FILED IN UNITED STATES DISTRICT COURT DISTRICT OF UTAH JOHN W. HUBER United States Attorney (#7226) - OCT 0 5 2018 MARK VINCENT Assistant United States Attorney (#5357) BRYAN R. WHITTAKER, Assistant United States Attorney JONES CLERK Attorneys for the United States of America 111 South Main Street Suite 1800 Salt Lake City, Utah 84111 Telephone: (801) 524?5682 IN THE UNITED STATES DISTRICT COURT DISTRICT OF UTAH, NORTHERN DIVISION UNITED STATES OF AMERICA, Case No. Plaintiff, W. FELONY A I WILLIAM CLYDE ALLEN, Defendant. (Magistrate Judge Dustin B. Pead) Before Dustin B. Pead, United States Magistrate Judge for the District of Utah, appears the undersigned, who on oath deposes and says: COUNT 1 On or about September 24, 2018-, in the Northern Division of the District of Utah, WILLIAM CLYDE ALLEN, the defendant herein, did knowingly threaten to use a biological toXin, namely RICIN, as a weapon; all in Violation of 1.8 U.S.C. 175(a). COUNT 2 Between on or about September 24, 2018, through October 1, 2018, in the Northern Division of the District of Utah, WILLIAM CLYDE ALLEN, the defendant herein, did knowingly cause to be delivered by the Postal Service according to the directions thereon a communication, addressed to ?Pres Trump, The White House, 7 1600 Avenue, NW, Washington, DC 205 00,? who is President of the United States of America and an officer and. employee of the United States under 18 U.S.C. 1114, and containing a threat to injure President Donald J. Trump; all in violation of 18 U.S.C. 876(0). COUNT 37 Between on or about September 24, 2018, through October 1, 2018, in the Northern Division of the District of Utah, WILLIAM CLYDE ALLEN, the defendant herein, did knowingly cause to be delivered by the Postal Service according to the directions thereon a communication, addressed. to ?James N. Mattis, Secretary of Defense, 1000 Defense Pentagon, Washington, DC 20301?1000,? who is United States Secretary of Defense and an officer and employee of the United States under 18 U.S.C. 7 1114, and containing a threat to injure Secretary James N. Mattis; all in violation of 18 use. 876(c). COUNT 4 Between on or about September 24, 2018, through October 1, 2018, in the Northern Division of the District of Utah, WILLIAM CLYDE ALLEN, the defendant herein, did knowingly cause to be delivered by the POstal Service according to the directions thereon 'a communication, addressed to ?Admiral John M. Richardson, Chief of Naval Operations, 2000 Navy Pentagon, Washington, DC 20350?2000,? who is Chief of Naval Operations, United States Navy, and is an member of the uniformed services of the United States under 18 U.S.C. 1114, and containing a threat to injure . Admiral John M. Richardson; all in violation of 18 U.S.C. 876(0). COUNT 5 Between on or about September 24, 2018, through October 3, 2018,. in the Northern Division of the District of Utah, WILLIAM CLYDE ALLEN, the defendant herein, did knowingly cause to be delivered by the Postal Service according . to the directions thereon a communication, addressed to ?Christopher A. Wray, FBI Headquarters, 935 Ave. NW, Washington, DC 20535?0001,? who is Director of the Federal Bureau of Investigation, United States Department of Justice, and is an officer and employee of the United States under 18 U.S.C. 1114, and containing a threat to injure Director Christopher A. Wray; all in violation of 18 U.S.C. 876(c). AFFIDAVIT IN SUPPORT OF COMPLAINT AND ARREST WARRANT This Complaint is based on information obtained through an investigation consisting of the following: 1. I am a Special Agent with the Federal Bureau of Investigation and have been so employed since September 2011. I am currently assigned to the Salt Lake City Division and am charged with investigating acts 0 domestic terrorism. I am tasked with the investigation of federal criminal offenses, including the investigation of weapons of mass destruction which comprise, in part, biological agents, toxins, explosive devices, and related materials. During my law enforcement career, I have conducted investigations into violations of numerous federal laws that resulted in arrests, convictions, issuance of search authorities, and seizure of evidence. I have participated in the execution of numerous searchand seizure warrants for evidence associated with federal crimes. This affidavit is intended to Show only that there is sufficient probable cause for the arrest of William Clyde Allen, (hereinafter for violating 18 U.S.C. 175(a) (Knowingly Threaten To Use A Biological Toxin As A Weapon); and 18 U.S.C. 876(c) (Mailing Threatening Communications) and does not set forth all of my knowledge about this matter. 2. I am familiar with the facts and circumstances alleged in this complaint which are based on my (review of reports or statements made to me by other law enforcement officers. 3. 'On October 2018, I received information from FBI Headquarters (FBIHQ) that a letter had been sent to the President of the United States, Donald Trump. The envelope, stamped by the United States Postal Service on? September 24, 2018, contained the return address of WM ALLEN, 380 200 W, Logan, UT 84321. Law enforcement con?rmed that William Clyde Allen, (ALLEN resides .at 380 200 W, Logan, Utah, 8432l. The contents of the envelope included a note that read, ack and the Missile Bean Stock Powder.? Tin-addition, there appeared to be ground castor beans inside of the envelope. Preliminary field testing yielded a positive result for Ricin. Laboratory Response Network (LRN) testing confirmed the initial examination results later that. day. I confirmed through United States Secret Service Agents and the United States Postal Inspector?s Office that ALLEN currently resides at 380 200 W, Logan,- UT. I 4. Also on October 1, 2018, the Pentagon Mailing Facility received two letters from the same return?address as above. One letter was addressed to Secretary of Defense, James N. Mattis, and the other letter was addressed to Chief of Naval. Operations, Admiral John M. Richardson. Both letters contained small pieces of what appeared to be- castor beans and a note with the same message, ?Jack and the Missile Bean Stock Powder.? 5. On October 3, 2018, the FBI Mailing Facility discovered a letter addressed to FBI Director Christopher Wray. The return address on the envelope was. WM ALLEN 380 200 Logan, UT. The contents included a note identical to the ones addressed to President Trump, Secretary of Defense Mattis, and Admiral Richardson and particles consistent with ground castor beans. 6. On October 3, 2018, a FBI Laboratory Biologist informed me that the letters to the President and the Pentagon tested positive for Ricin as a result of two different examinations. The following day, the FBI Laboratory advised the fourth letter, addressed to FBI Director Wray, also tested positive for Ricin. A 7. In the past, ALLEN has issued numerous threats toward government officials. For example, in 2015, ALLEN sent an email to the CIA threatening to- kill the President if the Agency did not stop infringing On his Constitutional Rights. United States Secret Service Agents interviewed ALLEN at his Logan, UT residence regarding this threat. 8. Furthermore, ALLEN sent a bomb threat to Lacklanid Air Force Base, Bexar County, Texas, in February 2017 which read, have a bomb to kill your people.? Air Force Internal Affairs identified the email was sent from ?William Allen.? The internet protocol (IP) address associated with the email correspondence was traced back to the Salt Lake. City, Utah, area. Federal law enforcement officers interviewed ALLEN at his residence in Logan, Utah, regarding this incident. During the interview, ALLEN admitted to sending the threat from the ALLEN email address. 9. Additionally, on December 3, 2017, ALLEN used his acebook account to post a youtube.co.m video entitled, ?Extracting Cyanide from Apple Seeds with Hydraulic Press.? ALLEN commented, ?Don?t eat apple seeds.? 10. Finally, on September 26, 2018, ALLEN sent an email to Utah Department of Public Safety entitled, ?Multiple Imminent Radiation ALLEN included his name and phone number. Agents queried the number and confirmed it belonged to ALLEN 11. On October 3, 2018, federal law enforcement executed a search warrant on 380 N. 200. W. Logan, UT. During the search warrant, ALLEN was found to be alone in the residence. Agents escorted ALLEN off the property and into an unmarked FBI vehicle in front of his house. There, I read ALLEN his rights. ALLEN expressed understanding and stated he was Willing to answer questions at-that time. 12. During the interview, ALLEN was shown photographs of letters sent to President Trump, Secretary Mattis, Admiral Richardson, and Director Wray. ALLEN was also shown photographs of the aforementioned notes contained in each envelope. ALLEN explained he had sent thoseletters on or about September 24, 2018, from the post office near his house. ALLEN stated he had also placed a castor- bean in each envelope. ALLEN further informed he had sent other letters with the same contents to Attorney General Jeff Sessions, the Queen of England, Russian President Vladimir Putin, and the Secretary of the Air Force (whose name he did not recall). ALLEN said he sent the letters to send a mess-age. ALLEN did not elaborate with regards to the message he intended to convey. ALLEN said he had performed an Internet search of the mailing addresses for each recipient approximately an hour before sending the letters. 13. ALLEN explained castor beans contain a poison called Ricin. He (ALLEN stated he had researched Ricin on the Internet on one of his electronic devices at his residence. In addition, ALLEN advised he had purchased approximately 100? castor beans from eBay. ALLEN said he still had the package and the remaining castor beans in the basement of his residence. During the-search of the residence, FBI personnel found the package of caster beans as indicated by ALLEN When asked about the purpose of purchasing the caster beans, ALLEN said he wanted to have them in case World War broke out. ALLEN elaborated and stated he could make them useful, to bear arms, and to defend our nation. ALLEN believed he had not used any other castor beans, except the ones sent on or about September 24, 2018. 14. ALLEN provided written consent for the FBI to access and search his eBay account. ALLEN furnished me with his user name and password. On October 4, 2018, FBI personnel accessed ALLEN eBay account and searched the account?s purchases. We discovered that on December 3, 2017, ALLEN had made two purchases of castor beans in quantities of 100 and 30. 1 RICIN 15. Ricin is a toxin as defined in 18 U.S.C. 3? 178(2). Ricin is listed as a select agent by the United States Department of Health and Human Services.1 See 42 C.F.R. 73.3. Ricin .naturally exists in, and may be extracted from, the seeds of the castor bean plant (ricinus communis). The extraction of Ricin from these seeds is relatively easy and does not require technical expertise. Procedures and methods for this extraction are available from open sources on the Internet. 1 Select agents and toxins are a subset of biological agents and toxins that the Departments of Health and Human Services and Agriculture have determined to have the potential to pose a severe threat to public health and safety, to animal or plant health, or to animal or plant products. 16. Small doses of Ricin are lethal to human beings if ingested, inhaled, or injected. from poisoning from Ricin can include difficulty breathing, nausea, vomiting, and diarrhea, with possible death occurring within 36 to 72 hours. According to information posted by the Center for Disease Control on its website, there are no known antidotes for poisoning from Ricin. 17. Extracting the Ricin from the seeds of the plant may involve the use of milling and grinding equipment. In addition, solvents including but not limited to acetone, lye, chloroform and diethyl ether may be used for the extraction. Laboratory glassware is also equipment that is well-suited to the extraction and puri?cation processes involved in the manufacture and production of Ri'cin. I 18. Due to the risk of death posed by the inhalation of this toxin, the use of a respirator or other barrier to inhalation is critically important when handling Ricin in powder form. - CONCLUSION Based upon the foregoing, Affiant submits that there is probable causeto believe that William Clyde Allen, 111, has violated 18 U.S.C. 175(a), (Did Knowingly Threaten To Use A Biological Toxin, namely Ricin, As A Weapon) and 18 U.S.C. 876(c) (Mailing Threatening Communications). DATED this Saday of OCTOBER, 2018. v1. SUBSCRIBED AND SWORN TO before me this 7/ day of OCTOBER, 2018. AD, Magistrate Judge istri-ct Court REVIEWED JOHN W. HUBER United States Attorney MARK Assistant United States Attorney