Case: Doc 1-1 Filed: 08/12/19 1 of 7. PageID 2 AFFIDAVIT IN SUFPORT OF A CRIMINAL COMPLAINT l, Themistocles Tsarnas, being ?rst duly sworn, hereby depose and state as follows: AGENT BACKGROUND 1. i am an investigative or law enforcement of?cer of the United States within the meaning of 18 U.S.C. 2510(7); that is, an of?cer ofthe United States who is empowered by law to conduct investigations of, and to make arrests for, the offenses enumerated in 18 U.S.C. 2516. I have been trained in advanced investigative techniques and have satisfied all requirements de?ned by the Federal Criminal Investigator Classi?cation series established by the US. Of?ce of Personnel Management. 2. have been employed by the Federal Bureau of Investigation (hereinafter as a Special Agent since May of 201 8 and have been assigned to the Cleveland Division, Youngstown Resident Agency, since February 2019. have been assigned to and participated in investigations in the area of general criminal matters, which include bank robberies, drug violations, crimes against children, and threats of violence. I have participated in all of the usual methods of investigation including, but not limited to, ?nancial analysis, physical surveillance, cooperating witnesses, con?dential human sources, telephone toll record analysis, interception of wire and cellular telephone communications, consensual monitoring, and the execution of search and arrest warrants. 3. Over the course of my employment as a FBI Special Agent 1 have conducted and participated in multiple criminal investigations that have resulted in arrests for violent criminal offenses. These crimes resulted in subsequent convictions in Federal Courts. 4. This af?davit is being submitted for the limited purpose of establishing probable cause to believe that JUSTIN OLSEN, age 18, currently residing at Oakridge Drive, Boardman, Ohio 44512 in the Northern District of Ohio, Eastern Division, has committed a Case: Doc 1-1 Filed: 08/12/19 2 of 7. PageID 3 violation of Title 18, United States Code, Section 115(8), Threatening to Assault a Federal law enforcement officer. 5. The statements contained in this af?davit are based in part on: information provided by FBI Special Agents, Task Force Officers and F131 written reports about this and other investigations that have received, directly or indirectly, from other law enforcement agents, information gathered from the results of physical surveillance conducted by law enforcement agents, reporting by witnesses, independent investigation and analysis by FBI and computer forensic professionals, and my experience, training and background as a Special Agent of the FBI. Because this affidavit 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. Instead, I have set forth only the facts that I believe are necessary to establish the necessary foundation for the requested complaint. 6. This court has jurisdiction to issue the prOposed warrant because it is a ?court. of competent jurisdiction? as defined in 8 U.S.C. 2711. Speci?cally, the Court is a district court of the United States that has jurisdiction over the offense being investigated. BASIS FOR PROBABLE CAUSE 7. iFunny1 is a website and mobile application featuring user?submitted media in the form of images, and videos. iFunny is known for circulating and popularizing a-variety of internet "merges? 8. On or about February 11, 2019, FBI Agents from Anchorage, Alaska (hereinafter Anchorage?) researched the Internet chat room iFunny and the associated user, iFunny was created on April 26th, 2011, as an mobile application on the Apple ?App Store? for sharing photos, videos. 3 A meme is humorous image, video, piece of text, etc, that is cepied (often with slight. variations) and spread via the Internet. Case: Doc 1-1 Filed: 08/12/19 3 of 7. PageID 4 ?ArrnyOfChrist? with an associated Internet web address of, The investigation into ArmyOfChrist was based upon the observation by FBI Anchorage into multiple Internet postings in which ArmyOfChrist discussed supporting mass shootings, and assault and/or targeting of Planned Parenthood. 9. On or about March 18, 2019, FBI Anchorage noted the iFunny account related to ArmyofChrist ?showed a large increase in subscribers? from the previous month. FBI Anchorage noted the Subscriber amount reached approximately 4,400. 10. On or about March 28, 2019, FBI Anchorage issued a subpoena to iFunny for subscriber information for the user, ArmyOfChrist. 1. On or about April 16, 2019, FBI Anchorage received the subpoena. return for iFunny user ArrnyOfChri st, which has an associated email address of, 12.. On or about June 2, 2019, ArmyOfChrist engaged in a conversation with another user regarding the 1993 siege in Waco, Texas3. During that conversation, ArmyOfChrist posted a threat to assault federal law enforcement officers, ?In conclusion, shoot every federal agent on sight.? Below is a screenshot capturedldepicting iFunny online comments made by AnnyOfChrist; the posting reflects ArmyOfChrist?s opinion of the 1993 Waco siege: 3 The Waco siege was the siege of a compound belonging to the religious sect Branch Davidians, carried out by American federal and Texas state law enforcement, as well as the US. military, during the performance of their of?cial duties, between February 28 and April 19, 1993. Case: Doc 1-1 Filed: 08/12/19 4 of 7. PageID 5 13. 011 or about July 8, 2019, FBI Anchorage served a subpoena to Google for subscriber information. for Gmail account, The Google subpoena return indicated an account registered to JUSTIN OLSEN (hereafter with an Internet Protocol (IP) address of24.101.90.107. A query of IP address 24.101.90.107 was associated with Cable Services located in Boardrnan, Ohio. 14. On or about August 2, 2019, F81 Anchorage reassigned this matter to FBI Youngstown, Ohio for further investigation. Case: Doc 1-1 Filed: 08/12/19 5 of 7. PageID 6 15. On or about August 6, 2019, I reviewed past online posts made by AnnyOfChrist documented and witnessed that ArmyOfChrist stated, comply with gun laws, stock up on stuff they could ban. In fact, go out of your way to break these laws, they?re fucking stupid,? and ?Hell, even the Oklahoma City bombing shows that armed resistance is a viable method of political change. There is no legal solution? and ?In conclusion, shoot every federal agent on Sight.? 16. On or about August 6, 2019, TFO William ?Bill? Woods ofthe FBI Mahoning Valley Violent Crimes Task Force conducted an Ohio Law Enforcement Gateway query of OLSEN which indicated a residence of, Presidential Court, Boardman, Ohio, and that the owner of Presidential Court, Boardman, Ohio is mother. 17. On or about August. 6, 2019, Boardman Municipal Court Judge, Joseph M. Bouser authorized the Search of Presidential Court, Boardman, Ohio and the seizure of any computers, cellular devices, hate related literature, and ?rearms. 18. On or about August 7, 2019, FBI SAS and TFOS with the executed a search warrant at Presidential Court, Boardman, Ohio. During the execution of the warrant, OLSEN was not present, however neighbors indicated that OLSEN recently moved to his father?s residence at Oakridge Drive, Boardrnan, Ohio. 19. On or about August 7, 2019, FBI SAs and TFOS with the went to Olsen?s father?s residence. investigators observed OLSEN exiting the residence and arrested OLSEN for state charges. 20. On or about August 7, 2019, I went to Oakridge Drive, Boardman, Ohio to interview OLSEN. I advised OLSEN of his Miranda rights and he verbally stated that he understood his constitutional rights and wished to Speak with me. Case: Doc 1-1 Filed: 08/12/19 6 of 7. PageID 7 21. During the interview with OLSEN, he admitted to me that he posted on iFunny I from the username ArmyofChrist and he made the comments online concerning violence but stated that they were ?only a joke.? OLSEN also admitted to making the comments on the hiternet regarding shooting Federal Agents on sight, and stated . . .that?s a hyperbolic conclusion based on the results of the Waco siege.? and . .where the ATP slaughtered families.? OLSEN said that he resided at Oakridge Drive, Boardman, Ohio for approximately two weeks. OLSEN also told me that he utilized his personal Apple iPhone 7 to make the referenced posts online. 22. On or about August 2019, OLSEN gave me written consent to search his bedroom at Oakridge Drive, Boardman, Ohio and his car which he used daily. investigators located a large machete inside of the trunk car. 23. On. or about August 7, 2019, Investigators entered residence at Oakridge Drive, Boardrnan, Ohio, upon entering the residence, Of?cers observed approximately 300 rounds of various ammunition to include ri?e ammunition on the stairway leading to the second ?oor. Given the nature of the threat, the potential for firearms in the house and the potential of suspects unknown being inside of the residence, of?cers conducted a safety sweep of the residence. Inside room, investigators observed a computer on bed and an iPad on the dresser. In another bedroom, investigators observed ri?e cases, approximately 10,000 rounds of ammunition, camou?age clothing, and camou?aged backpacks. lnvesti gators also observed a large gun vault during the search. 24. On or about August 7, 2019, Eric Olsen accompanied TFO John Elberty and FBI SA Bryon Speakes into his bedroom at Oakridge Drive, Boardman, Ohio. Eric Olsen opened the gun vault revealing several firearms to include 5 style ri?es Case: Doc 1-1 Filed: 08/12/19 7 of 7. PageID 8 and shotguns. 25. On or about August 7, 2019, Judge Houser authorized the search of Oakridge Drive, Boardinan, Ohio. The search warrant authorized the seizure of any computers, cellular devices, hate related literature, and all ?rearms. 26. The search of Oak?ridge Drive, Boardman, Ohio resulted in the seizure of approximately 15 ri?es to include assault type ri?es, shotguns, as well as approximately 10 semi?automatic pistols. investigators also observed an estimated 10,000 rounds of ammunition and additional firearm paraphernalia which was left Within the residence. CONCLUSION 27. Based on the foregoing, there is probable cause to believe that OLSEN has committed a violation of Title 18, United States Code, Section I l5(B), Threatening to Assault a Federal law enforcement of?cer. 28. Accordingly, I respectfully request the court issue a warrant for the arrest of JUSTIN OLSEN. (H SA Themistocles Tsamas Federal Bureau of Investigation Sworn to and subscribed before me this i 2_day of August 20 I 9. HO RAB GE Rosita/[BERT U.S.MAGISTRAT JUDGE