Affidavit in Support of Complaint

State of AFFIDAVIT Case No:
Michigan District: 86th

IN SUPPORT OF Circuit:
COMPLAINT
THE COMPLAINING WITNESS, ON INFORMATION AND BELIEF, SAYS:
1. I, Detective/Sergeant Michael Fink, am a Detective Sergeant with the Michigan

Department of State Police and been employed as a law enforcement officer for over
26 years. Affiant has served in multiple capacities during my career with the
Michigan State Police.
2. The Michigan State Police (MSP) and the Federal Bureau of Investigation (FBI)
have jointly investigated an anti-government militia group within Michigan called
the Wolverine Watchmen, an anti-government, anti-law enforcement, militia group
who have performed tactical training at 8008 Dunn Rd., Munith, Michigan (Jackson
County). The Wolverine Watchmen and associates have made terroristic threats
towards government officials and organizations and provided material support for
planned acts of terrorism. The facts of this affidavit and my knowledge of this
investigation come from training, experience, and information provided to me by
Federal Bureau of Investigation (FBI) Special Agents (SA) Henrik Impola and
Jayson Chambers, MSP D/Sgt. Brian Russell and other investigators as part of a
joint domestic terrorism investigation.
3. In early 2020, FBI became aware of groups of individuals in several states that were
discussing a violent overthrow of government and law enforcement entities. These
groups agreed to unite others in their cause and take violent action against
government entities they believed to be violating the U.S. Constitution.
4. The “Wolverine Watchmen” is a militia group who recruited members using a social
media platform, FaceBook, since November 2019. Once recruited, members
communicated via a secure, encrypted messaging platform. Members of Wolverine
Watchmen periodically met for “field training exercises” (FTXs) on private property
in remote areas where they engaged in firearms training and tactical drills to
prepare for the “boogaloo,” a terms referencing a violent uprising against the
government or impending politically-motivated civil war. Joseph Morrison and
Pete Musico are founding members of the Wolverine Watchmen. Joseph Morrison is
considered Wolverine Watchmen’s “Commander” and is known by the online
moniker “Boogaloo Bunyan.”
5. The Wolverine Watchmen have called on members to identify law enforcement

officers home addresses in order to target the officers, have made threats of violence
to instigate a civil war leading to societal collapse, and have engaged in planning
and training for an operation to attack the Capitol of Michigan, and kidnap
Government officials including the Governor of Michigan.
6. Joseph Morrison and Pete Musico are individuals that reside at 8008 Dunn Rd.,
Munith, Michigan located in Jackson County where FTXs have been conducted.
Joseph Morrison and Pete Musico have hosted multiple tactical training sessions
with other members of the Wolverine Watchmen at their property. During these
trainings, specific training was provided for members to learn and practice tactical
maneuvers. The group has drawn upon their members’ individual skills for
trainings including tactical skills, medical knowledge, communications knowledge,
and weapons expertise. For instance, member Paul Bellar, who was appointed the
role of “Sergeant,” had specific expertise in medical and firearms training and
designed tactical exercises for training.
7. Wolverine Watchmen members together with another group of individuals led by

Adam Fox engaged in planning and training for various acts of violence, including
kidnapping politicians and storming the Michigan Capitol Building in Lansing.
8. Ultimately, participants of these trainings and meetings, led by Michigan resident

Adam Fox, went on to engage in a plot to kidnap the Governor of Michigan by the
November 2020 national election. In preparing for this plot, Shawn Fix, William
Null, Michael Null and Eric Molitor all aided in physical surveillance of the
Governor’s private vacation home. Several other members of this conspiracy are
being charged federally for their part in the plot to kidnap the Governor.
9. Based on my training and experience, as well as other information received from

other law enforcement officers and the facts outlined in this affidavit, your Affiant
believes that Michael and William Null conspired with one another and others and
in fact provided material support and resources in the furtherance of terrorist acts.
In particular, William Null and Michael Null have provided assistance for a
nighttime physical surveillance operation of the Governor’s vacation home by acting
as lookouts for Adam Fox and other participants contrary to MCL 750.543k. While
providing material support to a terrorist, Michael and William Null were in
possession of a firearm.
10. Your affiant believes, based upon the facts of this investigation, that the Wolverine
Watchmen as an organization, sub-groups of Wolverine Watchmen, or associates of
Wolverine Watchmen have provided the means and opportunity to commit material
support for terrorism, in violation of MCL 750.411u..
11. By pooling the skills of its members and providing training, the Wolverine
Watchmen organization and its associates have provided training and expertise to
materially support and provide resources to plan, prepare, carry out or facilitate
acts of terrorism.
Count 1 – Providing Material Support for Terrorist Acts
Did knowingly provide material support or resources to be used by a terrorist or terrorist

organizations , to be used in whole or in part, to plan, prepare, carry out, facilitate, or
avoid apprehension for committing an act of terrorism against the United State or its
citizens, this state or its citizens, or a political subdivision of any other instrumentality of
this state or of a local unit of government; contrary to MCL 750.543k(1)(b).
Count 2 – Felony Firearm
Did carry or have in his possession a firearm to-wit: rifle, at the time he committed or
attempted to commit a felony, to-wit: providing material support to a terrorist MCL
750.543k; contrary to MCL 750.227b
FURTHER AFFIANT SAYETH NOT.
Dated: ___________ ________________________________

Detective/Sergeant Michael Fink
STATE OF MICHIGAN
COUNTY OF _______________
Subscribed and sworn to before me
This ___ day of October, 2020.
___________________________________
____________________, NOTARY PUBLIC
___________ COUNTY, MICHIGAN
MY COMMISSION EXPIRES: ___________

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State of AFFIDAVIT Case No:

Michigan District: 86th

THE COMPLAINING WITNESS, ON INFORMATION AND BELIEF, SAYS:

1. I, Detective/Sergeant Michael Fink, am a Detective Sergeant with the Michigan

5. The Wolverine Watchmen have called on members to identify law enforcement

7. Wolverine Watchmen members together with another group of individuals led by

8. Ultimately, participants of these trainings and meetings, led by Michigan resident

9. Based on my training and experience, as well as other information received from

Did knowingly provide material support or resources to be used by a terrorist or terrorist

Count 2 – Felony Firearm

FURTHER AFFIANT SAYETH NOT.

Dated: _ ______________________

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