The criminal complaint against Timothy McVeigh, a suspect being held in connection with the April 19th bombing in Oklahoma City.
United States District Court
WESTERN DISTRICT OF OKLAHOMA
UNITED STATES OF AMERICA
V.
TIMOTHY JAMES McVEIGH CRIMINAL COMPLAINT
CASE NUMBER: M-95-98-H
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 facts:
See attached Affidavit of Special Agent Henry C. Gibbons,
Federal Bureau of Investigation, which is incorporated and made a
part hereof by reference.
Continued on the attached sheet and made a
part hereof: XX Yes No
/s/ Henry C. Gibbons
Signature of Complainant
Henry C. Gibbons
Special Agent
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
Name and Title of Judicial Officer Signature of Judicial Officer
STATE OF OKLAHOMA:
COUNTY OF OKLAHOMA
AFFIDAVIT
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, 1995;
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, Florida.
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 information:
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, Omaha, Nebraska.
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 Administration.
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 1970's.
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 fertilizer.
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 Mercury Marquis.
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
Special Agent
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
