UNITED STATES OF AMERICA: Plaintiff Versus Timothy James McVeigh and Terry Lynn Nichols, Defendants.

Violations:

  • 18 USC Sec. 2332a
  • 18 USC Sec. 844(f)
  • 18 USC Sec. 1114
  • 18 USC Sec. 1111
  • 18 USC Sec. 2(a)&(b)

Indictment

Count One: Conspiracy to Use a Weapon of Mass Destruction

The Grand Jury charges:

Beginning on or about September 13, 1994, and continuing until on or about April 19, 1995, at Oklahoma City, Oklahoma, in the Western District of Oklahoma and elsewhere, Timothy James McVeigh And
Terry Lynn Nichols knowingly, intentionally, willfully, and maliciously conspired, combined, and agreed together and with others unknown to use a weapon of mass destruction — an explosive bomb placed in a truck — against people and against property owned and used by the United States and by a department and agency of the United States.

The attack at the Alfred P. Murrah Federal Building at 200 N.W. 5th Street in Oklahoma City resulted in death, grievous bodily injury, and the destruction of the building.

The aim of their conspiracy was to kill and injure innocent persons and to damage the aforementioned property.

The Conspirators' Manner and Mean to Further Their Conspiracy:

The manner and means the defendants used to further their conspiracy included the following:

  • McVeigh and Nichols planned an act of violence against persons and property of the United States.
  • They selected the Alfred P. Murrah Federal Building and its occupants as the targets of their act of violence. McVeigh attempted to recruit others to assist.
  • McVeigh and Nichols obtained and attempted to obtain the components of a truck bomb. This included a truck, ammonium nitrate, racing and diesel fuel, detonation cord, and other explosive materials.
  • They used storage units to conceal the truck bomb components and stolen property.
  • They used stolen property and its proceeds to help finance their act of violence.
  • They made calls with a telephone calling card that they had acquired in a false name in order to conceal their true identities and to prevent calls from being traced to them.
  • They used different false names in business transactions to conceal their true identities, their whereabouts, and the true intent of their activities.
  • They constructed an explosive truck bomb. McVeigh placed it outside the Alfred P. Murrah Federal Building in downtown Oklahoma City and detonated the bomb.

Additional Acts:

To further the conspiracy and to achieve its objectives, McVeigh and Nichols committed and caused to be committed the following acts, among others, in the Western District of Oklahoma and elsewhere:

  • On or about September 22, 1994, McVeigh rented a storage unit under the name "Shawn Rivers" in Herington, Kansas.
  • On or about September 30, 1994, McVeigh and Nichols purchased 45-pound bags of ammonium nitrate in McPherson, Kansas, under the name "Mike Havens."
  • On or about late September 1994, McVeigh made telephone calls in an attempt to obtain detonation cord and racing fuel.
  • On or about October 1, 1994, McVeigh and Nichols stole explosives from a storage locker, commonly referred to as a magazine, in Marion, Kansas.
  • On or about October 3, 1994, McVeigh and Nichols transported the stolen explosives to Kingman, Arizona.
  • On or about October 4, 1994, McVeigh rented a storage unit in Kingman, Arizona, for the stolen explosives.
  • On or about October 16, 1994, Nichols registered at a motel in Salina, Kansas, under the name "Terry Havens."
  • On or about October 17, 1994, Nichols rented storage unit No. 40 in Council Grove, Kansas, under the name "Joe Kyle."
  • On or about October 18, 1994, McVeigh and Nichols purchased 45-pound bags of ammonium nitrate in McPherson, Kansas, under the name "Mike Havens."
  • On or about October 1994, McVeigh and Nichols planned a robbery of a firearms dealer in Arkansas to obtain moneys to help finance their planned act of violence.
  • On or about November 5, 1994, McVeigh and Nichols caused firearms, ammunition, coins, United States currency, precious metals, and other property to be stolen from a firearms dealer in Arkansas.
  • On or about November 7, 1994, Nichols rented storage unit No. 37 in Council Grove, Kansas, under the name "Ted Parker" and used the unit to conceal property stolen in the Arkansas robbery.
  • On or about November 16, 1994, Nichols rented a storage unit in Las Vegas, Nevada, and stored, among other items, a ski mask.
  • On or about November 21, 1994, and prior to departing for the Philippines, Nichols prepared a letter to McVeigh, to be delivered only in the event of Nichols' death, in which he advised McVeigh, among other matters, that storage unit No. 37 in Council Grove, Kansas, had been rented under the name "Parker" and instructed McVeigh to clear out the contents or extend the lease on No. 37 by February 1, 1995. Nichols further instructed McVeigh to "liquidate" storage unit No. 40.
  • On or about December 16, 1994, while en route to Kansas to take possession of firearms stolen in the Arkansas robbery, McVeigh drove with Michael Fortier to the Alfred P. Murrah Federal Building and identified the building as the target.
  • In early 1995, following Nichols' return from the Philippines, firearms stolen in the Arkansas robbery were sold and McVeigh, Nichols, and Michael Fortier obtained currency from those sales.
  • On or about February 9, 1995, Nichols, using currency, paid for the continued use of storage unit No. 40 at Council Grove, Kansas, under the name "Joe Kyle."
  • On or about March, 1995, McVeigh obtained a driver's license under the name "Robert Kling" bearing a date of birth of April 19, 1972.
  • On or about April 14, 1995, McVeigh, using currency, purchased a 1977 Mercury Marquis in Junction City, Kansas.
  • On or about April 14, 1995, McVeigh called the Nichols residence in Herington, Kansas, from Junction City, Kansas.
  • On or about April 14, 1995, McVeigh called a business in Junction City and, using the name "Bob Kling," inquired about renting a truck capable of carrying 5,000 pounds of cargo.
  • On or about April 14, 1995, McVeigh, using currency, rented a room at a motel in Junction City, Kansas.
  • On or about April 15, 1995, McVeigh, using currency, placed a deposit for a rental truck under the name "Robert Kling."
  • On or about April 17, 1995, McVeigh took possession of a 20-foot rental truck in Junction City, Kansas.
  • On or about April 18, 1995, at Geary Lake State Park in Kansas, McVeigh and Nichols constructed an explosive truck bomb with barrels filled with a mixture of ammonium nitrate, fuel, and other explosives placed in the cargo compartment of the rental truck.
  • On April 19, 1995, McVeigh parked the truck bomb directly outside the Alfred P. Murrah Federal Building, located within the Western District of Oklahoma, during regular business and daycare hours.
  • On April 19, 1995, McVeigh caused the truck bomb to explode.

The Results of the Conspiracy:

The truck bomb explosion resulted in death and personal injury and the destruction of the Alfred P. Murrah Federal Building, located within the Western District of Oklahoma. The following persons were present at the Alfred P. Murrah Federal Building on April 19, 1995, and were killed — all in violation of Title 18, United States Code, Section 2332a — as a result of the explosion:

  • Charles E. Hurlburt, 73
  • John Karl Vaness III, 67
  • Anna Jean Hurlburt, 67
  • Donald Lee Fritzler, 64
  • Eula Leigh Mitchell, 64
  • Donald Earl Burns, Sr., 63
  • Norma Jean Johnson, 62
  • Calvin C. Battle, 62
  • Laura Jane Garrison, 61
  • Olen Burl Bloomer, 61
  • Luther Hartman Treanor, 61
  • RhetaIone Bender Long, 60
  • Juretta Colleen Guiles, 59
  • Robert Glen Westberry, 57
  • Carolyn Ann Kreymborg, 57
  • Leora Lee Sells, 57
  • Mary Anne Fritzler, 57
  • Virginia Mae Thompson, 56
  • Peola Y. Battle, 56
  • Peter Robert Avillanoza, 56
  • Richard Leroy Cummins, 55
  • Ronald Vernon Harding, 55
  • LaRue Ann Treanor, 55
  • Ethel Louise Griffin, 55
  • Antonio C. Reyes, 55
  • Thompson Eugene Hodges, Jr., 54
  • Alvin Junior Justes, 54
  • Margaret Goodson, 54
  • Oleta Christine Biddy, 54
  • David Jack Walker, 54
  • James Anthony McCarthy, 53
  • Carol L. Bowers, 53
  • Linda Coleen Housley, 53
  • John Albert Youngblood, 52
  • Robert Nolan Walker, Jr., 52
  • Thomas Lynn Hawthorne, Sr., 52
  • Dolores Marie Stratton, 51
  • Jules Alfonso Valdez, 51
  • John Thomas Stewart, 51
  • Mickey Bryant Maroney, 50
  • John Clayton Moss III, 50
  • Carole Sue Khalil, 50
  • Emilio Tapla-Rangel, 50
  • James Everette Boles, 50
  • Donald R. Leonard, 50
  • CastineDeveroux, 49
  • Clarence Eugene Wilson, 49
  • Wanda Lee Watkins, 49
  • Michael Lee Loudenslager, 48
  • Carrol June Fields, 48
  • Frances Ann Williams, 48
  • Claudine Ritter, 48
  • Ted Leon Allen, 48
  • Linda Gail Griffin McKinney, 47
  • Patricia "Trish" Ann Nix, 47
  • Betsy Janice McGonnell, 47
  • David Neil Burkett, 47
  • Michael George Thompson, 47
  • Catherine Mary Leinen, 47
  • Sharon Louise Wood Chesnut, 47
  • Ricky Lee Tomlin, 46
  • Larry James Jones, 46
  • Richard Arthur Allen, 46
  • Harley Richard Cottingham, 46
  • Lanny Lee David Scroggins, 46
  • George Michael Howard, 45
  • Jerry Lee Parker, 45
  • Judy Joann Fisher, 45
  • Diane Hollingsworth Althouse, 45
  • Michael D. Weaver, 45
  • Robert Lee Luster, Jr., 45
  • Peter Leslie DeMaster, 44
  • Katherine Ann Finley, 44
  • Doris Adele Higginbottom, 44
  • Stephen Douglas Curry, 44
  • Michael Joe Carrillo, 44
  • Cheryl E. Bradley Hammon, 44
  • Aurelia Donna Luster, 43
  • Linda L. Florence, 43
  • Claudette Meek, 43
  • William Stephen Williams, 42
  • Johnny Allen Wade, 42
  • Larry Laverne Turner, 42
  • Brenda Faye Daniels, 42
  • Margaret Louise Clark Spencer, 42
  • Paul Gregory Broxterman, 42
  • Paul Douglas Ice, 42
  • Woodrow Clifford "Woody" Brady, 41
  • Claude Arthur Medearis, 41
  • Teresa Lea Lauderdale, 41
  • Terry Smith Rees, 41
  • Alan Gerald Whicher, 40
  • Lola Renee Bolden, 40
  • Kathy Lynn Seidl, 39
  • Kimberly Kay Clark, 39
  • Mary LeasureRentie, 39
  • Diana Lynn Day, 38
  • Robin Ann Huff, 37
  • Peggy Louise Jenkins Holland, 37
  • Victoria Jeanette Texter, 37
  • Susan Jane Ferrell, 37
  • Kenneth Glenn McCullough, 36
  • Victoria Lee Sohn, 36
  • Pamela Denise Argo, 36
  • Rona Linn Chafey, 36
  • Jo Ann Whittenberg, 35
  • Gilbert Xavier Martinez, 35
  • Wanda Lee Howell, 34
  • Saundra Gail "Sandy" Avery, 34
  • James Kenneth Martin, 34
  • Lucio Aleman, Jr., 33
  • Valerie Jo Koelsch, 33
  • Teresa Antionette Alexander, 33
  • Kim Robin Cousins, 33
  • Michelle Ann Reeder, 33
  • Andrea Y. Blanton, 33
  • Karen Gist Carr, 32
  • Christi Yolanda Jenkins, 32
  • Jamie Lee Genzer, 32
  • Ronota Ann Woodbridge, 31
  • Benjamin Laranzo Davis, 29
  • Kimberly Ruth Burgess, 29
  • Tresia Jo Mathes-Worton, 28
  • Mark Allen Bolte, 28
  • Randolph Guzman, 28
  • Sheila R. Gigger Driver, 28
  • Karan Denise Shepherd, 27
  • Sonja Lynn Sanders, 27
  • Derwin Wade Miller, 27
  • Jill Diane Randolph, 27
  • Carrie Ann Lenz, 26
  • Cynthia Lynn Campbell Brown, 26
  • Cassandra K. Booker, 25
  • Shelly Deann (Turner) Bland, 25
  • Scott Dwain Williams, 24
  • Dana LeAnne Cooper, 24
  • Julie Marie Welch, 23
  • Frankie Ann Merrell, 23
  • Christine Nicole Rosas, 22
  • Lakesha Levy, 21
  • Cartney J. McRaven, 19
  • Aaron M. Coverdale, 5
  • Ashley Megan Eckles, 4
  • Zackary Taylor Chavez, 3
  • Kayla Marie Haddock, 3
  • Peachlyn Bradley, 3
  • Chase Dalton Smith, 3
  • Anthony Christopher Cooper II, 2
  • Colton Smith, 2
  • Elijah Coverdale, 2
  • Dominique R. London, 2
  • BayleeAlmon, 1
  • Jaci Rae Coyne, 1
  • Blake Ryan Kennedy, 1
  • TevinD'Aundrae Garrett, 1
  • Danielle Nicole Bell, 1
  • Tylor S. Eaves, 8 months
  • Antonio Ansara Cooper, Jr., 6 months
  • Kevin Lee Gottshall II, 6 months
  • Gabreon Bruce, 4 months

Count Two: Use of a Weapon of Mass Destruction

Additional Grand Jury charges:

On or about April 19, 1995, at Oklahoma City, Oklahoma, in the Western District of Oklahoma, Timothy James McVeigh and Terry Lynn Nichols knowingly, intentionally, willfully, and maliciously used, aided, and abetted the use of, and caused to be used, a weapon of mass destruction — namely, an explosive bomb placed in a truck — against persons within the United States. This resulted in death to the persons named above and personal injury to others.

This action was in violation of Title 18, United States Code, Sections 2332a and 2(a)&(b).

Count Three: Destruction by Explosive

Additional Grand Jury charges:

On or about April 19, 1995, at Oklahoma City, Oklahoma, in the Western District of Oklahoma, Timothy James McVeigh and Terry Lynn Nichols knowingly, intentionally, willfully, and maliciously damaged and destroyed, aided and abetted the damage and destruction of, and caused to be damaged and destroyed, by means of an explosive — namely, an explosive bomb placed in a truck — a building and other personal and real property in whole and in part owned, possessed, and used by the United States and departments and agencies of the United States: The Alfred P. Murrah Federal Building at 200 N.W. 5th Street in Oklahoma City.

This caused the death of the persons named above and personal injury to others, all in violation of Title 18, United States Code, Sections 844(f) and 2(a)&(b).

Counts Four Through Eleven: First Degree Murder

On or about April 19, 1995, at Oklahoma City, Oklahoma, in the Western District of Oklahoma, Timothy James McVeigh and Terry Lynn Nichols unlawfully, willfully, deliberately, maliciously, and with premeditation and malice aforethought killed and aided, abetted, and caused the killing of the following persons while they were engaged in and on account of the performance of official duties as law enforcement officers:

  • Mickey Bryant Maroney, Special Agent, United States Secret Service
  • Donald R. Leonard, Special Agent, United States Secret Service
  • Alan Gerald Whicher, Assistant Special Agent in Charge, United States Secret Service
  • Cynthia Lynn Campbell-Brownv, Special Agent, United States Secret Service
  • Kenneth Glenn McCullough, Special Agent, United States Drug Enforcement Administration
  • Paul Douglas Ice, Special Agent, United States Customs Service
  • Claude Arthur Medearis, Special Agent, United States Customs Service
  • Paul G. Broxterman, Special Agent, Department of Housing and
    Urban Development Office of Inspector General

These counts were in violation of Title 18, United States Code, Sections 1114, 1111 and 2(a)&(b), and Title 28, Code of Federal Regulations, Section 64.2(h).