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Page 1 of 7
v.
United
States
of
America,
by
and
through
its
Obstruction
of
Exercise
of
Religion
by
Force
2:15-cr-00472-RMG
The
United
States
proposes
to
prove
Page 2 of 7
the
following
13-21
and
25-33
(except
where
other
Counts
are
specified):
(A) DYLANN STORM ROOF was 18 years of age or older at
the time of the offense.
(B) Statutory
Threshold
Factors
Enumerated
under
18
U.S.C. 3591(a)(2)(A)-(D).
(1) Intentional
Killing.
intentionally
killed
DYLANN
Reverend
Coleman-Singleton,
Cynthia
Jackson,
Lance,
Ethel
Lee
STORM
ROOF
Sharonda
Hurd,
Susie
Reverend
DePayne
Infliction
DYLANN
STORM
of
ROOF
Serious
Bodily
intentionally
2:15-cr-00472-RMG
Reverend
Daniel
Simmons,
Page 3 of 7
Sr.,
and
Myra
DYLANN
STORM
ROOF
intentionally
person,
participants
Sharonda
Susie
the
than
one
offense,
and
Coleman-Singleton,
Ethel
Lee
Middleton-Doctor,
Pinckney,
Simmons,
direct
in
Jackson,
DePayne
other
Tywanza
Sr.,
result
and
of
Sanders,
Myra
such
of
the
Reverend
Cynthia
Hurd,
Lance,
Reverend
Reverend
Clementa
Reverend
Thompson
action.
died
18
Daniel
as
U.S.C.
3591(a)(2)(C).
(4) Intentional Engagement in Acts of Violence,
Knowing that the Acts Created a Grave Risk of
Death
to
Person.
DYLANN
STORM
ROOF
2:15-cr-00472-RMG
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Coleman-Singleton,
Jackson,
DePayne
Lee
Middleton-Doctor,
Pinckney,
Simmons,
direct
Ethel
Tywanza
Sr.,
result
Sanders,
and
of
Myra
such
Cynthia
Hurd,
Lance,
Reverend
Reverend
Clementa
Reverend
Thompson
action.
died
18
Daniel
as
U.S.C.
3591(a)(2)(D).
(C) Statutory Aggravating Factors Enumerated under 18
U.S.C. 3592(c).
(1) Multiple
Killings.
DYLANN
STORM
ROOF,
in
13-21
and
25-33
after
substantial
2:15-cr-00472-RMG
Page 5 of 7
to
Incite
Violence.
In
preparation
Impact.
DYLANN
STORM
ROOF
caused
co-workers
of
those
individuals.
The
2:15-cr-00472-RMG
Page 6 of 7
endangered
the
persons
in
addition
murders
charged
in
safety
to
of
the
the
one
or
victims
Indictment
more
of
the
in
the
expressed
hatred
and
contempt
towards
of
men
Victims.
and
DYLANN
women
STORM
participating
ROOF
in
of
Remorse.
DYLANN
STORM
ROOF
2:15-cr-00472-RMG
Page 7 of 7
Respectfully submitted,
s/ Julius N. Richardson
JULIUS N. RICHARDSON (ID #9823)
NATHAN WILLIAMS
Assistant United States
Attorneys
1441 Main Street, Suite 500
Columbia, SC 29201
(803) 929-3000