8/95 Grand Jury Indictment Of McVeigh & Nichols


PREMIUM LEGAL RESOURCES LEGAL FORMS ASK A LAWYER

IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF OKLAHOMA

No CR 95-110

UNITED STATES OF AMERICA,
Plaintiff,
--VS--
TIMOTHY JAMES McVEIGH and
TERRY LYNN NICHOLS,
Defendants.

Violations

18 USC Sec. 2332a;
18 USC Sec. 844(f);
18 USC Sec. 1114;
18 USC Sec. 1111;
18 USC Sec. 2(a)&(b)

I N D I C T M E N T

COUNT ONE (Conspiracy to Use a Weapon of Mass Destruction)

The Grand Jury charges:

1. Beginning on or about September 13, 1994 and continuing thereafter until on or about April 19, 1995, at Oklahoma City, Oklahoma, in the Western District of Oklahoma and elsewhere,

TIMOTHY JAMES McVEIGH
and
TERRY LYNN NICHOLS,

the defendants herein, did knowingly, intentionally, willfully and maliciously conspire, combine and agree together and with others unknown to the Grand Jury to use a weapon of mass destruction, namely an explosive bomb placed in a truck (a "truck bomb"), against persons within the United States and against property that was owned and used by the United States and by a department and agency of the United States, namely, the Alfred P. Murrah Federal Building at 200 N.W. 5th Street, Oklahoma City, Oklahoma, resulting in death, grievous bodily injury and destruction of the building.

2. It was the object of the conspiracy to kill and injure innocent persons and to damage property of the United States.

THE MANNER AND MEANS USED BY THE CONSPIRATORS TO FURTHER THE OBJECTS OF THE CONSPIRACY

Among the manner and means used by the defendants to further the objects of the conspiracy were the following:

3. McVEIGH and NICHOLS planned an act of violence against persons and property of the United States.

4. McVEIGH and NICHOLS selected the Alfred P. Murrah Federal Building and its occupants as the targets of their act of violence and McVEIGH attempted to recruit others to assist in the act of violence.

5. McVEIGH and NICHOLS obtained and attempted to obtain the components of a truck bomb, including a truck, ammonium nitrate, racing and diesel fuel, detonation cord and other explosive materials.

6. McVEIGH and NICHOLS used storage units to conceal the truck bomb components and stolen property.

7. McVEIGH and NICHOLS used stolen property and its proceeds to help finance their act of violence.

8. McVEIGH and NICHOLS made calls with a telephone calling card that they had acquired in a false name as a means of concealing their true identities and as a means of preventing calls from being traced to them.

9. McVEIGH and NICHOLS used different false names in business transactions as a means of concealing their true identities, their whereabouts and the true intent of their activities.

10. McVEIGH and NICHOLS constructed an explosive truck bomb, and McVEIGH placed it outside the Alfred P. Murrah Federal Building in downtown Oklahoma City, where he detonated the bomb.

OVERT ACTS

To further the conspiracy and to achieve its objectives, McVEIGH and NICHOLS committed and caused to be committed the following acts, among others, in the Western District of Oklahoma and elsewhere:

11. On or about September 22, 1994, McVEIGH rented a storage unit in the name "Shawn Rivers" in Herington, Kansas.

12. On or about September 30, 1994, McVEIGH and NICHOLS purchased forty fifty-pound bags of ammonium nitrate in McPherson, Kansas under the name "Mike Havens."

13. In or about late September 1'394, McVEIGH made telephone calls in an attempt to obtain detonation cord and racing fuel.

14. On or about October 1, 1994, McVEIGH and NICHOLS stole explosives from a storage locker (commonly referred to as a magazine) in Marion, Kansas.

15. On or about October 3, 1994, McVEIGH and NICHOLS transported the stolen explosives to Kingman, Arizona.

16. On or about October 4, 1994, McVEIGH rented a storage unit in Kingman, Arizona for the stolen explosives.

17. On or about October 16, 1994, NICHOLS registered at a motel in Salina, Kansas under the name "Terry Havens."

18. On or about October 17, 1994, NICHOLS rented storage unit No. 40 in Council Grove, Kansas in the name "Joe Kyle."

19. On or about October 18, 1994, McVEIGH and NICHOLS purchased forty fifty-pound bags of ammonium nitrate in McPherson, Kansas under the name "Mike Havens.

20. In or about October 1994, McVEIGH and NICHOLS planned a robbery of a firearms dealer in Arkansas as a means to obtain moneys to help finance their planned act of violence.

21. On or about November 5, 1994, McVEIGH and NICHOLS caused firearms, ammunition, coins, United States currency, precious metals and other property to be stolen from a firearms dealer in Arkansas.

22. On or about November 7, 1994, NICHOLS rented storage unit No. 37 in Council Grove, Kansas in the name "Ted Parker" and used the unit to conceal property stolen in the Arkansas robbery.

23. On or about November 16, 1994, NICHOLS rented a storage unit in Las Vegas, Nevada and stored, among other items, a ski mask.

24. On or about November 21, 1994 and prior to departing for the Philippines, NICHOLS prepared a letter to McVEIGH, to be delivered only in the event of NICHOLS' death, in which he advised McVEIGH, among other matters, that storage unit No. 37 in Council Grove, Kansas had been rented in the name "Parker" and instructed McVEIGH to clear out the contents or extend the lease on No. 37 by February 1, 1995. NICHOLS further instructed McVEIGH to "liquidate" storage unit No. 40.

25. On or about December 16, 1994, while en route to Kansas to take possession of firearms stolen in the Arkansas robbery, McVEIGH drove with Michael Fortier to the Alfred P. Murrah Federal Building and identified the building as the target.

26. In early 1995, following NICHOLS' return from the Philippines, firearms stolen in the Arkansas robbery were sold and McVEIGH, NICHOLS and Michael Fortier obtained currency from those sales.

27. On or about February 9, 1995, NICHOLS, using currency, paid for the continued use of storage unit No. 40 at Council Grove, Kansas in the name of "Joe Kyle."

28. In or about March, 1995, McVEIGH obtained a driver's license in the name of "Robert Kling" bearing a date of birth of April 19, 1972.

29. On or about April 14, 1995, McVEIGH, using currency, purchased a 1977 Mercury Marquis in Junction City, Kansas.

30. On or about April 14, 1995, McVEIGH called the NICHOLS residence in Herington, Kansas from Junction City, Kansas.

31. On or about April 14, 1995, McVEIGH called a business in Junction City and, using the name "Bob Kling", inquired about renting a truck capable of carrying 5,000 pounds of cargo.

32. On or about April 14, 1995, McVEIGH, using currency, rented a room at a motel in Junction City, Kansas.

33. On or about April 15, 1995, McVEIGH, using currency, placed a deposit for a rental truck in the name "Robert Kling."

34. On or about April 17, 1995, McVEIGH took possession of a 20- foot rental truck in Junction City, Kansas.

35. On or about April 18, 1995, at Geary Lake State Park in Kansas, McVEIGH and NICHOLS constructed an explosive truck bomb with barrels filled with a mixture of ammonium nitrate, fuel and other explosives placed in the cargo compartment of the rental truck.

36. On April 19, 1995, McVEIGH parked the truck bomb directly outside the Alfred P. Murrah Federal Building, located within the Western District of Oklahoma, during regular business and day-care hours.

37. On April 19, 1995, McVEIGH caused the truck bomb to explode.

THE RESULTS OF THE CONSPIRACY

38. As intended by McVEIGH and NICHOLS, the truck bomb explosion resulted in death and personal injury and the destruction of the Alfred P. Murrah Federal Building, located within the Western District of Oklahoma. The following persons were present at the Alfred P. Murrah Federal Building on April 19, 1995, and were killed as a result of the explosion:

Charles E. Hurlburt 73
John Karl Vaness III 67
Anna Jean Hurlburt 67
Donald Lee Fritzler 64
Eula Leigh Mitchell 64
Donald Earl Burns, Sr. 63
Norma Jean Johnson 62
Calvin C. Battle 62
Laura Jane Garrison 61
Olen Burl Bloomer 61
Luther Hartman Treanor 61
Rheta Ione Bender Long 60
Juretta Colleen Guiles 59
Robert Glen Westberry 57
Carolyn Ann Kreymborg 57
Leora Lee Sells 57
Mary Anne Fritzler 57
Virginia Mae Thompson 56
Peola Y. Battle 56
Peter Robert Avillanoza 56
Richard Leroy Cummins 55
Ronald Vernon Harding 55
LaRue Ann Treanor 55
Ethel Louise Griffin 55
Antonio C. Reyes 55
Thompson Eugene Hodges, Jr. 54
Alvin Junior Justes 54
Margaret Goodson 54
Oleta Christine Biddy 54
David Jack Walker 54
James Anthony McCarthy 53
Carol L. Bowers 53
Linda Coleen Housley 53
John Albert Youngblood 52
Robert Nolan Walker, Jr. 52
Thomas Lynn Hawthorne, Sr. 52
Dolores Marie Stratton 51
Jules Alfonso Valdez 51
John Thomas Stewart 51
Mickey Bryant Maroney 50
John Clayton Moss III 50
Carole Sue Khalil 50
Emilio Tapla-Rangel 50
James Everette Boles 50
Donald R. Leonard 50
Castine Deveroux 49
Clarence Eugene Wilson 49
Wanda Lee Watkins 49
Michael Lee Loudenslager 48
Carrol June Fields 48
Frances Ann Williams 48
Claudine Ritter 48
Ted Leon Allen 48
Linda Gail Griffin McKinney 47
Patricia "Trish" Ann Nix 47
Betsy Janice McGonnell 47
David Neil Burkett 47
Michael George Thompson 47
Catherine Mary Leinen 47
Sharon Louise Wood Chesnut 47
Ricky Lee Tomlin 46
Larry James Jones 46
Richard Arthur Allen 46
Harley Richard Cottingham 46
Lanny Lee David Scroggins 46
George Michael Howard 45
Jerry Lee Parker 45
Judy Joann Fisher 45
Diane Hollingsworth Althouse 45
Michael D. Weaver 45
Robert Lee Luster, Jr. 45
Peter Leslie DeMaster 44
Katherine Ann Finley 44
Doris Adele Higginbottom 44
Stephen Douglas Curry 44
Michael Joe Carrillo 44
Cheryl E. Bradley Hammon 44
Aurelia Donna Luster 43
Linda L. Florence 43
Claudette Meek 43
William Stephen Williams 42
Johnny Allen Wade 42
Larry Laverne Turner 42
Brenda Faye Daniels 42
Margaret Louise Clark Spencer 42
Paul Gregory Broxterman 42
Paul Douglas Ice 42
Woodrow Clifford "Woody" Brady 41
Claude Arthur Medearis 41
Teresa Lea Lauderdale 41
Terry Smith Rees 41
Alan Gerald Whicher 40
Lola Renee Bolden 40
Kathy Lynn Seidl 39
Kimberly Kay Clark 39
Mary Leasure Rentie 39
Diana Lynn Day 38
Robin Ann Huff 37
Peggy Louise Jenkins Holland 37
Victoria Jeanette Texter 37
Susan Jane Ferrell 37
Kenneth Glenn McCullough 36
Victoria Lee Sohn 36
Pamela Denise Argo 36
Rona Linn Chafey 36
Jo Ann Whittenberg 35
Gilbert Xavier Martinez 35
Wanda Lee Howell 34
Saundra Gail "Sandy" Avery 34
James Kenneth Martin 34
Lucio Aleman, Jr. 33
Valerie Jo Koelsch 33
Teresa Antionette Alexander 33
Kim Robin Cousins 33
Michelle Ann Reeder 33
Andrea Y. Blanton 33
Karen Gist Carr 32
Christi Yolanda Jenkins 32
Jamie Lee Genzer 32
Ronota Ann Woodbridge 31
Benjamin Laranzo Davis 29
Kimberly Ruth Burgess 29
Tresia Jo Mathes-Worton 28
Mark Allen Bolte 28
Randolph Guzman 28
Sheila R. Gigger Driver 28
Karan Denise Shepherd 27
Sonja Lynn Sanders 27
Derwin Wade Miller 27
Jill Diane Randolph 27
Carrie Ann Lenz 26
Cynthia Lynn Campbell Brown 26
Cassandra K. Booker 25
Shelly Deann (Turner) Bland 25
Scott Dwain Williams 24
Dana LeAnne Cooper 24
Julie Marie Welch 23
Frankie Ann Merrell 23
Christine Nicole Rosas 22
Lakesha Levy 21
Cartney J. McRaven 19
Aaron M. Coverdale 5
Ashley Megan Eckles 4
Zackary Taylor Chavez 3
Kayla Marie Haddock 3
Peachlyn Bradley 3
Chase Dalton Smith 3
Anthony Christopher Cooper II 2
Colton Smith 2
Elijah Coverdale 2
Dominique R. London 2
Baylee Almon 1
Jaci Rae Coyne 1
Blake Ryan Kennedy 1
Tevin D'Aundrae Garrett 1
Danielle Nicole Bell 1
Tylor S. Eaves 8 months
Antonio Ansara Cooper, Jr. 6 months
Kevin Lee Gottshall II 6 months
Gabreon Bruce 4 months

All in violation of Title 18, United States Code, Section 2332a.

COUNT TWO (Use of A Weapon of Mass Destruction)

The Grand Jury further charges:

On or about April 19, 1995, at Oklahoma City, Oklahoma, in the Western District of Oklahoma,

TIMOTHY JAMES McVEIGH
and
TERRY LYNN NICHOLS.

the defendants herein, did knowingly, intentionally, willfully and maliciously use, aid and abet the use of, and cause to be used, a weapon of mass destruction, namely an explosive bomb placed in a truck, against persons within the United States, resulting in death to the persons named in Count One, Paragraph 38 (which is expressly incorporated by reference herein) and personal injury to other persons.

All in violation of Title 18, United States Code, Sections 2332a and 2(a)&(b).

COUNT THREE (Destruction by Explosive)

The Grand Jury further charges:

On or about April 19, 1995, at Oklahoma City, Oklahoma, in the Western District of Oklahoma,

TIMOTHY JAMES McVEIGH
and
TERRY LYNN NICHOLS,

the defendants herein, did knowingly, intentionally, willfully and maliciously damage and destroy, aid and abet the damage and destruction of, and cause to be damaged and destroyed, by means of an explosive, namely, an explosive bomb placed in a truck, a building and other personal and real property in whole and in part owned, possessed and used by the United States and departments and agencies of the United States, that is. the Alfred P. Murrah Federal Building, 200 N.W. 5th Street, Oklahoma City, Oklahoma, causing, as a direct and proximate result, the death of the persons named in Count One, Paragraph 38 (which is expressly incorporated by reference herein) and personal injury to other persons. All in violation of Title 18, United States Code, Sections 844(f) and 2(a)&(b).

COUNTS FOUR THROUGH ELEVEN (First Degree Murder)

The Grand Jury further charges:

On or about April 19, 1995, at Oklahoma City, Oklahoma, in the Western District of Oklahoma,

TIMOTHY JAMES McVEIGH
and
TERRY LYNN NICHOLS,

the defendants herein, did unlawfully, willfully, deliberately, maliciously, and with premeditation and malice aforethought, kill, and aid, abet and cause the killing of, the following persons while they were engaged in and on account of the performance of official duties as law enforcement officers:

Name/Position:

COUNT: FOUR
Name/Position: Mickey Bryant Maroney
Special Agent United States Secret Service

COUNT: FIVE
Name/Position: Donald R. Leonard
Special Agent United States Secret Service

COUNT: SIX
Alan Gerald Whicher
Assistant Special Agent in Charge
United States Secret Service

COUNT: SEVEN
Cynthia Lynn Campbell-Brownv Special Agent United States Secret Service

COUNT: EIGHT
Kenneth Glenn McCullough
Special Agent United States Drug
Enforcement Administration

COUNT: NINE
Paul Douglas Ice
Special Agent United States Customs Service

COUNT: TEN Claude Arthur Medearis
Special Agent United States Customs Service

COUNT: ELEVEN
Paul G. Broxterman
Special Agent Department of Housing and
Urban Development Office of Inspector General

All in violation of Title 18, United States Code, Sections 1114, 1111 and 2(a)&(b); and Title 28, Code of Federal Regulations, Section 64.2(h).

PATRICK M. RYAN
United States Attorney

A TRUE BILL:

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