'28 Case Document 1 Filed 10/24/18 Page 1 of 59 Page ID FEED UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, CR NOTE {j 3 3 r. v. [18 U.S.C. 371: Conspiracy; 18 U.S.C. 844(e): Conveying TYLER RAI BARRISS, False Information Concerning the aka Use of An Explosive Device; 18 aka ?Robert Hayward,? U.S.C. 875(c): Threats to Injure aka ?Robert,? in Interstate Commerce; 18 U.S.C. aka ?Alex Mendez,? 1349: Conspiracy to Commit Bank aka ?Alex Mendez,? Fraud; 18 U.S.C. 2: Aiding and aka ?Alex,? Abetting] aka ?Matthew, aka ?Aaron,? Defendant. The United States Attorney charges: INTRODUCTION At all times relevant to this Information: 1. Twitter was an online social networking service on which users post and interact with messages known as tweets. Twitter users could also send Direct Messages to one another. 2. A Twitter ?handle? was the name a user selected to use on Twitter. Case Document 11 Filed 10/24/18 Page 2 of 59 Page ID 3. Defendant TYLER RAI BARRISS, also known as aka ?Robert Hayward,? aka ?Robert,? aka ?Alex Mendez,? aka ?Alex,? aka ?Matthew,? aka ?AarOn,? resided in, and was located in, Los Angeles County within the Central District of California. Defendant BARRISS used the Twitter handle 4. Unindicted Co?Conspirator No. resided in, and was located in, Des Plaines, Illinois. Unindicted Co?Conspirator No. 1 used the Twitter handle 5. Unindicted Co?Conspirator No. 2 resided in, and was located in, Gulf Breeze, Florida. Unindicted Co?Conspirator No. 2 used the Twitter handle 6. Unindicted Co?Conspirator No. 3 resided in, and was located in, Grand Rapids, Michigan. ,Unindicted Co-Conspirator No. 3 used the Twitter handle 7. Unindicted Co?Conspirator No. 4 resided in, and was located in, Greenwood, Missouri. Unindicted Co-Conspirator No. 4 used the Twitter handle 8. Waukesha State Bank was a financial institution insured by the Federal Deposit Insurance Corporation. 9. ?Swatting? was the action or practice of harassing a victim by deceiving an emergency service into sending police and emergency service response teams to the victim's address often by making a false report of a serious law enforcement emergency such as a murder or hostage situation at the victim?s address to trigger the deployment of the response team. Case Document 11 Filed 10/24/18 Page 3 of 59 Page ID COUNT ONE [18 U.S.C. 844(e)] On or about September 24, 2015, in Los Angeles County, within the Central District of California, defendant TYLER RAI BARRISS, also known as aka ?Robert Hayward,? aka ?Robert,? aka ?Alex Mendez,? aka ?Alex,? aka ?Matthew,? aka ?Aaron,? by a telephone and other instrument of commerce, willfully made a threat, and maliciously conveyed false information knowing the information to be false, to the Beaver Creek Police Department in Beaver Creek, Ohio, concerning an alleged attempt being made, or to be made, to kill, injure, and intimidate an individual and to damage and destroy property by means of fire and an explosive, namely, and in substance and effect, that bombs were planted at a high school in Beaver Creek and that those bombs were set to explode. Case Document 1? Filed 10/24/18 Page 4 of 59 Page ID COUNT TWO [18 U.S.C. 844(6)] On or about September 29, 2015, in Los Angeles County, within the Central District of California, defendant TYLER RAI BARRISS, also known as aka ?Robert Hayward,? aka ?Robert,? aka ?Alex Mendez,? aka ?Alex,? aka ?Matthew,? aka ?Aaron,? by a telephone and other instrument of commerce, willfully made a threat, and maliciously conveyed false information knowing the information to be false, to the Keene Police Department in Keene, New Hampshire, concerning an alleged attempt being made, or to be made, to kill, injure, and intimidate an individual and to damage and destroy property by means of fire and an explosive, namely, and in substance and effect, that bombs were planted at a high school in Keene and that those bombs were set to explode. Case Document 1 Filed 10/24/18 Page 5 of 59 Page ID COUNT THREE [18 U.S.C. 844(e)] On or about late September 2015, in Los Angeles County, within the Central District of California, defendant TYLER RAI BARRISS, also known as aka ?Robert Hayward,? aka ?Robert,? aka ?Alex Mendez,? aka ?Alex,? aka ?Matthew,? aka ?Aaron," by a telephone and other instrument of commerce, willfully made a threat, and maliciously conveyed false information knowing the information to be false, to the Clark County School District Police Department in Henderson, Nevada, concerning an alleged attempt being made, or to be made, to kill, injure, and intimidate an individual and to damage and destroy property by means of fire and an explosive, namely, and in substance and effect, that bombs were planted at a school and that those bombs were set to explode. Case Document 1? Filed 10/24/18 Page 6 of 59 Page ID COUNT FOUR [18 U.S.C. On or about October 1, 2015, in Los Angeles County, within the Central District of California, defendant TYLER RAI BARRISS, also known as aka ?Robert Hayward," aka ?Robert,? aka ?Alex Mendez,? aka ?Alex,? aka ?Matthew,? aka ?Aaron,? with the purpose of issuing a threat and with knowledge that the communication would be viewed as a threat, knowingly transmitted in interstate commerce to the Ipswich Police Department in Ipswich, Massachusetts, a communication containing true threats to injure the person of another, namely, and in substance and effect, that he had murdered his girlfriend and intended to go to the Ipswich Police Department to kill officers and himself. Case Document 1 Filed 10/24/18 ,Page 7 of 59 Page ID COUNT FIVE [18 U.S.C. 844(e)] On or about October 5, 2015, in Los Angeles County, within the Central District of California, defendant TYLER RAI BARRISS, also known as aka ?Robert Hayward,? aka ?Robert,? aka ?Alex Mendez,? aka ?Alex,? aka ?Matthew,? aka ?Aaron,? by a telephone and other instrument of commerce, willfully made a threat, and maliciously conveyed false information knowing the information to be false, to the DuPage University Police Department in Glen Ellyn, Illinois, concerning an alleged attempt being made, or to be made, to kill, injure, and intimidate an individual and to damage and destroy property by means of fire and an explosive, namely, and in substance and effect, that bombs were planted at a college in Glen Ellyn and that those bombs were set to explode. Case Document 1 Filed 10/24/18 ,Page 8 of 59 Page ID #38 COUNT [l8 U.S.C. 844(e)] On or about October 7, 2015, in Los Angeles County, within the Central District of California, defendant TYLER RAI BARRISS, also known as aka ?Robert Hayward,? aka ?Robert,? aka ?Alex Mendez,? aka ?Alex,? aka ?Matthew," aka ?Aaron,? by a telephone and other instrument of commerce, willfully made a threat, and maliciously conveyed false information knowing the information to be false, to the University of IllinoisMChicago Police Department in Chicago, Illinois, concerning an alleged attempt being made, or to be made, to kill, injure, and intimidate an individual and to damage and destroy property by means of fire and an explosive, namely, and in substance and effect, that bombs were planted in backpacks at a university in Chicago. Case Document 1 Filed 10/24/18 Page 9 of 59 Page ID COUNT SEVEN [l8 U.S.C. 844(e)] On or about October 8, 2015, in Los Angeles County, within the Central District of California, defendant TYLER RAI BARRISS, also known as aka ?Robert Hayward,? aka ?Robert,? aka ?Alex Mendez,? aka ?Alex,? aka ?Matthew,? aka ?Aaron,? by a telephone and other instrument of commerce, willfully made a threat, and maliciously conveyed false information knowing the information to be false, to the Northern Illinois University Police Department in Dekalb, Illinois, concerning an alleged attempt being made, or to be made, to kill, injure, and intimidate an individual and to damage and destroy property by means of fire and an explosive, namely, and in substance and effect, that bombs were planted at a university in Dekalb and that those bombs were set to explode. Case Document 1 Filed 10/24/18 Page 10 of 59 Page ID #:10 COUNT EIGHT [18 U.S.C. 875(c)] On or about September 26, 2017, in Los Angeles County, within the Central District of California, defendant TYLER RAI BARRISS, also known as aka ?Robert Hayward,? aka ?Robert," aka ?Alex Mendez,? aka ?Alex,? aka ?Matthew," aka ?Aaron,? with the purpose of issuing a threat and with knowledge that the communication would be viewed as a threat, knowingly transmitted in interstate commerce to the Washington Police Department in Washington, Illinois, a communication containing true threats to injure the person of another, namely, and in substance and effect, that he had just shot two people at a residence on South Elm Street in Washington and that he was armed with an assault rifle. 10 Case Document 1' Filed 10/24/18 Page 11 of 59 Page ID #:11 COUNT NINE [18 U.S.C. 844(8)] On or about September 26, 2017, in Los Angeles County, within the Central District of California, defendant TYLER RAI BARRISS, also known as aka ?Robert Hayward,? aka ?Robert," aka ?Alex Mendez,? aka ?Alex,? aka ?Matthew,? aka ?Aaron,? by a telephone and other instrument of commerce, willfully made a threat, and maliciously conveyed false information knowing the information to be false, to the Layton Police Department in Layton, Utah, concerning an alleged attempt being made, or to be made, to kill, injure, and intimidate an individual and to damage and destroy property by means of fire and an explosive, namely, and in substance and effect, that he had planted bombs at a shopping center in Layton and that those bombs were set to explode. 11 Case Document 1. Filecj 10/24/18 Page 12 of 59 Page ID #512 COUNT TEN [18 U.S.C. 844(e)] On or about September 27, 2017, in Los Angeles County, within the Central District of California, defendant TYLER RAI BARRISS, also known as aka ?Robert Hayward," aka ?Robert,? aka ?Alex Mendez,? aka ?Alex,? aka ?Matthew," aka ?Aaron,? by a telephone and other instrument of commerce, willfully made a threat, and maliciously conveyed false information knowing the information to be false, to the Peoria Police Department in Peoria, Illinois, concerning anaalleged attempt being made, or to be made, to kill, injure, and intimidate an individual and to damage and destroy property by means of fire and an explosive, namely, and in substance and effect, that he had planted bombs in backpacks throughout a high school, that those bombs were set to explode, and that he was at or near the high school, armed with a gun, and intended to open fire. 12 Case Document 11 Filed 10/24/18 Page 13 of 59 Page ID #313 COUNT ELEVEN [18 U.S.C. 844(e)] On or about September 28, 2017, in Los Angeles County, within the Central District of California, defendant TYLER RAI BARRISS, also known as aka ?Robert Hayward,? aka ?Robert,? aka ?Alex Mendez,? aka ?Alex,? aka ?Matthew,? aka ?Aaron,? by a telephone and other instrument of commerce, willfully made a threat, and maliciously conveyed false information knowing the information to be false, to the Richmond Police Department in Richmond, Virginia, concerning an alleged attempt being made, or to be made, to kill, injure, and intimidate an individual and to damage and destroy property by means of fire and an explosive, namely, and in substance and effect, that he had planted bombs in a building on West Broad Street in Richmond. 13 Case Document 1 Filed 10/24/18 Page 14 of 59 Page ID #314 COUNT TWELVE [18 U.S.C. 844(8)] On or about September 28, 2017, in Los Angeles County, within the Central District of California, defendant TYLER RAE BARRISS, also known as aka ?Robert Hayward,? aka ?Robert,? aka ?Alex Mendez,? aka ?Alex,? aka ?Matthew,? aka ?Aaron," by a telephone and other instrument of commerce, willfully made a threat, and maliciously conveyed false information knowing the information to be false, to the Arlington Police Department in Arlington, Virginia, concerning an alleged attempt being made, or to be made, to kill, injure, and intimidate an individual and to damage and destroy property by means of fire and an explosive, namely, and in substance and effect, that he had planted a bomb in a building on Wilson Boulevard in Arlington. 14 Case Document 1. Filed 10/24/18 Page 15 of 59 Page ID #515 COUNT THIRTEEN [18 U.S.C. 844(e)] On or about September 28, 2017, in Los Angeles County, within the Central District of California, defendant TYLER RAI BARRISS, also known as aka ?Robert Hayward,? aka ?Robert," aka ?Alex Mendez,? aka ?Alex,? aka ?Matthew,? aka ?Aaron,? by a telephone and other instrument of commerce, willfully made a threat, and maliciously conveyed false information knowing the information to be false, to the West University Place Police Department in West University Place, Texas, concerning an alleged attempt being made, or to be made, to kill, injure, and intimidate an individual and to damage and destroy property by means of fire and an explosive, namely, and in substance and effect, that bombs were planted in a building on Bissonnet Street in Houston and that those bombs were set to explode. 15 Case Document 1' Filed 10/24/18 Page 16 of 59 Page ID #:16 COUNT FOURTEEN [18 U.S.C. 844(8)] On or about September 29, 2017, in Los Angeles County, within the Central District of California, defendant TYLER RAI BARRISS, also known as aka ?Robert Hayward,? aka ?Robert,? aka ?Alex Mendez,? aka ?Alex,? aka ?Matthew,? aka ?Aaron,? by a telephone and other instrument of commerce, willfully made a threat, and maliciously conveyed false information knowing the information to be false, to a television station in Phoenix, Arizona, concerning an alleged attempt being made, or to be made, to kill, injure, and intimidate an individual and to damage and destroy property by means of fire and an explosive, namely, and in substance and effect, that he had planted a bomb inside a public works building on North 23rd Avenue in Phoenix and that the bomb was set to explode. l6 Case Document 1' Filed 10/24/18 Page 17 of 59 Page ID #:17 COUNT FIFTEEN [l8 U.S.C. 844(e)] On or about September 29, 2017, in Los Angeles County, within the Central District of California, defendant TYLER RAI BARRISS, also known as aka ?Robert Hayward," aka ?Robert,? aka ?Alex Mendez,? aka ?Alex,? aka ?Matthew,? aka ?Aaron,? by a telephone and other instrument of commerce, willfully made a threat, and maliciously conveyed false information knowing the information to be false, to the Allen Police Department in Allen, Texas, concerning an alleged attempt being made, or to be made, to kill, injure, and intimidate an indiyidual and to damage and destroy property by means of fire and an explosive, namely, and in Substance and effect, that he had planted bombs throughout a high school in Allen and that those bombs were set to explode. l7 Case Document 1 1 Filed. 10/24/18 Page 18 of 59 Page ID #:18 COUNT SIXTEEN [18 U.S.C. 844(8)] On or about September 29, 2017, in Los Angeles County, within the Central District of California, defendant TYLER RAI BARRISS, also known as aka ?Robert Hayward,? aka ?Robert," aka ?Alex Mendez,? aka ?Alex,? aka ?Matthew,? aka ?Aaron,? by a telephone and other instrument of commerce, willfully made a threat, and maliciously conveyed false information knowing the information to be false, to the Harvard University Police Department in Cambridge, Massachusetts, concerning an alleged attempt being made, or to be made, to kill, injure, and intimidate an individual and to damage and destroy property by means of fire and an explosive, namely, and in substance and effect, that he had planted bombs on a university campus and that the bombs were set to explode. 18 Case Document 1 Filed: 10/24/18 Rage 19 of 59 Page ID COUNT SEVENTEEN [18 U.S.C. 844(e)] On or about September 30,.2017, in Los Angeles County, within the Central District of California, defendant TYLER RAI BARRISS also known as aka ?Robert Hayward,? aka ?Robert,? aka ?Alex Mendez," aka ?Alex,? aka ?Matthew," aka ?Aaron,? by a telephone and other instrument of commerce, willfully made a threat, and maliciously conveyed false information knowing the information to be false, to a television station in Phoenix, Arizona, concerning an alleged attempt being made, or to be made, to kill, injure, and intimidate an individual and to damage and destroy property by means of fire and an explosive, namely, and in substance and effect, that he had planted bombs throughout a building located on West Adams Street in Phoenix and that those bombs were set to explode. 19 Case Document Filed 10/24/18 Page 20 of 59 Page ID #:20 COUNT EIGHTEEN [18 U.S.C. 844(e)] On or about September 30, 2017, in Los Angeles County, within the Central District of California, defendant TYLER RAI BARRISS, also known as aka ?Robert Hayward,? aka ?Robert,? aka ?Alex Mendez,? aka ?Alex,? aka ?Matthew,? aka ?Aaron," by a telephone and other instrument of commerce, willfully made a threat, and maliciously conveyed false information knowing the information to be false, to the Alexandria Police Department in Alexandria, Virginia, concerning an alleged attempt being made, or to be made, to kill, injure, and intimidate an individual and to damage and destroy property by means of fire and an explosive, namely, and in substance and effect, that he had planted bombs in a movie theater in 'Alexandria and that he was outside that theater armed with an assault rifle. 20 Case Document 1., Filed 10/24/18 Page 21 of 59 Page ID #521 COUNT NINETEEN [18 U.S.C. On or about September 30, 2017, in Los Angeles County, within the Central District of California, defendant TYLER RAI BARRISS, also known as aka ?Robert Hayward,? aka ?Robert,? aka ?Alex Mendez,? aka ?Alex,? aka ?Matthew,? aka ?Aaron,? with the purpose of issuing a threat and with knowledge that the communication would be viewed as a threat, knowingly transmitted in interstate commerce to Marion County Emergency Services in Marion County, Missouri, a communication containing true threats to injure the person of another, namely, and in substance and effect, that he had just shot two people and planned to burn down a residence on Whitaker Lane in New London, Missouri. 21 Case Document 1: Filed 10/24/18 Page 22 of 59 Page ID #:22 COUNT TWENTY [l8 U.S.C. 875(c)] On or about September 30, 2017, in Los Angeles County, within the Central District of California, defendant TYLER RA: BARRISS, also known as aka ?Robert Hayward,? aka ?Robert," aka ?Alex Mendez,? aka ?Alex,? aka ?Matthew,? aka ?Aaron,? with the purpose of issuing a threat and with knowledge that the communication would be viewed as a threat, knowingly transmitted in interstate commerce to Marion County Emergency Services in Marion County, Missouri, a communication containing true threats to injure the person of another, namely, and in substance and effect, that he had just shot two people at a residence on Walnut Street in Hannibal, Missouri. 22 Case Document 1: Filed 10/24/18 Page 23 of 59 Page ID #:23 COUNT [18 U.S.C. 844(8)] On or about October 2, 2017, in Los Angeles County, within the Central District of California, defendant TYLER RAI BARRISS also known as aka ?Robert Hayward,? aka ?Robert,? aka ?Alex Mendez,? aka ?Alex,? aka ?Matthew,? aka ?Aaron," by a telephone and other instrument of commerce, willfully made a threat, and maliciously conveyed false information knowing the information to be false, to Marion County Emergency Services in Marion County, Missouri, concerning an alleged attempt being made, or to be made, to kill, injure, and intimidate an individual and to damage and destroy property by means of fire and an explosive, namely, and in substance and effect, that he had planted bombs at a high school in Center, Missouri. 23 Case Document 11 Filed 10/24/18 Page 24 of 59 Page ID COUNT [18 U.S.C. 875(c)] On or about October 2, 2017, in Los Angeles County, within the Central District of California, defendant TYLER RAI BARRISS, also known as aka ?Robert Hayward,? aka ?Robert," aka ?Alex Mendez," aka ?Alex," aka ?Matthew,? aka ?Aaron,? with the purpose of issuing a threat and with knowledge that the communication would be viewed as a threat, knowingly transmitted in interstate commerce to the Las Vegas Police Department in Las Vegas, Nevada, a communication containing true threats to injure the person of another, namely, and in substance and effect, that he had shot his wife at a Las Vegas hotel and intended to shoot other hotel guests. 24 Case Document 1, Filed 10/24/18 Page 25 of 59 Page ID #:25 COUNT [18 U.S.C. 875(0)] On or about October 2, 2017, in Los Angeles County, within the Central District of California, defendant TYLER RAI BARRISS, also known as aka ?Robert Hayward,? aka ?Robert,? aka ?Alex Mendez,? aka ?Alex,? aka ?Matthew,? aka ?Aaron,? with_the purpose of issuing a threat and with knowledge that the communication would be viewed as a threat, knowingly transmitted in interstate commerce to the Washington Police Department in Washington, Illinois, a communication containing true threats to injure the person of another, namely, and in substance and effect, that he had just killed two people at a residence on South Wood Street in Washington, that he had an assault rifle, and that he would kill any law enforcement officer that approached the residence. 25 Case Document 1: Filed 10/24/18 Page 26 of 59 Page ID #726 COUNT [18 U.S.C. 844(e)] On or about October a, 2017, in Los Angeles County, within the Central District of California, defendant TYLER RAI BARRISS also known as aka ?Robert Hayward,? aka ?Robert,? aka ?Alex Mendez,? aka ?Alex,? aka ?Matthew,? aka ?Aaron,? by a telephone and other instrument of commerce, willfully made a threat, and maliciously conveyed false information knowing the information to be false, to emergency services in Ralls County, Missouri, concerning an alleged attempt being made, or to be made, to kill, injure, and intimidate an individual and to damage and destroy property by means of fire and an explosive, namely, and in substance and effect, that bombs were planted at a high school in Center, Missouri. 26 Case Document 1: Filed 10/24/18 Page 27 of 59 Page ID #327 COUNT TWENTY-FIVE [18 U.S.C. 844(8)] On or about November 2, 2017, in Los Angeles County, within the Central District of California, defendant TYLER RAI BARRISS, also known as aka ?Robert Hayward,? aka ?Robert," aka ?Alex Mendez,? aka ?Alex,? aka ?Matthew,? aka ?Aaron,? by a telephone and other instrument of commerce, willfully made a threat, and maliciously conveyed false information knowing the information to be false, to the West Virginia University Police Department in Morgantown, West Virginia, concerning an alleged attempt being made, or to be made, to kill, injure, and intimidate an individual and to damage and destroy property by means of fire and an explosive, namely, and in substance and effect, that he had planted bombs on a university campus, that he had an assault rifle, and that he intended to open fire on students. 27 Case Document 1, Filed 10/24/18 Page 28 of 59 Page ID #:28 COUNT TWENTY-SIX [18 U.S.C. 844(e)] On or about November 9, 2017, in Los Angeles County, within the Central District of California, defendant TYLER RAI BARRISS, also known as aka ?Robert Hayward,? aka ?Robert,? aka ?Alex Mendez,? aka ?Alex,? aka ?Matthew,? aka ?Aaron,? by a telephone and other instrument of commerce, willfully made a threat, and maliciously conveyed false information knowing the information to be false, to the Portland Police Department in Portland, Maine, concerning an alleged attempt being made, or to be made, to kill, injure, and intimidate an individual and to damage and destroy property by means of fire and an explosive, namely, and in substance and effect, that he had placed bombs around a television station in Portland. 28 Case Document 1' Filed 10/24/18 Page 29 of 59 Page ID #:29 COUNT [18 U.S.C. 844(8)] On or about November 10, 2017, in Los Angeles County, within the Central District of California, defendant TYLER RAI BARRISS, also known as aka ?Robert Hayward," aka ?Robert,? aka ?Alex Mendez,? aka ?Alex,? aka ?Matthew,? aka ?Aaron,? by a telephone and other instrument of commerce, willfully made a threat, and maliciously conveyed false information knowing the information to be false, to the Dedham Police Department in Dedham, Massachusetts, concerning an alleged attempt being made, or to be made, to kill, injure, and intimidate an individual and to damage and destroy property by means of fire and an explosive, namely, and in substance and effect, that he worked with the designated terrorist organization known as the Islamic State of Iraq and the Levant, also known as ISIS, that he had planted bombs on and around a television station located on Fox Drive in Dedham, and that the bombs were set to explode. 29 Case Document 1, Filed 10/24/18 Page 30 of 59 Page ID #:30 COUNT [18 U.S.C. 844(e)] On or about November 10, 2017, in Los Angeles County, within the Central District of California, defendant TYLER RAI BARRISS, also known as aka ?Robert Hayward,? aka ?Robert," aka ?Alex Mendez,? aka ?Alex,? aka ?Matthew,? aka ?Aaron,? by a telephone and other instrument of commerce, willfully made a threat, and maliciously conveyed false information knowing the information to be false, to the Chicago Police Department in Chicago, Illinois, concerning an alleged attempt being made, or to be made, to kill, injure, and intimidate an individual and to damage and destroy property by means of fire and an explosive, namely, and in substance and effect, that he was an agent of the designated foreign terrorist organization known as the Islamic State of Iraq and the Levant, otherwise known as ISIS, and that he had planted a bomb in a building on North State Street in Chicago. 30 Case Document 1? Filed 10/24/18 Page 31 of 59 Page ID #:31 COUNT [18 U.S.C. 844(e)] On or about November 11, 2017, in Los Angeles County, within the Central District of California, defendant TYLER RAI BARRISS, also known as aka ?Robert Hayward,? aka ?Robert," aka ?Alex Mendez,? aka ?Alex,? aka ?Matthew,? aka ?Aaron,? by a telephone and other instrument of commerce, willfully made a threat, and maliciously conveyed false information knowing the information to be false, to the Philadelphia Police Department in Philadelphia, concerning an alleged attempt being made, or to be made, to kill, injure, and intimidate an individual and to damage and destroy property by means of fire and an explosive, namely, and in substance and effect, that bombs were planted at a museum in Philadelphia. 31 Case Document 1, Filed 10/24/18 Rage 32 of 59 Page ID #:32 COUNT [18 U.S.C. 844(e)] On or about November 19, 2017, in Los Angeles County, within the Central District of California, defendant TYLER RAI BARRISS, also known as aka ?Robert Hayward," aka ?Robert,? aka ?Alex Mendez,? aka ?Alex,? aka ?Matthew," aka ?Aaron,? by a telephone and other instrument of commerce, willfully made a threat, and maliciously conveyed false information knowing the information to be false, to the Austin Police Department in Austin, Texas, concerning an alleged attempt being made, or to be made, to kill, injure, and intimidate an individual and to damage and destroy property by means of fire and an explosive, namely, and in substance and effect, that he had left backpacks containing dynamite at an apartment complex on Farm to Market Road in Austin and that the dynamite was set to explode. 32 Case Document 1 Filecj 10/24/18 Page 33 of 59 Page ID #:33 COUNT [18 U.S.C. 844(e)] On or about November 24, 2017, in Los Angeles County, within the Central District of California, defendant TYLER RAI BARRISS, also known as aka ?Robert Hayward,? aka ?Robert,? aka ?Alex Mendez,? aka ?Alex," aka ?Matthew,? aka ?Aaron,? by a telephone and other instrument of commerce, willfully made a threat, and maliciously conveyed false information knowing the information to be false, to the Bernalillo Police Department in Bernalillo, New Mexico, concerning an alleged attempt being made, or to be made, to kill, injure, and intimidate an individual and to damage and destroy property by means of fire and an explosive, namely, and in substance and effect, there were bombs planted at a shopping center in Bernalillo. '33 Case Document 1 Filed 10/24/18 Page 34 of 59 Page ID #:34 COUNT [18 U.S.C. On or about November 24, 2017, in Los Angeles County, within the Central District of California, defendant TYLER RAI BARRISS, also known as aka ?Robert Hayward,? aka ?Robert,? aka ?Alex Mendez,? aka ?Alex,? aka ?Matthew,? aka ?Aaron,? with the purpose of issuing a threat and with knowledge that the communication would be viewed as a threat, knowingly transmitted in interstate commerce to the Dallas Police Department in Dallas, Texas, a communication containing true threats to injure the person of another, namely, and in substance and effect, that he intended to engage in violent acts toward persons at a shopping center in Dallas. 34 Case Document 1 Filed 10/24/18 Page 35 of 59 Page ID #:35 COUNT THIRTY-THREE [18 U.S.C. 844(e)] On or about November 24, 2017, in Los Angeles County, within the Central District of California, defendant TYLER RAI BARRISS, also known as aka ?Robert Hayward,? aka ?Robert,? aka ?Alex Mendez,? aka ?Alex,? aka ?Matthew," aka ?Aaron,? by a telephone and other instrument of commerce, willfully made a threat, and maliciously conveyed false information knowing the information to be false, to the Nassau County Police Department in Nassau County, New York, concerning an alleged attempt being made, or to be made, to kill, injure, and intimidate an individual and to damage and destroy property by means of fire and an explosive, namely, and in substance and effect, that there were bombs at shopping center in Valley Stream, New York. 35 Case Document Filed 10/24/18 Page 36 of 59 Page ID #:36 COUNT [18 U.S.C. 844(e)] On or about November 24, 2017, in Los Angeles County, within the Central District of California, defendant TYLER RAI BARRISS, also known as aka ?Robert Hayward," aka ?Robert," aka ?Alex Mendez,? aka ?Alex,? aka ?Matthew,? aka ?Aaron,? by a telephone and other instrument of commerce, willfully made a threat, and maliciously conveyed false information knowing the information to be false, to the Michigan City Police Department in Michigan City, Indiana, concerning an alleged attempt being made, or to be made, to kill, injure, and intimidate an individual and to damage and destroy property by means of fire and an explosive, namely, and in substance and effect, that there were bombs at a Michigan City shopping center. 36 Case Document 10 Filed 10/24/18 Page 37 of 59 Page ID #:37 COUNT THIRTY-FIVE [18 U.S.C. 844(e)] On or about November 28, 2017, in Los Angeles County, within the Central District of California, defendant TYLER RAI BARRISS, also known as aka ?Robert Hayward,? aka ?Robert,? aka ?Alex Mendez,? aka ?Alex,? aka ?Matthew,? aka ?Aaron,? by a telephone and other instrument of commerce, willfully made a threat, and maliciously conveyed false information knowing the information to be false, to the Panama City Beach Police Department in Panama City Beach, Florida, concerning an alleged attempt being made, or to be made, to kill, injure, and intimidate an individual and to damage and destroy property by means of fire and an explosive, namely, and in substance and effect, that he had planted bombs at a high school in Panama City Beach, that the bombs were set to explode, and that he and another person were at the school, armed with guns. 37 Case Document 1: Filed 10/24/18 Page 38 of 59 Page ID #:38 COUNT [18 U.S.C. 844(e)] On or about November 28, 2017, in Los Angeles County, within the Central District of California, defendant TYLER RAI BARRISS, also known as aka ?Robert Hayward,? aka ?Robert," aka ?Alex Mendez,? aka ?Alex,? aka ?Matthew,? aka ?Aaron,? by a telephone and other instrument of commerce, willfully made a threat, and maliciously conveyed false information knowing the information to be false, to the Durand Area Schools in Durand, Michigan, concerning an alleged attempt being made, or to be made, to kill, injure, and intimidate an individual and to damage and destroy property by means of fire and an explosive, namely, and in substance and effect, that he had planted bombs at a high school and that those bombs were set to explode. 38 Case Document 1 Filed 10/24/18 Page 39 of 59 Page ID #:39 COUNT [18 U.S.C. 1349] A. THE OBJECT OF THE CONSPIRACY 1. Beginning on a date unknown to the Grand Jury, but no later than November 27, 2017, and continuing through on or about December 5, 2017, in Los Angeles County, within the Central District of California, and elsewhere, defendant TYLER RAI BARRISS also known as aka ?Robert Hayward,? aka ?Robert,? aka ?Alex Mendez,? aka ?Alex,? aka ?Matthew,? aka ?Aaron,? and Unindicted Co?Conspirator No. 1, together with others known and unknown to the Grand Jury, knowingly combined, conspired, and agreed to commit bank fraud, in violation of Title 18, United States Code, Section 1344(2). B. THE MANNER AND MEANS OF THE CONSPIRACY 2. The object of the conspiracy was to be carried out, and was carried out, in substance as follows: a. Unindicted COHConspirator No. 1 would obtain credit and debit card account numbers that he knew belonged to real persons; b. Unindicted Co?Conspirator No. 1 would use those unauthorized debit and credit card account numbers to purchase clothing and other items online for, and at the request of, defendant c. In purchasing those items, Unindicted Co?Conspirator No. 1 would falsely represent to online retailers that he was authorized to use those credit and debit card account numbers to make purchases, when, in fact, he was not authorized to do so. 39 Case Document 1: Filed 10/24/18 Page 40 of 59 Page ID #:40 C. OVERT ACTS 3. On or about the following dates, in furtherance of the conspiracy and to accomplish its objects, defendant BARRISS and Unindicted Co?Conspirator No. 1, together with other co?conspirators known and unknown to the Grand Jury, committed and caused others to commit various overt acts within the Central District of California and elsewhere, including the following: Overt Act No. 1: On or before November 27, 2017, Unindicted Co?Conspirator No. 1 opened an account with a virtual private network service provider (the Service?). Overt Act No. 2: On December 1, 2017, Unindicted Co? Conspirator No. 1 attempted to purchase a 1?month subscription to the VPN Service with a credit card number that he knew belonged to a real person and that he was not authorized to use. Overt Act No. 3: On or about December 2, 2017, in Twitter Direct Messages, defendant BARRISS asked Unindicted Co~Conspirator No. to purchase a cap bearing a NASA logo (the cap?) for defendant BARRISS. Overt Act No. 4: On or about December 3, 2017, in Twitter Direct Messages, defendant BARRISS again asked Unindicted Co~ Conspirator No. 1 to purchase the NASA cap for him. Unindicted Cos Conspirator No. 1 agreed to make the purchase after obtaining credit and debit card account numbers belonging to others that he knew he was not authorized to use. Overt Act No. 5: On December 3, 2017, and again on December 4, 2017, in Twitter Direct Messages, defendant BARRISS repeatedly insisted that Unindicted Co?Conspirator No. 1 purchase the 40 Case Document 1 Filed 10/24/18 Page 41 of 59 Page ID #:41 NASA cap for him and provided Unindicted Co?Conspirator No. with defendant mailing address in Los Angeles. Overt Act No. 6: On or before December 4, 2017, Unindicted Co?Conspirator No. 1 obtained a debit card account number (the ?Account Number?), which he knew belonged to Victim J.B., which was linked to her checking account at Waukesha State Bank. Overt Act No. 7: On or about December 4, 2017, Unindicted Conspirator No. 1 purchased the NASA cap from an online retailer, using the unauthorized Account Number. Unindicted Co?Conspirator No. 1 represented to the online retailer that he was authorized to use the Account Number to make the purchase when, in fact, he was not. Unindicted Co?Conspirator No. 1 provided the online retailer with defendant name and address in Los Angeles for shipping purposes. Overt Act No. 8: On or about December 4, 2017, defendant BARRISS told Unindicted Co?Conspirator No. 1 that he wanted him to purchase shoes for him. Overt Act No. 9: On or about December 4, 2017, Unindicted Co? Conspirator No. 1 purchased a l?month subscription to the VPN Service, using the Account Number, knowing that he was not authorized to use that Account Number. Overt Act No. 10: On or about December 5, 2017, in Twitter Direct Messages, defendant BARRISS told Unindicted Co~Conspirator No. 1 that he had received the NASA cap and was thankful for it. Overt Act No. 11: On or about December 6, 2017, in Twitter Direct Messages, defendant BARRISS told Unindicted C0wConspirator No. 1 that he wanted him to purchase shoes and a belt for him. He then directed Unindicted Co~Conspirator No. to a website and asked 41 Case Document 1 Filed 10/24/18 Page 42 of 59 Page ID #:42 him, ?Can you card which was coded language indicating his intent that Unindicted Co-Conspirator No. 1 use an unauthorized debit or card account number to make the purchase. Unindicted Co- Conspirator No. responded, ?yessir.? 42 Case Document 1 Filed 10/24/18 Page 43 of 59 Page ID #:43 COUNT THIRTY-EIGHT [18 U.S.C. 371] A. THE OBJECT OF THE CONSPIRACY 1. Beginning on a date unknown to the Grand Jury, but no later than December 4, 2017, and continuing through on or about December 6, 2017, in Los Angeles, within the Central District of California, and elsewhere, TYLER RAI BARRISS also known as aka ?Robert Hayward,? aka ?Robert,? aka ?Alex Mendez,? aka ?Alex,? aka ?Matthew,? aka ?Aaron,? and Unindicted Co~Conspirator No. 2, knowingly combined, conspired, confederated, and agreed to, by a telephone and instrument of commerce, willfully make a threat, and maliciously convey false information knowing the information to be false, concerning an alleged attempt being made, or to be made, to kill, injure, and intimidate an individual and to damage and destroy property by means of fire and an explosive, in violation of Title 18, United States Code, Section 844(e). B. THE MANNER AND MEANS OF THE CONSPIRACY 2. The object of the conspiracy was to be carried out, and was carried out, in substance as follows: a. Unidentified Co?Conspirator No. 2 would identify a school building that he wanted to evacuate while school was in session. b. Unidentified Co?Conspirator No. 2 would share information concerning that school with defendant BARRISS, to include its address. c. Defendant BARRISS would call the school and willfully and maliciously convey the false information that he had planted bombs at the school, knowing that information to be false. 43 Case Document 1 Filed 10/24/18 Page 44 of 59 Page ID #:44 d. Defendant BARRISS would call law enforcement and willfully and maliciously convey that he had planted bombs at the school, knowing that information to be false. C. OVERT ACTS 3. On or about the following dates, in furtherance of the conspiracy and to accomplish its object, defendant BARRISS, together with Unindicted Co-Conspirator No. 2 and other co?conspirators known and unknown to the Grand Jury, committed and caused others to commit various overt acts within the Central District of California and elsewhere, including the following: Overt Act No. 1: On or about December 4, 2017, Unindicted Co? Conspirator No. 2, in Twitter Direct Messages, asked defendant BARRISS to cause the evacuation of a high school in Gurnee, Illinois (the ?Gurnee High School?), and defendant BARRISS agreed. Overt Act No. 2: On or about December 5, 2017, defendant BARRISS and Unindicted Co-Conspirator No. 2 investigated the address and telephone number of the Gurnee High School, including by looking up that information online. Overt Act No. 3: On or about December 5, 2017, defendant BARRISS and Unindicted Co?Conspirator No. 2 investigated the address and telephone number for the Gurnee Police Department, including by looking up that information online. Overt Act No. 4: On or about December 5, 2017, defendant BARRISS called the Gurnee High School and told a secretary there, in substance and effect, that he left a backpack containing dynamite in the Gurnee High School and that it was set to explode. Overt Act No. 5: On or about December 5, 2017, defendant BARRISS called the Gurnee Police Department and told a communications 44 Case Document 1 Filed 10/24/18 Page 45 of 59 Page ID #:45 center operator that he had planted a bomb at the Gurnee High School and that the bomb was set to explode. Overt Act No. 6: On or about December 5, 2017, defendant BARRISS, in Twitter Direct Messages, told Unindicted Co?Conspirator No. 2 that he had taken steps to cause an evacuation of the Gurnee High School. Overt Act No. 7: On or about December 6, 2017, in Twitter Direct Messages, Unindicted Co?Conspirator No. 2 and defendant BARRISS agreed to try again to cause an evacuation of the Gurnee High School. Overt Act No. 8: On or about December 6, 2017, defendant BARRISS called the Gurnee High School and left a voicemail on a school line in which he said that he had planted a bomb at the school. Overt Act No. 9: On or about December 6, 2017, defendant BARRISS called the Gurnee Police Department and told a communications center operator that he left a backpack containing explosives in a classroom at the Gurnee High School, that the explosives were set to explode, that he was high on methamphetamine, that he was carrying a pistol, and that he was considering opening fire on students and teachers. 45 Case Document 1 Filed 10/24/18 Page 46 of 59 Page ID #:46 COUNT THIRTY-NINE [18 U.S.C. 371] A. THE OBJECT OF THE CONSPIRACY 1. Beginning on a date unknown to the Grand Jury, but no later than December 7, 2017, and continuing through on or about December 10, 2017, in Los Angeles, within the Central District of California, and elsewhere, TYLER RA: BARRISS also known as aka ?Robert Hayward,? aka ?Robert,? aka ?Alex Mendez,? aka ?Alex," aka ?Matthew,? aka ?Aaron," and Unindicted Co?Conspirator No. 1, knowingly combined, conspired, confederated, and agreed to, by a telephone and instrument of commerce, willfully make a threat, and maliciously convey false information knowing the information to be false, concerning an alleged attempt being made, or to be made, to kill, injure, and intimidate an individual and to damage and destroy property by means of fire and an explosive, in violation of Title 18, United States Code, Section 844(e). B. THE MANNER AND MEANS OF THE CONSPIRACY 2. The object of the conspiracy was to be carried out, and was carried out, in substance as follows: a. Unidentified Co?Conspirator No. and defendant BARRISS would identify a person or persons that they wanted to harass, intimidate, disrupt, and annoy either by swatting them or by causing them to be evacuated from their locations. b. Unidentified Co~Conspirator No. and defendant BARRISS would investigate their intended victims, to include identifying their victims? addresses and telephone numbers and the addresses and telephone numbers of law enforcement local to those victims. 46 10 1.1 12 13 14Case Document 1 Filed 10/24/18 Page 47 of 59 Page ID #:47 c. Defendant BARRISS would call law enforcement and maliciously convey false information, knowing that information to be false, and willfully make a threat, about explosives being present at the victim?s address to cause a law enforcement response. d. Defendant BARRISS would call the location where he believed the victim was then located and maliciously convey false information, knowing that information to be false, and willfully make a threat, about explosives being present at that location to cause its evacuation. C. OVERT ACTS 3. On or about the following dates, in furtherance of the conspiracy and to accomplish its object, defendant BARRISS, together with Unindicted Co?Conspirator No. 1 and other co?conspirators known and unknown to the Grand Jury, committed and caused others to commit various overt acts, among others, within the Central District of California, and elsewhere, including, but not limited to, the following: Overt Act No. 1: On or about December 7, 2017, in Twitter direct messages, Unindicted Co~Conspirator No. 1 asked defendant BARRISS to swat Victim R.S., and defendant BARRISS agreed. Overt Act No. 2: On or about December 7, 2017, in Twitter direct messages, Unindicted Co?Conspirator No. 1 provided defendant BARRISS with what he believed to be personal identification information for Victim R.S., including Victim home address. Overt Act No. 3: On or about December 7, 2017, defendant BARRISS called the Milford Police Department in Milford, Connecticut, identified himself as Victim R.S., and provided what he believed to be the home address of Victim R.S. He also maliciously conveyed the 47 Case Document 1 Filed 10/24/18 Page 48 of 59 Page ID #:48 false information, knowing that information to be false, and willfully made the threat, that he had shot his parents, that he had tied up his siblings and intended to kill them, and that he planned to burn down his house. Overt Act No. 4: On or about December 7, 2017, in Twitter direct messages, defendant BARRISS told Unindicted Co?Conspirator No. 1 that he had swatted Victim R.S. Overt Act No. 5: On or about December 8, 2017, in Twitter direct messages, Unindicted Co?Conspirator No. 1 provided defendant BARRISS with what he believed to be the address for a convention center in Dallas, Texas (the ?Convention Center"), where a video game tournament was then occurring. Overt Act No. 6: On or about December 8, 2017, in Twitter Direct Messages, Unindicted Co?Conspirator No. agreed to create, and did in fact create, an account with a voice?over?internet services provider for defendant BARRISS to use in making hoax phone calls to and concerning the Convention Center. Overt Act No. 7: On or about December 8, 2017, defendant BARRISS called both the Convention Center?s administrative line and a Crime Stoppers tip line and maliciously conveyed the false information, and willfully made the threat, that he left backpacks containing explosives in the Convention Center and that they were set to explode. Overt Act No. 8: On or about December 8, 2017, in Twitter direct messages, Unindicted Co?Conspirator No. 1 provided defendant BARRISS with information about the evacuation of the Convention Center in response to defendant knowingly false reports that he planted bombs there. 48 Case Document 1 Filed 10/24/18 Page 49 of 59 Page ID #:49 Overt Act No. 9: On or about December 10, 2017, defendant BARRISS called the Dallas Police Department and said that he and a friend had left backpacks containing explosives inside the Convention Center and that they were set to explode. Overt Act No. 10: On or about December 10, 2017, defendant BARRISS called the Convention Center?s administrative line and maliciously conveyed the false information that he had planted a bomb there. That day, the Convention Center was again evacuated. 49 Case Document 1 Filed 10/24/18 Page 50 of 59 Page ID #:50 COUNT FORTY [18 U.S.C. 844(e)] On or about December 11, 2017, in Los Angeles County, within the Central District of California, defendant TYLER RAI BARRISS, also known as aka ?Robert Hayward,? aka ?Robert,? aka ?Alex Mendez,? aka ?Alex," aka ?Matthew," aka ?Aaron,? by a telephone and other instrument of commerce, willfully made a threat, and maliciously conveyed false information knowing the information to be false, to the Suffolk County Police Department in Smithtown, New York, concerning an alleged attempt being made, or to be made, to kill, injure, and intimidate an individual and to damage and destroy property by means of fire and an explosive, namely, and in substance and effect, that he and a friend had planted bombs at a mall in Lake Grove, New York, that those bombs were set to explode, and that he and others were armed with assault weapons and planned to open fire at the mall. 50 Case Document 1 Filed 10/24/18 Page 51 of 59 Page ID #:51 COUNT FORTY-ONE [18 U.S.C. 844(e)] On or about December 14, 2017, in Los Angeles County, within the Central District of California, defendant TYLER RAI BARRISS, also known as aka ?Robert Hayward,? aka ?Robert,? aka ?Alex Mendez,? aka ?Alex,? aka ?Matthew," aka ?Aaron,? by a telephone and other instrument of commerce, willfully made a threat, and maliciously conveyed false information knowing the information to be false, to the George Mason University Police Department in Fairfax County, Virginia, concerning an alleged attempt being made, or to be made, to kill, injure, and intimidate an individual and to damage and destroy property by means of fire and an explosive, namely, and in substance and effect, that he had planted dynamite at a secondary school in Burke, Virginia, and that the dynamite was set to explode. 51 Case Document 1 Filed 10/24/18 Page 52 of 59 Page ID #:52 COUNT [18 U.S.C. 844(e)] On or about December 17, 2017, in Los Angeles County, within the Central District of California, defendant TYLER RAI BARRISS, also known as aka ?Robert Hayward,? aka ?Robert,? aka ?Alex Mendez,? aka ?Alex,? aka ?Matthew,? aka ?Aaron,? by a telephone and other instrument of commerce, willfully made a threat, and maliciously conveyed false information knowing the information to be false, to a mall in Lake Grove, New York, concerning an alleged attempt being made, or to be made, to kill, injure, and intimidate an individual and to damage and destroy property by means of fire and an explosive, namely, and in substance and effect, that he and a friend had planted bombs at the mall and that those bombs were set to explode. 52 Case Document 1 Filed 10/24/18 Page 53 of 59 Page ID #:53 COUNT [18 U.S.C. 371] A. THE OBJECT OF THE CONSPIRACY 1. Beginning on a date unknown to the Grand Jury, but no later than December 16, 2017, and continuing through on or about December 17, 2017, within the Central District of California, and elsewhere, TYLER RAI BARRISS also known as aka ?Robert Hayward,? aka ?Robert,? aka ?Alex Mendez,? aka ?Alex,? aka ?Matthew," aka ?Aaron,? Unindicted Co?Conspirator No. 3, and Unindicted Co?Conspirator No. 4 knowingly combined, conspired, confederated, and agreed to: a. By a telephone and other instrument of commerce, willfully make a threat, and maliciously convey false information knowing the information to be false, concerning an alleged attempt being made, or to be made, to kill, injure, and intimidate an individual and to damage and destroy property by means of fire and an explosive, in violation of Title 18, United States Code, Section 844(e). b. With the purpose of issuing a threat and with knowledge that the communication would be viewed as a threat, knowingly transmit in interstate commerce a communication containing true threats to injure the person of another, in violation of Title 18, United States Code, Section 875(c). B. THE MANNER AND MEANS OF THE CONSPIRACY 2. The object of the conspiracy was to be carried out, and was carried out, in substance as follows: 53 Case Document 1 Filed 10/24/18 Page 54 of 59 Page ID #:54 a. Unindicted Co?Conspirator No. 3 and Unindicted Co? Conspirator No. 4 would identify victims that either or both of them wanted to harass, intimidate, disrupt, and annoy by swatting them. b. Unindicted Co-Conspirator No. 3 and Unindicted Co? Conspirator No. 4 would provide information about their victims, such as what they believed to be their victims? home addresses, to defendant BARRISS. c. Using an online payment processor, Unindicted Co? Conspirator No. 4 would pay defendant BARRISS to swat the victims. d. Defendant BARRISS would willfully and maliciously call law enforcement and make a false report, knowing that information to be false, of a serious law enforcement emergency in order to trigger a law enforcement and emergency services response at what he believed to be the victim?s home address. c. ACTS 3. On or about the following dates, in furtherance of the conspiracy and to accomplish its object, defendant BARRISS, together with Unindicted Co?Conspirator No. 3 and Unindicted COMConspirator No. 4 and other co~conspirators known and unknown to the Grand Jury, committed and caused others to commit various overt acts within the Central District of California and elsewhere, including the following: Overt Act No. 1: On or about December 16, 2017, Unindicted Co?Conspirator No. 3 asked defendant BARRISS, in Twitter Direct Messages, whether he would ?do some naughty tasks 4me? in exchange for payment, to include Bitcoin, which is a peernto?peer currency, and a Microsoft Xbox, which is a video game system. 54 Case Document 1 Filed 10/24/18 Page 55 of 59 Page ID #:55 Overt Act No. 2: On or about December 17, 2017, Unindicted Co?Conspirator No. 3 told Unindicted COHConspirator No. 4, in Twitter Direct Messages, ?@SWAutistic knows a thing or 2 on naughty look at his namell? Unindicted Co?Conspirator No. 3 also told Unindicted C0wConspirator No. 4 that defendant BARRISS charged $10 to conduct a swat. Overt Act No. 3: On or about December 17, 2017, in Twitter Direct Messages with Unindicted Co?Conspirator No. 3, defendant BARRISS agreed to swat Victim P.E. Overt Act No. 4: On or about December 17, 2017, Unindicted Co?Conspirator No. 3 sought, for his own amusement, to record Victim reaction to the swat on a multi?party voice?over?internet communication. Overt Act No. 5: On or about December 17, 2017, defendant BARRISS, with the purpose of issuing a threat and with knowledge that the communication would be viewed as a threat, called the Indianapolis Metropolitan Police Department in Indianapolis, Indiana, and falsely reported, knowing the information to be false, that he had shot his father at what defendant BARRISS believed to be Victim home address on Caval Cade Court in Avon, Indiana. Overt Act No. 6: On or after December 17, 2017, Unindicted Co?Conspirator No. 4 told defendant BARRISS, in Twitter Direct Messages, in substance and effect, that he had paid defendant BARRISS to swat Victim P.E. and that Unindicted Co?Conspirator No. 3 was the ?middle man.? Overt Act No. 7: On or about December 17, 2017, Unindicted Co?Conspirator No. 4 and defendant BARRISS agreed that defendant BARRISS would swat Victim C.V., and Unindicted Co?Conspirator No. 4 55 Case Document 1 Filed 10/24/18 Page 56 of 59 Page ID #:56 provided defendant BARRISS with what he believed to be Victim home address on Wittekind Terrace in Cincinnati, Ohio. Overt Act No. 8: On or about December 17, 2017, using an online payment processor, Unindicted Co?Conspirator No. 4 sent three payments of $10.00 each to defendant BARRISS to pay him for conducting the swats of Victim P.E. and Victim C.V. Overt Act No. 9: On December 18, 2017, by a telephone and other instrument of commerce, defendant BARRISS willfully make a threat, and maliciously conveyed false information knowing the information to be false, to the Hamilton County Sheriff?s Office Communications Center in Hamilton County, Ohio, concerning an alleged attempt being made, or to be made, to kill, injure, and intimidate an individual and to damage and destroy property by means of fire and an explosive, specifically, in substance and effect, that he had shot his father at a residence on Wittekind Terrace in Cincinnati, Ohio, that he was holding his mother and sister hostage, and that he planned to set the residence on fire. ?56 Case Document 1 Filed 10/24/18 Page 57 of 59 Page ID #:57 COUNT [18 U.S.C. 844(e)] On or about December 19, 2017, in Los Angeles County, within the Central District of California, defendant TYLER RA: BARRISS, also known as aka ?Robert Hayward,? aka ?Robert,? aka ?Alex Mendez,? aka ?Alex,? aka ?Matthew,? aka ?Aaron,? by a telephone and other instrument of commerce, willfully made a threat, and maliciously conveyed false information knowing the information to be false, to the Lee?s Summit Police Department in Lee?s Summit, Missouri, concerning an alleged attempt being made, or to be made, to kill, injure, and intimidate an individual and to damage and destroy property by means of fire and an explosive, namely, and in substance and effect, that he had planted a bomb at a high school and that the bomb was set to explode. 57 Case Document 1 Filed 10/24/18 Page 58 of 59 Page ID #:58 COUNT [18 U.S.C. 875(0)] On or about December 22, 2017, in Los Angeles County, within the Central District of California, defendant TYLER RAI BARRISS, also known as aka ?Robert Hayward,? aka ?Robert,? aka ?Alex Mendez,? aka ?Alex,? aka ?Matthew,? aka ?Aaron,? with the purpose of issuing a threat and with knowledge that the communication would be viewed as a threat, knowingly transmitted in interstate commerce to Calgary emergency services in Calgary, Canada, a communication containing true threats to injure the person of another, namely, and in substance and effect, that he had shot a person and was holding two others as hostages. 58 Case Document Filecj 10/24/18 Page 59 of 59 Page ID #359 COUNT [18 U.S.C. 875(c)] On or about December 26, 2017, in Los Angeles County, within the Central District of California, defendant TYLER RAT BARRISS, also known as aka ?Robert Hayward,? aka ?Robert,? aka ?Alex Mendez," aka ?Alex,? aka ?Matthew,? aka ?Aaron,? with the purpose of issuing a threat and with knowledge that the communication would be viewed as a threat, knowingly transmitted in interstate commerce to the San Antonio Police Department in San Antonio, Texas, a communication containing true threats to injure the person of another, namely, and in substance and effect, that he had shot his mother and intended to harm others. NICOLA T. HANNA United States Attorney see PATRICK R. FITZG LD Assistant United States Attorney Chief, National Security Division CHRISTOPHER GRIGG Assistant United States Attorney Chief, Terrorism and Export Crimes Section GEORGE E. PENCE Assistant United States Attorney Terrorism and Export Crimes Section 59