i a POLICE CRIMINAL COMPLAINT Dagipt Namabor: — | Gale Fede — | OTHiLiveSean Number: ‘Conipieindnciaent Number CReteS ft fiive “TIP AAT Ho7-2431318 ames} Fist Taiadle: ast AFFIDAVIT of PROBABLE CAUSE ‘Your affiant is a member of the Pennsylvania State Police and has been so since 2006. Your affiant currently holds the rank of Trooper and is assigned to the Criminal Investigations Unit at Troop H, York. On Wednesday, September 02, 2016 Tpr. Edward PRENTICE, PSP York Patrol Unit, responded to @Highland Ra. (Ine COFFLINISNYDER residence) for a call regarding threatening text messages. As a resull of his investigation, Tp PRENTICE established that Howard COFFLIN was communicating through text messages to an acquaintance rramed Jo ‘Aan MOORE, his desire to harm his long term girlfriend, Tina Marie SNYDER. The content of the text messages indicated that he, COFFLIN, planned to "take care of SNYDER. COFFLIN specifically sent MOORE a photograph of a hatchet along wih a message-that read "I think it would be best if you guys don’t text or talk fo me anymore. You don’t want fo be associated with me and this mess". Furthermore, COFFLIN indicated thal he had purchased the small axe but ‘was shopping for "a suitable large one now’ arid that he was “stil looking for a gun, but could get an axe faster". As result, COFFLIN was charged wilh terroristc threats. SNYDER was directed to seek a Protection Form Abuse Order. A temporary PFA was obtained by SNYDER later that day. On Thursday October 22, 2018.an attorney COFFLIN hired to defend him contacted PSP York. COFFLIN's attorney voiced concern regarding his client after COFFLIN communicated to him his plans to carry out acts of violence against SNYDER as well as law enforcement personnel upon representing him at a preliminary hearing on Wednesday October 21, 2018. COFFLIN’s attorney subsequently contacted the Pennsylvania Bar Association Ethics Hottine and was granted pormission to breach COFFLIN's atlomney/client confidentiality privilege in this instance due to a legitimate officer and public safety concern. meee Having received such permission, COFFLIN's allomey prepared the following brief synopsis of his contact with COFFLIN and provided it to PSP York: zs “in the course of my representation | believe | have a duty to disclose an imminent threat of death or serious bodily injury. On October 6, 2015, Mr. Coffin communicated to me thet he is in the planning and operational stages of taking back possession of his house, He further communicated fo me that he had acquired ballistic body armor and assault rifles. On October 21, 2015, prior to his preliminary hearing Mr. Coffin fold me that he had the body armor and thet he had the pieces for tho assauit rifle. He went on to say that he was machining the necessary parts fo complete the assault rife, Mr. Coffin said that as soon as the parts were machined fie was going to take action.” |, TPR. JEREMY CORRIE, BEING DULY SWORN ACCORDING TO THE LAW, DEPOSE AND SAY THAT THE FACTS SET FORTH IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT TO THE BEST OFMY KNOWLEDGE, INFORMATION AND BELIEF. i i‘ worn to mo and subscribed before me this __ 7 dayot Ya Dale a My Zommission expires first Monday of January, —— %, “Gp BEES Patani AOPC 4116 - Rev. 07/10 Page 1 of {.tes POLICE CRIMINAL COMPLAINT AFFIDAVIT CONTINUATION PAGE It Bockes Number: Date Filed: OTNALiveScan Numb ‘Compiainvincidant Number Robo gue Litt FPL Aa, Ho7-2431318 : ‘dai: Last Defendant Name: Sealy Ee a AFFIDAVIT of PROBABLE CAUSE CONTINUATION Through speaking with SNYDER as well as a PFA proof of service, it was determined that COFFLIN was residing a Ar Westfield Rd., Dundalk, MD 21222 which was discovered to be his mother's home. On Thursday October 22, 2015 | contacted Corporal Larry GICK, Baltimore County Police Department Firearms Interdiction Unit, and relayed all pertinent information regarding my investigation to him. Cpl. GICK informed me that, according to his records, COFFLIN was prohibited by Maryland state law from possessing a firearm due to various prior criminal convictions Cpl. GICK then contacted COFFLIN's atlomey, and utilizing the information gained in his Intefview of him, prepared and successfully obtained a search warrant for COFFLIN’s mother's residence. Ablack Mercedes GLK 350 registered to COFFLIN was found to be parked outside the residence and included in Cpl. GICK's search warrant. Members of the Baltimore County Police Department executed a search of COFFLIN’s mother's home and his vehicle on Friday, October 23, 2015 at approximately 1405 HRS. Inside this vehicle, officers located items such as plans, components and parts to build a complete and functional AR15 style rifle, 6 thity-round AR-15 magazines, heavy duty body armor and 5.56 caliber ammunition. Also located in the vehicle was documentation indicating the date of purchase of these items was October 11, 2015 as well as handwritten notes describing the location and other details of the Pennsylvania State Police, Troop H, York barracks. An additional handwritten note concerning tactical equipment was discovered during the search and was dated 9-20-16. This note listed items such as night vision and "IR laser on weapon’. Finally, a lease agreement for "A Better Rate Storage" facilty, Space # 424 with COFFLIN as the occupant, was located within the vehicle. Shortly after the execution of the Search warrant, | was contacted 53, CPL GICK who Incstes that COFFLIN was custody for firearms related offense(s) On October 23, 2016 at approximately 1630 HRS | arrived at BCPD Precinct 12 where | viewed and photographed all items seized from COFFLIN during the search. Cpl. GICK added that they also seized COFFLIN’s cell phone, an Apple iPhone 6, at the time of his arrest. sty RL Ola ral, SN nt ef Real, “ROPC 4116 - Rev. 07/10ie POLICE CRIMINAL COMPLAINT AFFIDAVIT CONTINUATION PAGE ‘Gompfaindine!dent Number “BoE py wi ate Fede iLveScan Number: apd | fire eel foraariste at wae tat Defendant Name: | Howard Timothy COFFLIN = AFFIDAVIT of PROBABLE CAUSE CONTINUATION _ On Ociober 23, 2016 at approximately 1730 HRS, | interviewed COFFLIN in an Interview room at Precinct 12 along with BCPD Det. HINTON. Detective HINTON had previously informed COFFLIN of his MIRANDA warnings on October 23, 2018 at 1422 HRS. COFFLIN was informed that the purpose of our visil was to obtain an audibly recorded statement from hitn. COFFLIN began his statement by saying “Yjust don't think | wanna talk anymore. | mean, talking is what's got me in trouble and talking is why you're here, you know, the time for talking is over. It's time for action and that’s what I'm doing. If get out I’m gonna start again, | have a mission and those things were Just fools, you know, for me to do what gotta doe He went on to state "As far as ! know, you know, I've got other stuff that you haven't found, I've got, you know, Vm buileing explosives and bombs. !'m building IEDs, You can take @ simple propane tank and put Tannerite binary explosive on it and strap nails or IED, you know, make an IED. |'m taking out personnel. I'm gonna go to my house and dofend my house. If the police try to come in my door, I'm gonna set it off And that’s why | need a seventeen hundred foot per ‘second bullet or better causa that’s what sots off the Tannerite. So1'm planning on going fo war, 'm not mentaily insane, [know they're gonna got me. I'm not suicidal, I'm not gonna kill mysell. 'm gonna go and am I'm gonna do what! have to do, This is a war and they've attacked me so I'm gonna attack them.” COFFLIN then freely discussed his plan and the events that led to his decision for nearly an hour and a half indicating that he intended to acquire another gun when released from prison and provided detailed information regarding his plot The following is a summation of the information gained through interviewing COFFLIN: Tina Marie SNYDER is COFFLIN's exgirlriend of over 20 years. Their relationship has been stale for 10-12 yoars with no intimacy during that time. In fact, COFFLIN later specified that the two are “more lke roommates.” Recently, the relationship took a turn for the worse afer their home was flooded by a broken pipe which went unnoticed for several days. COFFLIN was in California when this occurred and when he returned, was upset with how the situation was being handled. He and SNYDER engaged in a-dispute which resulted in PSP being called to their homie, No arrest was fade however, SNYDER was granted a temporary Protection From Abuse (PFA) order later that day, August 14, 2016. COFFLIN was served with the order which prohibited him from being at his home and having any.contact with SNYDER both directly and indirectly. COFFLIN has become angry due to his belongings being inaccessible and feels that the PFA was withoul cause. He also feels that SNYDER is “gloating” and is using the court sysiem to evict him from his house. Due to this fact, COFFLIN added "/plan fo go and kill her. I plan to build a rifle. | have the element of surprise on my side, especialy at night, and I'm going to go and kill hes. And then I'm going to go back and take possession of my house and go fo war with whatover police they send. That's why | got the body armor. 1 stil have to gota tactical helmet. I plan to get a lear gas mask in case they try to gas me. | have night vision optics so I can see-them creeping around at night. ‘And | know they're gonna get me.” Hy TRIAL Ol 7!n, Sea 1 “a ‘AOPG 411G - Rov. 07/10ee POLICE CRIMINAL COMPLAINT AFFIDAVIT CONTINUATION PAGE _ Dogiet Numper; , | Date Filed] OTNiCivaSean Number: ‘Compisiinerdnt Nu Exc ON | passe THM ARA ee Ho7-2431318 Fret de Last Defendant Name: | Licward Timothy COFFLIN - AFFIDAVIT of PROBABLE CAUSE CONTINUATION Although he claimed to have no experience with firearms, COFFLIN was certain that due to his mechanical engineering background he possesses the knowledge and capability to successfully build an AR-15 with the items seized by Baltimore County Police Department (BCPD.) He is ‘nof an expert at weapons” but stated "I am trying to make myself that now." He planned to complete the rifle build by miling the remaining lower receiver components but didn't have access to a drill press quite yet. COFFLIN went on to discuss how he knows he could carry out his plen to kill SNYDER at her place of employment in Hunt Valley, MD, but sated “Y had fo decide do ! want fo do this thing in Maryland or in Pennsytvania and | really wanted {0 do itn Pennsylvania. Because ideally | could ambush her at the house and’kil her right there and take my house, | don't want fo be caught out in the open going from Hunt Valley lo my house because 'm more vulnerable, I can defend ‘my house a lot easier than I can in a car.” COFFLIN indicated that Pennsylvania State Police are responsiole for police coverage at his residence in Loganville, PA and he hopes they are the agency that responds after he carries out his pian since “They are the ones that ambushed mo af my house and arrested me." He also stated "7.they step on my property, I'm gonna fire on them” When asked if he intended to kill Penrisyivania State Troopers, COFFLIN responded “Absolutely. | already staked out their headquarters. | already know where they fuel their cars. | already know the entrances and exits fo their... 've already done surveillance ‘on their... they ambushed me at my house so I'm debating whether I” like to ambush them at their slate police headquarters. They alteady had two of them shot by a sniper.” COFFLIN indicated that the State Police facility he was speaking about is located in Loganville, PA stating specifically that It is “two minutes from my house” adding "I've already leken piclures of t. I already know when and how they fuel their vehicles. I'm looking at their habits. I'm looking at their vulnerabilities... 'm going fo war with them... It sounds crazy but they're pushing me over the edge. They started with mo and I'm going to war with them as you can see.” When asked to expand on the vulnerabilities he identified, COFFLIN Tefused to further discuss his findings but explained that he “wasn’t done” and hadn't begun to build the explosives. ‘According to COFFLIN ‘you can tako a simple propane tank, and put nuts and bolts ar nails on it and put Tannerite on it that you can go éind buy right at Cabela's or at Dick's and | could put that in a van and.” COFFLIN added that he had three 40:pound tanks in his shed as well as three or four “Iwentios” and was angry that he didn’t have access to them. Furthermore, he related that he planned fo, acquire Tannerite which he “could have bought right at this gun show. ° And you need a high velocity round to set that off.” COFFLIN continued his statement discussing that he feels the court has not been cooperating with him and attempted to use the court-permitted 4 hour window to gather necessities from his residence noting “that's when State Police ambushed me that day, because of the text messages.” COFFLIN specifically noted that the two troopers he recalled being involved in his arrest(s) were “Hutchins” and “Prentice” and added “and now | know what they look ks.” According to COFFLIN "They'd be the first fo go if can identity then.” st 80, NER Diy, SS sGouinonoy 4, m4 aii ae ai We file —- pape AOPC 411C - Rev. 07/10 Page 4 of 8POLICE CRIMINAL COMPLAINT AFFIDAVIT CONTINUATION PAGE igi number, | Date Filed: | OTN ‘Complainvinciaent Number tbe | hyde H07-2431318 First Wide ast - Defendant Name: | Howard Timothy COFFLIN AFFIDAVIT of PROBABLE CAUSE CONTINUATION COFFLIN went om to relate that he bought arraxe with the intent to decapitate SNYDER” He ther planned to’ put her head on a pole to teach the "York County government’ a lesson and stated that "they need to change these policies.” He further related that he did not carry out this plan because he assumes SNYDER is now in possession of a gun and doesn’ want to “bring an axe to a gunfight.” As the interview progressed, COFFLIN indicated he suspects his lawyer of reporting the situation to police. He further indicated that he isr't worried about his upcoming trials for his prior arrests because “a terrorstic threats charge is going to be poanuts compared to first degree murder, which is what its. I'm planning it. 'm gonna execute it. I'm not worried about their simple lille torroristc threats chargo. I'm on a timeline. | only have so much time, 'm looking at it now lke if like if| have an arraignment December 4" | have to get that recoiver machined and get that gun together and do what | gotta do.” COFFLIN went on to relate that he does not plan to plea to anything and serve any time he's sentenced to and resume his plan when he gets out of jail. With that said, COFFLIN made a point to discuss his finances and how he Is running out of money due to his lack of employment, In fact, COFFLIN planned to liquidate his-belongings to fund his plan after his incarceration COFFLIN also indicated that he does not pian to survive his operation, noting that he already prepared a will and clearly stated that he is not suicidal but rather suspects that he will “die in a shootout with the police.” > By his own admission COFFLIN isin the “gather the supplies and equipment stage” and has a desire to acquire ammunition, namely tungsten bullets, capable of penetrating ballistic shields used by police in tactical scenarios. If he ‘was unable to purchase such ammunition, he figured he would use his machinist’s background and precise measuring tools to make them at home. Addressing the lack of access to his home, he indicated that he contemplated renting an apartment and re-purchasing the tools to complete assembly of the AR-18. In doing so, COFFLIN planned to convert it to a fully automatic firearm, ‘As he continued his statement COFFLIN spoke of doing things such as parking his boat in the front lawn of his house merely 2s an act of defiance toward the judge involved in his case. When asked if he harbored any ill feelings toward York County judges he stated “absolufoly” and recalled Judge ADAMS being involved in his case. Furthermore, he noted that during his last court appearance at the York County courthouse he surveyed the entrance to the sheriffs office where the judges park their personally owned vehicles and stated tat if he “wanted to get a judge I would just wait for him there". COFFLIN stated he views, York County as “tyrannical government and overreach." ‘Speaking of his plot, COFFLIN further indicated that he planned fo kill SNYDER, barricade himself in his house and wait {or police to respond, taking "as many of them with me as ican.” He added thal he would not consider his statements threats but more so ‘a plan.” Additionally he stated he was attempting to put himself in the best defensible position within his home but added that he considered culting the gas lines and blowing it up “ust fo feach them a lesson.” Moreover, COFELIN added, */¢ really ike fo get info that house because in that house is all the stuff that I need to bulld and machine this gun. All the propane tanks are there, all the tools.” “ROPE A116 - Rev. O70 Page 5 of 8oes POLICE CRIMINAL COMPLAINT AFFIDAVIT CONTINUATION PAGE [Boe umbse Cale Filed: —] OTNILveSgan Nump Complainvncident Nonber Le Sei | pele THEE) HoT 231018 Frat Wie Last Dofondant Name: | HSE Timothy COFFUN AFFIDAVIT of PROBABLE CAUSE CONTINUATION COFFLIN one more time detailed various Bars 6f fils plan Statiig “I! can catch her there at that Fiouse that would be ideal and if she's there with other people, if they seo a gun like | have,.1'm gonna tell her leave now, and I'm sure they will, and then Vn gonna have her and then that’s when 'm gonna do what | have f0 do... If they try to-defend her or iy fo fake the weapon away from me then lm gonna kill them. 1'm not gonna let anyone get close to mo fo overpower me. I'm. ‘gonna have my distance and I'm gonna fell them fo leave and I'm gonna fell them or 'm gonne kill you and they'l leave. ‘And Tina is gonna try to run. She's gonna try to run away screaming so it! have fo shoo! her in the back, 'm gonna ‘shoot her in the back and then I'm gonna empty an entire cilp info her head. 1'm gonna make a point. This is‘ statement. | don’t want fo just shoot her once | want fo shoot her with every bullet that [ have... I(S gonna send 2 message of rage and hatred... But Im wrong there because | don’t want to completely deplete my ammunition. !'m not gonna leave myself completely defenseless.” Near the end of our interaction, Det. HINTON and | briefly discussed, with COFFLIN, his feeling toward whomever reported hig plan to police. COFFLIN indicated that he felt it was his allomey and indicated if he found out who it was for sure, he “absolutely” holds ill wil toward him or her because his arrest is costing him ‘a lof more time and money and delay”. COFFLIN felt that whomever it was “deserved fo pay a penalty for that.” Upon returning to PSP York, contact was made with an employee of “A Better Rate Storage who confirmed that COFFLIN is the lessee of Units #424 and #426 at that particular facility. A search warrant was obtained and approved for the hours of nighttime. During this search, an abundance of engineering literature and paperwork, assumedly from COFFLIN’s past education and employment, was found to be present in Unit #424, A large John Deere Tractor and Harley Davidson motorcycle was also noted to be stored in the facility. 7 On Monday, October 26, 2015 | learned through SNYDER that COFFLIN also rents a storage unit at South Hanover Storage. I then made contact with the owner of South Hanover Storage, via telephone who verified that COFFLIN leases two storage units, garages #5 and #6, at his facility Based on the aforementioned information, a search warrant was oblainéd and searches of the garages were conducted on October 26, 2016 at approximately 1426 HRS. The garage(s) contained three vehicles and 2 large boat but otherwise were relatively empty. Despite there being no other literature, similar to that located in the first storage facilly, a binder tiled "Target Description Standards For Ballistic Survivabiily, Lethality, & Vulnerability Analyses of Ground Mobile Vehicles & Aircraft” was locaied in the irunk of a white Nissan Maxima parked inside Garage #6. Ry NAL Dik Sauer AOPC 411C - Rev. 07/10 Page & of &des POLICE CRIMINAL COMPLAINT AFFIDAVIT CONTINUATION PAGE Bo “ambos ate FibaE [OTS Namba Sennen Haron &, Spl | ie “THA Z| HO7-2431318 ora Ti Defondant name: | Fre tnt cued AFFIDAVIT of PROBABLE CAUSE CONTINUATION Based on COFFLIN’s statements concerning taking photographs of Pennsylvania State Police facilities, as well as statements and notes concerning his planning and researching of his operation, | obtained a search warrant for COFFLIN's iPhone. Custody of the iPhone was then transferred to PSP York from BCPO on October 26, 2015. Custody of the phone along with a copy of the applicable search warrant was subsequently transferred to Detective Mark BAKER, ‘2 member ofthe Norther York Gounty Regional Police Depariment and York County Cyber Crimes Investigations Task Force, for analysis. Or October 27, 2015 | was provided a report detaliing Det. BAKER'S findings. Such results included numerous internet searches which were found to be conducted on COFFLIN's iPhone, These seaiches were conducted ‘on muitiple occasions for topics including but not limited to: How to kill a state trooper (Google Search conducted en September 27, 2018) + Howtokilla state cop (Google Search conducted on September 27, 2016) + Killing a state cop (Google Search conducted on September 27, 2015) + Killing @ state trooper (Google Search conducted on September 27, 2018) + Killing with an ar 45 (Google Search conductéd on September 28, 2015) Detective BAKER also indicated that numerous bookmarks were found on the device, many of which surrounded body armor. Also of particular concern were bookmarks for topics such as but not limited to: Best 656 ammo Gas mask to stop tear gas How to build an incendiary bomb more powerful than napalm How to deal with riot control agents: 8 steps How to defend against a taser a How to make a virtually untraceable phone call. Make your own tannerite Milling machine for 80% ar lower Mini mitt comparison — fitimachineshop.com Murder-suicide: when killing yourself isn’t enough — Officer.com Plate armor on a budget ~ the bang ewitch Remington 700 .308 tactical - google search Thermite igniter fuses to get thermite started — survivalist forum ‘Also on October 26, 2015 | obtained @ search warrant for SNYDER’s residence (COFFLIN's former residence) of ti Highland Rd, in Loganville Boro, and its curtlage. A search of the residence was ccnducted on October 27, 2016 at approximately 0900 HRS. tt, SERIAL Dig SE Cy Se pninen AOPC 441C - Rev. 07/10a dee POLICE CRIMINAL COMPLAINT AFFIDAVIT CONTINUATION PAGE Deft nu, snare Date Fede ComlaiUldent Nur CROCS |/ Bile Hon Ho7-2431318 | Fist: Middle: Tast Defendant Name: | Howard Tinothy _| corrun AFFIDAVIT of PROBABLE CAUSE CONTINUATION {As 2 Fesuit of this search the following items were located and seized: (3) Large propane tanks (located in the shed.) (6) Small propane tanks (located in the shed.) (1) ICOM police scanner (located in COFFLIN's bedroom.) (1) Standard Horizon police scanner (located in COFFLIN's bedroom.) (1) Dell tablet (located in COFFLIN's bedroom.) (1) Dell taptop computer (located in COFFLIN's bedroom.) (1) Storage basin containing a large amount of misc. nails and screws (located outside the shed) (1) Mitutoyo caliper (located amongst COFFLIN's belongings in the basement.) (1) Fowler caliper (located amongst COFFLIN's belongings in the basement. While reviewing the report prepared by Det. BAKER on a later date, | noticed that COFFLIN's IPhone connected to a wireless network named *Rutters’ on October 11, 2015 at 1723 HRS. Consequently, was noted through receipts Tecovered by 8CPD that October 11, 2015 was also the date COFFLIN purchased the AR-15 components. According to fone receipt from Precision Firearms, the purchase was made at 1440 HRS (2 hours and 43 minutes prior to the Wf connection.) Itwas then determined that the wireless network was that of Rutte’s In Loganville Boro. This particular establishment is located approximately 0.15 miles (<300 yards) frbm the PSP York Barracks, On October 28, 2018 a search warrant was obtained for COFFLIN’s financial information through TransUnion. As a result of this search warrant, information relevant to COFFLIN's financial history was received from TransUnion on November $3, 2016. ‘This report indicated that COFFLIN may have utilized fourcifferent accounts to make purchases to further his endeavors in carrying Out his plan. An account through Bank of America was confirmed to be the account which was used to make at least a portion ofthe previously mentioned purchases at the Harrisburg gun show. On December 17, 2018 | received audio recordings of several inmate telephone calls placed by COFFLIN to his mother ‘fom the Baltimore County Detention Facility since the commencement of his incarceration. While reviewing thes recordings it became apparent to me that COFFLIN stil Intends to'harm SNYDER upon his release from prison. During fone of thase recorded calls COFFLIN specifically steted ‘T!! never recognize any authorily that tells me | can't own a gun. When I'm out 'm gonna get a gun as easily as you can go to the corner store and buy milk.” Based on the facts set forth above, itis clear thal the defendant, Howard Timothy COFFLIN Jr, planned and intended to kil SNYDER as well as Pennsylvania State Police Troopers and took substantial steps toward doing so. Your affiant believes the informatisn contained within this affidavit it rue and correct and requests the issuance of due process for the defendant ty TRIAL Diy! Seed aes AOPC A11C - Rev. 07/10 Page 8 of &