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AO 91 (Rev. 08/09) Criminal Complaint

UNITED STATES DISTRICT COURT
for the
Southern District o f Ohio
United States o f America
v.
Case No.

1: 15 MJ - 024

Christopher Lee Cornell
Defendant(s)

CRIMINAL COMPLAINT
1, the complainant in this case, state that the following is true to the best of my knowledge and belief.
On

or about the
Southern

date(s) o f
District o f

January 14, 2015
Ohio

Code Section

Hamilton

in the county of

in the

, the defendant(s) violated:
Offense

Description

18 U.S.C. Section 1114

Attempted Killing of a U.S. Government Officer

18 U.S.C. Section 924(c)

Possession of Firearm in Furtherance of Attempted Crime of Violence

This criminal complaint is based on these facts:
See the Affidavit of Special Agent T.A. Staderman.

Continued on the attached sheet.

Complainant' signature

T.A. Staderman, FBI Special Agent
Printed name and title

Sworn to before me and signed in my presence.

Date:

January 14, 2015
Judge's signature

City and state:

Cincinnati, Ohio

Stephanie K. Bowman, United States Magistrate Judge
Printed name and title

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A F F I D A V I T IN S U P P O R T O F C O M P L A I N T
I , Special Agent T.A. Staderman, being first duly sworn, hereby depose and state as
follows:
I N T R O D U C T I O N AND A G E N T B A C K G R O U N D
1.

I am a Special Agent with the Federal Bureau o f Investigation, and have been

since 2008. As a Special Agent, I have been assigned to investigate various Domestic and
International Terrorism matters and am assigned to the FBI's Cincinnati-Dayton Joint Terrorism
Task Force.
2.

1 make this affidavit in support o f a Complaint charging Defendant

C H R I S T O P H E R L E E C O R N E L L (also known as Raheel Mahrus Ubaydah) with violating
Title 18, United States Code, Section 1114 (Attempted K i l l i n g o f a U.S. Government Officer);
and Title 18, United States Code, Section 924(c) (Possession o f Firearm in Furtherance o f
Attempted Crime o f Violence); on or about January 14, 2015, in Cincinnati, Ohio, in the
Southern District o f Ohio.
3.

The facts in this affidavit are based on my personal observations, my training and

experience, and information obtained from other agents and witnesses. This affidavit is intended
to show merely that there is sufficient probable cause for the requested complaint and does not
set forth all o f my knowledge about this matter.
4.

Title 18, United States Code, Section 1114 prohibits, in pertinent part, a person

from "attempting] to k i l l any officer or employee o f the United States or of any agency in any
branch of the United States Government. . . while such officer or employee is engaged in or on
account o f the performance o f official duties."

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5.

Title 18, United States Code, Section 924(c), in pertinent part, prohibits a person

from possessing a firearm in furtherance o f a crime o f violence.
6.

On October 15, 2004, the United States Secretary o f State designated al-Qa'ida in

Iraq (AQI), then known as Jam'at al Tawhid wa'al-Jihad, as a Foreign Terrorist Organization
(FTO) under Section 219 of the Immigration and Nationality Act and as a Specially Designated
Global Terrorist under section 1(b) o f Executive Order 13224.
7.

On May 15, 2014, the Secretary o f State amended the designation o f al-Qa'ida in

Iraq as a Foreign Terrorist Organization under Section 219 o f the Immigration and Nationality
Act and as a Specially Designated Global Terrorist entity under section 1(b) o f Executive Order
13224 to add the alias Islamic State o f Iraq and the Levant (1SIL) as its primary name. The
Secretary also added the following aliases to the ISIL listing: the Islamic State o f Iraq and alSham (ISIS), the Islamic State o f Iraq and Syria (ISIS), ad-Dawla al-Islamiyya fi al-'Iraq wa-shSham, Daesh, Dawla al Islamiya, and Al-Furqan Establishment for Media Production. Although
the group has never called itself A Q I this name has frequently been used to describe it through
its history.
8.

From my participation in the investigation, including my review of FBI reports,

Twitter communications, and recordings of the Defendant's statements, I have learned the
following:
a.

At all times relevant, Defendant C H R I S T O P H E R C O R N E L L has resided in
Cincinnati, Ohio, in the Southern District of Ohio.

b. Beginning in approximately Summer 2014 and continuing to January 2015,
Defendant C H R I S T O P H E R C O R N E L L established and used Twitter accounts
under the alias Raheel Mahrus Ubaydah.

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c.

Using his Twitter accounts, Defendant C H R I S T O P H E R C O R N E L L posted
statements, videos, and other content indicating his support for 1SIL.

Defendant

C H R I S T O P H E R C O R N E L L also voiced his support for violent jihad, as well
as support for violent attacks committed by others in North America and
elsewhere.
d.

In the fall o f 2014, a Confidential Human Source (CHS) who began cooperating
with the F B I in order to obtain favorable treatment with respect to his criminal
exposure on an unrelated case, supplied information to the FBI about a person
using the alias o f Raheel Mahrus Ubaydah (Defendant C H R I S T O P H E R
C O R N E L L ) who posted comments and information supportive o f ISIL through
Twitter accounts.

e.

The CHS and Defendant C H R I S T O P H E R C O R N E L L first made contact with
each other over Twitter in August 2014, then began communicating through an
instant messaging platform separate from Twitter.

f.

On August 29, 2014, C O R N E L L wrote an instant message on a separate messaging
platform to the CHS that he had been in contact with persons overseas and he did not
think he would receive specific authorization to conduct a terrorist attack in the United
States, but stated that he wanted to go forward with violent jihad and opined that this
would be their way o f supporting 1S1L. Specifically C O R N E L L stated that, "1 believe
that we should just wage jihad under our own orders and plan attacks and everything." In
undertaking these actions, C O R N E L L stated that he thought he was fulfilling the
directives o f violent jihadists. C O R N E L L wrote that, '"we already got a thumbs up from
the Brothers over there and Anwar al A w l a k i before his martyrdom and many others."
C O R N E L L made it clear that the attacks he contemplated were to be conducted in

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alliance with 1SIL by writing, " I believe we should meet up and make our own group in
alliance with the Islamic State here and plan operations ourselves."
g.

Defendant C H R I S T O P H E R C O R N E L L and the CHS met in Cincinnati, Ohio
on October 17-18, 2014. During the meeting, Defendant C H R I S T O P H E R
C O R N E L L discussed his support o f ISIL and waging jihad. Defendant
C H R I S T O P H E R C O R N E L L stated that they needed weapons and wanted to
"move" in December 2014, but he did not want to reveal his plans at their first
meeting. Defendant C H R I S T O P H E R C O R N E L L also showed the CHS
jihadist videos and information about the construction o f bombs on C O R N E L L ' S
laptop computer.

h.

In a subsequent instant message to the CHS, Defendant C H R I S T O P H E R
C O R N E L L stated that their first meeting was to get acquainted, the second
meeting would involve the discussion o f their jihadist plans, and the third meeting
would be to "move."

i.

Defendant C H R I S T O P H E R C O R N E L L and the CHS met in Cincinnati, Ohio
for a second time on November 10-11, 2014. During the meeting, Defendant
C H R I S T O P H E R C O R N E L L indicated that he considered the members o f
Congress as enemies and that he intended to conduct an attack on the U.S. Capitol
in Washington, D.C. Defendant C H R I S T O P H E R C O R N E L L explained that
he and CHS would travel to Washington, D . C , conduct reconnaissance of the
security for certain government buildings, including the U.S. Capitol, and then
execute a plan o f attack on the U.S. Capitol. Defendant C H R I S T O P H E R
C O R N E L L specifically planned that he and the CHS would build, plant, and

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detonate pipe bombs at and near the U.S. Capitol, then use firearms to shoot and
kill employees and officials in the U.S. Capitol,
j.

Using his computer, Defendant C H R I S T O P H E R C O R N E L L showed the CHS
that he had researched the targeted government buildings in Washington, D.C.,
researched the construction o f pipe bombs, and researched the cost and sourcing
for firearms and the ingredients for pipe bombs. Defendant C H R I S T O P H E R
C O R N E L L also identified a gun store nearby that would sell a Smith & Wesson
semi-automatic rifle.

k.

In furtherance o f the planned attack, Defendant C H R I S T O P H E R C O R N E L L
saved money to fund the attack, researched the targeted government buildings in
Washington, D.C., researched the construction o f pipe bombs, and researched the
cost and sourcing for firearms and the ingredients for pipe bombs.

9.

On or about January 13 and 14, 2015, in the Southern District of Ohio, Defendant

C H R I S T O P H E R C O R N E L L and the CHS discussed and took the final steps in order to travel
to Washington, D.C. to execute the plan.
10.

On or about January 14, 2015, in the Southern District o f Ohio, Defendant

C H R I S T O P H E R C O R N E L L purchased and possessed a firearm, namely 2 Armalite Inc., Model
M-15, 5.56mm, semi-automatic rifles (Serial numbers: MS000788B and MS000974A), and
approximately 600 rounds of ammunition, with the plan to travel to Washington, D . C , and kill
employees and officers working in and around the U.S. Capitol.
11.

Defendant C H R I S T O P H E R C O R N E L L was arrested by law enforcement on

January 14, 2015, after Defendant purchased and took possession o f the firearm.

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12.

Based on the foregoing, I believe there is probable cause to believe that

Defendant C H R I S T O P H E R L E E C O R N E L L (also known as Raheel Mahrus Ubaydah)
violated Title 18, United States Code, Section 1114 (Attempted K i l l i n g o f a U.S. Government
Officer); and Title 18, United States Code, Section 924(c) (Possession of Firearm in Furtherance
of Attempted Crime o f Violence); on or about January 14, 2015, in Cincinnati, Ohio, in the
Southern District o f Ohio.
Respectfully submitted,

T.A. Staderman
Special Agent
Federal Bureau o f Investigation

Subscribed and sworn to before me on January _ 14 ,2015

STEPHANIE K. B O W M A N
U N I T E D STATES M A G I S T R A T E JUDGE

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