Excerpts from Complaint:
This Affidavit is offered in support of a criminal complaint charging Curtis Wayne ALLEN, Patrick Eugene STEIN, and Gavin Wayne WRIGHT with violations of federal statutes concerning Arson/Explosives and Use of a Weapon of Mass Destruction (18 U.S.C. §§ 2, 844(h), (i), & (m), and 2332a).
2. Since February 2016, the Federal Bureau of Investigation (FBI) has been conducting a domestic terrorism investigation of a group of individuals operating in southwestern Kansas who identifies themselves as “the Crusaders.” This is a militia group whose members support and espouse sovereign citizen, anti-government, anti-Muslim, and anti immigrant extremist beliefs. Certain key members of this group, including Patrick STEIN, Curtis ALLEN, and Gavin WRIGHT, have been regularly meeting and planning to carry out a violent attack against Muslims in their community and have taken steps in furtherance of accomplishing this, including identifying a target location.
BACKGROUND OF CASE
Through recordings, CHS cooperation and reporting, and open source and social media investigation, STEIN, ALLEN, and WRIGHT have been identified as members of the aforementioned militia group. They have also been determined to be the primary architects of the attack plan. STEIN has been identified as a leader within the Crusaders. ALLEN is a close associate of STEIN’s, and has led meetings of the Crusaders. WRIGHT is also a member of the Crusaders and has participated in the planning of the attack.
9. The investigation to date has revealed that Crusaders members Patrick STEIN, Curtis ALLEN, and Gavin WRIGHT are conspiring to carry out a domestic terrorist attack by using an improvised explosive device (IED) to destroy an apartment complex in Garden City, Kansas, which contains a mosque and is home to many Muslims. Their activities have demonstrated, and continue to demonstrate, actions taken in furtherance of this scheme. They have routinely expressed a hatred for Muslims, individuals of Somali descent, and immigrants. They chose the target location based on their hatred of these groups, their perception that these groups represent a threat to American society, a desire to inspire other militia groups, and a desire to “wake people up.”
On one such surveillance in February 2016 when the CHS was driving STEIN around, STEIN at various times yelled at Somali women dressed in traditional garb, calling them “fucking raghead bitches.” STEIN also referred to Somalis as “cockroaches” and said several times that they needed to eliminate the Somalis. During the surveillance, STEIN had with him a pistol, an assault rifle with several magazines, a ballistic vest, and a night vision scope. He also mentioned to the CHS that he had done several surveillances like this on his own in the past and that he always made sure he was armed. STEIN also discussed Oklahoma City and the bomb used (referring to the fuel oil and ammonium nitrate device used by Timothy McVeigh to destroy the Murrah Building in Oklahoma City). He was looking for any more explosives or things he could use to blow things up
11. During a Zello conference call in April 2016, STEIN stated, “Make sure if you start using your bow on them cockroaches, make sure you dip them in pig’s blood before you shoot them.”
In a May 2016 meeting, ALLEN stated: “We need to get some signs made up…hundreds of them, kind of like the redneck deal, ‘here’s your sign’ and just put right there on it: I SUPPORT ILLEGAL IMMIGRATION, I GO AGAINST THE CONSTITUTION ON A DAILY BASIS, I DO NOT HAVE ANY CARE FOR MY FELLOW CITIZENS IN THE STATE OR IN THE TOWN THAT I REPRESENT…and then for every one of them that we blow the top of their head off we just put that around their neck.” STEIN said he liked the idea. This conversation was recorded via consensual monitoring.
13. During a phone call to the CHS in May 2016, STEIN talked about some of his frustrations. STEIN wanted to just go do something. He said he wanted to get a .22, go over to Garden City, Kansas, start kicking in the doors of the Somali apartments, and kill them one by one. He wanted to use a .22 because it was quieter and he also mentioned he wanted to buy or make a silencer
In June 2016, STEIN called for a meeting with the Crusaders. Attendees included STEIN and the CHS. They met in a field with the stated intention of avoiding surveillance by the FBI. During the meeting, STEIN brought up the Orlando night club shooting and said that something needed to be done in response to this act of terrorism. He proposed carrying out an attack similar to the Orlando shooting against a Muslim refugee location in Garden City. The group discussed how they could carry out such an attack.
During an in-person meeting in June 2016, STEIN stated: “Garden City for example, I know exactly where probably a majority of those motherfuckers are at in their homes…in Garden City…and…they’ve got these apartment complexes over there where literally every fucking apartment…that’s all it is, fucking goddamn cockroaches…and…I mean I wouldn’t be against if I could get a hold of some RPG’s (rocket propelled grenades), I’ll run some RPG’s right through…I’ll blow every goddamn building up right there…boom…I’m outta there.”
Read the rest of the affidavit which refers to the gathering of evidence (one of the guys beat up his girlfriend and she called the authorities and notified them about explosives,etc)