Copy of today's Grand Jury Indictment

If someone did successfully download the indictment, could they please upload it to Portland IMC so that we can access it? There seems to be a problem with the link or the server it points to.

A lot of people must have been downloading the indictment because the server seems to be blocking access by clicking on it. However, I was able to FTP it. Here it is.

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF OREGON
UNITED STATES OF AMERICA C R N O - O ( O - - ~ O ~ ( I - @
v. SEALED

1
JOSEPH DIBEE, aka "Seattle" ) INDICTMENT
CHELSEA DAWN GERLACH, aka 1
"Country Girl," ) [I8 U.S.C. $5 371,
SARAH KENDALL HARVEY, aka "Kendall," ) 844(f), 844(i), 84qn),
DANIEL GERARD McGOWAN, aka "Sorrell" ) 924(c)(l)(A)(i) & (B)(ii) &
and "Jamie," ) (C)(ii),1366(a),and2]
STANISLAS GREGORY MEYERHOFF, )
akaUCountry Boy" and "Jack," )
JOSEPHINE SUNSHINE OVERAKER, aka )
"Maria," )
JONATHAN MARK CHRISTOPHER PAUL, )
aka "J.P.," 1
REBECCA RUBIN, aka "Kara,"
SUZANNE SAVOIE, aka "India,"
DARREN TODD THURSTON, and
KEVIN TUBBS, aka "Bob" and "Dog" 1
)
Defendants. )
THE GRAND JURY CHARGES:
COUNT 1
CONSPIRACY TO COMMIT ARSON
I. OBJECT OF THE CONSPIRACY
Beginning in October 1996 and continuing through December 2005, in the District of
Oregon and elsewhere, defendants JOSEPHINE SUNSHINE OVERAKER, KEVIN TUBBS,
STANISLAS GREGORY MEYERHOFF, DANIEL GERARD McGOWAN, JOSEPH DIBEE,
REBECCA RUBIN, CHELSEA DAWN GERLACH, SARAH KENDALL HARVEY,
SUZANNE SAVOIE, JONATHAN MARK CHRISTOPHER PAUL and DARREN TODD
THURSTON, and unindicted co-conspirator WILLIAM C. RODGERS, and other persons known
and unknown to the Grand Jury, willfully and knowingly conspired and agreed to commit the
following offenses against the United States:
to maliciously damage or destroy, or attempt to damage or destroy, by means of
fire or an explosive, any building, vehicle or other personal or real property in
whole or in part owned or possessed by, or leased to, the United States or any
department or agency thereof, in violation of Title 18, United States Code, Section
844(f)(l); and
to maliciously damage or destroy, or attempt to damage or destroy, by means of
fire or an explosive, any building, vehicle or other real or personal property used
in interstate commerce or in any activity affecting interstate commerce, in
violation of Title 18, United States Code, Section 844(i).
11. MANNER AND MEANS OF THE CONSPIRACY
The foregoing objects of the conspiracy were to be accomplished in the following manner
and means by the above-listed defendants and others at various times during the course of the
conspiracy:
1. Certain of the defendants and others joined together in a group they called the
"Family." This "Family" was what is commonly known as a "cell" of groups and movements
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publicly named and described by certain of the defendants and others as the Earth Liberation
Front (ELF), the Animal Liberation Front (ALF), and other names.
2. The general purposes of the conspiracy were to influence and affect the conduct
of government, commerce, private business and others in the civilian population by means of
force, violence, sabotage, mass destruction, intimidation and coercion, and by similar means to
retaliate against the conduct of government, commerce and private business. To achieve these
purposes, the conspirators committed and attempted to commit acts dangerous to human life and
property that constituted violations of the criminal laws of the United States and of individual
states.
3. Certain of the defendants and others targeted for arson buildings, vehicles and
other real and personal property owned, possessed, and leased by the United States and its
departments and agencies.
4. Certain of the defendants and others targeted for arson buildings, vehicles and
other real and personal property used in interstate commerce and in activities affecting interstate
commerce.
5. Certain of the defendants and others conducted and participated in meetings to
plan arsons of the targeted sites.
6. Certain of the defendants and others conducted research and surveillance of sites
targeted for arson.
7. In discussing their actions among themselves, certain of the defendants and others
used code words, code names, and nicknames.
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8. Certain of the defendants and others designed and constructed destructive devices
which functioned as incendiary bombs to ignite fires and destroy the targets.
9. Certain of the defendants and others provided transportation to the sites targeted
for arson.
10. Certain of the defendants and others dressed in dark clothing, wore masks and
gloves and otherwise disguised their appearance.
11. Certain of the defendants and others acted as "look-outs" to ensure secrecy as the
crimes were carried out.
12. Certain of the defendants and others placed destructive devices and accelerants at
sites targeted for arson and ignited or attempted to ignite the devices and accelerants.
13. Certain of the defendants and others, by means of fire and explosives, maliciously
damaged and destroyed, and attempted to damage and destroy, buildings, vehicles and other real
and personal property owned and possessed by the United States and its departments and
agencies.
14. Certain of the defendants and others, by means of fire and explosives, maliciously
damaged and destroyed, and attempted to damage and destroy, buildings, vehicles and other real
and personal property used in interstate commerce and in activities affecting interstate
commerce.
15. In some of the arsons and attempted arsons, certain of the defendants and others
painted messages on the walls of the targets, including "Earth Liberation Front," "ELF" and
related names and statements concerning the purposes of the crimes.
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16. After the arsons and attempted arsons, certain of the defendants and others
provided transportation away from the scenes of the crimes.
17. After the arsons and attempted arsons, certain of the defendants and others
destroyed, buried, hid and otherwise disposed of physical evidence used in the commission of the
crimes.
18. After the arsons, certain of the defendants and others publicized and promoted the
results of the fires by means of written press releases and communiques attributing the arsons to
the Earth Liberation Front (ELF), the Animal Liberation Front (ALF) and related groups, and
stating the purposes of the arsons.
19. Before, during and after the arsons and attempted arsons, certain of the defendants
and others agreed and took an oath among themselves never to reveal to law enforcement
authorities or to anyone else outside "the Family" the identity of the conspirators and participants
in the arsons and attempted arsons.
20. Before, during and after the arsons and attempted arsons, certain of the defendants
and others agreed among themselves to conceal or destroy any evidence connecting them to the
arsons and attempted arsons.
21. Before, during and after the arsons and attempted arsons, certain of the defendants
and others possessed andlor used false identification documents in order to conceal their true
identities.
22. After the arsons and attempted arsons, certain of the defendants and others fled
and secreted themselves in foreign countries in order to avoid detection and arrest by law
enforcement authorities in the United States.
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111. OVERT ACTS
In order to cany out the objects of the conspiracy, defendants and other persons
committed various overt acts within the District of Oregon and elsewhere, including but not
limited to the following:
1. On or about October 28, 1996, in Marion County, Oregon, defendant JOSEPHINE
SUNSHINE OVERAKER and other persons known to the Grand Jury, unlawfully and willfully
caused and aided, abetted, counseled, commanded, induced, and procured the attempt to damage
or destroy, by means of fire and an explosive, a building and other real and personal property
owned and possessed by the United States and the United States Forest Service of the
Department of Agriculture, located at the Detroit Ranger Station on the Willamette National
Forest.
la. At a time prior to October 28, 1996, JOSEPHINE SUNSHINE OVERAKER and
another person known to the Grand Jury prepared and tested a time-delayed incendiary device.
lb. On or about October 28, 1996, JOSEPHINE SUNSHINE OVERAKER and other
persons known to the Grand Jury drove to the U.S. Forest Service Detroit Ranger Station in
Marion County, Oregon, with an incendiary device which was placed on the roof of a U.S.
Forest Service building. That incendiary device failed to function.
lc. On or about October 28,1996, JOSEPHINE SUNSHINE OVERAKER and
another person known to the Grand Jury spray-painted graffiti on the sides of a U.S. Forest
Service building and vehicles which included the words "Earth Liberation Front."
2. On or about October 28, 1996 in Marion County, Oregon, defendant JOSEPHINE
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SUNSHINE OVERAKER and other persons known to the Grand Jury, unlawfully and willfully
caused and aided, abetted, counseled, commanded, induced, and procured the malicious
damaging and destroying, by means of a fire and an explosive, a vehicle and other real and
personal property owned and possessed by the United States and the United States Forest Service
of the Department of Agriculture, located at the Detroit Ranger Station on the Willamette
National Forest.
2a. On or about October 28,1996, JOSEPHINE SUNSHINE OVERAKER and
another person known to the Grand Jury intended and caused fire damage to a U.S. Forest
Service vehicle.
3. On or about October 30, 1996, in Lane County, Oregon, defendants JOSEPHINE
SUNSHINE OVERAKER and KEVIN TUBBS, and another person known to the Grand Jury,
unlawfully and willfully caused and aided, abetted, counseled, commanded, induced, and
procured the malicious damaging and destroying, by means of fire and an explosive, of a building
and other real and personal property owned and possessed by the United States and the United
States Forest Service of the Department of Agriculture, located at the Oakridge Ranger Station
on the Willamette National Forest.
3a. On or about October 30, 1996, in Lane County, Oregon, defendants JOSEPHINE
SUNSHINE OVERAKER and KEVIN TUBBS, and another person known to the Grand Jury,
drove to the U.S. Forest Service Oakridge Ranger Station, and set fire to the Ranger Station.
3b. On or about October 30, 1996, in Lane County, Oregon, defendants JOSEPHINE
SUNSHINE OVERAKER and KEVIN TUBBS, and another person known to the Grand Jury,
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while leaving the parking lot of the U.S. Forest Service Oakndge Ranger Station, threw nails
onto the parking lot in order to slow down responding emergency vehicles.
3c. On or about October 30, 1996, in Lane County, Oregon, defendants JOSEPHINE
SUNSHINE OVERAKER and KEVIN TUBBS, and another person known to the Grand Jury,
while leaving the U.S. Forest Service Oakridge Ranger Station and driving westbound on
Highway 58 towards Eugene, Oregon, discarded their gloves in a reservoir near the Lowell
Bridge.
4. On or about July 21, 1997, at Redmond, Deschutes County, Oregon, defendants
KEVIN TUBBS, JOSEPH DIBEE and JONATHAN MARK CHRISTOPHER PAUL, and other
persons known to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,
commanded, induced, and procured the malicious damaging and destroying, by means of fire and
an explosive, of a building and other real and personal property used in interstate commerce and
in activities affecting interstate commerce, at Cavel West, Inc., 1607 SE Railroad, Redmond,
Oregon.
4a. Approximately one week prior to the July 21, 1997 arson at Cavel West, Inc.,
Defendants KEVIN TUBBS and JONATHAN MARK CHRISTOPHER PAUL and others
known and unknown to the Grand Jury went on a reconnaissance in order to locate a staging area
where the participants could complete final preparations prior to committing the arson.
4b. Prior to the July 21, 1997 arson at Cavel West Inc., defendant JONATHAN
MARK CHRISTOPHER PAUL and another person known to the Grand Jury prepared a mixture
of soap and petroleum products which was the fuel used in the time-delayed incendiary devises.
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4c. On or about July 21, 1997, defendants KEVIN TUBBS, JOSEPH DIBEE and
JONATHAN MARK CHRISTOPHER PAUL, and other persons known to the Grand Jury, drove
to the previously chosen staging area near Cavel West, Inc., and upon arrival dressed in dark
clothing, masks, and gloves, and dug a hole at the staging area in which to bury their dark
clothing upon completion of the arson.
4d. On or about July 21, 1997, defendants KEVIN TUBBS, JOSEPH DIBEE and
JONATHAN MARK CHRISTOPHER PAUL, and other persons known to the Grand Jury,
completed a two-way radio check with one another and confirmed their scanner and radios
functioned properly.
4e. On or about July 21, 1997, defendants KEVIN TUBBS, JOSEPH DIBEE and
JONATHAN MARK CHRISTOPHER PAUL, and other persons known to the Grand Jury, went
to the location of Cavel West, Inc., to place time-delayed incendiary devices on and about that
location.
4f. On or about July 21, 1997, defendant JOSEPH DIl3EE drilled holes through the
wall of the Cavel West, Inc., facility so as to allow fuel to be poured directly into the building.
4g. On or about July 21, 1997, defendants KEVIN TUBBS, JOSEPH DIBEE and
JONATHAN MARK CHRISTOPHER PAUL, and other persons known to the Grand Jury, upon
placing the time-delayed incendiary devices at Cavel West, Inc., traveled back to the staging area,
removed their dark clothes and shoes, placed them in the hole, poured acid on the clothing in the
hole and then buried the items.
4h. On or about July 26, 1997, certain defendants in the Cavel West arson issued a
written communique attributing the fire to the Animal Liberation Front (ALF) and the Equine
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and Zebra Liberation Front. The communique was publicized by Craig Rosebraugh of the
Liberation Collective in Portland, Oregon.
4i. Approximately three years after July 2 1, 1997, defendant JOSEPH DIBEE
contacted defendant KEVIN TUBBS and told KEVIN TUBBS to return to the staging area and
retrieve the buried clothes.
5. On or about November 30, 1997, in Hamey County, Oregon, defendants
JOSEPHINE SUNSHINE OVERAKER, KEVIN TUBBS, and REBECCA RUBIN, unindicted
co-conspirator WILLIAM C. RODGERS, and another person known to the Grand Jury,
unlawfully and willfully caused and aided, abetted, counseled, commanded, induced, and
procured the malicious damaging and destroying, by means of fire and an explosive, of buildings
and other real and personal property owned and possessed by the United States and the Bureau of
Land Management of the Department of the Interior, located at the Wild Horse and Burro
Facility, Bums, Harney County, Oregon.
5a. Approximately three months prior to November 30, 1997, defendants
JOSEPHINE SUNSHINE OVERAKER and KEVIN TUBBS, unindicted co-conspirator
WILLIAM C. RODGERS, and another person known to the Grand Jury, did a reconnaissance at
and near the Wild Horse and Burro Facility, to prepare themselves for the arson and horse
release.
5b. Sometime prior to November 30,1997, Defendant JOSEPHINE SUNSHINE
OVERAKER and another person known to the Grand Jury, obtained five-gallon, white plastic
buckets and the fuel to be used in making time-delayed incendiary devices.
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5c. Sometime prior to November 30,1997, persons known and unknown to the Grand
Jury, prepared the five-gallon plastic buckets by wiping the buckets to ensure all fingerprints
were removed, and painted them with black spray paint.
5d. Sometime prior to November 30, 1997, defendants JOSEPHINE SUNSHINE
OVERAKER, KEVIN TUBBS and REBECCA RUBIN, unindicted co-conspirator WILLIAM C.
RODGERS, and another person known to the Grand Jury, obtained additional components and
assembled time-delayed incendiary devices, which were composed of kitchen timers, matches,
sponges, model rocket igniters, one-gallon jugs filled with fuel and five-gallon buckets which
contained fuel.
5e. On or about November 30, 1997, defendants JOSEPHINE SUNSHINE
OVERAKER, KEVIN TUBBS and REBECCA RUBIN, unindicted co-conspirator WILLIAM C.
RODGERS, and another person known to the Grand Jury, arrived at the Wild Horse and Burro
Facility, cut the lock on the front gate, released horses and burros, placed time-delayed incendiary
devices in and around the facility and left the area.
5f. On or about December 5, 1997, certain defendants in the Wild Horse and Bums
Facility arson issued a communique attributing the fire and horse release to the Earth Liberation
Front (ELF) and the Animal Liberation Front (ALF). The communique was publicized by Craig
Rosebraugh of the Liberation Collective in Portland, Oregon.
6. On or about June 21, 1998, at Olympia, Washington, in the Western District of
Washington, defendants JOSEPHINE SUNSHINE OVERAKER, KEVIN TUBBS and JOSEPH
DIBEE, unindicted co-conspirator WILLIAM C. RODGERS, and another person known to the
Grand Jury, willfully caused and aided, abetted, counseled, commanded, induced, and procured
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the malicious damaging and destroying, by means of fire and an explosive, of a building and
other real and personal property leased and possessed by the United States and the Animal, Plant
and Health Inspection Service (APHIS) of the Department of Agriculture, located at the National
Wildlife Research Facility, 9701 Blomberg Street SW, Olympia, Washington.
6a. Approximately two weeks before June 2 1, 1998, defendants KEVIN TUBBS and
JOSEPH DIBEE, and other persons known and unknown to the Grand Jury, met in Olympia,
Washington, to discuss plans for the APHIS arson, and agreed at that time there would be a
second and simultaneous arson committed when the APHIS arson was to occur.
6b. At a time prior to June 2 1, 1998, defendant JOSEPHINE SUNSHINE
OVERAKER and other persons known to the Grand Jury prepared five-gallon buckets by
wiping the buckets to remove any fingerprints, and obtained fuel for the APHIS arson.
6c. At a time prior to June 21, 1998, defendant KEVIN TUBBS utilized false
identification to acquire a van which was used in the APHIS arson.
6d. On or about June 2 1, 1998, defendant JOSEPHINE SUNSHINE OVERAKER,
while attempting to steal items in preparation for the APHIS arson, was arrested by authorities for
shoplifting.
6e. On or about June 21, 1998, defendant KEVIN TUBBS and another person known
to the Grand Jury transferred five-gallon buckets of fuel to be used in the APHIS arson from a
van purchased by KEVIN TUBBS to a vehicle owned by unindicted co-conspirator WILLIAM C.
RODGERS.
6f. On or about June 21, 1998, defendant KEVIN TUBBS, unindicted co-conspirator
WILLIAM C. RODGERS, and another person known to the Grand Jury, drove to the APHIS
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facility and placed five-gallon buckets filled with fuel at locations at and around the facility, and
ignited the fuel-filled buckets by hand.
6g. On or about June 22, 1998, certain defendants in the APHIS arson issued a
communique attributing the fire to the Earth Liberation Front (ELF) and the Animal Liberation
Front (ALF). The communique was publicized by Katie Fedor of the North American ALF Press
Office.
6h. At a time after June 22, 1998, defendant KEVIN TUBBS assisted in the
disposal of the van used in the APHIS arson.
7. In about September 1998, at Rock Springs, Wyoming, in the District of Wyoming,
defendants KEVIN TUBBS and REBECCA RUBIN, and unindicted co-conspirator WILLIAM
C. RODGERS, and other persons known and unknown to the Grand Jury, unlawfully and
willfully caused and aided, abetted, counseled, commanded, induced, and procured the attempt to
damage or destroy, by means of fire and an explosive, a building and other real and personal
property owned and possessed by the United States and the Bureau of Land Management of the
Department of the Interior, located at the Wild Horse Holding Facility, Rock Springs, Wyoming.
7a. In or about September 1998, defendants KEVIN TUBBS and REBECCA RUBIN,
unindicted co-conspirator WILLIAM C. RODGERS, and other persons known and unknown to
the Grand Jury, arrived at the staging area near Rock Springs, Wyoming, assigned roles, prepared
time-delayed incendiary devices, and made preparations for the arson, when a law enforcement
officer made inquiry as to their presence at that location.
7b. In or about September, 1998, defendants KEVIN TUBBS and REBECCA
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RUBIN, unindicted co-conspirator WILLIAM C. RODGERS, and other persons known and
unknown to the Grand Jury, buried the time-delayed incendiary devices in an attempt to avoid
detection.
8. On or about October 11, 1998, at Rock Springs, Wyoming, in the District of
Wyoming, defendants JOSEPHINE SUNSHINE OVERAKER, KEVIN TUBBS, STANISLAS
GREGORY MEYERHOFF and CHELSEA DAWN GERLACH, unindicted co-conspirator
WILLIAM C. RODGERS, and other persons known to the Grand Jury, unlawfully and willfully
caused and aided, abetted, counseled, commanded, induced, and procured the attempt to damage
and destroy, by means of fire and an explosive, buildings and other real and personal property
owned and possessed by the United States and the Bureau of Land Management of the
Department of the Interior, located at the Wild Horse Holding Facility, Rock Springs, Wyoming.
8a. On or about October 11,1998, defendants JOSEPHINE SUNSHINE
OVERAKER, KEVIN TUBBS, STANISLAS GREGORY MEYERHOFF and CHELSEA
DAWN GERLACH, unindicted co-conspirator WILLIAM C. RODGERS, and other persons
known and unknown to the Grand Jury, brought digital timers, containers of fuel, two-way radios
and a scanner, to a staging area near the Wild Horse Holding Facility.
8b. On or about October 11, 1998, at Rock Springs, Wyoming, defendants
JOSEPHINE SUNSHINE OVERAKER, KEVIN TUBBS, STANISLAS GREGORY
MEYERHOFF and CHELSEA DAWN GERLACH, unindicted co-conspirator WILLIAM C.
RODGERS, and other persons known to the Grand Jury, went to the Wild Horse Holding
Facility, and began the release of horses and the placing of incendiary devices in and about the
facility.
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8c. On or about October 11, 1998, at Rock Springs, Wyoming, defendants
JOSEPHINE SUNSHINE OVERAKER, KEVIN TUBBS, STANISLAS GREGORY
MEYERHOFF and CHELSEA DAWN GERLACH, unindicted co-conspirator WILLIAM C.
RODGERS, and other persons known to the Grand Jury, hid timing devices in large rock outcroppings
near the Wild Horse Holding Facility, after hearing on their scanner that police had
been dispatched to their location.
8d. On or about November 13, 1998, certain defendants in the Wild Horse Holding
Facility attempted arson issued a statement attributing responsibility for the horse release and
attempted arson to the Animal Liberation Front (ALF).
9. On or about October 19, 1998, in Eagle County, Colorado, defendants
JOSEPHINE SUNSHINE OVERAKER, KEVIN TUBBS, STANISLAS GREGORY
MEYERHOFF and CHELSEA DAWN GERLACH, unindicted co-conspirator WILLIAM C.
RODGERS, and other persons known and unknown to the Grand Jury, unlawfully and willfully
caused and aided, abetted, counseled, commanded, induced, and procured the malicious
damaging and destroying, by means of fire and explosives, of buildings and other real and
personal property used in interstate commerce and in activities affecting interstate commerce, at
the Vail Ski Facility.
9a. On or about October 21, 1998, certain defendants in the Vail arson issued a
communique attributing the fire to the Earth Liberation Front (ELF).
10. On or about December 22, 1998, at Medford, Jackson County, Oregon, defendants
SARAH KENDALL HARVEY, KEVIN TUBBS and REBECCA RUBIN, and another person
known to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,
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commanded, induced, and procured the attempt to damage or destroy, by means of fire and an
explosive, a building and other real and personal property used in interstate commerce and used
in activities affecting interstate commerce, namely, an office building and its contents at U.S.
Forest Industries, 261 1 Whittle Avenue, Medford, Jackson County, Oregon.
lOa. A few weeks prior to December 22, 1998, defendants SARAH KENDALL
HARVEY, KEVIN TUBBS and REBECCA RUBIN, and another person known to the Grand
Jury, performed a reconnaissance and "dry run" for the arson at the U.S. Forest Industries
building in Medford, Oregon.
lob. On or about December 22, 1998, at Medford, Jackson County, Oregon, defendants
SARAH KENDALL HARVEY, KEVIN TUBBS and REBECCA RUBIN, and another person
known to the Grand Jury, placed time-delayed incendiary devices at and about the U.S. Forest
Service building.
10c. Prior to December 27, 1998, after placement of the time-delayed incendiary
devices at the U.S. Forest Industries building, defendant SARAH KENDALL HARVEY and
another person known to the Grand Jury searched the media and found no mention of the burning
of the U.S. Forest Industries building.
10d. Between December 22 and 27,199 8, defendant SARAH KENDALL HARVEY
and another person known to the Grand Jury returned to the U.S. Forest Industries building to
check on the destructive devices.
11. On or about December 27, 1998, at Medford, Jackson County, Oregon, defendant
SARAH KENDALL HARVEY and another person known to the Grand Jury unlawfully and
willfully caused and aided, abetted, counseled, commanded, induced, and procured the malicious
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damaging and destroying, by means of fire and an explosive, of a building and other real and
personal property used in interstate commerce and used in activities affecting interstate
commerce, namely, an office building and its contents at U.S. Forest Industries, 261 1 Whittle
Avenue, Medford, Jackson County, Oregon.
1 la. On or about December 27, 1998, defendant SARAH KENDALL HARVEY and
another person known to the Grand Jury returned to the U.S. Forest Industries building, placed a
new time-delayed incendiary device at or about the building and left the area.
1 lb. On or about December 27, 1998, defendant SARAH KENDALL HARVEY and
another person known to the Grand Jury, traveled to Dunsmuir, California, to avoid detection.
1 lc. On or about December 27, 1998, defendant SARAH KENDALL HARVEY
registered under a false name in the Cedar Lodge Motel in Dunsmuir, California.
1 1 d. On or about January 16, 1999, certain defendants in the U.S. Forest Industries
arson issued a communique attributing the fire to the Earth Liberation Front (ELF). The
communique was publicized by Craig Rosebraugh of the Liberation Collective in Portland,
Oregon.
12. On or about May 9, 1999, at Eugene, Lane County, Oregon, defendants
JOSEPHINE SUNSHINE OVERAKER, KEVIN TUBBS, STANISLAS GREGORY
MEYERHOFF, CHELSEA DAWN GERLACH, and other persons known to the Grand Jury,
unlawfully and willfully caused and aided, abetted, counseled, commanded, induced, and
procured the malicious damaging and destroying, by means of fire and an explosive, of a building
and other real and personal property used in interstate commerce and in activities affecting
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interstate commerce, at Childers Meat Company, 29476 Airport Road, Eugene, Lane County,
Oregon.
12a. On or about May 9,1999, defendants JOSEPHINE SUNSHINE OVERAKER,
KEVIN TUBBS, STANISLAS GREGORY MEYERHOFF and CHELSEA DAWN GERLACH,
and other persons known to the Grand Jury, prepared five-gallon buckets, timers and fuel for the
arson which was to occur at the Childers Meat Company, Eugene, Oregon.
12b. On or about May 9, 1999, defendants JOSEPHINE SUNSHINE OVERAKER,
KEVIN TUBBS, STANISLAS GREGORY MEYERHOFF and CHELSEA DAWN GERLACH,
and other persons known to the Grand Jury, traveled to the Childers Meat Company and placed
one time-delayed incendiary device near the front of the office building and placed another such
device at the back of the building near a gas meter.
12c. On or about May 27, 1999, certain defendants in the Childers arson issued a
communique attributing the fire to the Animal Liberation Front (ALF). The communique was
publicized by the ALF Frontline Information Service.
13. On or about December 25, 1999, at Monmouth, Polk County, Oregon, defendants
JOSEPHINE SUNSHINE OVERAKER, STANISLAS GREGORY MEYERHOFF and
CHELSEA DAWN GERLACH, and another person known to the Grand Jury, unlawfully and
willfully caused and aided, abetted, counseled, commanded, induced, and procured the malicious
damaging and destroying, by means of fire and an explosive, of a building and other real and
personal property used in interstate commerce and in activities affecting interstate commerce, at
the Boise Cascade Office, 450 North Pacific Avenue, Monrnouth, Polk County, Oregon.
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13a. On or about December 25, 1999, defendants JOSEPHINE SUNSHINE
OVERAKER, STANISLAS GREGORY MEYERHOFF and CHELSEA DAWN GERLACH,
and another person known to the Grand Jury, prepared time-delayed incendiary devices to be
used at the Boise Cascade Office, and, after disguising the devices by wrapping them in
Christmas paper, transported the devices to the Boise Cascade Office location.
13b. On or about December 25, 1999, at Monmouth, Polk County, Oregon, defendants
JOSEPHINE SUNSHINE OVERAKER, STANISLAS GREGORY MEYERHOFF and
CHELSEA DAWN GERLACH, and another person known to the Grand Jury, placed timedelayed
incendiary devices at and about the Boise Cascade Office building and left the area.
13c. On or about December 30, 1999, certain defendants in the Boise Cascade arson
issued a communique attributing the fire to the Earth Liberation Front (ELF). The communique
was publicized by Craig Rosebraugh of the Liberation Collective in Portland, Oregon, and the
North American ELF Press Office.
14. On or about September 6,2000, at Eugene, Lane County, Oregon, defendants
STANISLAS GREGORY MEYERHOFF, KEVIN TUBBS and CHELSEA DAWN GERLACH,
unlawfully and willfully caused and aided, abetted, counseled, commanded, induced, and
procured the malicious damaging and destroying, by means of fire and an explosive, of a building
and other real and personal property used in interstate commerce and in activities affecting
interstate commerce, at the Eugene Police Department West University Public Safety Station,
79 1 East 1 3th Avenue, Eugene, Oregon.
14a. On or about September 6,2000, defendants STANISLAS GREGORY
MEYERHOFF, KEVIN TUBBS and CHELSEA DAWN GERLACH traveled to the Eugene
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Police Department West University Public Safety Station and placed time-delayed incendiary
devices at and about the police station.
15. On or about January 2, 2001, at Glendale, Douglas County, Oregon, defendants
STANISLAS GREGORY MEYERHOFF, KEVIN TUBBS, DANIEL GERARD McGOWAN
and SUZANNE SAVOIE, and another person known to the Grand Jury, unlawfully and willfully
caused and aided, abetted, counseled, commanded, induced, and procured the malicious
damaging and destroying, by means of fire and an explosive, of a building and other real and
personal property used in interstate commerce and used in activities affecting interstate
commerce, namely, a building and its contents located at Superior Lumber Company, 2695
Glendale Valley Road, Glendale, Douglas County, Oregon.
15a. On or about January 2,200 1, defendants STANISLAS GREGORY
MEYERHOFF, KEVIN TUBBS, DANIEL GERARD McGOWAN and SUZANNE SAVOIE,
and another person known to the Grand Jury, traveled in separate vehicles to a predetermined
staging area at a rest area located just north of the town of Glendale, Oregon, on Interstate 5,
where they dressed in dark clothing and put on their radio earpieces and masks.
15b. On or about January 2,2001, defendants STANISLAS GREGORY
MEYERHOFF, KEVIN TUBBS, DANIEL GERARD McGOWAN and SUZANNE SAVOIE,
and another person known to the Grand Jury, traveled to the Superior Lumber Company building,
set up lookouts, positioned the "pick-up7' vehicle, placed the time-delayed incendiary devices,
and returned to the staging area.
15c. On or about January 2,2001, defendants STANISLAS GREGORY
MEYERHOFF, KEVIN TUBBS, DANIEL GERARD McGOWAN and SUZANNE SAVOIE,
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and another person known to the Grand Jury, upon returning to the staging area, changed their
clothing and disposed of their dark clothing.
15d. On or about January 6,2001, certain defendants in the Superior Lumber
Company arson issued a communique attributing the fire to the Earth Liberation Front (ELF).
The communique was publicized by Craig Rosebraugh of the North American ELF Press Office.
16. On or about March 30,2001, at Eugene, Lane County, Oregon, defendants
STANISLAS GREGORY MEYERHOFF and KEVIN TUBBS, unindicted co-conspirator
WILLIAM C. RODGERS, and other persons unknown to the Grand Jury, unlawfully and
willfully caused and aided, abetted, counseled, commanded, induced, and procured the malicious
damaging and destroying, by means of fire and an explosive, of vehicles and other personal
property used in interstate commerce and in activities affecting interstate commerce, at Joe
Romania Chevrolet Truck Center, 1425 Walnut Street, Eugene, Oregon.
16a. On or about March 30,2001, defendants STAMSLAS GREGORY
MEYERHOFF and KEVIN TUBBS, unindicted co-conspirator WILLIAM C. RODGERS, and
other persons unknown to the Grand Jury, traveled to Joe Romania Chevrolet Truck Center and
stationed KEVIN TUBBS as a lookout, while the others placed an incendiary device and plastic
containers filled with gasoline underneath the vehicles and connected the vehicles and containers
with rolled-up sheets soaked in gasoline.
16b. On or about March 3 1,2001, certain defendants in the Romania Chevrolet arson
issued a communique which was publicized by Craig Rosebraugh of the North American ELF
Press Office.
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17. On or about May 2 1,2001, at Clatskanie, Columbia County, Oregon, defendants
STANISLAS GREGORY MEYERHOFF, KEVIN TUBBS, DANIEL GERARD McGOWAN
and CHELSEA DAWN GERLACH, unindicted co-conspirator WILLIAM C. RODGERS, and
other persons known and unknown to the Grand Jury, unlawfully and willfully caused and aided,
abetted, counseled, commanded, induced, and procured the malicious damaging and destroying,
by means of fire and an explosive, of buildings, vehicles and other real and personal property
used in interstate commerce and in activities affecting interstate commerce, at Jefferson Poplar
Farm, 791 14 Collins Road, Clatskanie, Columbia County, Oregon.
17a. At a time prior to May 2 1,200 1, defendant STANISLAS GREGORY
MEYERHOFF, unindicted co-conspirator WILLIAM C. RODGERS, and other persons known
and unknown to the Grand Jury, participated in a meeting in which it was decided by those
present that two arsons would be carried out at the same time, one at the Jefferson Poplar Farm in
Clatskanie, Oregon, and the other at the University of Washington Horticulture Center in Seattle,
Washington.
17b. At a time prior to May 2 1,2001, defendants STANISLAS GREGORY
MEYERHOFF and CHELSEA DAWN GERLACH performed a reconnaissance for the arson at
the Jefferson Poplar Farm.
17c. On or about May 2 1,2001, STANISLAS GREGORY MEYERHOFF and
DANIEL GERARD McGOWAN, and others known and unknown to the Grand Jury, traveled to
Jefferson Poplar Farm and placed time-delayed incendiary devices at several locations at and
around the facility, with one of the locations being adjacent to a large propane gas tank.
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17d. On or about May 2 1,2001, certain defendants in the Jefferson Poplar Farm arson
spray-painted graffiti at the site attributing the action to the Earth Liberation Front (ELF).
17e. On or about June 1,2001, certain defendants in the Jefferson Poplar Farm arson
issued a communique attributing the fire, along with the University of Washington fire described
below, to the Earth Liberation Front (ELF). The communique was publicized by Craig
Rosebraugh of the North American ELF Press Office.
18. On or about May 21,2001, at Seattle, Washington, in the Western District of
Washington, defendant STANISLAS GREGORY MEYERHOFF, unindicted co-conspirator
WILLIAM C. RODGERS, and other persons known and unknown to the Grand Jury, unlawfully
and willfully caused and aided, abetted, counseled, commanded, induced, and procured the
malicious damaging and destroying, by means of fire and an explosive, of a building and other
real and personal property used in interstate commerce and in activities affecting interstate
commerce, at the University of Washington Horticulture Center, Seattle, Washington.
18a. At a time prior to May 2 1,2001, defendants STANISLAS GREGORY
MEYERHOFF, CHELSEA DAWN GERLACH, and unindicted co-conspirator WILLIAM C.
ROGERS performed one or more reconnaissances of the University of Washington Horticulture
Center, Seattle, Washington.
18b. On or about June 1,2001, certain defendants in the University of Washington
arson issued a communique attributing the fire, along with the Jefferson Poplar Farm fire
described above, to the Earth Liberation Front (ELF). The communique was publicized by Craig
Rosebraugh of the North American ELF Press Office.
19. On or before May 28,200 1, defendant STANISLAS GREGORY MEYERHOFF
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and unindicted co-conspirator WILLIAM C. RODGERS authored and published a document
entitled "Setting Fire with Electrical Timers, an Earth Liberation Front Guide" in order to expose
to a widespread audience their methods of operation and the design of the "Cat's Cradle"
incendiary device so that they would no longer be unique to the arsons committed by "the
Family," thereby hindering detection by law enforcement.
20. On or about October 15,2001, at Litchfield, California, in the Eastern District of
California, defendants STANISLAS GREGORY MEYERHOFF, JOSEPH DIBEE, REBECCA
RUBIN, KEVIN TUBBS, CHELSEA DAWN GERLACH and DARREN TODD THURSTON,
unindicted co-conspirator WILLIAM C. RODGERS, and other persons known and unknown to
the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled, commanded,
induced and procured the malicious damaging and destroying, by means of fire and explosives,
of buildings and other real and personal property owned and possessed by the United States and
the Bureau of Land Management of the Department of the Interior, located at the Wild Horse
Facility, Litchfield, California.
20a. On or about October 15,2001, defendant STANISLAS GREGORY
MEYERHOFF and persons known and unknown to the Grand Jury placed time-delayed
incendiary devices at and about the Litchfield Wild Horse Facility.
20b. On or about October 30,2001, certain defendants in the Litchfield Wild Horse
Facility arson issued a communique attributing the fire to the Earth Liberation Front (ELF). The
communique was publicized by David Barbarash at the North American ALF Press Office.
21. On or about November 25,2005, unindicted co-conspirator WILLIAM C.
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RODGERS attempted to recruit a person known to the Grand Jury to participate in future direct
actions and stated: ". . .I'll be really energized and ready to set up. . .activities in ways that
haven't been seen before."
22. On or about December 21,2005, defendants CHELSEA DAWN GERLACH
and DARREN TODD THURSTON possessed books and documents containing instructions on
how to engage in unlawful activities, including a book entitled "Advanced Anarchist Arsenal:
Recipes for Improvised Incendiaries and Explosives".
23. In order to conceal evidence and to hinder the investigation and prosecution of the
above-described crimes, and to facilitate the flight and concealment of certain of the defendants,
a number of overt acts occurred, including but not limited to the following:
23a. Defendants CHELSEA DAWN GERLACH and DARREN TODD THURSTON
possessed and used false identification documents, including those found in their possession on
December 7,2005, and discovered at their Portland residence on December 2 1,2005.
23b. On December 21,2005, defendants CHELSEA DAWN GERLACH and
DARREN TODD THURSTON possessed in their residence books and informational materials
with respect to manufacturing false identity documents.
23c. On December 21,2005, defendants CHELSEA DAWN GERLACH and
DARREN TODD THURSTON possessed in their residence large amounts of information on the
identities of other individuals, including many deceased persons.
23d. On December 7,2005, defendant KEVIN TUBBS possessed in a locked safe
false identity documents.
23e. Sometime after the Fall of 2001, defendant JOSEPHINE SUNSHINE
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OVERAKER left the United States and fled to Europe.
23f. In or about the Spring of 2005, defendant REBECCA RUBIN returned to Canada.
23g. On or about December 11,2005, defendant JOSEPH DIBEE left the United States
following contact by federal law enforcement agents.
All of the above conduct violated Title 18, United States Code, Section 844(n).
COUNT 2
CONSPIRACY TO COMMIT ARSON AND
DESTRUCTION OF AN ENERGY FACILITY
I. OBJECT OF THE CONSPIRACY
Beginning in October 1996 and continuing through December 2001, in the District of
Oregon and elsewhere, defendants JOSEPHINE SUNSHINE OVERAKER, KEVIN TUBBS,
STANISLAS GREGORY MEYERHOFF, DANIEL GERARD McGOWAN, JOSEPH DIBEE,
REBECCA RUBIN, CHELSEA DAWN GERLACH, SARAH KENDALL HARVEY,
SUZANNE SAVOIE, JONATHAN MARK CHRISTOPHER PAUL and DARREN TODD
THURSTON, and unindicted co-conspirator WILLIAM C. RODGERS, and other persons known
and unknown to the Grand Jury, willfully and knowingly conspired and agreed to commit the
following offenses against the United States:
to maliciously damage or destroy, or attempt to damage or destroy, by means of
fire or an explosive, any building, vehicle or other personal or real property in
whole or in part owned or possessed by, or leased to, the United States or any
department or agency thereof, in violation of Title 18, United States Code, Section
844(f)(l);
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to maliciously damage or destroy, or attempt to damage or destroy, by means of
fire or an explosive, any building, vehicle or other real or personal property used
in interstate commerce or in any activity affecting interstate commerce, in
violation of Title 18, United States Code, Section 844(i); and
to knowingly and willfully damage and attempt to damage the property of an
energy facility of the United States involved in the transmission and distribution
of electricity, in an amount exceeding or which would have exceeded $100,000, in
violation of Title 18, United States Code, Section 1366(a).
11. MANNER AND MEANS OF THE CONSPIRACY
The foregoing objects of the conspiracy were to be accomplished in the following manner
by the above-listed defendants and others at various times during the course of the conspiracy:
1. Certain of the defendants and others joined together in a group they called the
"Family." This "Family77w as what is commonly known as a "cell" of groups and movements
publicly named and described by certain of the defendants and others as the Earth Liberation
Front (ELF), the Animal Liberation Front (ALF), and other names.
2. The general purposes of the conspiracy were to influence and affect the conduct
of government, commerce, private business and others in the civilian population by means of
force, violence, sabotage, mass destruction, intimidation and coercion, and by similar means to
retaliate against the conduct of government, commerce and private business. To achieve these
purposes, the conspirators committed and attempted to commit acts dangerous to human life and
property that constituted violations of the criminal laws of the United States and of individual
states.
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3. Certain of the defendants and others targeted for arson buildings, vehicles and
other real and personal property owned, possessed, and leased by the United States and its
departments and agencies.
4. Certain of the defendants and another person targeted for willful damage an
energy facility of the United States involved in the transmission and distribution of electricity, in
an amount exceeding or which would have exceeded $100,000.
5. Certain of the defendants and others targeted for arson buildings, vehicles and
other real and personal property used in interstate commerce and in activities affecting interstate
commerce.
6. Certain of the defendants and others conducted and participated in meetings to
plan arsons and other damage of the targeted sites.
7. Certain of the defendants and others conducted research and surveillance of sites
targeted for arson and other damage.
8. In discussing their actions among themselves, certain of the defendants and others
used code words, code names, and nicknames.
9. Certain of the defendants and others designed and constructed destructive devices
which functioned as incendiary bombs to ignite fires and destroy the targets.
10. Certain of the defendants and others provided transportation to the sites targeted
for arson and other damage.
11. Certain of the defendants and others dressed in dark clothing, wore masks and
gloves and otherwise disguised their appearance.
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12. Certain of the defendants and others acted as "look-outs" to ensure secrecy as the
crimes were carried out.
13. Certain of the defendants and others placed destructive devices and accelerants at
sites targeted for arson and ignited or attempted to ignite the devices and accelerants.
14. Certain of the defendants and others, by means of fire and explosives, maliciously
damaged and destroyed, and attempted to damage and destroy, buildings, vehicles and other real
and personal property owned and possessed by the United States and its departments and
agencies.
15. Certain of the defendants and others, by means of fire and explosives, maliciously
damaged and destroyed, and attempted to damage and destroy, buildings, vehicles and other real
and personal property used in interstate commerce and in activities affecting interstate
commerce.
16. Certain of the defendants and another person willfully damaged and attempted to
damage the property of an energy facility of the United States involved in the transmission and
distribution of electricity, in an amount exceeding or which would have exceeded $100,000.
17. In some of the arsons and attempted arsons, certain of the defendants and others
painted messages on the walls of the targets, including "Earth Liberation Front," "ELF" and
related names and statements concerning the purposes of the crimes.
18. After the arsons, attempted arsons, and other crimes, certain of the defendants and
others provided transportation away fiom the scenes of the crimes.
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19. After the arsons, attempted arsons, and other crimes, certain of the defendants and
others destroyed, buried, hid and otherwise disposed of physical evidence used in the
commission of the crimes.
20. After the arsons, certain of the defendants and others publicized and promoted the
results of the fires by means of written press releases and communiques attributing the arsons to
the Earth Liberation Front (ELF), the Animal Liberation Front (ALF) and related groups, and
stating the purposes of the arsons.
21. Before, during and after the arsons, attempted arsons and other crimes, certain of
the defendants and others agreed and took an oath among themselves never to reveal to law
enforcement authorities or to anyone else outside "the Family" the identity of the conspirators
and participants in the arsons, attempted arsons and other crimes.
22. Before, during and after the arsons, attempted arsons and other crimes, certain of
the defendants and others agreed among themselves to conceal or destroy any evidence
connecting them to the arsons, attempted arsons and other crimes.
23. Before, during and after the arsons, attempted arsons and other crimes, certain of
the defendants and others possessed andlor used false identification documents in order to
conceal their true identities.
24. After the arsons, attempted arsons and other crimes, certain of the defendants and
others fled and secreted themselves in foreign countries in order to avoid detection and arrest by
law enforcement authorities in the United States.
I / I
/ 11
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111. OVERT ACTS
In order to carry out the objects of the conspiracy, defendants and other persons
committed various overt acts within the District of Oregon and elsewhere, including but not
limited to the following:
1. On or about October 28, 1996, in Marion County, Oregon, defendant JOSEPHINE
SUNSHINE OVERAKER and other persons known to the Grand Jury, unlawfully and willfully
caused and aided, abetted, counseled, commanded, induced, and procured the attempt to damage
or destroy, by means of fire and an explosive, a building, and other real and personal property
owned and possessed by the United States and the United States Forest Service of the
Department of Agriculture, located at the Detroit Ranger Station on the Willamette National
Forest.
1 a. At a time prior to October 28,1996, JOSEPHINE SUNSHINE OVERAKER and
another person known to the Grand Jury prepared and tested a time-delayed incendiary device.
lb. On or about October 28, 1996, JOSEPHINE SUNSHINE OVERAKER and other
persons known to the Grand Jury drove to the U.S. Forest Service Detroit Ranger Station in
Marion County, Oregon, with an incendiary device, which was placed on the roof of a U.S.
Forest Service building. That incendiary device failed to function.
lc. On or about October 28, 1996, defendant JOSEPHINE SUNSHINE OVERAKER
and other persons known to the Grand Jury spray-painted graffiti on the sides of the U.S. Forest
Service building and vehicles which included the words "Earth Liberation Front."
2. On or about October 28, 1996, in Marion County, Oregon defendant JOSEPHINE
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SUNSHINE OVERAKER and other persons known to the Grand Jury, unlawfully and willfully
caused and aided, abetted, counsel, commanded, induced, and procured the malicious damaging
and destroying, by means of fire and an explosive of a vehicle and other real and personal
property owned and possessed by the Untied States and the United States Forest Service of the
Department of Agriculture, located at the Detroit Ranger Station on the Willamette National
Forest.
2a. On or about October 28,1996, JOSEPHINE SUNSHINE OVERAKER and
another person known to the Grand Jury intended and caused fire damage to a U.S. Forest
Service vehicle.
3. On or about October 30, 1996, in Lane County, Oregon, defendants JOSEPHINE
SUNSHINE OVERAKER and KEVIN TUBBS, and another person known to the Grand Jury,
unlawfully and willfully caused and aided, abetted, counseled, commanded, induced, and
procured the malicious damaging and destroying, by means of fire and an explosive, of a building
and other real and personal property owned and possessed by the United States and the United
States Forest Service of the Department of Agriculture, located at the Oakridge Ranger Station
on the Willamette National Forest.
3a. On or about October 30, 1996, in Lane County, Oregon, defendants JOSEPHINE
SUNSHINE OVERAKER and KEVIN TUBBS, and another person known to the Grand Jury,
drove to the U.S. Forest Service Oakridge Ranger Station, intending to set fire to the Ranger
Station.
3b. On or about October 30, 1996, in Lane County, Oregon, defendants JOSEPHINE
SUNSHINE OVERAKER and KEVIN TUBBS, and another person known to the Grand Jury,
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while leaving the parking lot of the U.S. Forest Service Oakridge Ranger Station, threw nails
onto the parking lot in order to slow down responding emergency vehicles.
3c. On or about October 30, 1996, in Lane County, Oregon, defendants JOSEPHINE
SUNSHINE OVERAKER and KEVIN TUBBS, and another person known to the Grand Jury,
while leaving the U.S. Forest Service Oakridge Ranger Station and driving westbound on
Highway 58 towards Eugene, Oregon, discarded their gloves in a reservoir near the Lowell
Bridge.
4. On or about July 21, 1997, at Redmond, Deschutes County, Oregon, defendants
KEVIN TUBBS, JOSEPH DBEE and JONATHAN MARK CHRISTOPHER PAUL, and other
persons known to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,
commanded, induced, and procured the malicious damaging and destroying, by means of fire and
an explosive, of a building and other real and personal property used in interstate commerce and
in activities affecting interstate commerce, at Cavel West, Inc., 1607 SE Railroad, Redmond,
Oregon.
4a. Approximately one week prior to the July 2 1, 1997, arson at Cavel West, Lnc.,
defendants KEVIN TUBBS and JONATHAN MARK CHRISTOPHER PAUL and others known
and unknown to the Grand Jury, went on a reconnaissance in order to locate a staging area where
the participants could complete final preparations prior to committing the arson.
4b. Prior to the July 2 1, 1997, arson at Cavel West Inc., defendant JONATHAN
MARK CHRISTOPHER PAUL and another person known to the Grand Jury prepared a mixture
of soap and petroleum products which was the fuel used in the time- delayed incendiary devices.
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4c. On or about July 21, 1997, defendants KEVIN TUBBS, JOSEPH DIBEE and
JONATHAN MARK CHRISTOPHER PAUL, and other persons known to the Grand Jury, drove
to the previously chosen staging area near Cavel West, Inc., and upon arrival, dressed in dark
clothing, masks, and gloves, and dug a hole at the staging area in which to bury their dark
clothing upon completion of the arson.
4d. On or about July 2 1, 1997, defendants KEVIN TUBBS, JOSEPH DIBEE and
JONATHAN MARK CHRISTOPHER PAUL, and other persons known to the Grand Jury,
completed a two-way radio check with one another and confirmed their scanner and radios
functioned properly.
4e. On or about July 2 1, 1997, defendants KEVIN TUBBS, JOSEPH DIBEE and
JONATHAN MARK CHRISTOPHER PAUL, and other persons known to the Grand Jury, went
to the location of Cavel West, Inc., to place time-delayed incendiary devices at and about that
location.
4f. On or about July 2 1, 1997, defendant JOSEPH DIBEE drilled holes through the
wall of the Cavel West, Inc., facility so as to allow fuel to be poured directly into the building.
4g. On or about July 2 1, 1997, defendants KEVIN TUBBS, JOSEPH DIBEE and
JONATHAN MARK CHRISTOPHER PAUL, and other persons known to the Grand Jury, upon
placing the time-delayed incendiary devices at Cavel West, Inc., traveled back to the staging area,
removed their dark clothes and shoes, placed them in the hole, poured acid on the clothing in the
hole and then buried the items.
4h. On or about July 26, 1997, certain defendants in the Cavel West arson issued a
written communique attributing the fire to the Animal Liberation Front (ALF) and the Equine
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and Zebra Liberation Front. The communique was publicized by Craig Rosebraugh of the
Liberation Collective in Portland, Oregon.
4i. Approximately three years after July 2 1, 1997, defendant JOSEPH DIBEE
contacted defendant KEVIN TUBBS and told KEVIN TUBBS to return to the staging area and
retrieve the buried clothes.
5. On or about November 30, 1997, in Harney County, Oregon, defendants
JOSEPHINE SUNSHINE OVERAKER, KEVIN TUBBS, JOSEPH DIBEE and REBECCA
RUBIN, unindicted co-conspirator WILLIAM C. RODGERS, and another person known to the
Grand Jury, unlawfully and willfully caused and aided, abetted, counseled, commanded, induced,
and procured the malicious damaging and destroying, by means of fire and an explosive, of
buildings and other real and personal property owned and possessed by the United States and the
Bureau of Land Management of the Department of Interior, located at the Wild Horse and Burro
Facility, Bums, Harney County, Oregon.
5a. Approximately three months prior to November 30, 1997, defendants
JOSEPHINE SUNSHINE OVERAKER and KEVIN TUBBS, unindicted co-conspirator
WILLIAM C. RODGERS, and another person known to the Grand Jury, did a reconnaissance at
and near the Wild Horse and Burro Facility, to prepare themselves for the arson and horse
release.
5b. Sometime prior to November 30, 1997, defendant JOSEPHINE SUNSHINE
OVERAKER and another person known to the Grand Jury, obtained five-gallon, white plastic
buckets and the fuel to be used in making time-delayed incendiary devices.
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5c. Sometime prior to November 30, 1997, persons known and unknown to the Grand
Jury, prepared the five-gallon plastic buckets by wiping the buckets to ensure all fingerprints
were removed, and painted them with black spray paint.
5d. Sometime prior to November 30,1997, defendants JOSEPHINE SUNSHINE
OVERAKER, KEVIN TUBBS and REBECCA RUBIN, unindicted co-conspirator WILLIAM C.
RODGERS, and another person known to the Grand Jury, obtained additional components and
assembled time-delayed incendiary devices, which were composed of kitchen timers, matches,
fuel-soaked sponges, model rocket igniters, one-gallon jugs filled with fuel and five-gallon
buckets which contained fuel.
5e. On or about November 30,1997, defendants JOSEPHINE SUNSHINE
OVERAKER, KEVIN TUBBS and REBECCA RUBIN, unindicted co-conspirator WILLIAM C.
RODGERS, and another person known to the Grand Jury, arrived at the Wild Horse and Burro
Facility, cut the lock on the front gate, released horses and burros, placed time-delayed incendiary
devices in and around the facility, and left the area.
5f. On or about December 5, 1997, certain defendants in the Wild Horse and Burro
Facility arson issued a communique attributing the fire and horse release to the Earth Liberation
Front (ELF) and the Animal Liberation Front (ALF). The communique was publicized by Craig
Rosebraugh of the Liberation Collective in Portland, Oregon.
6. On or about June 21, 1998, at Olympia, Washington, in the Western District of
Washington, defendants JOSEPHINE SUNSHINE OVERAKER, KEVIN TUBBS and JOSEPH
DIBEE, unindicted co-conspirator WILLIAM C. RODGERS, and another person known to the
Grand Jury, willfully caused and aided, abetted, counseled, commanded, induced, and procured
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the malicious damaging and destroying, by means of fire and an explosive, of a building and
other real and personal property leased and possessed by the United States and the Animal, Plant
and Health Inspection Service (APHIS) of the Department of Agriculture, located at the National
Wildlife Research Facility, 9701 Blomberg Street SW, Olympia, Washington.
6a. Approximately two weeks before June 21, 1998, defendants KEVIN TUBBS and
JOSEPH DIBEE, and other persons known and unknown to the Grand Jury, met in Olympia,
Washington, to discuss plans for the APHIS arson, and agreed at that time there would be a
second and simultaneous arson committed when the APHIS arson was to occur.
6b. At a time prior to June 21, 1998, defendant JOSEPHINE SUNSHINE
OVERAKER and other persons known to the Grand Jury prepared five-gallon buckets by wiping
the buckets to remove any fingerprints, and obtained fuel for the APHIS arson.
6c. At a time prior to June 21, 1998, defendant KEVIN TUBBS utilized false
identification to acquire a van which was used in the APHIS arson.
6d. On or about June 2 1,1998, defendant JOSEPHINE SUNSHINE OVERAKER,
while attempting to steal items in preparation for the APHIS arson, was arrested by authorities
for shoplifting.
6e. On or about June 21, 1998, defendant KEVIN TUBBS and another person known
to the Grand Jury transferred five-gallon buckets of fuel to be used in the APHIS arson from a
van purchased by KEVIN TUBBS to a vehicle owned by unindicted co-conspirator WILLIAM C.
RODGERS.
6f. On or about June 21, 1998, defendant KEVIN TUBBS, unindicted co-conspirator
WILLTAM C. RODGERS, and another person known to the Grand Jury, drove to the APHIS
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facility and placed five-gallon buckets filled with fuel at locations at and around the facility and
ignited the fuel-filled buckets by hand.
6g. On or about June 22, 1998, certain defendants in the APHIS arson issued a
communique attributing the fire to the Earth Liberation Front(ELF) and the Animal Liberation
Front (ALF). The communique was publicized by Katie Fedor of the North American ALF Press
Office.
6h. At a time after January 27, 1998, defendant KEVIN TUBBS assisted in the
disposal of the van used in the APHIS arson.
7. In about September 1998, at Rock Springs, Wyoming, in the District of Wyoming,
defendants KEVIN TUBBS and REBECCA RUBIN, unindicted co-conspirator WILLIAM C.
RODGERS, and other persons known and unknown to the Grand Jury, unlawfully and willfully
caused and aided, abetted, counseled, commanded, induced, and procured the attempt to damage
or destroy, by means of fire and an explosive, a building and other real and personal property
owned and possessed by the United States and the Bureau of Land Management of the
Department of the Interior, located at the Wild Horse Holding Facility, Rock Springs, Wyoming.
7a. In or about September 1998, defendants KEVIN TUBBS and REBECCA RUBIN,
unindicted co-conspirator WILLIAM C. RODGERS, and other persons known and unknown to
the Grand Jury, arrived at the staging area near Rock Springs, Wyoming, assigned roles, prepared
time-delayed incendiary devices, and made preparations for the arson, when a law enforcement
officer made inquiry as to their presence at that location.
7b. In or about September 1998, defendants KEVIN TUBBS and REBECCA RUBIN,
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unindicted co-conspirator WILLIAM C. RODGERS, and other persons known to the Grand Jury,
buried the time-delayed incendiary devices in an attempt to avoid detection.
8. On or about October 11, 1998, at Rock Springs, Wyoming, in the District of
Wyoming, defendants JOSEPHINE SUNSHINE OVERAKER, KEVIN TUBBS, STANISLAS
GREGORY MEYERHOFF and CHELSEA DAWN GERLACH, unindicted co-conspirator
WILLIAM C. RODGERS, and other persons known to the Grand Jury, unlawfully and willfully
caused and aided, abetted, counseled, commanded, induced, and procured the attempt to damage
and destroy, by means of fire and an explosive of buildings and other real and personal property
owned and possessed by the United States and the Bureau of Land Management of the
Department of the Interior, located at the Wild Horse Holding Facility, Rock Springs, Wyoming.
8a. On or about October 1 1, 1998, defendants JOSEPHINE SUNSHINE
OVERAKER, KEVIN TUBBS, STANISLAS GREGORY MEYERHOFF and CHELSEA
DAWN GERLACH, unindicted co-conspirator WILLIAM C. RODGERS, and other persons
known and unknown to the Grand Jury, brought digital timers, containers of fuel, two-way radios
and a scanner to a staging area near the Wild Horse Holding Facility.
8b. On or about October 11, 1998, at Rock Springs, Wyoming, defendants
JOSEPHINE SUNSHINE OVERAKER, KEVIN TUBBS, STANISLAS GREGORY
MEYERHOFF and CHELSEA DAWN GERLACH, unindicted co-conspirator WILLIAM C.
RODGERS, and other persons known to the Grand Jury, went to the Wild Horse Holding Facility
and began the release of horses and the placing of incendiary devices in and about the facility.
8c. On or about October 11, 1998, at Rock Springs, Wyoming, defendants
JOSEPHINE SUNSHINE OVERAKER, KEVIN TUBBS, STANISLAS GREGORY
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MEYERHOFF and CHELSEA DAWN GERLACH, unindicted co-conspirator WILLIAM C.
RODGERS, and other persons known to the Grand Jury, hid timing devices in large rock outcroppings
near the Wild Horse Holding Facility, after hearing on their scanner that police had
been dispatched to their location.
8d. On or about November 13, 1998, certain defendants in the Wild Horse Holding
Facility attempted arson issued a statement attributing responsibility for the horse release and
attempted arson to the Animal Liberation Front (ALF).
9. On or about October 19, 1998, in Eagle County, Colorado, in the District of
Colorado, defendants JOSEPHINE SUNSHINE OVERAKER, KEVIN TUBBS, STANISLAS
GREGORY MEYERHOFF and CHELSEA DAWN GERLACH, unindicted co-conspirator
WILLIAM M C. RODGERS, and other persons known and unknown to the Grand Jury,
unlawfully and willfidly caused and aided, abetted, counseled, commanded, induced, and
procured the malicious damaging and destroying, by means of fire and explosives, of buildings
and other real and personal property used in interstate commerce and in activities affecting
interstate commerce, at the Vail Ski Facility.
9a. On or about October 21, 1998, certain defendants in the Vail arson issued a
communique attributing the fire to the Earth Liberation Front (ELF).
10. On or about December 22, 1998, at Medford, Jackson County, Oregon, defendants
SARAH KENDALL HARVEY, KEVIN TUBBS and REBECCA RUBIN, and another person
known to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,
commanded, induced, and procured the attempt to damage or destroy, by means of fire and an
explosive, a building and other real and personal property used in interstate commerce and used
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in activities affecting interstate commerce, namely, an office building and its contents at U.S.
Forest Industries, 261 1 Whittle Avenue, Medford, Jackson County, Oregon.
lOa. A few weeks prior to December 22, 1998, defendants SARAH KENDALL
HARVEY, KEVIN TUBBS and REBECCA RUBIN, and another person known to the Grand
Jury, performed a reconnaissance and a "dry run" for the arson at the U.S. Forest Industries
building in Medford, Oregon.
lob. On or about December 22, 1998, at Medford, Jackson County, Oregon, defendants
SARAH KENDALL HARVEY, KEVIN TUBBS and REBECCA RUBIN, and another person
known to the Grand Jury, placed time-delayed incendiary devices at and about the U.S. Forest
Industries building.
10c. Prior to December 27, 1998, after placement of the time-delayed incendiary
devices at the U.S. Forest Industries building, defendant SARAH KENDALL HARVEY and
another person known to the Grand Jury searched the media and found no mention of the burning
of the U.S. Forest Industries building.
1 Od. Between December 22 and 27,1998, defendant SARAH KENDALL HARVEY
and another person known to the Grand Jury returned to the U.S. Forest Industries building to
check on the destructive devices.
11. On or about December 27, 1998, at Medford, Jackson County, Oregon, defendant
SARAH KENDALL HARVEY and another person known to the Grand Jury unlawfully and
willfully caused and aided, abetted, counseled, commanded, induced, and procured the malicious
damaging and destroying, by means of fire and an explosive, of a building and other real and
personal property used in interstate commerce and used in activities affecting interstate
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commerce, namely, an office building and its contents at US. Forest Industries, 261 1 Whittle
Avenue, Medford, Jackson County, Oregon.
I la. On or about December 27, 1998, defendant SARAH KENDALL HARVEY and
another person known to the Grand Jury returned to the U.S. Forest Lndustries building, placed a
new time-delayed incendiary device, and left the area.
1 lb. On or about December 27, 1998, defendant SARAH KENDAL HARVEY and
another person known to the Grand Jury traveled to Dunsmuir, California, to avoid detection.
1 lc. On or about December 27, 1998, defendant SARAH KENDALL HARVEY
registered under a false name in the Cedar Lodge Motel in Dunsmuir, California.
1 1 d. On or about January 16, 1999, certain defendants in the U.S. Forest Industries
arson issued a communique attributing the fire to the Earth Liberation Front (ELF). The
communique was publicized by Craig Rosebraugh of the Liberation Collective in Portland,
Oregon.
12. On or about May 9, 1999, at Eugene, Lane County, Oregon, defendants
JOSEPHINE SUNSHINE OVERAKER, KEVIN TUBBS, STANISLAS GREGORY
MEYERHOFF and CHELSEA DAWN GERLACH, and other persons known to the Grand Jury,
unlawfully and willfully caused and aided, abetted, counseled, commanded, induced, and
procured the malicious damaging and destroying, by means of fire and an explosive, of a building
and other real and personal property used in interstate commerce and in activities affecting
interstate commerce, at Childers Meat Company, 29476 Airport Road, Eugene, Lane County,
Oregon.
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12a. On or about May 9, 1999, defendants JOSEPHINE SUNSHINE OVERAKER,
KEVIN TUBBS, STANISLAS GREGORY MEYERHOFF and CHELSEA DAWN GERLACH,
and other persons known to the Grand Jury, prepared five-gallon buckets, timers and fuel for the
arson which was to occur at the Childers Meat Company, Eugene, Oregon.
12b. On or about May 9,1999, defendants JOSEPHINE SUNSHINE OVERAKER,
KEVIN TUBBS, STANISLAS GREGORY MEYERHOFF and CHELSEA DAWN GERLACH,
and other persons known to the Grand Jury, traveled to the Childers Meat Company and placed
one time-delayed incendiary device near the front of the office building and placed another such
device at the back of the building near a gas meter.
12c. On or about May 27, 1999, certain defendants in the Childers arson issued a
communique attributing the fire to the Animal Liberation Front (ALF). The communique was
publicized by the ALF Frontline Information Service.
13. On or about December 25, 1999, at Monrnouth, Polk County, Oregon, defendants
JOSEPHINE SUNSHINE OVERAKER, STANISLAS GREGORY MEYERHOFF and
CHELSEA DAWN GERLACH, and another person known to the Grand Jury, unlawfully and
willfully caused and aided, abetted, counseled, commanded, induced, and procured the malicious
damaging and destroying, by means of fire and an explosive, of a building and other real and
personal property used in interstate commerce and in activities affecting interstate commerce, at
the Boise Cascade Office, 450 North Pacific Avenue, Monmouth, Polk County, Oregon.
13a. On or about December 25, 1999, defendants JOSEPHINE SUNSHINE
OVERAKER, STANISLAS GREGORY MEYERHOFF and CHELSEA DAWN GERLACH,
and another person known to the Grand Jury, prepared time-delayed incendiary devices to be
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used at the Boise Cascade Office, and, after disguising the devices by wrapping them in
Christmas paper, transported the devices to the Boise Cascade Office location.
13b. On or about December 25,1999, defendants JOSEPHINE SUNSHINE
OVERAKER, STANISLAS GREGORY MEYERHOFF and CHELSEA DAWN GERLACH,
and another person known to the Grand Jury, placed time-delayed incendiary devices at and
about the Boise Cascade Office building and left the area.
13c. On or about December 30, 1999, certain defendants in the Boise Cascade arson
issued a communique attributing the fire to the Earth Liberation Front (ELF). The communique
was publicized by Craig Rosebraugh of the Liberation Collective in Portland, Oregon, and the
North American ELF Press Office.
14. On or about December 30, 1999, in Deschutes County, Oregon, defendants
JOSEPHINE SUNSHINE OVERAKER, STANISLAS GREGORY MEYERHOFF and
CHELSEA DAWN GERLACH, and another person known to the Grand Jury, willfully damaged
and attempted to damage the property of an energy facility of the United States, namely, a
Bonneville Power Administration tower, involved in the transmission and distribution of
electricity near the City of Bend, Oregon, in an amount exceeding or which would have exceeded
$100,000.
15. On or about September 6,2000, defendants STANISLAS GREGORY
MEYERHOFF, KEVIN TUBBS and CHELSEA DAWN GERLACH, and unindicted coconspirator
WILLIAM C. RODGERS, unlawfully and willfully caused and aided, abetted,
counseled, commanded, induced, and procured the malicious damaging and destroying, by means
of fire and an explosive, of a building and other real and personal property used in interstate
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commerce and in activities affecting interstate commerce, at the Eugene Police Department West
University Public Safety Station, 791 East 13th Avenue, Eugene, Lane County, Oregon.
15a. On or about September 6,2000, defendants STANISLAS GREGORY
MEYERHOFF, KEVIN TUBBS and CHELSEA DAWN GERLACH traveled to the Eugene
Police Department West University Public Safety Station and placed time-delayed incendiary
devices at and about the police station.
16. On or about January 2,2001, at Glendale, Douglas County, Oregon, defendants
STANISLAS GREGORY MEYERHOFF, KEVIN TUBBS, DANIEL GERARD McGOWAN
and SUZANNE SAVOIE, unlawfully and willfully caused and aided, abetted, counseled,
commanded, induced, and procured the malicious damaging and destroying, by means of fire and
an explosive, of a building and other real and personal property used in interstate commerce and
used in activities affecting interstate commerce, namely, a building and its contents located at
Superior Lumber Company, 2695 Glendale Valley Road, Glendale, Douglas County, Oregon.
16a. On or about January 2,2001, defendants STANISLAS GREGORY
MEYERHOFF, KEVIN TUBBS, DANIEL GERARD McGOWAN and SUZANNE SAVOIE,
and another person known to the Grand Jury, traveled in separate vehicles to a predetermined
staging area at a rest area located just north of the town of Glendale, Oregon, on Interstate 5,
where they dressed in dark clothing and put on their radio earpieces and masks..
16b. On or about January 2,2001, defendants STANISLAS GREGORY
MEYERHOFF, KEVIN TUBBS, DANIEL GERARD McGOWAN and SUZANNE SAVOIE,
and another person known to the Grand Jury, traveled to the Superior Lumber Company, set up
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lookouts, positioned the "pick-up" vehicle, placed the time-delayed incendiary devices, and
returned to the staging area.
16c. On or about January 2,2001, defendants STANISLAS GREGORY
MEYERHOFF, KEVIN TUBBS, DANIEL GERARD McGOWAN and SUZANNE SAVOIE,
and another person known to the Grand Jury, upon returning to the staging area, changed their
clothing and disposed of their dark clothing.
16d. On or about January 6,2001, participants in the Superior Lumber Company arson
issued a communique attributing the fire to the Earth Liberation Front (ELF). The communique
was publicized by Craig Rosebraugh of the North American ELF Press Office.
17. On or about March 30,2001, at Eugene, Lane County, Oregon, defendants
STANISLAS GREGORY MEYERHOFF and KEVIN TUBBS, unindicted co-conspirator
WILLIAM C. RODGERS, and other persons unknown to the Grand Jury, unlawfully and
willfully caused and aided, abetted, counseled, commanded, induced, and procured the malicious
damaging and destroying, by means of fire and an explosive, of vehicles and other personal
property used in interstate commerce and in activities affecting interstate commerce, at Joe
Romania Chevrolet Truck Center, 1425 Walnut Street, Eugene, Lane County, Oregon.
17a. On or about March 30,2001, defendants STANISLAS GREGORY
MEYERHOFF and KEVIN TUBBS, unindicted co-conspirator WILLIAM C. RODGERS, and
other persons unknown to the Grand Jury, arrived at Joe Romania Chevrolet Truck Center and
stationed KEVIN TUBBS as a lookout, while the others placed plastic containers filled with
gasoline underneath the vehicles and connected the vehicles and containers with rolled-up sheets
soaked in gasoline.
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17b. On or about March 3 1,2001, certain defendants in the Romania Chevrolet arson
issued a communique that was publicized by Craig Rosebraugh of the North American ELF Press
Office.
18. On or about May 21,2001, at Clatskanie, Columbia County, Oregon, defendants
STANISLAS GREGORY MEYERHOFF, KEVIN TUBBS, DANIEL GERARD McGOWAN
and CHELSEA DAWN GERLACH, and other persons known and unknown to the Grand Jury,
unlawfully and willfully caused and aided, abetted, counseled, commanded, induced, and
procured the malicious damaging and destroying, by means of fire and an explosive, of buildings,
vehicles and other real and personal property used in interstate commerce and in activities
affecting interstate commerce, at Jefferson Poplar Farm, 791 14 Collins Road, Clatskanie,
Columbia County, Oregon.
18a. At a time prior to May 2 1,2001, defendant STANISLAS GREGORY
MEYERHOFF, unindicted co-conspirator WILLIAM C. RODGERS, and other persons known
and unknown to the Grand Jury, participated in a meeting in which it was decided by those
present that two arsons would be carried out at the same time, one at the Jefferson Poplar Farm in
Clatskanie, Oregon, and the other at the University of Washington Horticulture Center in Seattle,
Washington.
18b. At a time prior to May 21,2001, defendant STANISLAS GREGORY
MEYERHOFF and CHELSEA DAWN GERLACH performed a reconnaissance for the arson at
the Jefferson Poplar Farm.
18c. On or about May 2 1,2001, STANISLAS GREGORY MEYERHOFF and
DANIEL GERARD McGOWAN, and others known and unknown to the Grand Jury, traveled to
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the Jefferson Poplar Farm and placed time-delayed incendiary devices at several locations at and
around the facility, with one of the locations being adjacent to a large propane gas tank.
18d. On or about May 2 1,2001, certain defendants in the Jefferson Poplar Farm arson
spray-painted graffiti at the site attributing the action to the Earth Liberation Front (ELF).
18e. On or about June 1,2001, certain defendants in the Jefferson Poplar Farm arson
issued a communique attributing the fire, along with the University of Washington fire described
below, to the Earth Liberation Front (ELF). The communique was publicized by Craig
Rosebraugh of the North American ELF Press Office.
19. On or about May 21, 2001, at Seattle, Washington, in the Western District of
Washington, defendant STANISLAS GREGORY MEYERHOFF, unindicted co-conspirator
WILLIAM C. RODGERS, and other persons known and unknown to the Grand Jury, unlawfully
and willfully caused and aided, abetted, counseled, commanded, induced, and procured the
malicious damaging and destroying, by means of fire and an explosive, of a building and other
real and personal property used in interstate commerce and in activities affecting interstate
commerce, at the University of Washington Horticulture Center, Seattle, Washington.
19a. At a time prior to May 2 1,2001, defendants STANISLAS GREGORY
MEYERHOFF, CHELSEA DAWN GERLACH, and unindicted co-conspirator WILLIAM C.
ROGERS performed one or more reconnaissances of the University of Washington Horticulture
Center, Seattle, Washington.
19b. On or about June 1,2001, certain defendants in the University of Washington
arson issued a communique attributing the fire, along with the Jefferson Poplar Farm fire
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described above, to the Earth Liberation Front (ELF). The communique was publicized by Craig
Rosebraugh of the North American ELF Press Office.
20. On or before May 28,2001, defendant STANISLAS GREGORY MEYERHOFF
and unindicted co-conspirator WILLIAM C. RODGERS authorized and published a document
entitled "Setting Fire with Electrical Timers, an Earth Liberation Front Guide," in order to
expose to a widespread audience their methods of operation and the design of the "Cat's Cradle"
incendiary device so they would no longer be unique to the arsons committed by "the Family,"
thereby hindering detection by law enforcement.
21. On or about October 15,2001, at Litchfield, California, in the Eastern District of
California, defendants STANISLAS GREGORY MEYERHOFF, JOSEPH DIBEE, REBECCA
RUBIN, KEVIN TUBBS, CHELSEA DAWN GERLACH and DARREN TODD THURSTON,
unindicted co-conspirator WILLIAM C. RODGERS, and other persons known and unknown to
the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled, commanded,
induced and procured the malicious damaging and destroying, by means of fire and explosives,
of buildings and other real and personal property owned and possessed by the United States and
the Bureau of Land Management of the Department of the Interior, located at the Wild Horse
Facility, Litchfield, California.
2 1 a. On or about October 15,2001, defendants STANISLAS GREGORY
MEYERHOFF and persons known and unknown to the Grand Jury placed time-delayed
incendiary devices at and about the Litchfield Horse Facility
21b. On or about October 30,2001, certain defendants in the Litchfield Wild Horse
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Facility arson issued a communique attributing the fire to the Earth Liberation Front (ELF). The
communique was publicized by David Barbarash of the North American ALF Press Office.
22. On or about November 25,2005, unindicted co-conspirator WILLIAM C.
RODGERS attempted to recruit a person known to the Grand Jury to participate in future direct
actions and stated: ". . .I'll be really energized and ready to set up. . .activities in ways that
haven't been seen before."
23. On or about December 21,2005, defendants CHELSEA DAWN GERLACH and
DARREN TODD THURSTON possessed books and documents containing instructions on how
to engage in unlawful activities, including a book entitled "Advanced Anarchist Arsenal: Recipes
for Improvised Incendiaries and Explosives."
24. In order to conceal evidence and to hinder the investigation of the above-described
crimes, and to facilitate the flight and concealment of certain of the defendants, a number of
overt acts occurred, including but not limited to the following:
24a. Defendants CHELSEA DAWN GERLACH and DARREN TODD THURSTON
possessed and used false identification documents, including those found in their possession on
December 7,2005, and at their Portland residence on December 2 1,2005.
24b. On December 21,2005, defendants CHELSEA DAWN GERLACH and
DARREN TODD THURSTON possessed in their residence books and informational materials
with respect to manufacturing false identity documents.
24c. On December 21,2005, defendants CHELSEA DAWN GERLACH and
DARREN TODD THURSTON possessed in their residence large amounts of information on the
identities of other individuals, including many deceased persons.
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24d. On December 7,2005, defendant KEVIN TUBBS possessed in a locked safe false
identity documents.
24e. Sometime after the Fall of 2001, defendant JOSEPHINE SUNSHINE
OVERAKER left the United States and fled to Europe.
24f. In or about the Spring of 2005, defendant REBECCA RUBIN returned to Canada.
24g. On or about December 11,2005, defendant JOSEPH DIBEE left the United States
following contact by federal law enforcement agents
All of the above conduct violated Title 18, United States Code, Section 37 1.
COUNT 3
ATTEMPTED ARSON
On or about October 28, 1996, in Marion County, Oregon, in the District of Oregon,
defendant JOSEPHINE SUNSHINE OVERAKER and other persons known to the Grand Jury,
unlawfully and willfully caused and aided, abetted, counseled, commanded, induced, and
procured the attempt to damage or destroy, by means of fire and an explosive, a building and
other real and personal property owned and possessed by the United States and the United States
Forest Service of the Department of Agriculture, located at the Detroit Ranger Station on the
Willamette National Forest; all in violation of Title 18, United States Code, Sections 844(f) and
2.
/ / /
/ / I
/ / I
/ I /
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COUNT 4
ARSON
On or about October 28, 1996, in Marion County, Oregon, in the District of Oregon,
defendant JOSEPHINE SUNSHINE OVERAKER and other persons known to the Grand Jury,
unlawfully and willfully caused and aided, abetted, counseled, commanded, induced, and
procured the malicious damaging and destroying, by means of fire, of a vehicle and other real and
personal property owned and possessed by the United States and the United States Forest Service
of the Department of Agriculture, located at the Detroit Ranger Station on the Willamette
National Forest; all in violation of Title 18, United States Code, Sections 844(f) and 2.
COUNT 5
ARSON
On or about October 30, 1996, in Lane County, Oregon, in the District of Oregon,
defendants JOSEPHINE SUNSHINE OVERAKER and KEVIN TUBBS, and another person
known to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,
commanded, induced, and procured the malicious damaging and destroying, by means of fire and
an explosive, of a building and other real and personal property owned and possessed by the
United States and the United States Forest Service of the Department of Agriculture, located at
the Oakridge Ranger Station on the Willamette National Forest; all in violation of Title 18,
United States Code, Sections 844(f) and 2.
/I/
I//
/I/
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COUNT 6
ARSON
On or about July 21, 1997, at Redmond, Deschutes County, Oregon, in the District of
Oregon, defendants KEVIN TUBBS, JOSEPH DIBEE, and JONATHAN MARK
CHRISTOPHER PAUL, and other persons known to the Grand Jury, unlawfully and willfully
caused and aided, abetted, counseled, commanded, induced, and procured the malicious
damaging and destroying, by means of fire and an explosive, of a building and other real and
personal property used in interstate commerce and in activities affecting interstate commerce, at
Cave1 West, Inc., 1607 SE Railroad, Redmond, Oregon; all in violation of Title 18, United States
Code, Sections 844(i) and 2.
COUNT 7
ARSON
On or about November 30, 1997, in Hamey County, Oregon, in the District of Oregon,
defendants JOSEPHINE SUNSHINE OVERAKER, KEVIN TUBBS and REBECCA RUBIN,
unindicted co-conspirator WILLIAM C. RODGERS, and another person known to the Grand
Jury, unlawfully and willfully caused and aided, abetted, counseled, commanded, induced, and
procured the malicious damaging and destroying, by means of fire and an explosive, of buildings
and other real and personal property owned and possessed by the United States and the Bureau of
Land Management of the Department of the Interior, located at the Wild Horse and Burro
Facility, Bums, Hamey County, Oregon; all in violation of Title 18, United States Code, Sections
844(f) and 2.
/ / 1
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COUNT 8
ARSON
On or about December 22, 1998, at Medford, Jackson County, Oregon, in the District of
Oregon, defendants SARAH KENDALL HARVEY, KEVIN TUBBS, and REBECCA RUBIN,
and another person known to the Grand Jury, unlawfully and willfully caused and aided, abetted,
counseled, commanded, induced, and procured the attempt to damage or destroy, by means of
fire and an explosive, a building and other real and personal property used in interstate commerce
and used in activities affecting interstate commerce, namely, an office building and its contents at
U.S. Forest Industries, 261 1 Whittle Avenue, Medford, Jackson County, Oregon; all in violation
of Title 18, United States Code, Sections 844(i) and 2.
COUNT 9
ARSON
On or about December 27, 1998, at Medford, Jackson County, Oregon, in the District of
Oregon, defendant SARAH KENDALL HARVEY and another person known to the Grand Jury,
unlawfully and willfully caused and aided, abetted, counseled, commanded, induced, and
procured the malicious damaging and destroying, by means of fire and an explosive, of a building
and other real and personal property used in interstate commerce and used in activities affecting
interstate commerce, namely, an office building and its contents at U.S. Forest Industries, 261 1
Whittle Avenue, Medford, Jackson County, Oregon; all in violation of Title 18, United States
Code, Sections 844(i) and 2.
/ / I
/ / /
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COUNT 10
ARSON
On or about May 9, 1999, at Eugene, Lane County, Oregon, in the District of Oregon,
defendants JOSEPHINE SUNSHINE OVERAKER, KEVIN TUBBS, STANISLAS GREGORY
MEYERHOFF and CHELSEA DAWN GERLACH, and other persons known to the Grand Jury,
unlawfully and willfully caused and aided, abetted, counseled, commanded, induced, and
procured the malicious damaging and destroying, by means of fire and an explosive, of a building
and other real and personal property used in interstate commerce and in activities affecting
interstate commerce, at Childers Meat Company, 29476 Airport Road, Eugene, Oregon; all in
violation of Title 18, United States Code, Sections 844(i) and 2.
COUNT 11
ARSON
On or about December 25, 1999, at Monmouth, Polk County, Oregon, in the District of
Oregon, defendants JOSEPHINE SUNSHINE OVERAKER, STANISLAS GREGORY
MEYERHOFF and CHELSEA DAWN GERLACH, and another person known to the Grand
Jury, unlawfully and willfully caused and aided, abetted, counseled, commanded, induced, and
procured the malicious damaging and destroying, by means of fire and an explosive, of a building
and other real and personal property used in interstate commerce and in activities affecting
interstate commerce, at the Boise Cascade Office, 450 North Pacific Avenue, Monmouth, Polk
County, Oregon; all in violation of Title 18, United States Code, Sections 844(i) and 2.
/ / /
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COUNT 12
DESTRUCTION OF AN ENERGY FACILITY
On or about December 30, 1999, in Deschutes County, Oregon, in the District of Oregon,
defendants STANISLAS GREGORY MEYERHOFF, JOSEPHINE SUNSHINE OVERAKER,
CHELSEA DAWN GERLACH, and others both known and unknown to the Grand Jury,
knowingly and willfully damaged and attempted to damage the property of an energy facility of
the Untied States, namely, a Bonneville Power Administration tower, involved in the
transmission and distribution of electricity near the City of Bend, Oregon, in an amount
exceeding or which would have exceeded $100,000; all in violation of Title 18, United States
Code, Section l366(a).
COUNT 13
ARSON
On or about September 6,2000, at Eugene, Lane County, Oregon, in the District of
Oregon, defendants STANISLAS GREGORY MEYERHOFF, KEVIN TUBBS and CHELSEA
DAWN GERLACH unlawfully and willfully caused and aided, abetted, counseled, commanded,
induced, and procured the malicious damaging and destroying, by means of fire and an explosive,
of a building and other real and personal property used in interstate commerce and in activities
affecting interstate commerce, at the Eugene Police Department West University Public Safety
Station, 791 East 13th Avenue, Eugene, Lane County, Oregon; all in violation of Title 18, United
States Code, Sections 844(i) and 2.
I / /
I / /
Page 56 - INDICTMENT
COUNT 14
ARSON
On or about January 2,2001, at Glendale, Douglas County, in the District of Oregon,
defendants STANISLAS GREGORY MEYERHOFF, KEVIN TUBBS, DANIEL GERARD
McGOWAN and SUZANNE SAVOIE, unlawfully and willfully caused and aided, abetted,
counseled, commanded, induced, and procured the malicious damaging and destroying, by means
of fire and an explosive, of a building and other real and personal property used in interstate
commerce and used in activities affecting interstate commerce, namely, a building and its
contents located at Superior Lumber Company, 2695 Glendale Valley Road, Glendale, Douglas
County, Oregon; all in violation of Title 18, United States Code, Sections 844(i) and 2.
COUNT 15
USING AND CARRYING A DESTRUCTIVE DEVICE
IN RELATION TO A CRIME OF VIOLENCE
On or about January 2, 2001, at Glendale, Douglas County, in the District of Oregon,
defendants STANISLAS GREGORY MEYERHOFF and DANIEL GERARD McGOWAN, and
others known and unknown to the Grand Jury, unlawfully and knowingly used and carried one or
more destructive devices, namely, one or more incendiary bombs, during and in relation to a
crime of violence, namely, arson, in violation of Title 18, United States Code, Section 844(i), as
charged in Count 14 of this indictment, and possessed such destructive devices in furtherance of
such crime; all in violation of Title 18, United States Code, Sections 924(c)(l)(A)(i) & (B)(ii) &
(C) (i i) and 2.
I / /
Page 57 - INDICTMENT
COUNT 16
ARSON
On or about March 30, 2001, at Eugene, Lane County, in the District of Oregon,
defendants KEVIN TUBBS and STANISLAS GREGORY MEYERHOFF, and other persons
unknown to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,
commanded, induced, and procured the malicious damaging and destroying, by means of fire and
an explosive, of a vehicle used in interstate commerce and used in activities affecting interstate
commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number
3GNGK26U41 G209163, located at Romania Chevrolet Truck Center, 1425 Walnut Street,
Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, Sections 844(i)
and 2.
COUNT 17
ARSON
On or about March 30,2001, at Eugene, Lane County, in the District of Oregon,
defendants KEVIN TUBBS and STANISLAS GREGORY MEYERHOFF, and other persons
unknown to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,
commanded, induced, and procured the malicious damaging and destroying, by means of fire and
an explosive, of a vehicle used in interstate commerce and used in activities affecting interstate
commerce, namely, a 2001 Tahoe, bearing Vehicle Identification Number
1 GNEK13T7 lRl54866, located at Romania Chevrolet Truck Center, 1425 Walnut Street,
Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, Sections 844(i)
and 2.
Page 58 - INDICTMENT
COUNT 18
ARSON
On or about March 30,2001, at Eugene, Lane County, in the District of Oregon,
defendants KEVIN TUBBS and STANISLAS GREGORY MEYERHOFF, and other persons
unknown to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,
commanded, induced, and procured the malicious damaging and destroying, by means of fire and
an explosive, of a vehicle used in interstate commerce and used in activities affecting interstate
commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number
3GNGK26G8 1 G23SOS0, located at Romania Chevrolet Truck Center, 1425 Walnut Street,
Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, Sections 844(i)
and 2.
COUNT 19
ARSON
On or about March 30,2001, at Eugene, Lane County, in the District of Oregon,
defendants KEVIN TUBBS and STANISLAS GREGORY MEYERHOFF, and other persons
unknown to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,
commanded, induced, and procured the malicious damaging and destroying, by means of fire and
an explosive, of a vehicle used in interstate commerce and used in activities affecting interstate
commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number
3GNGK26G8 1 G2O3 103, located at Romania Chevrolet Truck Center, 1425 Walnut Street,
Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, Sections 844(i)
and 2.
Page 59 - INDICTMENT
COUNT 20
ARSON
On or about March 30,2001, at Eugene, Lane County, in the District of Oregon,
defendants KEVIN TUBBS and STANISLAS GREGORY MEYERHOFF, and other persons
unknown to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,
commanded, induced, and procured the malicious damaging and destroying, by means of fire and
an explosive, of a vehicle used in interstate commerce and used in activities affecting interstate
commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number
3GNFK16T3 1 Gl97472, located at Romania Chevrolet Truck Center, 1425 Walnut Street,
Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, Sections 844(i)
and 2.
COUNT 21
ARSON
On or about March 30, 2001, at Eugene, Lane County, in the District of Oregon,
defendants KEVIN TUBBS and STANISLAS GREGORY MEYERHOFF, and other persons
unknown to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,
commanded, induced, and procured the malicious damaging and destroying, by means of fire and
an explosive, of a vehicle used in interstate commerce and used in activities affecting interstate
commerce, namely, a 2001 Tahoe, bearing Vehicle Identification Number
1 GNEKl3TOl Jl8lO82, located at Romania Chevrolet Truck Center, 1425 Walnut Street,
Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, Sections 844(i)
and 2.
Page 60 - INDICTMENT
COUNT 22
ARSON
On or about March 30,2001, at Eugene, Lane County, in the District of Oregon,
defendants KEVIN TUBBS and STANISLAS GREGORY MEYERHOFF, and other persons
unknown to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,
commanded, induced, and procured the malicious damaging and destroying, by means of fire and
an explosive, of a vehicle used in interstate commerce and used in activities affecting interstate
commerce, namely, a 2001 Tahoe, bearing Vehicle Identification Number
lGNEKl3T4lRllOl62, located at Romania Chevrolet Truck Center, 1425 Walnut Street,
Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, Sections 844(i)
and 2.
COUNT 23
ARSON
On or about March 30,2001, at Eugene, Lane County, in the District of Oregon,
defendants KEVIN TUBBS and STANISLAS GREGORY MEYERHOFF, and other persons
unknown to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,
commanded, induced, and procured the malicious damaging and destroying, by means of fire and
an explosive, of a vehicle used in interstate commerce and used in activities affecting interstate
commerce, namely, a 200 1 Tahoe, bearing Vehicle Identification Number
1GNEK13T3 1 Jl50960, located at Romania Chevrolet Truck Center, 1425 Walnut Street,
Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, Sections 844(i)
and 2.
Page 61 - INDICTMENT
COUNT 24
ARSON
On or about March 30,2001, at Eugene, Lane County, in the District of Oregon,
defendants KEVIN TUBBS and STANISLAS GREGORY MEYERHOFF, and other persons
unknown to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,
commanded, induced, and procured the malicious damaging and destroying, by means of fire and
an explosive, of a vehicle used in interstate commerce and used in activities affecting interstate
commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number
3GNFK16T71 G228593, located at Romania Chevrolet Truck Center, 1425 Walnut Street,
Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, Sections 844(i)
and 2.
COUNT 25
ARSON
On or about March 30,2001, at Eugene, Lane County, in the District of Oregon,
defendants KEVIN TUBBS and STANISLAS GREGORY MEYERHOFF, and other persons
unknown to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,
commanded, induced, and procured the malicious damaging and destroymg, by means of fire and
an explosive, of a vehicle used in interstate commerce and used in activities affecting interstate
commerce, namely, a 2001 Tahoe, bearing Vehicle Identification Number
1GNEK13T5 lR148547, located at Romania Chevrolet Truck Center, 1425 Walnut Street,
Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, Sections 844(i)
and 2.
Page 62 - INDICTMENT
COUNT 26
ARSON
On or about March 30, 2001, at Eugene, Lane County, in the District of Oregon,
defendants KEVIN TUBBS and STANISLAS GREGORY MEYERHOFF, and other persons
unknown to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,
commanded, induced, and procured the malicious damaging and destroying, by means of fire and
an explosive, of a vehicle used in interstate commerce and used in activities affecting interstate
commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number
3GNFK16T71G226598, located at Romania Chevrolet Truck Center, 1425 Walnut Street,
Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, Sections 844(i)
and 2.
COUNT 27
ARSON
On or about March 30, 2001, at Eugene, Lane County, in the District of Oregon,
defendants KEVIN TUBBS and STANISLAS GREGORY MEYERHOFF, and other persons
unknown to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,
commanded, induced, and procured the malicious damaging and destroying, by means of fire and
an explosive, of a vehicle used in interstate commerce and used in activities affecting interstate
commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number
3GNFK16T7 1 G23Ol79, located at Romania Chevrolet Truck Center, 1425 Walnut Street,
Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, Sections 844(i)
and 2.
Page 63 - INDICTMENT
COUNT 28
ARSON
On or about March 30,2001, at Eugene, Lane County, in the District of Oregon,
defendants KEVIN TUBBS and STANISLAS GREGORY MEYERHOFF, and other persons
unknown to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,
commanded, induced, and procured the malicious damaging and destroying, by means of fire and
an explosive, of a vehicle used in interstate commerce and used in activities affecting interstate
commerce, namely, a 2001 Tahoe, bearing Vehicle Identification Number
1 GNEKl3T8 lRl69490, located at Romania Chevrolet Truck Center, 1425 Walnut Street,
Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, Sections 844(i)
and 2.
COUNT 29
ARSON
On or about March 30,2001, at Eugene, Lane County, in the District of Oregon,
defendants KEVIN TUBBS and STANISLAS GREGORY MEYERHOFF, and other persons
unknown to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,
commanded, induced, and procured the malicious damaging and destroying, by means of fire and
an explosive, of a vehicle used in interstate commerce and used in activities affecting interstate
commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number
3GNGK26G2 1 G201069, located at Romania Chevrolet Truck Center, 1425 Walnut Street,
Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, Sections 844(i)
and 2.
Page 64 - INDICTMENT
COUNT 30
ARSON
On or about March 30,2001, at Eugene, Lane County, in the District of Oregon,
defendants KEVIN TUBBS and STANISLAS GREGORY MEYERHOFF, and other persons
unknown to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,
commanded, induced, and procured the malicious damaging and destroying, by means of fire and
an explosive, of a vehicle used in interstate commerce and used in activities affecting interstate
commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number
3GNFK16TXl G206720, located at Romania Chevrolet Truck Center, 1425 Walnut Street,
Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, Sections 844(i)
and 2.
COUNT 31
ARSON
On or about March 30, 2001, at Eugene, Lane County, in the District of Oregon,
defendants KEVIN TUBBS and STANISLAS GREGORY MEYERHOFF, and other persons
unknown to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,
commanded, induced, and procured the malicious damaging and destroying, by means of fire and
an explosive, of a vehicle used in interstate commerce and used in activities affecting interstate
commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number
3GNFK16T9 1 G226585, located at Romania Chevrolet Truck Center, 1425 Walnut Street,
Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, Sections 844(i)
and 2.
Page 65 - INDICTMENT
COUNT 32
ARSON
On or about March 30,2001, at Eugene, Lane County, in the District of Oregon,
defendants KEVIN TUBBS and STANISLAS GREGORY MEYERHOFF, and others known
and unknown to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,
commanded, induced, and procured the malicious damaging and destroying, by means of fire and
an explosive, of a vehicle used in interstate commerce and used in activities affecting interstate
commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number
3GNFK16T61 G2298 16, located at Romania Chevrolet Truck Center, 1425 Walnut Street,
Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, Sections 844(i)
and 2.
COUNT 33
ARSON
On or about March 30,2001, at Eugene, Lane County, in the District of Oregon,
defendants KEVIN TUBBS and STANISLAS GREGORY MEYERHOFF, and other persons
unknown to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,
commanded, induced, and procured the malicious damaging and destroying, by means of fire and
an explosive, of a vehicle used in interstate commerce and used in activities affecting interstate
commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number
3GNGK26U2 1 Gl8OO66, located at Romania Chevrolet Tmck Center, 1425 Walnut Street,
Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, Sections 844(i)
and 2.
Page 66 - INDICTMENT
COUNT 34
ARSON
On or about March 30, 2001, at Eugene, Lane County, in the District of Oregon,
defendants KEVIN TUBBS and STANISLAS GREGORY MEYERHOFF, and others known
and unknown to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,
commanded, induced, and procured the malicious damaging and destroying, by means of fire and
an explosive, of a vehicle used in interstate commerce and used in activities affecting interstate
commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number
3GNGK26U8 1 GI8 1349, located at Romania Chevrolet Truck Center, 1425 Walnut Street,
Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, Sections 844(i)
and 2.
COUNT 35
ARSON
On or about March 30,2001, at Eugene, Lane County, in the District of Oregon,
defendants KEVIN TUBBS and STANISLAS GREGORY MEYERHOFF, and other persons
unknown to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,
commanded, induced, and procured the malicious damaging and destroying, by means of fire and
an explosive, of a vehicle used in interstate commerce and used in activities affecting interstate
commerce, namely, a 2001 Tahoe, bearing Vehicle Identification Number
lGNEK13T81R160806, located at Romania Chevrolet Truck Center, 1425 Walnut Street,
Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, Sections 844(i)
and 2.
Page 67 - INDICTMENT
COUNT 36
ARSON
On or about March 30,2001, at Eugene, Lane County, in the District of Oregon,
defendants KEVIN TUBBS and STANISLAS GREGORY MEYERHOFF, and other persons
unknown to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,
commanded, induced, and procured the malicious damaging and destroying, by means of fire and
an explosive, of a vehicle used in interstate commerce and used in activities affecting interstate
commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number
3GNFKl6TOlG155650, located at Romania Chevrolet Truck Center, 1425 Walnut Street,
Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, Sections 844(i)
and 2.
COUNT 37
ARSON
On or about March 30,2001, at Eugene, Lane County, in the District of Oregon,
defendants KEVIN TUBBS and STANISLAS GREGORY MEYERHOFF, and other persons
unknown to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,
commanded, induced, and procured the malicious damaging and destroying, by means of fire and
an explosive, of a vehicle used in interstate commerce and used in activities affecting interstate
commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number
3GNFK16TO 1 G206838, located at Romania Chevrolet Truck Center, 1425 Walnut Street,
Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, Sections 844(i)
and 2.
Page 68 - INDICTMENT
COUNT 38
ARSON
On or about March 30, 2001, at Eugene, Lane County, in the District of Oregon,
defendants KEVIN TUBBS and STANISLAS GREGORY MEYERHOFF, and other persons
unknown to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,
commanded, induced, and procured the malicious damaging and destroying, by means of fire and
an explosive, of a vehicle used in interstate commerce and used in activities affecting interstate
commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number
3GNFKl6T3 1 Gl95205, located at Romania Chevrolet Truck Center, 1425 Walnut Street,
Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, Sections 844(i)
and 2.
COUNT 39
ARSON
On or about March 30,2001, at Eugene, Lane County, in the District of Oregon,
defendants KEVIN TUBBS and STANISLAS GREGORY MEYERHOFF, and other persons
unknown to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,
commanded, induced, and procured the malicious damaging and destroying, by means of fire and
an explosive, of a vehicle used in interstate commerce and used in activities affecting interstate
commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number
3GNFK16TXlG225834, located at Romania Chevrolet Truck Center, 1425 Walnut Street,
Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, Sections 844(i)
and 2.
Page 69 - INDICTMENT
COUNT 40
ARSON
On or about March 30, 2001, at Eugene, Lane County, in the District of Oregon,
defendants KEVIN TUBBS and STANISLAS GREGORY MEYERHOFF, and other persons
unknown to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,
commanded, induced, and procured the malicious damaging and destroying, by means of fire and
an explosive, of a vehicle used in interstate commerce and used in activities affecting interstate
commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number
1 GNFKl6T2 1 J2426 12, located at Romania Chevrolet Truck Center, 1425 Walnut Street,
Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, Sections 844(i)
and 2.
COUNT 41
ARSON
On or about March 30,2001, at Eugene, Lane County, in the District of Oregon,
defendants KEVIN TUBBS and STANISLAS GREGORY MEYERHOFF, and other persons
unknown to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,
commanded, induced, and procured the malicious damaging and destroying, by means of fire and
an explosive, of a vehicle used in interstate commerce and used in activities affecting interstate
commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number
3GNGK26U8 lGl92612, located at Romania Chevrolet Truck Center, 1425 Walnut Street,
Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, Sections 844(i)
and 2.
Page 70 - INDICTMENT
COUNT 42
ARSON
On or about March 30,2001, at Eugene, Lane County, in the District of Oregon,
defendants KEVIN TUBBS and STANISLAS GREGORY MEYERHOFF, and other persons
unknown to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,
commanded, induced, and procured the malicious damaging and destroying, by means of fire and
an explosive, of a vehicle used in interstate commerce and used in activities affecting interstate
commerce, namely, a 2001 Tahoe, bearing Vehicle Identification Number
1 GNEK13T7 lRll6389, located at Romania Chevrolet Truck Center, 1425 Walnut Street,
Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, Sections 844(i)
and 2.
COUNT 43
ARSON
On or about March 30,2001, at Eugene, Lane County, in the District of Oregon,
defendants KEVIN TUBBS and STANISLAS GREGORY MEYERHOFF, and other persons
unknown to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,
commanded, induced, and procured the malicious damaging and destroying, by means of fire and
an explosive, of a vehicle used in interstate commerce and used in activities affecting interstate
commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number
3GNFK16T91G189098, located at Romania Chevrolet Truck Center, 1425 Walnut Street,
Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, Sections 844(i)
and 2.
Page 71 - INDICTMENT
COUNT 44
ARSON
On or about March 30,2001, at Eugene, Lane County, in the District of Oregon,
defendants KEVIN TUBBS and STANISLAS GREGORY MEYERHOFF, and other persons
unknown to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,
commanded, induced, and procured the malicious damaging and destroying, by means of fire and
an explosive, of a vehicle used in interstate commerce and used in activities affecting interstate
commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number
3GNFK16TOlG198403, located at Romania Chevrolet Truck Center, 1425 Walnut Street,
Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, Sections 844(i)
and 2.
COUNT 45
ARSON
On or about March 30,2001, at Eugene, Lane County, in the District of Oregon,
defendants KEVIN TUBBS and STANISLAS GREGORY MEYERHOFF, and other persons
unknown to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,
commanded, induced, and procured the malicious damaging and destroying, by means of fire and
an explosive, of a vehicle used in interstate commerce and used in activities affecting interstate
commerce, namely, a 2001 Tahoe, bearing Vehicle Identification Number
lGNEKl3TOl Jl83320, located at Romania Chevrolet Truck Center, 1425 Walnut Street,
Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, Sections 844(i)
and 2.
Page 72 - INDICTMENT
COUNT 46
ARSON
On or about March 30, 2001, at Eugene, Lane County, in the District of Oregon,
defendants KEVIN TUBBS and STANISLAS GREGORY MEYERHOFF, and other persons
unknown to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,
commanded, induced, and procured the malicious damaging and destroying, by means of fire and
an explosive, of a vehicle used in interstate commerce and used in activities affecting interstate
commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number
3GNFKl6T9 1 G2O7 194, located at Romania Chevrolet Truck Center, 1425 Walnut Street,
Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, Sections 844(i)
and 2.
COUNT 47
ARSON
On or about March 30,2001, at Eugene, Lane County, in the District of Oregon,
defendants KEVIN TUBBS and STANISLAS GREGORY MEYERHOFF, and other persons
unknown to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,
commanded, induced, and procured the malicious damaging and destroying, by means of fire and
an explosive, of a vehicle used in interstate commerce and used in activities affecting interstate
commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number
3GNFK16T8 1G193241, located at Romania Chevrolet Truck Center, 1425 Walnut Street,
Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, Sections 844(i)
and 2.
Page 73 - INDICTMENT
COUNT 48
ARSON
On or about March 30,2001, at Eugene, Lane County, in the District of Oregon,
defendants KEVIN TUBBS and STANISLAS GREGORY MEYERHOFF, and other persons
unknown to the Grand Jury, unlawhlly and willfully caused and aided, abetted, counseled,
commanded, induced, and procured the malicious damaging and destroying, by means of fire and
an explosive, of a vehicle used in interstate commerce and used in activities affecting interstate
commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number
3GNFK16TllG105629, located at Romania Chevrolet Truck Center, 1425 Walnut Street,
Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, Sections 844(i)
and 2.
COUNT 49
ARSON
On or about March 30,2001, at Eugene, Lane County, in the District of Oregon,
defendants KEVIN TUBBS and STANISLAS GREGORY MEYERHOFF, and other persons
unknown to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,
commanded, induced, and procured the malicious damaging and destroying, by means of fire and
an explosive, of a vehicle used in interstate commerce and used in activities affecting interstate
commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number
3GNGK26U81G179567, located at Romania Chevrolet Truck Center, 1425 Walnut Street,
Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, Sections 844(i)
and 2.
Page 74 - INDICTMENT
COUNT 50
ARSON
On or about March 30,2001, at Eugene, Lane County, in the District of Oregon,
defendants KEVIN TUBBS and STANISLAS GREGORY MEYERHOFF, and others known
and unknown to the Grand Jury, unlawfully and willfully caused and aided, abetted, counseled,
commanded, induced, and procured the malicious damaging and destroying, by means of fire and
an explosive, of a vehicle used in interstate commerce and used in activities affecting interstate
commerce, namely, a 2001 Suburban, bearing Vehicle Identification Number
3GNGK26G2 1 G2 15392, located at Romania Chevrolet Truck Center, 1425 Walnut Street,
Eugene, Lane County, Oregon; all in violation of Title 18, United States Code, Sections 844(i)
and 2.
COUNT 51
USING AND CARRYING A DESTRUCTIVE DEVICE
IN RELATION TO A CRIME OF VIOLENCE
On or about March 30,2001, at Eugene, Lane County, in the District of Oregon,
defendants KEVIN TUBBS and STANISLAS GREGORY MEYERHOFF, and other persons
unknown to the Grand Jury, unlawfully and knowingly used and carried one or more destructive
devices, namely, one or more incendiary bombs, during and in relation to a crime of violence,
namely, arson, in violation of Title 18, United States Code, Section 844(i), as charged in Counts
16-50 of this indictment, and possessed such destructive devices in furtherance of such crime; all
in violation of Title 18, United States Code, Sections 924(c)(l)(A)(i) & (B)(ii) & (C)(ii) and 2.
/ / /
Page 75 - INDICTMENT
COUNT 52
ATTEMPTED ARSON
On or about May 21, 2001, at Clatskanie, Columbia County, in the District of Oregon,
defendants STANISLAS GREGORY MEYERHOFF, KEVIN TUBBS, DANIEL GERARD
McGOWAN and CHELSEA DAWN GERLACH, and other persons known and unknown to the
Grand Jury, unlawfully and willfully caused and aided, abetted, counseled, commanded, induced,
and procured the attempt to damage or destroy, by means of fire and an explosive, a building and
other real and personal property used in interstate commerce and used in activities affecting
interstate commerce, namely, the main office building and its contents located at Jefferson Poplar
Farm, 791 14 Collins Road, Clatskanie, Columbia County, Oregon; all in violation of Title 18,
United States Code, Sections 844(i) and 2.
COUNT 53
USING AND CARRYING A DESTRUCTIVE DEVICE
IN RELATION TO A CRIME OF VIOLENCE
On or about May 21,2001, at Clatskanie, Columbia County, in the District of Oregon,
defendants STANISLAS GREGORY MEYERHOFF, KEVIN TUBBS, DANIEL GERARD
McGOWAN and CHELSEA DAWN GERLACH, and other persons known and unknown to the
Grand Jury, unlawhlly and knowingly used and carried one or more destructive devices, namely,
one or more incendiary bombs, during and in relation to a crime of violence, namely, attempt to
commit arson, in violation of Title 18, United States Code, Section 844(i), as charged in Count
52 of this indictment, and possessed such destructive devices in furtherance of such crime; all in
violation of Title 18, United States Code, Sections 924(c)(l)(A)(i) & (B)(ii) & (C)(ii) and 2.
Page 76 - INDICTMENT
COUNT 54
ARSON
On or about May 21,2001, at Clatskanie, Columbia County, in the District of Oregon,
defendants STANISLAS GREGORY MEYERHOFF, KEVIN TUBBS, DANIEL GERARD
McGOWAN and CHELSEA DAWN GERLACH, and other persons known and unknown to the
Grand Jury, unlawfully and willfully caused and aided, abetted, counseled, commanded, induced,
and procured the malicious damaging and destroying, by means of fire and an explosive, of a
building and other real and personal property used in interstate commerce and used in activities
affecting interstate commerce, namely, a vehicle shop and its contents located at Jefferson Poplar
Farm, 791 14 Collins Road, Clatskanie, Columbia County, Oregon; all in violation of Title 18,
United States Code, Sections 844(i) and 2.
COUNT 55
ARSON
On or about May 21,2001, at Clatskanie, Columbia County, in the District of Oregon,
defendants STANISLAS GREGORY MEYERHOFF, KEVIN TUBBS, DANIEL GERARD
McGOWAN and CHELSEA DAWN GERLACH, and other persons known and unknown to the
Grand Jury, unlawfully and willfully caused and aided, abetted, counseled, commanded, induced,
and procured the malicious damaging and destroying, by means of fire and an explosive, of a
building and other real and personal property used in interstate commerce and used in activities
affecting interstate commerce, namely, a shop and office building and its contents located at
Jefferson Poplar Farm, 791 14 Collins Road, Clatskanie, Columbia County, Oregon; all in
violation of Title 18, United States Code, Sections 844(i) and 2.
Page 77 - INDICTMENT
COUNT 56
ARSON
On or about May 21, 2001, at Clatskanie, Columbia County, in the District of Oregon,
defendants STANISLAS GREGORY MEYERHOFF, KEVIN TUBBS, DANIEL GERARD
McGOWAN and CHELSEA DAWN GERLACH, and other persons known and unknown to the
Grand Jury, unlawfully and willfully caused and aided, abetted, counseled, commanded, induced,
and procured the malicious damaging and destroying, by means of fire and an explosive, of a
vehicle used in interstate commerce and used in activities affecting interstate commerce, namely,
a 1997 Ford truck bearing Oregon license number VHQ 660, located at Jefferson Poplar Farm,
791 14 Collins Road, Clatskanie, Columbia County, Oregon; all in violation of Title 18, United
States Code, Sections 844(i) and 2.
COUNT 57
ARSON
On or about May 21, 2001, at Clatskanie, Columbia County, in the District of Oregon,
defendants STANISLAS GREGORY MEYERHOFF, KEVIN TUBBS, DANIEL GERARD
McGOWAN and CHELSEA DAWN GERLACH, and other persons known and unknown to the
Grand Jury, unlawfully and willfully caused and aided, abetted, counseled, commanded, induced,
and procured the malicious damaging and destroying, by means of fire and an explosive, of a
vehicle used in interstate commerce and used in activities affecting interstate commerce, namely,
a 1984 Ford truck bearing Oregon license number CXR 901, located at Jefferson Poplar Farm,
791 14 Collins Road, Clatskanie, Columbia County, Oregon; all in violation of Title 18, United
States Code, Sections 844(i) and 2.
Page 78 - INDICTMENT
COUNT 58
ARSON
On or about May 21, 2001, at Clatskanie, Columbia County, in the District of Oregon,
defendants STANISLAS GREGORY MEYERHOFF, KEVIN TUBBS, DANIEL GERARD
McGOWAN and CHELSEA DAWN GERLACH, and other persons known and unknown to the
Grand Jury, unlawfully and willfully caused and aided, abetted, counseled, commanded, induced,
and procured the malicious damaging and destroying, by means of fire and an explosive, of a
vehicle used in interstate commerce and used in activities affecting interstate commerce, namely,
a 1997 Ford truck bearing Oregon license number VHQ 661, located at Jefferson 'Poplar Farm,
791 14 Collins Road, Clatskanie, Columbia County, Oregon; all in violation of Title 18, United
States Code, Sections 844(i) and 2.
COUNT 59
ARSON
On or about May 21,2001, at Clatskanie, Columbia County, in the District of Oregon,
defendants STANISLAS GREGORY MEYERHOFF, KEVIN TUBBS, DANIEL GERARD
McGOWAN and CHELSEA DAWN GERLACH, and other persons known and unknown to the
Grand Jury, unlawfully and willfully caused and aided, abetted, counseled, commanded, induced,
and procured the malicious damaging and destroying, by means of fire and an explosive, of a
vehicle used in interstate commerce and used in activities affecting interstate commerce, namely,
a 1997 Ford truck bearing Oregon license number VNS 404, located at Jefferson Poplar Farm,
791 14 Collins Road, Clatskanie, Columbia County, Oregon; all in violation of Title 18, United
States Code, Sections 844(i) and 2.
Page 79 - INDICTMENT
COUNT 60
ARSON
On or about May 21, 2001, at Clatskanie, Columbia County, in the District of Oregon,
defendants STANISLAS GREGORY MEYERHOFF, KEVIN TUBBS, DANIEL GERARD
McGOWAN and CHELSEA DAWN GERLACH, and other persons known and unknown to the
Grand Jury, unlawfully and willfully caused and aided, abetted, counseled, commanded, induced,
and procured the malicious damaging and destroying, by means of fire and an explosive, of a
vehicle used in interstate commerce and used in activities affecting interstate commerce, namely,
a 1996 Ford truck bearing Oregon license number UMZ 923, located at Jefferson Poplar Farm,
791 14 Collins Road, Clatskanie, Columbia County, Oregon; all in violation of Title 18, United
States Code, Sections 844(i) and 2.
COUNT 61
ARSON
On or about May 21, 2001, at Clatskanie, Columbia County, in the District of Oregon,
defendants STANISLAS GREGORY MEYERHOFF, KEVIN TUBBS, DANIEL GERARD
McGOWAN and CHELSEA DAWN GERLACH, and other persons known and unknown to the
Grand Jury, unlawfully and willfully caused and aided, abetted, counseled, commanded, induced,
and procured the malicious damaging and destroying, by means of fire and an explosive, of a
vehicle used in interstate commerce and used in activities affecting interstate commerce, namely,
a 1990 Ford truck bearing Oregon license number 283 ACE, located at Jefferson Poplar Farm,
791 14 Collins Road, Clatskanie, Columbia County, Oregon; all in violation of Title 18, United
States Code, Sections 844(i) and 2.
Page 80 - INDICTMENT
COUNT 62
ARSON
On or about May 2 1, 2001, at Clatskanie, Columbia County, in the District of Oregon,
defendants STANISLAS GREGORY MEYERHOFF, KEVIN TUBBS, DANIEL GERARD
McGOWAN and CHELSEA DAWN GERLACH, and other persons known and unknown to the
Grand Jury, unlawfully and willfully caused and aided, abetted, counseled, commanded, induced,
and procured the malicious damaging and destroying, by means of fire and an explosive, of a
vehicle used in interstate commerce and used in activities affecting interstate commerce, namely,
a 1990 Ford truck bearing Oregon license number 282 ACE, located at Jefferson Poplar Farm,
791 14 Collins Road, Clatskanie, Columbia County, Oregon; all in violation of Title 18, United
States Code, Sections 844(i) and 2.
COUNT 63
ARSON
On or about May 21,2001, at Clatskanie, Columbia County, in the District of Oregon,
defendants STANISLAS GREGORY MEYERHOFF, KEVIN TUBBS, DANIEL GERARD
McGOWAN and CHELSEA DAWN GERLACH, and other persons known and unknown to the
Grand Jury, unlawfully and willfully caused and aided, abetted, counseled, commanded, induced,
and procured the malicious damaging and destroying, by means of fire and an explosive, of a
vehicle used in interstate commerce and used in activities affecting interstate commerce, namely,
a 1990 Ford truck bearing Oregon license number 361 ACC, located at Jefferson Poplar Farm,
791 14 Collins Road, Clatskanie, Columbia County, Oregon; all in violation of Title 18, United
States Code, Sections 844(i) and 2.
Page 81 - INDICTMENT
COUNT 64
ARSON
On or about May 21,2001, at Clatskanie, Columbia County, in the District of Oregon,
defendants STANISLAS GREGORY MEYERHOFF, KEVIN TUBBS, DANIEL GERARD
McGOWAN, and CHELSEA DAWN GERLACH, and other persons known and unknown to the
Grand Jury, unlawfully and willfully caused and aided, abetted, counseled, commanded, induced,
and procured the malicious damaging and destroying, by means of fire and an explosive, of a
vehicle used in interstate commerce and used in activities affecting interstate commerce, namely,
a 1981 GMC truck bearing Oregon license number NA41574, located at Jefferson Poplar Farm,
791 14 Collins Road, Clatskanie, Columbia County, Oregon; all in violation of Title 18, United
States Code, Sections 844(i) and 2.
COUNT 65
ARSON
On or about May 21, 2001, at Clatskanie, Columbia County, in the District of Oregon,
defendants STANISLAS GREGORY MEYERHOFF, KEVIN TUBBS, DANIEL GERARD
McGOWAN and CHELSEA DAWN GERLACH, and other persons known and unknown to the
Grand Jury, unlawfully and willfully caused and aided, abetted, counseled, commanded, induced,
and procured the malicious damaging and destroying, by means of iire and an explosive, of a
vehicle used in interstate commerce and used in activities affecting interstate commerce, namely,
a 1989 Ford truck bearing Oregon license number PWV 249, at Jefferson Poplar Farm, 791 14
Collins Road, Clatskanie, Columbia County, Oregon; all in violation of Title 18, United States
Code, Sections 844(i) and 2.
Page 82 - INDICTMENT
@ Dated this /? day of January 2006.
A TWE BILL. - -
/ s / Grand Jury Foreperson
OFHCLATING FOREPERSON
Presented by:
KARIN J. IMMERGUT
United States Attorney
District of Oregon
s&$&kjr Assistant United S tes Attorney
MA k' La&
KIRK A. ENGDA , OSB #8 12 15
Assistant United States Attorney
STEBGEN F. PEIFER, (bS$#74252
Assistant United state(Morney
Page 83 - INDICTMENT