FILED IN THE

UNITED STATES DISTRICT COURT

DISTRICT OF HAWAII
KENJIM.PRICE #10523
United States Attorney ^ SEP 3 0 2020
District of Hawaii
at o'clock and.
MICHELLE RYNNE,CLE"^
MARC A. WALLENSTEIN #10456
Assistant United States Attorney
Room 6-100,PJKK Federal Building
300 Ala Moana Boulevard
Honolulu, Hawaii 96850
Telephone: (808)541-2850
Fax: (808)541-2958
E-Mail: [email protected]

Attorneys for Plaintiff

UNITED STATES OF AMERICA

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF HAWAII

UNITED STATES OF AMERICA, ) CR. NO. C'R^Q'QQOs 5

)
Plaintiff, ) INDICTMENT
)
vs. ) [18 U.S.C. § 229(a) and 26 U.S.C.
) § 5861(d)]
ETHAN SANDOMIRE, )
)
Defendant.

INDICTMENT

The Grand Jury charges:

 GENERAL ALLEGATIONS

1. At all times material to this Indictment,ETHAN SANDOMIRE,the

defendant, was a resident ofHonolulu, Hawaii. He used the name "P)to Pelican"

on social media, and his Tumblr profile photograph depicted a pelican with

explosives in its beak.

Sandomire's Conduct Involving Explosives and Chemical Weapons

2. Between at least December 2019 and March 2020, SANDOMIRE

conducted extensive internet research into explosives, explosive devices, chemical

and biological weapons, and related topics, and wrote privately about his plans for

explosive and chemical attacks in and around Honolulu, Hawaii. SANDOMIRE

also purchased and attempted to purchase materials that can be used to create a

destructive device; precursors that can be used to create toxic chemicals, such as

chlorine gas; and other dangerous substances capable of causing death and

permanent injury.

3. In or about August and September, 2019, SANDOMIRE was

hospitalized for a serious bum injury to his right hand and arm. SANDOMIRE

suffered the bum injury when he threw explosive powder onto a heat source.

4. On or about December 7, 2019, SANDOMIRE searched online for the

names ofthe perpetrators and victims of several mass killings, including: "Elliot

Rodgers,""Dylan Roof,""Adam Lanza," and "Veronika Weiss."

 5. On or about December 24,2019,SANDOMIRE recorded a video of

himselflighting explosive powder in his garage.

6. On or about January 4,2020, SANDOMIRE searched online for:

"AWOL,""how many soldiers go awol a year,""keep calm and go awol,""lED,"

"grenade thickness," and "how much explosives to destroy a building."

SANDOMIRE also visited a Wikipedia page entitled "building implosion,"

another web page entitled "how much explosives is needed to destroy a building,"

and another web page entitled "the threat to buildings from explosive devices."

7. On or about January 13,2020, SANDOMIRE used two websites to

search for personal information regarding two physicians who had previously

treated him.

8. Around this time, SANDOMIRE told others that he wanted to take

revenge on his treating physicians by "going AWOL." SANDOMIRE called one

ofthe physicians on the physician's personal phone and told the physician that he

was too aggressive and mean and should be nicer. Based on this call and their

prior interactions, the physician became concerned for his physical safety, and

changed his pattems of behavior, including by checking his surroundings for

weeks afterwards.

9. Between on or about January 12 and January 19, 2020, SANDOMIRE

purchased explosive precursor chemicals and related items from various online
vendors. He purchased aluminum powder and potassium perchlorate, which when

mixed creates flash powder, a type of explosive powder. He also purchased time

fuses, electronic matches, nichrome igniters, wireless firing systems, twelve-gauge

perimeter alarms, fireworks ignition systems, a flare gun,36 flares, stainless scales,

and a large steel pipe with matching iron end caps.

10. On or about January 28,2020,the aluminum powder was delivered to

SANDOMIRE's residence.

11. On or about January 29,2020, a package containing the time fuses,

electronic matches, nichrome igniters, wireless firing systems,twelve-gauge

perimeter alarms, and fireworks ignition systems was delivered to SANDOMIRE's

residence.

12. On or about February 4,2020 a package containing potassium

perchlorate was delivered to SANDOMIRE's residence. On or about February

10, 2020,three additional packages containing potassium perchlorate were

delivered to SANDOMIRE's residence. SANDOMIRE signed for all four of

these packages himself.

13. On or about February 9,2020, SANDOMIRE downloaded and saved

U.S. Army Field Manual 3-34.214, entitled "Explosives and Demolitions."

14. On or about February 9,2020, SANDOMIRE created a note on his

computer entitled "calcium hypochlorite and ammonium compound powder

explode" containing the text "carbon tetrachloride heated make phosgene gas,"
"pressure plates," "safety fuse," and "ammonium nitrate powder and nitromethane
160:64 by weight for high explosive charge." The note also contains a h3^erlink
to an online shopping cart containing "ammonium nitrate bulk," Phosgene gas

was used as a chemical weapon during World War 1.

15. On or about February 10, 2020,SANDOMIRE modified a

PowerPoint document on his laptop computer called "My Attack Plan." The

document depicted a diagram of a high explosive shaped charge.

16. On or about February 20, 2020,SANDOMIRE created a note on his

computer entitled "nerve gas," which contains the text "nerve gas,""anthrax,""bio

attack,""high explosive concrete shattering,""napalm,""fuel air explosive," and

"humanity is a disease on this planet, we are like fleas and ticks sucking the life out

of an animal."

17. On or about February 22, 2020,SANDOMIRE accessed a book on his

computer entitled "The Poisoner's Handbook," which was saved as "poison

weapons guide.pdf' on SANDOMIRE's computer. The book contains a section

about chemicals called phosphate esters, and lists a number of chemicals that are

also acetylcholinesterase inhibitors, which are a type of chemical that inhibits an

enzyme that affects the nervous system. The book describes these chemicals as

follows:"Discovered by the Germans in WWII,phosphate esters are now

primarily used as insecticides. Symptoms begin within minutes of ingestion and

include weakness, unsteadiness, blurred vision, pains in the chest and stomach,

vomiting, diarrhea, tremors, cyanosis, coma, convulsions, and within twenty-four

hours, death."

18. On or about February 23,2020, SANDOMBRE downloaded a

document entitled "Building Demolition Plan," drafted by the U.S. Army Corps of

Engineers, which appears to be an operational plan for the actual demolition of a

building located in New York.

19. On or about February 24, 2020, SANDOMIRE responded to a

Craigslist post offering a 1990s Chevy Astro van for sale. He confirmed via email

with the seller that the van was fimctional.

20. That same day, SANDOMIRE searched the internet for

"thiodiglycol," "sulfuric acid," and "muriatic acid." Thiodiglycol and muriatic

acid can be combined to create mustard gas, a toxic chemical that contains

elemental chlorine. SANDOMIRE knew that mustard gas and chlorine gas were

both toxic chemicals used as chemical weapons during World War I.

21. That same day, SANDOMIRE also searched for "Alfred P. Murrah

Federal Building,""Murrah Federal Building Size,""Okc federal building," and

"Munch Federal Building." The Alfred P. Murrah Federal Building was the target

ofthe 1995 Oklahoma City bombing.

 22. That same day, SANDOMIRE went to a hardware store in Honolulu,

Hawaii and purchased insecticide containing the active ingredient cypermethrin, as

well as two foggers and a sprayer. SANDOMIRE later searched the internet for

"cypermethrin on humans." Cypermethrin is a type of acetylcholinesterase

inhibitor, and has a similar effect on the nervous system as the chemicals discussed

in Paragraph 16 above.

23. Within minutes, SANDOMIRE re-entered the same hardware store in

Honolulu and purchased multiple items that, when combined, create chlorine gas, a

toxic chemical.

24. That same day, SANDOMIRE searched the internet approximately

nine times for information about the layout and internal design, including its

blueprints and floor plans, of a large residential apartment building ("Building A").

Building A is centrally located in Honolulu, Hawaii. It is 40 stories high with

more than 450 residential units, multiple floors ofparking, several commercial

units on the ground floor, and a large multi-level grocery store. SANDOMIRE

did not reside in Building A.

25. On or about February 26,2020,SANDOMIRE visited Building A in

person. Building A's security system required a key fob in order to enter the main

lobby and activate the elevators. Security camera footage showed SANDOMIRE
waiting outside the main lobby for someone to exit, then walking into the lobby
before the doors closed, and taking the elevator to the sixth-floor parking area.

26. SAJSIDOMIRE took photographs on his cellphone of structural

support columns inside the parking garage ofBuilding A. He also took

photographs of a storage area and large air vents coming out of an air handler.

The sixth-floor parking area was located below the building's outdoor recreational

area and lap pool, and the air handler served a 16,000 square-foot space elsewhere

in the building.

27. SANDOMIRE returned to Building A's main lobby and asked the

staff member at the front desk for copies ofthe building's floor plans, which the

staff member did not provide. SANDOMIRE also visited the building developer's

office and took photographs of a physical model of Building A.

28. On February 26,2020, SANDOMIRE searched the internet for

Building A's blueprints,"how many people live in [Building A],""school

shootings," and the names of an explosive chemical and explosive precursor.

SANDOMIRE found on the internet, downloaded, and saved floor plans of

Building A that showed the location of structural support columns.

29. On or about February 27,2020, SANDOMIRE deleted his safari

internet browser history.

 30. On or about February 29,2020, SANDOMIRE searched the internet

for numerous explosives, the name of one of his treating physicians,"how big was

the world trade center," "world trade center foundation,""911 attack" and "how

many people worked in the WTC."

31. From on or about March 1 to March 13, 2020, SANDOMIRE

searched the internet for numerous explosive materials and explosive precursors,

"reinforced concrete piers," "skyscraper foundation construction," a cross-section

ofBuilding A,and how to convert gallons to liters. He downloaded and saved a

document entitled "demolition tips," as well as a chart showing how much C4

explosive is needed to defeat a reinforced concrete pillar, depending on the

diameter ofthe pillar and the shape and placement ofthe charge. He searched for

"confinement,""firebomb," "plastique," and "blasting caps."

32. On or about March 2,2020, SANDOMIRE accessed a document

saved on his laptop computer entitled "explosives and weapons forum PDF,"

which contained a chat thread entitled "what can I combine to get chlorine gas."

33. Between on or about March 15 to 21,2020, SANDOMIRE searched

the internet for additional information about Building A and various topics

pertaining to explosives and chemical weapons. The searches included, among

other things:
a. Information about the Unabomber, Ted Kaczynski, Timothy

McVeigh,the Oklahoma City Bombing, and the Boston Bombing,

including "how long til they caught the okc bomber,""How Famous

was the Oklahoma City Bombing,""how many people did the

Unabomber kill,""Did the unabomber have a family," and "Brother

who turned in the Unabomber."

b. Information about ANFO,which stands for ammonium nitrate / fuel

oil. A bomb made out of ammonium nitrate fertilizer was used in the

1995 Oklahoma City bombing. SANDOMIRE's searches included:

"ANFO explosive,""can ANFO shatter concrete," and "ANFO

density."

c. Information about other explosives, including:"TNT equivalent,"

"Kinestick," "kinepak,""kinepak velocity," "tannerite composition,"

and "imploding explosives." "Kinestick" or "kinepak" is a two-part

commercial explosive. "Tarmerite" is a two-part commercial blasting

agent.

d. How to convert and calculate various measurements, such as "kg to

lb,""ms to fs,""cubic feet to meters,""cylinder volume,""cube

volume," and "5 gallon bucket volume."

e. Floor plans of—and condos for sale in—^Building A.

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 f. Information about containers, including:"bucket with curved edges,"

"bucket with dome bottom,""cement mixer,""10 gallon bucket,"

"how air proof are 5 gallon buckets,""can air pass through glass,"

"does water get through glass,""how fast does water leak from glass,'

"biggest glass jar,""5 gallon glass jar," and "how porous is silicone."

g. "doctors get way too much credit in our society" and "how many

people are at the Punahou carnival."

h. "activated charcoal,""fume absorber," and "improvised gas mask."

i. "psychology,""psycho,""psychopath," "sociopath," "profile of a

sociopath," and "im a bad person and don't want to change."

34. On or about March 20,2020, SANDOMIRE created a note on

his computer containing the text"ammonium nitrate containers,""nerve gas

container," and "botulism container."

35. On or about March 23,2020, SANDOMIRE created a note on his

computer entitled "destroy [Building A]," which reads as follows:

destroy [Building A]fill a large dense populated area with nerve

gas
spawn bio weapons everywhere, in food supply and water supply
use fuel air bombs in big spaces disguised as trash cans
bum down all dry grassy areas
start fires in buildings with incendiary devices
make a building collapse — high explosives on the main supports
bio or nerve agent weapon- spray in ac vents
spawn bio weapons-in water supply.

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 36. On or about March 26, 2020, SANDOMIRE entered the

address of Building A into a ride share application on his phone, but did not

complete the trip.

Sandomire's Arrest and Additional Investigation

37. SANDOMIRE was arrested by the FBI on March 29,2020,for

possessing the materials to make a destructive device.

38. During a search of his residence, SANDOMIRE was found to

possess a notebook that contained a handwritten drawing ofBuilding A's

floor plan, including the location of support columns, apparently copied

from an image available online, and a handwritten list that read "1. High

explosive shaped charges. 2. Large volume poison gas. 3. Incendiary flash

fire."

39. SANDOMIRE possessed a 5-gallon paint bucket in his

bedroom.

40. In a separate location, the FBI seized the items that

SANDOMIRE had previously purchased online, including approximately 30

pounds of aluminum powder, approximately 3.2 pounds ofcharcoal powder,

approximately one pound dextrin, approximately 2.1 pounds of magnesium

carbonate, approximately 1.9 pounds oflactose, approximately five pounds

of potassium chloride, approximately 30 pounds of ultra-pure potassium

12
perchlorate, approximately 45 pounds ofpotassium perchiorate, multiple

ignition systems, wireless firing systems, and victim-initiated tripwire

systems,including four twelve-gauge perimeter alarms.

41. SANDOMIRE's laptop computer contained 21 folders with

extensive research into explosives, chemical weapons, biological weapons,

improvised munitions, and similar topics. Some ofthe 21 folders were

entitled "building demolition,""my attack plan,""explosives," and "bio

warfare." The folders were concealed within unrelated directory names,

such as "interesting files,""boxing clips," and "gone." The folders

contained digital versions of54 books about explosives and related topics.

SANDOMIRE's laptop computer also contained an instructional document

titled "Advanced Chemical Weapons Design and Manufacture," with the

subtitle "Chemicals that Kill in 30 Seconds or your Money Back."

COUNT 1

Possession of a Chemical Weapon

(18 U.S.C. § 229(a))

On or about February 24, 2020,in the District ofHawaii,ETHAN

SANDOMIRE,the defendant, knowingly possessed and attempted to possess a

chemical weapon, namely, precursors (trichloro-s-triazinetrione and hydrochloric

acid), which when combined creates a toxic chemical, that is, chlorine and chlorine

13
gas, not intended for peaceful purposes, protective purposes, unrelated military

purposes, or law enforcement purposes, as described in 18 U.S.C. § 229F(7).

All in violation of Title 18, United States Code, Sections 229(a)and 229F.

COUNT 2

Possession of an Unregistered Destructive Device

(26 U.S.C. § 5861(d))

From on or about January 12, 2020,to a precise date unknown in or around

March 2020,in the District ofHawaii,ETHAN SANDOMIRE,the defendant,

knowingly possessed a firearm, namely,a combination of parts either designed or

intended for use in converting any device into a destructive device, and from which

a destructive device may be readily assembled, that was not registered to him in the

National Firearms Registration and Transfer Record.

All in violation of Title 26, United States Code, Sections 5841, 5861(d), and

5871.

FIRST FORFEITURE NOTICE

42. The allegations contained in Count 1 ofthis Indictment are hereby re-

alleged and incorporated by reference for the purpose ofnoticing forfeiture

pursuant to Title 18, United States Code, Section 229B.

43. The United States hereby gives notice to the defendant that, upon

conviction ofthe offense charged in Count 1 ofthis Indictment, the government

will seek forfeiture, in accordance with Title 18, United States Code, Section
14
229B,of(1)any property, real or personal, owned, possessed, or used by a person

involved in the offense charged in Count 1 ofthis Indictment;(2)any property

constituting, or derived from,and proceeds the person obtained, directly or

indirectly, as the result ofthe violation ofTitle 18, United States Code, Section

229, charged in Coimt 1 ofthis Indictment; and any property used in any manner

or part, to commit, or to facilitate the commission of, such violation.

44. If by any act or omission ofthe defendant, any ofthe property subject

to forfeiture described in paragraph 2 herein:

a. cannot be located upon the exercise of due diligence;

b. has been transferred or sold to, or deposited with, a third party;

c. has been placed beyond the jurisdiction ofthe court;

d. has been substantially diminished in value; or

e. has been commingled with odier property which cannot be subdivided

without difficulty,

the United States of America will be entitled to the forfeiture ofsubstitute property

up to the value ofthe property described above in paragraph 2, pursuant to Title

21, United States Code, Section 853(p), as incorporated by Title 18, United States

Code, Section 229B(b)(l).

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 SECOND FORFEITURE NOTICE

45. The allegations contained in Count 2 ofthis Indictment are hereby re-

alleged and incorporated by reference for the purpose of noticing forfeiture

pursuant to Title 18, United States Code, Section 924(d)(1), and Title 28, United

States Code, Section 2461(c).

46. The United States hereby gives notice to the defendant that, upon

conviction ofthe offense charged in Count 2 ofthis Indictment, the government

will seek forfeiture, in accordance with Title 18, United States Code, Section

924(d)(1), and Title 28, United States Code, Section 2461(c), ofany firearm or

ammunition involved in or used in the offense, including the materials that

SANDOMIRE ordered online in February 2020, which were seized by the FBI on

March 30, 2020.

47. If by any act or omission ofthe defendant, any ofthe property subject

to forfeiture described in paragraph 2 herein:

a. cannot be located upon the exercise of due diligence;

b. has been transferred or sold to, or deposited with, a diird party;

c. has been placed beyond the jurisdiction ofthe court;

d. has been substantially diminished in value; or

e. has been commingled with other property which cannot be subdivided

without difficulty,

16
the United States of America will be entitled to the forfeiture ofsubstitute property

up to the value ofthe property described above in paragraph 2, pursuant to Title

21, United States Code, Section 853(p), as incorporated by Title 28, United States

Code, Section 2461(c).

DATED: September 30,2020, at Honolulu, Hawaii.

KENH M.PRICE
United States Attomey
District ofHawaii

MARC A. WALLENSTEIN
Assistant United States Attomey

United States v. Ethan Sandomire

Indictment
Cr. No.

C120- 000 85

17