A. Elohim City.

Elohim City is a 240 acre compound near Muldrow, Oklahoma, consisting of between 25 and 30 families. D.E. 2482 at 19. Elohim City is listed in the publication Terrorist & Extremist Organizations In The United States at 109. According to this publication, Elohim City preaches white supremacy, polygamy and the overthrow of the government. Elohim City is also closely aligned with the extremist The Covenant, the Sword and the Arm of the Lord (CSA) and has been known to store weapons for that group. D.E. 2482 at 19.

The spiritual leader at Elohim City is the Reverend Robert Millar. Elohim City had a close association with the Christian Identity Movement and The Covenant, the Sword and the Arm of the Lord which had its own grievance against the United States government. See D.E. 2191 at 33. The federal government conducted a raid on the CSA on April 19, 1985--exactly ten years to the day prior to the Oklahoma City bombing. See Id. at 33-34; D.E. 2840 (Pretrial Conference: Volume m--Sealed, January 1997 at 181).

Members of the CSA now reside at Elohim City. One of the members of CSA turned on the organization and testified at the trial of Richard Snell in Arkansas. Snell was on trial with others on charges of sedition--that they conspired to destroy the Murrah Building in Oklahoma City with a rocket launcher in the early 1980s. Id. Snell was convicted on unrelated capital charges, sentenced to death in Arkansas, and was executed on the very day of the bombing in Oklahoma City--April 19, 1995. Id. One of his last statments [sic] before he was executed was, "Governor, look over your shoulder, justice is coming." D.E. 3410 at 16 (Pretrial Hearing--SEALED--Not Provided to Defendant Nichols, March 10, 1997). (Information in public press reports). His body is buried at Elohim City.

The government has alleged in the Indictment that the Defendants used a calling card, referred to as the Bridges' Spotlight card, as a means to prevent calls from being traced. See Indictment at 2. Phone records of the Bridges' Spotlight debit card reveal that a call was made from a motel in Kingman, Arizona, to Elohim City minutes before a call was made to a Ryder Truck rental store in Arizona. According to residents at Elohim City, the caller asked to speak to an individual named Andy Strassmeir. Around the same time from the same motel and again with the Bridges' card, nine calls were placed to a National Alliance Office in Arizona. The National Alliance is an organization headed by William Pierce, author of The Turner Diaries--the book characterized by the government as the "blue print" for the Oklahoma City bombing. See D.E. 2166 at 16.

In addition to the alleged phone call to Andy Strassmeir at Elohim City from someone allegedly using the Bridges' calling card, Strassmeir acknowledged meeting Timothy McVeigh at a gun show in Tulsa, Oklahoma in 1993. D.E. 2331 (Exhibit "2" FBI 302 D-12993). Although Strassmeir stated that he was unsure of the exact date of the meeting, he did recall that it took place sometime between the start of the federal raid on the Branch Davidian compound in Waco, Texas, February 28, 1993, and the conclusion of the standoff on April 19, 1993. Id. Strassmeir acknowledged that he attended gun shows with other residents at Elohim City where he was living at the time. He stated that he resided at Elohim City for approximately four years, leaving in August 1995.

Dennis Mahon, who now lives in Tulsa, Oklahoma, where Strassmeir says he met Timothy McVeigh, ran "dial a racist" hotline and would often visit Elohim City to engage in paramilitary training. D.E. 3123 (Exhibit quot;A"). As will be detailed below, a confidential ATF informant has reported that Mahon and Strassmeir discussed "targeting federal installations for destruction," such as the Tulsa IRS Office, the Tulsa Federal Building, and the Oklahoma City Federal Building. According to the ATF informant, Mahon and Strassmeir made at least three trips to Oklahoma in November 1994, December 1994, and February 1995. Id.

Elohim City also housed four of the six individuals arrested and charged with a series of mid-western bank robberies which allegedly were made in the name of "Aryan Revolutionary Army."[9] The four individuals arrested and charged in a series of mid-western bank robberies described themselves as members of the Aryan Revolutionary Army.

The Grand Jury charged the gang of robbers were Richard Lee Guthrie, Jr., Kevin McCarthy, Scott A. Stedeford, Peter Langan, Mark Thomas and Michael Brescia. D.E. 2191 at 17. Richard Lee Guthrie, Jr., committed suicide (allegedly) in his jail cell in Ohio after entering a plea of guilty and offering to cooperate with the federal government in the prosecution of the remaining three. Two of the remaining six, Kevin McCarthy, Scott Stedeford, have ties to Elohim City in that they lived there for several months as did Brescia. Mark Thomas, the leader of the Posse Comitatus in Pennsylvania and an Aryan Nations member, and who was close to two of the mid-west bank robbers, was in Elohim City on the Thursday before the bomb attack on Oklahoma City. D.E. 2191 at 34. Mark Thomas allegedly introduced the four of them to each other in either Eastern Oklahoma or Western Arkansas in 1994. Id.

In the Winter of 1994, or the Spring of 1995, but in any event, before the April 19, 1995, Oklahoma City bombing, federal officials were actively planning a raid on Elohim City. If Elohim City was aware of the raid, then Carol Howe's information that they would strike first and attack the federal government was a real potential. Elohim City knew, or at least strongly suspected, there would be a raid because Rev. Millar admitted his fears and apprehensions to two local sheriffs. Elohim City also had located a series of "spotters" who would advise them of approaching suspect vehicular traffic. Millar also complained of an increase in aerial over-flights of Elohim City and the community also monitored police scanners.

Thus, in the weeks before April 19, 1995, Elohim City (1) was populated by several individuals who later were indicted for armed bank robbery involving the use of bomb threats; (2) was populated by individuals who previously had engaged in armed confrontation with the federal government, exactly ten years before; (3) had avowed it would not be another Waco and would strike first in a "Holy War"; (4) knew that the federal government was actively planning a raid; (5) was populated by people committed to its belief of Christian Identity, including neo-Nazis with training manuals on how to make ammonium nitrate bombs.

Finally, there was one other element present at Elohim City, the significane [sic] of which has not been fully appreciated. It may be a far reach to make a connection between Elohim City and the Oklahoma City bombing to Iraq or Iran, but the reach is not far at all. Present at Elohim City was a German national with a commitment to neo-Nazism and an individual who already had demonstrated a willingness to break the law by overstaying his visa, and by assuming the identity of another and driving through Eastern Oklahoma with books in his car on how to make a bomb.

Also present at Elohim City was Dennis Mahon who once described himself as "the master of all disguises." Mahon is a world traveler with extensive trips to Germany and efforts to enter Canada and the United Kingdom. Mahon was the facilitator. Where does all this leave Tim McVeigh? Is he a part of this? The evidence suggests not and certainly the defense will contend that he is not. Tim McVeigh is the classic example of the right man at the wrong place at the wrong time. Eyewitnesses may place him at places, but the eyewitnesses' accounts are variable and changing. What is missing is the physical evidence and other evidence that ties him to the crime. Ideology is not proof of complicity or involvement in terrorist attacks.

In addition, April 19 was the date of the execution of Richard Snell, soon to be buried in Elohim City. The same Snell who had previously planned and considered a rocket launched attack on the Murrah Building which would destroy it. Thus, the persons responsible for the Murrah Building bombing were alerted, ready, armed, committed, and poised to strike. And strike they did. The government had knowledge from an informant plus knowledge it would obtain from simple, ordinary analysis of the criminal intelligence available to it. It conducted a somewhat superficial security search of the federal property in downtown Oklahoma City and found nothing. When the bomb went off, federal authorities were first stunned and then realized that they did in fact apprehend the danger and had conducted a limited physical inspection, but to admit such prior knowledge and such limited physical search would be to face congressional inquiry and public outrage of such ferocity that confidence in American government would be badly shaken. April 19, 1995, was December 7, 1941, the Pearl Harbor strike, and December 21, 1988. the bombing of Pan Am 103, all over again.

[CONTINUED IN PART NINE]

[9] Among the residents of Elohim City, two have a striking physical resemblance to Timothy James McVeigh and another has a strong physical resemblance to the person the government describes as John Doe No. 2.