3a

 

CRIMINAL COMPLAINT

A0 91 (Rev. 11/82)

 

 

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

 

DOCKET NO.

UNITED STATES OF AMERICA
V.

 

CASE NO.

ROBERT PAUL RUNDO, ROBERT BOMAN,
TYLER LAUBE, and AARON EASON

 

?_02791

 

 

 

Complaint for Violation of Title 18, United States Code, Sections 2101, 371

 

 

 

NAME OF MAGISTRATE JUDGE LOCATION
UNITED STATES . .
DATE OF OFFENSE PLACE OF OFFENSE ADDRESS OF ACCUSED (IF KNOWN)
March 25, 2017 February Los Angeles County
2018 .

 

 

 

STATEMENT OF FACTS CONSTITUTING THE OFFENSE OR VIOLATION:
[18 U.S.C. 2101, 371]

Between at least March 25, 2017, and February 12, 2018, in Los Angeles County, within the Central District of California, and
elsewhere, defendants ROBERT PAUL RUNDO, ROBERT BOMAN, TYLER LAUBE, and AARON EASON were part of an
agreement to use, and in fact used facilities of interstate or foreign commerce with intent to incite, organize, promote, encourage,
participate in, or carry on riots, or to commit acts of violence in furtherance of a riot, or to aid or abet any person in inciting or
participating in or carrying on a riot or committing any act of violence in furtherance of a riot, and during such use, performed or
attempted to perform an overt act for one or more of the purposes speci?ed above, in violation of Title 18, United States Code,
Sections 2101, 371.-

 

BASIS OF CHARGE AGAINST THE ACCUSED:

(See attached af?davit which is incorporated as part of this Complaint)

 

MATERIAL WITNESSES IN RELATION TO THIS CHARGE: 

 

. SIGNATURE OF COMPLAINANT
Belng duly sworn, I declare that the

 

 

foregoing is true and correct to the SCOTT BIERWIRTH

best of my knowledge. OFFICIAL TITLE . 
Speclal Agent, Federal Bureau of Investigation

 

 

 

Sworn to before me and subscribed in my presence,

 

SIGNATURE OF MAGISTRATE 7 . ,1 DATE

October 20, 2018

   

 

 

 

 

(1) See Federal Ruies of Criminal Procedure 3 and 54

AUSA David Ryan x4491 REC: Detention

AFFIDAVIT

I, SCOTT J. BIERWIRTH, being duly sworn, declare and state as

follows:
I. INTRODUCTION
1. I am a Special Agent with the Federal Bureau of
Investigation in Los Angeles, California and have been
so employed for approximately ten months. I am currently

assigned to a counter?terrorism squad, where I specialize in the
investigations of domestic terrorist groups. I attended 21
weeks of New Agent Training at the FBI Academy in Quantico,
Virginia. Prior to joining the FBI, I was an Infantry Officer
in the United States Army, where I trained for counter-terrorism
related missions across the globe for over four years.

2. Through my training and experience in the FBI and the
United States Army, I am familiar with terrorist organizations?
methods of operations, including their use of social media to
communicate regarding coordination of strategic ideological
goals, recruit and radicalize individuals, and coordinate
violent extremist activities and other criminal activities to

generate funds for the terrorist organization.

II. PURPOSE OF THE AFFIDAVIT

 

3. I make this affidavit in support of criminal
complaints and arrest warrants for Robert Rundo 
Robert Boman Tyler Laube and Aaron Eason
for violations of Title 18, United States Code,

Sections 2101 (Riots) and 371 (Conspiracy).

 

4. The facts set forth in this affidavit are based upon
my personal observations, my training and experience, and
information obtained.from other agents and witnesses. This
affidavit is intended to show merely that there is sufficient
probable cause for the requested complaints and warrants and
does not purport to set forth all of my knowledge of or
investigation into this matter. Unless specifically indicated
otherwise, all conversations and statements described in this
affidavit are related in substance and in part only with

original typographical errors and all dates are approximate.

SUMMARY OF PROBABLE CAUSE

 

5. As described more fully below, RUNDO, BOMAN, LAUBE,
and EASON (collectively, the ?defendants?) are members of the
?Rise Above Movement? a white supremacy extremist group
headquartered in Southern Galifornia. Throughout 2017, the
defendants and other RAM members traveled to political rallies,
including in Huntington Beach, California on March 25, 2017,
Berkeley, California on April 15, 2017, San Bernardino,
California on June 10, 2017, and Charlottesville, Virginia on
August 11?12, 2017. RAM members violently attacked and
assaulted counterwprotestors at each of these events.

6. On October 10, 2018, four RAM members were indicted in
the Western District of Virginia for Conspiracy to Riot and
Riots, in violation of 18 U.S.C. 371, 2101, as a result of

their participation in the events at Huntington Beach, Berkeley,

 

and Charlottesville, Virginia. See United States v. Daley et

 

al;, 3:18mCRm00025 (W.D. Va.).1

7. The defendants and other RAM members used facilities
of interstate commerce with the intent to organize, promote,
encourage, participate in, or carry on riots in at least two
ways. First, the defendants used the Internet to coordinate
combat training in preparation for the events, to arrange travel
to the events, to coordinate attendance at the events, and to
celebrate their acts of violence in order to recruit members for
future events. Second, the defendants and other RAM members

traveled to the April 15, 2017 event in Berkeley in a van that

EASON rented using his Visa credit card.

IV.STATEMENT OF PROBABLE CAUSE

 

8. Based on my training and experience, my personal
investigation into this matter, my conversations with other law
enforcement officers, and my review of open?source materials and
law enforcement reports, I know the following:

A. Background on RAM

9. RAM was founded in or around the winter of 2016?2017
by several founding members, including RUNDO and Ben Daley
(?Daley?). According to private Facebook messages sent by Daley

in or around June 2017, RAM was originally branded as the 

 

1 On October 2, 2018, United States Magistrate Judge Jean P.
Rosenbluth issued search warrants for the premises of several
RAM members, including RUNDO and BOMAN, in Case Numbers 
2592, and (C.D. Cal.). During those searches,
agents received physical evidence of RUNDO and 
participation in RAM, as well as several digital devices, which
are still being reviewed.

 

 but formally rebranded to the Rise Above Movement in
2017.2

10. RAM represents itself publicly, through videos and
other public online postings, as a combat?ready, militant group
of a new nationalist white supremacy/identity movement. For
example, RAM members maintained a Twitter account with the user
name ?@RiseAboveMvmt? (the Twitter account?), which posted
videos and pictures of RAM members conducting training in hande
to~hand combat, often interspersed with video clips of RAM
members assaulting people at political events, with their faces
partially obscured by distinctive skeleton or American flag
masks. RUNDO, BOMAN, and LAUBE appear in several of these
videos and photographs. The photographs below, posted by the
RAM twitter account, depict RUNDO and Daley training above the

words and several RAM members, with RUNDO front

and center, posing in skeleton masks.

 

 

2 I reviewed contents from Daley?s Facebook page pursuant
to a search warrant issued on April 4, 2018 from the Honorable
Joel C. Hoppe, United States Magistrate Judge, Western District
of Virginia, in Case Number (W.D. 

 

ll. Based on my review of private messages sent by the RAM
Twitter account, I believe the account was operated by RUNDO.
For example, on April 11, 2018, the RAM Twitter account sent a
direct message to another Twitter user stating, am going over
to Europe next week and will be competing in a pan European
[mixed martial arts] event.? Based on my review of Customs and
Border Protection records, law enforcement databases,
and subsequent interviews with RUNDO, I know that RUNDO traveled
to Europe in April 2018 and participated in a mixed martial arts
event.

12. The RAM Twitter account regularly posted content in
support of the group?s white supremacy extremist ideology. For
example, on February 5, 2018, the RAM Twitter account posted a
photograph of RAM members covering their faces with books with
the accompanying text, ?When the squads not out smashing commies

#nationalist #lifestyle.? On March 9, 2018, the RAM
Twitter account posted a photograph of RAM members posing with
?their faces partially covered with black skeleton masks and the
hashtags, ?#nationalist #ultraright.? On March 20, 2018, the
RAM Twitter account posted a photograph of a man doing physical
exercises next to a banner depicting one person kicking another
and the text, NIGHT LEFT appearing to endorse the
use of physical violence against others who do not share 
?ultraright? ideology.

13. Based on my review of private social media
communications between RAM members, I know that RAM leaders

discourage RAM members from using explicitly violent or

5

 

extremist language in public social media postings in order to
avoid generating unwanted attention or dissuading potential
recruits. For example, in private Facebook messages on August
25, 2017, an associate of Daley?s complimented Daley on a recent
RAM promotional video and said he was interested in getting
involved with RAM. Daley wrote, ?Yeah man. If your still in LA
area it?ll probably be me meeting up with you. We go for the
implicit look so you?ll have to change your [style] up a bit
when your with us.? The associate responded, ?Yea that?s fine
can grow my hair out if need be, drop the boots and braces
look etc.? Daley responded with an image of an symbol, and
stated, ?Trust I did it for a long time too but ultimately the
808 in that style of nationalism proved to be ineffective.
think its time to reimagine the nationalist look and
playbook, we have become predictable that needs to change.? In
January 2018, in private Facebook messages to another associate,
Daley wrote: would be mindful of saying anything that could
be misconstrued as a call to violence. I know people who
literally have had feds show up at there door over posts. [J]ust
food for thought. Trust I?m not speaking in terms of morality
rather practicality.?

l4. Notwithstanding Daley?s admonishment, RAM and its
members documented their white supremacy extremist ideology in
both private and public Internet postings. In a video taken by
a RAM associate, later posted online, the RAM associate asked
RUNDO to say the ?14 words.? Based on my training and

experience, I know that ?14 words? refers to a slogan commonly

6

 

known and used by white supremacy extremists and neo?Nazis that
states: ?We must secure the existence of our people and a future
for white children.? RUNDO responded, ?I?m a big supporter of
the fourteen, I?ll say that.?

15. RAM members also used graffiti to promote their white
supremacist ideology. On January 12, 2018, law enforcement
officers took photographs of graffiti in the Aqua Chinon Wash
Tunnel in Irvine, California, where RAM members have posted
videos of the group conducting physical training exercises. The
photographs showed the words and written in
yellow spray paint inside the tunnel, as well as a Celtic cross
with the number ?14? over the top in black spray paint. As
discussed above, the number ?14? is commonly used among white
supremacy extremists and neo?Nazis to refer to the ?14 words.?
Based on my training and experience, I know that the image of
the Celtic cross, combined with the number 14, is commonly used
by white supremacy extremists and neo?Nazis to express their
ideology.

16. In the Spring of 2018, according to reports of
interviews conducted by Customs and Border Protection officers
as well as public posts on social media accounts of RAM and
several of its members, several RAM members, including RUNDO,
Daley, and Michael Miselis (?Miselis?) traveled to Germany,
Ukraine, and Italy to celebrate Adolf Hitler?s birthday and meet
with members of European white supremacy extremist groups,
including a group known as White?Rex. Shortly after that trip,

the RAMmaffiliated clothing company Right Brand Clothing, of

7

 

which RUNDO is the registered owner, posted several photographs
on its Instagram page of RUNDO and other RAM members in Germany,
Ukraine, and Italy, slap?tagging stickers on various buildings
and poles with the RAM logo and the words ARE NOT
WELCOME and AGAINST MODERN
. . . RIGHT RAM members also
posted online a video showing Daley in the Ukraine performing a
salute known to be associated with the western Hammerskins, a
well?established violent white supremacy extremist group that is
associated with RAM, and of which Daley was a member before co?
founding RAM.

17. xOn August 1, 2018, an Instagram user ?tagged? Right
Brand Clothing?s account in a post containing a photograph of
RAM members during their trip to Germany, Ukraine, and Italy
meeting with Olena Semenyaka, the leader of the International
Department for the National Corps, which is a political party in
the Ukraine that was founded in 2016 out of a regiment of the
Ukranian military called the Azov Battalion. Based on my
training and experience, I know that the Azov Battalion is a
paramilitary unit of the Ukranian National Guard which is known
for its association with neo?Nazi ideology and use of Nazi
symbolism, and which is believed to have participated in
training and radicalizing United States?based white supremacy
organizations. The text associated with the post stated,
it was an honor to meet the singer and patriot

from #8l8th #nationalist #blackmetal #ukraine #antiantifa.?

 

B. March 25, 2017: RUNDO, BOMAN, LAUBE, and Other RAM
Members Attacked Counter-Protestors at a Political
Rally in Huntington Beach, California

18. Based on my review of law enforcement reports, videos
and photographs posted online, and public and private
communications between RAM members, I know that groups of RAM
members have attended public rallies together, acted in concert
to commit acts of violence, and planned such acts in advance
using the Internet.

19. For example, I reviewed a recording of a December 2016
RAM group phone call in which Daley shared strategic plan
to attend rallies in 2017 in order to provide ?security.? Based
on my training and experience, evidence gathered in this
investigation, and the context of this discussion, Daley and the
RAM group, who had no official role in the rallies they planned
to attend, appeared to be discussing appearing as security
personnel at the rallies so they could be prepared to engage in
violent confrontations that may erupt at the rallies. On the
call, Daley instructed listeners to wear specific clothing, such
as polo?style shirts and khakis, to get military style haircuts,
and to maintain an organized presence at the events.

20. On March 25, 2017, at least several hundred people
attended a ?Make America Great Again? rally at the Bolsa Chica
State Beach in Huntington Beach, California. The rally, and the
violence that ensued, were captured on video by numerous
journalists and participants. Throughout the morning, the

attendees engaged in various activities, including chanting and

 

making speeches. As those activities were ongoing, a small
group of counter?protestors gathered nearby on the beach.

21. Videos uploaded online show hundreds of rally
attendees marching south along the beach. At the same time, to
the north of the marchers, videos show a small group of rally
attendees, including several RAM members carrying signs that
read and ?Da Goyim Know,? did not march south,
but instead confronted the counter?protestors. Based on my
training and experience, I know that the phrase ?da goyim know?
is commonly used by white supremacist extremists to refer to
their supposed knowledge of a Jewish conspiracy to control world
affairs.

22.. Videos show several rally attendees confronting,
pushing, and then punching two journaliSts from a local news
publication. As the journalist stumbled backward, LAUBE grabbed
the journalist?s shoulder with his left hand, and punched him
three times in the face. A counter?protestor then released
pepper spray, leading the crowd to momentarily disperse. LAUBE

is depicted assaulting the journalist in the screenshot below.

 

 

23. Videos show a group of approximately three to five
counter?protestors then turned away from the group of rally
attendees and walked north along the beach while a small group,
led by RUNDO, BOMAN, LAUBE, Daley, and other RAM members pursued
them.

24. Approximately 20 seconds later, Videos Show that BOMAN
caught up to one of the counter?protestors and kicked him in the

back, as depicted below.

 

25. A second counter?protestor turned and approached
Daley, who shoved the counter?protestor in response. The
counter?protestors continued walking north away from the RAM
members, as the RAM members continued pursuing them. Another
rally attendee walking alongside the RAM members approached one
of the counter?protestors and punched him in the face, knocking

him to the ground.

11

 

26. Seconds later, videos show RUNDO approached another of
the counter?protestors from behind and punched him in the back
of the head. BOMAN ran up behind RUNDO toward the counter~
protestor, but turned back after a second counter?protestor
released pepper spray. RUNDO then turned to the second counter~
protestor, punched him in the back of the head, grabbed the back
of his neck, and threw him to the ground, landing on top of him.
RUNDO then held the counter-protestor down with his left hand
and threw several punches at the counter?protestor?s head while
other RAM members looked on, cheered, and prevented others from

intervening, as depicted in the screenshot below.

 

Jam?

27. After several seconds, video shows the counter?
protestor released pepper spray, leading RUNDO to back away from
him. The counter?protestor then ran northeast from the beach
into a parking lot, while other rally attendees pursued him,

pushing him and hitting him with flag poles. According to

12

 

eyewitnesses, another RAM member pursued the counter?protester
and threw a large rock at him, striking him in the chest.

28. During and after these violent confrontations, videos
show the majority of the rally attendees continued peacefully
marching south down the beach, while RUNDO, BOMAN, LAUBE, Daley,
and other RAM members, remained in the same area with a group of
other rally attendees. Approximately 20 minutes later,
approximately five countereprotestors arrived at the beach near
where the location where the RAM members remained gathered. The
RAM members, including RUNDO, BOMAN, LAUBE, and Daley, led a
group of 15?20 men who pursued the counter?protestors for over a
minute as the counter?protestors walked north along and the

beach to the parking lot.

C. MarchmApril 2017: RAM Members Celebrated Their
Assaults at Huntington Beach and Prepared for Berkeley

29. Based on my review of the contents of Daley?s cell
phone, I know that later on March 25, 2017, Daley sent a text
message to another RAM member, stating, ?Front page of the
stormer we did it fam.? Based on my training and experience, I
know that the ?Daily Stormer? is a news website and online
community forum that is well known among neo?Nazis and white
supremacy extremists, which published an article after the
Huntington Beach event titled ?Trumpenkriegers Physically Remove

Antifa Homos in Huntington Beach.?3 Based on my review of the

 

3 Based on my training and experience, know that
?Trumpenkriegers? is intended to mean ?Fighters for Trump.?
?Physical removal? is a term commonly used by white supremacy
extremists to refer to the goal of separating or ?physically

13

 

contents of Facebook account, I know that BOMAN posted
the Daily Stormer article on his Facebook page, along with the
comment, ?We did it fam.?4

30. I reviewed photographs of the Huntington Beach rally
published on the Internet. One image, which appears to have
been posted by the DIY Division?s Instagram account, depicts
RUNDO punching a counter?protestor, with the words ?Physical
Removal? superimposed across the top. That image is depicted

below.

 

31. The RAM Twitter account later posted a picture of RAM
members, including RUNDO, BOMAN, and Daley, at the Huntington
Beach rally, standing behind a sign stating ?Defend America,?

with the accompanying text, ?Shortly after this pic antifa was

 

removing? those with viewpoints or lifestyles that are viewed as
undesirable.

4 I reviewed contents from Facebook page pursuant to
a search warrant issued on September 4, 2018 from the Honorable
Paul L. Abrams, United States Magistrate Judge, Central District
of California, in Case Number (C.D. Cal.).

14

 

btfo in Huntington Beach.? Based on my training and experience,
I know that stands for ?Blown The Fuck Out.?

32. Based on my review of the contents of Miselis?s cell
phone, I know that, on March 27, 2017, EASON sent a text message
to Miselis, who appears to have first been introduced to the
other RAM members at the Huntington Beach rally, inviting him to
the rally in Berkeley on April 15, 2017. EASON wrote, ?It?s
Aaron from the HB rally. I wanted to let you know that the
organizers of the free speech rally at Berkeley on April 15 are
paying for rooms for our guys. . . . We?re expecting about 15
solid guys in our caravan coming up from So Cal and we can
accomodate as many as you can give. Quality only of course. If
you have good people who aren?t cut out for security, the
organiziers are looking for people to fill roles like
photography. Anyone who doesn?t come will wish they had. Oh and
we have hand to hand and formation fighting training in San
Clemente this Saturday. It?s not required, but we?d like to get
everyone we can there.?

33. Later on March 27, 2017, Daley wrote to Miselis to
invite him to the Berkeley rally, and Miselis replied, ?Right
on, Aaron from the rally mentioned some folks were going up.
I?ll drop the line on our end and see if anyone else can make
it.? Daley replied, ?Preciate we need all heads we can get.?

34. On March 29, 2017, EASON wrote to MISELIS again,
stating, ?Training is a go. Saturday at 11 am. Marblehead
Park, San Clemente. . . . we?ll probably have equipment for

shield and stick training and our formation tactics ready.?

15

 

35. On April 12, 2017, Daley wrote to Miselis, ?Got a 11
van reserved for Friday.? Asking everyone to kick in 20 or 40.
Thinking of leaving around 1130. Does that time work for you??
Miselis replied, ?Absolutely.?

36. According to records received from Airport Van Rental,
on April 14, 2017, EASON rented a 12?15 passenger van for
$493.87, using a Visa credit card with account number ending in
0807. Photographs posted online show BOMAN, Daley, Miselis, and
other RAM members posing in front of the van following the event

in Berkeley on April 15, 2017.

D. April 15, 2017: RUNDO, BOMAN, EASON, and Other RAM
Mambers Attacked Counteerrotestors at a Political
Rally in Berkeley, California

37. On April 15, 2017, RUNDO, BOMAN, EASON, Daley, and
other RAM members attended a political rally at Martin Luther
King Jr. Civic Center Park in Berkeley, California. Videos
posted online also show RUNDO, BOMAN, EASON, and Daley standing
alongside other RAM members displaying a sign that stated
?Defend America? with their hands taped in the manner of a boxer
or mixed martial arts fighter, wearing grey and black athletic
shirts with their faces partially covered by the distinctive
skeleton masks shown in RAM training videos. Videos posted
online show that rally attendees and counter?protestors were
initially separated by orange fencing. After several minutes,
several RAM members crossed the orange fencing and assaulted
counter?protestors. In one video, ROMAN is shown punching a
counter?protestor in the face. In another video, BOMAN is shown

punching a person while holding the person down on the ground.

16

 

The images below depict BOMAN at the Berkeley rally preparing to
fight with his hands taped and then BOMAN punching a counter?

protester while EASON, Miselis, and other RAM members stood

beside him.

   

38. In another video, another RAM member is shown
repeatedly punching a person while two unidentified people and a
second RAM member appear to hold the person down in a crouched
position. In another video, Miselis, Daley, and two other RAM
members are shown repeatedly kicking and punching a counter?
protestor who was crouching in a defensive position, until
police intervened and pushed them away. In another video, RUNDO
is shown.approaching a counter?protestor and punching him in the
side of the head.

39. Minutes later, after several RAM members and rally
attendees had crossed the orange fencing separating them from
the counter?protestors, RUNDO, BOMAN, EASON, Daley, Miselis
confronted several counter?protesters. Videos show RUNDO,
BOMAN, and Daley attempting to pull away a banner held by

several of the counter?protesters. After one of the counter?

17

 

protestors fell to the ground, Videos show RUNDO began throwing
punches at multiple different people, including one person who
was falling to the ground. According to Berkeley Police
Department officers, a BPD officer saw RUNDO punching
the apparently defenseless person in the head, and ordered RUNDO
to stop, but RUNDO did not respond. The BPD officer knocked
RUNDO to the ground to stop the ongoing assault, and RUNDO
punched the officer twice in the head before BPD officers
subdued and arrested him.

40. Several minutes later, EASON, Daley and other RAM
members and rally attendees pursued counter?protestors out of
the park through public streets, chanting ?hey, hey, hey,
Goodbye.? Videos show BOMAN confronting counter?protestors and
hitting a countermprotestor in the face. Videos show Daley
climbing over over a barricade separating protestors and
counter?protestors, kicking counter?protestors as they fall down
due to the falling barricade, and then chasing a counter?
protestor and kicking him in the back. Pictures posted online
from after the event show BOMAN, Daley, Miselis, and other RAM
members holding up in celebration the banner that they pulled

away from counterwprotestors during the rally.

E. April?August 2017: RAM MEmbers Celebrated Their
Assaults at Berkeley and Prepared for More Events

41. On April 16, 2017, the day after the Berkeley rally,
BOMAN posted a photograph on his Facebook page showing him
punching counterwprotestors at what appears to be the rally in

Berkeley the previous day. BOMAN then ?liked? the photograph on

18

 

Facebook. Another RAM member commented on the post, ?You can?t
like your own photo you idiot,? and BOMAN responded, 
you 

42. On April 16, 2017, BOMAN posted a photograph on his
Facebook page showing himself and fellow RAM members pulling
what appears to be a banner or poster away from counter?
protestors at the Berkeley rally.

43. On April 16, 2017, another RAM member sent a text
message to Miselis describing a Video showing Miselis at the
Berkeley event, and Miselis replied, ?Hell yeah man. I was
about to jump into that but our guys were just wrecking them,
like not even any room to get a hit in. was like alrite, 
guys got it handled then lol.?5 Later that day, Miselis sent
another text message describing how one of the guys ?up their
fighting with us . . . was pretty based too, apparently he hit
an antifa so hard he dislocated his shoulder.? Miselis wrote,
?I?ve been dealing with my hand all day. Just found a Video on
that site where you can see me breaking it on a guys head lol.?
The other RAM member responded, ?I?ve been looking at videos.
There?s a grey?shirted storm trooper at the fucking front every,
single, time. You guys were lions.? Miselis replied, ?Total
Aryan Victory.?

44. On April 21, 2017, EASON sent a text message to

Miselis asking if his broken hand was strong enough to attend

 

5 ?Lol? is an acronym meaning ?laugh out loud.?

19

 

another event at Berkeley on April 27, 2017, stating, ?I?m
driving up to deny antifa a face?saving victory.?

45. On May 15, 2017, the RAM Twitter account sent a
message to another Twitter user who had proposed interviewing
RAM leaders for a podcast. The RAM Twitter account replied,
?Maybe if there [is] enough time could mention berekly how we
were the first guys to jump over the barrier and engage and how
that had a huge impact.?

46. On June 1, 2017, Daley sent a private Facebook message"
to an associate stating that he and his group ?stole yevet
farlarkas banner at the April 15?lriots lol.? Daley?s associate
responded, ?That subhuman professor from CA. . . . She needs the
appearing to suggest that the professor should be
hanged. Daley responded, ?Yep lol.? The associate responded,
?My boy supposedly kicked her in the face.? Based on my review
of publicly available media accounts of the rally in Berkeley on
April 15, 2017, Yvette Felarca was a leader of a local group of
antifa counter?protesters who attended the rally.

47. In May 2017, BOMAN posted a picture on Facebook
showing himself and another RAM member boxing in a garage with
various white supremacist signs and banners posted on the walls.
One of the signs states, ?Da Goyim know,? and appears to be the
same sign BOMAN and other RAM members were photographed carrying
at the Huntington Beach rally in March 2017. Another of the
banners appears to be the same banner that Daley claimed he and
his associates stole from Yvette Felarca during the Berkeley

rally in April 2017.

20

 

48. On August 10, 2017, BOMAN posted a photograph on his
Facebook page showing himself punching a counter?protester.
Another Facebook user later commented on the photograph, in

Charlottesville?? BOMAN responded, ?Naw that was in Berkley.?

F. August 11~12, 2017: Other RAM Mmeers Committed
Violent Assaults at the Unite the Right Rally in
Charlottesville, Virginia

49. Based on my review of RAM members text messages and
Facebook communications, photographs and videos posted online,
and law enforcement reports, I know that, between April and
August 2017, RAM members engaged in regular combat training
sessions and attended additional political events where they
confronted counter?protesters and others who do not share their
ideology. For example, videos posted online show that, on June
10, 2017, RUNDO, Daley, and other RAM members attended an ?Anti?
Islamic Law? rally in San Bernardino, California, where they
engaged in violence against counter?protesters, leading to
arrests of three RAM members. On June 13, 2017, Daley wrote a
text message to an associate stating, ?We smashed some antifa as
they were leaving.? The associate responded, ?If it wasn?t for
the White Nationalists nothing would ever get done. Daley
replied, ?This is true would?ve been no victory in Huntington or
Berkeley.?

50. On August 12, 2017, several RAM members, including
Daley and Miselis, attended the ?Unite the Right? rally in
Charlottesville, Virginia. RAM members coordinated their
attendance at that rally in the previous months. For example, 1

reviewed a screenshot from a group chat on the chatroom hosting

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service Discord, from a subgroup labeled ?lodging_wanted? within
a group labeled ?Charlottesville in which a user named
?Ben Daley? stated on July 24, 2017, ?need room for at least
three Goys from CA. For Friday and Saturday night. Solid sober
respectful experienced at these events all were in Berkeley
riots. let me know.? Based on my training and experience
and facts learned in this investigation, I believe that in this
message, ?Ben Daley" was Offering his and his associates?
?experience? and presence at the ?Berkeley riots? as bona fides,
demonstrating his intent to travel to Charlottesville to create
another riot there, and seeking lodging amongst other white
supremacists willing to host ?Goys.?

51. I reviewed another statement posted using Discord, in
a chat subgroup labeled ?general_l,? within the ?Charlottesville
2.0? group, in which unknown users discussed whether the permit
for the Unite the Right rally had been revoked. After the users
confirmed that the permit had been renewed, user ?Ben Daley?
responded, ?Good stuff. Regardless we should all still go. 1m
flying out from CA with a handful regardless. Fuck these jews."

52. On July 25, 2017, RUNDO sent a text message to Miselis
stating, ?Hey, if you can get in touch with ben, I may have a
place for you guys to stay in Charlottesville.?

53. Videos uploaded to YouTube and published by
individuals and news organizations show Daley, Miselis, and
other RAM members at the rally in Charlottesville with their
hands taped in the manner of a boxer or mixed martial arts

fighter, committing multiple assaults against multiple victims.

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One video shows Daley approaching a man from behind as the man
stood still on the side of the street watching the protesters
march down the street. Daley raised his right hand and punched
the man in the back of the head, causing him to fall to the
ground. Daley then walked up to various counterwprotestors who
were standing in the path of the Unite the Right protestors,
punched some counter?protestors in the face, and threw others to

the ground.

G. August 2017-February 2018: RAM Members Celebrated
Their Assaults and Prepared for More Events

54. Based on my review of RAM members text messages and
Facebook communications, photographs and videos posted online,
and law enforcement reports, following the Charlottesville
event, RAM members continued to engage in regular combat
training sessions and post photographs and videos on social
media promoting their assaults at prior rallies. For example,
on September 14, 2017, the RAM Twitter account posted a picture.
of RUNDO and another RAM member assaulting counter?protestors at
the Berkeley rally, with the accompanying text: ?#antiantifa,
#goodnightleftsisde, #riseabovemovement.?

55. On September 25, 2017, EASON sent a text message to
Miselis stating, ?Im back in a position to go hard with
activism. I got sidetracked after Berkeley.? Miselis responded
that ?for the time being I think everyone is laying a little low
on account of [Charlottesville] fallout.?

56. In November 2017, RUNDO and Miselis exchanged several

text messages about creating a video promoting RAM. On December

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17, 2017, the ?Rise Above Movement" YouTube account posted a RAM
promotional video combining video of RUNDO, BOMAN, LAUBE, and
other RAM members assaulting counter?protestors with photographs
and video of RAM members training in hand?to?hand combat. Based
on my review of text messages between RUNDO and Miselis, in
which RUNDO described putting together a RAM promotional video
and the clips he was using for the video, I believe that RUNDO
orchestrated the creation of the video.

57. On January 10, 2018, the RAM Twitter account wrote,
?What?s up with giving a shoutout to the only alt right crew
that actually beats antifa senseless and wins rallies.?

58. On January 17, 2018, the RAM Twitter account wrote,
?From the guys that [won] very rally they ever attended and
always chased out antifa.?

59. On February 12, 2018, Daley sent a private Facebook
message to an associate stating, ?We?re not going be going to
rally?s for a few months cause we got a big trip planned but
definitely after that we?ll be back on the scene. Some good
scenes from the April 15 Berkeley riots halfway thru this
video.? The associate responded, ?i?ve never heard of you guys.
Just nationalists or white nationalists?? Daley responded,
?Huwhite. We were the only reason shit was popping off at socal
right wing events. Were not hostile to non whites we just do
our thing the way all other races do theirs. Didn?t want you
thinking I was just some lop critiquing from the sidelines lol.?

60. AS described above, RUNDO, BOMAN, LAUBE, and EASON

along with other RAM members, have used the Internet to prepare

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to incite and participate in violence at various political
events, have committed violent assaults while at those events,
and have applauded each other for it and publicly documented
their assaults in order to recruit more members to engage in
further assaults.
V2 CONCLUSION

61. Based on the foregoing, there is probable cause to

believe RUNDO, BOMAN, LAUBE, and EASON violated Title 18, United

nspiraey)- XIX
fir?

30

States Code, Sections 2101 (RiotsSCOTT J. Special Agent
Federal Bureau of Investigation

  


y? A
?we

Subscribed to and sworn
before me on October?g?z 2018

  

 

THE HONORABLE STEVE KIM
UNITED STATES MAGISTRATE JUDGE

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