Charges Against Terry Nichols

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Count 1: Conspiracy to Use a Weapon of Mass Destruction

The grand jury charges that beginning in September 1994, Timothy James McVeigh and Terry Lynn Nichols did conspire with others unknown to the grand jury to use a weapon of mass destruction, namely an explosive bomb placed in a truck against persons within the United States and against property that was owned and used by the United States and by a department and agency of the United States, namely, the Alfred P. Murrah Federal Building, Oklahoma City, resulting in death, grievous bodily injury and destruction of the building. The grand jury charges that the object of their conspiracy was to kill and injure innocent persons and to damage property of the United States. The grand jury charges that McVeigh and Nichols planned the act of violence and McVeigh attempted to recruit others to assist. The grand jury charges the two men obtained and attempted to obtain the components, including a truck, ammonium nitrate, racing and diesel fuel, detonation cord and other explosive materials. The grand jury charges they used storage units to conceal the bomb components and stolen property that was sold to help finance their act of violence. The grand jury charges that McVeigh and Nichols made calls with a telephone calling card that they had acquired in a false name as a means of concealing their true identities. The grand jury charges McVeigh and Nichols used different false names in business transactions as a means of concealing their true identities, their whereabouts and the true intent of their activities. The grand jury charges they constructed an explosive truck bomb, and McVeigh placed it outside the building and detonated the bomb.

Count 2: Use of A Weapon of Mass Destruction

The grand jury further charges on or about April 19, 1995, at Oklahoma City, McVeigh and Nichols did cause to be used a weapon of mass destruction, namely a truck bomb, against persons within the United States, resulting in death and personal injury.


Count 3: Destruction by Explosive

The grand jury further charges that on or about April 19, 1995, at Oklahoma City, McVeigh and Nichols did cause to be damaged and destroyed by means of a truck bomb the Alfred P. Murrah Federal Building, causing death and injury. Counts 4-11: First Degree Murder The grand jury further charges on or about April 19, 1995, at Oklahoma City, McVeigh and Nichols did, with premeditation and malice aforethought, cause the killing of the following persons engaged in the performance of official duties as law enforcement officers: Mickey Bryant Maroney, special agent, U.S. Secret Service; Donald R. Leonard, special agent, U.S. Secret Service; Alan Gerald Whicher, assistant special agent in charge, U.S. Secret Service; Cynthia Lynn Campbell-Brown Special, special agent, U.S. Secret Service; Kenneth Glenn McCullough, special agent, U.S. Drug Enforcement Administration; Paul Douglas Ice, special agent, U.S. Customs Service; Claude Arthur Medearis, special agent, U.S. Customs Service; and Paul G. Broxterman, special agent, Department of Housing and Urban Development, Office of Inspector General.