Case Document 1 Filed 08/09/19 Page 1 of 11 3" NICHOLAS A. TRUTANICH 113 E: 9 United States Attorney District of Nevada 2019 ELIE ?9 ME 9: Nevada Bar Number 13644 . 1 NICHOLAS D. DICKINSON 15.5. E?Sihsig- 'a {Li t; National Security Civil Rights Section. 3 Assistant United States Attorney 501 Las Vegas Blvd. South, Suite 1100 Las Vegas, Nevada 89101 Phone: (702) 388-6336 Email: gov Attorneys the United States of America Counsel ?Jr the United States UNITED STATES DISTRICT COURT DISTRICT OF NEVADA -000- UNITED STATES OF AMERICA, I COMPLAINT Magistrate No. Plaintiff vs. VIOLATIONS: 18 U.S.C. 5841, 5861(d) and 5871 CONOR CLIMO, Possession ofczn Unregistered Firearm Defendant. BEFORE the United States Magistrate Judge, Las Vegas, Nevada, the undersigned Complainant, being duly sworn, deposes and states: Count One (Possession of an Unregistered Firearm) On or about August 8, 2019, CONOR CLIMO, knowingly possessed ?rearms, speci?cally destructive devices, as that term is de?ned in Title 18 United States Code, Section 5845(f), that were not registered to him in the National Firearms Case Document 1 Filed 08/09/19 Page 2 of 11 Registration and Transfer Record. All in Violation of Title 26 United States Code, Sections 5841, 5861(d) and 5871. AF FIANT EXPERIENCE 1. I am a Special Agent with the Federal Bureau of Investigation and have employed by the FBI for approximately 10 years and have 5 years of experience as a police of?cer with the York City Police Department, York I am currently assigned to the Las Vegas FBI Joint Terrorism Taskforce and I am responsible for investigating Domestic Terrorism, including Racially Motivated Violent Extremism. 2. The following information contained within this criminal complaint is based upon my participation in this investigation or information provided to me by other TTF members and law enforcement personnel. Because this Af?davit is being submitted for the limited purpose of securing a Criminal Complaint, I have not included each and every fact known to me concerning this investigation. I have set forth only those facts that I believe are necessary to establish probable cause for the above listed offense. All times noted are approximate. PROBABLE CAUSE 3. In April 2019, The Las Vegas JTTF began actively investigating Conor Climo based on information that CLIMO was communicating with individuals who identi?ed with the white supremacist extremist group Atomwaffen Division AWD is a White Supremacist Extremist Organization using the National Socialist Movement to promote their ideology. AWD membership consists of mostly white males between the ages of approximately 16 to 30 years of age who all believe in the superiority of the white race. AVVD utilizes a ?Leaderless Resistance? strategy in which small independent groups, or individuals called ?Lone Wolves,? try to achieve a common goal of challenging the established laws, social Case Document 1 Filed 08/09/19 Page 3 of 11 order, and government via terrorism and other violent acts. AWD encourages attacks on the federal government, including critical infrastructure, minorities, homosexuals, and Jews. AWD works to recruit like?minded members to the organization, train them in military tactics, hand to hand combat, bomb making, and other techniques in preparation for an ?ultimate and uncompromising Victory? in a race war. Because one of goals is to maintain anonymity, members primarily communicate using online chat applications, such as Wire and Discord. Wire is an communication program on which users can transmit text messages and ?les. Discord is an application designed initially for the video gaming community that specializes in text, image, video, and audio communication between users in a chat channel. Both applications for Wire and Discord can be downloaded, used, and stored on any computer, tablet, and cellular telephone. 4. In 2016, a local Las Vegas news report featured CLIMO patrolling his Centennial Hills neighborhood carrying an style assault ri?e, four magazines each containing 30 rounds of ammunition, and wearing a tactical vest. 5. An open source search revealed a Quora social media account registered to CLIMO. Quora is an American question-and-answer website where questions are asked, answered, and edited by Internet users in the form of opinions. On January 1, 2017, CLIMO answered the following question on Quora: ?What are the downsides of multiculturalism?? CLIMO ended his answer with the following: ?To quote a Nationalist: ?your most precious possession on this earth is your people!?? This quote is from Adolph Hitler and is regularly used by extremist individuals and groups. Additionally, profile picture on his Quora account is of an 5 style rifle which resembles the ri?e he used in 2016 to patrol his Case Document 1 Filed 08/09/19 Page 4 of 11 Centennial Hills neighborhood. As discussed below, CLIMO also used a ?rearm as his pro?le picture on his Wire account. 6. In May 2019, an FBI con?dential human source who has provided reliable and accurate information in the past, established contact with CLIMO on the Wirecom online chat application. The CHS told CLIMO that the CH8 was a ?far- right ally? who found a website identifying CLIMO as a member of AWD. From that point on, CLIMO maintained regular contact with the CH8. Wire pro?le picture is a photograph of a bolt-action ri?e. 7. During initial conversations with the CH8, CLIMO acknowledged being in the Las Vegas area and owning a Compact 92fs firearm. CLIMO discussed, in detail, 110W to build a ?Self Contained Molotov? by using ?gasoline sulfuric acid inside a Double Magnum Wine Bottle.? 8. During conversations with both the CH8 and an FBI Online Cover Employee CLIMO would regularly use derogatory racial, anti-Semitic, and homosexual slurs. 9. On or about May 10, 2019, the CH8 had an online conversation with CLIMO during which Climo discussed setting ?re to a synagogue and making Molotov Cocktails and Urea Nitrate Improvised Explosive Devices CLIMO stated that in October 2017, he tried to recruit a homeless person to conduct surveillance on a Las Vegas area synagogue, but ultimately failed. 10. On May 23, 2019, an FBI OCE, with experience and training investigating violent white supremacist extremist groups and individuals, established contact with user CLIMO on the Wire online chat application through an introduction by the CH8. During their ?rst conversation, the FBI OCE states that he/ she heard CLIMO was ?someone Case Document 1 Filed 08/09/19 Page 5 of 11 worth talking to.? CLIMO replied, am more interested in action than online shit.? After discussing his military experienceI with explosives and IEDS, CLIMO talked about being a security guard living in Las Vegas. ll. The FBI OCE asked, ?What are you looking to do with the group? What are your goals?? CLIMO replied, ?Mainly help out as best as I can further the cause.? The FBI OCE also asked, ?What have you been involved with before?? CLIMO responded, ?Also I live in Las Vegas have found a ADL Headquarters at 215 Eastern.? I believe CLIMO is referring to the Anti-Defamation League which is an international Jewish non governmental organization based in the United States. The ADL has an of?ce in Las Vegas. 12. Ibelieve that stated intent to ?further the cause? references desire to engage in anti-Semitic and Antiahomosexual violent extremism. My opinion is based on discussion of the ADL and as set forth below, plans for committing Violent attacks both on a synagogue and a bar CLIMO believe catered to homosexuals. 13. In another online conversation between the CLIMO and the FBI OCE, CLIMO offered the book ?Total Resistance? as a good guide to use when selecting a target. The book explains guerrilla warfare tactics and how to implement them against an enemy. CLIMO further discussed identifying a power plant as a good ?soft target,? and suggested targeting police leadership as ?Tactical Value Targets,? and ?low level political targets (as part of TAC- I believe that TAC-VT is an abbreviation for tactical value targets. 14. On or about June 19, 2019, CLIMO talked with the CH8 about various weapons. During the conversation, CLIMO said, ?Plus a bolt gun is good enough for me.? The CHS An analysis of military records showed that he greatly exaggerated his military and tactical experience. CLIMO was discharged from the military after approximately ll months for actions related to not being able to perform speci?c required duties. Case Document 1 Filed 08/09/19 Page 6 of 11 replied, ?Oh yeah. Bolt ri?es are, IMO highly under rated. Yes yes, you should keep a battle ri?e of some sort, but pretty much any decent caliber ri?e can pop any body armor.? CLIMO responded, ?Yea. Though groin leg shots are good for luring combatants.? Later in the conversation, CLIMO stated, ?Hell and White Phosphorus can be made via distilling pee. Add that shit to a good mix of Tiki Torch Oil Napalm BBQ Kikes.? The term ?Kike? is a derogatory racial slur used to describe members of the Jewish community 15. Between June 19, 2019 and July 8, 2019, during online conversations with the FBI OCE, CLIMO discussed conducting surveillance on Fremont Street in Downtown Las Vegas in preparation for a potential attack and described in great detail the geographical layout of the area. At the beginning of the conversations, the FBI OCE asked, ?Sounds like you have some solid plans in place. Got any plans for a goodbye to Vegas?? CLIMO responded, ?Still thinking on that.? The FBI OCE asked CLIMO, ?You been doing any recon lately? Putting the intel prep into practice?? CLIMO responded with a detailed description of an area around Fremont Street in Downtown Las Vegas, speci?cally noting a bar that CLIMO claimed catered to homosexuals. 16. Between July 8, 2019 and July 15, 2019, during online conversations with the FBI OCE, CLIMO provided more detail about his plan to carry out an attack on a Las Vegas synagogue. CLIMO first sent the FBI OCE sending screenshots of Google Maps images of synagogues in the Las Vegas area. One of the images contained the message, ?Also! Screenshot a group of Kike Synagogue locations in Vegas. CLIMO proposed using an attack against homeless people as a test run for attacks against synagogues community centers. CLIMO stated that he lived close to one of the synagogues on the map and that there was also a mosque close to that synagogue. Case Document 1 Filed 08/09/19 Page 7 of 11 17. CLIMO discussed attacking the synagogue close to his home. In short, CLIMO proposed attacking the synagogue using an incendiary device combined with a ?Light Infantry Weapon Attack.? CLIMO further discussed a plan for escaping after the attack and sent the FBI OCE a screenshot of an image from Google Maps of a satellite image of the area around the synagogue focusing on the escape route. . . . l8. CLIMO also discussed h1s plan to the same synagogue the CH8. During that discussion, CLIMO described how to make an explosive device. 19. On August 8, 2019, the TTF executed court authorized federal search warrants at residence. During the search of CLIMO bedroom, which both aunt and mother identified, FBI Special Agent Bomb Technician (SABT) Anthony Telenko located a bottle of ?Pot Perm Plus? Potassium Permanganate, which can be used as a strong oxidizing agent, on the top shelf of bedroom closet. Also located on the closet shelf were separate jars of thermite, sulfuric Acid and lithium aluminum hydride, which can be used as fuels. SABT Telenko further observed a soldering iron, wires, circuit boards, and other electrical components in bedroom that are consistent with items needed to construct an (Improvised Explosive Device) circuit. A green colored notebook containing numerous hand drawn schematics of IED circuits was also located in bedroom. SABT Telenko reviewed the hand drawn schematics and determined they were consistent with the items and circuitry needed to function a timed explosive device. 20. In the garage of the house SABT Telenko located multiple large commercial ?reworks, empty ?rework ?mortar? tubes, and more than ?ve feet of hobby fuse, multiple cans of brake ?uid, and additional fuels. Hobby fuse is commonly used in consumer ?reworks and used to create a delay in ?reworks or other explosives. Case Document 1 Filed 08/09/19 Page 8 of 11 21. Based on SABT Telenko?s training and experience he is aware that the both oxidizing agents and fuels are common compounds that are used in producing Home Made Explosives (HMES). HME can be initiated by heat, shock and friction, including though the ignition of a hobby fuse. By placing HMES in items, such as empty firework mortar tubes, they can be initiated with hobby fuse. 22. Based on SABT Telenko?s training and experience, the above described item?s found in bedroom and garage could be used to readily assemble a destructive device as defined in 26 U.S.C. 58456). 23. According to the Bureau of Alcohol, Tobacco, Firearms, and Explosives, CLIMO has no firearms or destructive devices registered to him in the National Firearms Registration and Transfer Record. 24. During the execution of the search warrant, CLIMO agreed to voluntarily talk with me. Based on statements, there is signi?cant evidence that CLIMO intended to use the above described item?s found in his bedroom and garage to assemble a destructive device. 25. During the interview, CLIMO provided the following information. For several years, CLIMO has studied and experimented with the making of explosive devices. CLIMO harbors biases and hatred toward various racial and religious groups to include African- Americans, Jews, and Homosexuals. Toward the end of 2017, CLIMO began to communicate online, through the chat application Discord, with members of the Neo-Nazi group, The Feuerkrieg Division FKD is a splinter group of the white supremacist extremist group, Atomwaffen Division and shares the same ideology and beliefs. For greater anonymity, CLIMO and FKD began using an chat application though Wire. Case Document 1 Filed 08/09/19 Page 9 of 11 26. CLIMO ultimately became a member of FKD because the group was interested in his knowledge of constructing explosive devices, and because he was interested in and shared the same white supremacy extremist views of the group. Additionally, CLIMO wanted to be a part of FKD because he wanted to do something generally different? related to his hatred of African~Americans, Jews, and Homosexuals. According to CLINIC, FKD offered him glory and the ability to contribute his knowledge of constructing explosive devices toward a ?righteous? cause. CLIMO further discussed drawing a plan and designing a bomb he intended to build to assist in a race war on behalf of FKD. Ultimately, CLIMO left the online FKD group because he became bored with the group and their inaction. CLIMO advised that he wanted to do more against the groups he hates by carrying out violent attacks against them. 27. About the same time that CLIMO became involved with FKD, he also recruited a homeless person to conduct surveillance on a Las Vegas synagogue to carry out an attack. In this instance, plan did not come to fruition because he needed more time to create better method of attack. CLIMO revisited this plan a few months ago around the same time he realized that FKD was not going to take violent action and considered igniting the synagogue on fire with people inside. One of the reasons CLIMO again thought about attacking this synagogue was to make the statement, ?Jews Suck.? The synagogue that CLIMO identi?ed is that same Las Vegas synagogue that he talked about attacking with the CH8 and FBI OCE. 28. CLIMO admitted talking to both the CH8 and FBI OCE on using his Wire application and stating that he in fact was the person using the Wire online profile that talked with the CH8 and FBI OCE. 29. After CLIMO was placed under arrest and given his M?z?rcmda warnings, he agreed to continue to speak with agents. CLIMO further discussed the acquisition of various electronic components, which he acknowledged were in his bedroom, to build a bomb or test the circuit Case Document 1 Filed 08/09/19 Page 10 of 11 with a light bulb. CLIMO stated that ?reworks found in his garage were left over from the Fourth of July and he claimed that he did not possess all of the needed parts for an explosive device. CLIMO further talked about a plan to mobilize an eight man sniper platoon to conduct a shooting attack on Jewish people either at a Las Vegas synagogue or any other area of opportunity. CLINIO explained that over approximately the past two years he has considered various ideas to carry out an attack on Jewish people, but he is still trying to decide on a plan that will work. 30. In addition to his interest in building an explosive device, CLIMO stated that he had developed an interest in building a 4? mortar. In a journal found in his room, CLIMO sketched a picture of an attack of a Las Vegas bar that he viewed as catering to homosexuals. Additionally, in this same sketch, CLIMO drew what he described as two infantry squads attacking the bar with ?rearms from the outside and one attacking it with a ?rearms from the inside. This is the same Las Vegas bar that CLIMO identified to the FBI OCE as a potential target of attack. Agents seized an AR-IS ri?e and a bolt action ri?e from bedroom. 10 Case Document 1 Filed 08/09/19 Page 11 of 11 CONCLUSION 31. Based on the above facts and circumstances, I believe there is probable cause that CLIMO did Violate Title 26 United States Code, Sections 5841, 5861(d) and 5871, Possession of an Unregistered Firearm. Respect?illy submitted, Matthew James Schaeffer, Special Agent Federal Bureau of Investigation SUBSCRIBED and SWORN to before me This 9? day of August 2019 UNITED SKIES MAGISTRATE JUDGE 11