UNITED STATES DISTRICT COURT EASTERN DISTRICT of TENNESSEE at CHATTANOOGA UNITED STATES OF AMERICA Judge Collier v. Magistrate Judge Lee ROBERT R. DOGGART SUPERSEDING INDICTMENT Solicitation to Commit a Civil Rights Violation The Grand Jury charges that, beginning in or about February, 2015, and continuing until in or about April, 2015, in the Eastern District of Tennessee and elsewhere, the defendant, ROBERT R. DOGGART, with the intent that another person or persons engage in conduct constituting a felony that has as an element the use, attempted use, and threatened use of physical force against the person and property of another in violation of the laws of the United States, and under circumstances strongly corroborative of that intent, did solicit, conunand, induce, and endeavor to persuade such other person and persons to engage in such conduct, that is, in and affecting interstate and foreign commerce, through the use, attempted use, and threatened use of a dangerous weapon, explosives, and fire, to intentionally damage and destroy religious real property, and attempt to do so, because of the religious character of that property, that is, a mosque in the state of New York; all in violation of Title 13, United States Code, Section 247(a)(1) and Title 18, United States Code, Section 373. Page 1 of3 Case Document 84 Filed 05/03/16 Page 1 of 3 PageID 437 COUNT TWO Solicitation to Commit Arson of a Building The Grand Jury charges that, beginning in or about February, 2015, and continuing until in or about April, 2015, in the Eastern District of Tennessee and elsewhere, the defendant, ROBERT R. DOGGART, with the intent that another person or persons engage in conduct constituting a felony that has as an element the use, attempted use, and threatened use of physical force against the person and property of another in violation of the laws of the United States, and under circumstances strongly corroborative of that intent, did solicit, command, induce and endeavor to persuade such other person and persons to engage in such conduct, that is, to maliciously damage and destroy, and attempt to damage and destroy, by means of ?re and explosive, any building and other real and personal property used in interstate and foreign conunerce, that is, a mosque in Hancock, New York; all in violation of Title 18, United States Code, Section 8446) and Title 18, United States Code, Section 373. Threat in Interstate Commerce The Grand Jury charges on or about March 22, 2015, in the Eastern District of Tennessee and elsewhere, the defendant, ROBERT R. DOGGART, through the use of a telephone and other instruments of interstate commerce, did willfully make a threat to kill, injure and intimidate any individual and to unlawfully damage and destroy a building and other real and personal property by means of ?re and an explosive; all in violation of Title 13, United States Code, Section 844(e). Page 2 of 3 Case Document 84 Filed 05/03/16 Page 2 of 3 PageID 438 COUNT FOUR Threat in Interstate Commerce The Grand Jury charges on or about April 9, 2015, in the Eastern District of Tennessee and elsewhere, the defendant, ROBERT R. DOGGART, through the use of a telephone and other instruments of interstate commerce, did willfully make a threat to kill, injure and intimidate any individual and to unlawfully damage and destroy a building and other real and personal property by means of ?re and an explosive; all in violation of Title 18, United States Code, Section 844(e). A TRUE BILL: JURY FOREPERSON NANCY STALLARD HARR Acting United States Attorney By: i/ Perry H. Piper l/ Assistant United States Attorney By: CV Saeed Mody Trial Attorney Civil Rights Division Page 3 of3 Case Document 84 Filed 05/03/16 Page 3 of 3 PageID 439 CRIMINAL CASE COVER SHEET U.S. OFFICE Place of Offense (City County): Chattanooga, Hamilton County, Tennessee Defendant Information: Juvenile Yes?L No Matter to be Sealed: Yes No Defendant Name: Robert R. Dogqart Interpreter: No Yes Language Total of Counts: Petty Misdemeanor (Class 1 Felony ORIGINAL Count(s) U.S.C. Citati9_n(s) and Description of Offense Charged Set 1 the intent that another person or persons engage in conduct constituting a felony that 1 has as an element the use. attempted use. and threatened use of physical force against the person and property of another in violation of the laws of the United States, and under circumstances strongly corroborative of that intent, did solicit. command, induce and endeavorto persuade such person or persons to engage in such conduct, that is, to damage and destroy religious property (a mosque), knowing the religious nature of the property, in the State of New York, in violation of Title 18, United States Code, Section 247, in violation of Title 18, United States Code, Section 373. Set 2 (Use tab key after enter? counts to create additional rows) SUPERSEDING INDICTMENT New count? New Count Old U.S.C. Citation(s) and Description of Offense or Count Charged if applicable! Set ?1 the intent that another person or persons engage in 1, 2 1 conduct constituting a felony that has as an element the use, attempted use, and threatened use of physical force against the person and property of another in violation of the laws of the United States, and under circumstances strongly corroborative of that intent, did solicit, command, induce and endeavorto persuade such person or persons to engage in such conduct, that is, to damage and destroy religious property (a mosque), knowing the religious nature of the property, in the State of New York, in violation of Title 18, United States Code, Section 247, in violation of Title 18, United States Code. Section 373. Set 2 through the use of a telephone and other instruments 3, 4 of interstate commerce, did willfully make a threat to kill, injure and intimidate any individual and to unlawfully damage and destroy a building and other real and personal property by means of ?re and an explosive; all in violation of Title 18, United States Code, Section 844?e2. (Use tab key after entering counts to create additional rows) Current Trial Date (if set): before Judge CLC Criminal Complaint Filed: No Yes Case No. Case Document 84-1 Filed 05/03/16 Page 1 of 2 PageID 440 Related Case(s): 1:15-cr-39 Bryan Hoss Case Number Defendant?s attorney How related Criminal Informations: Pending criminal case: No Yes Case No. New Separate Case Supersedes Pending Case Name of defendant?s attorney: Retained: Appointed: Date: 5/3/2016 Signature of AUSA: Case Document 84-1 Filed 05/03/16 Page 2 of 2 PageID 441