02.06.20 Federal Indictment of Alleged Aug. 3 Shooter Patrick Crusius
02.06.20 Federal Indictment of Alleged Aug. 3 Shooter Patrick Crusius
9URMA
EP 20 CR0 °
IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF TEXAS
EL PASO DIVISION L) ,
INTRODUCTION
1. On or about June 19, 2019, Defendant PATRICK WOOD CRUSIUS used the
Romanian-made firearm that is a variant of the AK-47 assault rifle. Also on or about June 19,
2019, Defendant PATRICK WOOD CRUSIUS used the internet to purchase 1,000 rounds of 7.62
2. Some time before August 3, 2019, Defendant PATRICK WOOD CRUSIUS drafted
a document with the title "The Inconvenient Truth." The document opens by stating, "This attack
Case 3:20-cr-00389-DCG Document 1 Filed 02/06/20 Page 2 of 9
is a response to the Hispanic invasion of Texas. They are the instigators, not me. I am simply
defending my country from cultural and ethnic replacement brought on by the invasion."
vehicle overnight from Allen, Texas, to the Walmart Supercenter store located at 7101 Gateway
West Boulevard in El Paso, Texas. Defendant PATRICK WOOD CRUSIUS traveled with the GP
WASR-10 semi-automatic rifle and 7.62 x 39 millimeter hollow point ammunition that he had
previously purchased.
the document he had drafted entitled "The Inconvenient Truth" onto the internet.
Inconvenient Truth" to the internet, Defendant PATRICK WOOD CRUSIUS opened fire and shot
multiple individuals in and around the Walmart Supercenter store located at 7101 Gateway West
Boulevard in El Paso, Texas. Defendant PATRICK WOOD CRUSIUS used his GP WASR- 10
semi-automatic rifle and 7.62 x 39 millimeter hollow point ammunition to conduct the attack,
which led to the death of twenty-two individuals and injured many more.
Paragraphs numbered 1 through 5 previously alleged in this indictment are re-alleged and
WOOD CRUSIUS willfully caused bodily injury to the victims listed below because of the actual
COUNT VICTIM
1 A.A.
2 J.A.
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3 A.B.
4 J.C.G.
5 L.C.
6 A.E.
7 M.F.
8 R.F.
9 A.C.H.
10 A.H.
11 D.J.
12 L.A.J.
13 M.L.R.
14 M.L.H.
15 I.F.M.
16 G.I.M.
17 E.M.M.
18 M.R.
19 S.R.M.
20 J.A.R.
21 T.S.
22 J.V.
and, in connection with each of the offenses in Counts One through Twenty-Two, the Defendant
employed a firearm that had traveled in interstate and foreign commerce, and the Defendant used
a channel, facility, and instrumentality of interstate and foreign commerce, and the Defendant's
conduct interfered with commercial and other economic activity in which the victims listed above
were engaged at the time of the offense. The offense resulted in the death of the victim.
Paragraphs numbered 1 through 5 previously alleged in this indictment are re-alleged and
WOOD CRUSIUS knowingly used, carried, brandished, and discharged a firearm, namely, a GP
WASR- 10 semi-automatic rifle with serial number A 1-65552-18, during and in relation to a crime
of violence for which he may be prosecuted in a court of the United States, namely, the offenses
charged in Counts One through Twenty-Two; and caused the death of each victim listed below
through the use of a firearm in such a manner as to constitute murder as defined by Title 18, United
States Code, Section 1111, in that the Defendant, with malice aforethought, unlawfully killed each
COUNT VICTIM
23 A.A.
24 J.A.
25 A.B.
26 J.C.G.
27 L.C.
28 A.E.
29 M.F.
30 R.F.
31 A.C.H.
32 A.H.
33 D.J.
34 L.A.J.
35 M.L.R.
36 M.L.H.
37 I.F.M.
38 G.I.M.
39 E.M.M.
40 M.R.
41 S.R.M.
42 J.A.R.
43 T.S.
44 J.V.
All in violation of Title 18, United States Code, Sections 924(c) and 924(j)(1).
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Paragraphs numbered 1 through 5 previously alleged in this indictment are re-alleged and
WOOD CRUSIUS willfully caused bodily injury to the victims listed below because of the actual
COUNT VICTIM
45 P.G.A.
46 M.A.P.
47 E.A.
48 J.A.A.
49 R.B.
50 M.A.P.B.
51 R.C.
52 L.C.
53 M.D.A.M.
54 E.G.D.A.R.
55 A.E.D.L.R.
56 G.G.S.
57 J.G.
58 M.M.G.G.
59 M.E.G.
60 E.C.G.
61 M.J.
62 M.S.L.
63 O.R.L.
64 OJ.M.
65 N.E.M.Z.
66 L.M.P.
67 R.V.
and, in connection with each of the offenses in Counts Forty-Five through Sixty-Seven, the
Defendant employed a firearm that had traveled in interstate and foreign commerce, and the
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Defendant used a channel, facility, and instrumentality of interstate and foreign commerce, and
the Defendant's conduct interfered with commercial and other economic activity in which the
victims listed above were engaged at the time of the offense. The offense included an attempt to
kill.
Paragraphs numbered 1 through 5 previously alleged in this indictment are re-alleged and
WOOD CRUSIUS knowingly used, carried, brandished, and discharged a firearm, namely, a GP
WASR-10 semi-automatic rifle with serial number A1-65552-18, during and in relation to a crime
of violence for which he may be prosecuted in a court of the United States, namely, the offenses
COUNT VICTIM
68 P.G.A.
69 M.A.P.
70 E.A.
71 J.A.A.
72 R.B.
73 M.A.P.B.
74 R.C.
75 L.C.
76 M.D.A.M.
77 E.G.D.A.R.
78 A.E.D.L.R.
79 G.G.S.
80 J.G.
81 M.M.G.G.
82 M.E.G.
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83 E.C.G.
84 M.J.
85 M.S.L.
86 O.R.L.
87 O.R.M.
88 N.E.M.Z.
89 L.M.P.
90 R.V.
CRUSIUS,
iii. intentionally inflicted serious bodily injury that resulted in the death of the
iv. intentionally participated in an act, contemplating that the life of a person would
be taken and intending that lethal force would be used in connection with a
person, other than one of the participants in the offense, and the victim died as
act created grave risk of death to a person, other than one of the participants in
the offense, such that participation in the act constituted a reckless disregard for
human life, and the victim died as a result of the act (18 U.S.C.
§ 3591(a)(2)(D));
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CRUSIUS knowingly created a grave risk of death to one or more persons in addition to the victim
CRUSIUS committed the offense after substantial planning and premeditation to cause the death
CRUSIUS intentionally killed and attempted to kill more than one person in a single criminal
(A.C.H.), Thirty-Two (A.FL), Thirty-Four (L.A.J.), Forty-One (S.R.M.), Forty-Three (T.S.), and
Forty-Four (J.V.), the victim was particularly vulnerable due to old age and infirmity (18 U.S.C.
§ 3592(c)(11)); and
15. As to Count Forty-Two (J.A.R.), the victim was particularly vulnerable due to
16. The grand jury re-alleges and incorporates by reference all allegations contained in
Counts Twenty-Three through Forty-Four, and Counts Sixty-Eight through Ninety of this
indictment for the purpose of alleging criminal forfeiture pursuant to Title 18, United States Code,
Section 924(d); and Title 28, United States Code, Section 2461(c). As part of the commission of
the violations of Title 18, United States Code, Sections 924(c) and 924(j)(1), charged in Counts
Twenty-Three through Forty-Four, and Counts Sixty-Eight through Ninety of this indictment, the
following firearms and ammunition, which were involved and used in the knowing commission of
Case 3:20-cr-00389-DCG Document 1 Filed 02/06/20 Page 9 of 9
those offenses, are subject to forfeiture pursuant to Title 18, United States Code, Sections 924(d);
b) any other property, to include ammunition, which was involved and used in the
A TRUE BILL.
uRIGINAL SIGNATURE
EDACTED PURSUANT TO
FOREPERSON OF THE 6I1?fRY
JOHN F. BAI'
UNITED %ATES ATTORNEY
WESTE1 DISTRICT OF TEXAS
ERIC S. DREIBAND
ASSISTANT ATTORNEY GENERAL
CIVIL RIGHTS DIVISION