58549682 FILED 2019 SEP 26 KING COUNTY SUPERIOR COURT CLERK CASE 19-2-25260-0 SEA Superior Court of Washington ForKingCounty No. Seattle Police Department Petitioner Petition for an Extreme Risk vs. Protection Order Kaleb James Cole 10-13-1995 (PT) Respondent DOB General Information I am a family or household member of the respondent. My relationship with the respondent is (check all that apply): Spouse or former spouse Blood relation other than parent or child Parent of a child in common ]Current or former legal guardian ]Current or former domestic partner ]Stepparent or stepchild ]Current or former cohabitant within the Parent or child past year ]In-Iaw Current or former dating relationship 1.3 I am filing on behalf of the Seattle Police Department, law enforcement agency. have already notified the respondent's family or household members and any known 3rd parties who may be at risk of violence; OR My agency will make a good faith effort to provide notice to them by telephone email in-person ]other within a reasonable period of time. 2. I reside in this county. I am filing on behalf of a law enforcement agency that is located in this county. ]The respondent resides in this county. 3. Describe below any firearms the respondent currently owns, possesses, has custody of, has access to, or controls. Type of firearm How many Where is the firearm Date/time/place you last saw the firearms? kept? firearm Handgun Multiple With the respondent or Self-admitted to ownership (see within his control and Custom and Border Protection possession in the State report) of Washington Petition for an Extreme Fl?r'sk Protection Order (PT) - Page 1 of 9 101 (0?/2019) RCW 7.94.030. 58549682 Shotgun Rifle Unknown Unknown Semi- 1 With the respondent or Cole self-admitted to owning an Automatic within his control and AK 47 (see Custom and Border Assault Rifle possession in the State Protection Report). of Washington Check all the boxes that apply and describe below: Respondent has access to someone else's firearm. Respondent expressed an intent to obtain a firearm. Respondent has unlawfully or recklessly used, displayed, or brandished a firearm. Respondent recently acquired a firearm. Describe: Kaleb Cole is a self-admitted member of the Atomwaffen Division and believed to be the cell leader of the Washington State chapter. The Atomwaffen Division, as noted by open source articles, is a nee-Nazi group known for its recruiting of young white men attracted to a violent ideology that idolizes Adolf Hitler and Charles Manson (see attached Open source articles). This group believes that a race war is coming and similar to Charles Manson's theory of ?Helter Skelter? the Atomwa?en Division, according to the Anti-defamation League, articulates a white supremacist ideology rooted in ?accelerationist beliefs." 1 Accelerationist beliefs are fueled by the perception that the future of the white race is bleak, and they must employ any means necessary to expedite the collapse of current system. Accelerationists believe that setting off a series of reactions, even if they result in changes that directly threaten the white race, can actually be a useful tool for motivating more reticent white supremacists. Following an extremist terrorist attack such as the Tree of Life or the Christchurch mass shootings, accelerationists identify a domino effect that is set into motion?a chain of societal reactions that further exacerbate the feeling of alienation among white supremacists and a greater impulse to engage in violence or destructive behavior.2 (See Exhibit 1). Kaleb Cole poses a serious threat to public safety by having access and possession to firearms and a concealed pistol license. Cole has a valid concealed pistol license issued by Whatcom County Sherriff?s Office, Respondent admits to owning firearms: Cole self-admitted to law enforcement officials that he owns firearms. In a recent report from US Customs and Border Protection, Cole admitted that he owns an AK-47 rifle and several handguns (please see the attached report). Additionally, photographs of firearms were recovered from a cell phone belonging to Cole, including the attached photos (See Exhibit 2). A record check of the Washington State Department 01 Licensing Firearms Database shows no White Supremacist Embrace League April 16. 2019. 2 Id. Petition for an Extreme Risk Protection Order (PT) - Page 2 of 9 7.94.030. 58549682 known firearm purchases for Cole. However, it is unknown if Cole recently purchased additional firearms as we were made aware that Washington?s Department of Licensing Records (DOL) has an approximate half million firearm record backlog. Any recent firearm purchases (including in the past several years) are unlikely to be updated in the DOL database. Additional evidence of firearm possession: Additionally, it is believed that Cole has participated in recent firearms training and recruitment efforts at organized, "Hate Camps." These "Hate Camps,? have taken place in Washington State. Cole is believed to be an organizer in the ?Hate Camps? and his participation is concerning to law enforcement as it appears that he has gone from espousing hate to now taking active steps or preparation for an impending ?race war." These ?Hate Camps" also show various Atomwaffen Division members in skull masks making threats of mass violence (threats to kill or gas the Kikes). Please see section 6 of this petition for additional information and Exhibit 4 (video clips). 4. Between the respondent and me: List any criminal or civil protection, restraining or no- contact orders, pending lawsuits, or other legal action: It you have more than three matters, tist details on additional sheet. Case #1 Case #2 Case #3 Case Name Case Number Court/County/ State Type of Case Protected Person Was there any order violation? 5. Between the respondent and any other person: List any criminal or civil protection, restraining or no-contact orders: if you have more than three matters, list details on additional sheet Case #1 Case #2 Case #3 Protected Person Case Number Petition for an Extreme Ftisk Protection Order (PT) - Page 3 of 9 101 (07/2019) RCW 7.94.030. 58549682 Court/Countyi State Was there any order violation? 6. Request for an Extreme Risk Protection Order I want a temporary extreme risk protection order effective immediately, without prior notice to respondent, that lasts up to 14 days, or until the court hea?ng: These are the specific facts known to me that cause me to believe the respondent poses a significant danger in the near future of causing personal injury to self or others by having custody or control, purchasing, possessing, accessing, or receiving firearms. More detailed information is provided in the Statement in section 7. Kaleb Cole is a self-admitted member of the Atomwaffen Division and is believed to be the cell leader of the Washington State chapter. Additionally. according to open source articles, The Atomwaffen Division is a neo-Nazi terrorist organization operating in the United States. Atomwaffen is German for ?Atomic Weapon.? The Atomwaffen Division is known to encourage flag burning, attacks on the federal government and to encourage attacks towards minorities, gays and Jews. The Atomwaffen Division is considered a hate group by the Southern Poverty Law Center. Additionally, members of the Atomwaffen Division have also been recently linked to several homicides. Self-admitted Atomwaffen membership: In the attached US. Customs and Border Protection Report, Cole admits being a member of the Atomwaffen Division and that he shares. ?a fascist ideology, the strong dominate the weak.? (See Exhibit 3). Although Cole denies that the Atomwaffen Division is interested in overthrowing the US. Government, he has been denied entry into Canada as a result of his membership with an organization that may engage in terrorism. According to Canadian authorities, Cole was deported, and he is barred from Canada for life. Additionally, law enforcement officials are aware of Cole?s involvement or association with various Atomwaffen facilitated, "Hate Camps.? These ?Hate Camps,? included several ?camps" that were held in Washington State (see synopsis of the video clips below). Law enforcement believe that the ?camps" are a training ground for the Atomwaffen Division cell members. Specifically, allowing members to receive combat/firearms training. These "camps" also served as a basis for several Atomwaffen recruitment videos. According to open source articles, Cole works on the group?s visual propaganda. Please see the attached open source video clips. (Exhibit 4): November 2018 video: This video shows various Atomwaffen Division cell members in military type fatigues with skull masks covering their faces. The cell members are engaged in firearms training and hand to hand combat. The cell members also participated in the desecration or burning of various flags. The Atomwaffen flag is on display in the background of the video. The various flags that were burned at the ?hate camp,? include: the Israel Jewish flag, Keklstan (made up flag created on 4Chan). United Nations flag, Gadsden flag, Rainbow Pride flag, Black Lives Matter and the Thin Blue Line Police flag. This video also had Petition for an Extreme Risk Protection Order (PT) - Page 4 of 9 X8 101 (07/2019) RCW 7.94.030. 58549682 the hashtags and The reference to the Siege and James Mason is also significant in understanding the violent ideology associated with this group. The Siege is a series of violent hate filled essays that advocates random attacks and murders in order to destabilize society. Per open source articles (ProPublica dated February 23, 2018), The Siege, is required reading for Atomwaffen cell members and the book provides an outline for the cell members ideology and training.(Exhibit 1). 2018 video: This video opens with a group of individuals dressed in military type fatigues with Atomwaffen patches adorned, skull masks covering their faces, while armed with firearms, chanting, ?Gas the Kikes, race war now." The words ?Gas the Kikes" appears on screen. The threats to kill, referencing possible mass violence, are being chanted while the group is firing military style firearms (actual discharging of high capacity firearms). The video continues with cell members conducting a clearing or sweep of a structure (as if they were clearly a building in a military operation). The video also shows various Atomwaffen members with a variety of firearms (handguns, long guns and other military style assault weapons). The video ends with the slogan, ?Join your local Nazis- Attomwaffendivisionorg." *Photos recovered from Cole?s cell phone also show the same skull masks that are used in the two open source videos as well as an Atomwaffen flag. After a hearing, where the respondent has a right to be present, I want the court to issue an Extreme Risk Protection Order that lasts for one year: After the hearing, I want the court to issue an Extreme Ftisk Protection Order that lasts for one year because the respondent poses a significant danger of causing personal injury to self or others by having custody or control, purchasing, possessing, or receiving a firearm. My statement below includes the respondent?s specific words, actions, or other facts that cause me to have a reasonable fear of future dangerous acts by respondent. 7. Statement To enter an Extreme Risk Protection Order, the court must find it more likely than not that the respondent poses a significant danger of causing personal injury to self or others by having custody or control, purchasing, possessing, accessing, or receiving a firearm. Complete all sections that apply. Attach additional pages, as needed. Petition for an Extreme Risk Protection Order (PT) - Page 5 of 9 101 (07/2019) RCW 7.94.030. 58549682 8. Convictions or Arrests. Check all the boxes that apply and describe below: Respondent has been arrested or convicted of a: 1 domestic violence crime. felony or violent crime. hate crime offense or malicious harassment (threats, physical injury or property damage based on the victim?s race, color, religion, ancestry, national origin, gender, sexual orientation, gender expression or identity, or mental, physical, or sensory disability). Describe on the next page. include location, court name, and case number, if known. The respondent has no known criminal arrests. However, law enforcement officials are increasingly concerned about the respondent?s access to firearms and his involvement in the Atomwaffen Division, a known terrorism group. Specifically, the video clips referenced above) show members of the Atomwaffen Division, handling and firing firearms while shouting threats to kill- including a specific reference to ?Race War Now.? This language suggests that the group is preparing in anticipation for an upcoming ?Race War." Law enforcement sources believe that the Atomwaffen Division follows an acceleration theory (see also section 3). It is also concerning to law enforcement that Cole was traveling to the Ukraine and other areas of Eastern Europe and that Cole was posing in photos with the Atomwaffen Division flag while travel overseas (Exhibit 2). Additionally. Cole has been identified by Canadian authorities as a possible member of an organization that may engage in terrorism and Cole has been mrmanently banned from entry into Canada as a result of his membership/affiliation with the Atomwaffen Division. 9. Violence and Threats: Check each box that applies and explain below. Respondent has recently committed or threatened violence against self or others, whether or not respondent had a firearm. Respondent has shown, within the past 12 months, a pattern of acts or threats of violence, which can include violent acts against self or others. Respondent has a history of use, attempted use, or threatened use of physical force against another person. Respondent has a history of stalking another person. Explain: DateNVhen Describe what happened. June and Cole flew from Quebec to British Columbia to see his girlfriend in late May/ early July 2019 June 2019. Cole was flagged by Canadian authorities because of concerns with open source information about Cole and his overseas travel to the Ukraine. Cole was detained during deportation proceedings. Cole was found inadmissible because he is a "Member of an organization that may engage in Petition for an Extreme Risk Protection Order (PT) - Page 6 of 9 101 (07/2019) - RCW 7.94.030. 58549682 terrorism", Section 34 from the Canadian Immigration Code. He was removed from Canada by deportation in early July 2019 and barred from Canada for life. Organized Please see above descriptions of the organized camps and the corresponding Firearms video clips. Training! Hate Camps Prior police ?mac's SPD 13-415433, November 5,2018: An Atomwafien Division decal was posted on traffic signs in the 1400 block of Union St., Seattle. These decals were placed on traffic signs across the street from the location of Temple De Hirsch Sinai. The decals depicted the Atomwatfen Division name and symbol. swastikas and other Hitler propaganda. Unknown suspect. SPD 18-414498, November 5, 2018: An Atomwatfen Division decal was placed on a building at the Seattle Academy of Art and Science, located on 1201, Union St. The decal depicted the Atomwafien Division name and symbol as well as the phrase, ?Prepare your fallout shelters for the Nuclear Helter Skelter.? Unknown suspect. 2015: A female called police to report that she had recently been in the apartment of Kaleb Cole and that he had Nee-Nazi flags and memorabilia throughout (Bellingham PD- Information Report 153-50887). 2012: In Anacortes, WA, Cole was contacted by law enforcement authorities after he was found outside of a store (Steinman?s Grocery). Cole was outside the store waiving a Nazi flag which offended another group (Anacortes A06302). 10. Respondent?s behavior Describe any behaviors by the respondent that present an imminent threat of harm to self or others. Petition for an Extreme Risk Protection Order (PT) - Page 7 of 9 XR 101 (07/2019) 7.94.030. 58549682 If you look at the pattern of contact with Cole (minimal police contacts in 2012 and 2015) and compare Cole?s more recent involvement with the Atomwaffen division. his words. actions and behaviors. suooest he has taken additional steps towards a plan with his ideologically motivated violence. Specifically. the coordinated camps with firearms training. overseas travel with Atomwaften paraphernalia-flaqs/skuII masks, threats to kill (gas the Kikes) and the possession of firearms, suggest an imminent risk to public safety if Cole is permitted to continue to purchase or possess firearms. Please also see the above sections and all attached exhibits. 11. Corroborated evidence of respondent?s alcohol or controlled substance abuse. Describe any evidence and attach any documents corroborating (supporting) the respondent?s abuse of alcohol, legal or illegal drugs. Unknown 12. Other important information that you think will help the court make a decision. As the sergeant. assiqned to the Regional Domestic Violence Enforcement Unit. am aware of the lethality factors for conducting a risk assessment. Specifically. the lethality factors involved in sewing and enforcing various protective orders, includino Extreme Risk Protection Orders. I know that individuals that exhibit certain warnino signs. such as the factors noted in this petition. includino threats to kill others. fixated violent ideoloov taroeted towards minorities. and the ownership or possession of hioh capacity firearms. creates a combination of factors that suggest that Cole is a siqnificant dancer to others by having firearms in his custody or control. Petition for an Extreme Risk Protection Order (PT) - Page 8 of 9 101 (07/2019) RCW 7.94.030. 58549682 13. You must provide an address where you can be served with legal documents. Chose ONE option, then write the address in the line below: I can be served with legal documents at the address below: Disclosing my residential address would risk harm to me or a member of my family or household. I can be served with legal documents at the alternate address below: OR I am filing on behalf of a law enforcement agency. Service can be made at the law enforcement agency address listed below: Address: Seattle Police Department, 610 5th Avenue, Seattle, WA 98104 I declare under penalty of perjury under the laws of the state of Washington that the foregoing is true and correct. at 5am, Dated: 9/20 /20?q Signature of Petitioner Dozomq em! #0057 Print Name and if Law enforcement Badge No. Washington. *Assisting on Extreme Risk Protection Order cases, the King County Prosecuting Attorney?s Office will appear under the general order, 18-2-12050-1, sub 14* Petition for an Extreme Risk Protection Order (PT) - Page 9 of 101 (07/2019) RCW 7.94.030. 58549682 Exhibit 1: Open Source Media Articles 58549682 Local News IOCAL BIZITECH SPORTS mm TIMI. nII'm NIH/tut V?m DvupclHunelnss Education [nu-dc Hunlth Data TumWat-L-I-doq NmObnuanr-s L'urnc erllNow-i Irv-.nlpolitlu North??t Report: Washington state home to one of the largest cells of notorious white supremacist group 0? mi?knl'l'm It . 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