U.S. Department of Homeland Security
Washington, DC 20528

Homeland
Security
June 20, 2018

Larry Schwartztol
Counsel
The Protect Democracy Project
2020 Pennsylvania Avenue, NW
#163
Washington, DC 20006

Re:

First Interim Release
Protect Democracy Project
17-2202 (2017-HQFO-01153)

Dear Mr. Schwartztol:
This is the first interim response to your August 23, 2017, Freedom of Information Act (FOIA)
request to the Department of Homeland Security (DHS) (2017-HQFO-01153).
For this month’s production, DHS processed for release 317 pages. Of the 317 pages, 77 pages
are withheld in full pursuant to 5 U.S.C 552(b) (5), 4 pages are withheld in part pursuant to 5
U.S.C 552(b) (5) and (b) (6), 13 pages are released in full, 196 pages were non-responsive, 18
pages are being referred to Office of Intelligence and Analysis (I&A) for direct response and 9
pages are being refereed to Federal Bureau of Investigation (FBI) for direct response. The 94
pages for release are bates-numbered DHS-001-1153-000001 to DHS-001-1153-000094.
DHS will review at least 250 additional pages of responsive documents for the July 30, 2018
release date.
Sincerely,

Kevin L. Tyrrell
Director FOIA Appeals and Litigation

1

  

 

Christensen, Gillian 00(5)
(FvotsoHansPoL 

"Media Inquirv ADMINISTRATIVE GROUP


Subject: RE: Request for HSAC report on private immigration detention
Date: 2016f11f30 15:53:50

Priority: Normal
Type: Note

 

 

 

 

 

 

 

 

 

 

 

Got it

 

 

From: Madison Pauly ME)

 

 

Sent: Wednesday, November 30, 2016 2:41 PM
To: Media Inquiry <Medialnquirv@HQ.DHS.GOV>

Subject: Request for HSAC report on private immigration detention

Hello,

My name is Madison Paulv and write for MotherJones magazine in San Francisco. I?m writing to
request a copv of the Homeland Security Advisory Committee's report on the use of private immigration
detention. Could you please send a copy of the report to me or direct me to where I can access it? If it's
not available, when will it be released?

Thanks for your time.

Madison Paulv
Assistant Editor, Mother Jones

(E3315)

 

 

 

 

 

 

Sender: Christensen, Gillian 

 

 

lfb??)

 

 

 

Rec, ient, ADMINISTRATIVE GROUP


Sent Date: 2016f11f30 15:53:45r
Delivered Date: 2016f11f30 15:53:50

 

 

 

 

 

DHS-001-1153000001

 

 

 

page draft document

 

 

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Peter 

"'Robert_D_Wl1itho H5)
"Stevens, Clark <10:



"Stickel, Nicole <f



stain,r on militia groups in the US
2014f?4l30 19:49:45
Note

 



 

From: Whithorne, Bobby 

Sent: Wednesday, April 3U, gum uneo PM

To: Stevens, Clark; Boogaard, Peter

Cc: Bradsher, Tanya; Stickel, Nicole; Catron, Marsha; Lee, SY
Subject: Re: newsweek story on militia groups in the US

 

 

 

All good on this one

 

From: Stevens, Clark 

 



 

Sent: Wednesday, April 30, 2014 04:00 PM Eastern Standard Time

 

T01Referred to AnotherAgencinomponent

 

 

CC Referred to AnotherAgencnyomponenl

 

 

 

Referred to AnotherAgencinornponent

 

 

Subject: RE: newsweek story on militia groups in the US

DHS takes seriously our responsibility to protect the civil rights and civil liberties of the public, and do
not concentrate efforts on any particular group or ideology.

le'verydz-iy, DHS works with its state, local, tribal, territorial and private partners towz-irds its
mission of preventing

and protecting our communities

against potential threats to the United States. This includes training law enforcement to
recognize behaviors and other indicators associated with violent criminal activity and to
distinguish them from those that are constitutionally protected.

 

From:lReferred to Another I
A i

 

Sent: Wednesday, April 30, 2014 2:39 PM

 

Referred to AnotherAgencinornponent

To

 

Cc

 

 

Subject: newsweek story on militia groups in the US



Max Strasser from Newsweek is doing a ston,f tied to the Cliven Bundy issue in NV about concerns over
right wing militia groups in the US. they mentioned the 2009 rwe memo, and wanted to know if we had
anyr comment on concerns over these

groups or any actions we were taking regarding these groups.

Think we need to be pretty' careful commenting here. suggest the following. Deadline COB.

ON THE RECORD

 

(W5)

 

 

 

 

 



Sender

 

Recipient

 

 

Sent Date: 2014f04130 19:49:45

 

 

 

Delivered Date: 2014f04f30 19:49:45

 

 



IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF KANSAS

 

 

(Wichita Docket)

UNITED STATES OF AMERICA

Plaintiff,
v, Case Number: 16-
CURTIS WAYNE ALLEN,
PATRICK EUGENE STEIN, and FILED UNDER SEAL
GAVIN WAYNE WRIGHT,

Defendants.

 

 

SEALED CRIMINAL COMPLAINT
1, Federal Bureau of Investigation Task Force Of?cer Chad B. Moore, being duly sworn,
state the following is true and correct to the best of my knowledge and belief, and establishes
probable cause that the following offenses have been committed:
COUNT 1
Beginning in approximately February 2016 and continuing until on or about October 12,
2016, in the District of Kansas, the defendants,
CURTIS WAYNE ALLEN,
PATRICK EUGENE STEIN, and
GAVIN WAYNE WRIGHT.
without lawful authority, conspired with each other and with others, to use a weapon of mass
destruction an explosive device as defined by Title 18, United States Code, Section 92])
against people and property within the United States and such property is used in interstate and
foreign commerce, and the offense, and the results of the offense, would have affected interstate

or foreign commerce.

DHS-001-1153000082

All in violation of Title 18, United States Code, Sections 2 2332a(a)(2)(D).

 

The following facts were made known to me by personal observation or from information
I received from other law enforcement officers, andz?or from other individuals and does not
contain all facts known to me, but only those facts sufficient to establish probable cause.
Furthermore, statements of individuals, including those attributed to the defendants, are set forth
in substance and in part: 1, Chad Moore, a Task Force Officer with the FBI, being first duly
sworn, hereby depose and state:

INTRODUCTION

 

1. This Affidavit is offered in support of a criminal complaint charging Curtis
Wayne ALLEN, Patrick Eugene STEIN, and Gavin Wayne WRIGHT with violations of
federal statutes concerning Arsom?Explosives and Use of a Weapon of Mass Destruction (18
U.S.C. 2, 844(h), 6: and 2332a).

2. Since February 2016, the Federal Bureau of Investigation (FBI) has been
conducting a domestic terrorism investigation of a group of individuals operating in
southwestern Kansas who identi?es themselves as ?the Crusaders.? This is a militia group
whose members support and espouse sovereign citizen, anti-government, anti-Muslim, and anti?
immigrant extremist beliefs. Certain key members of this group, including Patrick STEIN,
Curtis ALLEN, and Gavin WRIGHT, have been regularly meeting and planning to carry out a
violent attack against Muslims in their community and have taken steps in furtherance of
accomplishing this, including identifying a target location. These individuals regularly use their

cell phones to arrange the meetings and also utilize them to engage in additional discussion and

2



coordination of their plans via a conference call app called Zello.J These activities are being
done in violation of ArsonfExplosives and Weapons of Mass Destruction statutes (18 U.S.C. 
844 and 2332a).

3. Based on my training and experience, and the facts set forth in this Af?davit, I
believe there is probable cause that violations of federal law have been committed in the District
of Kansas.

4. The facts in this Affidavit come from my personal observations, my training and
experience, and information obtained from other law enforcement of?cers, federal agents, and
witnesses. Because this Af?davit is being submitted to support only a finding of probable cause,
I have not set forth all of my knowledge regarding the investigation.

BACKGROUND OF AFFIANT

 

5. I am a Task Force Of?cer with the Federal Bureau of Investigation (FBI) and
have been so employed since February 2013. As such, 1 am an investigator or law enforcement
officer of the United States within the meaning of 18 U.S.C. 2510(7). I have been employed as
a Kansas State Trooper with the Kansas Highway Patrol since 2007' and have been a certified law
enforcement of?cer since 1996. Since August 2013, I have been assigned to the Federal Bureau
of Investigation Kansas City Joint Terrorism Task Force.

6. During my tenure in law enforcement, I have participated in numerous and varied
types of investigations, including, but not limited to: Terrorism investigations, weapons
violations, crimes involving the transportation, possession, manufacture, andfor distribution of
controlled substances. 1 have also received training in complex conspiracy investigations, money

laundering, telecommunications exploitation, and asset forfeiture.

 

Zello is a phone-based application that allows the user to communicate with other Zello users
as if their cellular telephones were push-to-talk walkie-talkies.

3



BACKGROUND OF CASE

 

7. This investigation began based on reporting from a reliable, paid Con?dential
Human Source (CHS) who has attended numerous Crusaders meetings where plans were
discussed to carry out a violent attack against Muslims (whom the group members refer to as
?cockroaches") in southwestern Kansas. These groups meet in person frequently, as often as
once per week, and also engage in frequent communication daily through a telephone application
(app) called Zello. Information provided by the CH3 has been verified multiple times through
consensual monitoring of phone calls and messages, as well as recordings of meetings made
when the CH8 was wearing a body recorder. On at least one occasion a local law enforcement
of?cer provided information consistent with CHS reporting over several topics. The CHS has
been further corroborated through social media and open source reporting.

8. Through recordings, CHS cooperation and reporting, and open source and social
media investigation, STEIN, ALLEN, and WRIGHT have been identified as members of the
aforementioned militia group. They have also been determined to be the primary architects of the
attack plan. STEIN has been identified as a leader within the Crusaders. ALLEN is a close
associate of and has led meetings of the Crusaders. WRIGHT is also a member of the
Crusaders and has participated in the planning of the attack.

PROBABLE CAUSE

9. The investigation to date has revealed that Crusaders members Patrick STEIN,
Curtis ALLEN, and Gavin WRIGHT are conspiring to carry out a domestic terrorist attack by
using an improvised explosive device (IED) to destroy an apartment complex in Garden City,
Kansas, which contains a mosque and is home to many Muslims. Their activities have

demonstrated, and continue to demonstrate, actions taken in furtherance of this scheme. They

4

DHS-001-1153000085

have routinely expressed a hatred for Muslims, individuals of Somali descent, and immigrants.
They chose the target location based on their hatred of these groups, their perception that these
groups represent a threat to American society, a desire to inspire other militia groups, and a
desire to ?wake people up.?

10. According to CH8 reporting, on three separate occasions STEIN conducted
surveillance on potential target locations around Garden City and other parts of southwestern
Kansas. These surveillances were conducted on a mall frequented by members of the Somali
community, and a mosque located in an apartment complex, as well as on various vehicles
believed to be occupied by individuals of Somali descent or Muslims. On one such surveillance
in February 2016 when the CH8 was driving STEIN around, STEIN at various times yelled at
Somali women dressed in traditional garb, calling them ?fucking raghead bitches.? STEIN also
referred to Somalis as ?cockroaches? and said several times that they needed to eliminate the
Somalis. During the surveillance, STEIN had with him a pistol, an assault ri?e with several
magazines, a ballistic vest, and a night vision scope. He also mentioned to the CH3 that he had
done several surveillances like this on his own in the past and that he always made sure he was
armed. STEIN also discussed Oklahoma City and the bomb used (referring to the fuel oil and
ammonium nitrate device used by Timothy McVeigh to destroy the Murrah Building in
Oklahoma City). He was looking for any more explosives or things he could use to blow things
up.

11. During a Zello conference call in April 2016, STEIN stated, ?Make sure if you
start using your bow on them cockroaches, make sure you dip them in pigs blood before you

shoot them.? This conversation was recorded via consensual monitoring by the CH3.

5

DHS-001-1153000086

12. In a May 2016 meeting, ALLEN stated:
?We need to get some signs made up. . .hundreds of them, kind of
like the redneck deal, ?here?s your sign? and just put right there on
it: I SUPPORT ILLEGAL IMMIGRATION, IGO AGAINST
THE CONSTITUTION ON A DAILY BASIS, I DO NOT HAVE
ANY CARE FOR MY FELLOW CITIZENS IN THE STATE OR
IN THE TOWN THAT I then for every one of
them that we blow the top of their head off we just put that around
their neck.?
STEIN said he liked the idea. This conversation was recorded via consensual monitoring.

13. During a phone call to the CHS in May 2016, STEIN talked about some of his
frustrations. STEIN wanted to just go do something. He said he wanted to get a .22, go over to
Garden City, Kansas, start kicking in the doors of the Somali apartments, and kill them one by
one. He wanted to use a .22 because it was quieter and he also mentioned he wanted to buy or
make a silencer.

14. In June 2016, STEIN called for a meeting with the Crusaders. Attendees
included STEIN and the CHS. They met in a ?eld with the stated intention of avoiding
surveillance by the FBI. During the meeting, STEIN brought up the Orlando night club shooting
and said that something needed to be done in response to this act of terrorism. He proposed
carrying out an attack similar to the Orlando shooting against a Muslim refugee location in
Garden City. The group discussed how they could carry out such an attack.

15. During a group Zello call that the CHS was part of in June 2016, STEIN and
ALLEN discussed conducting surveillance in Garden City at the African Community Center, the
mosques, and the Somali apartments. They wanted to get photos and videos of the places during

the day and also conduct surveillance throughout the night to see what the members of the

Somali community were doing. ALLEN stated that the purpose of the surveillance was to begin

6

DHS-001-1153000087

to put a plan into action. STEIN said he wanted to know where they are so they can ?kill all of

the motherfucking cockroaches.?

16.

During an in-person meeting in June 2016, STEIN stated:

?Garden City for example, Iknow exactly where probably a
majority of those motherfuckers are at in their Garden
City. . got these apartment complexes over there
where literally every fucking apartment. . .that?s all it is, fucking
goddamn cockroaches. . .and. . .I mean I wouldn?t be against if I
could get a hold of some RPG's (rocket propelled grenades), I'll
run some 5 right through. . .l?ll blow every goddamn building
up right there. . .boom. . .I?m outta there.?

This was recorded via consensual monitoring by the CH8.

17.

18.

During a consensually monitored Zello conference call in June 2016, STEIN said:

?The only fucking way this country?s ever going to get turned
around is it will be a bloodbath and it will be a nasty, messy
motherfucker. Unless a lot more people in this country wake up
and smell the fucking coffee and decide they want this country
back. ..we might be too late, if they do wake up. . .1 think we can
get it done. But it ain?t going to be nothing nice about it.?

During a consensually monitored Zello conference call in June 2016, STEIN,

WRIGHT, and ALLEN, along with a larger group, discussed targeting churches in Garden City

that have supported refugees. While discussing a particular church STEIN said, ?That

motherfucker needs burnt to the ground.? When the discussion turned to burning mosques,

WRIGHT stated, ?Yeah, during prayer time.?

19.

In July 2016, STEIN, ALLEN, WRIGHT, and the CH8 met in person at 083.0

Mobile Home Center a business in Liberal, Kansas owned by WRIGHT, and at

which ALLEN works. During the meeting, STEIN and ALLEN proposed and discussed a wide

range of potential targets, including Muslim-occupied apartment complexes, residences, and

places of worship, cityfcounty commission meetings, local public officials, landlords who rent

7

DHS-001-1153000088

property to Muslim refugees, and organizations providing assistance to Muslim refugees. While
they were discussing these plans, WRIGHT pulled up Google Maps on the computer at his
business and began dropping pins on the map at these various locations using the label
?cockroaches.? Prior to the meeting WRIGHT researched guides for making explosives and
printed off a substantial number of pages of this material. The group brainstormed various
methods of attack, including murder, kidnapping, rape, and arson. They decided to pick a
speci?c target at their next meeting. At one point, ALLEN stated: ?We?re going to talk about
killing peOple and going to prison for life. Less than sixty days, maybe forty days until
something major happens. We need to be preemptive before something happens.? STEIN
responded: ?The only good Muslim is a dead Muslim.? At another point in the conversation,
STEIN said: ?If you?re a Muslim I?m going to enjoy shooting you in the head.? Then he told the
group, ?When we go on operations there?s no leaving anyone behind, even if it?s a one-year old,
I?m serious. I guarantee ifI go on a mission those little fuckers are going bye-bye."

20. On August 14, 2016, STEIN, ALLEN, WRIGHT, and the CH8 met at 
During this meeting, the group ultimately decided on a particular apartment complex in Garden
City, Kansas, as the target location of their attack due to the number of members of the Somali
community that live there and the fact that one of the apartments is used as a mosque. They
decided that they would obtain four vehicles, fill them with explosives, and park them at the four
corners of the apartment complex to create a big explosion. ALLEN stated that he could make
the explosives and mentioned aluminum powder and ammonium nitrate, among other
components. Later he said he already had the materials needed to make the explosives. Once he
had assembled the explosives, ALLEN said the group would need to test them prior to the

execution of the plan to make sure they worked. He also mentioned that he could detonate the

8



bombs with a cell phone, and they discussed having militia members in different states purchase
prepaid cell phones for them so that they could not be traced. The group researched mosque
prayer times online to determine when the most people would be around. WRIGHT was tasked
with ordering glassware in order to make the bombs. STEIN was instructed to get a rock
tumbler to crush cans into aluminum powder. The CHS was told to do reconnaissance at the
complex to look for security cameras and take pictures and such. ALLEN decided he would
work on the group?s manifesto to release in conjunction with the attack. They discussed not
wanting to get caught and wanting for this to be the ?rst of several things they do. This meeting
was recorded by the CHS via consensual monitoring.

21. On September 14, 2016, the CHS and STEIN spoke by telephone. During the
call, STEIN revealed his intentions to begin discussing project strategies via an mobile
messaging application. The CHS and STEIN brie?y discussed installing this app on their
phones. STEIN indicated he and the CHS will only discuss conversations about projects on the
app.

22. On September 13, 2016, STEIN and the CHS spoke over Zello during which
STEIN stated they would need a 35-gallon container (trash can) if not a SS-gallon container in
which to store explosive material. STEIN suggested the group would need 4 6 trash cans in
order to avoid suspicion. STEIN believes the trash cans should be in place at a mosque no
earlier than three (3) hours prior to detonation in order to avoid suspicion.

23. During the course of the investigation, agents had the CHS introduce an FBI
Undercover Covert Employee (UCE) to STEIN, under the ruse that the CHS worked for the
UCE delivering money and contraband and that the UCE could provide automatic weapons and

components for explosive devices to STEIN and the others. On October 12, 2016, STEIN met

9

DHS-001-1153000090

with the UCE at a rural location in Finney County, Kansas. The FBI UCE (and other FBI UCEs
who were present in a support capacity) were holding automatic weapons that were provided
from the FBI lab in Quantico, Virginia. STEIN asked the UCE if he could shoot the weapons.
STEIN was given the opportunity to shoot the weapons and shot both a 5.56 fully automatic ri?e
and a 7.62X39 fully automatic ri?e.

24. After STEIN shot the ri?es during this meeting, he spoke to the UCE regarding
the price of the ri?es as well as the location of the apartment complex. STEIN agreed to go to
Garden City and show the UCE the apartment complex that houses the mosque. While in the
vehicle with the UCE, STEIN discussed trading drugs for explosives. STEIN also told the UCE
that WRIGHT and ALLEN have previously mixed explosives at in Liberal, Kansas.
STEIN stated that he has fertilizer (Ammonium Nitrate) for the device and the fertilizer is
located about sixty miles away. (Both residence and 685G are located approximately
60 miles away from where this meeting took place.) STEIN directed the UCE to the apartment
complex in Garden City. This apartment complex houses a mosque and a large number of
members of the Somali community. When the UCE drove by the apartment complex, STEIN
told the UCE that the apartment complex is ?full of goddamn cockroaches.?

25. At the same meeting, STEIN and the UCE discussed making a device for which
will deliver the Ammonium Nitrate. STEIN told the UCE about the recent arrest of
ALLEN (ALLEN had been arrested by local authorities the previous day) and stated that
girlfriend ?needs to disappear? because she is a concern. STEIN stated he believes
that girlfriend is giving information to local law enforcement. STEIN also told the

UCE that he can come up with $200-$300 along with Ammonium Nitrate for the explosive

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DHS-001-1153000091

device. The UCE agreed to this arrangement and promised to contact STEIN in the near future
to ?nalize the plan.

26. On October 11, 2016 at 1633 hours, Liberal Police Department (LPD) was
contacted by a female who identified herself as girlfriend at a residence she shares
with ALLEN, in Liberal, Kansas, regarding a domestic battery. This female advised the LPD
dispatcher that she was battered by ALLEN during an argument over money and her leaving
their residence. She also advised the LPD dispatcher that ALLEN had access to firearms and
had already ?ed the scene. Finally, she showed LPD officers a room in the residence containing
a large amount of ammunition, brass casings, components and tools for use in the manufacture of
ammunition and ?rearms.

27. At approximately 1710 hours, officers located a maroon 1999 GMC Yukon,
bearing a Kansas tag at ALLEN was believed to be inside. As LPD officers were
planning on making contact with ALLEN, WRIGHT and ALLEN left the business and traveled
south on Highway 83 from Tucker Road in separate vehicles. LPD officers stOpped both
vehicles and ALLEN was taken into custody. A search of ALLEN's vehicle revealed a large
amount of ammunition, multiple magazines, an magazine, and a Glock handgun
magazine, all loaded with ammunition. Also located was a tool used to create baf?es for ?rearm
silencers or suppressors.

28. Later in the day on October 11, 2016, girlfriend provided the following
information to the FBI: Within the last two weeks she had witnessed a white powdery substance
being produced on the counter at in a manner consistent with YouTube videos she
observed with ALLEN depicting the process of manufacturing explosives. She also observed

glassware and a long glass stirring stick being used to manufacture the explosives while at 0&6.

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She saw hydrogen peroxide, fuel tablets and cheesecloth being used for the manufacture of
explosives. In addition, she describes the substance being cooled in an ice bath (she stated the
substance was so unstable it needs to be produced in a climate controlled environment).

29. Kansas Highway Patrol Technical Trouper Bomb Technician BRODI GOSCH
has reviewed statements made by girlfriend and, based on his training and experience,
believes them to be consistent with the manufacturing of a homemade explosive known as
Hexamethylene Triperoxide Diamine (HMTD). This is known as a primary explosive, very
sensitive to heat, shock and friction. This primary explosive presents a signi?cant public safety
hazard and is usually used to create homemade blasting caps to initiate a larger explosive.

30. On October 12, 2016 search warrants were conducted at residence and
0&0. A possible detonator was found inside 0&0. The detonator was believed to be HMTD.
Agents also found a black thermometer, bamboo chopsticks with a white substance, Hydrogen
Peroxide Hydrogen Peroxide 35% (food grade), possible urea, and possible urea fertilizer.
All of the substances can be used in the production of improvised explosives. Agents used a
chemical testing tool to test the white substance on the bamboo chopsticks. The white substance
tested positive for Hexamine, an ingredient in HMTD. A yellow binder and paperwork labeled
?The Anarchist Cookbook,? was also found inside 0&0.

31. Inside residence, agents found a Sharps .22 caliber handgun and a
Glock 19 handgun. Agents also found at least four ?ammo cans? full of ammunition, at least 13
boxes of ammunition and countless loose ammunition. LPD of?cers estimated that they found

and seized close to a metric ton of ammunition in residence.

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CONCLUSION
Based on the above information, Irespectfully submit that probable cause exists
to believe that Patrick Eugene STEIN, Curtis Wayne ALLEN, and Gavin Wayne
WRIGHT have committed the offense set forth above, and I respectfully request the

Court issue warrants for their arrest.

FURTHER AFFIANT SAITH NOT.

Wigwam

Chad B. Moore
FBI Task Force Office

SUBSCRIBED TO AND SWORN before me this the 13th day of October. 2016.

TM 

 

JAMES P. 
Chief United States Magistrate Judge
District of Kansas

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