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Affidavit in Support of Complaint
Affidavit in Support of Complaint
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.”
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.
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 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
STATE OF MICHIGAN
COUNTY OF _______________
Subscribed and sworn to before me
This ___ day of October, 2020.
___________________________________
____________________, NOTARY PUBLIC
___________ COUNTY, MICHIGAN
MY COMMISSION EXPIRES: ___________