o

AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT I, __ being duly sworn, state as follows:

INTRODUCTION

1. I am a Special Agent (SA) with the Federal Bureau of Investigation (FBI) and

have been so employed since January 2008. I am currently assigned to the Jacksonville, Florida Division of the FBI where I conduct a variety of investigations in the area of counterterrorism. In the performance of my duties, I have investigated and assisted in the investigation of matters involving violations of federal law related to domestic terrorism, international terrorism, weapons of mass destruction, and bombing matters. I have been involved in searches pertaining to the possession, purchase, manufacture, and/or distribution of weapons of mass destruction and explosive materials through the execution of search warrants. I have conferred with colleagues who have received specialized training from the FBI in investigating crimes related to bombing matters.

2. I have investigated and assisted in the investigation of criminal matters

involving damage to religious property and obstruction of persons in the free exercise of religious beliefs in violation of 18 U.S.C. 247 and the possession and transfer of destructive devices, that include incendiary bombs as defined in 26 U.S.C. 5845(f), and as such are subject to the provisions of the National Firearms Act (NFA). The manufacture, possession and transfer of a destructive device not registered in the National Firearms Registration and Transfer Record is a violation of 26 U.S.C. 5861 (d),(f) and 5871. I have investigated and assisted in the investigation of criminal matters involving the unlawful flight by individuals to avoid prosecution in violation of 18 U.S.C. 1073.

3. The statements contained in this affidavit are based in large part on my

personal knowledge as well as on information provided to me by other law enfor-cement officers, including Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF)_ SA _ is currently employed as a Special Agent with the ATF, Jacksonville, Florida, and has been employed since March 1989. During this tenure, SA I • has been trained in the investigative techniques and enforcement offederal explosives laws and has investigated more than 100 bombing incidents. This affidavit is submitted in support of a Criminal Complaint charging Sandlin Matthews Smith with knowingly violating 18 U.S.C. 247, 26 U.S.C. 5861 (d),(f), 5845(a),(f) and 5871, and 1BU.S.C. 1073.

STATUTORY AUTHORITY

4. This investigation concerns alleged violations of 18 U.S.C. 247, 26 U.S.C.

5861 (d),(f), 5845(a),(f) and 5871, and 18' U.S.C. 1073, relating to damage to religious property, obstruction of persons in the free exercise of religious beliefs, possession and transfer of a destructive device, manufacture, possession, transfer of an unregistered firearm, and flight to avoid prosecution. Based upon my training and experience, I know the following:

a. 18 U.S.C. 247 in pertinent part prohibits a person from intentionally

defacing, darnaqinq, or destroying any religious real property, because of. the religious character of that property, or attempts to do so or intentionally obstructs, by force or threat of force, any person in the enjoyment of that person's free exercise of religious beliefs, or attempts to do so.

2

b. 26 U.S.C. 5861 (d) in pertinent part prohibits a person-from receiving or

possessing a firearm which is not registered to him in the National Firearms Registration

and Transfer Record. 26 U.S.C. 5861 (f) in pertinent part prohibits a person from making a

firearm in violation of the provisions of 26 U.S.C. 5801.

c. 18 U.S.C. 1073 in pertinent part prohibits a person from moving or

traveling in interstate or foreign commerce with intent to avoid prosecution, or custody or

confinement after conviction, under the laws of the place from which he flees, for a crime,

or an attempt to commit a crime, punishable by death orwhich is a felony under the laws of

the place from which a fugitive flees.

d. Based on your affiant's and SA _s training and experience,

it is common for individuals who are manufacturing unregistered destructive devices to

maintain materials, to include, but not limited to galvanized steel pipe, end caps, duct tape,

gasoline containers, explosive powders, and precursor chemicals used in the manufacture

of homemade explosive powders. These individuals may also maintain records and

receipts of these materials they acquired for the use of manufacturing of these items. Your

affiant also knows that it is common for these individuals to maintain certain tools, to

include, but not limited to drills, drill bits, and clamping devices as part of the manufacturing

process. Your affiant also knows that it is common for these individuals to maintain these

items in their premises.

BACKGROUND OF INVESTIGATION AND FACTS ESTABLISHING PROBABLE CAUSE

5. I make this affidavit in support of a Criminal Complaint charging Sandlin

Matthews Smith with damaging a religious property at the Islamic Center of Northeast

Florida (ICNEF), obstruction of persons in the free exercise of religious beliefs at the

3

ICNEF, possession and transfer of a destructive device, the possession of an unregistered firearm, and unlawful fright to avoid prosecution in violation of 18 U.S.C. 247, 26 U.S.C. 5861 (d),(f), 5845(a),(f) and 5871, and 18 U.S.C. 1073.

6. On the evening of May 10, 2010, members of the FBI Jacksonville Field

Office to include your affiant responded to the report of an explosion at the ICNEF located in Jacksonville, Duval County, Florida. During interviews conducted that night and follow up interviews in the subsequent days your affiant determined that on May 10, 2010, at approximately 9:36 pm, witnesses attending prayer atthe ICNEF located at 2333 st. Johns Bluff Road South, Jacksonville, FL 32246, heard a loud explosion come from the rear of the building. One member of the ICNEF responded to the explosion and saw a fire located at the brick wall near the rear of the ICNEF. This member extinguished the fire and called the Jacksonville Fire and Rescue Department (JFRD). JFRD responded and notified the State of Florida Fire Marshall's Office (SF-M). SFM then .notified the FBI Joint Terrorism Task Force (JTTF) and the Church Arson Task Force to include the FBI, ATF, and the Jacksonville Sheriff's Office (JSO). Evidence from the scene was collected by SA and later provided to the ATF Atlanta Forensic Science Laboratory for examination.

7. The FBI assigned your affiant as the co-Case Agent along with JSO Detective

_. Follow up investigation has been conducted as a joint state and federal investigation under the auspices of the FBI JTTF. Your affiant knows that in addition to the above referenced federal violations, the subject's conduct is a violation of Florida Statute 790.161 (1), Making, possessing, throwing, projecting) placing, or discharging any destructive device or attempt to do so. This crime is a third degree felony under the laws of the state of Florida.

4

8. Review of footage from the ICNEF video surveillance system by your affiant

revealed an image of what appears to be a white male holding a cylindrical object in his hand at a location near the rear of the ICNEF, minutes before the detonation of the destructive device. The unidentified male stands and moves with a distinctive posture. This posture has the characteristics of rounded, broad shoulders, with a forward-leaning head and a noticeable gait including distinctive hand and arm movement. The unidentified male is wearing pants, a light colored shirt and a baseball-type hat. The unidentified male is visible on the surveillance video from 9:25:30 pm to 9:25:34 pm, according to the video time stamp on the ICNEF security system. He can be observed on the video stepping into view around a portable buildinq near the rear of the ICNEF and subsequently out of view stepping back around the portable building. A flash of light, indicating the detonation of the destructive device, is visible at 9:36:26 pm, according to the video time stamp .. The white male does not appear in this portion of the footage based on my review of the video surveillance system. This flash of light is followed by a plume of white smoke originating from a location near the rear of the ICNEF.

9. Review by your affiant of a video surveillance system at Turf Tech, Inc., a business located on the property directly south of the ICNEF, revealed multiple images of a black extended-cab passenger pick-up truck with a silver or chrome tool box located in the bed of the truck directly behind the cab durinq the time surrounding the detonation of the destructive device at the ICNEF. The truck entered the Turf Tech, Inc. property off of st. Johns Bluff Road South at 9:16:58 pm. At 9:18:02 pm, the truck parked in a location in front of Vanguard Electric Co-Op, a business that leases space from the owner of Turf Tech, Inc. Investigation by your affiant revealed that Vanguard Electric Co-Op closed just before 5: 00 pm on May 10, 2010, and no employees visited the business after this time. At

9:28:51 pm, the truck was observed on the video surveillance system backing out of the parking space and exiting the property onto St. Johns Bluff Road.

10. While conducting interviews of members of the ICNEF concerning the above referenced incident, your affiant learned of an earlier incident that occurred at the ICNEF approximately a month prior. According to members of the ICNEF that were present at nightly prayer on April 4, 2010, a white male caused a disturbance at nightly prayers .

. Witnesses indicated that a white male driving a white four-door sedan entered the prayer room.at the ICNEF on April 4, 2010 and began yelling. According to these witnesses, the man yelled something to the effect of "stop this blasempy" and "I'm tired of hearing this II" and then exited the prayer room and the ICNEF. According to witnesses, the individual also yelled something to the effect of "I'll be back" before exiting the parking lot of the ICNEF. Witnesses found an empty beer can that they believed fell out of the vehicle and indicated that the individual might have been intoxicated .. The witnesses did not retain the beer can.

11. Your affiant reviewed footage from the video surveillance system at the ICNEF from April 4, 2010. The footage depicts an image of a white four-door sedan entering the property of the rCNEF at 9:08:26 pm on April 4, 2010. A white male wearing a dark colored T-shirt, long shorts, dark slipper-type shoes, and a dark-colored hat then approaches the front door of the ICNEF at 9:08:50 pm and walks down the hallway of the ICNEF toward the prayer room at 9:09:30 pm. The unidentified male's T-shirt appears to have a logo on the front of the T-shirt similar in appearance to an "Army of One" logo. Your affiant knows that "Army of One" is a recruiting logo for the United States Army. At 9: 1 0:43 pm the white sedan is observed exiting the property of the ICNEF. Inthe footage the unidentified male stands and moves with a distinctive posture. This posture has the characteristics of

6

rounded, broad shoulders, with a forward-leaninq head and a noticeable gait including distinctive hand and arm movement.

12. Review of the footage from both April 4, 2010 and May 10,2010 by your affiant indicates that the individual on both dates has a similar posture and gait. This posture has the characteristics of rounded, broad shoulders, with a forward-leaning head and a noticeable gait including distinctive hand and arm movement. Because of the similarities in posture and the determination that both individual are the same height, you affiant believed that the individuals were in fact the same person.

13. On or about June 28,2010, your affiant met with SA_and received a written communication dated June 24, 2010, which I have read and which states in substance that laboratory examinations of evidence recovered at the scene of the pipe bombing at the ICNEF on May 10,2010 were conducted by the ATF. Analysis of evidence collected and examined from the bomb scene identified a mixture of double base (flattened ball and disc shaped) and single base (perforated-rod shaped) smokeless powders in sweepings collected from the concrete slab' where the device was detonated. The rod shaped powder was also found in pieces of duct tape and a metal tube recovered from the

scene.

14. Metal fragments recovered from the scene were identified as having

originated from a thin wall steel pipe or tube measuring at least 30 inches in length by 1 inch in diameter. This steel pipe was scored or serrated approximately every 1 inch of length around the pipe. The pipe was painted with a thick coat of a black paint. One end of the pipe has remnants of a gray duct tape adhering to the outer surface. A large brass plumb bob with the sharp end cut and broken off was also recovered from the scene. Your affiant knows that a plumb bob is an instrument used in various construction methods

7

including masonry and carpentry used for leveling purposes. The portion of the plumb bob

was totally wrapped with gray duct tape, except for the cut/broken end of the plumb bob

which was exposed. Residue of a paraffin-type wax was identified on a fragment of the

pipe. Melted remains of one red plastic gasoline container were recovered. The

manufacture was identified as "BLITZ U.S.A. INC., MIAMI, OK" and the size identified as

an apparent 2 gallon-8 ounce size. The remains of the plastic gasoline container as well

as a soil sample from the scene were found to contain gasoline.

15. On November 11, 2010, a federal search warrant issued by United States

Magistrate Judge ••••••• was conducted at the residence of

admitted to

creating the disturbance at the ICNEF on April 4,2010, but denied any involvement with the pipe bombing at the ICNEF on May 10, 2010. The search produced no evidence

. .

connecting ,.to the pipe bombing at the ICNEF on -May 10, 2010. _

consented to a polygraph examination and showed no signs of deception with regards to

L - ". I

'. • !"

""""""!;:. .--=-- ~ ~ - -_ - - _,__

his connection to the pipe bombing incident on May 10, 2010.

16. On April 28, 2011, FBI SA _ received a telephone call from _, Your affiant spoke with SA ~n April 28, 2011, whom explained to your affiant the following information. lilt reported that he knows the person responsible

.. ~

for the mosque bombing in Jacksonville, FL According to _Sandlin Smith (Sandlin) was in Georgia on April 22, 2011. Sandlin was there to visit _is .current wife. Sandlin became violent with CfII!JIIJbrandished a handgun, and pointed it at_ During the altercation, Sandlin told ..... hat he bombed the

~-

mosque in Jacksonville and that he was wanted by the "feds." Sandlin also said that he did not like Muslims. "_"told the duty agent thatll'I'1' viewed a video of the suspect of the

8

pipe bombing at the ICNEF on the FBI's website and identified the individual as Sandlin . • stated he learned this information from his wife and that he was not present when the alternation occurred between. and Sandlin.

17. A review of Florida Driver and Vehicle Information Database (DAVID) on April

28, 2011 by your affiant indicates that Sandlin is the registered owner of a black 2004

Toyota with a Vehicle Identification Number (VIN) of 5~BRT34194S442130. A review by your affiant of an informational booklet provided by a Toyota dealer, indicated this VIN describes a SR5 Access Cab, 4.7 Liter V8 Toyota Tundra. This type of vehicle matches

the description of the suspect vehicle identified in the surveillance video from May 10,

2010.

18. On April 29, 2011, SA_'" Your affiant spoke with SA •••

was interviewed via telephone by FBI

on April 29, 2011, whom explained

to your affiant the following information. During the telephone interview .stated in substance that after the incident involving Sandlin threatening -'i_spoke with Sandlin's father,_, During this conversation~stated in SUbstance that he previously knew that Sandlin had bombed a mosque. "stated that Sandlin has an

unlicensed, fully-automatic AK-47 assault rifle. _'statedthat he was going to go see

Sandlin, throw Sandlin's weapons in the river, and get Sandlin "committed II to s~me sort of mental institution because_'is concerned that Sandlin will have a violent encounter with .

19. On April 29, 2011, ._._.. was interviewed via telephone by

SA' .. Your affiant spoke with SA O'Donovan on April 29, 2011, whom explained

to your affiant the following information. During the interview

tated in substance

that. used to live with Sandlin Smith's brother,

9

daughter named.

stays in touch with the Smith family. Recently, Sandlin told

that he wanted to visit her because he was going to be travelling to Georgia. On

April 23, 2011, Sandlin arrived at~residence in husband, _ was out of town at the time. One .of

._'

friends,

'_'was at her residence when Sandlin arrived. _ left shortly after Sandlin arrived. After initially talking, Sandlin and _went upstairs to play pool. At this time, Sandlin produced a handgun and asked~to load the handgun ... said she could not load the handgun. At this time, Sandlin grabbed _. and pointed the handgun at her head. After pleading with Sandlin to let her gO_ told Sandlin that she had to use the bathroom. Sandlin then let _ go and she went into her bathroom.

She called

from the bathroom and asked him to come to her residence to help her.

_Jh~n~fft the bathroom and went di'C!nst~i~~ith Sandlin. Sandlin continued to point the gun at IF. and told her that the feds were after him because he had bombed a mosque. __ arrived shortly thereafter. Sandlin threatened~with the handgun and told ~ to tum around and get on his knees. ~ refused and told Sandlin that

if he was going to shoot him, Sandlin would have to shoot him in the face. Sandlin then sat down on a couch and put the handgun down. "'grabbed the handgun and unloaded it. Sandlin then started to cry and apologized for his actions. Sandlin said again that he was wanted by the feds and that he had bombed a mosque. ~ and _ told Sandlin to leave and he did. ~ spoke with her nineteen year-old daughter,.Sr about this incident within twenty-four hours of the incident occurring. ~ told..,..,that

sh,r~c~II~,~t one time when she was riding in a car with Sandlin, they passed by a mosque in Jacksonville. Sandlin told_that he hates those people. last spoke

10

with Sandlin on the telephone on or about Wednesday, April.27, 2011.

. poke with

Sandlinon Sandlin's cell phone with number 904-217-2070.

20. On April 29, 2011

was interviewed via telephone by

FBI SA

Your affiant spoke with SA _ on April 29, 2011, whom

explained to your affiant the following information. During the interview'_stated in

substance that he went to visit

at approximately 2:30 pm on

Saturday, April 23, 2011. At approximately 3:30 pm,.and_'were sitting outside on .... patio when Sandlin "Sandi" Smith arrived. Sandlin is .-daughter's uncle. _does not specifically recall the exact kind of vehicle Sandlin was driving, but believes it was a dark-colored full-size Chevy pick-up truck. ~introduced _·to Sandlin before _Ieft_.house, _received a telephone call from'_' approximately .twenty minutes after he left her house._ told. to "come get me," • asked _ if she was alright and •• replied "just come get me," ,entered--.house and saw Sandlin s,ltting on a couch and_' sitting in a chair. Sandlin asked why_ was there. _ replied that -.had invited him and he was going to stay, Sandlin told _that he and ~ere having a discussion and that he needed to leave .•• again told _dlin that he was an invited guest and that he was going to stay. _then noticed that Sandlin had a gun in his lap. Sandlin told ",that he (Sandlin) "was the bad guy _was talking about." As Sandlin said this, he pointed his gun ate. and called him "police." Sandlin was convinced thatlllltwas a "cop" and was at ... hou~e to arrest him (Sandlin). Sandlin then stood up, pushed -.to the ground and forced_into the kitchen. Sandlin then told ..,.to turn around and

get on his knees. _refused to turn around and get on his knees.

d Sandlin

that if Sandlin was going to shoot him, Sandlin would have to shoot him_ in the face.

11

_feared for his life at this time. Sandlin then said something to the effect of "I give up." Sandlin turned around and walked out of the kitchen. Sandlin put down his gun and started to look through his luggage .• picked-up Sandlin's gun and unloaded it. _ noticed '\":Va actditrQ~~cljps" in Sandlin's bag and told ~l1dliqo give him the "clips" .•. received these "clips" from Sandlin, unloaded them, and returned them to Sandlin along with the gun. _ believes the gun was a .40 caliber Taurus pistol. Sandlin then began talking about how he had blown up a mosque and that the feds were looking for him. Sandlin began to cry and then left .• said that after talking to _ after the incident, she told him that she called __ and not the police because __ number was the first to come to her mind.

21. On April 3D, 2011, was interviewed by your

affiant and JSO Detective _ During the interview, ~ 'stated in substance that

she has been married to Sandlin "Sandy" Smith for twenty-two years. and Sandlin

. .

I , '.

, _ .... -f-- ~. __ ,. I I

have a sixteen year-old son named

In approximately November

2009, Sandlin fell out of a tree and broke both of his legs. Sandlin was climbing the tree for

fun. Sandlin likes to do things that give him an adrenaline rush. Sandlin began taking pain

medication after he broke his legs and has recently been visiting a pain clinic in Jacksonville for his pain medication. s1 [[ : knows that Sandy takes methadone and

numerous other medications for his pain. Sandlin's behavior began to become more

erratic, after he began taking the pain medications. Forexample, Sandlin would telC S.

that he no longer wants to associate with people that have been long-time friends of and Sandlin. -"hought it was odd that Sandlin would end friendships with no

apparent reason. recall what the argument concerned. ~old Sandlin that he needed to leave the

12

house and Sandlin moved out. •• _after the break-up, Sandlin showed up-at her house whileA4ALwas away and moved his belongings out of the house. Sandy left some things in the garage. ,.. threw some of the items away. Sandy moved into a house on Race Track Road. Sandy knew the owner of the property on Race Track Road because he (Sandy) worked with the owner's son.

_ is not sure exactly when he moved into the house. Sandy works as a subcontractor for AT&T. Sandy's current employer is Progressive. Sandy has worked in this industry throughout the duration of their marriage. Sandy progressed from installing underground utilities to inspecting this type of installation. Sandy hunts and reloads his own ammunition. Sandy keeps supplies of gun powder in order to reload his ammunition. Sandy usually worked in their garage while Sandy and _ were living together. For example, Sandy would make things out of old bed frames. _explained that Sandy would reshape the metal from bed frames into other items such as knives. Sandlin has tools such as a dremel tool in order to make these items. As part of the break up, Sandy took all of his tools and reloading equipment and supplies with him, including powder .

••• Iast spoke with him on or about Tuesday, April 26, 2011 on Sandlin's cell phone number 904-217-2070. Sandlin drives a black Toyota Tundra pickup truck. During

__ conversation with law enforcement she verbally consented to a search of her garage. During the consent search, a black, metal, storage rack, two black cylindrical metal objects, and two red, plastic fuel canisters were observed. _agreed to release these objects to the FBI. Your affiant observed these items and believes they are similar to the items recovered from the bombing of ICNEF on May 10, 2010, which your affiant has also observed. Your affiant believes the black, metal storage rack and the two black, cylindrical metal objects are similar to the tubing used and subsequently recovered at the

13

scene of the bombing at the ICNEF on May 10, 2010. Your affiant believes that the two

red, plastic fuel canisters are similar to the recoveredfue! canister used at the bombing at

the ICNEF on May 10, 2010.

22. Based on my training and experience your affiant knows that reloading means

reloading ammunition which involves the use of explosive powders to reload ammunition.

Your affiant knows that the same explosive powders used to reload ammunition are

consistent with the type of smokeless powder identified by ATF as being present in the

sweepings recovered from the ICNEF bombing that occurred on May 10, 2010.

23. On April 30, 2011, was interviewed by your affiant and

Detective'S • During the interview, .stated in substance that he last visited his father, Sandlin Smith at his father's house on Race Track Road some time during the week

of April 1 B, 2011, and that he last spoke with his father on his father's cell phone on or about Tuesday, April 26, 2011. ~ spoke with Sandlin on Sandlin's cell phone with number 904-217-2070. _also stated in substance that his father, Sandlin, drives a black SR5 Toyota Tundra pickup truck with a chrome tool box.

24. On April 30,2011,

was interviewed by Joint Terrorism Task

Force Officers (TFO)

and

. Your affiant spoke with TFO

Congleton on April 30, 2011, whom explained to your affiant the following information. During the interview, .tated in substance that he is Sandlin Smith'sfather. _heard from ~that Sandlin pulled a gun on in Georgia and that Sandlin said he was responsible for bombing a mosque .• stated that he had no previous knowledge of Sandlin's involvement with bombing a mosque, prior to learning of it

from_

in or about the week of April 25, 2011 .• Iast spoke with his son,

Sandlin, on Thursday, April 2B, 2011 on the phone while .was in Georgia. On Friday,

14

April 29, 2011, .. traveled from his home in Georgia to his home in Jacksonville, Florida.

The purpose of ,,'s travel was to meet with some of his old friends, but_ also wanted to see his son, Sandlin. Since the time _ arrived in Jacksonville, he has left Sandlin

numerous telephone messages on Sandlin's telephone number 904-217-2070 that have

not been returned. On the afternoon of Friday, April 29, 2011, ~isited Sandlin's house

at 6174 Race Track Road, st. Johns County, Florida and did not locate Sandlin.

25. On May 1, 2011, was interviewed by FBI SA a: •

Your affiant spoke with TFO Congleton on May 1, 2011, whom explained to your affiant the following information. During the interview, _

stated in substance that Sandlin Smith moved into a house on his __ property located at 6174 Race Track Road, st. Johns County, Florida in approximately April or May 2010. There are two houses on_ property located at 6174 Race Track Road, st. Johns County, Florida .• owns the property on which both homes are situated and owns both homes. The main house is occupied by.and his wife. The second house

is occupied by Sandlin. _ showed the interviewing agents the exterior of the residence in which Sandlin has been living. .7 \said that Sandlin was seeking an apartment after separating from his wife in or about April 2010. _ said that Sandlin was recommended to him _ by people he knew that worked for AT&T. an , last saw Sandlin at approximately 9 or 10 am on Friday, April 29, 2011 ..... Ieft his residence shortly after

noticed that Sandlin was gone. .. has not seen or talked to Sandlin since Friday

,

morning. On Friday evening, Sandlin's father, • visited'tl"U" and said that he was looking for his son, Sandlin. On Saturday, April 3D, 2011 , ... entered Sandlin's house to

check on Sandlin's well-being and observed "reloading equipment" including "gun powder,"

15

26. On Sunday, May 1, 2011,

was interviewed via telephone by

SA O'Donovan. Your affiant spoke with SA O'Donovan on May 1, 2011, whom explained to your affiant the following information. During the interview,. stated in substance that she is Sandlin Smith's niece. ~ parents are .-and _. " •• _(l1li called"on Monday, April 25, 2011 and told her about Sandlin Smith pulling a gun on her and admitting to bombing a mosque. After talking with her mother, .. talked to Sandlin via telephone on Monday, April 25, 2011. During "and Sandlin's telephone 'conversation, Sandlin told "that he had bombed a mosque. Sandlin told ethat the reason he bombed the mosque was because he was angry about our men going overseas, fighting, and dying. Sandlin told _ that he wanted to make a statement and show Muslims that they were vulnerable too. Sandlin told" that he thought the police and feds were after him and that he was paranoid that everyone was a cop. The last telephone contactJia had with Sandlin was a voicemail message Sandlin left on tSl cell phone on Friday, April 29, 2011. ~ said that the nature of the message gave her the impression that Sandlin was leaving and going on the run from the police ... attempted to call Sandlin back as soon as she received the voicemail message, but Sandlin did not answer the call. Your affiant has reviewed Sandlin's telephone records for cellular telephone number 904-217-2070 for April 29-30, 2011. The records confirm the aforementioned attempted telephone call from .,to Sandlin at 904-217-2070 on Friday, April 29, 2011.

27. On May 1, 2011, a federal search warrant issued by United States Magistrate Judge Thomas E. Morris was executed at the residence of Sandlin Matthews Smith at 6174 Race Track Road, St. Johns County, Florida 32246. Pursuant to the search warrant and while your affiant was present during the search law enforcement seized eight containers of explosive powder and a suspected pressure switch were seized at Sandlin's >

16

residence. Your affiant observed the suspected pressure switch and describes this item as

a cylindrical metal object with a thin metal object that appears to have been affixed to the

cylindrical object with some sort of putty. A small metallic screw is affixed to the cylindrical object. If pressure is placed on the thin metal object, it makes contact with the small metal

screw which is affixed to the cylindrical metal object. On Monday, May 2, 2011, the ATF

transported the evidence to the ATF Atlanta Forensic Science Laboratory for analysis.

28. On May 1, 2011,

was interviewed by FBI SA

and

FBI SA, •••• ".'II Your affiant spoke with SA. .and SA

on May 1,2011,

and they explained to your affiant the following information. During the interview."stated in substance that he last spoke with Sandlin via telephone on or about Friday, April 29, 2011. During the conversation .as~ed Sandlin where Sandlin was located. Sandlin replied that information was "confidential". SA_and SA_did not discuss the bombing of the ICNEF with.

29. At approximately 9 pm on May 1, 2011, the SFM office received a call on their

7

tip-line. The caller identified himself as I I ''''' a a and provided his telephone

number as

.... and this information was sent to your affiant. Your affiant.

interviewed" via telephone on May 2, 2011. During the interview, ._. stated in

substance ~hat he met~ in June or July 2010. ""an

together for

Horizon, which is a subcontractor for the Navy .• and~ worked together and lived in the same house in Fort Smith, Virginia. _told "last June or July that" brother, Sandy, had bombed a mosque. II also told" that Sandy had a large collection of weapons and that Sandy wanted to sell some automatic weapons .... and _have

stayed in touch by telephone since meeting last June of July. On or about Saturday, April 30,2011, IIcalled _and told him that his _ brother, Sandy, had tried to rape his

17

_ ex-girlfriend in Georgia. He further stated that Sandy had told his _ex-girlfriend that he had bombed a mosque.

30. Your affiant has reviewed telephone records for Sandlin Smith's cell phone

number (904) 217-2070. Analysis of the records show a telephone call made from

Sandlin's Smith's telephone on April 30,2011. This telephone call was routed through a

cell tower located near Interstate Highway 10 between Pensacola, Florida and Mobile,

Alabama.

31. On May 1, 2011, your affiant learned from SA _ that a search of

official records revealed that Sandlin Matthews Smith, date of birth October 26, 1964, has

no devices properly registered in the National Firearms Registration and Transfer Record.

CONCLUSION

.

32. Based on the foregoing, I have probable cause to believe SANDLIN

MATTHEWS SMITH is involved with damaging a religious property, obstruction of

persons in the free exercise of religious beliefs, possession and transfer of a destructive

device, the possession of an unregistered firearm, and unlawful flight to avoid

prosecution, in violation of 18 U.S.C. 247, 18 U.S.C. 5861 (d),(f), 5845(a),(f), and 5871, and 18 U.S.C. 1073.

33. Accordingly, I respectfully request a Criminal Complaint be issued by this

Court authorizing the arrest of Sandlin Matthews Smith.

-- -----------

ial Agent Federal Bureau of Investigation

18