CANADA C.R.

441654
NOVA SCOTIA
COUNTY OF HALIFAX

IN THE SUPREME COURT OF NOVA SCOTIA

BETWEEN:
HER MAJESTY THE QUEEN

-and-

LINDSAY KANITHA SOUVANNARATH

AGREED STATEMENT OF FACTS

Pursuant to section 724 of the Criminal Code, the parties agree to the following facts:

[1] Lindsay Souvannarath was born in Chicago, Illinois on January 9, 1992. She is a citizen of
the United States of America. She is currently 26 years old. She has been in custody awaiting
disposition of these charges since her arrest on February 13, 2015.

[2] At the time of her arrest, she was 23 years old. She lived with her mother and father in
their family home located in Geneva, Illinois, a suburb of Chicago. She graduated from college
in 2014, and was unemployed at the time of the events in question.

[3] Souvannarath spent much of her time on the internet. She was active on a variety of
social media platforms including Tumblr, Facebook, and Skype. While online, she frequently
posted or shared materials that were racist in nature, promoted Nazism, and/or glorified
violence and death. Souvannarath had a Tumblr blog, entitled “Cockswastika”, showing a
Swastika emblem along with a sub-title, “School Shooter Chic”.

[4] She developed a fascination with the Columbine high school massacre. Her admiration
of Columbine quickly became a powerfully unifying factor between her and James Gamble.
[5] James Gamble was born in Halifax, Nova Scotia on August 6, 1995.

[6] At the time of his death on February 12, 2015, he was 19 years old. Gamble also lived at
home with his parents, was unemployed, and spent much of his time on the internet. He too
was active on a variety of social media platforms including Facebook, Tumblr and Reddit. Like
Souvannarath, much of the material he shared or posted online glorified death and violence.
Gamble had a Tumblr blog entitled, “Shallow-existences”, the main image of which is a short
repeating video of footage taken from the Columbine high-school cafeteria while Eric Harris and
Dylan Klebold were committing their massacre.

[7] Randall (aka Randy) Shepherd was born in Victoria, British Columbia on July 4, 1994.

[8] At the time of his arrest on February 13, 2015, Shepherd was 20 years old. Shortly after
his birth, he and his family moved to Halifax, Nova Scotia. He experienced a strained
relationship with his family in the years prior to the events in question, had poor employment
options, and had several failed romantic relationships. Shepherd had a Tumblr blog entitled,
“GenesistoGenocide”, a blog which featured mostly the glorification of heavy metal music,
serial/mass killers, gore and pornography.

[9] Gamble attended Sir John A. MacDonald High School in Tantallon, Nova Scotia, located a
short distance outside of Halifax, Nova Scotia. It is there he met Shepherd.

[10] Gamble and Shepherd had few other friends in high school. Shepherd, who had been
home-schooled, found it hard to socially-integrate. Gamble struggled with a diagnosed social
anxiety disorder. The two bonded over heavy metal music, gore/horror movies, marijuana and
a shared fascination with death and morbidity, often focusing on school shootings and mass
murders.

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[11] In the time leading up to the events in question, both Gamble and Shepherd were
having increasing difficulties. Shepherd became more despondent and suicidal. Gamble too
was spiraling, first into suicidal thoughts, and then towards homicidal ideation. He became
increasingly obsessed with school shootings and other mass killing sprees. He shared these
thoughts and ideas with Shepherd.

[12] As time passed, Gamble considered committing a mass killing in Halifax. Gamble asked
Shepherd to be his partner in such a crime. Shepherd resisted, but offered a receptive audience
to Gamble’s plans.

[13] In December of 2014, Gamble began to “follow” Souvannarath’s Tumblr blog,

“Cockswastika” from his own “shallow-existences” Tumblr blog. It is unclear how exactly
Gamble came to know of the existence of Souvannarath’s blog.

[14] Quickly thereafter, Souvannarath and Gamble began to communicate over Facebook, a
conversation which began on December 21, 2014.

(a) The Facebook Messages between Souvannarath and Gamble: December 21, 2014 to
February 13, 2015.

[15] After Ms. Souvannarath’s arrest on February 13, 2015, the Kane County Court in the
state of Illinois ordered Facebook Inc. to produce the chatlogs from Ms. Souvannarath’s
Facebook account.

[16] The electronically formatted chatlogs submitted to this Court by the Crown is a true and
accurate representation of the chat logs produced by Facebook as a result of the Kane County
Court Order.
[17] The bound paper volumes marked “Facebook Chat Logs” exhibited by the Crown were
prepared by the Crown for ease of review. They are copied from the original electronic format
and are believed to be accurate, but are not certified.

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[18] Apart from some postings on each other’s Tumblr blogs, the Facebook messages appear
to be the sole means of communication between Souvannarath and Gamble, and thus is a near
complete capture of their relationship. There is no evidence suggesting they communicated
over the telephone or through other electronic means such as Skype or FaceTime.

[19] The Facebook conversation reflects approximately 7.5 weeks of communication that
occurred every day during this time-period, often for hours at a time.

(b) The Evolution of the Relationship between Souvannarath and Gamble

[20] Gamble and Souvannarath bonded quickly.

[21] They immediately discovered a shared interest and admiration for the Columbine
massacre.

[22] Souvannarath and Gamble repeatedly stated that they were adopting the personas of
Eric Harris and Dylan Klebold, respectively. They would often refer to each other by the
nicknames of Harris (Reb) and Klebold (VoDKa). Like Harris and Klebold, Souvannarath and
Gamble would speak of going “NBK” – a short-hand for “natural born killers” – which, as used
by the Columbine shooters, was used to describe their intended massacre. They would quote
passages to each other from the publicly-accessible journals of Harris and Klebold.

[23] Apart from Columbine, a review of the Facebook conversation reveals the following
about the relationship between Gamble and Souvannarath which is non-exhaustive:

 Their relationship was sexual and the pair often exchanged explicit intimate photographs
of each other while ‘sexting’. They confided in each other that they were both virgins.
They desired to have sex the night before the massacre.

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  They expressed a shared connection to one another, a connection they had not felt
before. They felt deeply fated to one another.

 The pair perceived Souvannarath as more intelligent, more well read, and more easily
able to expound upon her views and collection of ideologies.

 They idolized past mass/serial killers, in addition to Klebold and Harris.

 They both wanted to commit a mass or spree-killing and quickly agreed to be partners.

 They believed their destiny was to commit this massacre.

 They both expressed enthusiasm for the pain/death they were going to cause.

 They both deeply desired to achieve infamy and notoriety through the mass killing of
others.

 They enjoyed speculating at the shock, wondering, pain, and confusion their event
would bring.

 They reveled in thinking about the pain and anguish their families would feel at their
horrendous acts.

 They hoped their massacre would inspire others to do the same.

 They, especially Souvannarath, believed they were racially and intellectually superior.

 They, especially Souvannarath, endorsed Nazism.

 They both were content to die. They both expressed being at peace with their life
ending together in suicide.

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  Souvannarath’s motivations were many and various. Souvannarath expressed her belief
that she is a sex goddess with superior intellect who is entitled to cull the inferior. She
also commented that she is a warrior in a world in which racial and ethnic realities must
be righted through violence. She commented that committing a mass killing would
punish the popular and hurt those who never understood her. She expressed the desire
to be infamous.

(c) The Nature and Details of the Intended “Valentine’s Day Massacre”

[24] After agreeing to commit a mass-killing, preparations began. This entailed careful
consideration and discussions which are thoroughly revealed in their Facebook messages. In
the end, the plan, which the pair nicknamed “Der Untergang” (The Downfall), was settled upon
as follows:

 The mass-killing was to take place on February 14 th, “Valentine’s Day” in the food court
at the Halifax Shooting Centre.

 The mall was ultimately chosen as they felt it would result in “mass panic.”

 Souvannarath was to travel by air to Halifax to meet with Gamble on February 13th.

 Gamble planned to shoot both of his parents before Souvannarath arrived.

 Gamble and Souvannarath would spend the night in the Gamble residence and sexually
consummate their relationship.

 Randy Shepherd hoped to be shot and killed by Gamble on the 13 th as a form of assisted-
suicide that same evening. Souvannarath was not a part of this aspect of the plan.

 The following day the massacre was to begin in the food court, an area they believed
would provide them the best cover.

 The pair intended to precede the shooting by throwing Molotov cocktails.

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  Gamble intended to arm himself with his father’s lever-action hunting rifle as well as a
hunting knife.

 Souvannarath would be armed with Gamble’s father’s single-action 16-gauge shotgun.

 Each was to wear their previously selected “death outfits”; outfits chosen in many ways
to pay tribute to Harris and Klebold. These outfits included masks.

 The pair intended to shoot as many people as their ammunition allowed.

 The pair intended to reserve their final bullets for themselves, as a means of ensuring
their joint-suicides.

 They planned to kneel facing each other, killing themselves on the count of three.

 They planned to have queued social media posts on Tumblr, scheduled to go live on
February 15, boasting about a “mass shooting in Halifax”.

(d) The Involvement of Randy Shepherd

[25] Shepherd was kept informed of the evolving plan between Souvannarath and Gamble.
He encouraged it. In February of 2015, Shepherd and Gamble went to the Halifax Shopping
Centre and filmed videos of where the attack was to occur.

[26] These videos were noted by the pair to be “basement tapes”, a reference to the
preparatory video recordings made by the two Columbine shooters designed to memorialize the
planning of the attack and enhance its notoriety.

[27] While Shepherd was not agreeable to raising a weapon alongside Gamble and
Souvannarath, he did purchase a hacksaw and materials needed to make the Molotov cocktails
for use in the massacre. Additionally, he offered to pick-up Souvannarath from the airport.

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 (e) February 12, 2015

[28] In the days leading up to February 12, 2015, Souvannarath obtained sufficient funds to
enable her to purchase a one-way ticket from Chicago to Halifax. On the morning of February
12, 2015, she snuck out of her family home and took a train to Chicago O’Hare Airport before
boarding her flight to Halifax.

[29] On the same day, Gamble faced delays in his plan to murder his parents. He sent a
Facebook message to Souvannarath that "I'm going to have to wait until tomorrow to kill them"
and "you'll have to stay at Randy's for the night".

[30] On this same day, an anonymous tip was received by Crime Stoppers.
Detective/Constable Kristopher Barr of the Halifax Regional Police was assigned to investigate.

[31] The following is a summary of the tip:

a. Two suspects are posting on different social media sights that they plan to shoot up
the mall in Halifax, Nova Scotia on 02-14-15;
b. The two suspects are obsessed with school shootings;
c. The female suspect is to leave Chicago, Illinois on 02-12-15, on a Delta Airlines flight to
Halifax International Airport, Nova Scotia, Canada, and meet up with the male suspect
who has weapons for them to use;
d. The first suspect is an Asian female, known as Lindsay, last name unknown but begins
with "S", she is approximately twenty-three years old, born 01 -16-92 and is 5'3" tall and
weighs 90 Ibs. Lindsay has black shoulder length hair, which is dyed red right now and
she wears brown framed glasses;
e. Lindsay is friends with the male suspect James Gamble;
f. Lindsay has several social media names under a Facebook account under the name of
"Lindsay Shub-Niggurath", Tumbler account under 'Cockswastika" and Skype account
under "thenewheresy";

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 g. The male subject is known as James Gamble, a Caucasian male, nineteen years old,
born 08-06-95, and is described as very skinny with dark brown hair parted to one side;
h. James Gamble lives in Halifax, Nova Scotia;
i. The anonymous source has not met James Gamble in person;
j. James Gamble is Lindsay's friend from online;
k. James Gamble has several social media names under a Facebook account under the
name "James Gamble" and a Tumbler account under the name of "shallowexistences";

[32] Investigators contacted the Canadian Border Services Agency (“CBSA”) who issued a
national lookout to their agents to identify anyone who may match the description of the
“Lindsay S” spoken of in the tip.

(f) The Suicide of James Gamble

[33] The investigation quickly led officers to attend the Gamble residence in Timberlea, Nova
Scotia. Officers surrounded the home and sought to make contact with Gamble. His parents
confirmed that he was inside the residence. Officers called Gamble by telephone and requested
that he exit the home to speak with police. Gamble agreed, but failed to do so. Instead, he
committed suicide by shooting himself in the head with a single bullet from his father’s hunting
rifle, one of the two firearms intended for use in the attack at the Halifax Shopping Centre.

(g) Souvannarath Arrives in Halifax

[34] At the time Gamble killed himself, Souvannarath was on the last leg of her journey into
Halifax.

[35] Prior to leaving for Halifax, she had an online conversation with a friend from Skype
which included the following exchange:

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 Lindsay Souvannarath: “I’ve purchased the plane ticket. I’m leaving for
Canada tomorrow, and the only way I’m coming back is in a body bag.
Wish me luck.”

Skype Friend: “Christ...Are you 100% sure”

Lindsay Souvannarath: “Yes”

Friend: “well… I’ll be honest and say that I hope you dont do it but I
guess you do whatever you want you’re not going to listen to me or
anything”

Lindsay Souvannarath: “This is what I was meant to do my whole life…

I’ve had so many revelations this past month and a half”

Friend: “I guess…I dunno man”

Lindsay Souvannarath: “it’s hard to understand, I know. But once it

happens, once the chatlogs and the videos we’re going to record have
been released, everything will be explained. How much sense it’ll all
make, I don’t know, but whatever happens happens”

Friend: “but I just hope you reconsider I guess though I highly doubt it”

Lindsay Souvannarath: “Yeah, I’ve been keeping a lot of things just

between him and me in the first place, so I don’t expect it to make much
sense right now…But it goes like this: I want to kill, he wants to die. Just
like Eric and Dylan.”

(h) Shepherd Goes to Pick-Up Souvannarath at the Airport

[36] As previously offered by him, Shepherd attended the Stanfield International Airport by
city bus to pick up Souvannarath.

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[37] Shepherd communicated with Souvannarath and advised that Gamble was behind
schedule (referring to the fact that Gamble had not yet had an opportunity to kill his parents)
and that she would have to stay with him for the night.

(i) Souvannarath Detained by the CBSA

[38] Souvannarath landed at midnight in Halifax. At 12:10am on February 13, 2015, she
presented herself to primary immigration and spoke to a CBSA agent. For unknown reasons,
the national lookout, previously put in place by the CBSA, did not raise a flag at that time.

[39] Nevertheless, the CBSA agent who processed Souvannarath was concerned by her.

[40] The officer was concerned that Souvannarath may have been attempting to bring drugs
into Canada. His concerns revolved around the fact that she advised him that she flew to
Canada on a one-way ticket, had only $33.00, and did not know where her boyfriend, James
Gamble, lived. The officer noted “she had very bad teeth and her complexion was very bad with
sores on her face. This made me think she may be on drugs (crystal meth/crack cocaine).”

[41] The officer directed Souvannarath to a secondary Immigration examination as well as a

secondary Customs inspection.

[42] Souvannarath was questioned at secondary Immigration by Tracey Eisener. Ms. Eisener
questioned Ms. Souvannarath and confirmed that she did not know where she was going, had a
small amount of money, and did not have a return ticket to Chicago. Ms. Souvannarath
indicated that she was in Halifax to spend a “memorable” Valentine’s weekend with her
boyfriend, James Gamble, who she had previously met online. She further advised that Randy
Shepherd was at the Airport to pick her up, this was subsequently confirmed by CBSA officials.

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[43] The contents of Souvannarath’s luggage were subjected to inspection. Ms.
Souvannarath had little with her, aside from some make-up, her “death outfit”, and two books
on serial killers.

(j) CBSA Notify the Police that they have “Lindsay S” in Custody

[44] While Souvannarath was being dealt with by CBSA agents, officials reviewed the
previously issued national lookout. They determined that Souvannarath may be the person of
interest. The police were contacted and advised that Souvannarath was in the custody of the
CBSA and that Randy Shepherd was in the waiting area.

[45] Upon arrival at the Airport, police quickly arrested both Shepherd and Souvannarath
without incident. Souvannarath was arrested at 1:25 a.m. on February 13, 2015.

[46] Souvannarath was detained and held for Court.

(k) Post-Arrest

[47] Since her arrest, Souvannarath has affirmed that it was her intention to commit a
“Valentine’s Day Massacre” in Halifax.

[48] On February 17, 2015, while being transported for court purposes, Souvannarath had
the following exchange with an undercover officer posing as a fellow prisoner in a transport
van:

Lindsay Souvannarath: I love that shirt so much 'cause it looks like something Eric
Harris would wear.
Undercover Officer: (laughs)
Lindsay Souvannarath: And - yeah, we were - .

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 Undercover Officer: And Eric Harris is?
Lindsay Souvannarath: Uh, one of the Columbine shooters.
Undercover Officer: Okay, that's what I thought. I didn't know his last name,
but I thought I remembered Eric.
Lindsay Souvannarath: Yeah. And so I would be Eric, and he would be Dylan.
Undercover Officer: (laughs) You had that all figured out, huh?
Lindsay Souvannarath: Yeah. We'd planned this a long time ago. (laughs)
Undercover Officer: Oh yeah?
Lindsay Souvannarath: Mmm.
Undercover Officer: How long ago?
Lindsay Souvannarath: Urn, we started planning things in, like, December. Like,
somewhere around Christmas. Oh yeah, and I also had a
skull mask that I was going to wear, and he had his scream
mask.
Undercover Officer: (laughs) You guys were going to wear masks?
Lindsay Souvannarath: Yeah!
Undercover Officer: Hey, go big or go home, eh?
Lindsay Souvannarath: Yeah. We would have looked so perfect.
…
Lindsay Souvannarath: Uh-huh. 'Cause I have no idea how I'm going to go home
and tell my parents, hey mom and dad, me and this guy I
met on the internet - we had plans to shoot up a mall and
then kill ourselves.
Undercover Officer: (laughs) Oh shit!
Lindsay Souvannarath: Yeah.
Undercover Officer: You mean you were going to do something like that?
Lindsay Souvannarath: Yeah!
Undercover Officer: Oh!
Lindsay Souvannarath: That's what we were planning.
Undercover Officer: Fuck, I thought you just wanted to kill yourself.
Lindsay Souvannarath: No, more than that.
Undercover Officer: Holy shit.
Lindsay Souvannarath: Yeah. It was going to be a Valentine's Day massacre.

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 Undercover Officer: Yeah, I guess, huh? Fuck. You guys really thought about
everything.
Lindsay Souvannarath: Yeah.

[49] On March 13, 2015, an officer at the Central Nova Scotia Correctional Facility found the
following note written on the back of a Sudoku puzzle in the cell of Lindsay Souvannarath:

It is a strange feeling to meet someone and almost immediately know that

you ought to die with them. To James and I, it happened simultaneously.
At first we were casual acquaintances having discovered each other’s
Tumblr blogs through a mutual interest in the Columbine shooting and in
National Socialism. Less than a month later, we were planning our deaths.
I was to be his Eric Harris, and He would be my Dylan Klebold. We trusted
each other instantly, behaving as if we’d known each other for years. “We
must have known each other in a past life,” I said, half-jokingly. Eventually
I realized that we really were Eric and Dylan, their minds having taken
refuge in our bodies some time after their demise in 1997”

SIGNED at Halifax Nova Scotia on April , 2018.

______________________________________
Luke Craggs, counsel for Lindsay Souvannarath

______________________________________
Mark Heerema, Crown Counsel

_________________________________
Shauna MacDonald, Crown Counsel

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