Case: Doc 8 Filed: 05/03/12 1 of 2. PagelD 154 13 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO 7. EASTERN DIVISION . UNITED STATES OF AMERICA, INDICTMENT 1?37. . ?x ?tzfij? Plainti??, (3,113 13] c? . 23R 238 v. JUDGE DOUGLAS L. WRIGHT, BRANDON L. BAXTER, Title 18, United States Code, ANTHONY HAYNE, Sections 2332a(a)(2)(B) and (D), CONNOR C. STEVENS, and 844(i), and 2. JOSHUA STAFFORD, Defendants. JUD 0WD COUNT The Grand Jury charges that: From on or about February 20, 2012 to on or about April 30, 2012, in the Northern District of Ohio, Eastern Division, the defendants, DOUGLAS L. WRIGHT, BRANDON L. BAXTER, ANTHONY HAYNE, CONNOR C. STEVENS, and JOSHUA STAFFORD, acting without lawful authority, did knowingly conspire to use a weapon of mass destruction, speci?cally, a destructive device composed of two Improvised Explosive Devices (IEDs) containing plastic explosives, against property within the United States used in interstate commerce or in an activity that affects interstate commerce, namely the Brecksville-North?eld High Level Bridge, and the offense and the results of the offense would have affected interstate commerce. All in violation of Title 18, United States Code, Section 2332a(a)(2)(B) and (D). Case: Doc 8 Filed: 05/03/12 2 of 2. PagelD 155 2 COUNT 2 The Grand Jury further charges that: On or about April 30, 2012, in the Northern District of Ohio, Eastern Division, the defendants, DOUGLAS L. WRIGHT, BRANDON L. BAXTER, ANTHONY HAYNE, CONNOR C. STEVENS, and JOSHUA STAFFORD, acting without lawful authority, did knowingly attempt to use a weapon of mass destruction, speci?cally, a destructive device composed of two Improvised Explosive Devices (IEDs) containing 04 plastic explosives, against property within the United States used in interstate commerce or in an activity that affects interstate commerce, namely the Brecksville?North?eld High Level Bridge, and the offense and the results of the offense would have affected interstate commerce. All in violation of Title 18, United States Code, Sections 23323(a)(2)(B) and (D), and 2. COUNT 3 The Grand Jury further charges that: On or about April 30, 2012, in the Northern District of Ohio, Eastern Divsion, the defendants, DOUGLAS L. WRIGHT, BRANDON L. BAXT ER, ANTHONY HAYNE, CONNOR C. STEVENS, and JOSHUA STAFFORD, maliciously attempted to damage and destroy, by means of explosives, speci?cally, two Improvised Explosive Devices (IEDs) containing C-4 plastic explosives, real property used in interstate commerce, speci?cally the Brecksville-North?eld High Level Bridge, and aided and abetted each other to do the same. All in violation of Title 18, United States Code, Sections 844(i) and 2. A TRUE BILL. Original Document - Signatures on ?le with the Clerk of Courts, pursuant to the E-Government Act of 2002.