1. Executive Summary (Key Judgments + Confidence)
The affidavit alleges that an eight-page handwritten plan titled “OPERATION MIDNIGHT SUN” contemplated placing backpacks containing “ieds” (improvised explosive devices) described as “complex pipe bombs,” to be detonated simultaneously at five locations associated with two U.S. companies at midnight on New Year’s Eve 2025 in the Central District of California. [DOC] (Confidence: High) (Aff. ¶5, ¶10–12)
The complaint and affidavit present a theory that the four named defendants (AUDREY ILLEENE CARROLL, ZACHARY AARON PAGE, DANTE GAFFIELD, and TINA LAI) progressed from planning into execution-phase preparation by acquiring materials, coordinating logistics via the Signal application, and traveling to the Mojave Desert on December 12, 2025 for test construction/detonation before law enforcement intervention. [DOC] (Confidence: High) (Aff. ¶6, ¶18–24; Complaint p.1)
The record includes allegations of deliberate operational security planning (burner phones; cash-only purchasing; device-sequestration; clothing/disguise guidance; gait-alteration; and alibi/“plausible deniability” guidance) that, if credited, supports an inference of premeditation rather than impulsive conduct. [INF] (Confidence: Moderate) (INF from Aff. ¶12–14, ¶17–18, ¶21–23)
The government’s evidence narrative ties core planning and facilitation roles to CARROLL and PAGE (authorship/dissemination of plans; procurement lists; logistical coordination), and ties LAI and GAFFIELD to recruited participation and material/logistics contributions culminating in presence at the desert test site. [INF] (Confidence: Moderate) (INF from Aff. ¶5–6, ¶10, ¶17–18, ¶21–24)
The affidavit states that, after a predetermined signal from an undercover FBI employee, Federal Bureau of Investigation personnel intervened and placed the four defendants into custody while bomb testing was described as “imminent,” and before completion of a functional explosive device. [DOC] (Confidence: High) (Aff. ¶23; Aff. ¶6 (summary framing))
The affidavit reports seizure from the desert campsite of materials including potassium nitrate, charcoal/charcoal powder, sulfur powder, PVC pipe pieces, gasoline, glass bottles, cloth items, and “six boxes of primer,” and reports an FBI bomb technician assessment that the components could likely be used to build improvised explosive devices and Molotov cocktail devices and were “readily assemblable.” [DOC] (Confidence: High) (Aff. ¶24–25)
For Count Two, the affidavit’s registration predicate is an asserted Bureau of Alcohol, Tobacco, Firearms and Explosives records check dated December 11, 2025 stating there is no record of any of the four defendants registering any destructive device with the National Registration and Transfer Record. [DOC] (Confidence: High) (Aff. ¶27)
The record distinguishes between a public-facing “Turtle Island Liberation Front – LA Chapter” identity (including an Instagram account the affidavit attributes to CARROLL) and an internal operational chat titled “Order of the Black Lotus” that CARROLL allegedly described as “our group for everything radical,” with “Operation Midnight Sun” functioning as a code name for the specific alleged New Year’s Eve bombing plot. [DOC] (Confidence: Moderate) (Aff. ¶8–10, ¶17–18)
The affidavit includes allegations of post–New Year’s Eve target expansion discussions (specifically, discussion of targeting U.S. Immigration and Customs Enforcement agents and vehicles with pipe bombs beginning in January or February 2026), which, if credited, bears on risk assessment beyond the charged conduct even though such conduct is not charged in this complaint. [DOC] (Confidence: Moderate) (Aff. ¶17(i))
2. Document Characterization and Procedural Posture
The source record consists of a “Criminal Complaint by Telephone or Other Reliable Electronic Means” in the United States District Court for the Central District of California, supported by an attached affidavit sworn by Federal Bureau of Investigation Special Agent Carolyn Thompson. [DOC] (Complaint p.1; Aff. ¶1–4)
The affidavit explicitly states it is “made in support of arrest warrants and a criminal complaint” against the four named defendants for violations of 18 U.S.C. § 371 (Conspiracy) (Count One) and 26 U.S.C. § 5861(d) (Possession of Unregistered Destructive Device) (Count Two) “on or about December 12, 2025.” [DOC] (Aff. ¶3)
The affiant states that the facts set forth are based on her observations, training/experience, and information from law enforcement personnel and witnesses, and that the affidavit is “intended to show merely” sufficient probable cause and “does not purport to set forth all of my knowledge of or investigation into this matter,” with conversations described “in substance and in part only,” and dates/times “on or about.” [DOC] (Aff. ¶4)
The complaint form lists the alleged offense date “on or about…December 12, 2025,” and the location as “the county of Los Angeles in the Central District of California,” and lists the two charged code sections and offense descriptions (18 U.S.C. § 371—Conspiracy; 26 U.S.C. § 5861(d)—Possession of Unregistered Destructive Device). [DOC] (Complaint p.1)
The complaint identifies the defendants as AUDREY ILLEENE CARROLL (aka “Asiginaak”), ZACHARY AARON PAGE (aka “AK”), DANTE GAFFIELD (aka “Nomad”), and TINA LAI (aka “Kickwhere”). [DOC] (Complaint p.1)
The complaint and concluding page reflect attestation by telephone and the signature/attestation of “Honorable Michael B. Kaufman, United States Magistrate Judge,” with a timestamp “December 13, 2025 at 4:33 PM,” and the affidavit concludes with the same magistrate judge name. [DOC] (Complaint p.1; Aff. concluding attestation)
The record does not supply the case number (the “Case No.” field appears blank in the provided form), which constrains committee tracking unless separately obtained from docketing systems outside this record. [GAP] (Complaint p.1)
The record does not define “criminal complaint” or “probable cause” as legal standards; the only within-record characterization is the affiant’s statement that the affidavit is intended to show sufficient probable cause and is not complete. [GAP] (Aff. ¶4)
3. Statutory Elements-to-Facts Matrix
Count One: 18 U.S.C. § 371 (Conspiracy)
| Element (plain language) | Strongest alleged facts supporting element | Ambiguities / vulnerabilities | What would materially strengthen or weaken |
|---|---|---|---|
Agreement (an understanding to commit the charged unlawful objective) | The affidavit describes a written operational plan (“OPERATION MIDNIGHT SUN”) contemplating coordinated New Year’s Eve bombings at five locations, and describes dissemination/discussion of that plan across multiple meetings and in a Signal group chat used to discuss the bombing plot and desert testing. [DOC] (Aff. ¶5, ¶10–12, ¶15, ¶18(c))
| The record excerpts do not include full verbatim transcripts of meetings or full Signal logs showing explicit assent by each defendant to the New Year’s Eve attack objective, which may leave room to contest the breadth of agreement (e.g., agreement to “test” vs agreement to execute New Year’s Eve bombings). [GAP] (Aff. ¶4 (partiality disclaimer); ¶15 (audio recording referenced); ¶18 (messages referenced))
| Strengthen: full authenticated recordings/transcripts and complete chat exports showing explicit agreement, role assignment, and shared intent across all defendants. [GAP] (Implied by Aff. ¶15, ¶18, ¶21 references to recordings/messages)
; Weaken: credible evidence that some participants understood discussions as hypothetical/aspirational, or that one or more defendants refused/withdrew and were nonetheless present for unrelated reasons. [GAP] |
Knowing participation (each defendant knowingly joined) | CARROLL is alleged to have provided the plan to the Confidential Human Source and discussed testing explosives in the desert; PAGE is alleged to have been present at the initial plan handoff and to have posted/relayed operational instructions for desert testing; LAI and GAFFIELD are alleged to have been recruited and to have participated in the “Order of the Black Lotus” chat and to have traveled to the desert with the group. [DOC] (Aff. ¶5–6, ¶10, ¶17, ¶18, ¶21)
| GAFFIELD’s specific material contribution to bomb components is less explicit than CARROLL/PAGE/LAI in the desert-materials paragraph (which expressly names CARROLL, PAGE, and LAI as bringing components), creating potential room to argue mere association/presence for GAFFIELD absent more detail on constructive possession and intent. [INF] (INF from Aff. ¶22 (names CARROLL/PAGE/LAI for components) vs ¶21(a) (GAFFIELD traveled) and ¶23 (GAFFIELD set up tent))
| Strengthen: forensic linkage (device residues, fingerprints/DNA), digital attribution (device-to-alias mapping), and explicit statements by each defendant committing to the plan. [GAP] (Aff. ¶4 partiality; ¶18 attribution footnote; ¶25 technical assessment but not forensics)
; Weaken: evidence that one or more defendants were misattributed to a Signal alias or that their participation was coerced/unknowing. [GAP] |
Overt act(s) (at least one act to advance the conspiracy) | The affidavit alleges multiple overt steps: dissemination of the plan; acquisition/procurement activity (e.g., Amazon purchase of potassium nitrate; purchase of primers; coordination of materials and travel logistics); and travel to and setup at the desert campsite with steps described as beginning device construction before arrest. [DOC] (Aff. ¶10–11, ¶17(f), ¶18(a–h), ¶19–24)
| Many procurement items are lawful in isolation, so the overt-act force depends heavily on context (plan document + coordination + convergence at test site) rather than any single purchase. [INF] (INF from Aff. ¶14 (instructions likely yield operational device), ¶18 (list of components + burner phones), ¶21–24 (convergence + setup + seizure list))
| Strengthen: proof of additional overt acts tied to the New Year’s Eve targets (e.g., target surveillance evidence, reconnaissance artifacts, specific backpacks/timers assembled, or physical casing preparations). [GAP] (Aff. ¶13 discusses pre-op surveillance conceptually but does not provide target-surveillance evidence)
; Weaken: proof that the desert trip and materials had an alternative lawful purpose unrelated to explosive construction, though the plan document and bomb-technician assessments would still need to be addressed. [GAP] |
Show raw matrix text (audit view)
Element (plain language) Strongest alleged facts supporting element Ambiguities / vulnerabilities What would materially strengthen or weaken Agreement (an understanding to commit the charged unlawful objective) The affidavit describes a written operational plan (“OPERATION MIDNIGHT SUN”) contemplating coordinated New Year’s Eve bombings at five locations, and describes dissemination/discussion of that plan across multiple meetings and in a Signal group chat used to discuss the bombing plot and desert testing. [DOC] (Aff. ¶5, ¶10–12, ¶15, ¶18(c)) doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint The record excerpts do not include full verbatim transcripts of meetings or full Signal logs showing explicit assent by each defendant to the New Year’s Eve attack objective, which may leave room to contest the breadth of agreement (e.g., agreement to “test” vs agreement to execute New Year’s Eve bombings). [GAP] (Aff. ¶4 (partiality disclaimer); ¶15 (audio recording referenced); ¶18 (messages referenced)) doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint Strengthen: full authenticated recordings/transcripts and complete chat exports showing explicit agreement, role assignment, and shared intent across all defendants. [GAP] (Implied by Aff. ¶15, ¶18, ¶21 references to recordings/messages) doj-criminal-complaint doj-criminal-complaint ; Weaken: credible evidence that some participants understood discussions as hypothetical/aspirational, or that one or more defendants refused/withdrew and were nonetheless present for unrelated reasons. [GAP] Knowing participation (each defendant knowingly joined) CARROLL is alleged to have provided the plan to the Confidential Human Source and discussed testing explosives in the desert; PAGE is alleged to have been present at the initial plan handoff and to have posted/relayed operational instructions for desert testing; LAI and GAFFIELD are alleged to have been recruited and to have participated in the “Order of the Black Lotus” chat and to have traveled to the desert with the group. [DOC] (Aff. ¶5–6, ¶10, ¶17, ¶18, ¶21) doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint GAFFIELD’s specific material contribution to bomb components is less explicit than CARROLL/PAGE/LAI in the desert-materials paragraph (which expressly names CARROLL, PAGE, and LAI as bringing components), creating potential room to argue mere association/presence for GAFFIELD absent more detail on constructive possession and intent. [INF] (INF from Aff. ¶22 (names CARROLL/PAGE/LAI for components) vs ¶21(a) (GAFFIELD traveled) and ¶23 (GAFFIELD set up tent)) doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint Strengthen: forensic linkage (device residues, fingerprints/DNA), digital attribution (device-to-alias mapping), and explicit statements by each defendant committing to the plan. [GAP] (Aff. ¶4 partiality; ¶18 attribution footnote; ¶25 technical assessment but not forensics) doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint ; Weaken: evidence that one or more defendants were misattributed to a Signal alias or that their participation was coerced/unknowing. [GAP] Overt act(s) (at least one act to advance the conspiracy) The affidavit alleges multiple overt steps: dissemination of the plan; acquisition/procurement activity (e.g., Amazon purchase of potassium nitrate; purchase of primers; coordination of materials and travel logistics); and travel to and setup at the desert campsite with steps described as beginning device construction before arrest. [DOC] (Aff. ¶10–11, ¶17(f), ¶18(a–h), ¶19–24) doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint Many procurement items are lawful in isolation, so the overt-act force depends heavily on context (plan document + coordination + convergence at test site) rather than any single purchase. [INF] (INF from Aff. ¶14 (instructions likely yield operational device), ¶18 (list of components + burner phones), ¶21–24 (convergence + setup + seizure list)) doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint Strengthen: proof of additional overt acts tied to the New Year’s Eve targets (e.g., target surveillance evidence, reconnaissance artifacts, specific backpacks/timers assembled, or physical casing preparations). [GAP] (Aff. ¶13 discusses pre-op surveillance conceptually but does not provide target-surveillance evidence) doj-criminal-complaint ; Weaken: proof that the desert trip and materials had an alternative lawful purpose unrelated to explosive construction, though the plan document and bomb-technician assessments would still need to be addressed. [GAP]
Count Two: 26 U.S.C. § 5861(d) (Possession of Unregistered Destructive Device)
| Element (plain language) | Strongest alleged facts supporting element | Ambiguities / vulnerabilities | What would materially strengthen or weaken |
|---|---|---|---|
Possession (actual or constructive possession by defendants) | The affidavit asserts that, at the desert campsite, the group had bomb-making materials present and being arranged on a table, and that FBI personnel seized enumerated components; it also asserts that CARROLL, PAGE, and LAI “all brought bomb-making components” to the campsite. [DOC] (Aff. ¶22–24)
| GAFFIELD is not expressly named as bringing components in the paragraph listing who brought bomb-making components, creating a potential possession-element vulnerability as to GAFFIELD unless constructive possession is supported by additional evidence not included here. [INF] (INF from Aff. ¶22 (CARROLL/PAGE/LAI brought components) and ¶23 (GAFFIELD set up tent behind table) and ¶21(a) (GAFFIELD traveled))
| Strengthen: individualized proof of dominion/control over specific items (e.g., who transported which items, fingerprints/DNA on containers/pipes, admissions, or video of handling). [GAP] (Aff. ¶4 partiality; ¶24 list but not individualized attribution)
; Weaken: evidence that certain items were not under a defendant’s control/knowledge or were introduced without their awareness. [GAP] |
“Destructive device” / readily assemblable (device or parts meeting statutory definition; “readily assemblable” per affidavit) | The affidavit reports an FBI bomb technician determination that the components seized “could likely be used to build” improvised explosive devices and Molotov cocktail devices and that the components were “readily assemblable,” and separately reports that bomb-making instructions in the plan, if followed, would likely create an operational explosive device. [DOC] (Aff. ¶14–15, ¶25)
| The affidavit also reports law enforcement intervened before completion of a functional explosive device, which may shift litigation onto whether the seized items constitute a “destructive device” or a “combination of parts” under the statute, an issue the affidavit addresses via “readily assemblable” language but does not fully litigate in-record. [INF] (INF from Aff. ¶6, ¶25)
| Strengthen: laboratory confirmation of chemical identities, expert report details, demonstrative reconstruction testing under controlled conditions, and full documentation of all parts present (including any end-cap or closure components). [GAP] (Aff. ¶25 includes technician conclusion and a note about missing “end caps” without full report)
; Weaken: expert re-evaluation concluding parts were not readily assemblable into a statutory destructive device without substantial additional materials/steps. [GAP] |
Registration status (device not registered as required) | The affidavit states that an ATF records check on December 11, 2025 found no record of any of the four defendants registering any destructive device with the National Registration and Transfer Record. [DOC] (Aff. ¶27)
| The record does not provide the underlying ATF query details (identifiers used; scope; whether aliases were checked), which may matter if identity records are contested. [GAP] (Aff. ¶27)
| Strengthen: production of ATF certification/records custodian declaration and identity linkage demonstrating the search covered all relevant names/aliases. [GAP] (Aff. ¶27 provides conclusion only)
; Weaken: credible evidence that the device/parts were not registrable under the applicable statutory definition or that the records check was incomplete/mismatched to the defendants. [GAP] |
Show raw matrix text (audit view)
Element (plain language) Strongest alleged facts supporting element Ambiguities / vulnerabilities What would materially strengthen or weaken Possession (actual or constructive possession by defendants) The affidavit asserts that, at the desert campsite, the group had bomb-making materials present and being arranged on a table, and that FBI personnel seized enumerated components; it also asserts that CARROLL, PAGE, and LAI “all brought bomb-making components” to the campsite. [DOC] (Aff. ¶22–24) doj-criminal-complaint doj-criminal-complaint GAFFIELD is not expressly named as bringing components in the paragraph listing who brought bomb-making components, creating a potential possession-element vulnerability as to GAFFIELD unless constructive possession is supported by additional evidence not included here. [INF] (INF from Aff. ¶22 (CARROLL/PAGE/LAI brought components) and ¶23 (GAFFIELD set up tent behind table) and ¶21(a) (GAFFIELD traveled)) doj-criminal-complaint doj-criminal-complaint Strengthen: individualized proof of dominion/control over specific items (e.g., who transported which items, fingerprints/DNA on containers/pipes, admissions, or video of handling). [GAP] (Aff. ¶4 partiality; ¶24 list but not individualized attribution) doj-criminal-complaint doj-criminal-complaint ; Weaken: evidence that certain items were not under a defendant’s control/knowledge or were introduced without their awareness. [GAP] “Destructive device” / readily assemblable (device or parts meeting statutory definition; “readily assemblable” per affidavit) The affidavit reports an FBI bomb technician determination that the components seized “could likely be used to build” improvised explosive devices and Molotov cocktail devices and that the components were “readily assemblable,” and separately reports that bomb-making instructions in the plan, if followed, would likely create an operational explosive device. [DOC] (Aff. ¶14–15, ¶25) doj-criminal-complaint doj-criminal-complaint The affidavit also reports law enforcement intervened before completion of a functional explosive device, which may shift litigation onto whether the seized items constitute a “destructive device” or a “combination of parts” under the statute, an issue the affidavit addresses via “readily assemblable” language but does not fully litigate in-record. [INF] (INF from Aff. ¶6, ¶25) doj-criminal-complaint doj-criminal-complaint Strengthen: laboratory confirmation of chemical identities, expert report details, demonstrative reconstruction testing under controlled conditions, and full documentation of all parts present (including any end-cap or closure components). [GAP] (Aff. ¶25 includes technician conclusion and a note about missing “end caps” without full report) doj-criminal-complaint ; Weaken: expert re-evaluation concluding parts were not readily assemblable into a statutory destructive device without substantial additional materials/steps. [GAP] Registration status (device not registered as required) The affidavit states that an ATF records check on December 11, 2025 found no record of any of the four defendants registering any destructive device with the National Registration and Transfer Record. [DOC] (Aff. ¶27) doj-criminal-complaint The record does not provide the underlying ATF query details (identifiers used; scope; whether aliases were checked), which may matter if identity records are contested. [GAP] (Aff. ¶27) doj-criminal-complaint Strengthen: production of ATF certification/records custodian declaration and identity linkage demonstrating the search covered all relevant names/aliases. [GAP] (Aff. ¶27 provides conclusion only) doj-criminal-complaint ; Weaken: credible evidence that the device/parts were not registrable under the applicable statutory definition or that the records check was incomplete/mismatched to the defendants. [GAP]
4. Chronology (Timeline with Evidence Trails)
November 26, 2025 (in-person meeting; plan dissemination): The affidavit states the confidential human source met with two Turtle Island Liberation Front members—“Asiginaak” (later identified as CARROLL) and “AK” (later identified as PAGE)—and that CARROLL provided the confidential human source an eight-page handwritten document titled “OPERATION MIDNIGHT SUN,” with the confidential human source observing CARROLL appeared to possess three to four additional copies; the document described five “marks” (target locations) with additional blank slots labeled “add more if enough comrades,” and the affidavit characterizes the targets as properties/facilities of two separate companies affecting interstate/foreign commerce. [DOC] (Aff. ¶10)
Late November 2025 (summary framing): In the affidavit’s summary section, the affiant states that “in late November 2025” CARROLL provided the confidential human source the eight-page plan describing a bombing plot and discussed the prospect of testing explosives “in the desert” in mid-December 2025, with PAGE present. [DOC] (Aff. ¶5)
December 2, 2025 (evening; in-person meeting; audio recording referenced): The affidavit states that, based on the confidential human source and review of an audio recording, another in-person meeting occurred between the confidential human source, CARROLL, and PAGE in or around downtown Los Angeles, with “Co-Conspirators 1 and 2” present; the confidential human source saw CARROLL provide a copy of the handwritten attack plan to Co-Conspirator 1, and Co-Conspirator 1 expressed concern about timeline, while Co-Conspirator 2 was present and was described by CARROLL as potentially providing off-ground support such as monitoring police scanners. [DOC] (Aff. ¶15)
December 2, 2025 (approx. 11:30 p.m.; surveillance to motel): The affidavit states FBI agents conducting surveillance saw CARROLL depart the downtown Los Angeles location with Co-Conspirator 2 and followed them to a motel in the Pico-Robertson neighborhood, and that surveillance then saw Co-Conspirator 2 shortly thereafter with no passengers, indicating CARROLL had been dropped off at the motel. [DOC] (Aff. ¶16)
December 3, 2025 (Signal direct communications; procurement list): The affidavit states the confidential human source communicated with CARROLL via Signal, and that CARROLL provided a list identifying components/chemicals/tools (with prices) required to create pipe bombs, with some components noted as already purchased or assigned to another “comrade,” and that CARROLL stated they should purchase burner phones “bought with cash only.” [DOC] (Aff. ¶18(a))
December 5, 2025 (Signal group characterization; “Order of the Black Lotus”): The affidavit states multiple co-conspirators used a Signal group titled “Order of the Black Lotus,” and that on December 5, 2025 CARROLL wrote the group was “our group for everything radical.” [DOC] (Aff. ¶18(b))
On or about December 5, 2025 (desert-testing instructions relayed to confidential human source): The affidavit states CARROLL forwarded to the confidential human source instructions for desert testing originally posted by PAGE in the Black Lotus group, including geocoordinates corresponding to Lucerne Valley, California, a satellite map screenshot with markings for camp and test areas, and statements about a “morning group” and PAGE meeting at night, along with phone-handling instructions (only two burners for emergencies; phones sealed in a box wrapped in aluminum until leaving). [DOC] (Aff. ¶18(d)–(f))
December 7, 2025 (early morning; in-person recruitment/briefing with undercover FBI employee present): The affidavit states that the confidential human source and an undercover FBI employee met with CARROLL, PAGE, and a male known as “NOMAD” later identified as GAFFIELD; CARROLL stated she had “the plan” and handed GAFFIELD four sheets of paper, and the undercover FBI employee later told law enforcement the papers contained detailed instructions on how to construct a black powder pipe bomb; PAGE stated it was “100,000 percent” that the FBI would be onto them; and CARROLL stated she had components including “13 PVC pipes” and potassium nitrate ordered on Amazon via a burner account for delivery December 11. [DOC] (Aff. ¶17(a), ¶17(d), ¶17(f))
December 7, 2025 (future-attacks discussion; not charged here): The affidavit states CARROLL and PAGE discussed plans for future attacks after the New Year’s Eve bombings, specifically targeting U.S. Immigration and Customs Enforcement agents and vehicles with pipe bombs beginning in January or February 2026. [DOC] (Aff. ¶17(i))
December 7, 2025 (business records; potassium nitrate purchase): The affidavit states that, according to Amazon records, CARROLL purchased two five-pound bags of potassium nitrate for delivery to an Amazon Counter at a Whole Foods location in Los Angeles, California, and that the potassium nitrate was delivered on December 11, 2025. [DOC] (Aff. ¶19)
December 8, 2025 (Signal; LAI confirms desert travel; equipment): The affidavit states LAI, using the Signal alias “Kickwhere,” wrote to the group confirming LAI would be going to the desert and had a cargo box on top of their vehicle for camping gear. [DOC] (Aff. ¶18(g))
December 8–9, 2025 (Signal; fuse-material discussion): The affidavit states that during an exchange about shoelaces/cotton string discussed in context as fuse material, LAI posted photographs depicting string and what appear to be packages of shoelaces, and on December 9 LAI sent a photo of twine and asked if it would work, with PAGE responding that PAGE thought it would and that they could test it. [DOC] (Aff. ¶18(h); ¶18(k))
December 10, 2025 (Signal + surveillance; procurement and tradecraft): The affidavit states PAGE messaged the group that “ingredients” were acquired and the “starter” would be acquired that evening, and the affiant states that agents conducting surveillance saw PAGE obtain a package from an Amazon pickup location shortly before the message; the affidavit also states agents saw PAGE purchasing pistol primers in Irvine, California while wearing a medical mask, gloves, ball cap, and long-sleeve shirt, and that (per a bomb technician) the primers could serve as an initiator for an improvised explosive device. [DOC] (Aff. ¶18(l)–(m))
December 10–11, 2025 (Signal; desert travel comms security): The affidavit states PAGE wrote guidance that only burner phones should be present (with non-navigators’ phones wrapped in foil or a Faraday bag for the trip) and instructed installation of an “open source maps” application to avoid “corporate tracking,” and that on December 11 PAGE wrote that building circuits for a digital timer was beyond PAGE (while “rudimentary options” still existed). [DOC] (Aff. ¶18(o), ¶18(q))
On or about December 10, 2025 (CARROLL direct message to confidential human source): The affidavit states CARROLL messaged the confidential human source about having a notebook of multiple plans (“my terrorist diary”) and stated “I have to get rid of that.” [DOC] (Aff. ¶18(r))
On or about December 11, 2025 (pickup of delivered potassium nitrate): The affidavit states that, based on Signal communications and surveillance on LAI, LAI picked up the box of potassium nitrate referenced in the Amazon records on or about December 11, 2025. [DOC] (Aff. ¶20)
December 11, 2025 (ATF records check re registration): The affidavit states that on December 11, 2025 an ATF records check found no record of any defendant registering any destructive device with the National Registration and Transfer Record. [DOC] (Aff. ¶27)
December 12, 2025 (morning; travel to desert; vehicle recordings referenced): The affidavit states that on the morning of December 12, 2025, the four defendants traveled to in or around Lucerne Valley in two vehicles, with the confidential human source riding with CARROLL and LAI and the undercover FBI employee riding with PAGE and GAFFIELD, and that the affiant’s knowledge comes in part from recorded conversations from the vehicles and surveillance footage; the affidavit reports that CARROLL described the day as a “test run” for the New Year’s Eve plot and stated “What we’re doing will be considered a terrorist act.” [DOC] (Aff. ¶21(a)–(c))
December 12, 2025 (approx. 10:00 a.m.; arrival; campsite setup): The affidavit states the co-conspirators arrived at the desert at approximately 10:00 a.m. and began setting up a campsite, and that (based on the undercover FBI employee and confidential human source) CARROLL, PAGE, and LAI brought bomb-making components including PVC pipes and suspected precursor powders and fuse materials; photographs in the affidavit depict some of these components on a table at the site. [DOC] (Aff. ¶22; Aff. p.19 photographs)
December 12, 2025 (shortly after; intervention and arrests): The affidavit states that, shortly after transferring components from vehicles, CARROLL, PAGE, and LAI began setting up materials on a table and GAFFIELD and others set up a tent behind the table; it states that after the undercover FBI employee alerted law enforcement with a predetermined signal indicating bomb testing was imminent, Federal Bureau of Investigation personnel intervened and placed CARROLL, PAGE, GAFFIELD, and LAI into custody. [DOC] (Aff. ¶23)
December 12, 2025 (post-arrest; campsite search and bomb technician assessment): The affidavit lists items seized from the campsite (including potassium nitrate, charcoal, sulfur, PVC pipes, gasoline, glass bottles, cloth/twine items, respirator/goggles, and primer) and reports an FBI bomb technician concluded components could likely be used to build improvised explosive devices and Molotov cocktail devices and were “readily assemblable.” [DOC] (Aff. ¶24–25)
December 12, 2025 (residence searches; additional seizures): The affidavit states search warrants were executed at the defendants’ residences and items seized included: in CARROLL’s residence, posters/materials associated with Turtle Island Liberation Front (with a photograph depicting “TURTLE ISLAND LIBERATION FRONT” signage and slogans including “DEATH TO ICE!!!”); in PAGE’s residence, a copy of the handwritten “Operation Midnight Sun” plan; in GAFFIELD’s residence, a Taser device that records indicate was stolen from the U.S. Federal Protective Service; and in LAI’s residence, a metal saw next to PVC shards, additional PVC pipe with receipts, and handwritten notes reflecting ideologies aligned with Turtle Island Liberation Front. [DOC] (Aff. ¶26; Aff. p.22 photograph)
December 13, 2025 (complaint attestation): The complaint reflects attestation by telephone and the magistrate judge’s name, with the timestamp “December 13, 2025 at 4:33 PM.” [DOC] (Complaint p.1)
5. Evidence Inventory and Reliability Assessment
Confidential Human Source reporting (including background, compensation, reliability claims): The affidavit states the confidential human source is “validated and vetted,” has been reliable since in or around August 2021, is cooperating for financial compensation, has no criminal history, and has provided past reliable reporting and reliable reporting in this case. [DOC] (Aff. ¶5 n.1)
The confidential human source is described as a participant/witness to multiple in-person meetings (Nov 26; Dec 2; Dec 7) and as a recipient of Signal communications and forwarded “Order of the Black Lotus” instructions, which makes the confidential human source a central evidentiary conduit for both direct observations and message content. [DOC] (Aff. ¶10, ¶15, ¶17, ¶18)
Reliability considerations include the affidavit’s acknowledgement of compensation (potential bias) and the fact that many claims are relayed through the affiant rather than presented as full transcripts, creating a hearsay and summarization layer even where the confidential human source may have firsthand knowledge. [INF] (INF from Aff. ¶4 (summarization/partiality) and ¶5 n.1 (compensation))
Missing for reliability evaluation are handling documentation (source validation details, payment history beyond the bare statement, debriefing reports) and the underlying audio/message extracts referenced by the affidavit. [GAP] (Aff. ¶4, ¶15, ¶18)
Undercover FBI employee presence and recordings: The affidavit states an undercover FBI employee was present at the Dec 7 meeting and traveled with PAGE and GAFFIELD to the desert, and that the undercover FBI employee gave a predetermined signal indicating bomb testing was imminent, triggering intervention. [DOC] (Aff. ¶17, ¶21–23)
The undercover FBI employee’s presence provides a direct law-enforcement witness layer that can corroborate or contradict confidential human source reporting, but the affidavit still summarizes rather than reproducing full undercover FBI employee reports/recordings, which constrains an independent committee assessment of context and potential inducement issues. [INF] (INF from Aff. ¶4 (partiality) and ¶17(a) (undercover FBI employee present) and ¶21 (recorded conversations referenced))
Signal communications and attribution basis: The affidavit describes Signal communications between the confidential human source and CARROLL and a group chat titled “Order of the Black Lotus,” including quotes and logistical instructions, and includes a footnote stating agents identified the co-conspirators based on surveillance, monikers used in-person and in Signal, and business records including location data associated with phones believed used. [DOC] (Aff. ¶18; Aff. ¶18 n.5)
Reliability considerations include (i) whether the Signal content is complete and forensically preserved or selectively provided via the confidential human source, and (ii) whether attribution from alias-to-person rests on robust device/account linkage versus inference from behavior and location data; the affidavit asserts attribution methods but does not provide the underlying technical exhibits. [INF] (INF from Aff. ¶18 (messages “provided by the CHS”) and n.5 (attribution methods described))
Surveillance observations (physical and digital): The affidavit includes asserted surveillance observations such as: FBI agents saw CARROLL depart a downtown location with Co-Conspirator 2 and go to a motel; agents saw PAGE pick up an Amazon package and later buy pistol primers while dressed to obscure identity; and agents observed LAI’s residence and saw a vehicle with a roof cargo box. [DOC] (Aff. ¶16; ¶18(l)–(m); ¶18 n.6)
Reliability considerations are generally stronger than hearsay for agent firsthand observations, but the record omits the contemporaneous surveillance logs, photos/video, and the precise legal process used for any location-data acquisition. [GAP] (Aff. ¶4; ¶18 n.5 implies location-data reliance without providing it)
Business records (Amazon, receipts): The affidavit cites “Amazon records” for CARROLL’s potassium nitrate purchase and delivery, and describes a surveillance-linked pickup by LAI; it also states receipts show LAI purchased PVC pipe found at LAI’s residence. [DOC] (Aff. ¶19–20; ¶26(d))
Reliability is typically high for merchant records as third-party documentation, but the record omits the underlying record extracts (account identifiers, payment methods, order history, and chain-of-custody for the record production), which are needed to evaluate linkage and completeness. [GAP] (Aff. ¶19–20; ¶26(d))
Physical seizures (campsite and residences): The affidavit lists seized items from the campsite and residences and references photographs, including the campsite-component photos and the CARROLL-residence posters photo. [DOC] (Aff. ¶24–26; Aff. p.19 & p.22 photographs)
Reliability evaluation is constrained by absent chain-of-custody details, lab testing results confirming chemical identity (e.g., that “suspected potassium nitrate” is chemically confirmed), and absent forensic results (fingerprints/DNA) tying items to specific individuals. [GAP] (Aff. ¶22 (uses “suspected”); ¶24–26 (lists items without forensics))
Expert assessments (bomb technician): The affidavit relays bomb technician assessments at multiple points: that instructions, if followed, would likely create an operational explosive device; that primers could serve as an initiator; and that the campsite components were readily assemblable into improvised explosive devices and Molotov cocktail devices. [DOC] (Aff. ¶14; ¶18(m); ¶25)
Reliability considerations include the absence of the bomb technician’s full methodology, assumptions, and whether conclusions were based on visual inspection, testing, or standardized criteria; the affidavit provides bottom-line conclusions but not the underlying report. [GAP] (Aff. ¶14; ¶25)
6. Operational Analysis (Tradecraft, Capability, and Imminence)
The alleged operational security measures in the plan and communications include guidance to use burner phones and dispose of them, to avoid carrying personal devices and instead create an alibi/“plausible deniability” signal of device use, to wear layered concealing clothing and gloves/hair concealment to reduce identification and DNA transfer, to alter gait using a pebble in a shoe, to use cash-only purchasing in small quantities split across a team, and to sequester phones during the desert trip using foil/Faraday methods and limited burner-phone availability. [DOC] (Aff. ¶12–13; ¶18(a), ¶18(o), ¶18(f))
Taken together, these measures support an inference that the alleged actors anticipated law-enforcement attention and attempted to reduce attribution and detection risk, which is operationally consistent with planned clandestine action rather than spontaneous conduct, while also indicating possible anxiety about infiltration/surveillance (e.g., PAGE’s statement that the FBI would be “onto them”). [INF] (INF from Aff. ¶12–13 (tradecraft guidance) and ¶17(d) (“100,000 percent” FBI onto them))
The alleged device-construction plan can be summarized at a non-operational level as: the written plan allegedly contains detailed instructions for creating pipe-bomb-type devices using black-powder-type explosive material, and the group allegedly planned to test devices in a remote desert location prior to the New Year’s Eve operation, with procurement and transport of precursor powders, containment materials (pipes), and initiation components (e.g., primers), and with an FBI bomb technician opining the assembled set of components could likely be used for improvised explosive devices and incendiary bottle devices. [DOC] (Aff. ¶14; ¶17(a); ¶18(m); ¶22–25)
Capability indicators in-record include: repeated handling/dissemination of written instructions; procurement activity documented via business records and surveillance; and convergence at a test site with steps described as beginning construction (arranging materials on a table; preparing precursor powder processing; possessing protective gear like respirator/goggles), coupled with the bomb technician’s assessment that instructions could yield an operational device if followed. [INF] (INF from Aff. ¶14–15, ¶19–25)
Countervailing indicators of limitations include PAGE’s Signal statement retracting an earlier claim of specializing in electrical work and stating that building circuits for a digital timer was beyond PAGE, which supports an inference that at least one contemplated timing method may have faced technical constraints, though the record also reflects “rudimentary options” were discussed. [INF] (INF from Aff. ¶18(q))
Imminence within the complaint’s framing is anchored to (i) the planned operational date of December 31, 2025 at midnight, (ii) the stated intent to conduct desert testing on or about December 12, 2025, and (iii) the intervention described as occurring when bomb testing was “imminent,” suggesting an enforcement decision point at the transition from planning/procurement to active device testing. [INF] (INF from Aff. ¶11–12 (Dec 31 timing), ¶18(c) (plan to test), ¶23 (imminent testing signal))
7. Group Structure and Symbolism (Bounded and Comparative Within-Record)
The affidavit’s public-facing characterization of the Turtle Island Liberation Front is grounded in a cited social media page titled “Turtle Island Liberation Front – LA Chapter” described as dedicated to “Liberation through decolonization and tribal sovereignty,” and in the affiant’s description of an Instagram account (@turtleislandliberationfrontla) allegedly operated by CARROLL that posts content advocating violence against United States officials and urging “direct action,” with an example caption quoted in the affidavit. [DOC] (Aff. ¶8–9; ¶17(j))
The affidavit’s internal/cell-facing structure centers on a Signal group titled “Order of the Black Lotus,” which CARROLL allegedly described as a “radical” faction and “our group for everything radical,” and which the affidavit asserts was used to discuss the bombing plot and logistics for desert testing, alongside use of “Operation Midnight Sun” as the code name for the New Year’s Eve bombing plan. [DOC] (Aff. ¶8; ¶18(b)–(d); ¶15 n.4)
Functionally (within-record), this naming pattern supports an inference of a layered identity system: “Turtle Island Liberation Front” as a broader outward-facing banner (social media/Instagram), “Order of the Black Lotus” as a narrower operational coordination channel (encrypted group chat described as “radical”), and “Operation Midnight Sun” as a specific operation identifier enabling participants to discuss a discrete plot as a bounded project with roles, timelines, and logistics. [INF] (INF from Aff. ¶8–10 (public branding) and ¶18(b)–(d) (operational chat) and ¶10–11 (team structure in plan) and ¶15 n.4 (code name))
On the specific question “Are these symbols part of Indigenous resistance traditions,” the affidavit provides only limited and indirect material: it states that “Turtle Island” is a term used by some Native Americans to describe the North American continent, and it quotes the movement’s stated dedication to “decolonization and tribal sovereignty,” but it does not provide evidence that the named defendants or the Turtle Island Liberation Front/Order of the Black Lotus are institutionally connected to Indigenous governance structures, recognized tribal authorities, or specific Indigenous ceremonial/traditional frameworks. [DOC] (Aff. ¶8)
Within-record negative evidence supporting the conclusion that lineage cannot be established from this record includes: the affidavit’s framing of Turtle Island Liberation Front as an “anti-capitalist, anti-government movement” based on “open source information and other evidence,” the operational planning emphasis on clandestine tradecraft and improvised explosive devices, and the absence (in the affidavit’s described excerpts) of specific Indigenous-language terms, named tribal affiliations, or claims of authorization by Indigenous institutions beyond generalized rhetoric. [INF] (INF from Aff. ¶8 (movement framing) and ¶10–14 (operational planning content described) and ¶17–18 (operational recruitment/logistics))
The document therefore does not allow a grounded determination that these symbols/names are (or are not) part of Indigenous resistance traditions; that question remains evidentially unresolved on this single-source record. [GAP] (Aff. ¶8 provides limited context only)
8. Alternative Interpretations and Defenses (Within-Record)
Expressivism/roleplay vs operational intent: A defense could argue the writings and rhetoric were expressive or performative rather than intended for real-world execution, particularly if “content production for a separate group” was a motivating context for meetings. [INF] (INF from Aff. ¶15 (meeting intended as opportunity to produce content for a separate group))
The complaint narrative counters that interpretation by alleging procurement steps, travel to a desert test site, and beginning assembly/testing preparations, which (if proven) are difficult to reconcile with purely expressive intent. [INF] (INF from Aff. ¶19–24 and ¶23 intervention narrative)
What would be decisive includes the full content of the recordings/messages and whether the defendants took concrete steps tied to the identified targets beyond generalized preparation. [GAP] (Aff. ¶15, ¶18, ¶21 references but does not provide full content)
Lack of intent to harm persons (property-only framing): The affidavit reports LAI asked whether people would be at the bombing target locations and that CARROLL responded “in the negative,” adding that if they saw people (e.g., security guard) they would warn them, which could be used to argue an intent focused on property damage rather than casualties. [DOC] (Aff. ¶21(c) n.8)
The counterpoint within-record is that the plan still allegedly involved explosive devices at multiple locations and that the complaint’s charges do not require proof of intent to kill; the primary legal posture is conspiracy and possession of an unregistered destructive device rather than a homicide-related offense. [INF] (INF from Complaint p.1 listing charges; Aff. ¶3 and ¶28 listing counts)
Decisive additional facts would include the specific target locations, timing assumptions about occupancy, and any internal discussion of acceptable collateral effects beyond the single cited exchange. [GAP] (Aff. ¶10 (targets not named); ¶21(c) provides only one exchange)
Mere preparation (no completed device): Because the affidavit states intervention occurred before completion of a functional explosive device, a defense might argue the government stopped conduct at a preparatory stage, and that the “destructive device” charge depends on contested classification of parts rather than an assembled device. [DOC] (Aff. ¶6; ¶25)
The affidavit anticipates this by reporting the bomb technician’s “readily assemblable” assessment and by alleging steps toward assembly at the campsite, which supports the government’s theory under a parts/assemblability framework rather than a completed-device framework. [INF] (INF from Aff. ¶23–25)
Decisive additional facts would include the complete inventory of parts, lab confirmation, and the bomb technician’s full methodology. [GAP] (Aff. ¶24–25 provide conclusion-level summaries)
Misattribution of Signal identities and statements: Because the affidavit relies on Signal messages and alias usage (“Asiginaak,” “AK,” “Nomad,” “Kickwhere”), a defense might contest whether particular messages were authored by the defendants or whether phones/accounts were shared or compromised. [INF] (INF from Aff. ¶18 and n.5 attribution description; Complaint lists aliases)
The government’s within-record answer is that identification relied on surveillance, moniker usage in person and in chat, and business records including location data for phones believed used, but the underlying attribution artifacts are not included here. [DOC] (Aff. ¶18 n.5)
Decisive facts would be forensic device extractions, account identifiers, and correlation of message timestamps with location and possession. [GAP]
Entrapment / improper inducement (undercover involvement): The presence of an undercover FBI employee in the Dec 7 meeting and in the Dec 12 travel could support a defense theory focusing on inducement or government overreach depending on what the undercover FBI employee said/did, but the affidavit excerpts do not supply the undercover FBI employee’s dialogue or any inducement narrative, and the initial plan is alleged to have originated with CARROLL providing a handwritten plan to the confidential human source prior to the undercover FBI employee’s documented role. [INF] (INF from Aff. ¶10 (plan provided Nov 26), ¶17(a) (undercover FBI employee present Dec 7), ¶21(b) (undercover FBI employee traveled Dec 12), and Aff. ¶4 (summarized conversations))
Decisive facts would include full undercover FBI employee recordings/transcripts, instructions given, and the timeline of government suggestion versus defendant-originated planning. [GAP]
Suppression / warrant and seizure vulnerabilities: The affidavit states search warrants were executed at residences and implies surveillance and business-record acquisitions, but does not provide warrant affidavits, probable cause showings, or chain-of-custody details; defenses may challenge searches, seizures, and admissibility, but the record is not sufficient to evaluate those issues. [GAP] (Aff. ¶26 (search warrants executed) and ¶4 (partiality))
9. Case Posture: Likely Next Procedural Steps (Conservative)
Within the four corners of this record, the procedural posture is limited to: a criminal complaint supported by an affidavit “made in support of arrest warrants,” with the magistrate judge attesting by telephone on December 13, 2025, and the affidavit asserting arrests occurred on December 12, 2025 after desert-site intervention. [DOC] (Aff. ¶3; ¶23; Complaint p.1)
The document does not describe what occurred after arrest (initial appearance timing, detention arguments, grand jury actions, or charging evolution), so committee briefing on “what typically follows” would require procedure knowledge not contained in this single-source record. [GAP] (Aff. ¶4 emphasizes the affidavit is not complete and is for probable cause only)
A bounded inference from the charging choice is that, as of this complaint, the government proceeded with conspiracy and unregistered destructive device possession allegations rather than additional substantive bombing/attempt statutes, but this inference remains provisional because the record itself does not explain charging strategy or whether other charges were considered. [INF] (INF from Complaint p.1 listing only two statutes and Aff. ¶28 listing only two counts)
10. Intelligence-Value Takeaways (Committee-Relevant)
Targeting logic (within-record): The plan as described targets “property and facilities operated by two separate companies” affecting interstate/foreign commerce, and schedules detonation at midnight on New Year’s Eve with an explicit stated advantage that fireworks may delay detection, which indicates target selection and timing were integrated with environmental/holiday context to shape response latency. [INF] (INF from Aff. ¶10 (company properties) and ¶12 (fireworks rationale))
Coordination patterns (online/offline integration): The record depicts a multi-channel model: in-person meetings used for plan distribution/recruitment, while encrypted chat was used for logistics (materials lists, travel, desert coordinates, and operational security), culminating in coordinated physical movement to a remote test site. [INF] (INF from Aff. ¶10, ¶15, ¶17 (in-person) and ¶18 (Signal logistics) and ¶21–23 (movement to desert))
Procurement behavior and intervention points: The affidavit highlights procurement through mainstream retail channels (Amazon delivery/pickup; store purchase of primers) alongside explicit operational security guidance (cash-only, splitting purchases, burner accounts), and the decisive intervention point was tied to the transition into test execution (predetermined signal that testing was imminent at the desert campsite). [INF] (INF from Aff. ¶13–14 (procurement guidance), ¶18(a) (burner/cash), ¶19–20 (Amazon records), ¶18(m) (store purchase), and ¶23 (signal/intervention))
Early-warning indicators (non-actionable, policy-relevant, within-record): Indicators suggested by this record include: circulation of a detailed written operational plan with explicit role structure and operational security guidance; migration of a subset of a public-facing movement into a smaller encrypted “radical” operational group; coordinated procurement of mixed precursor/containment/initiator materials combined with explicit anti-attribution guidance; and convergence travel to a remote location described as suitable for live testing. [INF] (INF from Aff. ¶10–14, ¶18, ¶21–23)
Limits on intelligence generalization: The affidavit’s stated partiality and the narrow time window (late Nov to mid-Dec 2025) constrain extrapolation about broader networks beyond the named defendants and the referenced “Co-Conspirators 1 and 2” and “other comrades,” absent additional collection not present here. [INF] (INF from Aff. ¶4 (not complete) and ¶10–11 (“add more if enough comrades”) and ¶15–17 (Co-Conspirators 1 and 2))
11. Gaps and Collection Priorities
Full verbatim copies (or authenticated facsimiles) of the “OPERATION MIDNIGHT SUN” handwritten plan, including any appended pages, markings, and the specific “marks” (targets), are not included in this record even though the plan is central to both counts and is referenced as containing detailed instructions and operational security guidance. [GAP] (Aff. ¶10–14; ¶26(b) indicates a copy found at PAGE’s residence)
Identification of the two targeted companies and the five target locations is withheld (described only as two companies affecting interstate/foreign commerce), which materially limits committee risk assessment regarding sector targeting, geographic distribution, and protective posture. [GAP] (Aff. ¶10)
The audio recording referenced for the December 2 meeting is not provided (only summarized), preventing independent evaluation of tone, intent, assent, and any role of government direction (and is also relevant to potential defenses). [GAP] (Aff. ¶15; Aff. ¶4 (summarization))
The “recorded conversations taken from the co-conspirators’ vehicles” referenced for December 12 are not provided, limiting evaluation of real-time intent statements and whether any participant expressed reluctance, dissent, or conditionality. [GAP] (Aff. ¶21; Aff. ¶4)
Complete Signal logs (with metadata), device forensic extractions, and attribution exhibits mapping aliases to persons are not in the record, even though Signal messages and alias identities are core to agreement/participation proof and to anticipated defenses. [GAP] (Aff. ¶18; ¶18 n.5)
Chain-of-custody documentation and laboratory testing results for seized “suspected” precursor powders and other materials are absent, including confirmatory chemistry and any residue analysis, which is central to proving “destructive device” parts and rebutting lawful-purpose arguments. [GAP] (Aff. ¶22 (uses “suspected”); ¶24–25 (seizure list + technician conclusion))
Individualized possession evidence (who transported which items; who handled which components) is not detailed beyond certain attributions (e.g., CARROLL/PAGE/LAI brought components), leaving constructive-possession questions particularly salient for GAFFIELD under Count Two. [GAP] (Aff. ¶22–23)
The bomb technician’s full written report(s), methodology, and any standardized criteria for “readily assemblable” are not included, even though the technician’s conclusions are load-bearing for Count Two given the affidavit’s statement that intervention occurred before a functional device was completed. [GAP] (Aff. ¶6; ¶25)
Details of the ATF National Registration and Transfer Record query (identifiers checked, scope, and whether aliases were included) are not provided beyond the conclusory statement that no registration record exists, which may become material if identity or naming disputes arise. [GAP] (Aff. ¶27)
The identities, roles, and scope of “Co-Conspirators 1 and 2,” “other comrades,” and any referenced “another group” offering firearms training are not specified, limiting network mapping and the committee’s ability to assess whether the four defendants represent a broader operational set. [GAP] (Aff. ¶10–11 (“add more if enough comrades”); ¶15–17; ¶17(g))
Documentation about confidential human source handling (validation basis, compensation specifics, and debrief reports) is absent beyond the affidavit’s reliability assertions, which constrains independent evaluation of informant credibility and potential bias. [GAP] (Aff. ¶5 n.1; ¶4)
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Appendix: raw analysis text
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1. Executive Summary (Key Judgments + Confidence) The affidavit alleges that an eight-page handwritten plan titled “OPERATION MIDNIGHT SUN” contemplated placing backpacks containing “ieds” (improvised explosive devices) described as “complex pipe bombs,” to be detonated simultaneously at five locations associated with two U.S. companies at midnight on New Year’s Eve 2025 in the Central District of California. [DOC] (Confidence: High) (Aff. ¶5, ¶10–12) doj-criminal-complaint doj-criminal-complaint The complaint and affidavit present a theory that the four named defendants (AUDREY ILLEENE CARROLL, ZACHARY AARON PAGE, DANTE GAFFIELD, and TINA LAI) progressed from planning into execution-phase preparation by acquiring materials, coordinating logistics via the Signal application, and traveling to the Mojave Desert on December 12, 2025 for test construction/detonation before law enforcement intervention. [DOC] (Confidence: High) (Aff. ¶6, ¶18–24; Complaint p.1) doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint The record includes allegations of deliberate operational security planning (burner phones; cash-only purchasing; device-sequestration; clothing/disguise guidance; gait-alteration; and alibi/“plausible deniability” guidance) that, if credited, supports an inference of premeditation rather than impulsive conduct. [INF] (Confidence: Moderate) (INF from Aff. ¶12–14, ¶17–18, ¶21–23) doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint The government’s evidence narrative ties core planning and facilitation roles to CARROLL and PAGE (authorship/dissemination of plans; procurement lists; logistical coordination), and ties LAI and GAFFIELD to recruited participation and material/logistics contributions culminating in presence at the desert test site. [INF] (Confidence: Moderate) (INF from Aff. ¶5–6, ¶10, ¶17–18, ¶21–24) doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint The affidavit states that, after a predetermined signal from an undercover FBI employee, Federal Bureau of Investigation personnel intervened and placed the four defendants into custody while bomb testing was described as “imminent,” and before completion of a functional explosive device. [DOC] (Confidence: High) (Aff. ¶23; Aff. ¶6 (summary framing)) doj-criminal-complaint doj-criminal-complaint The affidavit reports seizure from the desert campsite of materials including potassium nitrate, charcoal/charcoal powder, sulfur powder, PVC pipe pieces, gasoline, glass bottles, cloth items, and “six boxes of primer,” and reports an FBI bomb technician assessment that the components could likely be used to build improvised explosive devices and Molotov cocktail devices and were “readily assemblable.” [DOC] (Confidence: High) (Aff. ¶24–25) doj-criminal-complaint For Count Two, the affidavit’s registration predicate is an asserted Bureau of Alcohol, Tobacco, Firearms and Explosives records check dated December 11, 2025 stating there is no record of any of the four defendants registering any destructive device with the National Registration and Transfer Record. [DOC] (Confidence: High) (Aff. ¶27) doj-criminal-complaint The record distinguishes between a public-facing “Turtle Island Liberation Front – LA Chapter” identity (including an Instagram account the affidavit attributes to CARROLL) and an internal operational chat titled “Order of the Black Lotus” that CARROLL allegedly described as “our group for everything radical,” with “Operation Midnight Sun” functioning as a code name for the specific alleged New Year’s Eve bombing plot. [DOC] (Confidence: Moderate) (Aff. ¶8–10, ¶17–18) doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint The affidavit includes allegations of post–New Year’s Eve target expansion discussions (specifically, discussion of targeting U.S. Immigration and Customs Enforcement agents and vehicles with pipe bombs beginning in January or February 2026), which, if credited, bears on risk assessment beyond the charged conduct even though such conduct is not charged in this complaint. [DOC] (Confidence: Moderate) (Aff. ¶17(i)) doj-criminal-complaint 2. Document Characterization and Procedural Posture The source record consists of a “Criminal Complaint by Telephone or Other Reliable Electronic Means” in the United States District Court for the Central District of California, supported by an attached affidavit sworn by Federal Bureau of Investigation Special Agent Carolyn Thompson. [DOC] (Complaint p.1; Aff. ¶1–4) doj-criminal-complaint doj-criminal-complaint The affidavit explicitly states it is “made in support of arrest warrants and a criminal complaint” against the four named defendants for violations of 18 U.S.C. § 371 (Conspiracy) (Count One) and 26 U.S.C. § 5861(d) (Possession of Unregistered Destructive Device) (Count Two) “on or about December 12, 2025.” [DOC] (Aff. ¶3) doj-criminal-complaint The affiant states that the facts set forth are based on her observations, training/experience, and information from law enforcement personnel and witnesses, and that the affidavit is “intended to show merely” sufficient probable cause and “does not purport to set forth all of my knowledge of or investigation into this matter,” with conversations described “in substance and in part only,” and dates/times “on or about.” [DOC] (Aff. ¶4) doj-criminal-complaint The complaint form lists the alleged offense date “on or about…December 12, 2025,” and the location as “the county of Los Angeles in the Central District of California,” and lists the two charged code sections and offense descriptions (18 U.S.C. § 371—Conspiracy; 26 U.S.C. § 5861(d)—Possession of Unregistered Destructive Device). [DOC] (Complaint p.1) doj-criminal-complaint The complaint identifies the defendants as AUDREY ILLEENE CARROLL (aka “Asiginaak”), ZACHARY AARON PAGE (aka “AK”), DANTE GAFFIELD (aka “Nomad”), and TINA LAI (aka “Kickwhere”). [DOC] (Complaint p.1) doj-criminal-complaint The complaint and concluding page reflect attestation by telephone and the signature/attestation of “Honorable Michael B. Kaufman, United States Magistrate Judge,” with a timestamp “December 13, 2025 at 4:33 PM,” and the affidavit concludes with the same magistrate judge name. [DOC] (Complaint p.1; Aff. concluding attestation) doj-criminal-complaint doj-criminal-complaint The record does not supply the case number (the “Case No.” field appears blank in the provided form), which constrains committee tracking unless separately obtained from docketing systems outside this record. [GAP] (Complaint p.1) doj-criminal-complaint The record does not define “criminal complaint” or “probable cause” as legal standards; the only within-record characterization is the affiant’s statement that the affidavit is intended to show sufficient probable cause and is not complete. [GAP] (Aff. ¶4) doj-criminal-complaint 3. Statutory Elements-to-Facts Matrix Count One: 18 U.S.C. § 371 (Conspiracy) Element (plain language) Strongest alleged facts supporting element Ambiguities / vulnerabilities What would materially strengthen or weaken Agreement (an understanding to commit the charged unlawful objective) The affidavit describes a written operational plan (“OPERATION MIDNIGHT SUN”) contemplating coordinated New Year’s Eve bombings at five locations, and describes dissemination/discussion of that plan across multiple meetings and in a Signal group chat used to discuss the bombing plot and desert testing. [DOC] (Aff. ¶5, ¶10–12, ¶15, ¶18(c)) doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint The record excerpts do not include full verbatim transcripts of meetings or full Signal logs showing explicit assent by each defendant to the New Year’s Eve attack objective, which may leave room to contest the breadth of agreement (e.g., agreement to “test” vs agreement to execute New Year’s Eve bombings). [GAP] (Aff. ¶4 (partiality disclaimer); ¶15 (audio recording referenced); ¶18 (messages referenced)) doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint Strengthen: full authenticated recordings/transcripts and complete chat exports showing explicit agreement, role assignment, and shared intent across all defendants. [GAP] (Implied by Aff. ¶15, ¶18, ¶21 references to recordings/messages) doj-criminal-complaint doj-criminal-complaint ; Weaken: credible evidence that some participants understood discussions as hypothetical/aspirational, or that one or more defendants refused/withdrew and were nonetheless present for unrelated reasons. [GAP] Knowing participation (each defendant knowingly joined) CARROLL is alleged to have provided the plan to the Confidential Human Source and discussed testing explosives in the desert; PAGE is alleged to have been present at the initial plan handoff and to have posted/relayed operational instructions for desert testing; LAI and GAFFIELD are alleged to have been recruited and to have participated in the “Order of the Black Lotus” chat and to have traveled to the desert with the group. [DOC] (Aff. ¶5–6, ¶10, ¶17, ¶18, ¶21) doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint GAFFIELD’s specific material contribution to bomb components is less explicit than CARROLL/PAGE/LAI in the desert-materials paragraph (which expressly names CARROLL, PAGE, and LAI as bringing components), creating potential room to argue mere association/presence for GAFFIELD absent more detail on constructive possession and intent. [INF] (INF from Aff. ¶22 (names CARROLL/PAGE/LAI for components) vs ¶21(a) (GAFFIELD traveled) and ¶23 (GAFFIELD set up tent)) doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint Strengthen: forensic linkage (device residues, fingerprints/DNA), digital attribution (device-to-alias mapping), and explicit statements by each defendant committing to the plan. [GAP] (Aff. ¶4 partiality; ¶18 attribution footnote; ¶25 technical assessment but not forensics) doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint ; Weaken: evidence that one or more defendants were misattributed to a Signal alias or that their participation was coerced/unknowing. [GAP] Overt act(s) (at least one act to advance the conspiracy) The affidavit alleges multiple overt steps: dissemination of the plan; acquisition/procurement activity (e.g., Amazon purchase of potassium nitrate; purchase of primers; coordination of materials and travel logistics); and travel to and setup at the desert campsite with steps described as beginning device construction before arrest. [DOC] (Aff. ¶10–11, ¶17(f), ¶18(a–h), ¶19–24) doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint Many procurement items are lawful in isolation, so the overt-act force depends heavily on context (plan document + coordination + convergence at test site) rather than any single purchase. [INF] (INF from Aff. ¶14 (instructions likely yield operational device), ¶18 (list of components + burner phones), ¶21–24 (convergence + setup + seizure list)) doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint Strengthen: proof of additional overt acts tied to the New Year’s Eve targets (e.g., target surveillance evidence, reconnaissance artifacts, specific backpacks/timers assembled, or physical casing preparations). [GAP] (Aff. ¶13 discusses pre-op surveillance conceptually but does not provide target-surveillance evidence) doj-criminal-complaint ; Weaken: proof that the desert trip and materials had an alternative lawful purpose unrelated to explosive construction, though the plan document and bomb-technician assessments would still need to be addressed. [GAP] Count Two: 26 U.S.C. § 5861(d) (Possession of Unregistered Destructive Device) Element (plain language) Strongest alleged facts supporting element Ambiguities / vulnerabilities What would materially strengthen or weaken Possession (actual or constructive possession by defendants) The affidavit asserts that, at the desert campsite, the group had bomb-making materials present and being arranged on a table, and that FBI personnel seized enumerated components; it also asserts that CARROLL, PAGE, and LAI “all brought bomb-making components” to the campsite. [DOC] (Aff. ¶22–24) doj-criminal-complaint doj-criminal-complaint GAFFIELD is not expressly named as bringing components in the paragraph listing who brought bomb-making components, creating a potential possession-element vulnerability as to GAFFIELD unless constructive possession is supported by additional evidence not included here. [INF] (INF from Aff. ¶22 (CARROLL/PAGE/LAI brought components) and ¶23 (GAFFIELD set up tent behind table) and ¶21(a) (GAFFIELD traveled)) doj-criminal-complaint doj-criminal-complaint Strengthen: individualized proof of dominion/control over specific items (e.g., who transported which items, fingerprints/DNA on containers/pipes, admissions, or video of handling). [GAP] (Aff. ¶4 partiality; ¶24 list but not individualized attribution) doj-criminal-complaint doj-criminal-complaint ; Weaken: evidence that certain items were not under a defendant’s control/knowledge or were introduced without their awareness. [GAP] “Destructive device” / readily assemblable (device or parts meeting statutory definition; “readily assemblable” per affidavit) The affidavit reports an FBI bomb technician determination that the components seized “could likely be used to build” improvised explosive devices and Molotov cocktail devices and that the components were “readily assemblable,” and separately reports that bomb-making instructions in the plan, if followed, would likely create an operational explosive device. [DOC] (Aff. ¶14–15, ¶25) doj-criminal-complaint doj-criminal-complaint The affidavit also reports law enforcement intervened before completion of a functional explosive device, which may shift litigation onto whether the seized items constitute a “destructive device” or a “combination of parts” under the statute, an issue the affidavit addresses via “readily assemblable” language but does not fully litigate in-record. [INF] (INF from Aff. ¶6, ¶25) doj-criminal-complaint doj-criminal-complaint Strengthen: laboratory confirmation of chemical identities, expert report details, demonstrative reconstruction testing under controlled conditions, and full documentation of all parts present (including any end-cap or closure components). [GAP] (Aff. ¶25 includes technician conclusion and a note about missing “end caps” without full report) doj-criminal-complaint ; Weaken: expert re-evaluation concluding parts were not readily assemblable into a statutory destructive device without substantial additional materials/steps. [GAP] Registration status (device not registered as required) The affidavit states that an ATF records check on December 11, 2025 found no record of any of the four defendants registering any destructive device with the National Registration and Transfer Record. [DOC] (Aff. ¶27) doj-criminal-complaint The record does not provide the underlying ATF query details (identifiers used; scope; whether aliases were checked), which may matter if identity records are contested. [GAP] (Aff. ¶27) doj-criminal-complaint Strengthen: production of ATF certification/records custodian declaration and identity linkage demonstrating the search covered all relevant names/aliases. [GAP] (Aff. ¶27 provides conclusion only) doj-criminal-complaint ; Weaken: credible evidence that the device/parts were not registrable under the applicable statutory definition or that the records check was incomplete/mismatched to the defendants. [GAP] 4. Chronology (Timeline with Evidence Trails) November 26, 2025 (in-person meeting; plan dissemination): The affidavit states the confidential human source met with two Turtle Island Liberation Front members—“Asiginaak” (later identified as CARROLL) and “AK” (later identified as PAGE)—and that CARROLL provided the confidential human source an eight-page handwritten document titled “OPERATION MIDNIGHT SUN,” with the confidential human source observing CARROLL appeared to possess three to four additional copies; the document described five “marks” (target locations) with additional blank slots labeled “add more if enough comrades,” and the affidavit characterizes the targets as properties/facilities of two separate companies affecting interstate/foreign commerce. [DOC] (Aff. ¶10) doj-criminal-complaint Late November 2025 (summary framing): In the affidavit’s summary section, the affiant states that “in late November 2025” CARROLL provided the confidential human source the eight-page plan describing a bombing plot and discussed the prospect of testing explosives “in the desert” in mid-December 2025, with PAGE present. [DOC] (Aff. ¶5) doj-criminal-complaint December 2, 2025 (evening; in-person meeting; audio recording referenced): The affidavit states that, based on the confidential human source and review of an audio recording, another in-person meeting occurred between the confidential human source, CARROLL, and PAGE in or around downtown Los Angeles, with “Co-Conspirators 1 and 2” present; the confidential human source saw CARROLL provide a copy of the handwritten attack plan to Co-Conspirator 1, and Co-Conspirator 1 expressed concern about timeline, while Co-Conspirator 2 was present and was described by CARROLL as potentially providing off-ground support such as monitoring police scanners. [DOC] (Aff. ¶15) doj-criminal-complaint December 2, 2025 (approx. 11:30 p.m.; surveillance to motel): The affidavit states FBI agents conducting surveillance saw CARROLL depart the downtown Los Angeles location with Co-Conspirator 2 and followed them to a motel in the Pico-Robertson neighborhood, and that surveillance then saw Co-Conspirator 2 shortly thereafter with no passengers, indicating CARROLL had been dropped off at the motel. [DOC] (Aff. ¶16) doj-criminal-complaint December 3, 2025 (Signal direct communications; procurement list): The affidavit states the confidential human source communicated with CARROLL via Signal, and that CARROLL provided a list identifying components/chemicals/tools (with prices) required to create pipe bombs, with some components noted as already purchased or assigned to another “comrade,” and that CARROLL stated they should purchase burner phones “bought with cash only.” [DOC] (Aff. ¶18(a)) doj-criminal-complaint December 5, 2025 (Signal group characterization; “Order of the Black Lotus”): The affidavit states multiple co-conspirators used a Signal group titled “Order of the Black Lotus,” and that on December 5, 2025 CARROLL wrote the group was “our group for everything radical.” [DOC] (Aff. ¶18(b)) doj-criminal-complaint On or about December 5, 2025 (desert-testing instructions relayed to confidential human source): The affidavit states CARROLL forwarded to the confidential human source instructions for desert testing originally posted by PAGE in the Black Lotus group, including geocoordinates corresponding to Lucerne Valley, California, a satellite map screenshot with markings for camp and test areas, and statements about a “morning group” and PAGE meeting at night, along with phone-handling instructions (only two burners for emergencies; phones sealed in a box wrapped in aluminum until leaving). [DOC] (Aff. ¶18(d)–(f)) doj-criminal-complaint December 7, 2025 (early morning; in-person recruitment/briefing with undercover FBI employee present): The affidavit states that the confidential human source and an undercover FBI employee met with CARROLL, PAGE, and a male known as “NOMAD” later identified as GAFFIELD; CARROLL stated she had “the plan” and handed GAFFIELD four sheets of paper, and the undercover FBI employee later told law enforcement the papers contained detailed instructions on how to construct a black powder pipe bomb; PAGE stated it was “100,000 percent” that the FBI would be onto them; and CARROLL stated she had components including “13 PVC pipes” and potassium nitrate ordered on Amazon via a burner account for delivery December 11. [DOC] (Aff. ¶17(a), ¶17(d), ¶17(f)) doj-criminal-complaint doj-criminal-complaint December 7, 2025 (future-attacks discussion; not charged here): The affidavit states CARROLL and PAGE discussed plans for future attacks after the New Year’s Eve bombings, specifically targeting U.S. Immigration and Customs Enforcement agents and vehicles with pipe bombs beginning in January or February 2026. [DOC] (Aff. ¶17(i)) doj-criminal-complaint December 7, 2025 (business records; potassium nitrate purchase): The affidavit states that, according to Amazon records, CARROLL purchased two five-pound bags of potassium nitrate for delivery to an Amazon Counter at a Whole Foods location in Los Angeles, California, and that the potassium nitrate was delivered on December 11, 2025. [DOC] (Aff. ¶19) doj-criminal-complaint December 8, 2025 (Signal; LAI confirms desert travel; equipment): The affidavit states LAI, using the Signal alias “Kickwhere,” wrote to the group confirming LAI would be going to the desert and had a cargo box on top of their vehicle for camping gear. [DOC] (Aff. ¶18(g)) doj-criminal-complaint December 8–9, 2025 (Signal; fuse-material discussion): The affidavit states that during an exchange about shoelaces/cotton string discussed in context as fuse material, LAI posted photographs depicting string and what appear to be packages of shoelaces, and on December 9 LAI sent a photo of twine and asked if it would work, with PAGE responding that PAGE thought it would and that they could test it. [DOC] (Aff. ¶18(h); ¶18(k)) doj-criminal-complaint doj-criminal-complaint December 10, 2025 (Signal + surveillance; procurement and tradecraft): The affidavit states PAGE messaged the group that “ingredients” were acquired and the “starter” would be acquired that evening, and the affiant states that agents conducting surveillance saw PAGE obtain a package from an Amazon pickup location shortly before the message; the affidavit also states agents saw PAGE purchasing pistol primers in Irvine, California while wearing a medical mask, gloves, ball cap, and long-sleeve shirt, and that (per a bomb technician) the primers could serve as an initiator for an improvised explosive device. [DOC] (Aff. ¶18(l)–(m)) doj-criminal-complaint December 10–11, 2025 (Signal; desert travel comms security): The affidavit states PAGE wrote guidance that only burner phones should be present (with non-navigators’ phones wrapped in foil or a Faraday bag for the trip) and instructed installation of an “open source maps” application to avoid “corporate tracking,” and that on December 11 PAGE wrote that building circuits for a digital timer was beyond PAGE (while “rudimentary options” still existed). [DOC] (Aff. ¶18(o), ¶18(q)) doj-criminal-complaint On or about December 10, 2025 (CARROLL direct message to confidential human source): The affidavit states CARROLL messaged the confidential human source about having a notebook of multiple plans (“my terrorist diary”) and stated “I have to get rid of that.” [DOC] (Aff. ¶18(r)) doj-criminal-complaint On or about December 11, 2025 (pickup of delivered potassium nitrate): The affidavit states that, based on Signal communications and surveillance on LAI, LAI picked up the box of potassium nitrate referenced in the Amazon records on or about December 11, 2025. [DOC] (Aff. ¶20) doj-criminal-complaint December 11, 2025 (ATF records check re registration): The affidavit states that on December 11, 2025 an ATF records check found no record of any defendant registering any destructive device with the National Registration and Transfer Record. [DOC] (Aff. ¶27) doj-criminal-complaint December 12, 2025 (morning; travel to desert; vehicle recordings referenced): The affidavit states that on the morning of December 12, 2025, the four defendants traveled to in or around Lucerne Valley in two vehicles, with the confidential human source riding with CARROLL and LAI and the undercover FBI employee riding with PAGE and GAFFIELD, and that the affiant’s knowledge comes in part from recorded conversations from the vehicles and surveillance footage; the affidavit reports that CARROLL described the day as a “test run” for the New Year’s Eve plot and stated “What we’re doing will be considered a terrorist act.” [DOC] (Aff. ¶21(a)–(c)) doj-criminal-complaint December 12, 2025 (approx. 10:00 a.m.; arrival; campsite setup): The affidavit states the co-conspirators arrived at the desert at approximately 10:00 a.m. and began setting up a campsite, and that (based on the undercover FBI employee and confidential human source) CARROLL, PAGE, and LAI brought bomb-making components including PVC pipes and suspected precursor powders and fuse materials; photographs in the affidavit depict some of these components on a table at the site. [DOC] (Aff. ¶22; Aff. p.19 photographs) doj-criminal-complaint December 12, 2025 (shortly after; intervention and arrests): The affidavit states that, shortly after transferring components from vehicles, CARROLL, PAGE, and LAI began setting up materials on a table and GAFFIELD and others set up a tent behind the table; it states that after the undercover FBI employee alerted law enforcement with a predetermined signal indicating bomb testing was imminent, Federal Bureau of Investigation personnel intervened and placed CARROLL, PAGE, GAFFIELD, and LAI into custody. [DOC] (Aff. ¶23) doj-criminal-complaint December 12, 2025 (post-arrest; campsite search and bomb technician assessment): The affidavit lists items seized from the campsite (including potassium nitrate, charcoal, sulfur, PVC pipes, gasoline, glass bottles, cloth/twine items, respirator/goggles, and primer) and reports an FBI bomb technician concluded components could likely be used to build improvised explosive devices and Molotov cocktail devices and were “readily assemblable.” [DOC] (Aff. ¶24–25) doj-criminal-complaint December 12, 2025 (residence searches; additional seizures): The affidavit states search warrants were executed at the defendants’ residences and items seized included: in CARROLL’s residence, posters/materials associated with Turtle Island Liberation Front (with a photograph depicting “TURTLE ISLAND LIBERATION FRONT” signage and slogans including “DEATH TO ICE!!!”); in PAGE’s residence, a copy of the handwritten “Operation Midnight Sun” plan; in GAFFIELD’s residence, a Taser device that records indicate was stolen from the U.S. Federal Protective Service; and in LAI’s residence, a metal saw next to PVC shards, additional PVC pipe with receipts, and handwritten notes reflecting ideologies aligned with Turtle Island Liberation Front. [DOC] (Aff. ¶26; Aff. p.22 photograph) doj-criminal-complaint December 13, 2025 (complaint attestation): The complaint reflects attestation by telephone and the magistrate judge’s name, with the timestamp “December 13, 2025 at 4:33 PM.” [DOC] (Complaint p.1) doj-criminal-complaint 5. Evidence Inventory and Reliability Assessment Confidential Human Source reporting (including background, compensation, reliability claims): The affidavit states the confidential human source is “validated and vetted,” has been reliable since in or around August 2021, is cooperating for financial compensation, has no criminal history, and has provided past reliable reporting and reliable reporting in this case. [DOC] (Aff. ¶5 n.1) doj-criminal-complaint The confidential human source is described as a participant/witness to multiple in-person meetings (Nov 26; Dec 2; Dec 7) and as a recipient of Signal communications and forwarded “Order of the Black Lotus” instructions, which makes the confidential human source a central evidentiary conduit for both direct observations and message content. [DOC] (Aff. ¶10, ¶15, ¶17, ¶18) doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint Reliability considerations include the affidavit’s acknowledgement of compensation (potential bias) and the fact that many claims are relayed through the affiant rather than presented as full transcripts, creating a hearsay and summarization layer even where the confidential human source may have firsthand knowledge. [INF] (INF from Aff. ¶4 (summarization/partiality) and ¶5 n.1 (compensation)) doj-criminal-complaint doj-criminal-complaint Missing for reliability evaluation are handling documentation (source validation details, payment history beyond the bare statement, debriefing reports) and the underlying audio/message extracts referenced by the affidavit. [GAP] (Aff. ¶4, ¶15, ¶18) Undercover FBI employee presence and recordings: The affidavit states an undercover FBI employee was present at the Dec 7 meeting and traveled with PAGE and GAFFIELD to the desert, and that the undercover FBI employee gave a predetermined signal indicating bomb testing was imminent, triggering intervention. [DOC] (Aff. ¶17, ¶21–23) doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint The undercover FBI employee’s presence provides a direct law-enforcement witness layer that can corroborate or contradict confidential human source reporting, but the affidavit still summarizes rather than reproducing full undercover FBI employee reports/recordings, which constrains an independent committee assessment of context and potential inducement issues. [INF] (INF from Aff. ¶4 (partiality) and ¶17(a) (undercover FBI employee present) and ¶21 (recorded conversations referenced)) doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint Signal communications and attribution basis: The affidavit describes Signal communications between the confidential human source and CARROLL and a group chat titled “Order of the Black Lotus,” including quotes and logistical instructions, and includes a footnote stating agents identified the co-conspirators based on surveillance, monikers used in-person and in Signal, and business records including location data associated with phones believed used. [DOC] (Aff. ¶18; Aff. ¶18 n.5) doj-criminal-complaint doj-criminal-complaint Reliability considerations include (i) whether the Signal content is complete and forensically preserved or selectively provided via the confidential human source, and (ii) whether attribution from alias-to-person rests on robust device/account linkage versus inference from behavior and location data; the affidavit asserts attribution methods but does not provide the underlying technical exhibits. [INF] (INF from Aff. ¶18 (messages “provided by the CHS”) and n.5 (attribution methods described)) doj-criminal-complaint doj-criminal-complaint Surveillance observations (physical and digital): The affidavit includes asserted surveillance observations such as: FBI agents saw CARROLL depart a downtown location with Co-Conspirator 2 and go to a motel; agents saw PAGE pick up an Amazon package and later buy pistol primers while dressed to obscure identity; and agents observed LAI’s residence and saw a vehicle with a roof cargo box. [DOC] (Aff. ¶16; ¶18(l)–(m); ¶18 n.6) doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint Reliability considerations are generally stronger than hearsay for agent firsthand observations, but the record omits the contemporaneous surveillance logs, photos/video, and the precise legal process used for any location-data acquisition. [GAP] (Aff. ¶4; ¶18 n.5 implies location-data reliance without providing it) doj-criminal-complaint doj-criminal-complaint Business records (Amazon, receipts): The affidavit cites “Amazon records” for CARROLL’s potassium nitrate purchase and delivery, and describes a surveillance-linked pickup by LAI; it also states receipts show LAI purchased PVC pipe found at LAI’s residence. [DOC] (Aff. ¶19–20; ¶26(d)) doj-criminal-complaint doj-criminal-complaint Reliability is typically high for merchant records as third-party documentation, but the record omits the underlying record extracts (account identifiers, payment methods, order history, and chain-of-custody for the record production), which are needed to evaluate linkage and completeness. [GAP] (Aff. ¶19–20; ¶26(d)) Physical seizures (campsite and residences): The affidavit lists seized items from the campsite and residences and references photographs, including the campsite-component photos and the CARROLL-residence posters photo. [DOC] (Aff. ¶24–26; Aff. p.19 & p.22 photographs) doj-criminal-complaint doj-criminal-complaint Reliability evaluation is constrained by absent chain-of-custody details, lab testing results confirming chemical identity (e.g., that “suspected potassium nitrate” is chemically confirmed), and absent forensic results (fingerprints/DNA) tying items to specific individuals. [GAP] (Aff. ¶22 (uses “suspected”); ¶24–26 (lists items without forensics)) doj-criminal-complaint doj-criminal-complaint Expert assessments (bomb technician): The affidavit relays bomb technician assessments at multiple points: that instructions, if followed, would likely create an operational explosive device; that primers could serve as an initiator; and that the campsite components were readily assemblable into improvised explosive devices and Molotov cocktail devices. [DOC] (Aff. ¶14; ¶18(m); ¶25) doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint Reliability considerations include the absence of the bomb technician’s full methodology, assumptions, and whether conclusions were based on visual inspection, testing, or standardized criteria; the affidavit provides bottom-line conclusions but not the underlying report. [GAP] (Aff. ¶14; ¶25) 6. Operational Analysis (Tradecraft, Capability, and Imminence) The alleged operational security measures in the plan and communications include guidance to use burner phones and dispose of them, to avoid carrying personal devices and instead create an alibi/“plausible deniability” signal of device use, to wear layered concealing clothing and gloves/hair concealment to reduce identification and DNA transfer, to alter gait using a pebble in a shoe, to use cash-only purchasing in small quantities split across a team, and to sequester phones during the desert trip using foil/Faraday methods and limited burner-phone availability. [DOC] (Aff. ¶12–13; ¶18(a), ¶18(o), ¶18(f)) doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint Taken together, these measures support an inference that the alleged actors anticipated law-enforcement attention and attempted to reduce attribution and detection risk, which is operationally consistent with planned clandestine action rather than spontaneous conduct, while also indicating possible anxiety about infiltration/surveillance (e.g., PAGE’s statement that the FBI would be “onto them”). [INF] (INF from Aff. ¶12–13 (tradecraft guidance) and ¶17(d) (“100,000 percent” FBI onto them)) doj-criminal-complaint doj-criminal-complaint The alleged device-construction plan can be summarized at a non-operational level as: the written plan allegedly contains detailed instructions for creating pipe-bomb-type devices using black-powder-type explosive material, and the group allegedly planned to test devices in a remote desert location prior to the New Year’s Eve operation, with procurement and transport of precursor powders, containment materials (pipes), and initiation components (e.g., primers), and with an FBI bomb technician opining the assembled set of components could likely be used for improvised explosive devices and incendiary bottle devices. [DOC] (Aff. ¶14; ¶17(a); ¶18(m); ¶22–25) doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint Capability indicators in-record include: repeated handling/dissemination of written instructions; procurement activity documented via business records and surveillance; and convergence at a test site with steps described as beginning construction (arranging materials on a table; preparing precursor powder processing; possessing protective gear like respirator/goggles), coupled with the bomb technician’s assessment that instructions could yield an operational device if followed. [INF] (INF from Aff. ¶14–15, ¶19–25) doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint Countervailing indicators of limitations include PAGE’s Signal statement retracting an earlier claim of specializing in electrical work and stating that building circuits for a digital timer was beyond PAGE, which supports an inference that at least one contemplated timing method may have faced technical constraints, though the record also reflects “rudimentary options” were discussed. [INF] (INF from Aff. ¶18(q)) doj-criminal-complaint Imminence within the complaint’s framing is anchored to (i) the planned operational date of December 31, 2025 at midnight, (ii) the stated intent to conduct desert testing on or about December 12, 2025, and (iii) the intervention described as occurring when bomb testing was “imminent,” suggesting an enforcement decision point at the transition from planning/procurement to active device testing. [INF] (INF from Aff. ¶11–12 (Dec 31 timing), ¶18(c) (plan to test), ¶23 (imminent testing signal)) doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint 7. Group Structure and Symbolism (Bounded and Comparative Within-Record) The affidavit’s public-facing characterization of the Turtle Island Liberation Front is grounded in a cited social media page titled “Turtle Island Liberation Front – LA Chapter” described as dedicated to “Liberation through decolonization and tribal sovereignty,” and in the affiant’s description of an Instagram account (@turtleislandliberationfrontla) allegedly operated by CARROLL that posts content advocating violence against United States officials and urging “direct action,” with an example caption quoted in the affidavit. [DOC] (Aff. ¶8–9; ¶17(j)) doj-criminal-complaint doj-criminal-complaint The affidavit’s internal/cell-facing structure centers on a Signal group titled “Order of the Black Lotus,” which CARROLL allegedly described as a “radical” faction and “our group for everything radical,” and which the affidavit asserts was used to discuss the bombing plot and logistics for desert testing, alongside use of “Operation Midnight Sun” as the code name for the New Year’s Eve bombing plan. [DOC] (Aff. ¶8; ¶18(b)–(d); ¶15 n.4) doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint Functionally (within-record), this naming pattern supports an inference of a layered identity system: “Turtle Island Liberation Front” as a broader outward-facing banner (social media/Instagram), “Order of the Black Lotus” as a narrower operational coordination channel (encrypted group chat described as “radical”), and “Operation Midnight Sun” as a specific operation identifier enabling participants to discuss a discrete plot as a bounded project with roles, timelines, and logistics. [INF] (INF from Aff. ¶8–10 (public branding) and ¶18(b)–(d) (operational chat) and ¶10–11 (team structure in plan) and ¶15 n.4 (code name)) doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint On the specific question “Are these symbols part of Indigenous resistance traditions,” the affidavit provides only limited and indirect material: it states that “Turtle Island” is a term used by some Native Americans to describe the North American continent, and it quotes the movement’s stated dedication to “decolonization and tribal sovereignty,” but it does not provide evidence that the named defendants or the Turtle Island Liberation Front/Order of the Black Lotus are institutionally connected to Indigenous governance structures, recognized tribal authorities, or specific Indigenous ceremonial/traditional frameworks. [DOC] (Aff. ¶8) doj-criminal-complaint Within-record negative evidence supporting the conclusion that lineage cannot be established from this record includes: the affidavit’s framing of Turtle Island Liberation Front as an “anti-capitalist, anti-government movement” based on “open source information and other evidence,” the operational planning emphasis on clandestine tradecraft and improvised explosive devices, and the absence (in the affidavit’s described excerpts) of specific Indigenous-language terms, named tribal affiliations, or claims of authorization by Indigenous institutions beyond generalized rhetoric. [INF] (INF from Aff. ¶8 (movement framing) and ¶10–14 (operational planning content described) and ¶17–18 (operational recruitment/logistics)) doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint The document therefore does not allow a grounded determination that these symbols/names are (or are not) part of Indigenous resistance traditions; that question remains evidentially unresolved on this single-source record. [GAP] (Aff. ¶8 provides limited context only) doj-criminal-complaint 8. Alternative Interpretations and Defenses (Within-Record) Expressivism/roleplay vs operational intent: A defense could argue the writings and rhetoric were expressive or performative rather than intended for real-world execution, particularly if “content production for a separate group” was a motivating context for meetings. [INF] (INF from Aff. ¶15 (meeting intended as opportunity to produce content for a separate group)) doj-criminal-complaint The complaint narrative counters that interpretation by alleging procurement steps, travel to a desert test site, and beginning assembly/testing preparations, which (if proven) are difficult to reconcile with purely expressive intent. [INF] (INF from Aff. ¶19–24 and ¶23 intervention narrative) doj-criminal-complaint doj-criminal-complaint What would be decisive includes the full content of the recordings/messages and whether the defendants took concrete steps tied to the identified targets beyond generalized preparation. [GAP] (Aff. ¶15, ¶18, ¶21 references but does not provide full content) doj-criminal-complaint doj-criminal-complaint Lack of intent to harm persons (property-only framing): The affidavit reports LAI asked whether people would be at the bombing target locations and that CARROLL responded “in the negative,” adding that if they saw people (e.g., security guard) they would warn them, which could be used to argue an intent focused on property damage rather than casualties. [DOC] (Aff. ¶21(c) n.8) doj-criminal-complaint The counterpoint within-record is that the plan still allegedly involved explosive devices at multiple locations and that the complaint’s charges do not require proof of intent to kill; the primary legal posture is conspiracy and possession of an unregistered destructive device rather than a homicide-related offense. [INF] (INF from Complaint p.1 listing charges; Aff. ¶3 and ¶28 listing counts) doj-criminal-complaint doj-criminal-complaint Decisive additional facts would include the specific target locations, timing assumptions about occupancy, and any internal discussion of acceptable collateral effects beyond the single cited exchange. [GAP] (Aff. ¶10 (targets not named); ¶21(c) provides only one exchange) doj-criminal-complaint doj-criminal-complaint Mere preparation (no completed device): Because the affidavit states intervention occurred before completion of a functional explosive device, a defense might argue the government stopped conduct at a preparatory stage, and that the “destructive device” charge depends on contested classification of parts rather than an assembled device. [DOC] (Aff. ¶6; ¶25) doj-criminal-complaint doj-criminal-complaint The affidavit anticipates this by reporting the bomb technician’s “readily assemblable” assessment and by alleging steps toward assembly at the campsite, which supports the government’s theory under a parts/assemblability framework rather than a completed-device framework. [INF] (INF from Aff. ¶23–25) doj-criminal-complaint doj-criminal-complaint Decisive additional facts would include the complete inventory of parts, lab confirmation, and the bomb technician’s full methodology. [GAP] (Aff. ¶24–25 provide conclusion-level summaries) doj-criminal-complaint Misattribution of Signal identities and statements: Because the affidavit relies on Signal messages and alias usage (“Asiginaak,” “AK,” “Nomad,” “Kickwhere”), a defense might contest whether particular messages were authored by the defendants or whether phones/accounts were shared or compromised. [INF] (INF from Aff. ¶18 and n.5 attribution description; Complaint lists aliases) doj-criminal-complaint doj-criminal-complaint The government’s within-record answer is that identification relied on surveillance, moniker usage in person and in chat, and business records including location data for phones believed used, but the underlying attribution artifacts are not included here. [DOC] (Aff. ¶18 n.5) doj-criminal-complaint Decisive facts would be forensic device extractions, account identifiers, and correlation of message timestamps with location and possession. [GAP] Entrapment / improper inducement (undercover involvement): The presence of an undercover FBI employee in the Dec 7 meeting and in the Dec 12 travel could support a defense theory focusing on inducement or government overreach depending on what the undercover FBI employee said/did, but the affidavit excerpts do not supply the undercover FBI employee’s dialogue or any inducement narrative, and the initial plan is alleged to have originated with CARROLL providing a handwritten plan to the confidential human source prior to the undercover FBI employee’s documented role. [INF] (INF from Aff. ¶10 (plan provided Nov 26), ¶17(a) (undercover FBI employee present Dec 7), ¶21(b) (undercover FBI employee traveled Dec 12), and Aff. ¶4 (summarized conversations)) doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint Decisive facts would include full undercover FBI employee recordings/transcripts, instructions given, and the timeline of government suggestion versus defendant-originated planning. [GAP] Suppression / warrant and seizure vulnerabilities: The affidavit states search warrants were executed at residences and implies surveillance and business-record acquisitions, but does not provide warrant affidavits, probable cause showings, or chain-of-custody details; defenses may challenge searches, seizures, and admissibility, but the record is not sufficient to evaluate those issues. [GAP] (Aff. ¶26 (search warrants executed) and ¶4 (partiality)) doj-criminal-complaint doj-criminal-complaint 9. Case Posture: Likely Next Procedural Steps (Conservative) Within the four corners of this record, the procedural posture is limited to: a criminal complaint supported by an affidavit “made in support of arrest warrants,” with the magistrate judge attesting by telephone on December 13, 2025, and the affidavit asserting arrests occurred on December 12, 2025 after desert-site intervention. [DOC] (Aff. ¶3; ¶23; Complaint p.1) doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint The document does not describe what occurred after arrest (initial appearance timing, detention arguments, grand jury actions, or charging evolution), so committee briefing on “what typically follows” would require procedure knowledge not contained in this single-source record. [GAP] (Aff. ¶4 emphasizes the affidavit is not complete and is for probable cause only) doj-criminal-complaint A bounded inference from the charging choice is that, as of this complaint, the government proceeded with conspiracy and unregistered destructive device possession allegations rather than additional substantive bombing/attempt statutes, but this inference remains provisional because the record itself does not explain charging strategy or whether other charges were considered. [INF] (INF from Complaint p.1 listing only two statutes and Aff. ¶28 listing only two counts) doj-criminal-complaint doj-criminal-complaint 10. Intelligence-Value Takeaways (Committee-Relevant) Targeting logic (within-record): The plan as described targets “property and facilities operated by two separate companies” affecting interstate/foreign commerce, and schedules detonation at midnight on New Year’s Eve with an explicit stated advantage that fireworks may delay detection, which indicates target selection and timing were integrated with environmental/holiday context to shape response latency. [INF] (INF from Aff. ¶10 (company properties) and ¶12 (fireworks rationale)) doj-criminal-complaint doj-criminal-complaint Coordination patterns (online/offline integration): The record depicts a multi-channel model: in-person meetings used for plan distribution/recruitment, while encrypted chat was used for logistics (materials lists, travel, desert coordinates, and operational security), culminating in coordinated physical movement to a remote test site. [INF] (INF from Aff. ¶10, ¶15, ¶17 (in-person) and ¶18 (Signal logistics) and ¶21–23 (movement to desert)) doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint Procurement behavior and intervention points: The affidavit highlights procurement through mainstream retail channels (Amazon delivery/pickup; store purchase of primers) alongside explicit operational security guidance (cash-only, splitting purchases, burner accounts), and the decisive intervention point was tied to the transition into test execution (predetermined signal that testing was imminent at the desert campsite). [INF] (INF from Aff. ¶13–14 (procurement guidance), ¶18(a) (burner/cash), ¶19–20 (Amazon records), ¶18(m) (store purchase), and ¶23 (signal/intervention)) doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint Early-warning indicators (non-actionable, policy-relevant, within-record): Indicators suggested by this record include: circulation of a detailed written operational plan with explicit role structure and operational security guidance; migration of a subset of a public-facing movement into a smaller encrypted “radical” operational group; coordinated procurement of mixed precursor/containment/initiator materials combined with explicit anti-attribution guidance; and convergence travel to a remote location described as suitable for live testing. [INF] (INF from Aff. ¶10–14, ¶18, ¶21–23) doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint Limits on intelligence generalization: The affidavit’s stated partiality and the narrow time window (late Nov to mid-Dec 2025) constrain extrapolation about broader networks beyond the named defendants and the referenced “Co-Conspirators 1 and 2” and “other comrades,” absent additional collection not present here. [INF] (INF from Aff. ¶4 (not complete) and ¶10–11 (“add more if enough comrades”) and ¶15–17 (Co-Conspirators 1 and 2)) doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint 11. Gaps and Collection Priorities Full verbatim copies (or authenticated facsimiles) of the “OPERATION MIDNIGHT SUN” handwritten plan, including any appended pages, markings, and the specific “marks” (targets), are not included in this record even though the plan is central to both counts and is referenced as containing detailed instructions and operational security guidance. [GAP] (Aff. ¶10–14; ¶26(b) indicates a copy found at PAGE’s residence) doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint Identification of the two targeted companies and the five target locations is withheld (described only as two companies affecting interstate/foreign commerce), which materially limits committee risk assessment regarding sector targeting, geographic distribution, and protective posture. [GAP] (Aff. ¶10) doj-criminal-complaint The audio recording referenced for the December 2 meeting is not provided (only summarized), preventing independent evaluation of tone, intent, assent, and any role of government direction (and is also relevant to potential defenses). [GAP] (Aff. ¶15; Aff. ¶4 (summarization)) doj-criminal-complaint doj-criminal-complaint The “recorded conversations taken from the co-conspirators’ vehicles” referenced for December 12 are not provided, limiting evaluation of real-time intent statements and whether any participant expressed reluctance, dissent, or conditionality. [GAP] (Aff. ¶21; Aff. ¶4) doj-criminal-complaint doj-criminal-complaint Complete Signal logs (with metadata), device forensic extractions, and attribution exhibits mapping aliases to persons are not in the record, even though Signal messages and alias identities are core to agreement/participation proof and to anticipated defenses. [GAP] (Aff. ¶18; ¶18 n.5) doj-criminal-complaint doj-criminal-complaint Chain-of-custody documentation and laboratory testing results for seized “suspected” precursor powders and other materials are absent, including confirmatory chemistry and any residue analysis, which is central to proving “destructive device” parts and rebutting lawful-purpose arguments. [GAP] (Aff. ¶22 (uses “suspected”); ¶24–25 (seizure list + technician conclusion)) doj-criminal-complaint doj-criminal-complaint Individualized possession evidence (who transported which items; who handled which components) is not detailed beyond certain attributions (e.g., CARROLL/PAGE/LAI brought components), leaving constructive-possession questions particularly salient for GAFFIELD under Count Two. [GAP] (Aff. ¶22–23) doj-criminal-complaint The bomb technician’s full written report(s), methodology, and any standardized criteria for “readily assemblable” are not included, even though the technician’s conclusions are load-bearing for Count Two given the affidavit’s statement that intervention occurred before a functional device was completed. [GAP] (Aff. ¶6; ¶25) doj-criminal-complaint doj-criminal-complaint Details of the ATF National Registration and Transfer Record query (identifiers checked, scope, and whether aliases were included) are not provided beyond the conclusory statement that no registration record exists, which may become material if identity or naming disputes arise. [GAP] (Aff. ¶27) doj-criminal-complaint The identities, roles, and scope of “Co-Conspirators 1 and 2,” “other comrades,” and any referenced “another group” offering firearms training are not specified, limiting network mapping and the committee’s ability to assess whether the four defendants represent a broader operational set. [GAP] (Aff. ¶10–11 (“add more if enough comrades”); ¶15–17; ¶17(g)) doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint Documentation about confidential human source handling (validation basis, compensation specifics, and debrief reports) is absent beyond the affidavit’s reliability assertions, which constrains independent evaluation of informant credibility and potential bias. [GAP] (Aff. ¶5 n.1; ¶4) doj-criminal-complaint doj-criminal-complaint doj-criminal-complaint