and foreign travel. Airline tickets, airline ticket stubs, travel agency invoices and frequent flyer account documents; 14?. Photographs, and/or photographic albums, negatives, video tapes, films, undeveloped film and the contents therein, slides, in particular of co?conspirators', assets, currency; 15. Address and/or telephone books and papers re?ecting names, addresses and/or telephone numbers including but not limited to, names of, addresses for, and/or telephone numbers of coconspirators, including the contents of memory of cellular telephones; 176. Paper(s) and documents that tend to establish the identities of persons in control of the premises; 17. identification cards, Passports, other identi?cation documents; 18. All cellular telephones maintained, controlled, utilized, or possessed by McNeil, and/or located at the property to be searched, to the extent that this is not addressed below; 19., Any and all electronic storage media. This includes information stored on computer hard drives (to include. desktop, laptop, and tablet computers), diskettes, tapes, USB drives, cellular telephones, video game consoles, or any other media capable of storing i information in a form readable by a computer. This" also includes all copies of the information described above that may be stored on such media as archivelor backup cepies. The agents searching for such information are authorized to search: a. Computer system hardware, including: word processing equipment, modems, personal digital assistants, printers, plotters, circuit boards, optical scanners, and other computer related devices, and software including ?oppy disks and any other medium which is capable of storing magnetic tape or optical coding, software programs, and any other programs, or software used to communicate with computer hardware peripherals either directly or indirectly via telephone lines, radio, or other means of transmission, computer manuals relating to the operation of a computer system, computer software, and/or any related device. b. The computer system hard drive and associated electronic storage media to include, but not limited to the following: ?oppy diskettes, optical disks, and other removable storage media, including the memory of cellular telephones capable of storing electronic information or accessing the Internet. c. If necessary, the agents are authorized to seize such computers and. electronic storage media and remove them from the premises fOr a suf?cient period of time to obtain access to, searchfor, and recover the files and review its contents off?site?. In addition, if the files and records cannot be read and understood without the software or programs that created those ?les or records, the agents are authorized te seize such software and any documentation and manuals that describe the softwareand give instructions on its'installation and use. The agents searching for such information are authorized to search: Any deSktop or other ?personal computer? or other electronic storage media (including cellular telephones) in the premises, to copy all of the above referenced information stored on such computer(s) or accessible through such computers, if connected to other computers through a network of camputers, and diskettes or tapes found in the premises. d. The search of such computers or storage areas of such computers shall be limited to permit seizure of information that meets the description of items through above. The agents are authorized to seize computers?and other electronic storage media (including cellular telephones) and remove them to a laboratory setting for a suf?cient period of time to obtain access to, search for, and recover the ?les and records described herein. In addition, if the ?les and records cannot be read and understood without the software or programs that created those files or records, the agents are authorized to seiZe such software and any documentation and manuals that describe the software and give instructions On its installation and use. e. For any computer or storage medium whose seizure is otherwise authorized by this warrant, and any computer or storage medium that contains or in which is stored records or information that is otherwise called for by this warrant (hereinafter, "Computer"): i. Evidence of who used, owned, or controlled the Computer at the time the things described in this Warrant were created, edited, or deleted, such as logs, registry entries, configuration ?les, saved usernarnes and passwords, documents, browsing history, user pro?les, email, email contacts, "chat," instant messaging logs, photographs, and correspondence. ii. Evidence of software that would allow others to control the Computer, such as viruses, Trojan horses, and other forms of malicious'software, I as well as evidence of the presence or absence of security software designed to detect malicious software. Evidence of the lack of such malicious software. iv. Evidence of the attachment to the Computer of other storage devices or similar containers for electronic evidence. 20. v. Evidence of counter-forensic programs (and associated data) that are designed to eliminate data from the Computer. I I vi. Evidence of the times the Computer was used. vii. Passwords, keys, and other access devices that may be necessary to access the Computer. Documentation and manuals that may be necessary to access the Computer or to conduct a forensic examination of the Computer. 2 ix. Records of or information about Internet Protocol addresses used by the Computer. x. Records of or information about the Computers Internet activity, including ?rewall logs, caches, browser history and cookies, "boolqnarked" or "favorite" web pages, search terms that the user entered into any Internet search engine, and records of user?typed web addresses; contextual information 1' necessary to understand the evidence described in this, attachment. Telephone call histories, telephone contact lists/address books, photographs, videos, text messages, e?mail communications, voicernail communications, search/browsing histories, IP logs, activity logs, written/printed communications, and/or any other records as these pertain to any of the matters referenced above. 21. Records of ?nancial transactions, including signature cards, bank statements, credit card statements, and wire transfer receipts. 22. Records related to internet service providers, including account statements and billing information. 23.? Records related to telephone service providers, including account statements and billing information.