•

.
AO 91 (Rev. 11/82)
rN(Q; rp)f
II

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IL
I CRIMINAL COMPLAINT
lSI On
SITUATIONAL AWARENESS AND ACTIONABLE INTELLIGENCE

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

DOCKET NO.
UNITED STATES OF AMERICA
v.
MAGISTRATE'S CASE NO .
ROBERT PAUL RUNDO, ROBERT BOMAN,
TYLER LAUBE, and AARON EASON
..
"R- .102.79 i
Complaint for violation of Title 18, United States Code, Sections 2101,371

NAME OF MAGISTRATE JUDGE LOCATION

UNITED STATES
THE HONORABLE STEVE KIM MAGISTRATE JUDGE Los Angeles, California

DATE OF OFFENSE PLACE OF OFFENSE ADDRESS OF ACCUSED (IF KNOWN)

March 25,2017- February Los Angeles County

2018
COMPLAINANT'S STATEMENT OF FACTS CONSTITUTING THE OFFENSE OR VIOLATION:

[18 u.s.c. §§ 2101, 371]

Between at least March 25, 2017, and February 12, 2018, in Los Angeles County, within the Central District of California, and
elsewhere, defendants ROBERT PAUL RUNDO, ROBERT BOMAN, TYLER LAUBE, and AARON EASON were part of an
agreement to use, and in fact used facilities of interstate or foreign commerce with intent to incite, organize, promote, encourage,
participate in, or carry on riots, or to commit acts of violence in furtherance of a riot, or to aid or abet any person in inciting or
participating in or carrying on a riot or committing any act of violence in furtherance of a riot, and during such use, performed or
attempted to perform an overt act for one or more of the purposes specified above, in violation of Title 18, United States Code,
Sections 2101, 37L

BASIS OF COMPLAINANT'S CHARGE AGAINST THE ACCUSED:

(See attached affidavit which is incorporated as part of this Complaint)

MATERIAL WITNESSES IN RELATION TO THIS CHARGE: N/A

/ /J
Being duly sworn, I declare that the
foregoing is true and conect to the
best of my lmowledge.
SIGNATURE OF COMPLAINANT

SCOTT BIERWIRTH
OFFICIAL TITLE
il/5/,
v
1f {/

Special Agent, Federal Bureau of Investigation

Sworn to before me and subscribed in my presence,

SIGNATUREOFMAGISTRATE ~ ,. ~ DATE

..
~- -~
~~; .. October 20, 2018
(IJ See Federal Rules of Cnmmal Procedure 3 and 54

AUSA David Ryan x4491 REC: Detention

 AFFIDAVIT

I, SCOTT J. BIERWIRTH, being duly sworn, declare and state as

follows:

I. INTRODUCTION
1. I am a Special Agent with the Federal Bureau of

Investigation (“FBI”) in Los Angeles, California and have been

so employed for approximately ten months. I am currently

assigned to a counter-terrorism squad, where I specialize in the

investigations of domestic terrorist groups. I attended 21

weeks of New Agent Training at the FBI Academy in Quantico,

Virginia. Prior to joining the FBI, I was an Infantry Officer

in the United States Army, where I trained for counter-terrorism

related missions across the globe for over four years.

2. Through my training and experience in the FBI and the

United States Army, I am familiar with terrorist organizations’

methods of operations, including their use of social media to

communicate regarding coordination of strategic ideological

goals, recruit and radicalize individuals, and coordinate

violent extremist activities and other criminal activities to

generate funds for the terrorist organization.

II. PURPOSE OF THE AFFIDAVIT

3. I make this affidavit in support of criminal

complaints and arrest warrants for Robert Rundo (“RUNDO”),

Robert Boman (“BOMAN”), Tyler Laube (“LAUBE”), and Aaron Eason

(“EASON”) for violations of Title 18, United States Code,

Sections 2101 (Riots) and 371 (Conspiracy).

1
 4. The facts set forth in this affidavit are based upon

my personal observations, my training and experience, and

information obtained from other agents and witnesses. This

affidavit is intended to show merely that there is sufficient

probable cause for the requested complaints and warrants and

does not purport to set forth all of my knowledge of or

investigation into this matter. Unless specifically indicated

otherwise, all conversations and statements described in this

affidavit are related in substance and in part only with

original typographical errors and all dates are approximate.

III. SUMMARY OF PROBABLE CAUSE

5. As described more fully below, RUNDO, BOMAN, LAUBE,

and EASON (collectively, the “defendants”) are members of the

“Rise Above Movement” (“RAM”), a white supremacy extremist group

headquartered in Southern California. Throughout 2017, the

defendants and other RAM members traveled to political rallies,

including in Huntington Beach, California on March 25, 2017,

Berkeley, California on April 15, 2017, San Bernardino,

California on June 10, 2017, and Charlottesville, Virginia on

August 11-12, 2017. RAM members violently attacked and

assaulted counter-protestors at each of these events.

6. On October 10, 2018, four RAM members were indicted in

the Western District of Virginia for Conspiracy to Riot and

Riots, in violation of 18 U.S.C. §§ 371, 2101, as a result of

their participation in the events at Huntington Beach, Berkeley,

2
and Charlottesville, Virginia. See United States v. Daley et

al., 3:18-CR-00025 (W.D. Va.).1

7. The defendants and other RAM members used facilities

of interstate commerce with the intent to organize, promote,

encourage, participate in, or carry on riots in at least two

ways. First, the defendants used the Internet to coordinate

combat training in preparation for the events, to arrange travel

to the events, to coordinate attendance at the events, and to

celebrate their acts of violence in order to recruit members for

future events. Second, the defendants and other RAM members

traveled to the April 15, 2017 event in Berkeley in a van that

EASON rented using his Visa credit card.

IV. STATEMENT OF PROBABLE CAUSE

8. Based on my training and experience, my personal

investigation into this matter, my conversations with other law

enforcement officers, and my review of open-source materials and

law enforcement reports, I know the following:

A. Background on RAM
9. RAM was founded in or around the winter of 2016-2017

by several founding members, including RUNDO and Ben Daley

(“Daley”). According to private Facebook messages sent by Daley

in or around June 2017, RAM was originally branded as the “DIY

On October 2, 2018, United States Magistrate Judge Jean P.

1
Rosenbluth issued search warrants for the premises of several
RAM members, including RUNDO and BOMAN, in Case Numbers 2:18-MJ-
2592, and 2:18-MJ-2598 (C.D. Cal.). During those searches,
agents received physical evidence of RUNDO and BOMAN’s
participation in RAM, as well as several digital devices, which
are still being reviewed.

3
DIVISION,” but formally rebranded to the Rise Above Movement in

2017.2

10. RAM represents itself publicly, through videos and

other public online postings, as a combat-ready, militant group

of a new nationalist white supremacy/identity movement. For

example, RAM members maintained a Twitter account with the user

name “@RiseAboveMvmt” (the “RAM Twitter account”), which posted

videos and pictures of RAM members conducting training in hand-

to-hand combat, often interspersed with video clips of RAM

members assaulting people at political events, with their faces

partially obscured by distinctive skeleton or American flag

masks. RUNDO, BOMAN, and LAUBE appear in several of these

videos and photographs. The photographs below, posted by the

RAM twitter account, depict RUNDO and Daley training above the

words “WHITE UNITY,” and several RAM members, with RUNDO front

and center, posing in skeleton masks.

2 I reviewed contents from Daley’s Facebook page pursuant

to a search warrant issued on April 4, 2018 from the Honorable
Joel C. Hoppe, United States Magistrate Judge, Western District
of Virginia, in Case Number 3:18-MJ-00007 (W.D. Va.).

4
 11. Based on my review of private messages sent by the RAM

Twitter account, I believe the account was operated by RUNDO.

For example, on April 11, 2018, the RAM Twitter account sent a

direct message to another Twitter user stating, “I am going over

to Europe next week and will be competing in a pan European

[mixed martial arts] event.” Based on my review of Customs and

Border Protection (“CBP”) records, law enforcement databases,

and subsequent interviews with RUNDO, I know that RUNDO traveled

to Europe in April 2018 and participated in a mixed martial arts

event.

12. The RAM Twitter account regularly posted content in

support of the group’s white supremacy extremist ideology. For

example, on February 5, 2018, the RAM Twitter account posted a

photograph of RAM members covering their faces with books with

the accompanying text, “When the squads not out smashing commies

. . . #nationalist #lifestyle.” On March 9, 2018, the RAM

Twitter account posted a photograph of RAM members posing with

their faces partially covered with black skeleton masks and the

hashtags, “#nationalist #ultraright.” On March 20, 2018, the

RAM Twitter account posted a photograph of a man doing physical

exercises next to a banner depicting one person kicking another

and the text, “GOOD NIGHT LEFT SIDE,” appearing to endorse the

use of physical violence against others who do not share RAM’s

“ultraright” ideology.

13. Based on my review of private social media

communications between RAM members, I know that RAM leaders

discourage RAM members from using explicitly violent or

5
extremist language in public social media postings in order to

avoid generating unwanted attention or dissuading potential

recruits. For example, in private Facebook messages on August

25, 2017, an associate of Daley’s complimented Daley on a recent

RAM promotional video and said he was interested in getting

involved with RAM. Daley wrote, “Yeah man. If your still in LA

area it’ll probably be me meeting up with you. We go for the

implicit look so you’ll have to change your [style] up a bit

when your with us.” The associate responded, “Yea that’s fine

[I] can grow my hair out if need be, drop the boots and braces

look etc.” Daley responded with an image of an “OK” symbol, and

stated, “Trust I did it for a long time too but ultimately the

80s in that style of nationalism proved to be ineffective. . . .

[I] think its time to reimagine the nationalist look and

playbook, we have become predictable that needs to change.” In

January 2018, in private Facebook messages to another associate,

Daley wrote: “I would be mindful of saying anything that could

be misconstrued as a call to violence. I know people who

literally have had feds show up at there door over posts. [J]ust

food for thought. Trust I’m not speaking in terms of morality

rather practicality.”

14. Notwithstanding Daley’s admonishment, RAM and its

members documented their white supremacy extremist ideology in

both private and public Internet postings. In a video taken by

a RAM associate, later posted online, the RAM associate asked

RUNDO to say the “14 words.” Based on my training and

experience, I know that “14 words” refers to a slogan commonly

6
known and used by white supremacy extremists and neo-Nazis that

states: “We must secure the existence of our people and a future

for white children.” RUNDO responded, “I’m a big supporter of

the fourteen, I’ll say that.”

15. RAM members also used graffiti to promote their white

supremacist ideology. On January 12, 2018, law enforcement

officers took photographs of graffiti in the Aqua Chinon Wash

Tunnel in Irvine, California, where RAM members have posted

videos of the group conducting physical training exercises. The

photographs showed the words “RAM” and “RISE ABOVE” written in

yellow spray paint inside the tunnel, as well as a Celtic cross

with the number “14” over the top in black spray paint. As

discussed above, the number “14” is commonly used among white

supremacy extremists and neo-Nazis to refer to the “14 words.”

Based on my training and experience, I know that the image of

the Celtic cross, combined with the number 14, is commonly used

by white supremacy extremists and neo-Nazis to express their

ideology.

16. In the Spring of 2018, according to reports of

interviews conducted by Customs and Border Protection officers

as well as public posts on social media accounts of RAM and

several of its members, several RAM members, including RUNDO,

Daley, and Michael Miselis (“Miselis”) traveled to Germany,

Ukraine, and Italy to celebrate Adolf Hitler’s birthday and meet

with members of European white supremacy extremist groups,

including a group known as White-Rex. Shortly after that trip,

the RAM-affiliated clothing company Right Brand Clothing, of

7
which RUNDO is the registered owner, posted several photographs

on its Instagram page of RUNDO and other RAM members in Germany,

Ukraine, and Italy, slap-tagging stickers on various buildings

and poles with the RAM logo and the words “RAPEFUGEES ARE NOT

WELCOME HERE,” “FCK ANTIFA,” and “REVOLT AGAINST MODERN . . .

ACTIVITISM–ATHLETICS–VIRTUE . . . RIGHT SIDE.” RAM members also

posted online a video showing Daley in the Ukraine performing a

salute known to be associated with the western Hammerskins, a

well-established violent white supremacy extremist group that is

associated with RAM, and of which Daley was a member before co-

founding RAM.

17. On August 1, 2018, an Instagram user “tagged” Right

Brand Clothing’s account in a post containing a photograph of

RAM members during their trip to Germany, Ukraine, and Italy

meeting with Olena Semenyaka, the leader of the International

Department for the National Corps, which is a political party in

the Ukraine that was founded in 2016 out of a regiment of the

Ukranian military called the Azov Battalion. Based on my

training and experience, I know that the Azov Battalion is a

paramilitary unit of the Ukranian National Guard which is known

for its association with neo-Nazi ideology and use of Nazi

symbolism, and which is believed to have participated in

training and radicalizing United States-based white supremacy

organizations. The text associated with the post stated,

“@rightbrandwear it was an honor to meet the singer and patriot

from #8l8th #nationalist #blackmetal #ukraine #antiantifa.”

8
 B. March 25, 2017: RUNDO, BOMAN, LAUBE, and Other RAM
Members Attacked Counter-Protestors at a Political
Rally in Huntington Beach, California
18. Based on my review of law enforcement reports, videos

and photographs posted online, and public and private

communications between RAM members, I know that groups of RAM

members have attended public rallies together, acted in concert

to commit acts of violence, and planned such acts in advance

using the Internet.

19. For example, I reviewed a recording of a December 2016

RAM group phone call in which Daley shared RAM’s strategic plan

to attend rallies in 2017 in order to provide “security.” Based

on my training and experience, evidence gathered in this

investigation, and the context of this discussion, Daley and the

RAM group, who had no official role in the rallies they planned

to attend, appeared to be discussing appearing as security

personnel at the rallies so they could be prepared to engage in

violent confrontations that may erupt at the rallies. On the

call, Daley instructed listeners to wear specific clothing, such

as polo-style shirts and khakis, to get military style haircuts,

and to maintain an organized presence at the events.

20. On March 25, 2017, at least several hundred people

attended a “Make America Great Again” rally at the Bolsa Chica

State Beach in Huntington Beach, California. The rally, and the

violence that ensued, were captured on video by numerous

journalists and participants. Throughout the morning, the

attendees engaged in various activities, including chanting and

9
making speeches. As those activities were ongoing, a small

group of counter-protestors gathered nearby on the beach.

21. Videos uploaded online show hundreds of rally

attendees marching south along the beach. At the same time, to

the north of the marchers, videos show a small group of rally

attendees, including several RAM members carrying signs that

read “DEFEND AMERICA” and “Da Goyim Know,” did not march south,

but instead confronted the counter-protestors. Based on my

training and experience, I know that the phrase “da goyim know”

is commonly used by white supremacist extremists to refer to

their supposed knowledge of a Jewish conspiracy to control world

affairs.

22. Videos show several rally attendees confronting,

pushing, and then punching two journalists from a local news

publication. As the journalist stumbled backward, LAUBE grabbed

the journalist’s shoulder with his left hand, and punched him

three times in the face. A counter-protestor then released

pepper spray, leading the crowd to momentarily disperse. LAUBE

is depicted assaulting the journalist in the screenshot below.

10
 23. Videos show a group of approximately three to five

counter-protestors then turned away from the group of rally

attendees and walked north along the beach while a small group,

led by RUNDO, BOMAN, LAUBE, Daley, and other RAM members pursued

them.

24. Approximately 20 seconds later, videos show that BOMAN

caught up to one of the counter-protestors and kicked him in the

back, as depicted below.

25. A second counter-protestor turned and approached

Daley, who shoved the counter-protestor in response. The

counter-protestors continued walking north away from the RAM

members, as the RAM members continued pursuing them. Another

rally attendee walking alongside the RAM members approached one

of the counter-protestors and punched him in the face, knocking

him to the ground.

11
 26. Seconds later, videos show RUNDO approached another of

the counter-protestors from behind and punched him in the back

of the head. BOMAN ran up behind RUNDO toward the counter-

protestor, but turned back after a second counter-protestor

released pepper spray. RUNDO then turned to the second counter-

protestor, punched him in the back of the head, grabbed the back

of his neck, and threw him to the ground, landing on top of him.

RUNDO then held the counter-protestor down with his left hand

and threw several punches at the counter-protestor’s head while

other RAM members looked on, cheered, and prevented others from

intervening, as depicted in the screenshot below.

27. After several seconds, video shows the counter-

protestor released pepper spray, leading RUNDO to back away from

him. The counter-protestor then ran northeast from the beach

into a parking lot, while other rally attendees pursued him,

pushing him and hitting him with flag poles. According to

12
eyewitnesses, another RAM member pursued the counter-protestor

and threw a large rock at him, striking him in the chest.

28. During and after these violent confrontations, videos

show the majority of the rally attendees continued peacefully

marching south down the beach, while RUNDO, BOMAN, LAUBE, Daley,

and other RAM members, remained in the same area with a group of

other rally attendees. Approximately 20 minutes later,

approximately five counter-protestors arrived at the beach near

where the location where the RAM members remained gathered. The

RAM members, including RUNDO, BOMAN, LAUBE, and Daley, led a

group of 15-20 men who pursued the counter-protestors for over a

minute as the counter-protestors walked north along and the

beach to the parking lot.

C. March-April 2017: RAM Members Celebrated Their

Assaults at Huntington Beach and Prepared for Berkeley
29. Based on my review of the contents of Daley’s cell

phone, I know that later on March 25, 2017, Daley sent a text

message to another RAM member, stating, “Front page of the

stormer we did it fam.” Based on my training and experience, I

know that the “Daily Stormer” is a news website and online

community forum that is well known among neo-Nazis and white

supremacy extremists, which published an article after the

Huntington Beach event titled “Trumpenkriegers Physically Remove

Antifa Homos in Huntington Beach.”3 Based on my review of the

3 Based on my training and experience, I know that

“Trumpenkriegers” is intended to mean “Fighters for Trump.”
“Physical removal” is a term commonly used by white supremacy
extremists to refer to the goal of separating or “physically

13
contents of BOMAN’s Facebook account, I know that BOMAN posted

the Daily Stormer article on his Facebook page, along with the

comment, “We did it fam.”4

30. I reviewed photographs of the Huntington Beach rally

published on the Internet. One image, which appears to have

been posted by the DIY Division’s Instagram account, depicts

RUNDO punching a counter-protestor, with the words “Physical

Removal” superimposed across the top. That image is depicted

below.

31. The RAM Twitter account later posted a picture of RAM

members, including RUNDO, BOMAN, and Daley, at the Huntington

Beach rally, standing behind a sign stating “Defend America,”

with the accompanying text, “Shortly after this pic antifa was

removing” those with viewpoints or lifestyles that are viewed as

undesirable.
4 I reviewed contents from BOMAN’s Facebook page pursuant to
a search warrant issued on September 4, 2018 from the Honorable
Paul L. Abrams, United States Magistrate Judge, Central District
of California, in Case Number 2:18-MJ-02307 (C.D. Cal.).

14
btfo in Huntington Beach.” Based on my training and experience,

I know that “BTFO” stands for “Blown The Fuck Out.”

32. Based on my review of the contents of Miselis’s cell

phone, I know that, on March 27, 2017, EASON sent a text message

to Miselis, who appears to have first been introduced to the

other RAM members at the Huntington Beach rally, inviting him to

the rally in Berkeley on April 15, 2017. EASON wrote, “It’s

Aaron from the HB rally. I wanted to let you know that the

organizers of the free speech rally at Berkeley on April 15 are

paying for rooms for our guys. . . . We're expecting about 15

solid guys in our caravan coming up from So Cal and we can

accomodate as many as you can give. Quality only of course. If

you have good people who aren’t cut out for security, the

organiziers are looking for people to fill roles like

photography. Anyone who doesn’t come will wish they had. Oh and

we have hand to hand and formation fighting training in San

Clemente this Saturday. It’s not required, but we’d like to get

everyone we can there.”

33. Later on March 27, 2017, Daley wrote to Miselis to

invite him to the Berkeley rally, and Miselis replied, “Right

on, Aaron from the rally mentioned some folks were going up.

I’ll drop the line on our end and see if anyone else can make

it.” Daley replied, “Preciate we need all heads we can get.”

34. On March 29, 2017, EASON wrote to MISELIS again,

stating, “Training is a go. Saturday at 11 am. Marblehead

Park, San Clemente. . . . We’ll probably have equipment for

shield and stick training and our formation tactics ready.”

15
 35. On April 12, 2017, Daley wrote to Miselis, “Got a 11

van reserved for Friday.” Asking everyone to kick in 20 or 40.

Thinking of leaving around 1130. Does that time work for you?”

Miselis replied, “Absolutely.”

36. According to records received from Airport Van Rental,

on April 14, 2017, EASON rented a 12-15 passenger van for

$493.87, using a Visa credit card with account number ending in

0807. Photographs posted online show BOMAN, Daley, Miselis, and

other RAM members posing in front of the van following the event

in Berkeley on April 15, 2017.

D. April 15, 2017: RUNDO, BOMAN, EASON, and Other RAM

Members Attacked Counter-Protestors at a Political
Rally in Berkeley, California
37. On April 15, 2017, RUNDO, BOMAN, EASON, Daley, and

other RAM members attended a political rally at Martin Luther

King Jr. Civic Center Park in Berkeley, California. Videos

posted online also show RUNDO, BOMAN, EASON, and Daley standing

alongside other RAM members displaying a sign that stated

“Defend America” with their hands taped in the manner of a boxer

or mixed martial arts fighter, wearing grey and black athletic

shirts with their faces partially covered by the distinctive

skeleton masks shown in RAM training videos. Videos posted

online show that rally attendees and counter-protestors were

initially separated by orange fencing. After several minutes,

several RAM members crossed the orange fencing and assaulted

counter-protestors. In one video, BOMAN is shown punching a

counter-protestor in the face. In another video, BOMAN is shown

punching a person while holding the person down on the ground.

16
The images below depict BOMAN at the Berkeley rally preparing to

fight with his hands taped and then BOMAN punching a counter-

protestor while EASON, Miselis, and other RAM members stood

beside him.

38. In another video, another RAM member is shown

repeatedly punching a person while two unidentified people and a

second RAM member appear to hold the person down in a crouched

position. In another video, Miselis, Daley, and two other RAM

members are shown repeatedly kicking and punching a counter-

protestor who was crouching in a defensive position, until

police intervened and pushed them away. In another video, RUNDO

is shown approaching a counter-protestor and punching him in the

side of the head.

39. Minutes later, after several RAM members and rally

attendees had crossed the orange fencing separating them from

the counter-protestors, RUNDO, BOMAN, EASON, Daley, Miselis

confronted several counter-protestors. Videos show RUNDO,

BOMAN, and Daley attempting to pull away a banner held by

several of the counter-protestors. After one of the counter-

17
protestors fell to the ground, videos show RUNDO began throwing

punches at multiple different people, including one person who

was falling to the ground. According to Berkeley Police

Department (“BPD”) officers, a BPD officer saw RUNDO punching

the apparently defenseless person in the head, and ordered RUNDO

to stop, but RUNDO did not respond. The BPD officer knocked

RUNDO to the ground to stop the ongoing assault, and RUNDO

punched the officer twice in the head before BPD officers

subdued and arrested him.

40. Several minutes later, EASON, Daley and other RAM

members and rally attendees pursued counter-protestors out of

the park through public streets, chanting “hey, hey, hey,

Goodbye.” Videos show BOMAN confronting counter-protestors and

hitting a counter-protestor in the face. Videos show Daley

climbing over over a barricade separating protestors and

counter-protestors, kicking counter-protestors as they fall down

due to the falling barricade, and then chasing a counter-

protestor and kicking him in the back. Pictures posted online

from after the event show BOMAN, Daley, Miselis, and other RAM

members holding up in celebration the banner that they pulled

away from counter-protestors during the rally.

E. April-August 2017: RAM Members Celebrated Their

Assaults at Berkeley and Prepared for More Events
41. On April 16, 2017, the day after the Berkeley rally,

BOMAN posted a photograph on his Facebook page showing him

punching counter-protestors at what appears to be the rally in

Berkeley the previous day. BOMAN then “liked” the photograph on

18
Facebook. Another RAM member commented on the post, “You can’t

like your own photo you idiot,” and BOMAN responded, “Offff

couuuuurssseeee you can,!!!”

42. On April 16, 2017, BOMAN posted a photograph on his

Facebook page showing himself and fellow RAM members pulling

what appears to be a banner or poster away from counter-

protestors at the Berkeley rally.

43. On April 16, 2017, another RAM member sent a text

message to Miselis describing a video showing Miselis at the

Berkeley event, and Miselis replied, “Hell yeah man. I was

about to jump into that but our guys were just wrecking them,

like not even any room to get a hit in. I was like alrite, u

guys got it handled then lol.”5 Later that day, Miselis sent

another text message describing how one of the guys “up their

fighting with us . . . was pretty based too, apparently he hit

an antifa so hard he dislocated his shoulder.” Miselis wrote,

“I’ve been dealing with my hand all day. Just found a video on

that site where you can see me breaking it on a guys head lol.”

The other RAM member responded, “I’ve been looking at videos.

There’s a grey-shirted storm trooper at the fucking front every,

single, time. You guys were lions.” Miselis replied, “Total

Aryan victory.”

44. On April 21, 2017, EASON sent a text message to

Miselis asking if his broken hand was strong enough to attend

5 “Lol” is an acronym meaning “laugh out loud.”

19
another event at Berkeley on April 27, 2017, stating, “I’m

driving up to deny antifa a face-saving victory.”

45. On May 15, 2017, the RAM Twitter account sent a

message to another Twitter user who had proposed interviewing

RAM leaders for a podcast. The RAM Twitter account replied,

“Maybe if there [is] enough time could mention berekly how we

were the first guys to jump over the barrier and engage and how

that had a huge impact.”

46. On June 1, 2017, Daley sent a private Facebook message

to an associate stating that he and his group “stole yevet

farlarkas banner at the April 15th riots lol.” Daley’s associate

responded, “That subhuman professor from CA. . . . She needs the

rope[,]” appearing to suggest that the professor should be

hanged. Daley responded, “Yep lol.” The associate responded,

“My boy supposedly kicked her in the face.” Based on my review

of publicly available media accounts of the rally in Berkeley on

April 15, 2017, Yvette Felarca was a leader of a local group of

antifa counter-protestors who attended the rally.

47. In May 2017, BOMAN posted a picture on Facebook

showing himself and another RAM member boxing in a garage with

various white supremacist signs and banners posted on the walls.

One of the signs states, “Da Goyim know,” and appears to be the

same sign BOMAN and other RAM members were photographed carrying

at the Huntington Beach rally in March 2017. Another of the

banners appears to be the same banner that Daley claimed he and

his associates stole from Yvette Felarca during the Berkeley

rally in April 2017.

20
 48. On August 10, 2017, BOMAN posted a photograph on his

Facebook page showing himself punching a counter-protestor.

Another Facebook user later commented on the photograph, “U in

Charlottesville?” BOMAN responded, “Naw that was in Berkley.”

F. August 11-12, 2017: Other RAM Members Committed

Violent Assaults at the Unite the Right Rally in
Charlottesville, Virginia
49. Based on my review of RAM members text messages and

Facebook communications, photographs and videos posted online,

and law enforcement reports, I know that, between April and

August 2017, RAM members engaged in regular combat training

sessions and attended additional political events where they

confronted counter-protestors and others who do not share their

ideology. For example, videos posted online show that, on June

10, 2017, RUNDO, Daley, and other RAM members attended an “Anti-

Islamic Law” rally in San Bernardino, California, where they

engaged in violence against counter-protestors, leading to

arrests of three RAM members. On June 13, 2017, Daley wrote a

text message to an associate stating, “We smashed some antifa as

they were leaving.” The associate responded, “If it wasn’t for

the White Nationalists nothing would ever get done. Daley

replied, “This is true would’ve been no victory in Huntington or

Berkeley.”

50. On August 12, 2017, several RAM members, including

Daley and Miselis, attended the “Unite the Right” rally in

Charlottesville, Virginia. RAM members coordinated their

attendance at that rally in the previous months. For example, I

reviewed a screenshot from a group chat on the chatroom hosting

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service Discord, from a subgroup labeled “lodging_wanted” within

a group labeled “Charlottesville 2.0,” in which a user named

“Ben Daley” stated on July 24, 2017, “need room for at least

three Goys from CA. For Friday and Saturday night. Solid sober

respectful experienced at these events all were in Berkeley

riots. Plz let me know.” Based on my training and experience

and facts learned in this investigation, I believe that in this

message, “Ben Daley” was offering his and his associates’

“experience” and presence at the “Berkeley riots” as bona fides,

demonstrating his intent to travel to Charlottesville to create

another riot there, and seeking lodging amongst other white

supremacists willing to host “Goys.”

51. I reviewed another statement posted using Discord, in

a chat subgroup labeled “general_1,” within the “Charlottesville

2.0” group, in which unknown users discussed whether the permit

for the Unite the Right rally had been revoked. After the users

confirmed that the permit had been renewed, user “Ben Daley”

responded, “Good stuff. Regardless we should all still go. Im

flying out from CA with a handful regardless. Fuck these jews.”

52. On July 25, 2017, RUNDO sent a text message to Miselis

stating, “Hey, if you can get in touch with ben, I may have a

place for you guys to stay in Charlottesville.”

53. Videos uploaded to YouTube and published by

individuals and news organizations show Daley, Miselis, and

other RAM members at the rally in Charlottesville with their

hands taped in the manner of a boxer or mixed martial arts

fighter, committing multiple assaults against multiple victims.

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One video shows Daley approaching a man from behind as the man

stood still on the side of the street watching the protestors

march down the street. Daley raised his right hand and punched

the man in the back of the head, causing him to fall to the

ground. Daley then walked up to various counter-protestors who

were standing in the path of the Unite the Right protestors,

punched some counter-protestors in the face, and threw others to

the ground.

G. August 2017-February 2018: RAM Members Celebrated

Their Assaults and Prepared for More Events
54. Based on my review of RAM members text messages and

Facebook communications, photographs and videos posted online,

and law enforcement reports, following the Charlottesville

event, RAM members continued to engage in regular combat

training sessions and post photographs and videos on social

media promoting their assaults at prior rallies. For example,

on September 14, 2017, the RAM Twitter account posted a picture

of RUNDO and another RAM member assaulting counter-protestors at

the Berkeley rally, with the accompanying text: “#antiantifa,

#goodnightleftsisde, #riseabovemovement.”

55. On September 25, 2017, EASON sent a text message to

Miselis stating, “Im back in a position to go hard with

activism. I got sidetracked after Berkeley.” Miselis responded

that “for the time being I think everyone is laying a little low

on account of [Charlottesville] fallout.”

56. In November 2017, RUNDO and Miselis exchanged several

text messages about creating a video promoting RAM. On December

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17, 2017, the “Rise Above Movement” YouTube account posted a RAM

promotional video combining video of RUNDO, BOMAN, LAUBE, and

other RAM members assaulting counter-protestors with photographs

and video of RAM members training in hand-to-hand combat. Based

on my review of text messages between RUNDO and Miselis, in

which RUNDO described putting together a RAM promotional video

and the clips he was using for the video, I believe that RUNDO

orchestrated the creation of the video.

57. On January 10, 2018, the RAM Twitter account wrote,

“What’s up with giving a shoutout to the only alt right crew

that actually beats antifa senseless and wins rallies.”

58. On January 17, 2018, the RAM Twitter account wrote,

“From the guys that [won] very rally they ever attended and

always chased out antifa.”

59. On February 12, 2018, Daley sent a private Facebook

message to an associate stating, “We’re not going be going to

rally’s for a few months cause we got a big trip planned but

definitely after that we’ll be back on the scene. Some good

scenes from the April 15 Berkeley riots halfway thru this

video.” The associate responded, “I’ve never heard of you guys.

Just nationalists or white nationalists?” Daley responded,

“Huwhite. We were the only reason shit was popping off at socal

right wing events. Were not hostile to non whites we just do

our thing the way all other races do theirs. Didn’t want you

thinking I was just some lop critiquing from the sidelines lol.”

60. As described above, RUNDO, BOMAN, LAUBE, and EASON

along with other RAM members, have used the Internet to prepare

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to incite and participate in violence at various political

events, have committed violent assaults while at those events,

and have applauded each other for it and publicly documented

their assaults in order to recruit more members to engage in

further assaults.

V. CONCLUSION
61. Based on the foregoing, there is probable cause to

believe RONDO, BOMAN, LAUBE, and EASON violated Title 18, United

States Code, Sections 2101 (Riots) and

SCOTT J. BIER IRTH, Special Agent

Federal Bureau of Investigation

Subscribed to and sworn

before me on October 2018

THE HONORABLE STEVE KIM

UNITED STATES MAGISTRATE JUDGE

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