Criminal complaint against alleged Islamic State sympathizer

The FBI arrested an Ohio man Wednesday for allegedly plotting to set off pipe bombs at the U.S. Capitol and then shoot and kill lawmakers and their staff, according to federal court documents. Ohio man arrested in alleged plot to bomb Capitol, kill lawmakers

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.5 57'
A0 91 (Rev. 08t09} Criminal Complaint ti I

UNITED STATES DISTRICT COURT
for the -_.rir tifizl?i it 2:
Southern District of Ohio

I ll

CaseNo. 1

United States of America
v.

Christopher Lee Cornell

Defendant(s)

CRIMINAL COMPLAINT

1, the complainant in this case, state that the following is true to the best of my knowledge and belief.

On or about the date(s) of January 14, 2015 in the county of Hamilton in the
Southern District of Ohio the defendant(s) violated:
Code Section O?ense Description
18 U.S.C. Section 1114 Attempted Killing of a US. Government Of?cer
18 U.S.C. Section 924(0) Possession of Firearm in Furtherance of Attempted Crime of Violence

This criminal complaint is based on these facts:

See the Af?davit of Special Agent T.A. Staderman.

if Continued on the attached sheet.

Complainant ?s signature

T.A. Staderman, FBI Special Aqent

Printed name and titie

Sworn to before me and signed in my presence.

\12;
Date: January 14, 2015 \?o/mew

Judge! ?5 Signature

City and state: Cincinnati, Ohio Stephanie K. Bowman. United States Magistrate Judge
Printed name and title

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AFFIDAVIT IN SUPPORT OF COMPLAINT

1, Special Agent T.A. Staderman, being ?rst duly sworn, hereby depose and state as
follows:

INTRODUCTION AND AGENT BACKGROUND

1. I am a Special Agent with the Federal Bureau oflnvestigation, and have been
since 2008. As a Special Agent, 1 have been assigned to investigate various Domestic and
International Terrorism matters and am assigned to the Cincinnati?Dayton Joint Terrorism
Task Force.

2. I make this affidavit in support ofa Complaint charging Defendant
CHRISTOPHER LEE CORNELL (also known as Raheel Mahrus Ubaydah) with violating
Title 18, United States Code, Section 1114 (Attempted Killing ofa US. Government Officer);
and Title 18, United States Code, Section 924(c) (Possession of Firearm in Furtherance of
Attempted Crime of Violence); on or about January 14, 2015, in Cincinnati, Ohio, in the
Southern District othio.

3. The facts in this affidavit are based on my personal observations. my training and
experience, and information obtained from other agents and witnesses. This af?davit is intended
to show merely that there is sufficient probable cause for the requested complaint and does not
set forth all of my knowledge about this matter.

4. Title 18, United States Code, Section 1 14 prohibits, in pertinent part, a person
from ?attempt[ing] to kill any of?cer or employee ofthe United States or of any agency in any
branch ofthe United States Government . . . while such officer or employee is engaged in or on

account of the performance of official duties.?

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5. Title 18, United States Code, Section 924(c), in pertinent part, prohibits a person
from possessing a ?rearm in furtherance ofa crime of violence.

6. On October 15, 2004, the United States Secretary of State designated aI-Qa?ida in
Iraq (AQI), then known as Jam?at a1 Tawhid wa?al-Jihad, as a Foreign Terrorist Organization
(FTO) under Section 219 ofthe Immigration and Nationality Act and as a Specially Designated
Global Terrorist under section 1(b) of Executive Order 13224.

7. On May 15, 2014, the Secretary of State amended the designation of al-Qa?ida in
Iraq as a Foreign "Terrorist Organization under Section 219 ofthe Immigration and Nationality
Act and as a Specially Designated Global Terrorist entity under section 1(b) of Executive Order
13224 to add the alias Islamic State ofIraq and the Levant (ISIL) as its primary name. The
Secretary also added the following aliases to the ISIL listing: the Islamic State oflraq and al-
Sham (ISIS), the Islamic State of Iraq and Syria (ISIS), ad?Dawla al-Islamiyya f1 aI-?Iraq wa?sh-
Sham, Daesh, Dawla al Islamiya, and AI-Furqan Establishment for Media Production. Although
the group has never called itseIfAQI this name has frequently been used to describe it through
its history.

8. From my participation in the investigation, including my review of FBI reports,
Twitter communications, and recordings of the Defendant?s statements, I have learned the
following:

a. At all times relevant, Defendant CHRISTOPHER CORNELL has resided in
Cincinnati, Ohio, in the Southern District othio.

b. Beginning in approximately Summer 2014 and continuing to January 2015,
Defendant CHRISTOPHER CORNELL established and used Twitter accounts

under the alias Raheel Mahrus Ubaydah.

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c. Using his Twitter accounts, Defendant CHRISTOPHER CORNELL posted
statements, videos, and other content indicating his support for ISIL. Defendant
CHRISTOPHER CORNELL also voiced his support for violentjihad, as well
as support for violent attacks committed by others in North America and
elsewhere.

(1. in the fall of2014, a Confidential Human Source (CHS) who began cooperating
with the FBI in order to obtain favorable treatment with respect to his criminal
exposure on an unrelated case, supplied information to the FBI about a person
using the alias ofRaheel Mahrus Ubaydah (Defendant CHRISTOPHER
CORNELL) who posted comments and information supportive of ISIL through
Twitter accounts.

e. The CH8 and Defendant CHRISTOPHER CORNELL ?rst made contact with
each other over Twitter in August 2014, then began communicating through an
instant messaging platform separate from Twitter.

f. On August 29, 2014, CORNELL wrote an instant message on a separate messaging
platform to the CH8 that he had been in contact with persons overseas and he did not
think he would receive speci?c authorization to conduct a terrorist attack in the United
States, but stated that he wanted to go forward with violentjihad and opined that this
would be their way ofsupporting lSlL. Speci?cally CORNELL stated that, ?l believe
that we should just wagejihad under our own orders and plan attacks and everything." In
undertaking these actions, CORNELL stated that he thought he was fulfilling the
directives of violentjihadists. CORNELL wrote that, ?we already got a thumbs up from

the Brothers over there and Anwar a] Awlaki before his and many others.?

CORNELL made it clear that the attacks he contemplated were to be conducted in

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alliance with ISIL by writing, believe we should meet up and make our own group in
alliance with the Islamic State here and plan operations ourselves."

Defendant CHRISTOPHER CORNELL and the CHS met in Cincinnati, Ohio
on October 17-18, 2014. During the meeting, Defendant CHRISTOPHER
CORNELL discussed his support of ISIL and wagingjihad. Defendant
CHRISTOPHER CORNELL stated that they needed weapons and wanted to
?move? in December 2014, but he did not want to reveal his plans at their first
meeting. Defendant CHRISTOPHER CORNELL also showed the CH8
jihadist videos and information about the construction of bombs on

laptop computer.

In a subsequent instant message to the CH8, Defendant CHRISTOPHER
CORNELL stated that their first meeting was to get acquainted, the second
meeting, would involve the discussion of theirjihadist plans, and the third meeting
would be to ?move.?

Defendant CHRISTOPHER CORNELL and the CH8 met in Cincinnati, Ohio
for a second time on November 10-1 1, 2014. During the meeting, Defendant
CHRISTOPHER CORNELL indicated that he considered the members of
Congress as enemies and that he intended to conduct an attack on the US. Capitol
in Washington, DC. Defendant CHRISTOPHER CORNELL explained that
he and CH8 would travel to Washington, DC, conduct reconnaissance ofthe
security for certain government buildings, including the US. Capitol, and then
execute a plan of attack on the US. Capitol. Defendant CHRISTOPHER

CORNELL speci?cally planned that he and the CHS would build, plant, and

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detonate pipe bombs at and near the US. Capitol, then use ?rearms to shoot and
kill employees and of?cials in the US. Capitol.

j. Using his computer, Defendant CHRISTOPHER CORNELL showed the CH8
that he had researched the targeted government buildings in Washington, DC,
researched the construction ofpipe bombs, and researched the cost and sourcing
for ?rearms and the ingredients for pipe bombs. Defendant CHRISTOPHER
CORNELL also identi?ed a gun store nearby that would sell a Smith Wesson
semi?automatic rifle.

k. In furtherance ofthe planned attack, Defendant CHRISTOPHER CORNELL
saved money to fund the attack, researched the targeted government buildings in
Washington, DC, researched the construction ofpipe bombs, and researched the
cost and sourcing for ?rearms and the ingredients for pipe bombs.

9. On or about January 13 and 14, 2015, in the Southern District of Ohio, Defendant
CHRISTOPHER CORNELL and the CH8 discussed and took the ?nal steps in order to travel
to Washington, DC. to execute the plan.

10. On or about January 14, 2015. in the Southern District of Ohio, Defendant
CHRISTOPHER CORNELL purchased and possessed a ?rearm, namely 2 Armalite Inc., Model
5.56mm, semi?automatic rifles (Serial numbers: and and
approximately 600 rounds of ammunition, with the plan to travel to Washington, DC, and kill
employees and of?cers working in and around the US. Capitol.

1 1. Defendant CHRISTOPHER CORNELL was arrested by law enforcement on

January 14, 2015, after Defendant purchased and took possession of the ?rearm.

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12. Based on the foregoing, I believe there is probable cause to believe that
Defendant CHRISTOPHER LEE CORNELL (also known as Raheel Mahrus Ubaydah)
violated Title 18, United States Code, Section 1 1 14 (Attempted Killing ofa U.S. Government
Of?cer); and Title 18, United States Code, Section 924(c) (Possession ofFirearm in Furtherance
of Attempted Crime of Violence); on or about January 14, 2015, in Cincinnati, Ohio, in the
Southern District of Ohio.

Respectfully submitted,
T.A. Staderman

Special Agent
Federal Bureau of Investigation

Subscribed and sworn to before me on January '4 2015

Mam/27K ?(f7me

K. BOWMAN
UNITED STATES MAGISTRATE JUDGE