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    AO 91 (Rev. II /II) Criminal Complaint

    UNITED STATES DISTRICT COURTfor the

    Nmihern District ofNew York ORIGINALnited States of Americav.GLENDON SCOTT CRAWFORD andERIC J. FEIGHT

    Defendant(s)

    )))))))

    Case No.13

    CRIMINAL COMPLAINTI, 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 (see below) in the county of Albany in theNorthern District of NY and elsewhere , the defendant(s) violated:

    Code Section18 U.S.C. 2339A

    Offense DescriptionConspiracy to provide material support, or resources, intending that they beused in preparation for, or in carrying out, a violation of Title 18, U.S.C. 2332a (use of a weapon of mass destruction), from on or about Apri12012through June of 2013.

    This criminal complaint is based on these facts:See Attached Affidavit

    l2f Continued on the attached sheet.

    omplainant s signature FBI Special Agent Geoffrey Kent

    Printed name and title

    Date: 06/17/2013 I ~worn to before me and signed in my presence.Judge's signature

    City and state: Albany, New York Han. Christian F. Hummel, U.S. Magistrate JudgePrinted name and title

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    AFFIDAVIT IN SUPPORT OF A CRIMINAL COMPLAINT AND ARREST WARRANTS

    INTRODUCTIONGEOFFREY KENT, being duly sworn, deposes and s ta te s as follows:

    Agent Background:1 .) I am an inves t iga t ive or law enforcement of f i ce r of

    the United Sta tes , within the meaning of Sect ion 2510 (7) ofTi t le 18, United Sta tes Code, and am empowered by law t'o conductinves t iga t ions of and to make ar res t s for offenses enumerated inChapter 119 of Ti t le 18 of the United Sta tes Code, includingSect ion 2516 of tha t Ti t l e .

    2.) I have been a Specia l Agent of the Federal Bureau ofInves t iga t ion (here inaf te r "FBI") fo r over 13 years and amcur ren t ly assigned to the Albany Field Office, where I have beenthe Coordinator fo r Weapons of Mass Destruct ion ("WMD") program,which includes responding to and inves t iga t ing WMD th rea t s , forapproximately s ix years . My experience as an FBI agent i n c l ~ d e sbeing assigned to conduct cr iminal inves t iga t ions in theNorthern Dis t r i c t of New York and elsewhere concerning WMD,domestic ~ e r r o r i s m , des truc t ive devices, and heal th care fraud.Many of these inves t iga t ions have resul ted in the prosecutionand convic t ion of the defendants .

    3 . ) During my employment with the FBI, I have receivedt ra in ing in both invest igat ive procedures and evidence recovery.As a federa l agent, I am author ized to inves t iga teviolat ions of the laws of the United Sta tes and to executesearch warrants and a r re s t warrants issued under the author i ty .of the United Sta tes . In my work as an FBI Specia l Agent,par t icu la r ly in domestic terrorism inves t iga t ions and with theJTTF, I regular ly work with and consul t other Specia l Agents andlaw enforcement off icers who have par t i c ipa ted in s ta te andfedera l inves t iga t ions .

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    Criminal Complaint and Arrest Warrants Sought:4.) I submit th is af f idav i t in support of a cr iminal

    complaint and a r re s t warrant(s) charging GLENDON SCOTT CRAWFORDand ERIC J . FEIGHT with conspir ing to provide mater ia l support ,or resources , intending tha t they be used in preparat ion for,or in carrying out, a vio la t ion of 18 U.S.C. 2332a (use of aweapon of mass destruct ion) , from on or about Apri l 2012through June 2013, in v io la t ion of 18 U.S.C. 2339A.

    5.) The fac ts se t for th in th is a f f idav i t are based on myown inves t iga t ion, together with information I obtained from avar ie ty of sources, including other law enforcement of f ic ia l s ,of f i c i a l FBI records , analys is of subpoena or public records ,surve i l lances , Court authorized T i t l e - I I I in tercepts ofte lephone, SMS, and ora l comm unications, a nd pen r eg i s t e rinfol;:'mation.

    6.) I have not included every fac t regarding th i sinves t iga t ion in th i s af f idav i t . I have only se t for th the fac tswhich I bel ieve are necessary to es tabl ish probable cause tobel ieve t ha t the above crime has been committed by CRAWFORD andFEIGHT.

    SUMMARY OF INVESTIGATION7.) The essence of CRAWFORD's scheme i s the crea t ion of a

    mobile, remotely operated, radiat ion emit t ing device capable ofk i l l ing human t a rge t s s i l en t ly and from a dis tance with l e tha ldoses of radiat ion. A cent ra l fea ture of CRAWFORD's weaponizedrad ia t ion device i s tha t the t a rge t ( s ) , and those around them,would not immediately be aware they had absorbed le tha l doses ofrad ia t ion , and the harmful ef fec t s of tha t rad ia t ion would notbecome apparent u n t i l days af t e r the exposure.

    8.) CRAWFORD, conspir ing with FEIGHT, and ass i s t ed byothers , has supervised and successful ly completed the building,t es t ing , and demonstration of a remote i n i t i a t ion device. He now(on or about June 18, 2013) plans to in tegra te tha t remotei n i t i a t ion device in to a t ruck-borne, indus t r ia l -grade x-raysystem, thus weaponizing tha t system and allowing it to be

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    turned on and off from a dis tance and without detec t ion . Oncecompleted and fu l ly weaponized, CRAWFORD has descr ibed h isin ten t ion to provide the funct ioning radiat ion emit t ing deviceto ind iv iduals he bel ieves wil l use it to in jure or k i l l peopledeemed by CRAWFORD to be undesirable (CRAWFORD s ~ e c i f i c a l l y hasiden t i f i ed Muslims and severa l o ther individua ls /groups asta rge ts ) . CRAWFORD has researched t a rge t s and loca t ions for thef i r s t uses of h is rad ia t ion emit t ing device.

    9.) Beginning in a t l e a s t April of 2012, CRAWFORD act ivelyso l i c i t ed ind iv iduals and groups to finance h is acquis i t ion of asuf f ic ien t ly powerful x-ray system to carry out his scheme.After severa l unsuccessful so l i c i t a t i ons , CRAWFORD soon foundtw o separate groups with the apparent means and ab i l i t y to getfo r him the type of x-ray system he wanted fo r h is scheme. AtCRAWFORD, s request , these two separa te groups each haveobtained, and are prepared to make avai lable to him, an x-raysystem tha t he se lec ted or has approved. CRAWFORD has madec l ea r he intends, as soon as he has access to the x-ray systems,to connect h is remote i n i t i a t ion device in to the cont rol paneleof an x-ray systeme and render it remotely-operable as a l e tha lrad ia t ion emit t ing device. Fortunately, law enforcement wil lcont ro l the t iming of those events, as both groups present lydeal ing with CRAWFORD and h is scheme are composed of UndercoverEmployees ("UCES 11 ) and a Confident ia l Human Source ("CHS 11 ).

    10.) Within approximately s ix weeks of CRAWFORD 1 s at temptsin Apri l of 2012 to s o l i c i t f inancing fo r his radiat ion emit t ingdevice scheme from two Jewish organiza t ions , the inves t iga t ionhad a CHS in place and CRAWFORD had met with tha t CHS,descr ibing h is scheme and his rad ia t ion emi t t ing device conceptto the CHS (a l l meetings and in te rac t ions with the CHS and UCEsiden t i f i ed in th i s a f f idav i t were recorded, many with audio andvideo, except where noted) . Following t ha t meeting, an FBI UCEwas in troduced to CRAWFORD by the CHS. That combination - theCHS and t ha t UCE ( ident i f ied as UCE # 1) - forms one of the twogroups cur ren t ly deal ing with CRAWFORD. That f i r s t group i siden t i f ied here as the " f i r s t branch,, of the inves t iga t ion.

    11.) In August of 2012, CRAWFORD(unsol ic i ted and without any government roleh is home near Albany, NY to North Carolina

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    t rave led by caror d i rec t ion) fromto meet with an

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    individual who i s bel ieved to be a ranking member of the Ku KluxKlan ("KKK") . At the meeting, CRAWFORD ins t ruc ted on radiat ionphysics , iden t i f ied h is planned radiat ion emit t ing device,presented h is scheme to th i s of f i c i a l of the KKK, and so l ic i tedfunds from the KKK (through th is individual) fo r h is scheme(here inaf te r iden t i f ied as the "CW"). The CW to ld the FBI abouth is meeting with CRAWFORD. Several weeks l a t e r (early October2012), CRAWFORD drove his car from h is home outside Albany, NYto Greensboro, North Carol ina to meet with the CW and twoindividuals the CW introduced to CRAWFORD as Southernbusinessmen of means who were associated with the KKK. Twoind iv iduals assumed those roles , but were FBI UCEs, referencedin th i s a f f idav i t as UCE #2 and UCE #3 ( this second groupdeal ing with CRAWFORD, composed of UCE #2, UCE #3, and the CW,i s here inaf t e r re fe r red to in th i s a f f idav i t as the "secondbranch") . CRAWFORD described to UCEs #2 and #3 h is radiat ionemit t ing device scheme, the science and concepts underlying tha tdevice, h is remote i n i t i a t ion device, mobilizing the radiat iondevice, and discussed opera t ional securi ty concerns. CRAWFORDagain so l ic i ted money to f inance h is scheme (primari ly to fundthe purchase or acquis i t ion of an indus t r ia l s t rength x-raysystem) . Both the f i r s t and second branches have ass i s tedCRAWFORD with f inancing and obtaining of par t s .

    12.) From tha t time up through June 15, 2013 CRAWFORD hass tead i ly worked to design, acquire the par t s for, bu i ld , andt e s t a remote i n i t i a t ion device to remotely turn on and o ff anindus t r ia l x-