U S D C: Nited Tates Istrict Ourt
U S D C: Nited Tates Istrict Ourt
U S D C: Nited Tates Istrict Ourt
AUSA:
1, PageID.1
J. MichaelFiled 09/21/21 Telephone:
Buckley Page 1 of(313)
26 226-9100
AO 91 (Rev. 11/11) Criminal Complaint Special Agent: Sean Flood Telephone: (313) 965-2323
CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
On or about the date(s) of September 15, 2021 in the county of Cheboygan in the
Eastern District of Michigan , the defendant(s) violated:
Code Section Offense Description
18 U.S.C. § 1951 Extortion
Complainant’s signature
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3. I have been employed as a special agent with the FBI since January 2019. As
a Special Agent with the FBI, my duties include the investigation of alleged
violations of federal criminal laws, including the subject offenses, 18 U.S.C.
§ 1951 (Extortion), and 18 U.S.C. § 844(i) (Attempted Damage or
Destruction of Buildings Used in Interstate Commerce).
5. Based on my training and experience and the facts set forth in this affidavit,
there is probable cause to believe that, in the Eastern District of Michigan,
Northern Division, and elsewhere, JOHN ALLEN has committed violations
of federal criminal law, including 18 U.S.C. § 1951 (Extortion), and 18
U.S.C. § 844(i) (Attempted Damage or Destruction of Buildings Used in
Interstate Commerce).
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PROBABLE CAUSE
8. On August 26, 2021, law enforcement found a second letter at another tower
site near W19524 US-2, Gould City, Michigan. This is located on US-2 near
the Mackinac/Schoolcraft County line. This letter was also inside a polka dot
envelope, inside a sealed zip lock bag, but was found attached to the fence
with a black zip tie (circled in red). This letter was photographed and
collected as is, and was not opened. Here is a photo of the letter attached to
the fence in Mackinac County.
9. On August 26, 2021, the Ontonagon County Sheriff's Office reported that on
August 25, 2021, a Volterra Systems cell tower technician found another
letter at a tower located near 1199 Giesau Drive, Ontonagon Village,
Michigan. The letter was inside the same type of polka dot envelope inside a
sealed zip lock bag, which was attached to the fence with a black zip tie. The
contents of the letter appeared to be identical to the one located in St. Ignace.
10. On August 26, 2021, law enforcement located a black zip tie on the fence
surrounding the cell tower near W7221 Hiawatha Trail, Rexton, Michigan.
No letter could be found, but the zip tie appeared similar to the one found in
Gould City.
11. The letters each indicate that they are from the “Coalition for Moral
Telecommunication (CMT)” and were addressed to “AT&T, Verizon, and
all other Carriers.” In the letters, CMT claimed to be “almost thirty strong”
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and was “prepared to travel throughout this Country and begin distroying
[sic] inner city tower communication” unless several demands were
followed. One demand was that all “telecommunication containing immoral
content must be stopped,” which includes cursing, pornography, and “all
manner of indecent communication.” This demand had a time requirement
of “six months.” Another demand was payment of $5 million, which had a
time requirement “within 180 days.” The letters also noted that if one of its
members were arrested, then “your problems will begin” and the “price will
go up one hundred times.” The group claimed in the letter that its “reach”
was in 27 states. The letters also had “CMT 5101520TG” at the bottom of
them. Images of one of the letters are below.
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12. On September 15, 2021, at approximately 7:30 pm, a white male, wearing a
light-colored hat, a face mask, dark-colored glasses, light-colored shoes,
dark-colored pants, a dark-colored shirt, a light-colored vest, and a dark-
colored watch (based on the investigation, believed to be JOHN ALLEN)
was inside of a sporting goods store located in Sault Ste. Marie, according
to video footage. While inside of the sporting goods store, the person
consistent in appearance with and believed to be JOHN ALLEN was not
wearing gloves. Images from this video footage appear below.
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13. On September 15, 2021, at approximately 7:36 pm, the person consistent
in appearance with and believed to be JOHN ALLEN placed a box (circled
in red) outside of an AT&T Store, located at 2972 W 8th Street, Sault Ste.
Marie, Michigan 49783 (the SAULT STE. MARIE BOX), per video
footage from a nearby store. The AT&T Store is located in the same
shopping complex as the sporting goods store, referenced above. The
SAULT STE. MARIE BOX was a United States Postal Service (USPS)
box, with black tape on it and a wire coming out of it. The person
consistent in appearance with and believed to be JOHN ALLEN was
driving a maroon-colored Chevrolet Uplander, with a trailer hitch attached
to a gray rear bumper, license plate 5WFE503, with the name of a state
containing numerous letters (e.g., California or Washington). However,
law enforcement officers were unable to make out the name of the state on
this license plate with certainty from this video footage. This vehicle is
consistent with and appears to be the VEHICLE in paragraph 6. After
discovering the license plate number of this vehicle from this footage, law
enforcement officers conducted searches for this license plate number at
the Mackinac Bridge Authority, described in paragraph 6. Images of the
person consistent in appearance with and believed to be JOHN ALLEN
leaving the SAULT STE. MARIE BOX and the VEHICLE appear below.
The person consistent in appearance with and believed to be JOHN
ALLEN was wearing gloves at the time he left the SAULT STE. MARIE
BOX.
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16. On September 16, 2021, at approximately 8:44 am, the Cheboygan Police
Department was dispatched to the Verizon Store in Cheboygan, as a
Verizon Store employee had discovered a suspicious package. Once the
employee realized the package had a wire sticking out of it, the employee
called 911. Cheboygan police arrived, and then contacted the MSP Bomb
Squad for disposal. This package was also a USPS box with black tape and
a wire coming out of it; it looked similar in size and coloring as the
CHEBOYGAN BOX left by the person consistent in appearance with and
believed to be JOHN ALLEN. I therefore believe that the suspicious
package and the CHEBOYGAN BOX left by the person consistent in
appearance with and believed to be JOHN ALLEN are the same. Law
enforcement analyzed the package and observed it to be consistent with a
pipe bomb. Officers also determined the package contained material that,
when contained, can detonate when initiated by an outside force such as
heat, shock, or friction. The package also contained metal BBs.
17. On September 16, 2021, at approximately 8:50 am, officers from the Sault
Ste. Marie Police Department responded to the report of a suspicious
package at the AT&T Store in Sault Ste. Marie. In response, the Sault Ste.
Marie Police Department requested support from various law enforcement
agencies, including the MSP Bomb Squad and the FBI. The suspicious
package was a USPS box with black tape and a wire coming out of it; it
looked similar in size and coloring as the SAULT STE. MARIE BOX left
by the person consistent in appearance with and believed to be JOHN
ALLEN. I therefore believe that the suspicious package and the SAULT
STE. MARIE BOX left by the person consistent in appearance with and
believed to be JOHN ALLEN are the same. The device in the SAULT
STE. MARIE BOX contained nails instead of metal BBs but was
otherwise similar to the device in the CHEBOYGAN BOX described
above. Below is an image of one of the devices.
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18. The two devices recovered from the CHEBOYGAN BOX and the SAULT
STE. MARIE BOX were examined by the Explosives Unit, FBI
Laboratory, which concluded that the two devices were improvised
explosive devices (IEDs), also commonly referred to as homemade bombs
or pipe bombs. From the FBI Lab’s information, and based on my training
and experience, I conclude that the two items are destructive devices,
commonly referred to as bombs or IEDs. An IED is generally comprised of
an explosive main charge, a fuzing system, and a container, all of which
were present. Properly assembled and initiated, the potential explosion
from these devices could cause property damage, personal injury, and/or
death. Each of the devices consisted of a metal pipe nipple with two metal
end caps, which provided containment for the low explosive powder main
charge. Metal spheres and nails were found within the powders of each
device. Hardened objects such as these enhance the explosive effect,
propelling fragments of metal outwards at high velocities which can cause
additional damage and injuries. Each device contained black granular
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19. Both the SAULT STE. MARIE BOX and the CHEBOYGAN BOX each
contained handcuffs. “CMT” was written on both boxes, and “Handcuff
Johnny” was written on the CHEBOYGAN BOX, while “HJ” was written
on the SAULT STE. MARIE BOX. In addition, both boxes contained
language indicating that this was the “last warning,” and that next time, it
would be during “business hours” (circled in red in the photograph below).
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20. The AT&T Store in Sault Ste. Marie and the Verizon Store in Cheboygan
both participate in interstate commerce and engage in activities that affect
interstate commerce. Among other things, both stores sell cellular
telephones and other electronic devices that are manufactured outside the
State of Michigan. Both stores also sell cellular telephone services, which
involve interstate communication and interstate commerce. Likewise, the
cell towers in the Upper Peninsula at which the letters were placed are
instruments of interstate commerce.
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tower sites. An image of the vehicle, taken from the law enforcement
database, appears below.
24. The law enforcement database returned another positive result for license
plate number C7370. Specifically, on September 15, 2021, at
approximately 3:39 pm, this license plate was identified traveling
northbound on the Mackinac Bridge. The vehicle with this license plate
appears to be similar to the VEHICLE. The vehicle has a trailer hitch and a
gray bumper, and is a maroon van, which are characteristics consistent
with the VEHICLE. Also, this is the same date (September 15, 2021) that a
vehicle that appears to be the VEHICLE was identified traveling
southbound across the Mackinac Bridge at approximately 9:37 pm. In
addition, as noted above, on this date, the person consistent in appearance
with and believed to be JOHN ALLEN placed the boxes with explosives at
the two locations (AT&T Store in Sault Ste. Marie and Verizon Store in
Cheboygan). Specifically, this travel relates to the crime because it shows
the VEHICLE in (and outside of) the Upper Peninsula during the same
days/times when the criminal acts described above took place. An image of
the vehicle, taken from the law enforcement database, appears below.
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25. Overall, video footage at the Mackinac Bridge shows the VEHICLE
traveling northbound on the Mackinac Bridge on August 24, 2021, with the
California license plate and traveling southbound on August 24, 2021 on
the Mackinac Bridge with the Michigan license plate. Additional video
footage shows the VEHICLE traveling northbound on the Mackinac
Bridge on September 15, 2021 with the Michigan plate and traveling
southbound on the Mackinac Bridge on September 15, 2021 with the
California plate. I submit there is probable cause to believe that the plates
were switched, given the similarities of the vehicles and individuals
driving the vehicles. Based on my training and experience, suspected
criminals engage in this type of tactic to avoid detection by law
enforcement. Specifically, the images below from the Mackinac Bridge
Authority appear to show the same VEHICLE, with different license
plates. The top image is from September 15, 2021, and the bottom image is
from August 24, 2021.
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26. In addition, the individual who is driving the VEHICLE with the Michigan
license plate appears to have similarities with the individual who is driving
the VEHICLE with the California license plate, based on images from the
Mackinac Bridge Authority. Specifically, the individual appears to be
white and wearing a dark-colored watch on the left wrist. As indicated in
the video footage of the person consistent in appearance with and believed
to be JOHN ALLEN placing the device at the AT&T Store in Sault Ste.
Marie, the person consistent in appearance with and believed to be JOHN
ALLEN was wearing a dark-colored watch on his left wrist.
28. On September 18, 2021, the FBI obtained records regarding JOHN
DOUGLAS ALLEN from PayPal. PayPal had records on JOHN
DOUGLAS ALLEN and a woman who appears to be JOHN ALLEN’s
wife. The wife’s PayPal account was associated with a particular email
address. The FBI conducted open source research on this email address.
This email address is tied to a LinkedIn account under the name “John
Allen.” The description on the account is “Retired underground miner - TG
Chenicals [sic] Greater Saginaw – Midland - Bay City area.” As noted
above, the letters found at the cell tower sites in the Upper Peninsula had
“CMT 5101520TG” typed on them (note the “TG” in “TG Chenicals” on
the LinkedIn profile matches the “TG” that appears as the last two
characters in the content in the letters).
29. The FBI obtained a phone number associated with the PayPal accounts of
JOHN ALLEN and a woman who appears to be JOHN ALLEN’s wife. Per
subscriber records from service provider Ooma, this phone number is
linked to a customer named JOHN ALLEN, with an address of 2XX North
Street, Whittemore, Michigan 478870.
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33. On September 20, 2021, law enforcement officers observed a white male
exit 2XX North Street and enter the VEHICLE and drive away. A
comparison of the observed white male to JOHN ALLEN’s driver’s license
photograph and information confirmed that the white male who exited the
2XX North Street was JOHN ALLEN.
34. On September 20, 2021, law enforcement officers observed JOHN ALLEN
depart the 2XX North Street in the VEHICLE, go to the post office at 209
S Bullock Street, Whittemore, MI 48770, go to a gas station in
Whittemore, MI, and eventually go back to 2XX North Street, exit the
VEHICLE and enter 2XX North Street.
35. On September 20, 2021, a law enforcement officer who observed JOHN
ALLEN at 2XX North Street that day characterized JOHN ALLEN as
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39. During the interview, JOHN ALLEN advised agents of the following,
among other things. He created about three or four letters, signed from the
Coalition for Telecommunication (CMT), and left them at cell towers in
the Upper Peninsula. He specifically recalled leaving a letter at the tower
near road US-2 and the tower in Ontonagon. All of the zip ties he used
were pre-looped. JOHN ALLEN confirmed he switched the plates on his
vehicle to avoid detection by law enforcement. Additionally, he tried to
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disguise his vehicle further by removing the hitch attached to it. However,
JOHN ALLEN stated that he realized that he had made a mistake when he
noticed the emblem for the auto dealership on the rear of the vehicle could
not be removed. JOHN ALLEN bought the components of the bombs
about one year ago at various hardware stores. He used cash to buy these
components to avoid detection by law enforcement. For the past year, the
bombs were in a box at his property. He waited a year to build up the
courage to place them. JOHN ALLEN obtained the California license plate
referenced above at a flea market in Bay City, Michigan. JOHN ALLEN
noted he sent additional letters, addressed to AT&T and Verizon, to AT&T
headquarters. These letters were similar to the letters he left at the cell
towers in the Upper Peninsula. However, these mailed letters included
instructions on how to pay JOHN ALLEN.
40. JOHN ALLEN also advised he placed the packages at the AT&T Store in
Sault Ste. Marie and the Verizon Store in Cheboygan. He described what
he wrote on the boxes, including the reference to “Handcuff Johnny” and
the threat that next time, it would happen during business hours. “Handcuff
Johnny” referred to JOHN ALLEN’s belief that he (i.e., “Johnny”) would
end up in handcuffs as a result of his actions. JOHN ALLEN indicated that
he placed handcuffs in the packages. He also described the green fuse
sticking out of them. He did not remember which package went to which
cell phone store. After leaving the first package at the AT&T Store in Sault
Ste. Marie, JOHN ALLEN stated that he got scared because he thought
someone had seen him. But he continued to travel to Cheboygan to leave
the second package. JOHN ALLEN stated that he created and placed the
letters and bombs because he became dissatisfied with all of the immoral
content, including pornography, on phones and cable television. JOHN
ALLEN advised that he acted alone, and that there is no CMT group
composed of multiple individuals. He stated that he only made the two
bombs described above.
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CONCLUSION
42. Based on the aforementioned information, I respectfully submit there is
probable cause to believe that, in the Eastern District of Michigan,
Northern Division, and elsewhere, JOHN DOUGLAS ALLEN, d/o/b
XX/XX/1946, did violate Title 18 U.S.C. § 1951 (Extortion), and Title 18
U.S.C. § 844(i) (Attempted Damage or Destruction of Buildings Used in
Interstate Commerce).
43. Based on the foregoing, I request the Court issue the proposed complaint.
Respectfully submitted,
Sean Flood
Special Agent
FBI
_________________________________________
Honorable Patricia T. Morris
UNITED STATES MAGISTRATE JUDGE
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