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AFFIDAVIT IN SUPPORT OF SEARCH WARRANTI, Charles B. W ickersham, being duly sworn, depose and say:

I have been a Postal Inspector of the United States Postal.Inspection Service (USPIS) forapproximately twenty months. I am authorized to investigate crimes involving violations ofTitle 18 U.S.C. Sections 2332(a), 1114, and 15 12(a)(2).This affidavit is respectfully submitted in support of an application for warrants to searchthe following prem ises and vehicles, pursuant to the domestic terrorism search warrant provisionfound at R ule 41(b)(3) of the Federal Rules of Criminal Procedure, in that it involves threats towitnesses in, and obstruction of, a d omestic terrorism investigation, pending in the District ofColumbia.

,Frederick, Maryland, a single family residence. The residencehas white paln - wood siding, with a white front door that is located on the rightsid e of th; fron t of the home.- he front door has an exterior storm door. Left of thefront doo r are two window s cased with red shutters. A black railing leads up severalstairs to the front door where the nu mb ers re indicated in black above thedoor. Th e search will include a large peeling paint, that is located onthe rear of the property, along with the backyard. Bruce Edw ards Ivins purchased thehouse 0310611 990. Inves tigation has disc losed the prope rty has been his principleresidence sin ce Septem ber, 200 1.(2) Autom obile #1: a vehicle with Maryland registration expiration0211 112009, and Veh icle Identification N umber . The vehicleis described as a 2002 Saturn SL l, blue, 4 door sedan, and is registered to BruceEdwards 1vn Frederick, MD. Bruce Edwards Ivins purchased

the vehicle 9/13/20 02 and has been the sole owner, and is the primary user.(3) A utom obile # 2: search a vehicle w ith Maryland r e g i s t r a t i o , xpiration06/25/2008, and Vehicle Identificationr umber-. he vehicleis described as a 1993 Honda Civic; blue, 4 door sedan, and is registered to BruceEdwards Ivins,dha rederick, MD . Bruce Edwards Ivins purchasedthe vehicle 1210211 999 an as een the sole owner. The vehicle is primarily usedby Ivins's w and is driven on occasion by Bruce EdwardsIvins.(4) Au tomo bile #3: A warrant to search a vehicle with Maryland registration

exp iratio n 0710 112009, and Veh icle IdentificationTh e vehicle is described as a 1996 Dodg e van, red, and is registered to_, Frederick, MD. purchased the vehicle

1Oil 711 9 6 , and the vehicle is d riv en on odwad Ivins.

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As discussed below, there is probable cause to believe that a search of theaforementioned premises may result in the collection of evidence relevant to an ongoing criminalinvestigation into the dissemination of a W eapon of Mass Destruction (anthrax) through the U.S.mail system in September 2001 and October 2001 in violation of Title 18, United S tates Code,Sections 2332(a) and 11 14, which killed five people and infected at least 17 others, and into 'tampering with a witness or informant in connection with that ongoing dom estic terrorisminvestigation, in violation of Title 18, United States Co de S ection 15 12(a)(2).Overview

The Federal Bureau of Investigation and the U.S. Postal Inspection Service (hereinafter"Task Fo rce") investigation of the anthrax attacks has led to the identification of Dr. BruceEdward Ivins, an anthrax researcher at the U.S. Army Medical Research Institute for InfectiousDiseases, Fort Detrick, MD (hereinafter "US AM RI ID ), as a person necessitating furtherinvestigation for several reasons:. (1) At the time of the attacks, he was the cu stodian of a largeflask of highly purified anthrax spores that possess certain genetic mutations identical to theanthrax used in the attacks; (2) Ivins has been unable to give investigators an ad equateexplanation for his late night laboratory work hours arou nd the time of both anthrax mailings; (3)Ivins has claimed that he was suffering serious mental health issues in the months preceding theattacks, and told a cow orker that he had "incredible paranoid, delusional thoughts at times" andfeared that he might not b e ab le to control his behavior; (4) Ivins is believed to have subm ittedfalse samples of anthrax from his lab to the FBI for forensic analysis in order to misleadinvestigators; (5) at the time of th e attacks, Ivins was under pressure at work to assist a privatecompany that had lost its FDA approval to produce an anthrax vaccine the Army needed for U.S.troops, and which Ivins believed was essential for the anthrax program at USAM RIID; and (6)Ivins sent an email to a friend" a few days before the anthrax attackswarning her that "Bin Laden t m nthrax and sarin gas" and have "justdecreed death to all Jews and all Am ericans," language similar to the anthrax letters warning"W E HAVE THIS ANTHRAX .. DEATH TO AMERICA . . DEATH TO ISRAEL." In hisaffidavit dated October 3 1, 20 07 , submitted in support of an initial search of the residence andvehicles of B ruce Edwards Ivins, Supervisory Postal Inspector Tho mas F. Delafera described ingreater detail information regarding B ruce Edwards Ivins, and his probable connection to theanthrax m ailings. I hereby incorporate this affidavit by reference herein. See Exhibit A.

Factual BackgroundOver the course o f the past few years, Dr. Ivins has become awa re that the Task Forceconsid ers him a person wh o warrants further investigation in connection w ith the anthraxattacks. He has been interviewed a number of times by law enforcement throughout the course

of the nearly seven-year investigation, most recently in the presence of his attorney on June 9,2008. In addition, on Novem ber I, 2007, Task Force agents executed search warrants at hisresidence, his office at USAM RIID, and his vehicles, for evidence linking him to the anthraxattacks, and seized a num ber of items, including numerous letters to mem bers of Congress andthe media, along with handguns. Finally, in recent month s in particular, he has told co-workersand friends that he is a suspect in the investigation, even revealing to o ne friend a few weeks agothat his attorney has told him to prepare to be indicted for the anthrax attacks.

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His m ost recent statement regarding the attacks came two days ag o on Wednesday, July9, 20 08 . While at a group therapy session in Frederick, Maryland, he revealed to the LicensedClinical Social W orker and other members of the group that he was a suspect in thisinvestiga tion. He stated that he was a suspect in the anthrax investigation and that he was angryat the investigators, the governm ent, and the system in general. He said he was not going to facethe death penalty, but instead had a plan to kill co-workers and other individuals who hadwronged him. He said he had a bullet-proof vest, and a list of co-workers, and added that he wasgoing to obtain a Glock firearm from his son within the next day, because federal agents arewatching him and he could not obtain a weapon on his own. Based on these statements, theSocial W orker called the F rederick, Maryland, police department, and they took custody ofBruce Ed wards Ivins on Thursday, July 1 0,2 00 8, for a forensic evaluation at FrederickMem orial Hospital, where he remains as of this writing.Further, with respect to backyard at the residence, at approximately 10:30 p.m., in earlyJune 2 008, B ruce Edwards Ivins was observed w alking in the rain out into an area of hisbackyard near his back fence. He was then observed mak ing a raking or digging motion in thatarea. Subsequent visual scrutiny of that area revealed that itwas an untended area of grass and

other vegetation.Finally, with respect to the three veh icles, over the course of the past sev eral months,visual surveillance has been conducted regularly at the residence o f Bruce Edw ards Ivins aFrederick, Maryland. Such surveillance has revealed that all three vehicles are

regularly parked in front of the Ivins residence or in the driveway on the property.The Task Force submits that a search Subject Residence and Subject Vehicles may revealphysical or docum entary evidence that will assist the investigation into these threats to w itnessesrelated to the anthrax investigation, and obstruction o f that investigation. The search is forfirearms and other weapons, ballistics vests or other protective gear, and any w ritings identifying

a plan to kill witnesses or nam es of intended victims, or any other relevant documents, notes,photographs, and records in various formats, including compu ter files and other electronicmedia, as m ore fully described in the Attachmen t to this affidavit.Conclusion

Based on the foregoing, I submit that there is probable cause to believe that a search ofthe Subject Residence and Subject Vehicles may result in collection o f evidence relevant to theinvestigation of threats to witnesses in, and obstruction of, the investigation into thedissemination of a weapon of mass destruction (anthrax) through the U.S. mail system inSeptember and O ctober 2001 in violation of 18 U.S.C., Sections 1 512(a)(2), 2332a and 1114 .Specifically, there is probable cause to believe that a search of the S ubject Residence andSubject Vehicles a s described in the Attachment to this affidavit, may reveal firearms and otherweapons, ballistics vests, and w ritings identifying a plan to kill witnesses, names of intendedvictims, photographs, and other relevant documents.

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Because this affidavit is part of an ongoing investigation that would be jeopardized bypremature disclosure of information, I further request that this Affidavit, the accompanyingOrder, and o ther related docum ents be filed under seal until further order o f the Court.The statements contained in this Affidavit are based in part on inform ation provided byFBI Special Agents and U .S. Postal Inspectors, on observations m ade by law enforcementagents, and on my experience and background as a Postal Inspector. I have not included eachand every fact known to m e concerning this investigation. I have se t forth only the facts that Ibelieve are necessary to establish the necessary foundation for the search warrant.

vostal InspectorU.S. Postal Inspection Service

day of

f i 7 m e. AGISTRATE JUDGE/ United States District Court

for the District of Colum bia

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ATTACHMENT TO AFFIDAVITThe search of the Subject Property and Premises will include a physical search for theitems m entioned in the text of the search warrant, including more specifically the following:1 . Documents, memoranda, notes or other writings and equipment which include but arenot limited to schematics, diagrams, blueprints, surveillance equipment or its manuals and otherrelated paperwork, receipt for purchase of items, how-to magazines, books and pamphlets whichdescribe a plot to harm or kill other individuals, communication w hich wo uld include but not belimited to handwritten notes and drawings, memos and photographs, which would includedescriptive information such as telephone numbers, addresses, directions, and affiliations andcontact points of individuals Bruce Edwards Ivins believes may be involved in the investigationinto the anthrax attacks of 2001. Note that such documentary material described herein may bein printed o r electroriic form such as , but not limited to, comp uter disks. Such computerized andother elec tronic material would constitute contraband, fruits, instrumentalities or evidence of theoffenses enumerated herein and in the attached affidavit for search warrant.2. Firearms and ammunition, extra magazines, sights, ballistics vests, targets, andany other weapon of any kind, and any and all paperwork referencing purchase, maintenance,transfer and ownership of any w eapon.3. Keys, records, or other information pertaining to storage facilities, safety depositboxes or othe r locations where such items set forth in paragraph 1 and 2 may be stored.4. Computer hardware, computer software. computer-related documentation, computerpasswords and data security devices, records, documents, photos, and materials use tocommunicate, both written, electronic mail, and by any other means directed either tolfromsubject.a. Computer hardware is defined as any com puter equipm ent including any electronicdevices which are capable of analyzing, collecting, converting, creating, displaying, ortransmitting electronic, magnetic, optical computer impulses or data. These devices include, butare not limited to, computers, computer components, computer peripherals, data-processinghardware (such as CPUs, memory typewriters, and self-contained laptop or notebook_ computers), encryption circuit boards, internal and peripheral storage devices (such as fixeddisks, external hard disks, floppy disk drives and diskettes, tape drives and tapes and opticalstorage devices), peripheral input/output devices (such as keyboards, printers, scanners, plotters,and video display monitors), related communications devices (such as modems, cables andconnections, recording equipment, Random Access memory (RAM) or Read-Only memory

(ROM ) un its, autom atic dialers, speed dialers, ,program mable telephon e dialing or signalingdevices, and electronic tone gathering devices), as well as devices, mechanisms, or parts that canbe used to restrict access to such hardware (such as physical keys and locks.)b. Com puter software is defined as any instructions or programs stored in the form ofelectronic, magnetic, or optical media which are capable of being interpreted by a computer orits related compon ents. These items include, but are not limited to, operating systems,application software, utility programs, compilers, interpreters, and communications software, as

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well as software used to cornrnunjcate with computer hardw are peripherals, either directly orindirectly by telephone lines, radio, or other means of transmission. Com puter software mayalso include certain data, data fragments, or control characters integral to the operation of thecomputer software.c. Computer-related documentation is defined as any written, recorded, printed, orelectronically-stored material which provides instructions or exa mples concerning the operatingof a computer system, computer software, andlor any related de vice, including but not limited to,user agreements, software manuals, and operating procedure guidelines. Such documen tationmay also include material which explains or illustrates the configuration or use of any seizedhardware, software, or related item.d. Computer passwords and data security devices are defines as all those devices,programs, or data - whether themselves or in the nature of hardware or software - that can beused, or is designed for use to restrict access to, or facilitate concealment of, any computerhardware, software, computer-related documentation, electronic data, records, or materials

within the scope of this application. These items include, but are not limited to, any datasecurity software or information (such as test keys and encryption codes), similar informationthat is required to access computer programs or data or to othe rwise render programs or data intousable form.e. Records, docum ents, and materials, as used above, includes all the forgoing items ofevidence in whatever form and by whatever means such records, documents, or material, theirdrafts, or their mod ifications may have been created or stored, including, but not limited to, anyhandmade form (such writing or drawing), any photographs or negatives, any riiechanical form(such as printing or typing) or any electrical, electronic, magnetic, or optical form (such asfloppy diskettes, hard disks, CD -Roms, optical disks, printer buffers, sm art cards, thumb drives,mem ory calculators, electronic dialers, or electronic notebooks), as well as printouts or readoutsfrom any storage devices.f. The term electronic mail is defined as any communications, including, but not limitedto, the transfer of signs, signals, writing, images, sounds, data, or intelligence, previouslyreceived, transmitted, or stored, or prepared in contemplation of transmission, or anycommunications in the process of being received or transmitted, whether stored on anyelectronic media named above or held in temporary, intermediate storage incidental totransmission.