Case Document 14 Filed 01/04/18 Page 1 of 3 MCGREGOR W. SCOTT United States Attorney DAWRENCE W. RICE, .IR. - . CHRISTOPHER D. BAKER FE Assistant United States Attorneys 2500 Tulare Street, Suite 4401 _1 All 04 211111 Fresno, CA 93721 Telephone: (559) 497?4000 RR Facsimile: (559) 497-4099 eeunr Attorneys for Plaintiff United States of America IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, CASE NOLJO 3K0 Plaintiff, . VIOLATIONS: 18 U.S.C. 2339B(a)(l) and 2 v. Attempting to Provide Material Support and Resources to a Designated Foreign Terrorist EVERITT AARON JAMESON, Organization; 18 U.S.C. 842(p)(2)(A) Distribution of Information Relating to Destructive Defendant. Devices INDICTMENT COUNT ONE: 18 U.S.C. 2339B(a)(1) and 2 ?Attempting to Provide Material Support and Resources to 21 Designated Foreign Terrorist Organization The Grand Jury charges: I EVERITT AARON JAMESON, defendant herein, as follows: From on or around October 24, 20l 7,?through December 20, 2017, in Stanislaus County, within the State and Eastern District of California, and elsewhere, defendant EVERITT AARON JAMESON, a national of the United States, knowingly attempted to provide material support and resources, that is, personnel (namely himself) and services to a foreign terrorist organization, to wit, the Islamic State of Iraq and al?Sham (ISIS), which at all relevant times was designated by the Secretary of State as a foreign INDICTM ENT Case Document 14 Filed 01/04/18 Page 2 of 3 terrorist organization, knowing that 1S1S was a designated foreign terrorist organization and that 1S1S engages and has engaged in terrorist activity and terrorism, all in violation of Title 18, United States Code, Sections 2339B(a)(l) and 2. COUNT TWO: 18 U.S.C. 842(p)(2)(A) Distribution of Information Relating to Destructive Devices The Grand Jury further charges: EVERITT AARON JAMESON, defendant herein, as follows: On or around December 16, 2017, in Stanislaus County, within the State and Eastern District of California, and elsewhere, defendant EVERITT AARON JAMESON, did knowingly demonstrate the making and use of a ?destructive device? as de?ned in Title 18, United States Code, Section 921(a)(4), and distribute by any means information pertaining to, in whole or in part, the manufacture and use of a ?destructive device? as de?ned in Title 18, United States Code, Section 921(a)(4), with the intent that the information be used for, and in furtherance of, an activity that constitutes a Federal crime of violence, as de?ned in Title 18, United States Code, Section 16, including bombing of a place of public use, public transportation system, and infrastructure facility, in violation of Title 18, United States Code, Section 2332f, in that the defendant described to a person that he believed was working for a foreign terrorist organization (ISIS) that he was well versed with the Anarchist Cookbook, described how to build destructive devices, to wit, pipe bombs, out of PVC pipe, gunpowder, nails and described the location where he planned to assemble such destructive devices, asked for remote timing devices from the person that he believed was working for ISIS to use with such destructive devices, and described how to use such destructive devices in an attack on Pier 39 in San Francisco, California to funnel people into area in order to shoot them, all in violation of Title 18, United States Code, Section INDICTM ENT Case Document 14 Filed 01/04/18 Page 3 of 3 ?W?a?nm KIRK E.SHEHH1FF MW FOREPERSON KIRK E. SH ERRIFF Assistant United States Attorney Chief, Fresno Of?ce IN