FILED
CLERK, U.S. DISTRICT COURT

04/27/2019
CENTRAL DISTRICT OF CALIFORNIA
BY: ___________________ DEPUTY

2:19-MJ-01751-DUTY

 AFFIDAVIT

 

I, Tasha Coolidge, being 
follows:



l. I am a Special Agent

Investigation and have
2018. I am currently assigned
of the Los Angeles Fie
Special Agent, I was on active
Force Security Forces, serving
overall mission to deter, detec
terrorist activity. During thi
responsibilities such as, prote
dignitary support, anti?terrori

missions. ?In total, I have bee

United States for nearly ten ye
gained a broad expertise coveri
enforcement, operational terror
measures. Through the course 
the FBI, I have used a variety

resources, including, surveilla

warrants, evidence seizures, ar

familiar with strategy, tactics
techniques of criminals, terror

I

my employment with the FBI, 6
Training at the FBI Academy in

received both_formal and inform

iuly sworn,

eld Division.

acting high?valued U.S.

ears.

declare and state as

ITRODUCTION

with the Federal Bureau of

2 been so employed since March

to the Joint Terrorism Task Force
Before becoming a
?duty in the United States Air

-eight years overseas, with an

:t and mitigate criminal and

.s time I had numerous

assets,

:sm measures, and fly?away

:n sworn to protect and serve the

During my career, I have

ng weapon systems, law

ist cells, and counter-insurgency

pf my training and employment with
of investigative techniques and

.nce, confidential sources, search

1d telephone toll analysis. I am

methods, tradecraft, and



'ists, and their agents. During

?ttended 21 weeks of New Agent

Quantico, Virginia. I have

1al training from the FBI

1

 

regarding criminal and countert
also attended training concernj

communications and computers ir

II. PURPOSE

:errorism investigations. I have
.ng the use of electronic

1 furtherance of crime.

OF THE AFFIDAVIT

 

2. This affidavit is suk
complaint charging defendant Me
with Providing and Attempting 
Terrorists, in violation of Tit

(the 

SUMMARY

nmitted in support of a criminal
er Steven Domingo 
.0 Provide Material Support to
.le 18,

United States Code, 2339A

OF PROBABLE CAUSE

 

3. In March and April 2C
steps to manufacture and use a
order to commit mass murder. 
purchased several hundred nails
explosive device, and provided
DOMINGO believed to be a collar
undercover law enforcement offi
for the purpose of having the 
destruction for DOMINGO to use
discussed below, on April 26, 2
inspected the items DOMINGO bel
destruction (but unbeknownst tc

finalized plans to commit the a

 

1 Title 18, United States
unlawful to provide or attempt
resources, knowing or intending
preparation for,
specified offenses,
Section 2332a (Use of a Weapon

or in carrying
including 

119, DOMINGO planned and took
_weapon of mass destruction in

in April 23 and 24, 2019, DOMINGO

to be used as shrapnel inside an
the nails to a person whom

aorator, but who was in fact an

cer working for the FBI,

IC manufacture weapons of mass

in an upcoming attack. As

019, DOMINGO met the UC,
ieved were weapons of mass

him were actually inert), and

.ttack on Sunday April 28, 2019.

Code, Section 2339A, makes it
to provide material support or
that they are to be used in

out, a violation of certain
'itle 18, United States Code,
of Mass Destruction).

2

 

OF PROBABLE CAUSE

 

IV. STAEEMENT

4. The facts set forth
part on: information provided 1
officers; law enforcement repOJ

witnesses; my personal observat
training, and background as an

affidavit is intended to show 

:ts;

.-

in this affidavit are based in

:0 me by other law enforcement

information obtained from
ions; and my experience,

FBI Special Agent. This

Ierely that there is sufficient

probable cause for the requested complaint, arrest warrant, and

search warrants, and does not 

knowledge of or investigation i

 

specifically indicated otherwi



>urport to set forth all of my

nto this matter. Unless

all conversations and

statements described in this a fidavit are related in substance

and in part only with quoted nguage appearing in draft form

only, and all dates and times

A.

re approximate.

DOMINGO Posts About His pport for Violent Jihad and

Committing a Large-Scale Terrorist Attack

5. According to reports

employee 
online platform (hereinafter UE
group. On March 2,
which he introduced himself as
shahada.2

6. FBI Agents reviewed I
Motor Vehicles records, and sam

appeared to be DOMINGO. FBI Ag

 

2 Based on my training and
shahada is the profession of fa
?There is no god but Allah,
Allah.?

in March 2019,

anc

provided by an FBI online covert
the OCE identified a user of an

ERNAME l) in a private message

2019, USERNAME 1 posted a link to a video in

?Mark Domingo,? and declared the

California Department of
I that the person in the video

[ents also reviewed records

experience, I am aware that the
ith and the first tenet of Islam:
I Muhammad is the messenger of

 

provided by the platform, whicl
account was associated with eme
m.doming02014@hotmail.com, and

According to records provided 

1 showed that the USERNAME 1
address
telephone number 931?249?5283.

>y Microsoft, the name associated

with the m.domingo2014@hotmail.com e?mail address is ?Mark
Domingo.?
7. According to Department of Defense records, DOMINGO

was also previously an active 
was assigned to Fort Campbell,
Afghanistan from September 10,

8. FBI agents have revie

OCE in which DOMINGO described
his aspiration to conduct an at

a. On March 3, 2019

another vegas event tbh3 someth

and its not

about winning tr

america giving them a taste of



over the world. Based on my 

that DOMINGO's description of 
reference to the October 1, 20]
Nevada, which killed 59 people.

b. On March 14,
mosque shootings in new Zealanc

mustbe retribution.? Based on

 

3 Based on my training and
is used in electronic communica
honest.? 

201



1uty U.S. Army He

Kentucky, and then deployed to
-2012 to January 16, 2013.

awed online posts provided by the
his support for violent jihad and
.tack in the Los Angeles area.

5, DOMINGO posted, ?america needs
ing to kick off civil unrest 

1e civil war its about weakening
'the terror they gladly spread all
raining and experience, I believe
another vegas event? is a

7 mass shooting in Las Vegas,
9:

DOMINGO posted, ?there were

[sad emoji] there

my training and experience and

experience, I am aware that ?tbh?
tions as shorthand for ?to be

 

knowledge of this investigatior
to the March 13, 20l9 mass shoo

Christchurch, New Zealand, whic


4

Also on March 14, 2019, DOMINGO
make a Christians life miserabl




sis in new Zealand mayb

shed our blood no Musli

a message needs to be sent.?

B. DOMINGO Expresses His Inte

for the Mass Shooting in 

9. According to the OCE,

observing posts regar
Zealand mass shoOting, the OCE

conversation with DOMINGO, in 

about that mass shooting. In 

jus enraged atm5 these

one way or another.? The OCE 

would be ready the next day, ar
response would require planning
many people DOMINGO would like
wrote: ?one [individual]? was 
a bunch of jews around this one

theyre fOrced to find parking a

 

4 ?Idk? do

5 Based on my training and
is short for ?at the moment.?

is short for

 

1!

fuckers do need to bleed 

[a

I believe DOMINGO was referring
tings at two mosques in

killed 50 people.

posted, feel like I should
tomorrow for our fallen bros 


a jews life idk4 they

should have to experience this,

nt to Kill Americans to Retaliate

few Zealand

on March 14, 2019, after
ding retaliating for the New
initiated a private online

hich they discussed their anger



lI?



hose messages, DOMINGO wrote,

autioned DOMINGO that police

Ld that any sort of retaliatory

In discussing with the OCE how
to kill in retaliation, DOMINGO
hinking more like a group theres
street not alot of parking so

nd walk to the synagogue.? Later

n?t know.?



experience, I am aware that ?atm

in the conversation, DOMINGO w1

saturday their worship,? a:
had a lot of businesses and qu

10. On March 16, 2019, at

who also maintained ar

same private message group as I

private message to DOMINGO askj
?still mad 

responded, 

watched the vid.? Based on my
knowledge of this investigatior
reference to live footage of t?
the perpetrator streamed online
subsequently been reposted on 

11. DOMINGO continued,

took my ak out 

training and experience,

reference to a Kalashnikov?mant

commonly known model of which i

According to a law enforcement
firearms registered to him: a

semi?automatic rifle (WASR 10),

Tulski?Korovin SKS semi?automat

bolt?action rifle.

 

5 Based on my training and

is an Arabic word for Jews.

7 The CHS has worked with
2013.


its beer

I knov



In total, the CH8 has be
The CHS ddes not have a crimina

rote that ?the yahud6 go on

1d that the area was upscale and
:veillance cameras.

1 FBI Confidential Human Source7

1 online account and was in the

and the DOE, sent a
.ng how he was feeling. DOMINGO
even more so since I

training and experience and

i, I believe ?the vid" was a
is New Zealand shootings, which

a during the attacks and which has
.he Internet.

10w my bros sis died 
i by my bed.? Based on my

I that ?ak? is a common shorthand

[factured assault rifle, the most
8 referred to as an 

Idatabase, DOMINGO has three
?entury Arms Wassenaar Arrangement
which is an style rifle; a

ic rifle; and a Zastava 48

experience, I am aware that Yahud

the FBI since approximately August
en paid approximately $304,524.
1 history. 

6

 

12. Later in their conveJ

and the CH8 meet in person, an:

following week.

C. DOMINGO M?ets CHS on Marc}

Committing a Terrorist Ati

13. On the evening of Max

met in person to eat dinner anc

meeting was audio recorded. DL

below, DOMINGO discussed with 

attack, including Jews, police

military facility.

14. DOMINGO and the CHS 

Syria, and the activities of 

Iraq and al?Sham Aft

?not doing anything,? DOMINGO 5

plant Based on my trair

that is a reference to I

DOMINGO characterized Al?Qa'ida

the

run They'll shoot,

the Americans get mad. Then t?

This is why I like I like al-
direct stance victory 
training and experience,

to Abu Bakr al?Baghdadi, the le

 

3 Based on my training and

violent Islamic extremists, the

for Islam through violent jihac.

I beli

:sation, DOMINGO suggested that he

1 they agreed to meet the

1 18, 2019 and Proposes Ideas for
;aok

:Ch 18, 2019, the CH8 and DOMINGO
i attend a prayer service. The
iring that meeting, as detailed

:he CHS different targets for an

officers, churches, and a

iiscussed the wars in Iraq and
.?Qa?ida and the Islamic State of
:er the CHS said Al-Qa'ida was
said, ?Well, they'll, they?ll
iing and experience, I believe
improvised Explosive Devices.
l?s tactics as ?sort of hit and

an they'll run away then


?cuz he took the

go murder Muslims 
-Baghdadi, yeah,
?r Based on my
eve ?al?Baghdadi? was a reference

zader of ISIS.

experience, I know that among
a term martyr means one who dies
1 .

 

15. Throughout their drix

targets to the CH8, including 

National Guard Armory. At one

the business street

the

They?re all up and down the st:

everywhere. I mean it's a busi

?if you really want to do it, 3

online and do it, you know? Yc

DOMINGO interrupted the CH8 anc

replied, ?No. They going to pL

?If they catch me alive." The

go shahid?9 You going to kill

tell me 

You have a 
has to be done."

16. Moments later, DOMING

saying. We should plan.? The

to get caught. Your plan is jL
your plan.? DOMINGO replied 
?It's better not to get caught.
taken alive. But I hav
he had nine magazines,? fin
described to the CH8 the guns 
?They're all legally under my 
going to work. We're going to

Well to be fair, yeah.

 

9 Based on my training and-

facts, ?go shahid? is used here

7e, DOMINGO pointed out possible

>olice cars, churches, and a

point, DOMINGO stated ?This is
a Yahud come here on Saturday.
?eet, but there?s cameras

-ness you know.? The CHS said,

rou can?t just, you can't just go
u?re going to end up like??
The CHS

i said, martyr.?

1t you in jail.? DOMINGO replied,

CHS replied, ?okay, you going to

one or two? What's the plan? You

In?? DOMINGO replied, ?something

}0 said know what you?re
CHS replied mean I don't want

[St to go and get caught. That's

bro.? The CHS said,

If!

DOMINGO said ?Better not to be

'e many magazines." DOMINGO said
'e of which were loaded, and
hat he owned. After DOMINGO said
Lame,? the CH8 said ?That's not
?No



get caught." The CHS said,

Okay. So we plan

experience and the totality the
to mean ?become a'martyr.?

8

 



We chill.

We plan. We take our time

17. During the meeting,
said ?there's another one 
kuffar,10 brother.?

What do you want to hit?

Which one do you want to show me?"

always hit the cops.? The CHS

We chill for a bit.?

I

The CHS sa

Churc

You know we just, we cruise.
DOMINGO pointed out a church and
I mean this is the land of
id ?You want to go after church?
:hes or like the military base?
DOMINGO replied ?We can

.again expressed concern about

DOMINGO conducting an attack using guns registered in his own

name, and asked if the bullets

DOMINGO said the bullets were I

to handle the bullets so his fj

them.

18.

make 

described how an IED could be 

with a timer.

and went inside for several mir

mosque,

I,
I

see DOMINGO replied ?He can

the brother could not make IEDE

brother knew someone else who 

to DOMINGO's house,

You have my number. I have

 

Kuffar is the plural fo
non?believers or infidels,
non?Muslims.

The CHS then said the

DOMINGO replied ?1

The CH8 and 

the CH8 said the CH8 wc

and DOMINGO said,

like

were also registered in his name.
1ot registered, and he used gloves
.ngerprints would not appear on

1t he knew someone who ?used to
'hat's even better.? The CHS
alaced under a car and detonated
NGO then arrived at the mosque
Lutes to pray. When they left the
:uld talk to ?the brother, and
make The CHS replied that
but the CH8 would see if the

I

:ould. The CBS drove DOMINGO back
?We?ll keep in touch 

yours.?

rm of an Arabic word referring to
:ly used by DOMINGO to refer to

 

D. DOMINGO Proposes Conducti:

19. On March 20, 2019, DC
message of a photograph of an 2
of paper with a handwritten ca;
3/20/2019.? The rifle depictec

feature a foldable metal stock,

 

detachable high?capacity ammun
at his house. DOMINGO explain
?foldable stock for drive by?
replaced it with wire
on my training and experience
investigation, I believe DOMIN
rifle?s wooden stock with wire
DOMINGO modified his rifle so
more easily from inside a vehi
20. Later that day, DOMI
containing a similar photograp
OCE to send a timestamped phot
what I did with my ak 
know its mine and i ai
configuration is illegal afln
there may be a ?snitch" in the
assured DOMINGO that everyone


responded, ?inshallah 

go dark for a

 

AF is slang for ?as fuel

 

  
   
 
   
  
   
 
 
  
   
  
 
  
  
  
 

1g a Drive?By Shooting

sent the CH8 a private
iK?style rifle alongside a piece


1 in the photograph appeared to

)tion, 



an attached sling, and a

{tion magazine that DOMINGO keeps

to the CH8 that the rifle had a
nd that he ?took off wooden stock
cuz wire can fold." Based
nd knowledge of this

O?s reference to replacing the
_for a ?drive by? means that

hat it could be handled and fired
le.

GO sent a message to the OCE

of his rifle. DOMINGO asked the
graph in return and stated ?like
time stamped it 



DOMINGO said he thought



fed (cuz my ak

01.?
message group. When the OCE
ad to be invited, DOMINGO
lho if I do, do anything that is

it and I'll see you up

meaning very.

10

there if allah wills lc

experience, I believe ?up there
heaven, and DOMINGO expects to-
dying through violent jihad.

E. DOMINGO MEets with the

His Intent to Commit a

CH

21. On the evening of Max

met again to eat dinner and att
meeting was audio recorded. DL
below, DOMINGO discussed with 
committing an attack.

22. DOMINGO asked the CHE

apparently referencing the phot

of his rifle. DOMINGO spoke at

the rifle and added ?So when we

to act, I can keep it, like, yc

gonna be like, you know, it?s 9


The CHS replied that

the car With the wire,

23.



Islam and was ?so pure, and st

don't have to do this. You 
DOMINGO responded by pointing 
the police," and describing hon

glass but police officers ?roll

 

?Lol? is short?hand for
stated he had to ?show off," bL
[heart?eye emojis].? DOMINGO 
believer who was ?mad atm.? Ag

31..?12

3?
a



1ring that meeting,

Based on my training and
is a reference to paradise, or

earn his?place in paradise by

on march 22, 2019 and Discusses
Terrorist Attack

ch 22, 2019, the CH8 and DOMINGO
end a prayer service. The
as detailed

he CHS different plans for

5 if the CH8 saw his 

ograph DOMINGO had sent the CH8

aout some modifications he made to

decide to act or when I decide
it?s



:u know when it's the wood,
[onna be uncomfortable ?in
you can fold it.?
DOMINGO had just converted to
ated ?You don't need to, like you

that, right? You're pure.?

ut a police car, stating ?That's
police cars have bullet proof

their window down sometimes.?

-?laugh out loud.? DOMINGO also
lt added, to me is like
ater stated he was just a

ain, ?atm? means ?at the moment.?

11

 

24. DOMINGO and the CH5

prayers, and the CH8 again sai:

then discussed practicing Islamic

1 how DOMINGO was ?pure.? DOMINGO
replied ?To be fair though, most people here are shit 
Everyone I know are like, they?re like fake, you know I
always said that's fine, I?m just like, fuck 'em. I don't care

about them. They don?t care at

the deen.?l3 The CHS replied 

being patient, and DOMINGO rep]

of the times, it's a fucking tr

right?? The CHS said, ?Yeah, 1

?So you know, if they start it,

one way or another I?m gonna fj

by fighting. We can handle it

what you wanna do bro, like mu:

Shahid.?

F.
His Plans to Conduct a Te:

25. On March 27, 2019, DC

)out me.

They don't care about

hat Allah would reward DOMINGO for

ied ?But you know A lot

1ese Kuffar that start the beef,

hey do, yeah.? DOMINGO replied,

I?m gonna finish it. You know,
nish it. Like we can handle it
throwing bullets at each other,
I'll die

der me, kill me,

DOMINGO Speaks with the CH5 on March 27, 2019 to Discuss

rorist Attack

called the CH8 via the

 

platform to tell the CH8 that
wanted to kill him. DOMINGO i

of the ?Ummah?14 and said thati

 

Based on my training an:
the term the deen is an Arabic
religion.

Based on my training an<
Ummah is an Arabic word referri
community of Muslims.

15 Based on my training an<
term ?halal? is an Arabic word
DOMINGO also made reference to
neighbor involving trash on DOE

I

was upset with his neighbor and
entified the neighbor as an enemy

1is blood was ?halal.?15 The CH8

1 experience, I understand that
word referring to one's faith or

1 experience, I understand that
-ng the worldwide nation or

1 experience, I am aware that the
meaning religiously permissible.
a personal dispute with the
IINGO's lawn.

12

 

repeatedly tried to calm DOMINC
were in the ?heart of the enemj
around the corner,? there is n<

26. DOMINGO said he coulc
burglary, and that murders go 1
said they needed to ?start smaI
attack of a larger scale, becaL

the first time. DOMINGO said 

would test the response time of the police,

response time would likely be 5

Base.

30 down.



unsolved all the time.

DOMINGO said that they



and that if is just

)thing DOMINGO can do.

1 stage the attack like a

DOMINGO
before building up to an

lse they were bound to ?fuck up?
-f he killed his neighbor, it
and that the

slower than at a National Guard

 

G. DOMINGO With the CH

on April 3, 2019 and Preposes

Using IEDs and Firearms Attack Police Officers and

Military Service MEmbers

27.
met in person. The meeting wa
During that meeting, as detail
intent to commit a large?scale
and described using firearms ar

28. DOMINGO told the CH8

they both spoke to on the plati

The CHS said the person ?was ta



and DOMINGO told that person,

That would do damage. 

blows up on the freeway,
citizens injured.?

said ?Then the fun starts.?

On the evening of Ap il 3,

I

When the CH8 asked

Los Angeles

2019, the CH8 and DOMINGO
audio and video recorded.

.d below, DOMINGO reaffirmed his

attack in the Los Angeles area,

1d IEDs to do so.

that he was jealous of a person

form who had more guns than he.

leing about like IEDs and stuff,?

?an IED here, on the freeway?

An IED, like the ones in Iraq 

tundreds and maybe thousands of US

?And then what?? DOMINGO

l3

 

29. DOMINGO stated he wan

DOMING

Ramadi? and ?Fallujah.?

get, like, that will get like 

you bro, just the one IED that'

nest, bro.?

30. DOMINGO reiterated hi

?our brothers in Christchurch a

slaughtered.? DOMINGO also sai
martyr."
31. DOMINGO said his plan

rather than engage in a battle

DOMINGO said he intended to ?ki



-.

we flee, similar to the ?insur
they caused ?small casualties 
the stress? on America and leac
32. DOMINGO said that alt
was more like the tactics used

prefer to operate like ?al?Bagt

was not feasible because he anc

manpower to succeed in such a 
for ISIS and said if ISIS ?came
to ISIS.

33. The CHS said law enfc
Turkish man who had recently ki

Netherlands. DOMINGO replied 

 

Based on my training anc
is a reference to Ayman al?Zawa

:attle.

ted to ?make ?em bleed, like in
0 said, ?a dead police that will
he police riled up. But I need

3 going to stir up the hornet?s

intent to conduct an attack for
nd our sisters who were

he was ?not afraid fast? and ?raid,?
and try to ?hold positions.?
then

ll enemies here and there,

gency? in Iraq. DOMINGO said if

Lere and there,? that would ?put

1 to martial law.

Qhough such a hit~and?run strategy
by ?Zawahiri,?15 and he would
Ldadi? and fight a ?battle,? that
the CH3 did not have enough
DOMINGO expressed support

here,? he would swear allegiance

rrcement in Europe had caught the

lled three people in the

hat he ?had a feeling they were

1 experience, I believe ?Zawahiri?
.hiri, the leader of Al?Qa?ida.

l4

 

gonna catch him,? and explaine<
and crowded, and ?he probably 
said ?you have to be patient."
T1

you know, I want to do it.?

want to do, show me.?

34.
small.? DOMINGO then drew a d:
scenarios for how he could atta
described a scenario in which I
also described another scenaric
ballsy," in which he and the 
car stopped at a red traffic lj
shoot into the car. DOMINGO sa
its windows down while he and 
car in their first meeting, on
clarified that,

his car to ?burn the vehicle, 1

oil, [or] gasoline,? in order 

police car, causing a longer ir

little more difficult.?

that?s all I can do to these k6

35.

diagram18 he had drawn,

 

Based on my training anc
?dawla? is commonly used by Vic

The CHS later recovered

law enforcement was able to rea

iidn't plan it right.?

DOMINGO said ?So what I'm thinking is,

ick police officers.

1e could attack LAPD officers.

in this scenari

DOMINGO then stated ?Inshallah,

Later during the meet

and toL

i that the Netherlands is small

The CHS

DOMINGO replied ?Oh I know but

1e CHS replied ?Show me how you

yea, we start

-agram and explained multiple

He then

He
which he described as ?really
IS would pull alongside a police
_ght with its windows down and
lid he had seen a police car with
.he CHS were riding in the CHS's
March 18,

2019. DOMINGO later

0, he would want to get out of
.ike dawla?? with ?lighter fluid,
:0 destroy the cameras in the
[vestigation and making ?life a
if

I?m down.?

lffir, then wallahi,

.ing, DOMINGO ripped up the

the CH8 they had ?just talked

1 experience, I know that the term
_lent extremists to refer to ISIS.

the pieces of the diagram, and

ssemble them.

15

 

about some serious shit,? incll

?murdering people.? DOMINGO be




with the CH8 would result in
warned that the CH8 was in ?dee
discussion with the CH3 could I
and told the CH8

?We broke fede

Ican?t expect to do these kind 
forever At some point,
be a man and you gotta stand yc
out that they could get caught

we're gonna die shahid.?

H.

36.
with the CH8. DOMINGO arrived
holding a backpack containing

covered by what appeared to be

the CH5 expressed surprise that

DOMINGO replied ?If we?re going

commence fighting, jihad, yeah,

remain.? The CHS said the CH8

caught carrying a gun, and DOMI

Los Angeles to carry a gun.

remarked again that when DOMING

 

Fi sabillillah is an Ara
God/jihad in the way of God,? 

the cause of God.?

DOMINGO MEets With the CHE
Using IEDs and Firearms tc

On the evening of Apr



La

1ding ?murdering police? and
elieved what he had just discussed
1 lot of charges already? and

3p shit.? DOMINGO believed his

:esult in a ?conspiracy charge?

eral law.? DOMINGO said ?You

3f things and remain anonymous
they're gonna know and you gotta

:ur ground.? When the CH8 pointed

eventually, DOMINGO replied ?Then

i on April 19, 2019 and Discusses
Attack an Upcoming Rally

?il 19, 2019, DOMINGO again met
wearing camouflage pants and
Ln style rifle partially

a shirt. Upon arrival,

he had brought the rifle, and

I to commit?? if we?re going to

fi sabilillah,19 you gotta

did not want DOMINGO to get

NGO replied that it was common in

ter in the night, the CH8

.0 arrived with the rifle, the CH8

ibic term meaning ?In the way of
rr ?for the sake of God,? or ?for

16

 

thought he was crazy, and DOMII

you that I?m serious.?

37. DOMINGO asked about I

refer to individuals located OL

said ?If you want, you know wha

ready, huh? You?re not ready.?

?really thinking about it? for

see how serious? DOMINGO was.

added, ?if you're not ready tor

?you want to do it tonight? Wk

know, and was tired, but that i

for Christians, who were celeb:

CHS said, ?so that's it? You 9

where?? DOMINGO said,

serious. Are you serious?? DC

sooner or later, this was gc

38. The CH3 and DOMINGO 

DOMINGO said, ?We don?t have tc

brothers and sister across the

39. During the meeting, 

like, DOMINGO said, 

you want to, I might know somec

know someone, that's perfect 

make it?" The CHS said he did.

 

20 Based on my training an<
the facts, DOMINGO seemed to St
shooting homeless people.

lomeless people
1tside the meeting location),

it I?m saying20

?Anywher

JGO replied just wanted to show

(appearing to
and


The CHS said the CH8 had been

You?re not

the past two weeks and ?wanted to

DOMINGO said he was serious, and

Light, then okay.? The CBS said

Lere?? DOMINGO said he did not

.t was a ?holy day for yahud? and

?ating Passover and Easter. The

ranna do it? You have, like,



e. The CHS replied, ?You're not

replied, ?I?m serious 
nna happen.?
hen prayed and ate, after which

do this. But we do this for our

world, oppressed, yeah??

he CHS said, ?So you remember,

want to?? The CBS said, ?if



ne. DOMINGO replied ?If you
but does he know how to

DOMINGO said ?So he can write

1 experience and the totality of
ngest an attack in the form of

17

 

down instructions on how to ma

?Probably.? The CHS said the 

said ?Okay, tell him this. er

clearly, and then wallahi.
be

The CBS said ?Hc



masse, you know that

buying guns.?
buy it little by little 

CHS said, ?but where can you bL

)erson was from Iraq.

)w then??

1y it from??

it?? The CHS replied,

DOMINGO

-te down the instructions,
You can't buy these ingredients en

ecause that's more suspicious than

DOMINGO replied, ?We'll

so it?s not suspicious.? The

DOMINGO replied by

namin three home im rovement stores and said ?The ?re


everywhere. Here?s the thing,
explosives.? The CHS said, ?tr
it's easy. It?s not easy, but

time into it, everyone can make
wallahi, they don't want to.
Only a terrorist would want to,

40. During the meeting,

more damage and would be better

make it, I just don?t know how.

1ey can??

Because,

DOMINGO said,

the average person can make
DOMINGO said, ?Yeah,
it's not hard. If they put the
explosives. But obviously,
you know, why would you?
right??

?The IEDs would do
- 

to transport We?ll both

I'll be honest. I'm smart in

 

history but I failed chemistry.
So if that brother is willing

said, ?Should I talk to him?

replied, ?Talk to him, if not

make it, don't force him. But
Fucking to the letter details.



41. DOMINGO then asked,
you think he?ll tell the feds??

guarantee he?s not going to.?

Science is not my forte 

If


0 make it for us. The CHS

Ihat do you think?? DOMINGO
If he doesn't want to



ake it.
ask him how. Details.
Ask him.?

Do you think he's a snitch? Do
The CBS replied, can

DOMINGO replied, ?If he's not

18

 

gonna tell the feds, then you 1

?but he's not gonna, like,

replied that was OK, and ?if hf

make him take part. But that
and we should ask him, if you'J
least teach me how??

42. DOMINGO instructed t1

what was happening to Muslims._

you know, like, bro, al?Sunnah

I know you have a family and 
asked how the CH8 knew the associate,
at the same Mosque and the assc
?does 

America. DOMINGO said,

have the same ideas.?

:an talk to him.? The CHS said,

DOMINGO

3

.-

doesn?t want to take part, don?t

l5 an avenue we shouldn?t waste,

:e not gonna helpremind the associate
DOMINGO stated ?just remind him,
wal?Jummah is under attack. And
not gonna force you.? DOMINGO
and the CH8 said they were
)ciate had been criticizing

1e hate kuffar?? The CBS said ?He

 

hates kuffar, but because he has a family,

DOMINGO replie



Like

get involved.?
Talk to him some more
you ever made explosives?
and pieces.?

43. DOMINGO also brought
rally in Long Beach organized 
and told the CH8 it was going 
CHS asked, ?So what's the plan
We?ll hav

scope out the area.

CHS asked DOMINGO how he heard



he heard about it on the news

DOMINGO wanted to carry out the

1

about the rally, because at any point they can cancel it.?

he doesn?t want to

?That?s understandable 

.ou can be casual about it. Have

a, haha, a joke. You can get bits

up an upcoming April 28, 20l9

3y a ?white nationalist? group,

:0 take place at Bluff Park. The

 



DOMINGO said, ?We'll have to
to keep up everyday updates

The
about the rally, and DOMINGO said
1nd online. The CHS asked how

attack, and DOMINGO said,

19

 

?Parking's gonna be an issue.
We drive by, we empty a magaziI
it.?

44. The CHS asked ?but yc
damage?? DOMINGO replied that

and ?we can make it before. It



if we make it before,

ask your brother. Ask
we can ac
and said ?Detonate. Yes we car
would be perfect.?

45. DOMINGO then reiterat
make the IED himself, and said,

I need you to make sure he?s nc

the CH3 to ?have him write it down,

make it. Even a small IED woul

The human body is very easy to

.-



damage, but a big IED just in

looking at least 20 people deac

so around 50 at least.? The 

headline.? DOMINGO replied, 

are going to storm. Remember 

bombers, it stirred up a hornet

is going to be locked down.?

46. The CBS said ?are 

serious are you serious?? DOMI

C:
L.

to do the IED route, which is

will do a lot more damage crowc

We could do hit and run



1e or two. An AK. And we book
Du said the IED will do more

?the IED will do more damage,?
1's coming up. We have two weeks
the brother." The CHS said ?so
DOMINGO interrupted
1 detonate it in a crowd. Which
:ed that he did not know how to
need you to talk to him, and
at a snitch.? DOMINGO instructed

We can



and then we?ll see.



do damage in a crowd.

break. A grenade can do a lot of

backpack, in a crowd? You?re

1, maybe, maybe 30 people injured,

said, ?That's going to be the

think if we do the IED route we

he Tsarnaev brothers, the Boston

3 nest If we do this, LA

sure you want to do this, I am

NGO replied am serious, I want
omewhat the better idea. An IED

wise. We bring it and leave it

20

 

in the car. We each bring a d:

we can escape we can 
we possibly can change in the 
injured and take off clothes a1
one in plain sight. So if the
serious and a better plan than

47.

different clothes, and DOMINGO

leave the IED in a crowded spot.

have an IED and they cancel??

Lfferent set of clothes so


:hange in the car, be honest bro
:rowd. We can pretend we are
1d change. The best disguise is
IED thing is sounding more

going spraying and praying.?

The CHS asked if they would be able to change into

Ireplied ?Perhaps, we are going to



The CHS asked ?what if we

DOMINGO replied now we have

 

an IED that we can use at our disposal.?

DOMINGO Purchases and Sup?lies Materials to Create and Use

2019, tie CHS wrote in a private message

I.
a Weapon of Mass Destruction
48. On April 22,

to DOMINGO talk to the brot

help us but we have to get him

to come tomorrow to pick it up.

?get it all,? and the CH8 said

purchasing different parts of 

detection.
So your part is:
shrapn[el] We have to buy the

to come tomorrow to pick it up

the pressure cooker and a remot

about nails??

whatever goes inside.?

The CHS said wil

Chri

er and he said he's willing to
the stuff tonight And he?s going
DOMINGO asked if the CH3 could
no, they should split up

.he IED so they could avoid

.1 buy some and you will buy some
.stmas lights but no LEDs And

part tonight because he's going
so he can build it And I will buy

.e control.? DOMINGO asked ?what

The CHS said ?Like nails or [screw] driver

21

 

49. Shortly thereafter,
DOMINGO drive to multiple home
officers saw DOMINGO purchase 5
a self-service kiosk using a de
closed?circuit television videc
store, which showed that DOMINC
pounds of three?and~a?half?incr
card.
50. Later that day, 
?u wanna try pick up what I 

said ?Maybe today because we he

DOMINGO replied ?got nails look

CHS would look for the lights 
can reimburse you tomorrow.?

51.

I

with the CH8. The meeting was

)uy

Lve

On the evening of Apr

law enforcement officers observed

improvement stores. At one store
several large boxes of nails from
abit card. Agents later obtained
and transaction records from the

SO purchased approximately eight

1 and longer nails using his debit

IGO wrote the CH3 again and asked

today or tomorrow.? The CHS

to give it to him tomorrow.?
The CHS said the

in for 

he next day, and DOMINGO replied

il 23, 2019, DOMINGO again met

audio and video recorded.

DOMINGO walked in with a bag containing the boxes of nails he

had purchased the day before.
control race cars that the CH8
table.

52. The CBS told DOMINGO
this.? DOMINGO said that the 
cancelled, and proposed attacki
Nationalist? rally in Huntingtc
April 27, 2019. DOMINGO said 
be on the beach, which may make

many people because it was a wi

DOMINGO examined boxes of remote

had obtained and placed on the

that they ?don?t have to do

vent in Long Beach may be

ng a different ?White

an Beach, California, on Saturday,
.he Huntington Beach rally would
a it more difficult to kill as

de open space. DOMINGO said the

22

 

Santa Monica Pier would provide a better space for an attack,
particularly during the summer when it was crowded, because it
was a more enclosed space and people would not be able to escape
from a blast. DOMINGO said that detonating an IED with a timer
on the Santa Monica Pier would cause a lot of casualties.

53. DOMINGO confirmed that he had bought three?inch nails
to provide to the UC to use in making IEDs. DOMINGO said he
specifically bought three?inch nails because they would be long
enough to penetrate the human body and puncture internal organs.

54. DOMINGO examined the remote control cars that the CH8
had purchased and saw that the remote controls would work only
up to a distance of 100 feet. DOMINGO expressed concern that
the blast radius would extend beyond 100 feet. The CBS said
perhaps the remote controls could be modified so that they would
work from a distance of more than 100 feet. DOMINGO then said
that if they conducted the attack at the Santa Monica Pier, he
would remain on the pier and detonate the IED, but the CH8
should stay further away and leave the scene after the IED
detonated. DOMINGO said he would bring his gun, and was not
afraid to die a martyr.

55. DOMINGO showed the CH8 a map of the Santa Monica Pier
on his phone, and pointed out locations-where they could stand
near the entrance to the pier.

56. After about 45 minutes, the UC arrived. DOMINGO asked
the UC if the remote control cculd be modified to detonate the
IED from up to three quarters of a mile away. DOMINGO showed

the UC the boxes of three?inch nails he had bought, and told the

23

 

UC the nails were long enough 1
long as the nails did not get 
57. DOMINGO explained to

discussing a very serious matte

a crime. DOMINGO asked the UC
the IED, and the UC said it WOL
58. DOMINGO asked again a

remote control, and the UC sugg

instead of a remote control to

replied that ?would be perfect,

bail? and watch the blast from



I.

59. DOMINGO said they

operation because he wanted to

experience Ramadan, which woulc

UC again said they should all 5
other.
60. DOMINGO gave the UC i

get back in touch in a few days

should talk only on the platfor

that what they were talking abc

offered to buy more parts for 

said he would let them know whe



the operation and when the UC

asked how he would know when DC

complete the IED. DOMINGO saic



containing a photograph, like

ahead? for the Operation.

:0 kill their intended victims,

2r,

SO

)ent in the blast.

the CH8 and the UC that they were
and even talking about it was

how long it would take to make

take a few days.
1bout the lOO?foot reach of the

Jested they could use a timer

detonate the device. DOMINGO
because with a timer ?we can

a safe distance.

should consider delaying the

finish reading the Quran and

1 be starting on May 5, 2019. The

Lgree they would not pressure each

1is phone number and said he would

DOMINGO stressed that they

I.

m, and cautioned the CH8 and UC



aut were ?federal chargesneeded them, and
:n he was ready to proceed with
hould complete the IED. The UC
JMINGO was ready for him to

he would send the UC a message

?meme,? which would be the ?go

24

 

J. DOMINGO Finalizes His Attack Plans

61. On the evening of April 24, 2019, DOMINGO spoke to the
CH8 online. DOMINGO said was angry and had a rough day at work.
The CHS said the UC had said people were talking about going to
the Long Beach rally so it seemed the rally was really
happening, and they could execute the operation as previously
planned.

62. DOMINGO replied that he did not want to rush into the
operation, and since they had talked about waiting until after
Ramadan, he did not want to call the UC now and rush the UC to
finish making the IED. DOMINGO said if he had known yesterday
that the event was going to go forward, he would have wanted to
proceed with the operation. The CHS replied that the UC said
the IED could be ready in time for the event, and they could use
the timer to detonate it and watch the explosion from a safe
distance. DOMINGO said, ?the timer is great,? but said, ?Lets
not rush into this headfirst. If I give the go ahead . 
one of us will have to drive to Victorville? to collect the
completed IED from the UC, or perhaps meet the UC halfway.

63. The CHS replied it would be great to watch the
explosion from a distance, and DOMINGO agreed it ?would be cool?
to watch it but ?ideally we should be gone? because everyone
would be panicking and their calm demeanor may arouse suspicion.
The CHS said they could set the timer and then go home and watch
the blast on television, and DCMINGO said he did not need

publicity, and would ?rather just hear about it on 4chan.?

25

 

DOMINGO said, know it's gonr
sleep on it.?

64. The CHS said the CH3
operation,
complete the IED. The CHS saic

not contact the.UC over the 

and DOMINGO asked if

i no,

1a be big. 

Let me just
was ready to go forward with the
the CH8 already told the UC to
and DOMINGO said they should
>ne.

DOMINGO continued, ?Fuck,

 

it?s a good opportunity.

he was worried they were ?rush

wanted to act while they were all

to be ?calculated.? He contin

on it. If [the down, I

But let

me sleep on it.? DOMINGO said



into this too hastily, and he

ng
?motivated,? but also wanted
ed say me and you we'll sleep

on?t have a problem with it.?

The CBS said they could proceei with the operation and still

conduct more attacks after Rama

Let's just sleep on it. If we'

the go?ahead. I'll give the gc

65. The CHS suggested the



before the event, but DOMINGO



because people might see it. I
in a trash can to conceal it, 
attendees would be unlikely to
putting the IED in a trash can
deaths. DOMINGO proposed inste

it?s happening? and place the I

Ldan, and DOMINGO replied ?We can.
re still as motivated, we'll give
>?ahead.?

:y could place the IED the night
aid that would be too risky

?he CHS suggested placing the TED
aut DOMINGO said the rally
gather near a trash can, so
would not result in-a lot of

:ad that they go to the event ?as

ED where people were gathering.

The CHS offered to carry the IED into the event, but DOMINGO

replied, was thinking I'd dc
said the UC also could blend ir

was Caucasian.

DOMINGO repliec

it. I?d blend in.? The CHS
with the ?Nazis? because the DC

1 he was ?ready,? but ?this shit

26

 

we're talking about isn't easy.

they sleep on it, and if ?we?re
then DOMINGO would contact the

66. The next day, at app:
sent the UC a message oontainir
and skyline. Based on my trair

of this investigation, I beliex

3

a

:oximately 12:00 

f!

DOMINGO suggested again that
still feeling pumped by lunch,?
UC to proceed with the operation.

DOMINGO

1g a photograph of a crescent moon
ling and experience and knowledge

re this was the ?go ahead? meme

that DOMINGO had told the 00 he would send when he was ready to

proceed with the operation.
67. The UC responded,
wrote ?im waiting for the homie

gonna be on the weekend?? The

presents to make them fit in at

?Okay I hear and obey.?

as text,

DOMINGO
I think the kick back is
UC replied need to wrap the

the party spot.? DOMINGO wrote

 

?okk do what you need to do th

. party is on the weekend tho 

didn?t have to do all this tod The UC responded that it was

OK and ?the presents will be 
replied ?if ur sure ok then kee
with em.?

68. The UC asked DOMINGO
?presents? and asked ?do you kr

like? I-want to match the wrap

DOMINGO replied ?you don't have

bag y'go thru the trouble.?
69. The next morning,
UC, ?are you coming to 

finish the last piece of the p:

the presents somewhere safe 101.

Apr

Tr

.ady tomorrow morning.? DOMINGO

2p em somewhere no one will fuck

for help with wrapping the

what the party spot looks
aping with what?s natural.?
something like convenient like a
'il 26, 2019, DOMINGO wrote to the

Le UC replied ?Yeah akhi after I



27

 

?esents.?

DOMINGO replied ?keep

The UC said the UC wanted to

?stay in la for the party? and
sure [the couch is good

70.

someone and the UC replied ?we

sha Allah heading to [Victor]v:

idea.?

platform] considering our scheds it shud be simple 

DOMINGO replied ?ok no prob im



DOMINGO said he was going to Victorville to see

need to plan the party today in

.lle after the party is a good

DOMINGO replied ?I?ll talk with [the on [the

tho

find the parties address and show up but like I Said the prayer

times so we'll jus say hi go

place is crucial Youre good at

?im just practical albeit blunt

71.
groceries, pray, then

wrote ?u want me to pick up?

mean I think the party is on sunday 



kno.
DOMINGO replied ?if you insist
agreed to meet the finalize plans for the operation.

audio and video recorded. The

what DOMINGO thought were compl

DOMINGO said he was going to work out,

?ill be on my way afternoon.?

The UC wrote that they I

At approximately 7:15



. The UC said ?0k inshaAllah
this akhi,? and DOMINGO replied
as shit.?

shower, get
DOMINGO
Is that what had in mind??



leeded to meet that day and

I

so we got time ya

prolly later tonight then,? and

at 7:00 p.m.

DOMINGO met with the UC
The meeting was
UC showed DOMINGO how to operate

eted IEDs. DOMINGO said they

should set the timer on the IEDs for 5 to 30 minutes.

73.

Long Beach to surveil the location for the attack.

drive,

DOMINGO then drove tr

DOMINGO said the plan Bluff Park in
During the

to arrive early in the morning

on Sunday, before too many people showed up for the rally, and

28

 

disguise themselves as counterv
past the Port of LOng Beach, DC
they survived the attack on 
attacks, including at the Long
would significantly disrupt the
discussed initiating an attack

74. When they arrived at

the location with the UC and CH3.

to find the most ?crowded? area

people in the attack. DOMINGO

after they detonated the explos

a U.S.

-protestors. As DOMINGO drove

told the DC and CH8 that if

lday, they could conduct further
Beach Port, which DOMINGO said
economy. DOMINGO also
on a train.
Bluff Park, DOMINGO walked around
DOMINGO said they should try
[8 in order to kill the most
instructed the UC and CH8 that

.ives, they should walk away from

 

the event in separate directio
leave the scene without being
75. After
and CH8 back to their previous
again-inspected the IEDs in ads
then carried one of the IEDs or
UC's vehicle,






at which point he

1

surveilling th.

and get in separate cars to
etected.

location, DOMINGO drove the UC
meeting location, where they
'ance of their attack. DOMINGO
Lt of the location to put into the

was arrested by the FBI.

29

 

V. CONCLUSION

76. For the reasons described above, I respectfully submit
there is probable cause to issue the requested criminal

complaint and arrest warrant.

 

 

Special Agent
FEDERAL BUREAU OF INVESTIGATION

Subscrib ,o and sworn before
me this day of April, 2019.

63/ 

 

UNITED STATES MAGISTRATE JUDGE

3O