AFFIDAVIT OF ASSISTANT SPECIAL AGENT IN CHARGE

TERRY D. TURCHIE

U.S. DISTRICT OF MONTANA

1. I, Terry D. Turchie, having been duly sworn, depose and state that I am a Special Agent of the Federal Bureau of Investigation (FBI) and have been so employed since 1976. I graduated from California State University at Sacramento in 1972 with a BA Degree in Criminal Justice and Southern Illinois University in 1976 with an MS Degree in Political Science. From 1976 to 1988, I was assigned to investigate a variety of federal criminal matters in both the FBI’s Portland and New York’s offices. In 1988, I was assigned to the San Francisco Division of the FBI as a Supervisory Special Agent (SSA) of a Foreign Counterintelligence Squad, where I supervised a number of sensitive Foreign Counterintelligence investigations. In 1994, I was re-assigned as the SSA for the UNABOM Task Force
(UTF) in San Francisco. My responsibilities included the coordination of the efforts of the three agencies represented on the UTF (FBI, Bureau of Alcohol, Tobacco, and Firearms, and Postal Inspection Service); the development of an integrated investigative strategy to ensure the complete investigation of all UNABOM events and the identification of potential suspects; and the supervision of agent and support personnel assigned to the UNABOM Squad.

2. In 1995, I was designated the Assistant Special Agent in Charge (ASAC) of San Francisco’s National Foreign Intelligence Program, to include continued management oversight of the UNABOM investigation. As a result of a growing investigative effort, I was designated as the ASAC in charge of the UNABOM Division of the San Francisco office in July, 1995 In that position, I coordinate all investigative efforts of the UNABOM investigation throughout the United States.

[the following paragraphs, relating to physical rather than linguistic evidence, have been omitted]

IV STATEMENT OF PROBABLE CAUSE FOR THEODORE JOHN
KACZYNSKI’S CONNECTION TO UNABOM EVENTS AND
FOR THE SEARCH OF HIS RESIDENCE

A. Identity

95. Beginning on February 14, 1996, David Kaczynski informed members of the UNABOM Task Force (UTF) that he believes his brother Theodore John Kaczynski, also known as "Ted", to be the person responsible for the UNABOM event. David Kaczynski initiated contact with the FBI through an attorney. He stated that he did not want any of the reward money offered in connection with this investigation.

96. Investigation by the UTF has revealed that Theodore John Kaczynski is a white male, 5’9", 150 pounds, with a date of birth of May 22, 1942. He has a Montana driver’s license #342-34-3701 with a listed address as HCR 30, Lincoln, Montana and a mailing address of P.O. Box 524, Lincoln, Montana.

97. A warranty deed dated June 19, 1971 in the County of Lewis and Clark, State of Montana indicates that Clifford Gehring, Sr. sold a 1.4 acre parcel of land with the right of ingress and egress from Stemple Pass to Theodore John Kaczynski and his brother David R. Kaczynski. The property was more particularly described as four miles south of Lincoln, Montana, 1/4 mile east of Stemple Pass Road on Canyon Creek.

B. DNA
98. A postage stamp obtained from the envelope used to mail a copy of the FC manuscript to Dr. Tom Tyler was subjected to DNA analysis by the FBI Laboratory-DNA Section. The results of that analysis were compared to results obtained from the postage stamp and envelope flap of a letter sent by Theodore Kaczynski to his brother David Kaczynski. Based upon the analysis of the DQ alpha (DQA1) and the Polymarker (PM) Loci, the source of the DNA on
the known sample (Theodore Kaczynski’s letter to Dave Kaczynski) is included as a potential contributor to the DNA detected on the stamp from the letter received by Dr. Tyler.

99. The estimated probability expressed as a percentage of selecting an unrelated individual at random from the population having DQA1 type 1.1,2 as detected in these specimens, is approximately 3 percent of Caucasians, 3 percent of Blacks, and 5 percent of Southeastern Hispanics and 2 percent of Southwestern Hispanics.

100. It is noted by your affiant that at least one of the victims previously mentioned an(d) another suspect in the UNABOM investigation (whose identity is known to the UTF) have shared the same DNA Polymarker as Theodore Kaczynski. Because employment records for this person conflicted with known UNABOM events, UTF investigation eliminated this individual as a UNABOM subject.

C. Background

101. Theodore Kaczynski’s brother, David Kaczynski, has informed UTF investigators that he developed a suspicion of Theodore Kaczynski’s (hereafter referred to as Theodore Kaczynski, or as David Kaczynski’s brother if appropriate) involvement in the series of bombings committed by the UNABOM subject after reading news media reports, in approximately December, 1994, that summarized the dates and places of the UNABOM events and bombings.

102. David Kaczynski informed the UTF that he and his brother grew up in Chicago, Illinois (the locale of the first four bombings); his brother had obtained his doctorate from the University of Michigan (the location of a mail bomb victim targeted by the UNABOM subject); his brother had taught at the University of California at Berkeley (the site of two UNABOM bombings); and his brother had lived and worked in Salt Lake City, Utah (the location of
several UNABOM events.)

103. Independent investigation conducted by the UTF revealed that Theodore Kaczynski graduated from Evergreen Park High School in Evergreen Park, Illinois. He also attended Harvard University from 1958-1962, where he obtained a Bachelor of Arts degree in 1962. Theodore Kaczynski attended the University of Michigan at Ann
Arbor, Michigan from 1963-1967, where he earned both his master’s and doctorate.

104. Independent investigation conducted has further revealed that Theodore Kaczynski was employed as an Assistant Professor of Mathematics from July 16, 1967 through June 30, 1969 at the University of California, Berkeley (UCB).

105. David Kaczynski has advised investigators that following his reading of published excerpts from the UNABOM manuscript in approximately August, 1995, he became increasingly suspicious of strong similarities between Theodore Kaczynski’s views and those of the UNABOM subject. He further stated that upon reading the
published UNABOM manuscript in its entirety, in approximately September, 1995, he became convinced that his brother was the author of the UNABOM manuscript. In particular, David Kaczynski stated that there was a unique phrase in the UNABOM manuscript, which referred to a "cool-headed logician" which he, David Kaczynski, recognized as his brother’s terminology. David Kaczynski stated that this and other statements in the UNABOM
manuscript "leapt out" at him because they expressed his brother, Theodore Kaczynski’s, long-held position on the role of art versus science in our society. According to David Kaczynski, these statements marked the UNABOM manuscript as his brother’s product, because he and his brother had a running argument for years on these topic.

106. David Kaczynski advised investigators that he recognized, in particular, a paragraph in the first portion of the manuscript that spoke of art and the human experience. Paragraph 17 of the UNABOM manuscript (attachment 2) discusses art and rationality.

107. David emphasized that his brother has long been committed to "rationality" as a guiding principle. He further stated that since his brother’s ideas were based on a "rational ideal", any action in support of them was justifiable. David Kaczynski expressed his sadness to investigators in commenting that this type of justification would enable his brother to feel fully justified and even visionary in killing people to accomplish his "rational objectives."

D. A Comparative Analysis: Theodore Kaczynski’s Essay and Letters and the UNABOM Manuscript

108. In addition to providing 86 personal letters received from Theodore Kaczynski during the preceding 30 years, David Kaczynski provided investigators with a photocopy of a carbon copy of an essay written by his brother in approximately 1971 (a copy of this essay and incorporated by reference to this affidavit in attachment
number 3). In that essay his brother, Theodore Kaczynski, discusses the necessity of forming and supporting an organization to bring about the end of Federal and corporate funding for scientific research. David
Kaczynski has advised the UTF that his brother personally discussed with him in approximately 1971 the possibility of David heading up such an organization. David stated that he recognized substantial similarity between the ideas, concepts and expressions contained in his brother’s 23 page essay and the UNABOM manuscript.

109. On March 23, 1996, Wanda Kaczynski, Theodore and David Kaczynski’s mother, provided UTF members with a carbon copy of the essay bearing handwritten notations identified by David as Theodore Kaczynski’s handwriting.

110. The affiant has consulted with and reviewed the findings of FBI Supervisory Special Agent James R. Fitzgerald, who has directed the comparative analysis of all of Theodore Kaczynski’s correspondence and documentation in a side-by-side comparison of the UNABOM letters and 56 page manuscript entitled Industrial Society and Its
Future. Through this study SSA Fitzgerald has informed the affiant that the content, context and writing style of Theodore Kaczynski’s 6,374 word, 23-page, essay (attachment 3) and the 34,649 word UNABOM manuscript (attachment 2) are very similar. Some of those similarities are as follows:

111. One of the 47 paragraphs in the 1971 essay, 35 of the paragraphs can be correlated by subject matter with paragraphs in the UNABOM manuscript.

112. The comparative analysis provides over 160 examples of similarities including the following:

Theodore Kaczynski wrote in his 1971 essay (see attachment 3) regarding his objection to Perry London’s view in his book Behavior Control, "I simply find the sphere of freedom that he favors too narrow for me to accept." The UNABOM manuscript states in paragraph 93, "We are going to argue that industrial-technological
society cannot be reformed in such a way as to prevent it from progressively narrowing the sphere of human freedom…." In paragraphs 111, 128 and 133, the UNABOM manuscript contains references to "…narrowing our sphere of …freedom….narrows our sphere of freedom…..invades our sphere of freedom…."

In Theodore Kaczynski’s 1971 essay, he states: "Direct physical control of the emotions via electrodes and ‘chemitrodes’ inserted in the brain." Paragraph 158 of the UNABOM manuscript states: "It presumably would be impractical for all people to have electrodes inserted in their heads."

In Theodore Kaczynski’s 1971 essay, he states: "Various electronic devices for surveillance. These are being used. For example, according to newspaper reports, the police of New York City have recently instituted a system of 24 hour television surveillance over certain problem areas of the city." Paragraph 147 of the UNABOM manuscript states: "…there are the techniques of surveillance. Hidden videocameras are now used to collect and process vast amounts of information."

In Theodore Kaczynski’s 1971 essay, he states: "…Think of all the misery suffered as a result of Victorian repressions, sexual perversions, frigidity, unwanted pregnancies, and venereal disease." Note two of the UNABOM manuscript reads: "During the Victorian period many oversocialized people suffered from serious psychological problems as a result of repressing or trying to repress their sexual feelings."

In Theodore Kaczynski’s 1971 essay, he states: "Propaganda and image-making techniques. In this context we must not neglect the role of movies, television, literature, which commonly are regarded either as art or as entertainment, but which often consciously adopt certain points of view and thus serve as propaganda." Paragraph 73 of the UNABOM manuscript states: "…Propaganda is not limited to ‘commercials’ and advertisements…the content of entertainment programming is a powerful form of propaganda."

In Theodore Kaczynski’s 1971 essay, he states: "…we can assume that people will live more and more in the world of mass entertainment." Paragraph 156 of the UNABOM manuscript states: "…yet mass entertainment is a means of escape and stress-reduction on which most of us have become dependent."

113. There are additional similarities between the writing of Theodore Kaczynski and documents related to the UNABOM events. In a handwritten and undated rough draft written by Theodore Kaczynski provided to the UTF by Wanda Kaczynski on March 23, 1996, Theodore Kaczynski states: "…Modern technology has led to the concentration of economic and political power…by Big Business and Big Government." In note 13 of the UNABOM manuscript, the
UNABOM subject states: "…The conservatives are…exploiting his resentment of Big Government to promote the power of Big Business."

114. Other examples of similarities include the same uncommon (and in the last case inaccurate) spellings of words used in both categories of documents, such as "analyse" versus "analyze"; "wilfully" instead of "willfully"; licence instead of license and "instalment" rather than "installment."

115. A summary of similarities between documents associated with Theodore Kaczynski and documents associated with UNABOM events is contained in attachment 4 to this affidavit. Attachment 4 was prepared by SSA Fitzgerald in this investigation.

116. Many letters written by Theodore Kaczynski to his brother David and mother Wanda discussed his wilderness lifestyle. These discussions of Theodore Kaczynski’s lifestyle are consistent with the description of Theodore Kaczynski’s lifestyle provided to the UTF by David and Wanda Kaczynski, as well as ___ These discussions
of Theodore Kaczynski’s lifestyle are also consistent with reference to the UNABOM manuscript.

117. The following are examples:
In a letter to David Kaczynski dated August 28, 1979, Theodore Kaczynski says: "….by wilderness I meant a place where our nearest neighbor would be 5 miles away…" In paragraph 55 the UNABOM manuscript says: "many nuclear families lived by choice in such isolation; having no neighbors within several miles.

In a letter to David dated November 17, 1982, Theodore Kaczynski says: "…partial destruction of the ozone layer in the atmosphere, which is caused by releases of fluorcarbons…" and in a letter dated September 21, 1988, says: "They predict that in the coming years there will be increasing more drought… because of the greenhouse effect."
Paragraph 169 of the UNABOM manuscript says, "No one knows what will happen as a result of ozone depletion, the greenhouse effect and other environmental problems…"

In a letter to ___ dated July 23, 1984, Theodore Kaczynski writes, "…primitive people…may have had some elaborate process for making edible, as with certain other plants." Theodore Kaczynski refers to the "edibility of the roots" in several letters. Paragraph 198 of the UNABOM manuscript says, "When primitive man needed food he knew how to find and prepare edible roots…

In a letter to David dated August 21, 1981 Theodore Kaczynski writes, "…hunting and gathering wild fruits… killing an animal for its meat." In paragraph 75 of the UNABOM manuscript, "…hunting not for sport…but to get meat that is necessary for food."

E. Further Comparative Analysis Between UNABOM Manuscript and Theodore Kaczynski’s Letters

118. The UNABOM manuscript (attachment 2) specifically refers by title to four books: The Ancient Engineers by L. Sprague DeCamp; Chinese Political Thought in the Twentieth Century, by Chester D. Tan; The True Believer, by Eric Hoffer; and Violence in America: Historical and Comparative Perspectives, by Roger Lane and edited by Hugh Davies Graham and Ted Robert Gurr. In the UNABOM manuscript, Note 16 has quotes from Chapter 12, pages 476-478 of
Violence In America. The UNABOM subject sent a letter and a copy of his manuscript to "Scientific American" on June 24, 1995. The UNABOM subject referenced an article in the August, 1993 issue of "Scientific American" by Russell Ruthen, entitled, "Strange Matters: Can Advanced Accelerators Initiate Runaway Reactions?", and a
July, 1993 article entitled "Risk Analysis and Management," by M. Granger Morgon. The UNABOM manuscript made reference to articles in two magazines, "OMNI" and "Scientific American".

119. In a letter from Theodore Kaczynski to David Kaczynski dated September 2, 1986, Theodore Kaczynski makes reference to "L. Sprague DeCamp’s The Ancient Engineers".

120. In an interview with the FBI on February 17-18, 1996, David Kaczynski advised that the Kaczynski family subscribed to "Scientific American" at least up until the time that he went to college. Moreover, "Scientific American" was around the house and readily available to family members. In Theodore Kaczynski’s application
for admission to Harvard College dated October 22, 1957, question "G" requests the applicant to cite examples of current reading, to include books, magazines and newspapers. Theodore Kaczynski cites "Scientific American" to answer this question. UTF investigators ___ several letters written to __ by Theodore Kaczynski. In one of the letters dated May 26, 1991, Theodore Kaczynski references an article entitled "Aspirin" in the January,1991, issue of "Scientific American."

121. On March 24, 1996, Wanda Kaczynski, Theodore’s mother, provided a letter authored by Theodore dated December 14, 1969, and addressed to the editor of the Chicago Daily News. Paragraph 2 of the letter began, "The stricter gun control laws recommended by the U.S. Commission on Violence are a case in point."

122. The affiant notes that in 1968, President Lyndon Johnson formed a commission to address the growing problem of violence in America. This commission, the National Commission on the Causes and Prevention of Violence, headed by Milton Eisenhower, tasked a group of scholars to research the history and causes of violence in America. One of the members of this Commission was Eric Hoffer. James Q. Wilson, a Harvard Professor, was on the Commission’s Advisory Committee. The scholars produced a report, The History of Violence in America. Historical and Comparative Perspectives which entailed a thorough history of violence in the United States. This report was submitted to the Commission in 1969. Based on this report and others submitted by other groups working for the Commission, the Commission issued a number of recommendations to include the initiation of some sort of Federal gun control. These recommendations were reported in the New York Times during the Summer, Fall and Winter of 1969.
Theodore Kaczynski’s reference to the U.S. Commission on Violence and stricter gun control suggests that he read The History of Violence in America Historical and Comparative Perspectives, another one of the four books referenced by the UNABOM subject in the UNABOM manuscript.

F. Analysis of UNABOM Letters by David Kaczynski

123. During the course of the UNABOM investigation, your affiant has reviewed various interviews of individuals who, for a variety of reasons, have suggested that the UNABOM manuscript was written by a friend, co-worker, or relative. Often the conclusion reached by those individuals was that, in their opinion, the writings of their
friend, co-worker, or relative were similar to that of UNABOM manuscript.

124. David Kaczynski reviewed all of the writings attributed to the UNABOM subject. He came to the conclusion that based upon content, style, and specific phraseology of the writings that they were written by his brother, Theodore Kaczynski.

G. Scholarly Analysis of UNABOM Manuscript

125. Your affiant has reviewed the opinions expressed by a number of scholars and professional educators regarding their own evaluations of the UNABOM manuscript and associated UNABOM correspondence. None of these individuals had access to Theodore’s Kaczynski’s identity as a suspect nor to any of his writings. One individual (whose identity is known to the UTF) contacted the UTF and stated that he is familiar with The Technological Society, by
Jacques Ellul, and that he believed the UNABOM subject has been influenced by this book that was popular in 1964. David Kaczynski advised investigators that around the 1971-72 period, the book by Jacques Ellul, The Technological Society, became his brother’s "bible". In a letter from Theodore Kaczynski to his brother David, postmarked August 21, 1981, Theodore Kaczynski refers to Jacques Ellul and discusses Ellul’s philosophy.

126. Another individual, who is a doctor and a holder of a PhD (whose identity is known to the UTF), contacted the UTF and opined that the UNABOM manuscript was authored by an individual that was very familiar with and even paraphrased ideas from two books, In Defense of Elitism by William A. Henry, III (1994) and Behavioral Control by Perry London (1969). Your affiant notes that Theodore Kaczynski cites Jacques Ellul’s The Technological Society
and Perry London’s Behavioral Control beginning on page 10 of his 23-page essay (attachment 3), and devotes several pages to London’s philosophy. Perry London, on page 128 of his book Behavioral Control refers by name to University of Michigan Professor James McConnell. Professor McConnell was injured by a UNABOM mail bomb that was mailed from Salt Lake City, Utah, on November 12, 1985.

[rest of affidavit omitted]

230. Based upon the facts presented herewith, your affiant has reason to believe that there is probable cause to search the premises belonging to, owned by, and/or under the control of, Theodore John Kaczynski, and therefore request that a warrant be issued authorizing a search for the aforementioned items of evidence related to the violations mentioned herein.

/s/
Terry D. Turchie
Assistant Special Agent in Charge
Federal Bureau of Investigation

SWORN AND SUBSCRIBED TO BEFORE ME THIS 3RD DAY OF APRIL, 1996

/s/
United States District Judge

United States District Court
District of Montana