IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF OKLAHOMA
UNITED STATES OF AMERICA, )
v. ) No. M-95-98-H
TIMOTHY JAMES MCVEIGH, ) CRIMINAL COMPLAINT
I, the undersigned complainant being duly sworn state the following
is true and correct to the best of my knowledge and belief. On or
about April 19, 1995, in Oklahoma City, Oklahoma County, in the
Western District of Oklahoma defendant(s) did, maliciously damage and
destroy by means of fire or an explosive, any building, vehicle, and
other personal or real property in whole or in part owned, possessed,
or used by the United States, any department or agency thereof, in
violation of Title 18, United States Code, Section(s) 844(f).
I further state that I am a(n) Special Agent of the Federal Bureau of
Investigation and that this complaint is based on the following
See attached Affidavit of Special Agent Henry C. Gibbons, Federal
Bureau of Investigation, which is incorporated and made a part hereof
/s/ Henry C. Gibbons
Federal Bureau of Investigation
Sworn to before me and subscribed in ny presence, on this 21 day of
April, 1995, at Oklahoma City, Oklahoma.
RONALD L. HOWLAND
UNITED STATES MAGISTRATE JUDGE /s/ Ronald L. Howland
STATE OF OKLAHOMA:
COUNTY OF OKLAHOMA
I, HENRY C. GIBBONS, being duly sworn, do hereby state that I am an
agent with the Federal Bureau of Investigation, having been so
employed for 26 years and as such am vested with the authority to
investigate violations of federal laws, including Title 18, United
States Code, Section 844 (f).
Further, the Affiant states as follows:
1. The following information has been received by the Federal Bureau
of Investigation over the period from April 19 through April 21,
2. On April 19, 1995, a massive explosion detonated outside the
Alfred P. Murrah building in Oklahoma City, Oklahoma, at
approximately 9:00 a.m.
3. Investigation by Federal agents at the scene of the explosion
have determined that the explosive was contained in a 1993 Ford owned
by Ryder Rental company.
a. A vehicle identification number (VIN) was found at the scene of
the explosion and determined to be from a part of the truck that
contained the explosive.
b. The VIN was traced to a truck owned by Ryder Rentals of Miami,
c. Ryder Rentals informed the FBI that the truck was assigned to a
rental company known as Elliot's Body Shop in Junction City, Kansas.
4. The rental agent at Elliot's Body Shop in Junction
City, Kansas was interviewed by the FBI on April 19, 1995. The
individual who signed the rental agreement provided the following
a. The person who signed the rental agreement identified himself as
BOB KLING, SSN: 962-42-9694, South Dakota's driver's license number
YF942A6, and provided a home address of 428 Malt Drive, Redfield,
South Dakota. The person listed the destination as 428 Maple Drive,
b. Subsequent investigation conducted by the FBI determine all this
information to be bogus.
5. On April 20, 1995, the rental agent was recontacted and assisted
in the creation of composite drawings. The rental agent has told the
FBI that the composite drawings are fair and accurate depictions of
the individuals who rented the truck.
6. On April 20, 1995, the FBI interviewed three witnesses who wre
near the scene of the explosion at Alfred P. Murrah Federal Building
prior to the determination of the explosives. The three witnesses
were shown a copy of the composite drawing of Unsub #1 and identified
him as closely resembling a person the witnesses had seen in front of
the Alfred P. Murrah Building where the explosion occurred on April
19, 1995. The witnesses advised the FBI that they observed a person
identified as Unsub #1 at approximately 8:40 a.m. on April 19, 1995,
when they entered the building. They again observed Unsub #1 at
approximately 8:55 a.m., still in front of the 5th Road entrance of
the building when they departed just minutes before the explosion.
7. The Alfred P. Murrah building is used by various agencies of the
United States, including Agriculture Department Department of the
Army, the Defense Department, Federal Highway Administration, General
Accouinting Office, General Services Administration, Social Security
Administration, Labor Department, Marine Corps, Small Business
Administration, Transportation Department, United States Secret
Service, Bureau of Alcohol, Tobacco and Firearms, and Veteran's
8. The composite drawings were shown to employees at various motels
and commercial establishments in the Junction City, Kansas, vicinity.
Employees of the Dreamland Motel in Junction City Kansas, advised FBI
agents that an individual resembling Unsub #1 depicted in the
composite drawings had been a guest at the Motel from April 14
through April 18, 1995. This individual had registered at the Motel
under the name of Tim McVeigh, listed his automobile as bearing an
Oklahoma license plate with an illegible plate number, and provided a
Michigan address, on North Van Dyke Road in Decker, Michigan. The
individual was seen driving a car described as a Mercury from the
9. A check of Michigan Department of motor Vehicle records shows a
license in the name of Timothy J. McViegh, date of birth April 23,
1968, with an address of 3616 North Nan Dyke Road, Decker, Michigan.
This Michigan license was renewed by McViegh on April 8, 1995.
McViegh had a prior license issued in the state of Kansas on March
21, 1990, and surrendered to Michigan in November 1993, with the
following address: P.O. Box 2153, Fort Riley, Kansas.
10. Further investigation shows that the property at 3616 North Van
Dyke Road, Decker, Michigan, is associated with James Douglas Nichols
and his brother Terry Lynn Nichols. The property is a working farm.
Terry Nichols formerly resided in Marion, Kansas, which is
approximately one hour from Junction City.
11. A relative of James Nichols reports to the FBI that Tim McViegh
is a friend and associate of James Nichols, who has worked and
resided at the farm on North Van Dyke Road in Decker, worked and
resided ast the farm on North Van Dyke Road in Decker, Michigan.
This relative further reports that she had heard that James Nichols
had been involved in constructing bombs in approximately November
1994, and that he possessed large quantities of fuel oil and
12. On April 21, 1995, a former co-worker of Tim McViegh's reported
to the FBI that he had seen the composite drawing of Unsub #1 on the
television and recognized the drawing to be a former co-worker, Tim
McViegh. He further advised that McVeigh was known known to hold
extreme rightwing views, was a military veteran, and was particularly
agitated about the conduct of the federal government in Waco, Texas,
in 1993. In fact, the co-worker further reports that McViegh had
been so agitated about the deaths of the Branch Dividians in Waco,
Texas, on April 19, 1993, that he personnnaly visited the site.
After visiting the site, McViegh expressed extreme anger at the
federal government and advised that the Governemnt should never had
done what it did. He further advised that the last known address he
had for McViegh is 1711 Stockton Hill Road, #206, Kingman, Arizona.
13. On April 21, 1994, investigators learned that a Timothy McViegh
was arrested at 10:30 a.m. on April 19, 1995, in Perry, Oklahoma, for
not having a lisencse tag and for possession of a weapon
approxiamtely 1-1/2 hours after the detonation of the expolosive
device at the Alfred P. Murrah Federal Building in Oklahoma City,
Oklahoma. Perry, Oklahoma, is approximately a 1-1/2 hour drive from
Oklahoma City, Oklahoma. McViegh, who has been held in custody since
his arrest on April 19, 1995, listed his home address as 3616 North
Van Dyke Road, Decker, Michigan. He listed James Nichols of Decker,
Michigan, as a reference. McViegh was stopped driving a yellow 1977
14. The detonation of the explosive in front of the Alfred P. Murrah
Federal Building constitutes a violation of 18 U.S.C. Section
844(f), which makes it a crime to maliciously damage or destroy by
means of an explosive any building or real property, in whole or in
part owned, possessed or used by the United States, or any department
or agency thereof.
Further, your affiant sayeth not.
/s/HENRY C. GIBBONS
Federal Bureau of Investigation
Suscribed and sworn to before me this 21 day of April 1995.
/s/ Ronald J. Howland
UNITED STATES MAGISTRATE JUDGE
Western District of Oklahoma
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