Special Attorneys to the United States Attorney General 650 Capitol Mall Sacramento, CA 95814 Telephone: (916) 554-2700
In The United States District Court
For The Eastern District of California
United States of America,
Plaintiff
v.
Theodore John Kaczynski
aka "FC"
Defendant.
CR. No. S-CR-S-96-259 GEB
Violations: 18 U.S.C.
Section 844 (d) - Transportation
of an Explosive With Intent
To Kill of Injure (4 Counts) :
18 U.S.C. Section 1716 -
Mailing an Explosive
Device With Intent to Kill
or Injure (3 Counts) :
18 U.S.C. Section 924 (c) (1) - Use
of a Destructive Device In
Relation to a Crime of
Violence (3 Counts)
Indictment
I.
The Bomb That Killed Hugh Scrutton (Count 1)
Count One: [18 U.S.C. Sections 844 (d) and 2 (b) - Transportation of an Explosive With Intent to Kill or Injure]
The Grand Jury charges:
Theodore John Kaczynski
defendant herein, as follows:
1. In or about the fall of 1985, but not later than December 11, 1985, the defendant transported a bomb and bomb components from Montana to Sacramento, California. the defendant placed the bomb in the parking lot behind the rear entrance to Rentech, a computer store in Sacramento, California.
2. On or about December 11, 1984, Hugh Scrutton, the owner of Rentech, moved the bomb. this action caused the bomb to explode, killing Mr. Scrutton.
3. In or about the fall of 1985, but not later than December 11, 1985, in the State and Eastern District of California, and elsewhere, the defendant knowingly did transport and attempt to transport, and willfully did cause to be transported, in interstate commerce an explosive with the knowledge and intent that it would be used to kill, injure and intimidate an individual, and unlawfully to damage and destroy real and personal property, which did result in the death of Hugh Scrutton, in violation of Title 18, united States code, Sections 844 (d) and 2 (b).
II.
The Bomb That Injured Dr. Charles Epstein (Counts 2-4)
Count Two: [18 U.S.C. Sections 844 (d) and 2 (b) - Transportation of an Explosive With Intent to Kill or Injure]
The Grand Jury further charges:
Theodore John Kaczynski
defendant herein, as follows:
4. From on or about June 16, 1993, to on or about June 18, 1993, the defendant transported a bomb and bomb components from Montana to Sacramento, California.
5. On or about June 18, 1993, the defendant mailed the bomb from Sacramento, California to Dr. Charles Epstein in Tiburon, California. The bomb was contained in a wooden box, placed in a padded mailing envelope. The package containing the bomb was delivered to Dr. Epstein's home.
6. On or about June 22, 1993, while in his home, Dr. Epstein opened the package referred to in paragraph 5, causing it to explode and injure him.
7. From on or about June 16, 1993, to on or about June 22, 1993, in the State and Eastern District of California, and elsewhere, the defendant knowingly did transport and attempt to transport, and willfully did cause to be transported, in interstate commerce an explosive with the knowledge and intent that it would be used to kill, injure and intimidate and individual, and unlawfully to damage and destroy real personal property, which did result in personal injury to Dr. Charles Epstein, in violation of Title 18, United States Code, Sections 844 (d) and 2 (b).
Count Three: [18 U.S.C. Section 1716 - Mailing an Explosive Device With Intent to Kill or Injure]
The Grand Jury further charges:
Theodore John Kaczynski
defendant herein, as follows:
8. Paragraphs 4-6 are repeated and realleged as though set forth in full.
9. On or about June 18, 1993, in the State and Eastern District of California, and elsewhere, the defendant knowingly did deposit for mailing and delivery and knowingly did cause to be delivered by mail, according to the direction thereon, nonmailable matter, to wit: a device and composition which could ignite and explode, with the intent to kill and injure another, in violation of Title 18, United States Code, Section 1716.
Count Four: [18 U.S.C. Section 924 (c) (1) - Use of a Destructive Device In Relation to a Crime of Violence]
The Grand Jury further charges:
Theodore John Kaczynski
defendant herein, as follows:
10. Paragraphs 4 through 6 are repeated and realleged as though set forth in full.
11. From on or about June 16, 1993, to on or about June 22, 1993, in the State and Eastern district of California, and elsewhere, during and in relation to a crime of violence for which he may be prosecuted in a court of the united States, to wit: transportation of an explosive with intent to kill and injure and mailing an explosive device with intent to kill and injure, as charged in Counts Two and Three, the defendant knowingly did use and carry a firearm, that is, a destructive device, in violation of Title 18, united States code, Section 924 (c) (1).
III.
The Bomb Mailed that Injured Dr. David Gelernter (Counts 5-7)
Count Five: [18 U.S.C. Sections 844 (d) and 2 (b) - Transportation of an Explosive With intent to Kill or Injure]
The Grand Jury further charges:
Theodore John Kaczynski
defendant herein, as follows:
12. From on or about June 16, 1993, to on or about June 18, 19936, the defendant transported a bomb and bomb components from Montana to Sacramento, California.
13. on or about June 18, 1993, the defendant mailed the bomb from Sacramento, California to Dr. David Gelernter in New Haven, Connecticut. The bomb was contained in a wooden box, placed in a padded mailing envelope. the package containing the bomb was delivered to Dr. Gelernter's office.
14. On or about June 24, 1993, Dr. Gelernter opened the package referred to in paragraph 13, causing it to explode and injure him.
15. From on or about June 16, 1993, to on or about June 24, 1993, in the State and Eastern District of California, and elsewhere, the defendant knowingly did transport and attempt to transport, and willfully did cause to be transported, in interstate commerce an explosive with the knowledge and intent that it would be used to kill, injure and intimidate an individual, and unlawfully to damage and destroy real and personal property , which did result in personal injury to Dr. David Gelernter, in violation of Title 18, United States Code, Section 844 (d) and 2 (b).
Count Six: [18 U.S.C. Section 1716 - Mailing an Explosive Device With Intent to Kill or injure]
The Grand jury further charges:
Theodore John Kaczynski
defendant herein, as follows:
16. Paragraphs 12 through 14 are repeated and realleged as though set forth in full/
17. On or about June 18, 1993, in the State and Eastern District of California, and elsewhere, the defendant knowingly did deposit for mailing and delivery and knowingly did cause to be delivered by mail, according to the direction thereon, nonmailable matter, to wit: a device and composition which could ignite and explode, with the intent to kill and injure another, in violation of Title 18, United States Code, Section 1716.
Count Seven: [18 U.S.C. Section 924 (c) (1) - Use of a Destructive Device in Relation to a Crime of Violence]
The Grand Jury further charges:
Theodore John Kaczynski
defendant herein, as follows:
18. Paragraphs 12 through 14 are repeated and realleged as though set forth in full.
19. From on or about June 16, 1993, to on or about June 24, 1993, to on or about June 24, 1993, in the State and Eastern District of California, and elsewhere, during and in relation to a crime of violence for which he may be prosecuted in a court of the United States, to wit: transportation of an explosive with the intent to kill or injure, as charged in Counts Five and Six, the defendant knowingly did use and carry a firearm, that is, a destructive device, in violation of title 18, United States Code, Section 924 (c) (1).
IV.
The Bomb That Killed Gilbert B. Murray (Counts 8-10)
Count Eight: [18 U.S.C. Sections 844 (d) and 2 (b) - Transportation of an Explosive With Intent to Kill or Injure]
The Grand Jury further charges:
Theodore John Kaczynski
defendant herein, as follows:
20. From on or about March 13, 1995, to on or about April 20, 1995, the defendant transported a bomb and bomb components from Montana to Oakland, California.
21. on or about April 20, 1995, the defendant mailed the bomb from Oakland, California area to William Dennison, at the address of the California forestry Association, Sacramento, California. the bomb was contained in a wooden box wrapped with brown paper. The package containing the bomb was delivered to the California forestry Association on or about April 24, 1995.
22. On or about April 24, 1995, Gilbert B. Murray, Mr. Dennison's successor as the president of the California Forestry Association, opened the package referred to in paragraph 21, causing it to explode, killing Mr. Murray.
23. From on or about March 13, 1995, to on or about April 24, 1995, in the State and Eastern district of California, and elsewhere, the defendant knowingly did transport and attempt to transport, and willfully did cause to be transported, in interstate commerce an explosive with the knowledge and intent that it would be used to kill, injure, and intimidate an individual, and unlawfully to damage and destroy real and personal property, which did result in the death of Gilbert B. Murray, in violation of Title 18, United States Code, Section 844 (d) and 2 (b).
Count Nine: [18 U.S.C. Section 1716 - Mailing an Explosive Device With Intent to Kill or Injure]
The Grand Jury further charges:
Theodore John Kaczynski
defendant herein, as follows:
24. Paragraphs 20 through 22 are repeated and realleged as though set forth in full.
25. On or about April 20, 1995, the defendant knowingly did deposit for mailing and delivery for mailing and delivery and knowingly did cause to be delivered by mail in the State and Eastern District of California, and elsewhere, according to the direction thereon, nonmailable matter, to wit: a device and composition which could ignite and explode, with the intent to kill and injure another, and which did result in the death of Gilbert B. Murray, in violation of Title 18, united States Code, Section 1716.
Count Ten: [18 U.S.C. Section 924 9 (c) (1) - Use of a Destructive Device in Relation to a Crime of Violence]
The Grand Jury further charges:
Theodore John Kaczynski
defendant herein, as follows:
26. Paragraphs 20 through 22 are repeated and realleged as though set forth in full.
27. From on or about March 13, 1995 to on or about April 24, 1995, in the State and Eastern district of California, and elsewhere, during and in relation to a crime of violence for which he may be prosecuted in a court of the United States, to wit: transportation of an explosive with intent to kill and injure and mailing an explosive device with intent to kill injure, as charged in counts Eight and Nine, the defendant knowingly did use and carry a firearm, that is, a destructive device, in violation of Title 18, United States Code, Section 924 (c) (1).
