. .

AO 91 (Rev. 11/11) Criminal Complaint

UNITED STATES DISTRICT COURT

for the

United States of America,

Plaintiff

Vi

Mark Domingo,

Defendant

Central District of California loaari201 9

FILEDCLERK,U.S. DISTRICT COURT

CENTRALDISTRICT OF CALIFORNIA

BY: DEPUTY Case No. 2:4 9-MJ-01751-DUTY

CRIMINAL COMPLAINT

I, the complainantin this case, state that the following is true to the best of my knowledge andbelief.

Beginning on an unknowndate and continuing until April 26, 2019, in the county of Los Angeles in the Central

District of California, the defendantviolated:

Code Section

18 U.S.C. § 2339A

This criminal complaintis based onthese facts:

Please see attached affidavit.

Continued on the attached sheet.

Offense Description

Providing and Attempting to Provide

Material Support to Terrorists

Complainant's signature

Tasha Coolidge, Special Agent

Sworn to before me andhal in my presence.

Date: Y V] A

Cityand state: _Los Angeles, California

ry ted nameandtitle

& Wiiw—4 aa

{ Judge's signature

Hon. Michael R. Wilner, U.S. Magistrate JudgePrinted nameandtitle

AFFIDAVIT

I, Tasha Coolidge, being duly sworn,

follows:

I.

1. I am a Special Agent

Investigation (“FBI”), and have

2018. I am currently assigned

(“JTTE”) of the Los Angeles Fi¢

Special Agent, I was on active

Force Security Forces, serving

overall mission to deter, deted

terrorist activity. During thi

responsibilities such as, prote¢

dignitary support, anti-terrori

missions. ‘In total, I have bee

United States for nearly ten yé¢

gained a broad expertise coveri

enforcement, operational terronx

measures. Through the course

the FBI, I have used a variety

resources, including, surveilla

warrants, evidence seizures, an

familiar with strategy, tactics

techniques of criminals, terroy

my employment with the FBI, I a

Training at the FBI Academy in

received both formal and inform

declare and state as

INTRODUCTION

with the Federal Bureau of

been so employed since March

to the Joint Terrorism Task Force

id Division. Before becoming a

duty in the United States Air

eight years overseas, with an

t and mitigate criminal and

s time I had numerous

cting high-valued U.S. assets,

sm measures, and fly-away

n sworn to protect and serve the

I havears. During my career,

ng weapon systems, law

ist cells, and counter-insurgency

f my training and employment with

of investigative techniques and

nee, confidential sources, search

d telephone toll analysis. I am

methods, tradecraft, and’

ists, and their agents. During

attended 21 weeks of New Agent

Quantico, Virginia. I have

al training from the FBI

1

regarding criminal and countert

also attended training concerni

communications and computers in

II. PURPOSE

errorism investigations. I have

ng the use of electronic

n furtherance of crime.

OF THE AFFIDAVIT

2. This affidavit is suk

complaint charging defendant Ma

with Providing and Attempting {

Terrorists, in violation of Tit

(the “Subject Offense”) .1

IIIT. SUMMARY

3. In March and April 2¢

steps to manufacture and use a

order to commit mass murder. gd

purchased several hundred nails

explosive device, and provided

DOMINGO believed to be a collak

undercover law enforcement offi

for the purpose of having the U

destruction for DOMINGO to use

adiscussed below, on April 26, Z

inspected the items DOMINGO bel

destruction (but unbeknownst tc

finalized plans to commit the 4

1 Title 18, United Statesunlawful to provide or attempt

resources, knowing or intendingpreparation for, or in carryingspecified offenses, including TSection 2332a (Use of a Weapon

mitted in support of a criminal

rk Steven Domingo (“DOMINGO”)

o Provide Material Support to

le 18, United States Code, 2339A

OF PROBABLE CAUSE

19, DOMINGO planned and took

weapon of mass destruction in

m April 23 and 24, 2019, DOMINGO

to be used as shrapnel inside an

the nails to a person whom

orator, but who was in fact an

cer (“UC”) working for the FBI,

C manufacture weapons of mass

in an upcoming attack. As

019, DOMINGO met the UC,

lieved were weapons of mass

him were actually inert), and

ttack on Sunday April 28, 2019.

Code, Section 2339A, makes itto provide material support orthat they are to be used inout, a violation of certain

itle 18, United States Code,

of Mass Destruction).

2

Iv. STATEMENT OF PROBABLE CAUSE

4, The facts set forth |

part on: information provided t

officers; law enforcement repor

witnesses; my personal observat

training, and background as an

affidavit is intended to show 4

probable cause for the requesteé

search warrants, and does not 4

knowledge of or investigation ]j

specifically indicated otherwis

statements described in this af

and in part only with quoted la

only, and all dates and times a

A.

Committing a Large-Scale 7

5. According to reports

employee (“OCE”), in March 2019

online platform (hereinafter Ug

On March 2,group. 2019, USERN

which he introduced himself as

shahada.?

6. FBI Agents reviewed J

Motor Vehicles records, and saw

appeared to be DOMINGO. FBI Aq

2 Based on my training andshahada is the profession of fa“There is no god but Allah, and

Allah.”

n this affidavit are based in

o me by other law enforcement

ts; information obtained from

ions; and my experience,

FBI Special Agent. This

exely that there is sufficient

d complaint, arrest warrant, and

urport to set forth all of my

nto this matter. Unless

e, all conversations and

fidavit are related in substance

nguage appearing in draft form

re approximate.

DOMINGO Posts About His Support for Violent Jihad anderrorist Attack

provided by an FBI online covert

, the OCE identified a user of an

ERNAME 1) in a private message

AME 1 posted a link to a video in

“o“Mark Domingo,” and declared the

OMINGO’s California Department of

that the person in the video

ents also reviewed records

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

provided by the platform, whicl

account was associated with ema

m.domingo2014@hotmail.com, and

According to records provided 4

with the m.domingo2014@hotmail

Domingo.”

7. According to Departme

was also previously an active d

was assigned to Fort Campbell,

Afghanistan from September 10,

8. FBI agents have revig

OCE in which DOMINGO described

his aspiration to conduct an at

a. On March 3, 2019

another vegas event tbh? someth

-] and its not about winning th

america giving them a taste of

over the world.” Based on my t

that DOMINGO’s description of *

reference to the October 1, 201

Nevada, which killed 59 people,

b. On March 14, 201

mosque shootings in new Zealand

mustbe retribution.” Based on

3 Based on my training andis used in electronic communica

honest.” “ ing to kick off civil unrest [.

n showed that the USERNAME 1

il address

telephone number 931-249-5283.

y Microsoft, the name associated

com e-mail address is “Mark

nt of Defense records, DOMINGO

uty U.S. Army Infantryman. He

Kentucky, and then deployed to

2012 to January 16, 2013.

wed online posts provided by the

his support for violent jihad and

tack in the Los Angeles area.

DOMINGO posted, “america needs'

e 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,

“there were9, DOMINGO posted,

[sad emoji] [ . ,.] there

my training and experience and

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

knowledge of this investigation,

to the March 13, 2019 mass sho

Christchurch, New Zealand, whid

Also on March 14, 2019, DOMINGd

make a christians life miserab]

[.

+]

sis in new Zealand .] mayk

shed our blood [. no Musli

a message needs to be sent.”

B. DOMINGO Expresses His Inte

I believe DOMINGO was referring

tings at two mosques in

h killed 50 people.

posted, “I feel like I should

e tomorrow for our fallen bros n

[.e a jews life idk‘ .] they

m should have to experience this,

nt to Kill Americans to Retaliatefor the Mass Shooting in New Zealand

9. According to the OCE,

observing DOMINGO’s posts regar

Zealand mass shooting, the OCE

conversation with DOMINGO, in Ww

about that mass shooting. [In t

jus enraged atm [. .] these

one way or another.” The OCE qd

would be ready the next day, an

response would require planning.

many people DOMINGO would like

wrote: “one [individual]? was 4

a bunch of jews around this ond

theyre forced to find parking a

4 “Idk” “I do5 Based on my training and

is short for “at the moment.”

is short for fuckers do need to bleed [.

m

on March 14, 2019, after

ding retaliating for the New

initiated a private online

hich they discussed their anger

waim

-]

hose messages, DOMINGO wrote,

autioned DOMINGO that police

d 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

't know.”

experience, I am aware that “atm”

in the conversation, DOMINGO wt

saturday for their worship,” ar

had a lot of businesses and sur

10. On March 16, 2019, afr

(“CHS”), who also maintained an

same private message group as J]

private message to DOMINGO askji

responded, “still mad -][- 4

watched the vid.” Based on my

knowledge of this investigation

reference to live footage of th

the perpetrator streamed onling

subsequently been reposted on t

“h11. DOMINGO continued,

took my ak out [. .] its been

training and experience, I know

reference to a Kalashnikov-manu

commonly known model of which i

According to a law enforcement

firearms registered to him: a qd

semi-automatic rifle (WASR 10),

Tulski-Korovin SKS semi-automat

bolt-action rifle.

6 Based on my training andis an Arabic word for Jews.

7 The CHS has worked with2013. In total, the CHS has be

The CHS does not have a crimina Ly

rote that “the yahud® go on

nd that the area was upscale and

rveillance cameras.

h FBI Confidential Human Source’?

online account and was in the

OMINGO and the OCE, sent a

ng how he was feeling. DOMINGO

ven more so [. .] since I

training and experience and

I believe “the vid” was a

e New Zealand shootings, which

during the attacks and which has

he Internet.

ow my bros n sis died [.

by my bed.” Based on my

that “ak” is a common shorthand

factured assault rifle, the most

s referred to as an AK-47.

database, DOMINGO has three

entury Arms Wassenaar Arrangement

which is an AK-47 style rifle; a

ic rifle; and a Zastava M 48

experience, I am aware that Yahud

the FBI since approximately Augusten paid approximately $304,524.1 history. :

6

12. Later in their convei

and the CHS meet in person, an

following week.

c. DOMINGO Meets CHS on Marck

Committing a Terrorist Att

13. On the evening of Mat

met in person to eat dinner ang¢

meeting was audio recorded. Du

below, DOMINGO discussed with t

attack, including Jews, police

military facility.

14. DOMINGO and the CHS d

Syria, and the activities of Al

Iraq and al-Sham (“ISIS”). Aft

A.“not doing anything,” DOMINGO

plant IEDs.” Based on my train

that “IEDs” is a reference to I

DOMINGO characterized Al-Qa’ida

run [. -] They’11 shoot, the

the Americans get mad. Then th

This is why I like - I like al-

direct stance [. .] victory qd

training and experience, I beli

to Abu Bakr al-Baghdadi, the le

® Based on my training andviolent Islamic extremists, the

for Islam through violent jihad.

rsation,

rch 18,

i attend a prayer service.

tiring that meeting,

DOMINGO suggested that he

they agreed to meet the

a 18, 2019 and Proposes Ideas fortack

2019, the CHS and DOMINGO

The

as detailed

he CHS different targets for an

officers, churches, anda

iscussed the wars in Iraq and

-Qa’ida and the Islamic State of

er the CHS said Al-Qa’ida was

aid, “Well, they’ll, they’11l

ling and experience, I believe

mprovised Explosive Devices.

’s tactics as “sort of hit and

n they’11 run away [. .] then

[. -]

‘cuz he took the

ey go murder Muslims

Baghdadi, yeah,

r martyrdom.”® Based on my

eve “al-Baghdadi” was a reference

ader of ISIS.

experience, I know that among

term martyr means one who dies

15. Throughout their driv

targets to the CHS, including gz

National Guard Armory. At one

the business street [. -] the

They’ re all up and down the stiz

everywhere. I mean it’s a busi

“if you really want to do it, y

online and do it, you know? Yq

DOMINGO interrupted the CHS and

replied, “No. They going to pu

“If they catch me alive.” The

go shahid?? You going to kill

tell me [. -] You have a pla

has to be done.”

16. Moments later, DOMING

saying. We should plan.” The

to get caught. Your plan is ju

your plan.” DOMINGO replied “Mv

“It’s better not to get caught)

taken alive. But [. -] I hay

he had nine “AK magazines,” fiv

described to the CHS the guns t

‘They’ re all legally under my n

going to work.

[. +]

We’re going to

Well to be fair, yeah,

9 Based on my training andfacts, “go shahid” is used here

ve,

reet,

fou can’t just,

DOMINGO pointed out possible

olice cars, churches, anda

point, DOMINGO stated “This is

Yahud come here on Saturday.

but there’s cameras

ness you know.” The CHS said,

you can’t just go

u’re going to end up like-”

The CHSsaid, “A martyr.”

t you in jail.” DOMINGO replied,

CHS replied, “okay, you going to

one or two? What’s the plan? You

n?” DOMINGO replied, “something

O said “I know what you’re

CHS replied “I mean I don’t want

st to go and get caught. That’s

artyrdom, bro.” The CHS said,

a" DOMINGO said “Better not to be

e many magazines.” DOMINGO said

e of which were loaded, and

hat he owned. After DOMINGO said

ame,” the CHS said “That’s not

The CHS said, “No

[

get caught.”

[. -] Okay. So we plan

experience and the totality theto mean “become a martyr.”

8

-] We plan. We take our time You know we just, we cruise.

We chill. We chill for a bit.

17. During the meeting, POMINGO pointed out a church and

said “there’s another one [. .|.] I mean this is the land of

kuffar,}° brother.” The CHS sajid “You want to go after church?

What do you want to hit? Chur¢hes or like the military base?

Which one do you want to show me?” DOMINGO replied “We can

always hit the cops.” The CHS|again expressed concern about

DOMINGO conducting an attack using guns registered in his own

name, and asked if the bullets|were also registered in his name.

DOMINGO said the bullets were not registered, and he used gloves

to handle the bullets so his fingerprints would not appear on

them.

18. The CHS then said that he knew someone who “used to

make IEDs.” DOMINGO replied “That’s even better.” The CHS

described how an IED could be placed under a car and detonated

with a timer. The CHS and DOMINGO then arrived at the mosque

and went inside for several minutes to pray. When they left the

mosque, the CHS said the CHS would talk to “the brother, and

see.” DOMINGO replied “He can|make IEDs?” The CHS replied that

the brother could not make IEDs, but the CHS would see if the

brother knew someone else who dould. The CHS drove DOMINGO back

to DOMINGO’s house, and DOMINGO said, “We’1l keep in touch [.

.] You have my number. I have |/yours.”

10 Kuffar is the plural form of an Arabic word referring tonon-believers or infidels, likely used by DOMINGO to refer tonon-Muslims.

D. DOMINGO Proposes Conductir

19. On March 20, 2019, D

message of a photograph of an 3

of paper with a handwritten cag

3/20/2019.” The rifle depicted

feature a foldable metal stock

detachable high-capacity ammuni

at his house. DOMINGO explaing

q“foldable stock for drive by”

[. -] replaced it with wire

on my training and experience 4d

investigation, I believe DOMING

rifle’s wooden stock with wire

DOMINGO modified his rifle so 4

more easily from inside a vehid

20. Later that day, DOMIN

containing a similar photograph

OCE to send a timestamped photd

what I did with my ak [. -] i

know its mine [. -) and i ain

configuration is illegal af!1)

there may be a “snitch” in the

assured DOMINGO that everyone H

“inshallah [. J

-]

responded, q

[. -] go dark [. forak

11 AF is slang for “as fuc

hg a Drive-By Shooting

MINGO sent the CHS a private

\K-style rifle alongside a piece

tion, “USERNAME 1 [. -]

in the photograph appeared to

an attached sling, and a

tion magazine that DOMINGO keeps

nd that he

-] cuz wire can fold.”

nd knowledge of this

O’s reference to replacing the

for a “drive by” means that

le.

GO sent a message to the OCE

of his rifle.

graph in return and stated “like

time stamped it [. -]

“d

DOMINGO said he thought

so u

t fed [. (cuz my ak

Lol.”

message group. When the OCE

ad to be invited, DOMINGO

ho if I do, do anything that is

it [. -] and I’1il1 see you up

k,” meaning very.

10

d to the CHS that the rifle hada

“took off wooden stock

Based

hat it could be handled and fired

DOMINGO asked the

there [. -] if allah wills 1

experience,

heaven, and DOMINGO expects to

dying through violent jihad.

E. DOMINGO Meets with the

His Intent to Commit a

21. On the evening of

met again to eat dinner and att

meeting was audio recorded. Dv

below, DOMINGO discussed with t

committing an attack.

22. DOMINGO asked the CHS

apparently referencing the phot

of his rifle. DOMINGO spoke ak

the rifle and added “So when we

to act, I can keep it, like, yo

gonna be like, you know, it’s gq

the car [. With the wire,-d

23. The CHS replied that

a”Islam and was “so pure,” and st

_ don’t have to do this. You kne¢

DOMINGO responded by pointing qd

the police,” and describing ho

glass but police officers “roll

122 “Lol” is short-hand forstated he had to “show off,” bu

[heart-eye emojis].” DOMINGO I]believer who was “mad atm.” Aq

I believe “up there”

March 22,

wi21. Based on my training and

is a reference to paradise, or

earn his’ place in paradise by

CHS on March 22, 2019 and Discusses

Terrorist Attack

2019, the CHS and DOMINGO

end a prayer service. The

ring that meeting, as detailed

he CHS different plans for

if the CHS saw his “AK,”

ograph DOMINGO had sent the CHS

out some modifications he made to

decide to act or when I decide

u know when it’s the wood, it’s

onna be uncomfortable [. -] in

you can fold it.”

DOMINGO had just converted to

ated “You don’t need to, like you

w 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 alsot added, “martyrdom to me is like

ater stated he was just aain, “atm” means “at the moment.”

11

24. DOMINGO and the CHS

prayers, and the CHS again sai

replied “To be fair though, mo

Everyone I know are like, they

always said that’s fine, I’m j

about them.

the deen.”13 The CHS replied t

being patient, and DOMINGO replied “But you know [.

of the times,

right?” The CHS said, “Yeah,

“So you know, if they start it

one way or another I’m gonna finish it.

by fighting. We can handle it

They don’t care about me.

it’s a fucking th

t

then discussed practicing Islamic

1 how DOMINGO was “pure.” DOMINGO

st people here are shit [. -]

re like fake, you know [. -] I

ust like, fuck ’em. I don’t care

They don’t care about

hat Allah would reward DOMINGO for

-] A lot

nese Kuffar that start the beef,

hey do, yeah.” DOMINGO replied,

I’m gonna finish it. You know,

Like we can handle it

throwing bullets at each other, what you wanna do bro, like murder me, kill me, I’11 die

Shahid.”

F. DOMINGO Speaks with the CHS on March 27, 2019 to DiscussHis Plans to Conduct a Te

25. On March 27, 2019,

platform to tell the CHS that f

wanted to kill him.

of the “Ummah”’!4 and said that

13 Based on my training anthe term the deen is an Arabicreligion.

14 Based on my training anUmmah is an Arabic word referri

community of Muslims.

15 Based on my training anterm “halal” is an Arabic wordDOMINGO also made reference to

neighbor involving trash on DOM

rorist Attack

DOMINGO called the CHS via the

e was upsét with his neighbor and

DOMINGO identified the neighbor as an enemy

his blood was “halal.”15 The CHS

il experience, I understand that

word referring to one’s faith or

1 experience, I understand that

ng the worldwide nation or

i experience, I am aware that the

meaning religiously permissible.a personal dispute with theINGO’s lawn.

12

repeatedly tried to calm DOMIN

were in the “heart of the enemy

around the corner,” there is n

26. DOMINGO said he coul

burglary, and that murders go

said they needed to “start smal

attack of a larger scale, beca

the first time.

would test the response time of the police,

response time would likely be ¢

Base. G. DOMINGO Meets With the CH

50 down.

insolved all the time.

DOMINGO said 4

DOMINGO said that they

“on and that if “martyrdom is just

Dthing DOMINGO can do.

A stage the attack like a

DOMINGO

1,” before building up to an

hse they were bound to “fuck up”

£ he killed his neighbor, it

and that the

lower than at a National Guard

on April 3, 2019 and ProposesUsing IEDs and Firearms to Attack Police Officers andMilitary Service Members

27.

met in person. The meeting was

During that meeting, as detaile

intent to commit a large-scale

and described using firearms ay)

28. DOMINGO told the CHS

they both spoke to on the platf

The CHS said the person “was ta

yand DOMINGO told that person,

That would do damage. [. -]

.] blows up on the freeway, h

citizens injured.” When the CH

said “Then the fun starts.”

On the evening of April 3,

nm Los Angeles

2019, the CHS and DOMINGO

audio and video recorded.

d below, DOMINGO reaffirmed his

attack in the Los Angeles area,

d IEDs to do so.

that he was jealous of a person

orm who had more guns than he.

liking about like IEDs and stuff,”

an IED here, on the freeway?

An IED, like the ones in Iraq [.

undreds and maybe thousands of US

S asked “And then what?” DOMINGO

13

29. DOMINGO stated he war

Ramadi” and “Fallujah.” DOMIN

get, like, that will get like t

you bro, just the one IED that

nest, bro.”

30. DOMINGO reiterated hi

“our brothers in Christchurch 4d

slaughtered.” DOMINGO also sai

martyr.”

31. DOMINGO said his plan

rather than engage in a battle

DOMINGO said he intended to “ki

a"we flee,” similar to the “insur

they caused “small casualties H

the stress” on America and lead

32. DOMINGO said that alt

was more like the tactics used

prefer to operate like “al-Bagh

was not feasible because he and

manpower to succeed in such a 4

for ISIS and said if ISIS “came

to ISIS.

33. The CHS said law enfg

Turkish man who had recently ki

Netherlands. DOMINGO replied %

16 Based on my training anis a reference to Ayman al-Zawa

bO said,

i experience,

nted to “make ‘em bleed, like in

“a dead police that will

he police riled up. But I need

s going to stir up the hornet’s

s intent to conduct an attack for

nd our sisters who were

dhe was “not afraid to die a

was to “go in fast” and “raid,”

and try to “hold positions.”

1l enemies here and there, then

gency” in Iraq. DOMINGO said if

ere and there,” that would “put

to martial law.

hough such a hit-and-run strategy

by “Zawahiri,”1® and he would

dadi” and fight a “battle,” that

the CHS did not have enough

attle. DOMINGO expressed support

here,” he would swear allegiance

rceement in Europe had caught the

lled three people in the

hat he “had a feeling they were

saI believe “Zawahiri

hiri, the leader of Al-Qa’ ida.

14

gonna catch him,” and explaine

and crowded, and “he probably

said “you have to be patient.”

you know, I want to do it.”

want to do, show me.”

34.

small.” DOMINGO then drew a dj

scenarios for how he could atta

described a scenario in which f

also described another scenari¢

ballsy,” in which he and the CEH

car stopped at a red traffic 14

shoot into the car. DOMINGO sa

its windows down while he and t

car in their first meeting, on

clarified that, in this scenari

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

35. Later during the meet

diagram!® he had drawn, and tol

17 Based on my training an“dawla” is commonly used by vida

18 The CHS later recovered

law enforcement was able to rea

DOMINGO said “So what I’m thinking is,

DOMINGO then stated “Inshallah,

these ka

i that the Netherlands is small

didn’t plan it right.” The CHS

DOMINGO replied “Oh I know but

The CHS replied “Show me how you

yea, we start

Lagram and explained multiple

ack police officers. He then

ne could attack LAPD officers. He

, which he described as “really

iS would pull alongside a police

ght with its windows down and

id he had seen a police car with

he CHS were riding in the CHS’s

2019.March 18, DOMINGO later

o, he would want to get out of

ike dawla”)? with “lighter fluid,

o destroy the cameras in the

vestigation and making “life a

if

I’m down.”ffir, then wallahi,

ing, DOMINGO ripped up the

i the CHS they had “just talked

i experience, I know that the termlent extremists to refer to ISIS.

the pieces of the diagram, andssemble them.

15

about some serious shit,” incl

“murdering people.” DOMINGO be

with the CHS would result in “¢

warned that the CHS was in “dee

discussion with the CHS could 3:

and told the CHS

can’t expect to do these kind gq

forever [. .] At some point

be a man and you gotta stand yq

out that they could get caught

we’ re gonna die shahid.”

H.

36.

with the CHS. DOMINGO arrived

holding a backpack containing

covered by what appeared to be

the CHS expressed surprise that he

DOMINGO replied “If we’re going

commence fighting, jihad, yeah,

remain.” The CHS said the CHS

caught carrying a gun, and DOMINGO

Los Angeles to carry a gun.

remarked again that when DOMING

19 Fi sabillillah is an ArGod/jihad in the way of God,” oathe cause of God.”

“We broke fede

DOMINGO Meets With the CHSUsing IEDs and Firearms tq

On the evening of Apux

4

La

nding “murdering police” and

=lieved what he had just discussed

a2 lot of charges already” and

2p shit.” DOMINGO believed his

result in a “conspiracy charge”

ral law.” DOMINGO said “You

f things and remain anonymous

they’ re gonna know and you gotta

ur ground.” When the CHS pointed

eventually, DOMINGO replied “Then

on April 19, 2019 and Discusses

Attack an Upcoming Rally

il 19, 2019, DOMINGO again met

wearing camouflage pants and

n AK-47 style rifle partially

a shirt. Upon DOMINGO’s arrival,

had brought the rifle, and

to commit-- if we’re going to

fi sabilillah,1% you gotta

did not want DOMINGO to get

replied that it was common in

the CHSter in the night,

O arrived with the rifle, the CHS

abic term meaning “In the way ofr “for the sake of God,” or “for

16

thought he was crazy, and DOMI}

you that I’m serious.”

37. DOMINGO asked about

refer to individuals located ot

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?

know,

for Christians, who were

CHS said, “so that’s it?

where?” DOMINGO said,

serious.

-]

Are you serious?”

sooner or later,

38.

DOMINGO said,

brothers and sister across the

39. During the meeting,

like, IEDs?” DOMINGO said,

you want to,

know someone,

make it?”

20 Based on my training an

the facts,shooting homeless people.

Wh

and was tired, but that i

celeby

You wW

“Anywhey

DG

this was gq

The CHS and DOMINGO t

“We don’t have td

the CHS said,

“You want to?”

I might know somedne.

that’s perfect [,

The CHS said he did.

DOMINGO seemed to su

1GO replied “I just wanted to show

nomeless people (appearing to

htiside the meeting location), and

[. +]

The CHS said the CHS had been

at I’m saying2°® You're not

the past two weeks and “wanted to

DOMINGO said he was serious, and

ight, then okay.” The CHS said

ere?” DOMINGO said he did not

t was a “holy day for yahud” and

ating Passover and Faster. The

anna do it? You have, like,

“one. The CHS replied, “You’re not

MINGO replied, “I’m serious [.

nna happen.”

hen prayed and ate, after which

do this. But we do this for our

world, oppressed, yeah?”

“So you remember,

The CHS said, “if

“DOMINGO replied “If you

-] but does he know how to

DOMINGO said “So he can write

A experience and the totality ofggest an attack in the form of

17

down instructions on how to ma

“Probably.” The CHS said the yj

said “Okay, tell him this.

clearly, and then wallahi. Yo

masse, you know that [. . .]

The CHS said “He

[.

buying guns.”

buy it little by little |

CHS said, “but where can you bu

e it?” The CHS replied,

erson was from Iraq. DOMINGO

Write down the instructions,

h can’t buy these ingredients en

because that’s more suspicious than

w then?” DOMINGO replied, “We'll

so it’s not suspicious.” The

y it from?” DOMINGO replied by

naming three home improvement stores and said “They’ re

everywhere. Here’s the thing,

explosives.” The CHS said, “th

it’s easy. It’s not easy, but

time into it, everyone can maké

wallahi, they don’t want to.

Only a terrorist would want to,

40. During the meeting, BD

more damage and would be better

make it, I just don’t know how,

history but I failed chemistry:

So if that brother is willing t

“Should I talk to him?said, WwW

replied, “Talk to him, if not m

make it, don’t force him. But

Fucking to the letter details.

41. DOMINGO then asked, *

you think he’1ll tell the feds?”

guarantee he’s not going to.”

Because,

the average person can make

ey can?” DOMINGO said, “Yeah,

it’s not hard. If they put the

explosives. But obviously,

you know, why would you?

right?”

OMINGO said, “The IEDs would do

to transport [. . .] We’ll both

I’il be honest. I’m smart in

Science is not my forte [. . .]

“"o make it for us. .. The CHS

hat do you think?” DOMINGO

ake it. If he doesn’t want to

ask him how. Details. [. . .]

Ask him.”

Do you think he’s a snitch? Do

The CHS replied, “I can

DOMINGO replied, “If he’s not

18

gonna tell the feds, then you

“put he’s not gonna, like,

replied that was OK, and “if h

make him take part. But that

and we should ask him, if you’

least teach me how?”

42. DOMINGO instructed th

what was happening to Muslims.

you know, like, bro, al-Sunnah

I know you have a family and I

asked how the CHS knew the ass¢q

at the same Mosque and the assq

“does fiAmerica. DOMINGO said,

have the same ideas.”

can talk to him.” The CHS said,

DOMINGO

a doesn’t want to take part, don’t

is an avenue we shouldn’t waste,

re not gonna help, can you at

ne CHS to remind the associate

DOMINGO stated “just remind him,

wal-Jummah is under attack. And

m not gonna force you.” DOMINGO

ciate, and the CHS said they were

ciate had been criticizing

ne hate kuffar?” The CHS said “He hates kuffar, but because he has a family, he doesn’t want to

get involved.” DOMINGO replie

Talk to him some more [. -]

you ever made explosives? Like

and pieces.”

43. DOMINGO also brought

“That’s understandable [. -]

ou can be casual about it. Have

, haha, a joke. You can get bits

up an upcoming April 28, 2019

rally in Long Beach organized by a “white nationalist” group,

and told the CHS it was going t

CHS asked, “So what’s the plan?

scope out the area.

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

CHS asked DOMINGO how he heard

he heard about it on the news and online.

DOMINGO wanted to carry out the

We’1l have

o take place at Bluff Park. The

“ao DOMINGO said, “We'll have to

to keep up everyday updates

The

about the rally, and DOMINGO said

The CHS asked how

attack, and DOMINGO said,

19

“Parking’s gonna be an issue, We could do hit and run [. . .]

We drive by, we empty a magazine or two. An AK. And we book

it.”

44. The CHS asked “but y

damage?” DOMINGO replied that

and “we can make it before. Ii

[. . .] ask your brother. Ask

u said the IED will do more

“the IED will do more damage,”

‘s coming up. We have two weeks

the brother.” The CHS said “so

if we make it before, we can actually-[.]” DOMINGO interrupted

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 ng

detonate it in a crowd. Which

ed that he did not know how to

“I need you to talk to him, and

t a snitch.” DOMINGO instructed

the CHS to “have him write it down, and then we’ll see. We can

make it. Even a small IED woul

The human body is very easy to

damage, but a big IED just in d

looking at least 20 people dead

so around 50 at least.” The CH

headline.” DOMINGO replied, “]

are going to storm. Remember t

bombers, it stirred up a hornet

is going to be locked down.”

46. The CHS said “are you

serious are you serious?” DOMI

to do the IED route, which is gs

will do a lot more damage crowd

d do damage in a crowd. [. . .]

break. A grenade can do a lot of

backpack, in a crowd? You’re

, Maybe, maybe 30 people injured,

S said, “That’s going to be the

think if we do the IED route we

he Tsarnaev brothers, the Boston

s nest [. . .] If we do this, LA

sure you want to do this, I am

NGO replied “I am serious, I want

omewhat the better idea. An IED

wise. We bring it and leave it

20

in the car. We each bring ad

we can escape [. -] we can

we possibly can change in the

injured and take off clothes and change.

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?”

ifferent set of clothes [. . .]

crowd.

so

change in the car, be honest bro

We can pretend we are

The best disguise is

IED thing is sounding more

going spraying and praying.”

The CHS asked if they would be able to change into

replied “Perhaps, we are going to

a The CHS asked “what if we

DOMINGO replied “OK now we have

an IED that we can use at our disposal.”

lies Materials to Create and Use

e CHS wrote in a private message

I. DOMINGO Purchases and Supfa Weapon of Mass Destruction

48. On April 22, 2019, th

to DOMINGO “I talk to the broth

help us but we have to get him

to come tomorrow to pick it up,

“get it all,” and the CHS said

purchasing different parts of t

The CHS said “I wildetection.

[. . .] So your part is: Chri

shrapn[el] We have to buy the

to come tomorrow to pick it up

the pressure cooker and a remot

about nails?” The CHS said “Li

whatever goes inside.” er and he said he’s willing to

the stuff tonight And he’s going

” DOMINGO asked if the CHS 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

DOMINGO asked “whate control.”

ke nails or [screw] driver

21

49. Shortly thereafter,

DOMINGO drive to multiple home

officers saw DOMINGO purchase

a self-service kiosk using a debit card.

closed-circuit television vide

store, which showed that DOMIN

law enforcement officers observed

improvement stores. At one store

several large boxes of nails from

Agents later obtained

and transaction records from the

bO purchased approximately eight

pounds of three-and-a-half-inch and longer nails using his debit

card.

50. Later that day,

“u wanna try n pick up what I &k

said “Maybe today because we hd

DOMINGO replied “got nails look

CHS would look for the lights t

“I can reimburse you tomorrow.’

51. On the evening of Apr.

with the CHS. The meeting was

DOMINGO walked in with a bag cq

had purchased the day before.

control race cars that the CHS

table.

52. The CHS told DOMINGO

this.” DOMINGO said that the é¢

cancelled, and proposed attacki

Nationalist” rally in Huntingt¢

April 27, 2019. DOMINGO said t

be on the beach, which may maké

many people because it was a wi

DOMINGO

wrote the CHS again and asked

uy today or tomorrow.” The CHS

ve to give it to him tomorrow.”

in for lghts.” The CHS said the

he next day, and DOMINGO replied

il 23, 2019, DOMINGO again met

audio and video recorded.

ntaining the boxes of nails he

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

nm Beach, California, on Saturday,

he Huntington Beach rally would

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

was a more enclosed space and 4

from a blast.

on the Santa Monica Pier would

53.

to provide to the UC to use in

specifically bought three-inch

enough to penetrate the human k

54. DOMINGO examined the

had purchased and saw that the

up to a distance of 100 feet.

the blast radius would extend kh

perhaps the remote controls cou

work from a distance of more th

that if they conducted the atta

would remain on the pier and de

should stay further away and le

detonated. DOMINGO said he wou

afraid to die a martyr.

55. DOMINGO showed the CH

on his phone, and pointed out ]

near the entrance to the pier.

56. After about 45 minutes,

when it was crowded, because it

eople would not be able to escape

DOMINGO said that detonating an IED with a timer

cause a lot of casualties.

DOMINGO confirmed that he had bought three-inch nails

making IEDs. DOMINGO said he

nails because they would be long

ody and puncture internal organs.

remote control cars that the CHS

remote controls would work only

DOMINGO expressed concern that

eyond 100 feet. The CHS said

ld be modified so that they would

an 100 feet. DOMINGO then said

ck at the Santa Monica Pier, he

tonate the IED, but the CHS

ave the scene after the IED

ld bring his gun, and was not

S a map of the Santa Monica Pier

ocations-where they could stand

the UC arrived. DOMINGO asked

the UC if the remote control cquld be modified to detonate the

IED from up to three quarters cf a mile away.

the UC the boxes of three-inch

DOMINGO showed

nails he had bought, and told the

23

uc the nails were

long as the nails

57. DOMINGO explained to

discussing a very

a crime. DOMINGO asked the UC

the IED, and the UC said it wou

58.

remote control, and the UC sug¢

instead of a remote control to

replied that “would be perfect

bail” and watch the blast from

s59. DOMINGO said they

operation because he wanted to

experience Ramadan, which would

UC again said they should all 4d

other.

60. DOMINGO gave the UC

get back in touch in a few days.

should talk only on the platfoy

that what they were talking abd

offered to buy more parts for t

said he would let them know whe

0.the operation and when the UC

asked how he would know when Dd

complete the IED. DOMINGO said

4dcontaining a photograph, like

ahead” for the operation.

long enough to kill their intended victims,

serious matter,

so

did not get bent in the blast.

the CHS and the UC that they were

and even talking about it was

how long it would take to make

ld take a few days.

DOMINGO asked again about the 100-foot reach of the

ested they could use a timer

detonate the device. DOMINGO

” because with a timer “we can

a safe distance.

hould consider delaying the

finish reading the Quran and

2019.be starting on May 5, The

gree they would not pressure each

is phone number and said he would

DOMINGO stressed that they

m, and cautioned the CHS and UC

a”ut were “federal charges. He

he IED if the UC needed them, and

n he was ready to proceed with

hould complete the IED. The UC

MINGO was ready for him to

he would send the UC a message

“meme,” which would be the “go

24

J.

61. On the evening of Ap

CHS online. DOMINGO said was

The CHS said the UC had said p

the Long Beach rally so it seer

happening, and they could exec

planned.

62. DOMINGO replied that

DOMINGO Finalizes His Attack Plans

ril 24, 2019, DOMINGO spoke to the

angry and had a rough day at work.

sople were talking about going to

ned the rally was really

hte the operation as previously

he did not want to rush into the

operation, and since they had talked about waiting until after

Ramadan,

finish making thé IED. DOMING

that the event was going to go

proceed with the operation.

the IED could be ready in time

he did not want to cal 1 the UC now and rush the UC to

said if he had known yesterday

forward, he would have wanted to

The CHS replied that the UC said

for the event, and they could use

the timer to detonate it and watch the explosion from a safe

distance. DOMINGO said,

not rush into this headfirst.

one of us will have to drive td

completed IED from the UC,

63.

explosion from a distance, and

to watch it but “ideally we shg

would be panicking and their ca

“the timer is great,” but said,

or g

“Lets

If I give the go ahead [. . .]

Victorville” to collect the

erhaps meet the UC halfway.

The CHS replied it would be great to watch the

DOMINGO agreed it “would be cool”

uld be gone” because everyone

lm demeanor may arouse suspicion.

The CHS said they could set the timer and then go home and watch

the blast on television,

publicity,

and DOMINGO said he did not need

and would “rather just hear about it on 4chan.”

25

DOMINGO said, “I know it’s gony

sleep on it.”

64. The CHS said the CHS

operation,

complete the IED. The CHS saic

net contact the UC over the phd 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 UC’s] down, I

na be big.

and DOMINGO asked if

1 no,

But let

[. +] Let me just

was ready to go forward with the

the CHS already told the UC to

and DOMINGO said they should

me. DOMINGO continued, “Fuck,

me sleep on it.” DOMINGO said

ng into this too hastily,” and he

“motivated,” but also wanted

ed “I say me and you we’ll sieep

dont have a problem with it.”

The CHS said they could proceed with the operation and still

conduct more attacks after Rama

Let’s just sleep on it. If we’

the go-ahead. I’11 give the gq

65. The CHS suggested the

but DOMINGO Abefore the event,

because people might see it. If

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

The CHS offered to carry the IB

replied, “I was thinking I'd de

said the UC also could blend in

was Caucasian. DOMINGO replied

dan, 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 IED

ut 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.

D into the event, but DOMINGO

it. I’d blend in.” The CHS

with the “Nazis” because the UC

he was “ready,” but “this shit

26

we're talking about isn’t easy

they sleep on it, and if “we’r

then DOMINGO would contact the

66. The next day, at appi

sent the UC a message containirz

and skyline. Based on my trair

of this investigation, I beliey

“ao DOMINGO suggested again that

= still feeling pumped by lunch,”

UC to proceed with the operation.

roximately 12:00 p.m., DOMINGO

ng a photograph of a crescent moon

1ing and experience and knowledge

ve this was the “go ahead” meme

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

proceed with the operation.

67. The UC responded, “O

wrote “im waiting for the homie

gonna be on the weekend?” The

presents to make them fit in at

“okk do what you need to do the

didn’t have to do all this toda

OK and “the presents will be ready tomorrow morning.”

replied “if ur sure ok then kee

with em.”

68. The UC asked DOMINGO

”tay I hear and obey. DOMINGO

s text, I think the kick back is

UC replied “I need to wrap the

the party spot.” DOMINGO wrote

party is on the weekend tho u

y.” The uc responded that it was

DOMINGO

p em somewhere no one will fuck

for help with wrapping the

“presents” and asked “do you know what the party spot looks

like? I want to match the wrap ping with what’s natural.”

DOMINGO replied “you don’t have something like convenient like a

bag y go thru the trouble.”

69.

uc, “are you coming to LA?”

finish the last. piece of the py

the presents somewhere safe lol.

The next morning, Apyil 26, 2019, DOMINGO wrote to the

The UC replied “Yeah akhi after I

esents.” DOMINGO replied “keep

ao The UC said the UC wanted to

27

“stay in la for the party” and

sure [the CHS’s] couch is good

70. DOMINGO said he was ¢

someone and the UC replied “we

sha Allah heading to [Victor] vi

idea.” DOMINGO replied “I‘1l t

platform] considering our scheg

find the parties address and sh

times so we’ll jus say hin go

place is crucial Youre good at

‘im just practical albeit blunt

71. DOMINGO said he was g

groceries, pray, then “ill be ¢

wrote “u want me to pick u up?

mean I think the party is on su

“”kno. The UC wrote that they n

DOMINGO replied “if you insist

aagreed to méet the UC and CHS

72. At approximately 7:15

and CHS to finalize plans for t

audio and video recorded. The

what DOMINGO thought were comp]

should set the timer on the IED

73. DOMINGO then drove th

Long Beach to surveil the locat

drive, DOMINGO said the plan wa

on Sunday, before too'many peop

DOMINGO replied “ok no prob im

“"

yoing to Victorville to see

need to plan the party today in

lle after the party is a good

alk with [the CHS] on [the

is it shud be simple [. -] tho

10W up but like I said the prayer

“ The UC said “Ok inshaAllah

this akhi,” and DOMINGO replied

as shit.”

oing to work out, shower, get

n my way afternoon.” DOMINGO

Is that what u had in mind??

+]

I

nday [. so we got time ya

eeded to meet that day and

prolly later tonight then,” and

t 7:00 p.m.

p.m., DOMINGO met with the UC

he operation. The meeting was

UC showed DOMINGO how to operate

eted IEDs. DOMINGO said they

s for 5 to 30 minutes.

e UC and the CHS to Bluff Park in

ion for the attack. During the

s to arrive early in the morning

le showed up for the rally, and

28

disguise themselves as counter;protestors.

past the Port of Long Beach, D

they survived the attack on Sunday,

attacks, including at the Long

would significantly disrupt the U.S.

discussed initiating an attack

74. When they arrived at

the location with the UC and CHS.

to find the most “crowded” area

people in the attack. DOMINGO

after they detonated the explos

the event in separate el

leave the scene without being

75. After surveilling the

and CHS back to their previous

again inspected the IEDs in adv

then carried one of the IEDs ou

UC’s vehicle,

//

//

//

at which point he

As DOMINGO drove

MINGO told the UC and CHS that if

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

s in order to kill the most

instructed the UC and CHS that

ives, they should walk away from

s and get in separate cars to

etected.

location, DOMINGO drove the UC

meeting location, where they

ance of their attack. DOMINGO

t of the location to put into the

was arrested by the FBI.

29

Vix CONCLUSION

76. For the reasons described above, I respectfully submit

there is probable cause to issue the requested criminal

complaint and arrest warrant.

a ; etts,TASHA COOLIDGE, Special AgentFEDERAL BUREAU OF INVESTIGATION

methis(ito and sworn before

me this Faasy of April, 2019.

i5! NalaUNITED STATES MAGISTRATE JUDGE

30