JFD:tac
AO 91 (Rev. 1_1/11) Criminal Complaint                                                                                    2017R00341
                                         · UNITED STATES DISTRICT COURT
                                                                  for the
                                                          District of Minnesota
    UNITED STATES OF AMERICA
                           v.
    NIICHAEL MCWRORTER
    JOSEPH MORRIS
    MICHAEL HAR1
                                                      CRIMINAL COMPLAINT
           I, the undersigned complainant, being duly sworn, state·the following is true and correct to the best of my lmowledge
and belief. On or about August 5, 2017,.inHennepin County, in the State and District of~esota, defendant(s) .
    maliciOJlsJy damaged, by means affire and_explasives, the Dar al-Faraaq Islamic Center, a building 1jsed in
    interstate and foreign commerce, and in an activity affecting interstate or foreign commerce                     ··
   · in violation of Title 18, United States Code, Section(s) 844(i).
I further state that I am a{n) Special Agent and that this complaint is based on the following facts:
          · SEE ATTACHED AFFIDAVIT
Continued on the attached sheet and made a ·part hereof:          181Yes
                                                                        yan J. Westby, Task Force Officer
                                                                      FBI .
                                                                                      Pri~ted name and title
Sworn to pefore me and signed.in my presence.
   .
  Date:
                  t3/ J},tI     .
  City and Sta;; Minneapolis, MN ·
                                         'f pt? Pin
                                             {I
                                                  ·
                                                                                              Judge's Signature
                                                                        The Honorable Franklin L. Noel
                                                                        United States Magistrate Judge
                                                         ..   '
                                                                                          · Printed Name and Title
JFD:tac
lO 442 (Rev. 11/11) Arrest Warrant
                                                                                                                         2017R00341
                                     UNITED STATES DISTRICT COURT
                                                               for the
                                                       District of Minnesota
       UNITED STATES OF AIV1ER1CA .
                          v.
       :MICHAEL MCWHORTER
       JOSEPH MORRIS
       MICHAEL HART
                                                      ARREST WARRANT
['o:        Any authorized law enforcement officer
         YOU ARE CO::tv.IMANDED to arrest and bring before a United States magistrate judge without unnecessary delay
>zame ofperson to be arrested) :MICHAEL MCWHORTER,
vho is accused of an offense or violation based on the following document filed with the court: .
          Indictment      __ Superseding Indictment __ Information __ Superseding Information .K_ Complaint
 __ Probation Violation Petition __ Supervised Release Violation Petition __ Violation Notice __ Order of the Court
       On or about August 5, 2017, in Hennepin County, in the State and District of Minnesota, defendant(s) maliciously
       damaged, by means of fire and explosives, the Dar al-Farooq Islamic Center, a building used in interstate and foreign
       commerce, and in an activity affecting interstate or foreign commerce
                                                                               L
       in violation of Title 18, United States Code, Section(s) 844(i).
   Date:
                                                                                       Issuing officer's signature
   City and State: Minneapolis, MN                                  The Honorable Franklin L. Noel
                                                                    United States Magistrate Judge
                                                                                        Printed Name and Title
                                                               Return
            This warrant was received on (date) _ _ _ _ _ _ _ , and the person was arrested on (date)
  at (city and state)
  Date: - - - - - - - -
                                                                                       Arresting officer's signature
                                                                                         Printed name and title
   AO 442 (Rev. 11/11) Arrest Warrant (Page 2)
                          This second page contains personal identifiers provided for law-enforcement use only
                          and therefore should not be filed in court with the executed warrant unless under seal.
                                                        (Not for Public Disclosure)
   Name of defendant/offender:---------------------- - - - - - - - - - - - -
   Known a l i a s e s : - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
   Last known r e s i d e n c e : - - - - - - - - - - - - - - - - - - - - - - - - - - - - -- - -- -- - - - -
  Prior addresses to which defendant/offender may still have ties: - - - - - - - - - - - - - - - - - - - - - - -
  Last known e m p l o y m e n t : - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
  Last lmown telephone n u m b e r s : - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -- - - -
  Place of b i r t h : - - - - - - - - - - - - - - - - - - - -- - - - - - -- - - - - - -- - - - - -
  Date of birth: - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -- - - -
  8ocial Security n u m b e r : - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
  Height: - - - - - - - - - - - - - - - - - -                          Weight:------------------
  Sex: ____________________                                  Race: - - - - - - - - - - - - - - - - - - - -
  Hair:--------------------                                  Eyes:--------------------
  Scars, tattoos, other distinguishing m a r k s : - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
  History of violence, weapons, drug u s e : - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
  Known family, friends, and other associates (name, relation, address, phone n u m b e r ) : - - - - - - - - - - - - - - -
  FBI n u m b e r : - - - - - - - - - - - - - - - - - - - - - - - - - -- - - - -- - - - - -- - - - -
  Complete description of a u t o : - - - - - - - - - - - - - - - -- - - - - - - - - - - - - - -- -- - -
 Investigative agency and a d d r e s s : - - - - - - - - - - - - - - - - - - - - - - -- - - - - - - - - - -
 Name and telephone numbers (office and cell) of pretrial services or probation officer (if applicable): _ _ _ _ _ _ _ __
 Date of last contact with pretrial services or probation officer (if applicable):------- - - - -- - -- -- - -
TEA:tac
lO 442 (Rev. 11/11) Arrest Wan-ant                                                                                  20 17R00341
.0 442 (Rev. 11/11) Arrest Warrant                                                                                          2017R00341
                                      UNITED STATES DISTRICT COURT
                                                              for the
                                                       District of Minnesota
      UNITED STATES OF AMERICA
                          V.
                                                                        Case No.   \   i-Af\ -J. ,)_,3; () ~ L,.j
      MICHAEL MCWHORTER
      JOSEPH MORRIS
      MICHAEL HARl
                                                    ARREST WARRANT
~o:        Any authorized law enforcement officer
         YOU ARE COMl\.'.IANDED to arrest and bring before a United States magistrate judge without unnecessary delay
iame ofperson to be arrested)         JOSEPH MORRIS,
                                     - - - - - - - - - - - -- - - - - - - - - - - - - - - - - - -- - -
vho is accused of an offense or violation based on the following document filed with the comt:
        Indictment        __ Superseding Indictment __ Information __ Superseding Information .K_ Complaint
 __ Probation Violation Petition __ Supervised Release Violation Petition __ Violation Notice _ ·_ order of the Court
      On or about August 5, 2017, in Hennepin County, in the State and District of Minnesota, defendant(s) maliciously
      damaged, by means of fire and explosives, the Dar al-Farooq Islamic Center, a building used in interstate and foreign
  D:eviolation:z:;~;ted;:s :::ection(s)844(i).
                                             7
                                                                        LJ·t_ i lJ~
      commerce, and in an activity affecting interstate or foreign commerce
                     / T                                                t               Issuing officer's signature     ·
  City and State: Minneapolis, MN                                  The Honorable Franklin L. Noel
                                                                   United States Magistrate Judge
                                                                                         Printed Name and Title
                                                              Return
          This warrant was received on (date) - - - -- -- , and the person was arrested on (date)
 at (city and state) - - - - - - - -- - - - - -
 Date: - - -- - - - -
                                                                                        Arresting officer's signature
                                                                                          P r inte d na me and title
AO 442 (Rev. 11/11) Arrest Warrant (Page 2)
                      This second page contains personal identifiers provided for law-enforcement use only
                      and therefore should not be filed in court with the executed warrant unless under seal.
                                                    (Not for Public Disclosure)
Name of d e f e n d a n t / o f f e n d e r : - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
Known a l i a s e s : - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
Last known r e s i d e n c e : - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
Prior addresses to which defendant/offender may still have ties: - - - - - - - - - - - - - - - - - - - - - - -
Last known e m p l o y m e n t : - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
Last lmown telephone n u m b e r s : - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
Place of b i r t h : - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
Date of birth: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
Social Security n u m b e r : - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
Height: - - - - - - - - - - - - - - - - - -                        Weight:------------------
Sex: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __                        Race: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
Hair: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __                       Eyes: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
Scars, tattoos, other distinguishing m a r k s : - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
History of violence, weapons, drug use: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __;___ _ _ _ _ _ __
Known family, friends, and other associates (name, relation, address, phone number):---------------
FBI n u m b e r : - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
Complete description of a u t o : - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
Investigative agency and a d d r e s s : - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
Name and telephone numbers (office and cell) of pretrial services or probation officer (if applicable): _ _ _ _ _ _ _ __
Date of last contact with pretrial services or probation officer (if applicable):------------------
0 442 (Rev. 11/11) Arrest Warrant                                                                                               2017R00341
                                     UNITED STATES DISTRICT COURT
                                                              for the
                                                      District of Minnesota
      UNITED STATES OF AMERICA
                         v.
                                                                        · Case No.     \
                                                                                        ..
                                                                                             y\ - -(VIS" - d-3'(} f' LA)
                                                                                             ,J
      :MICHAEL MCWHORTER
      JOSEPH MORRIS
      IvilCHAEL HARI
                                                     ARREST WARRANT
'o:        Any authorized law enforcement officer
         YOU ARE COMJ.\1ANDED to aiTest and bring before a United States magistrate judge without unnecessary delay
iame ofperson to be arrested)        MICHAEL HARI,
                                    - - - - - - - - - - - - - -- - - - - - - - - - - - - - - - - - - - -
rho is accused of an offense or violation based on the following document filed with the court:
        fudictment       __ Superseding fudictment __ Information __ Superseding Information lf_ Complaint
__ Probation Violation Petition __ Supervised Release Violation Petition __ Violation Notice __ Order of the Court
      On or about August 5, 2017, in Hennepin County, in the State and· District of Minnesota, defendant(s) maliciously
      damaged, by means of fire and explosives, the Dar al-Farooq Islamic Center, a building used in interstate and foreign
      commerce, and in an activity affecting interstate or foreign commerce
      in violation of Title 18, United States Code, Section(s) 844(i).
                                                                                                                            :
                                                                                                             ·. A Nzu,{
  Date:
                                                                               I-             Issuing officer's signature
  City and State: Minneapolis, MN                                  The Honorable Franklin L. Noel
                                                                   United States Magistrate Judge
                                                                                                  Printed Name and Title
                                                              Return
          This warrant was received on (date) _ _ _ _ _ __               , and the person was arrested on (date)
 at (city and state)
 Date: - - - - -- - -
                                                                                              Arresting officer's signature
                                                                                                   Printed name and title
AO 442 (Rev. 11/11) Arrest Warrant (Page 2)
                      This second page contains personal identifiers provided for law-enforcement use only
                      and therefore should not be ftled in court with the executed warrant unless under seal.
                                                    (Not for Public Disclosure)
Name of d e f e n d a n t / o f f e n d e r : - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
Known aliases: - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
Last known residence: - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
Prior addresses to which defendant/offender may still have t i e s : - - - - - - - - - - - - - - - - - - - - - - -
Last lrnown e m p l o y m e n t : - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
Last known telephone n u m b e r s : - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
Place of birth: - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
Date of birth: - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
Social Security n u m b e r : - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
Height: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __             W~ight: - - - - - - - - - - - - - - - - - -
Sex: _____________________                                         Race:--------------------
Hair:--------------------                                          Eyes: - - - - - - - - - - - - - - - - - - - -
Scars, tattoos, other distinguishing marks: - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
History of violence, weapons, drug u s e : - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
Known fami!y, friends, and other associate~ (name, relation, address, phone number):------------ - - -
:FBI n u m b e r : - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
Co~plete description of auto: _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___;__ _ _ __
Investigative agency and a d d r e s s : - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
Name and telephone numbers (office and cell) of pretrial services or probation officer (if applicable): _ _ _ _ _ _ _ __
Date of last contact with pretrial services or probation officer (if applicable): - - - -- - - - - - - - - - - - - - -
                               UNITED STATES DISTRICT COURT
                                    DISTJUCT OF'. MINNESOTA,                     . .·. .        l.
                                              Case No.       \   i   -M CS- -JG 't . s;\._,.,-AJ
 UNITED STATES OF AMERICA,                               )
                                                         )   . Al?Fp)AVIT OF FBI TASK
        Plaintiff,                                       )      FORCE OFFICER RYAN
                                                         )      J. WESTBY IN SUPPORT
              vs.                                        )     .OF A CRIMINAL
                                                         )       COMPLAINT
 JVIICHAEL McWHORTER;                                    )
 JOSEPH MORRIS, arid                                     )
. MICHAEL HARI,                                      .   )
                                                         )
        Defendants.                                      )
      · Ryan J. Westby, being duly sworn upon his oath, deposes and states:
        1.          Y_our Affiant, Detective Ryan V:festby, is emp_loyed by the Hennepin County .
                                   a
 ,Sheriffs Office and has been Deputy Sheriff since 2005. Your Affiant is currently a Task
 Force Officer with the Federal Bureau of Investigation (FBI) and is assigned to the
 Minneapolis Division of the FBI's Joint Terrorism Task Force. Your Affiant has .been
'w orking as an investigator since 2006 with the Henn~pin County Narcotics Unit, Hennepin
· County Violent Offender Task Force and Detective Unit. In this capacity, your Affian~ has
been working with experienced Detectives, Investigators a~d Special.Agents froin the FBI.
                        .                                                                  .
Your Affiant has been involved in numerous investigations involving, executions of search
                                                                                  ..
warrants, undercover .n~rcotics buys, surveillance, ·interviews and arrests. of persons
involved in ~eapons, narcotics, robberies; thefts, fraud and many other crimes.
                                                 .                           .
       2. .     I r~spectfully submit that .t~e·· facts set fo~h in this affidavi~ constitute
probable cause to believe. that Michael McWHORTER, J0SEPI:I MORRlS; and
                               .                          .
  MICHAEL HARI have corruiutted t~e crime of maliciously damaging, by means of fire
  and exp~osiyes, a ·building used in interstate or foreign commerce, or in any ·activity
  affecting interstate or foreign commerce,
                                    .       in violation of Title :18, United
                                                                           .
                                                                              States Code,
  Section 844(i). I am thoroughly familiar with the facts ofthi~ case. This affiq.avit sets. forth
    .                                            .
  th9se facts which I believe .n~cessary to establish probable ca~se. I make no claim that this
  affi~avit sets forth all of my knowle_
                                       dge about this case.       This affidavit includes information .
  I' have received from other la~ ~nforcement personnel. In several _places, this affidavit
  draws upon a complaint affidavit subscribed and sworn to before a federal magistrate judge
                                             .                -                             '
  in Springfield, Illinois on March 13, 2018. · Your affiant ·has re·a d that complaint affidavit.
         3.    . On August 5, 2017, at approximately 5:05 in the morning, a window of the
 imam's .office at the Dar al-Farooq Islamic Center and Mosque, ·s201 Park Avenue South,
 .Bloomington, Minnesota, was br~ken, and a pipe bomb was thrown into the Islamic Center
 through the broken :window. The pipe bomb ~xploded and started a fire in the imam's
 office. The buil<l:ing' ~ fire suppression system.~ctivated and promptly put out th~ fire. ~he ·
 imam's office, and items in the irnarh's office, suffered explosion, fire, and water dam.age.·
 The ?no~que also suffered, as noted above, a broken window.
        4.      The Dar al-Farooq Isla~c Center ~s used not only for religious purpos.es, but
 also for commercial purposes. The al-Jazari Institute is housed at the Dar al-Farooq Islamic
· Center. ~e al-Jazari Institute operates. a dugsi, or Islamic·religious school for children,
 and did so on August 5,- 2017. T~e dugsi is ·a fee-b11sed schoo~. During J:uly of 2017, the:
 month before .the. bombing,
                     .       .
                               the ·aI-Jazari Institute
                                                    ...
                                                        ·deposited
                                                                .
                                                                   over $180,'000 in its bank
                                                                                         .
 a~count, and paid-out over $150,°oOO from that bank account.
           5.    The pipe bornb was cop.structed of polyvinyl chloride;·a plas~ic-like ~aterial
  better known by its initials; "PVC": Police .bomb squad officers who arrived at the imam's ·
  office s~elled .sulfur, which, from their. training and experience, they knew to be an
.. indicator .that black powder had been·used as the-explosiv·e in the device. A melted, ·plast!c
  container was found in the imam's offiGe, and there was a stain of diesel fuel on the carpet
  and padding underneath the remnants of the pipe bomb . .These facts are       consistent with
  diesel fuel.having been used as the ac<?elerant for a bJack-powder pipe bomb . .After going
  through the window, the pip~ bomb landed only a short distance inside the imarp.'s office.
           6.   An eyewitness, who was outside the mosque, turned around when s/he heard
  the sound ofbrea~g glass, just in time to see a nian get-into a dark-color~d pickup. The
  eyewitness· stated that as soon as the man got in, the pickup·truck drove out of the Islamic
  Center's parking lot at high speed, and turned north o~ Park_A.venue.
           7.    On November 7, 2017, at approximately 7:30 a.m., a staff member of the
 Women's Health Practice, 2125 South Neil Street, Champaign, Illinois, arrived to open the
 clinic for the d_ay. This clinic provides women's health services, including abortions. The
       .                                                                                     .
 _staff member found a broken window~ glass on the floor, and a device.~nside the surgery
 room. -The··device-had not exploded.
           8.   MuJtiple .federal and local law enforcement agencies responded to the
.Women's Health Practice. 'fhe device was rendered safe by-law enforcement. The device
·itself was described as.a segme.n t of.PVC pipe w~th a plastic cap on one end and duct tape
                                     r
 over the other
           .
                .end. The powder located witbin
                                          .
                                                the pipe was determined to contain. therniite,
                                                             .
 a pyrotechnic · compound. A magnesium strip was also pres·en.t in.· the device. The .
                                                3
    combination ·of these factors 1ed the bomb technician to the initial conclusion . that the
    device was designed t.o bum. Responders also noted that the room in,which.the device was ·
_located was·the surgi~al room and contained oxygen tanks.
          9.     The FBI in Illinois investigated the clinic bombing. This investigation led,
                      .                                                 .               .
    on March 10, 2018, to an interview of Michael McWHORTER, a defendant in this case. ,
    In his March 10, 2018 int~rview McWHORTER admitted               his .involvement,      and the
 involvement ofMichael_HARI and Joseph MORRIS, in the clini~ bombing, and also in the
bombing
   .
        of the Dar a-Farooq Islamic Center.
                                      .
          10.         In addition, on January 27, 2018, an FBI-Illinois confidential source (CS)
provided ~.formation that three individuals - HARI, ¥cWHORTER, and MORRIS - were
responsible for the·bombing c~rried out at the D.ar al-Farooq Islamic Center, as well as the
attempted bombing at the Wom~n's .Health Practice in Champaign, Illinois. CS is aware of
this information because CS had previously worked for         HA.RI, who recruited CS into an
                                1
organization led by HARI.
          11.   .CS reported seeing, _during a meeting on or about January 27, 2018, in the
group'~ possession, illegal firearms (~lly aD:tomatic), _M4s, and tannerite, which the group
locked in_a safe inside H;ARI's store/office in Clarence, Illinois. CS also said that one night
                  .                             .
when CS was drinking with MORR1S and McWHORTER, MORRIS began talking about
throwing a black ·powder pipe bomb at       amosque in Minnesota. MORR1S told CS that he
                                                                            '   I
1 CS· has a ·criminal history that includes convi;tiqns for possession of drug paraphe~alia/
possess-ion or ·cannabis charges in the late 1990s. In the e_arly 2000s, cs·had a c~nviction
for drunk driving·and misdemeanor assault. CS curie~tly has a pending -~ttempted .assault
charge. CS has been pai4. $1 ,ooo by the FBI for ip.formation provided..            -
                                                    4
 made the pipe ~omb and _that McWHORTER.threw            i~ in the ·mosque. MORRIS claimed
 HARI was going        to pay them.$18,000 for their participation in the Minnesota bombing.
 MORRIS later told CS that he mad~ ~nd placed the incendiary device at the Women's
Health Practice in Champaign. MORRIS complaineq. to CS that ·it di~ not go off and .
MORRiS had no ·idea why. MORRIS told CS that the truck; which was used to ~et away,
was rented iii Chaip_paign, pos-sibiy- at Enterprise Rent~A-Car.
       12.      In his March 10, 2018 interview, McWHORTER admitted to his
participation in the attempted :b ombing of the Women's Health Practice on November 7,
2017. McWHORTER ·said HARI, MORRIS, and McWHORTER were .in a gray Dodge
Ram 2500, which HARI rented at Enterprise Rent-A-Car in Champaign. (Records obtained
from Enterprise. revealed that HARI had rented a grey Dodge Ram at ·the time the pipe
·device was left in the women's clinic.) McWHORTER said the thennite device was made
before the attempted bombing. McWHORTER said HARI made 'the devi~e out of a white .
PVC pipe. Mc~ORTER said "in the middle of the night" MORRIS was dropped off;
that MORR1S proceeded ~o smash the window and threw the device in the_~in~ow ·at the
practice; and that they picked MORRIS up north of the pr~ctice. McWHORTER said they
woµld so!lletimes use a ~agnesium strip to set off a thermit~ device. -According to
·McWHORTER, the magnesium strip sets off the thermite device a lot faster "than a normal
wick would." He said the magnesium strip looks 1ike tape, but it is metal, "blackish grey
in color." -
        ..
       13.     · McWHORTER also admitted to his participation in the bomhing of the Dar
al-Farooq
   .     -
           Islamic Center
                       .
                          on·Augus.t
                                .
                                     5, 2b17.. McWHORTER
                                               .
                                                         saidMcWHORTER,
                                                             .       .
                                                                        HARI,
                  .~
                 '·
                                               5
·and Ma°RRIS. d~ove to.Mtnnesota in a charcoai gray Nissan Fron~ier, which HARI rented
 f~om Enterprise Rent-A-Car ·in Champaign, Illinois. Records qbtained from Enterprise
 Rental show that HARI rented a black Nissan Frontier Crew Cab on July 27, 2017 5 with a
. beginning mileage of 13,873. The vehicie was re~ed on Augus! .6, 2017, (the day after
the Dar al-Farooq bombing) with an ending mileage of 10,948. According to Google map·s,
the round trip mileage from. c4ampaign, Illinois· .to · Bloomington, ·Minnesota 1s
approximately 1,040 miles.
       14.    According     to   McWHORTER,           HARI   picked       µp   MORR1S   and
McWHORTER from their homes prior to departing Illinois. HARl, McWHORTER, ·a nd
MORRIS each had specific roles for the bombing. HARI was-the driver, MORRIS was
         -
responsible for smashing the window in, and McWHORTER was responsible for throwing
the bomb in the window. McWHORTER
                          ....,_
                                  claimed it was HART s idea
                                                 ,-       .
                                                             to target the Mosque .
McWHORTER said they did not intend to kill anyone, but they wanted to "scare them out
of the country'' (referring to Muslims), because they push their beliefs on. everyone "else.
McWHORTER also said they committed the bombing mainly to "show them hey, you're
not welcome here, get the fuck out." McWHORTE~ said MORRIS smashed the window
in with a sledgehammer. McWHORTER described the device as a "huge ass black powder
bomb.'' The device was approximately 1~"-24" tall. McWHORTER initially said it was
made out of PVC, but t~en stated it :was probably
                                          -.·
                                                  metal.
                                                   .
                                                         _M cWHORTER admitted igniting
                                                                      .            .
the device. McWHORTER said he didn't want to b~ anywhere near it when it wentoff.
                                             6
    McWHORTER said after he threw the bomb inside h_e saw a person, who looked "direct_ly
    at ~m." McWHORTER said this occurred at approximately 3:00 a.m. to 4:00 a.m.
    M~WHORTER       said, "we were long gone before it went ' off' (referring to the bomb
                                                       .               '
    exJ?loding).
           15.     In an interview with a Minneapolis FBI Agent on March 13, 2018,
    McWHORTERdescribed the Dar al-Farooq device·as black PVC, approximately 6 inches
    in diameter and ·approximately 12 inches long. 2 McWHORTER said·HARI drilled   ahole
in one of the · two end caps and the~ a thick green wick was placed through the hole.
McWHORTER d~scribed the w~ck as v~ry long (2-3 feet).
2   _As nqted in the prec~ding paragraph, in his March 10, 2018 interview, McWHORTER
stated that t~e deyice had an overall length of 18 to 24 inches.
                                              7
        16. ·   McWHORTER said a windshield ·washer fluid plastic container held
                                           .                                   .
 diesel/gas mixture that was purchased on the wa:Y to the mosque using cash.
 McWHORTER repeated that MORRIS broke the window with a sledge hammer..
 McWHORrER lit the fuse with. a cigarette lighter and threw it a few feet inside the
window. The windo~·; McWHORTER stated, was rand~mly chosen Qec_ause there was      no
light ~n inside.
       Further your affiant sayeth not.
 Sworn to before me this ·
t.3~day March, 2018
  ·UJ
T .· HONORABLE FRANKLIN L. NOEL
UNITED STATES MAGISTRATE JUDGE
                                          ·8