25 March 2001. Thanks to Anonymous.

See also: http://www.cluebot.com/articles/00/11/11/101218.shtml

[16 pages.]

FILED
NOV 17 2000

Magistrate Judge Arnold

BEFORE J. Kelley Arnold, United States Magistrate Judge,
Union Station Courthouse, 1717 Pacific Avenue, Tacoma, Washington.

COUNT ONE

(Interstate Stalking)

On or about October 23, 2000, at Vancouver, within the Western District of Washington, JAMES DALTON BELL did travel across a State line from the State of Washington to the State of Oregon, with the intent to injure or harass another person, to wit, Mike McNall, and as a result of such travel placed Mike McNall in reasonable fear of death or serious bodily injury to himself and to his immediate family.

All in violation of Title 18, United States Code, Section 2261A.

COUNT TWO

(Interstate Stalking)

On or about October 23, 2000, at Vancouver, within the Western District of Washington, JAMES DALTON BELL did travel across a State line from the State of Washington to the State 28 of Oregon, with the intent to injure or harass another person, to wit, Jeff Gordon, and as a result of such travel placed Jeff Gordon in reasonable fear of death or serious bodily injury to himself and to his immediate family.

All in violation of Title 18, United States Code, Section 2261A.

And the complainant states that this complaint is based on the following:

I, Philip Scott, being duly sworn, hereby depose and say:

1. I am a Special Agent with the United States Treasury Department, Inspector General for Tax Administration (TIGTA). I have been employed with this agency and its predecessor agency, the Internal Revenue Service's (IRS) Internal Security Division, for fourteen years. During such employment I have conducted numerous criminal investigations involving external attempts to corrupt or threaten employees of the IRS and related entities. I am familiar with an investigation of JAMES DALTON BELL for violations of Title 18, United States Code, 12 Section 2261A, involving Interstate Stalking. The facts alleged in this complaint are based on my personal knowledge as well as what I have learned from others during the course of this investigation.

2. In 1996,TIGTA Special Agent Jeff Gordon was assigned to an investigation involving JAMES DALTON BELL and the danger he posed to the safety of IRS and other Government employees. As part of Special Agent Gordon's investigation, he obtained information from IRS records, court documents, searches of BELL's vehicle and residence, other law enforcement agents, interviews, and other sources. Special Agent Gordon led the team of agents who searched BELL's house, as well as the team who arrested BELL in 1997. Special Agent Gordon also testified against BELL at several court hearings.

3. In 1989, BELL was convicted of possessing unregistered chemicals in his residence at 7214 Corregidor Road, Vancouver, Washington. Court records show that after his conviction, BELL failed to comply with the terms of his probation. In 1995, BELL was convicted of criminal mischief after he built and used a device which interfered with the normal operation of traffic signals.

4. In October, 1996, a federal investigation was initiated into BELL's activities after it was learned that BELL had gathered the names and home addresses of more than fifty IRS employees, and that BELL was openly advocating the assassination of Government employees.

5. During the course of the investigation, evidence was obtained regarding BELL's activities on the Internet and his interaction with a group calling itself "The Multnomah County Common Law Court". Evidence obtained during the course of the investigation included tape recordings and video tapes of some of the Common Law Court's meetings, as well as electronic mail messages sent by BELL.

6. On May 23, 1996, BELL proposed in an Internet message something he called "Operation LocatIRS", which was intended to locate the names and home addresses of IRS agents. In this message, BELL stated that the gathering of IRS agents' home addresses "would also act somewhat as a deterrent to those same statist agents: These people don't know exactly what we intend to do with this information, or what we (or others) may decide to do in the future. They can well imagine a breakdown in order sufficient to allow people armed with such a database to . . . well, you get the idea. (Their imaginations will be their worst enemy.) We needn't concern ourselves with these future issues. It is very likely that these people will be far more pliable and less abusive in the future if they are well-known."

7. On October 23, 1996, BELL stated at a meeting of the common law court "I started a project which is just informal until now to basically locate the names and home addresses of all the IRS agents in the area". On October 24, 1996, BELL posted to an Internet mailing list the names and home addresses of two IRS agents.

8. At a January 9, 1997 meeting of the common law court, BELL discussed correspondence being sent to IRS agents who were the subject of a "trial" by the common law court. BELL offered to help identify the IRS agents' home addresses and stated "it might be a little more psychologically effective if they were to receive their notices in their mailboxes at home."

9. BELL also attended a January 30, 1997 meeting of the common law court. At this meeting, a "trial" of IRS agents was held. BELL handed out a copy of his "Assassination Politics" document to "Jurors" and others on computer disks, which were labeled "AP: A solution to the Common Law Court Enforcement Problem". BELL stated "I wanted to hand out some more copies of a uh, essay I wrote which might turn into a, what I call a solution to the common law court enforcement problem".

10. On February 20, 1997, the IRS seized BELL's automobile from the driveway at 7214 Corregidor Road, Vancouver, Washington, to satisfy a portion of BELL's unpaid Federal taxes. A variety of incriminating items were located during a search of the vehicle, including documents involving chemicals and explosives, financial documents containing false social security numbers, ammunition, and the names, home address, and descriptions of an IRS employee and his spouse.

11. On March 16, 1997, the IRS office in Vancouver, Washington was contaminated with a noxious chemical, forcing employees to leave the premises with headaches and nausea.

12. On April 1, 1997, BELL was interviewed by Special Agent Gordon. During the interview, BELL admitted authoring the essay titled "Assassination Politics".

13. Also on April 1, 1997, a search warrant was executed on BELL's residence at 7214 Corregidor Road., Vancouver, Washington. During the course of the search, agents discovered a variety of dangerous and deadly chemicals, including cyanide, acids, and Diisopropyl Fluorophosphate, a toxic nerve agent which could be used as a precursor chemical to make a gas similar to Sarin, a deadly nerve agent.

14. During the search, BELL's computers were also seized and subsequently analyzed. The computers contained a large volume of electronic mail messages and other documents written by BELL. The search revealed that:

a. BELL had obtained and distributed the names and home addresses of more than seventy IRS employees, and in some cases members of their families;

b. BELL had similarly located the names and home addresses of agents of the Federal Bureau of Investigation (FBI), Bureau of Alcohol Tobacco and Firearms (ATF), and officers of local police agencies;

c. BELL had a computer diskette containing the names of federal judges, Assistant United States Attorneys, and IRS criminal investigators;

d. BELL bragged of using a noxious chemical to contaminate the office of a lawyer who had sued him;

e. In two messages,. BELL specifically stated that he had manufactured the nerve agent Sarin. BELL stated that he made the nerve agent in the basement of his residence;

f. In messages between BELL and an individual named Robert East, BELL discussed introducing nickel coated carbon fiber into Government facilities to destroy electronic equipment by creating short circuits; BELL stated that he was "truly serious" about obtaining a "huge quantity" of the fiber and wrote "Think of this: 1/4 ounce each in a few thousand tax returns filed on April 15, to the IRS." BELL also suggested "Ten pounds for each IRS service center?!?" BELL also stated in a message "Probably the most effective way to destroy everything in a building would be to dump a pile of fibers into the cold air return of a building;"

g. In a March 1, 1996 message, BELL wrote "For 'political' reasons I intend to 'harden' my house against assaults by unwanted visitors . . ." BELL discussed using high voltage wires and acid sprayers at the entrances to his residence, and creating a "choking, white cloud of ammonium chloride'" to deter law enforcement. BELL also discussed burying nitromethane bombs in his yard;

h. BELL and East also discussed an experiment involving the combination of the mind altering chemical BZ (Quinuclidinyl Benzilate) and DMSO, a chemical which is easily absorbed through the skin;

i. BELL was a member of a militia organization, and also a participant in a common law court.

16. On May 16, 1997, BELL was arrested on a federal complaint alleging felony violations of Title 26, United States Code, Section 7212(a), Corrupt Interference with Internal Revenue Laws, and Title 42, United States Code, Section 408, Using a False Social Security Number.

17. On July 18, 1997, BELL pled guilty to the violations alleged in the complaint. As elements of his guilty plea to Title 26, United States Code, Section 7212(a), BELL admitted that he contaminated an IRS office with a noxious chemical, collected the names and home addresses of IRS agents in order to intimidate them in the performance of their official duties, attempted to impede and obstruct the enforcement of internal revenue laws by suggesting an assassination scheme to a common law court, and used false Social Security numbers in order to hide his assets from the IRS and to impede the IRS' ability to collect taxes that had been assessed against him.

18. BELL was released from prison in April, 1998. As part of his supervised release terms, the Court ordered that BELL not possess, obtain, or disseminate the home address or phone number of any Government employee (absent express permission); not possess or use address or locator computer database files, such as DW, voter registration lists, national phone directories, real estate records, etc; and not knowingly be near the residence of any Government employee (absent express permission).

19. In June, 1998, the United States Probation Office petitioned the Court to issue an arrest warrant for BELL for violations of his conditions of supervised release. BELL's assigned probation officer was Matthew Richards.

20. In a search of BELL's residence conducted at the time of BELL's 1998 arrest for the violations of his supervised release, agents discovered in BELL's residence narcotics paraphernalia, ammunition, and a computer, all of which were prohibited for BELL to possess. Among the law enforcement officers participating in the arrest and/or search were Deputy United States Marshals Grizzle, Vollmer, and Stephenson.

21. On April 14, 2000, an article about BELL's pending release from prison was published by Wired News. The article referenced BELL's Assassination Politics scheme, and stated that after BELL is released from prison "he plans to extract revenge on the system that imprisoned him". The article quoted BELL as saying in a phone interview "if they continue to work for the Government, they deserve it. My suggestion to these people is to quit now and hope for mercy."

22. On June 21, 2000, electronic copies of two letters from BELL to the United States Circuit Court of Appeals were publicly posted on the Internet. In the letters, BELL alleged that the Federal Public Defender's office in Seattle had "colluded with various Federal government agencies" in his case. BELL complained about the head of the Public Defender's office, Thomas Hillier, as well as defense attorneys Peter Avenia, Judith Mandel, and Catherine Floit. In one of the letters, BELL stated, "I am alleging fraud and collusion (with various other government agents including prosecutor and investigators) by Peter Avenia and his replacement, Judith Mandel ".

23. On September 15, 2000, BELL publicly posted a message on the Internet. In this message, BELL wrote that on November 25, 1997, he was assaulted by a fellow prison inmate, Ryan Lund. BELL stated that he believed Lund assaulted him as part of a deal Lund made with the Government. BELL wrote that Bureau of Alcohol., Tobacco, and Firearms (ATF) Agent Mike McNall was present at a search warrant served in connection with the Lund investigation, and therefore, BELL concluded, "I suspect it was agent McNall who did the deal with Lund."

24. On October 10, 2000, BELL publicly posted a message to the "Usenet" portion of the Internet asking people to read his essay "Assassination Politics", and he provided an Internet "link" to a copy of the essay. The essay describes a plan to destroy the Government through the assassination of Government officials.

25. On October 19, 2000, BELL responded to an anonymously posted Internet message with the subject titled "judges needing killing. . ." The original message discussed a California Supreme Court case involving cars seized by law enforcement agencies. In BELL's response, titled "re: judges needing killing . . .," BELL suggested introducing "a few ounces or gallons of PCB's (poly-chlorinated biphenyls)," and spraying them into the vehicles, requiring an expensive environmental cleanup by the Government. BELL ended his response with his name and the statement "Better Living Through Chemistry."

26. Another person responded to BELL's PCB suggestion by stating in an e-mail message that PCBs are no fun whatsoever. On October 19, 2001, BELL posted a message to the Internet also titled "re: judges needing killing . . ." and replied "Sorta depends on your definition of fun, doesn't it?" BELL also stated "Acquiring PCB's requires little more than the will to do it. Believe me, I _know_."

27. On October 23, 2000, an individual named Chris Groener reported that at approximately 5:30 p.m., he came home from work to his residence in Oregon City, Oregon and discovered an unauthorized person trespassing on his property, coming from behind his home. Groener said that the person stated "I'm looking for Mike McNall," and also asked how long it was since McNall had resided there. Groener said he asked the person what this was all about, and the person replied "I'm an acquaintance". The person also asked about the Andrews, stating he had seen the name Andrews on the mailbox. When Groener asked for the person's name, he identified himself as "JIM BELL." BELL also gave him a phone number of (360) 696-4308. Groener asked BELL to leave, and BELL looked at Groener's car license plate, went to his own vehicle and started writing information down on some paper before finally leaving. Groener observed BELL's vehicle to be a yellowish 1980s Nissan four door sedan. Groener did not write down the vehicle's license plate, but he recalled it to be Washington 939LBH. Within a few hours of the incident Groener was shown two pictures of JAMES DALTON BELL by an Agent of the ATF, and he was positive that the person who was at his residence was the same person. Groener said that there are two residences on the property, and he lives in one and the Andrews family in the other. ATF Special Agent Mike McNall was the previous occupant of Groener's residence.

29. On October 24, 2000, BELL posted a message to the Internet with the subject titled "Say Goodnight to Joshua, Mr. Anonymous". The message was sent at 2:53 a.m., meaning it was sent the same evening that BELL bad been discovered by Groener at ATF Agent McNall"s former residence. In the message, BELL stated "Before I was satisfied to look into people who had, unfortunately, allowed their property to be used against me," and that he had been on "Just a 'show the flag' circuit. Intended to be seen." BELL closed the message by stating "So say goodnight to Joshua, Mr. Anonymous. Tell him it's not his fault that his father is 27 a thug."

29. I have reviewed the "header" information on the "Say Goodnight to Joshua" electronic message referenced above. The "header" information is an electronic routing trail which is normally hidden from view, but which shows the electronic path by which the message was sent. The "header" for this message showed that the message was originally sent by c1099371-A, ([24.16.209.166]). The message itself indicates that the author was "Jim Bell", using the electronic mail address jimdbell@home.com.

30. Hilda Muramoto, a Senior Legal Assistant with BELL's Internet Service Provider, Excite@horne, was interviewed. Muramoto said that she had researched the company's records regarding the Internet service account for the Internet address jimdbell@home.com. Muramoto said the account was registered to JIM BELL, 7214 Corregidor Rd., Vancouver, Washington, with a home phone number of (360) 696-4308. Muramoto also said that the Internet service provided by Excite@home is hard-wired directly into the customer's computer at his address. The customer's computer is assigned a specific Customer Premis Equipment (CPE) number and IP number, which are then automatically included on any electronic mail message sent through the Internet service from the customer's computer. Muramoto said that BELL's CPE number is C1099371-A and his IP number is 24.16.209.166.

31. On several occasions, including January 19, 1999, January 26, 2000, June 15, 18 2000, July 31, 2000, and September 27, 2000, the Government corresponded with BELL through BELL's attorneys, notifying BELL that property the Government seized during the 1997 search warrant at BELL's residence was available to be returned. In the last letter, the Government set a deadline of November 1, 2000 for BELL's designee to receive four items of property.

32. On October 31, 2000, a copy of the July 31, 2000 fax correspondence from Special Agent Gordon, originally sent to BELL's attorney Jonathan Solovy, was faxed back to Special Agent Gordon's office in Portland, Oregon. On Special Agent Gordon's original fax the following was written "How about if I drop by your house tomorrow night with my designee to pick up the 4 items? Or maybe you'd prefer at the address above? Jim B."

33. Also on October 31, 2000, BELL's attorney, Jonathan Solovy, returned Special Agent Gordon's previous call regarding the deadline for BELL's items to be picked up. Solovy said that it was his policy to forward the Government's correspondence to his client.

34. On November 6, 2000, I participated in a search warrant executed at BELL's residence at 7214 Corregidor Road, Vancouver, Washington. Among the documents seized was a spiral bound notebook containing handwritten notes. The notebook appears to be a journal detailing BELL's stalking activities directed at those he believes are agents of the Government. The following were among the entries and information found in the notebook:

a. Multiple pages of research and information involving persons named Saban and companies named Sundown;

b. An entry dated 4/26/00 titled "Clark County Voter's Registration Office", containing Washington State home address information on six people with the name Saban, and three persons named Gordon, including a Jeff Gordon and a Jeffrey Gordon;

c. An entry for "Go/Infoseek:" with the name and home address of a Jeff Gordon in Washington;

d. An entry with the name and home address for a Matthew Richards;

e. An entry for "Clark Co Assessor's office" with information on residences of several Sabans and the residence of a Jeff Gordon;

f. Numerous license plate numbers, many with corresponding dates and times, with names and addresses of the registered owners;

g. Numerous entries involving "visits" to various properties in both Washington and Oregon, with notes regarding the properties and vehicles;

h. An entry dated 6/16/00 titled "Pierce County Assessor's Office", with the notation "Thomas Hillier, Nothing" and the name and home address of a Peter Avenia;

i. An entry for 10/9/2000 titled "Clark Co Elections" containing home address information on three persons with names similar to Grizzel, six persons named Vollmer, and one person named Lisa Stevenson;

j. An entry "'Jeff Gordons' Voter Reg", containing a Washington home address for a Jeff Gordon, two license plate numbers, and a partial Vehicle Identification Number for one of the vehicles;

k. An entry relating to the address of another Jeff Gordon in Washington, with a license plate number and a second license plate number from a neighboring house;

l. An entry dated 10/10/2000 titled "According to Qwestdex.com", listing the home addresses for a Jeff Gordon in Vancouver, Washington, a Jeff Gordon in Battleground, Washington, a Jeff Gordon in Hillsboro, Oregon, a Jeff Gordon in Tualatin, Oregon, and a Jeff Gordon in Aloha, Oregon;

m. An entry titled "Questdex.com" listing the phone number for a Lisa Stevenson in Camas, Washington and a Lisa Stevenson in Banks, Oregon;

n. An entry titled "Mult Co Elections" listing home addresses for eight persons named Saban, and indicating that there is no Grizzle, Charles Vollmer, or Lisa Stevenson in Multnomah County (Oregon). There was also a home address for a Jeffrey Gordon in Portland with the note "No other Jeff Gordons in Mult Co." There are also notes about other persons named Stevenson;

o. An entry on a page dated 10/23/00, which contained the address of a Jeffrey Gordon in Eagle Creek, Oregon. Two license plate numbers are written by the entry, along with the words "next door" and additional names and numbers. This is the former residence of a Jeffrey and Barbara Gordon, who currently live in Tuatatin;

p. Immediately following the 10/23/00 Eagle Creek entry is an entry containing the address of Chris Groener in Oregon City, Oregon. This entry also contained the words "Says 'Andrews' on the mailbox" and "Chris", as well as two license plate numbers, one of which is the license plate of Groener's vehicle;

q. Immediately below the Groener entry is the address of a Jeff & Barbara Gordon in Tualatin, Oregon, A notation of the time is listed as 6:26 PM. The following two pages in the notebook contain very detailed information about Jeff and Barbara Gordon, including specific information about their insurance policies. The notations include information about a 10/4100 Blue Cross Blue Shield of Alabama claims report for Jeff and Barbara Gordon, involving patient Joshua Gordon. This is the last entry in the notebook.

35. Other items found in the search of BELL's residence include:

a. A copy of the July 31, 2000 fax correspondence from Special Agent Gordon, originally sent to BELL's attorney Jonathan Solovy. Written in blue ink on the document were the words "How about if I drop by your house tomorrow night with my designee to pick up the 4 items? Or maybe you'd prefer at the address above? Jim B";

b. An August 1, 2000 letter from Jonathan Solovy to JAMES D. BELL beginning "Enclosed please find the materials faxed to my office on July 31, 2000 by Agent Jeff to Gordon of the United States Treasury, Inspector General for Tax Administration";

c. A handwritten letter from BELL to a friend, in which BELL claims that two of his neighbors "are actually Fed spy operations directed against me, and have been secretly operated in excess of two years." The letter appears to have been written shortly after BELL's 1998 arrest. and identifies one of the neighbors as Sundown Development. Sundown Development is a company owned by BELL's next door neighbor, Dan Saban;

d. A computer printout with names and addresses involving Lisa Stevenson, with the handwritten names Ernie Grizzel and Charlie Volmer;

e. Four pages of computer printouts containing Oregon vehicle registration and address information on vehicles registered to persons named Jeff Gordon or Jeffrey Gordon. Included in these documents is information about a Jeffrey Gordon in Eagle Creek, Oregon;

f. Two pages of computer printouts containing Oregon driver's license and address information on persons with the name Jeff Gordon or Jeffrey Gordon, including the addresses in Tualatin and Eagle Creek, Oregon;

g. A computer printout containing vehicle registration and address information on Barbara Gordon of Tualatin, Oregon;

h. Numerous court and other documents relating to Ryan Lund;

i. A computer disk with the handwritten label "ATF - Thug Hunt" and a preprinted address label with the name JAMES D. BELL;

j. A computer printout of address and phone listings for persons with the last name Hillier and first name beginning with the letter T in the state of Washington;

k. A blank sales form titled "DMV 2000, Oregon's Dept. of Motor Vehicles on CD-Rom, including Oregon's Drivers License, License Plate and ID Card Databases." The document states in part "due to new Oregon and Federal laws, you must fill out this form, sign and date it, then return it . . ." and has the declaration in the signature section "We Warrant the above DMV Databases will be used for "Marketing" purposes only in accordance with all Oregon and federal laws";

l. Two computer printouts which were located in the output tray of BELL's computer printer. One of the printouts contained Oregon driver's license and address information for two persons with the name Lisa Stevenson, and the other contained registration information on a vehicle owned by a Jeffrey Gordon;

m. A file folder labeled "spy research" containing a large amount of data on numerous individuals, including persons with the last name Saban and companies named Sundown;

n. A large blue binder containing documents relating to persons named Saban and companies named Sundown;

o. Two CD Rom computer disks labeled "9-4-97 OR Lic: Plate," one CD Rom labeled "DMV 2000," one CD Rom labeled "State of Oregon's DMV Databases, Copyright 1994," one CD Rom labeled "Oregon Drivers 1997," one CD Rom labeled "State of Oregon's DMV Databases including License Plate & Drivers License Databases Copyright 1996," and two CD Roms labeled "Phonedisc USA Residential";

p. Clark County Washington property assessors records containing information regarding the residence of a Jeff Gordon in Vancouver, Washington.

36. Also on November 6, 2000, BELL's vehicle, a 1995 Nissan, license plate number 939LBF, was located at his residence in Vancouver, Washington and searched. A number of financial documents related to BELL were in the vehicle.

37. Barbara Gordon of Tualatin, Oregon, was contacted and notified that her address and insurance information had been found in a notebook at BELL's residence. Barbara Gordon stated that her husband is named Jeff Gordon, and that they have a son named Joshua. Barbara Gordon said that she was unaware of any contact between her family and JAMES BELL. Barbara Gordon confirmed that the specific information about her family in BELL's notebook was accurate. including that she had recently filed an insurance claim for her son Joshua with Blue Cross and Blue Shield of Alabama. She said she normally gets an explanation of benefits through the mail from the insurance company, but she had not received one for the most recent claim. Barbara Gordon reported that BELL could not have obtained the information from her trash, because she burns all of her mail inside the residence and does not throw it out. Barbara Gordon said that BELL may have obtained the information by stealing mail from her mailbox, since she and her husband both work and often leave the mail in the box. Jeff and Barbara Gordon of Tualatin are not related to Special Agent Gordon.

38. On November 9, 2000, an article containing an interview with BELL appeared in the Vancouver, Washington Columbian Newspaper. The article reported that BELL told the Columbian that he has been noting the license numbers of several cars he believes followed him, and then used Oregon motor vehicle records to discover who the cars were registered to. Bell also told the Columbian that he has gone to the homes of such people and taken pictures outside.

39. At approximately 1:00 a.m. on November 10, 2000, Clackamas County, Oregon Sheriffs deputies spotted Bell's vehicle approximately 1.25 miles from the residences of Chris Groener and the Andrews, on the same street where they live. BELL was heading away from the residences., and the deputies stopped the vehicle and identified and temporarily detained BELL.

40. The Sheriffs deputies discovered that notes had been placed on the windshields of vehicles parked at the Groener/Andrews property. The notes stated "please call Vancouver Columbian newspaper reporter John Branton at 1-360-759-8012 very important".

41. On November 11, 2000, an article about the search warrant at BELL's residence was published by Wired News. The article stated that in an interview, BELL acknowledged that he had shown up at the homes of suspected ATF agents and had done DMV searches on their names, in an effort to let them know that surveillance can be done in both directions. The article also quoted BELL as saying "I am thinking very strongly of picketing Jeff Gordon's house. I don't intend to violate any laws when I do that. It's conceivable that they won't appreciate my picketing their house." The article also quotes BELL as stating 1 wasn't all that happy before, but I'm hopping mad . . . If you think this is going to stop me, baloney. Needless to say I'm feeling very hostile. But I don't intend to violate black-letter Oregon law."

42. Based on the above information, I believe that JAMES DALTON BELL has attempted to harass at least two federal agents through threats, intimidation, and stalking activities which have crossed over State lines. BELL has harassed ATF Agent Mike McNall, by traveling from his residence in Vancouver, Washington to Oregon and trespassing on McNall's former property. BELL openly identified himself and gave his phone number, with the intent that the information would intimidate McNall, and within hours BELL publicly posted an Internet message stating he intended to be seen and was on a "show the flag circuit". On a second occasion, even after being served with a search warrant, BELL went back to the Oregon property and left notes on vehicles at the residence. BELL's own writings show that he knows of the effect his action will have on employees of the Government.

43. Based on the above information, I further believe that JAMES DALTON BELL has harassed Treasury Special Agent Jeff Gordon. BELL has expended considerable effort in stalking Special Agent Gordon through records, surveillance activities, and theft of mail. BELL has traveled from his residence in Vancouver, Washington to Oregon to carry out these activities. On the Internet BELL posted a message threatening to Special Agent Gordon by invoking the name of Joshua, whom BELL believed to be Special Agent Gordon's son. He posted the "'Say Goodnight to Joshua," e-mail just a few hours after he was found by Groener at Agent McNall's former residence on October 23, 2000, which indicates that he had already obtained Joshua Gordon's name by that date. Furthermore, McNall's former address (now Groener's) and the Tualatin address for Jeff and Barbara Gordon (Joshua's parents) were found together in successive entries in BELL's notebook, dated October 23, 2000. The first entry, dated October 23, included the information, "says 'Andrews' on the mailbox," and included Groener's license plate number. The next entry, which included the Gordons' Tualatin's address, was dated 6:26 p.m., and included detailed information about their October 4th Blue Cross Blue Shield of Alabama claims report for their son Joshua -- the claims report that the Gordons had never received in the mail. Accordingly.. I believe that on October 23, 2000, BELL 5 traveled from his home in Vancouver, Washington across the Columbia River into Oregon, went to McNall's former address (now Groener's), where he confronted, and was in turn confronted by, Groener at approximately 5:30 p.m. After writing down Groener's license plate number and recording the Andrews mailbox information in his notebook., he left. The next entry in the notebook at 6:26 p.m., containing all of the information about the Gordons in Tualatin, suggests that he then went to the Gordons' address in Tualatin where he was able to obtain the name of their son Joshua and the information about the Blue Cross Blue Shield of Alabama insurance claim. He then returned home and, early in the morning on October 24, posted the"'Say Goodnight to Joshua" e-mail to the Internet. BELL also sent a fax directly to Special Agent Gordon with the intent to cause him to fear for the safety of himself and his family, by implying BELL knew were Special Agent Gordon lived and might go there.

Based on the foregoing, I believe there is probable cause to find that on or about October 23, 2000, JAMES DALTON BELL committed at least two separate and distinct acts of interstate stalking, in violation of Title 18, United States Code, Section 2261A.

[Signature]

PHILIP SCOTT, Complainant
Special Agent,
Treasury Inspector General for Tax Administration

Complaint and affidavit sworn to before me this 17th day of November, 2000.

[Signature]

J. KELLEY ARNOLD
United States Magistrate Judge

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