Case 3:20-cr-00389-DCG Document 82 Filed 07/09/20 Page 1 of 9
IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF TEXAS
EL PASO DIVISION fl 9 5
- .:,
UNITED STATES OF AMERICA, CRIMINAL NO.
Plaintiff, SUPERSEDING
INDICTMENT
1u
V. CTS 1-23: 18 U.S.C. 249(a)(2)
Hate Crime Resulting in Death;
CTS 24-46: 18 U.S.C. § 924(c), (j)(1)
PATRICK WOOD CRUSIUS, Use of a Firearm to Commit Murder During
and In Relation to a Crime of Violence;
Defendant. CTS 47-68: 18 U.S.C. § 249(a)(2)
Hate Crime Involving Attempt to Kill;
CTS 69-90: 18 U.S.C. § 924(c)
Use of a Firearm During and In Relation to
a Crime of Violence.
Notice of Special Findings
Notice of ovërnment's Demand for
Forfeiture
THE GRAND JURY CHARGES:
INTRODUCTION
1. On or about June 19, 2019, Defendant PATRICK WOOD CRUSIUS used the
internet to purchase a GP WASR-10 semi-automatic rifle with serial number A1-65552-18, a
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
x 39 millimeter hollow point ammunition.
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 82 Filed 07/09/20 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."
3. On or about August 3, 2019, Defendant PATRICK WOOD CRUSIUS drove a
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.
4. On or about August 3, 2019, Defendant PATRICK WOOD CRUSIUS uploaded
the document he had drafted entitled "The Inconvenient Truth" onto the internet.
5. On or about August 3, 2019, after uploading the document entitled "The
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-three individuals and injured many more.
COUNTS ONE THROUGH TWENTY-THREE
(18 U.S.C. § 249(a)(2) - Hate Crime Resulting in Death)
Paragraphs numbered 1 through 5 previously alleged in this indictment are re-alleged and
incorporated as though fully set forth herein.
6. On or about August 3,2019, in the Western District of Texas, Defendant PATRICK
WOOD CRUSIUS willfully caused bodily injury to the victims listed below because of the actual
and perceived national origin of any person:
COUNT VICTIM
1 A.A.
2 J.A.
Case 3:20-cr-00389-DCG Document 82 Filed 07/09/20 Page 3 of 9
3 A.B.
4 J.C.G.
5 L.C.
6 A.E.
7 M.F.
8 R.F.
9 G.G.S.
10 A.C.H.
11 A.H.
12 D.J.
13 L.A.J.
14 M.L.R.
15 M.L.H.
16 I.F.M.
17 G.I.M.
18 E.M.M.
19 M.R.
20 S.R.M.
21 J.A.R.
22 T.S.
23 J.V.
and, in connection with each of the offenses in Counts One through Twenty-Three, 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.
All in violation of Title 18, United States Code, Section 249(a)(2)(A)(ii)(I).
COUNTS TWENTY-FOUR THROUGH FORTY-SIX
(18 U.S.C. § 924(c), (j)(1) - Use of a Firearm to
Commit Murder During and In Relation to a Crime of Violence)
Paragraphs numbered 1 through 5 previously alleged in this indictment are re-alleged and
incorporated as though fully set forth herein.
Case 3:20-cr-00389-DCG Document 82 Filed 07/09/20 Page 4 of 9
7. On or about August 3, 2019, in the Western District of Texas, Defendant PATRICK
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
charged in Counts One through Twenty-Three; 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
victim with the firearm.
COUNT VICTIM
24 A.A.
25 J.A.
26 A.B.
27 J.C.G.
28 L.C.
29 A.E.
30 M.F.
31 R.F.
32 G.G.S.
33 A.C.H.
34 A.H.
35 D.J.
36 L.A.J.
37 M.L.R.
38 M.L.H.
39 I.F.M.
40 G.LM.
41 E.M.M.
42 M.R.
43 S.R.M.
44 J.A.R.
45 T.S.
46 J.V.
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All in violation of Title 18, United States Code, Sections 924(c) and 924(j)(1).
COUNTS FORTY-SEVEN THROUGH SIXTY-EIGHT
(18 U.S.C. § 249(a)(2) - Hate Crime Involving Attempt to Kill)
Paragraphs numbered 1 through 5 previously alleged in this indictment are re-alleged and
incorporated as though fully set forth herein.
8. On or about August 3, 2019, in the Western District of Texas, Defendant PATRICK
WOOD CRUSIUS willfully caused bodily injury to the victims listed below because of the actual
and perceived national origin of any person:
COUNT VICTIM
47 P.G.A.
48 M.A.P.
49 E.A.
50 J.A.A.
51 R.B.
52 M.A.P.B.
53 R.C.
54 L.C.
55 M.D.A.M.
56 E.G.D.A.R.
57 A.E.D.L.R.
58 J.G.
59 M.M.G.G.
60 M.E.G.
61 E.C.G.
62 M.J.
63 M.S.L.
64 O.R.L.
65 O.R.M.
66 N.E.M.Z.
67 L.M.P.
68 R.V.
and, in connection with each of the offenses in Counts Forty-Seven through Sixty-Eight, 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.
All in violation of Title 18, United States Code, Section 249(a)(2)(A)(ii)(II).
COUNTS SIXTY-NINE THROUGH NINETY
(18 U.S.C. § 924(c) - Use of a Firearm During and In Relation to a Crime of Violence)
Paragraphs numbered I through 5 previously alleged in this indictment are re-alleged and
incorporated as though fully set forth herein.
9. On or about August 3, 2019, in the Western District of Texas, Defendant PATRICK
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 Forty-Seven through Sixty-Eight.
COUNT VICTIM
69 P.G.A.
70 M.A.P.
71 E.A.
J.A.A.
73 R.B.
74 M.A.P.B.
75 R.C.
76 L.C.
77 M.D.A.M.
78 E.G.D.A.R.
79 A.E.D.L.R.
80 J.G.
81 M.M.G.G.
82 M.E.G.
83 E.C.G.
Case 3:20-cr-00389-DCG Document 82 Filed 07/09/20 Page 7 of 9
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.
All in violation of Title 18, United States Code, Section 924(c).
NOTICE OF SPECIAL FINDINGS PURSUANT TO
TITLE 18, UNITED STATES CODE. SECTIONS 3591 AND 3592
THE GRAND JURY FINDS:
10. As to Counts Twenty-Four through Forty-Six, Defendant PATRICK WOOD
CRUSIUS,
i. was 18 years of age or older at the time of the offense;
ii. intentionally killed the victim (18 U.S.C. § 359 1(a)(2)(A));
iii. intentionally inflicted serious bodily injury that resulted in the death of the
victim (18 U.S.C. § 3591(a)(2)(B));
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
a result of the act (18 U.S.C. § 3591(a)(2)(C));
v. intentionally and specifically engaged in an act of violence, knowing that the
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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11. As to Counts Twenty-Four through Forty-Six, Defendant PATRICK WOOD
CRUSIUS knowingly created a grave risk of death to one or more persons in addition to the victim
of the offense (18 U.S.C. § 3592(c)(5));
12. As to Counts Twenty-Four through Forty-Six, Defendant PATRICK WOOD
CRUSIUS c mmitted the offense after substantial planning and premeditation to cause the death
of a person (18 U.S.C. § 3592(c)(9));
13. As to Counts Twenty-Four through Forty-Six, Defendant PATRICK WOOD
CRUSIUS intentionally killed and attempted to kill more than one person in a single criminal
episode (18 U.S.C. § 3592(c)(16));
14. As to Counts Twenty-Nine (A.E.), Thirty (M.F.), Thirty-One (R.F.), Thirty-Three
(A.C.H.), Thirty-Four (A.H.), Thirty-Six (L.A.J.), Forty-Three (S.R.M.), Forty-Five (T.S.), and
Forty-Six (J.V.), the victim was particularly vulnerable due to old age and infirmity (18 U.S.C. §
3592(c)(1 1)); and
15. As to Count Forty-Four (J.A.R.), the victim was particularly vulnerable due to
youth (18 U.S.C. § 3592(c)(11)).
NOTICE OF GOVERNMENT'S DEMAND FOR FORFEITURE
16. The grand jury re-alleges and incorporates by reference all allegations contained in
Counts Twenty-Four through Forty-Six, and Counts Sixty-Nine 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 246,1(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-Four through Forty-Six, and Counts Sixty-Nine through Ninety of this indictment, the
following firearms and ammunition, which were involved and used in the knowing commission of
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Case 3:20-cr-00389-DCG Document 82 Filed 07/09/20 Page 9 of 9
those offenses, are subject to forfeiture pursuant to Title 18, United States Code, Sections 924(d);
and Title 28, United States Code, Section 246 1(c):
a) a GP WASR-1O semi-automatic rifle with serial number A1-65552-18; and
b) any other property, to include ammunition, which was involved and used in the
knowing commission of the offenses specified above.
A TRUE BILL.
ORIGiNAL SIGNATURE
REDACTED PURSUANT TO
'' rp4r ACT OF 2002
FOREPERSON OF THE GRAND JURY
JOHN F. BASH
UNITED STATES ATTORNEY
ERIC S. DREIBAND
ASSISTANT ATTORNEY GENERAL
CIVIL RIGHTS DIVISION
