MAH/2006R01297

UNITED STATES DISTRICT COURT

DISTRICT OF NEW JERSEY

UNITED STATES OF AMERICA : Crim. No. 07-_________

:

: 18 U.S.C. §§ 1038(a)(1) and 2

v. :

:

: INDICTMENT

(b) The Internet website www.4chan.org and the “Random”

posting section of that website were publicly available to all

Internet users, and accepted and publicly broadcasted messages

and content from all Internet users.

(c) The New York Jets and New York Giants were

professional football teams in the National Football League, and

played their home games at Giants Stadium located in East

Rutherford, New Jersey.

2. On or about October 22, 2006:

(a) The New York Jets were scheduled to play the

(c) The Atlanta Falcons were scheduled to play the

Pittsburgh Steelers in Atlanta, Georgia.

(d) The Seattle Seahawks were scheduled to play the

Minnesota Vikings in Seattle, Washington.

(e) The Houston Texans were scheduled to play the

Jacksonville Jaguars in Houston, Texas.

(f) The Oakland Raiders were scheduled to play the

Arizona Cardinals in Oakland, California.

(g) The Cleveland Browns were scheduled to play the

Denver Broncos in Cleveland, Ohio.

and the New York Jets, and which was scheduled to host a New York

Jets home game on October 22, 2006. Additionally, the message

threatened that the explosive devices would cause radiological

fallout resulting in numerous fatalities. The message stated, in

substance and in part:

On Sunday, October 22nd, 2006, there will be seven "dirty"

explosive devices detonated in seven different U.S. cities;

Miami, New York City, Atlanta, Seattle, Houston, Oakland and

Cleveland. The death toll will approach 100,000 from the

initial blasts and countless other fatalities will later

fallout will destroy those not killed in the initial

explosion. The explosions will be near simultaneous, with

the cities specifically chosen in different time zones to

allow for multiple attacks at the same time.

The 22nd of October will mark the final day of Ramadan as it

would fall in Mecca. Al-Qaida will automatically be blamed

for the attacks. Later, through Al-Jazeera, Osama bin Laden

will issue a video message claiming responsibility for what

he dubs "America's Hiroshima".

additional times on www.4chan.org.

5. Before posting the message described in paragraph 3,

above, defendant JAKE BRAHM researched which National Football

League teams were playing on October 22, 2006, and listed the

cities to connote those stadiums hosting the games.

6. Defendant JAKE BRAHM knew the message described in

paragraph 3, above, was false when he authored it, and each time

that he posted it on www.4chan.org

7. The Internet website www.4chan.org and the “Random”

8. From in or around September 2006 to on or about October

knowingly and willfully engaged in conduct with intent to convey

information may reasonably have been believed and where such

information indicated that activity would take place that would

constitute a violation of: (i) Chapter 40 of Title 18, United

States Code (malicious damage of any building or vehicle, in

violation of 18 U.S.C. § 844(i)); and (ii) Chapter 113B of Title

18, United States Code (use of weapons of mass destruction

against persons or property within the United States, in

violation of 18 U.S.C. § 2332a(a)(1)(D), and use of radiological

dispersal devices designed and intended to release radiation or

radioactivity at a level dangerous to human life, in violation of

18 U.S.C. § 2332h(a)(1)(A)).

In violation of Title 18, United States Code, Sections

CHRISTOPHER J. CHRISTIE

United States Attorney

444444444444444444444444444444444

MICHAEL A. HAMMER (973)645-2771

ASSISTANT U.S. ATTORNEY

NEWARK, NEW JERSEY