Suspect Accused in Oregon Jihad Training Plot Extradited from Czech Republic by IPT IPT News September 26, 2007 http://www.investigativeproject.org/article/489 Oussama Kassir, a Lebanese-born Swedish citizen wanted in the U.S. on charges of plotting to set up a jihad training camp, was extradited Sept. 25 from the Czech Republic. Kassir was arrested on Dec. 11, 2005, in Prague by Czech officials while flying from Stockholm to Beirut. The arrest was based on a complaint <http://www.investigativeproject.org/documents/case_docs/506.pdf> filed in Manhattan federal court that alleged Kassir conspired with Mustafa Kamel Mustafa (a/k/a Abu Hamza al-Masri), Haroon Rashid Aswat, and others, to establish a jihad training camp in Bly, Oregon. The camp was to provide Muslims with military-style training to fight jihad or to receive further jihad training in Afghanistan. Al-Masri, a Muslim cleric who preached at the Finsbury Park in north London, was sentenced by a UK court to seven years in prison in Feb. 2006 for stirring up racial hate and inciting followers to kill non-Muslims. Aswat, a British-born citizen of Indian descent is alleged to have masterminded the July 7 London bombings. Aswat, believed to be an al Qaeda operative, was arrested in Zambia in July 2005 and deported to Britain. Both al-Masri and Aswat face extradition to the US on charges relating to setting up the training camp and providing aid to al Qaeda. Al-Masri is further charged with conspiracy relating to hostage taking in Yemen, facilitating violent jihad in Afghanistan, and supplying services to the Taliban. According to a new indictment <http://www.investigativeproject.org/documents/case_docs/507.pdf> returned by a federal grand jury in New York on Sept. 25, Al-Masri sent Kassir and Aswat to the US in late 1999 to set up the training camp in Oregon. In remarks <http://www.investigativeproject.org/documents/case_docs/508.pdf> at a news conference announcing Kassir's extradition, Michael Garcia, U.S. Attorney for the Southern District of New York, alleged that Kassir discussed hijacking trucks and killing the drivers to raise money to support the camp. Kassir and Aswat left the US after spending two months in Oregon. Kassir allegedly complained that there were only a handful of men available to train and he was not going to waste his time on such a small number of individuals, a Department of Justice news release said. The training camp was eventually abandoned. Kassir, who is believed to have undertaken jihad training in Afghanistan, Kashmir, and Lebanon, is also accused of setting up terrorist websites offering bomb and poison-making tips as well as information on the use of firearms. Kassir allegedly posted manuals such as "The Mujahideen Explosives Handbook" and "The Mujahideen Poisons Handbook" on the websites. An alleged bin Laden supporter, Kassir bragged to a Seattle newspaper in Sept. 2002, "I love al Qaeda" and "I love Osama bin Laden." Kassir however denied that during his arraignment Sept. 25 at Manhattan Federal Court. "I have nothing to do with al Qaeda," Kassir said. He pleaded not guilty to all counts. He repeatedly spoke out during his arraignment, blurting out "Why does he lie?" as a federal prosecutor discussed the case. U.S. District Judge John Keenan told Kassir to keep quiet. "You're in America now, in an American courtroom," the judge said. "You have to abide by American rules." Kassir faces life imprisonment if convicted on all counts. _____ UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK -X UNITED STATES OF AMERICA -v. - INDICTMENT MUSTAFA KAMEL MUSTAFA, S2 04 C r . 356 (JFK) a/k/a "Abu Hamza, " a/k/a "Abu Hamza al-Masri , " a/k/a "Mustafa Kamel," a/k/a "Mostafa K a m e l Mostafa, ": OUSSAMA ABDULLAH KASSIR, a/k/a "Abu Abdullah," a/k/a "Abu Khadi ja, " and HAROON RASHID ASWAT, a/k/a "Haroon, " a/k/a "Haroon Aswat, " Defendants. COUNT ONE CONSPIRACY TO TAKE HOSTAGES (THE ATTACK IN YEMEN) The Grand J u r y charges: 1. ~ r o m on or about December 23, 1998, up t o and including on or about December 29, 1998, i n an offense begun out of the j u r i s d i c t i o n of any p a r t i c u l a r S t a t e o r d i s t r i c t , MUSTAFA KAMEL MUSTAFA, a/k/a "Abu Hamza, " a/k/a "Abu Hamza al-Masri, " a/k/a "Mustafa Karnel," a/k/a "Mostafa Karnel Mostafa," the defendant, and others known and unknown, a t l e a s t one of whom'was f i r s t brought t o - - - , ' and a r r e s t e d i n the Southern District of New York, u n l a w f u l l y and knowingly combined, conspired, confederated and agreed together and with each other to violate Section 1203 of Title 18, United States Code. 2. It was a part and an object of the conspiracy that MUSTAFA KAMEL MUSTAFA, the defendant, and others known and unknown, - : would and did, inside and outside the United States, unlawfully and knowingly seize and detain and threaten to kill, to injure, and to continue to detain other persons, including two U.S. nationals, in - order compel a third person and a governmental organization, wit, the government of Yemen, to do and abstain fxom doing any act explicit and implicit condition for the release the persons detained. Overt Acts 3. In furtherance of said conspiracy, and to effect the illegal object thereof, the following overt acts, among others, were committed: , .. a. In or about late 1998, MUSTAFA KAMEL MUSTAFA, the defendant, provided a co-conspirator not named as a defendant herein- ("Co-Conspirator I"), the leader of the Abyan faction of the Islamic Army of den, and a group of co-conspirators not named as defendants herein (hereafter, the "hostage-takers") with a satellite phone. b. On or about December 27, 1998, MUSTAFA KAMEL MUSTAFA, the defendant, received three telephone calls at his home from the satellite phone he had previously provided to the hostage- - - - takers. c. On o r about December 28, 1998, the hostaget a k e r s stormed a c a r a v a n of s p o r t u t i l i t y v e h i c l e s carrying s i x t e e n Western t o u r i s t s and took t h e t o u r i s t s h o s t a g e - b y u s e of force. d . On o r about December 28, 1998, MUSTAFA KAMEL- .- MUSTAFA, t h e d e f e n d a n t , spoke t o Co-Conspirator 1 on t h e s a t e l l i t e phone a f t e r the h o s t a g e - t a k i n g was a l r e a d y underway. During t h a t t e l e p h o n e call, MUSTAFA KAMEL MUSTAFA, t h e d e f e n d a n t , a g r e e d t o a c t as an i n t e r m e d i a r y f o r Co-Conspirator 1 and t h e h o s t a g e - t a k e s s , and gave Co-Conspirator 1 c e r t a i n a d v i c e r e l a t e d t o t h e h o s t a g e - t a k i n g . e. On or about December 29, 1998, a f t e r t h e h o s t a g e - t a k i n g was underway, MUSTAFA KAMEL MUSTAFA, t h e d e f e n d a n t , = o r d e r e d f i v e hundred B r i t i s h pounds worth of a d d i t i o n a l a i r t i m e f o r t h e s a t e l l i t e phone b e i n g used by t h e h o s t a g e - t a k e r s . f . On o r about December 29, 1998, t h e Yemeni m i l i t a r y a t t e m p t e d t o r e s c u e t h e h o s t a g e s . During t h 9 r e s c u e a t t e m p t , t h e h o s t a g e - t a k e r s used t h e h o s t a g e s as human s h i e l d s and a t t e m p t e d t o f i g h t o f f t h e Yemeni m i l i t a r y . Although t h e m i l i t a r y u l t i m a t e l y overpowered t h e h o s t a g e - t a k e r s , during t h e r e s c u e a t t e m p t f o u r of the h o s t a g e s were k i l l e d and s e v e r a l o t h e r s wounded. ( T i t l e 18, United S t a t e s Code, S e c t i o n 1203.) COUNT m HOSTAGE-TAKING (THE ATTACK IN YEMEN) The Grand Jury further charges: - * 4 - From on or about December 23, 1998, up to and including on or about December 29, 1998, in an offense begun out of the jurisdiction of any particular State or district, MUSTAFA KAMEL MUSTAFA, a/k/a "Abu Hamza," a/k/a "Abu Hamza al-Masri," a/k/a "Mustafa Kamel," a/k/a "Mostafa Kamel Mostafa," the defendant, and . others known and unknown, at least one of whom was first brought to and arrested in the Southern District of New York, unlawfully and knowingly, inside and outside the ~ n i t ' e d States, did seize and detain and threaten to kill, to injure, and to continue to detain other persons, including two U.S. nationals, in order to compel a third person and a governmental organization, to i t , the government of Yemen, to do and abstain from doing any act as an explicit and implicit condition for the release of the persons detained. (Title 18, United States Code, Sections 1203 and 2.) COUNT THREE CONSPIRACY TO PROVIDE AND CONCEAL MATERIAL SUPPORT AND RESOURCES TO TERRORISTS (THE BLY, OREGON JIHAD TRAINING CAMP) The Grand Jury f u r t h e r charges: 5. From i n o r about October 1999, up t o and including i n or about e a r l y 2000, in the Southern D i s t r i c t of New York and elsewhere, MUSTAFA KAMEL MUSTAFA, a/k/a "Abu Hamza, " a/k/a "Abu Hamza a1-Masri," a/k/a "Mustafa Kamel," a/k/a "Mostafa Kame1 Mostafa, " OUSSAMA ABDULLAH KASSIR, a/k/a "Abu Abdullah, " a/k/a "Abu Khadi ja, " and HAROON RASHID ASWAT, a/k/a "Haroon, " a/k/a "Haroon Aswat," the defendants, and others known and unknown, a t l e a s t one .of whom was f i r s t brought t o and a r r e s t e d i n the Southern ~ i s t r i c t of New York, unlawfully and knowingly combined, conspired, confederated and agreed together and with each other t o v i o l a t e Section 2339A of T i t l e 18, United S t a t e s Code. 6. It was a p a r t and an object of the conspiracy t h a t MUSTAFA KAMEL MUSTAFA, OUSSAMA ABDULLAH KASSIR, and HAROON RASHID ASWAT, the defendants, and others known and unknown, would and did, within the United states, provide m a t e r i a l support and resources and conceal -and d i s g u i s e the nature, l o c a t i o n , source, and ownership of m a t e r i a l support and resources, knowing and intending t h a t they were t o be used i n preparation f o r , and in carrying out, a v i o l a t i o n of Section 956 of T i t l e 18, United S t a t e s Code (conspiring t o k i l l , kidnap, maim, and i n j u r e persons and t o damage and destroy property i n a foreign country), and i n preparation f o r , and i n c a r r y i n g o u t , t h e concealment and an e s c a p e from t h e commission of such v i o l a t i o n . Overt Acts 7. I n f u r t h e r a n c e of s a i d c o n s p i r a c y , and t o e f f e c t t h e - -* i l l e g a l a b j e c t t h e r e o f , t h e following o v e r t acts, among o t h e r s , were committed i n t h e Southern District of New York and e l s e w h e r e : a. On s e v e r a l o c c a s i o n s i n ox about October 1999, MUSTAFA KAMEL MUSTAFA, t h e d e f e n d a n t , d i s c u s s e d with a coc o n s p i r a t o r not named as a defendant herein ("Co-Conspirator 2 " ) , a U.S. c i t i z e n , t h e c r e a t i o n of a j i h a d t r a i n i n g camp i n Bly, Oregon. During t h e s e d i s c u s s i o n s , Co-Co.nspirator 2 asked MUSTAFA 3KAMEL MUSTAFA, t h e d e f e n d a n t , t o send two of MUSTAFA KAMEL MUSTAFAfs f o l l o w e r s to t h e United S t a t e s i n o r d e r t o a s s i s t Coc o n s p i r a t o r 2 i n r a i s i n g money and e s t a b l i s h i n g t h e Bly, Oregon j i h a d t r a i n i n g camp. b. On o r about October 25, 1999, Co-Conspirator 2 communicated t o MUSTAFA KAMEL MUSTAFA, the d e f e n d a n t , t h a t he and o t h e r c o - c o n s p i r a t o r s not named as d e f e n d a n t s h e r e i n were s t o c k - p i l i n g weapons and ammunition i n t h e United S t a t e s . Co-Conspirator 2 a l s o communicated t o MUSTAFA KAMEL MUSTAFA, t h e d e f e n d a n t , t h a t Co-Conspirator 2 was " e x p e c t i n g t h e two b r o t h e r s t h a t w e d i s c u s s e d t o come i n November." c. I n o r about l a t e October 1999 or e a r l y November 1999, MUSTAFA KAMEL MUSTAFA, t h e d e f e n d a n t , a s k e d OUSSAMA ABDULLAH - -- . KASSIR and HAROON RASHID ASWAT, t h e d e f e n d a n t s , t o t r a v e l from London t o the United S t a t e s i n order t o a s s i s t with e s t a b l i s h i n g the Bly, Oregon jihad t r a i n i n g camp. Prior t o t h e i r departure, MUSTAFA KAMEL MUSTAFA, the defendant, gave OUSSAMA ABDULLAH KASSIR and HAROON U S H I D ASWAT, the defendants, approximately four" - - thousand B r i t i s h Pounds t o pay for expenses incurred w h i l e e s t a b l i s h i n g t h e Bly, Oregon jihad t r a i n i n g camp. d. On November 26, 1999, OUSSAMA ABDULLAH KASSIR and HAROON RASHID ASWAT, t h e defendants, a r r i v e d i n the United S t a t e s a t John F. Kennedy I n t e r n a t i o n a l Airport i n New York. From New York, OUSSAMA ABDULLAH KASSIR and HAROON RASHID ASWAT, the defendants, traveled by bus t o S e a t t l e , Washington, and then by car . t o Bly, Oregon, in order to help e s t a b l i s h t h e Bly, Oregon jihad t r a i n i n g camp, as requested by MUSTAFA KAMEL MUSTAFA, the defendant. e. In or about December 1999, OUSSAMA ABDULLAH KASSIR and HAROON RASKID ASWAT, the defendants, arrived a t t h e Bly, Oregon property with Co-Conspirator 2, as requested by MUSTAFA WlMEL MUSTAFA, the defendant. After KASSIR and ASWAT arrived a t the Bly, Oregon property, KASSIR and ASWAT both t o l d individuals a t the property- t h a t they had been sent t h e r e by MUSTAFA KAMEL MUSTAFA, the defendant, t o t r a i n people for jihad and to assess the s u i t a b i l i t y of the Bly, Oregon property f o r a jihad t r a i n i n g camp. KASSIR and ASWAT a l s o both t o l d individuals a t the property t h a t they supported Usama bin Laden and al Qaeda, arid had r e c e i v e d . t h e i r - - - ' own jihad t r a i n i n g i n Afghanistan. f . In or about December 1999, a f t e r he arrived a t the Bly, Oregon property, OUSSAMA ABDULLAH KASSIR, the defendant, established s e c u r i t y p a t r o l s around the perimeter of the property - * t h a t would c o n s t i t u t e the jihad t r a i n i n g camp. g. In o r about December 1999, a f t e r he arrived a t the Bly, Oregon property, OUSSAMA ABDULLAH KASSIR, the defendant, taught two individuals how t o k i l l a person by s l i t t i n g t h e i r t h r o a t with a knife and how t o f i g h t with a knife i n hand-to-hand combat. h. In or about December 1999, a f t e r he arrived a t the Bly, Oregon property, OUSSAMA ABDULLAH KASSIR, the defendant, 'and others discussed a p l a n t o k i l l truck d r i v e r s t r a v e l i n g through Oregon and then " s t e a l t h e i r cargo f o r money and goods t o support the jihad t r a i n i n g camp. i. In or about December 1999, a f t e r they i f r i v e d a t the Bly, Oregon property, OUSSAMA ABDULLAH KASSIR and HAROON RASHID ASWAT, the defendants, d i s t r i b u t e d t o several individuals a cd-rorn containing i n s t r u c t i o n s on how t o make bombs and poisons, and t o l d them t h a t they should l e a r n t h e s e techniques because they might have t o use them in the future. ( T i t l e 18, United S t a t e s Code, Section 371.) COUNT FOUR PROVIDING AND CONCEALING MATERIAL SUPPORT AND RESOURCES TO TERRORISTS - (THE BLY, OREGON JIHAD TRAINING CAMP) The Grand Jury further charges: 8. From i n or about October 1999, up to and including i n or about early 2000, i n the Southern District of New York and elsewhere, MUSTAFA KAMEL MUSTAFA, a/k/a "Abu Hamza, " a/ k/a "Abu Hamza al-Masri," a/k/a "Mustafa Kamel," a/k/a "Mostafa Kame1 Mostafa," OUSSAMA ABDULLAH KASSIR, a/k/a "Abu Abdullah," a/k/a "Abu Khadi ja, " and HAROON RASHID ASWAT, a/k/a "Haroon, " a/k/a "Haroon Aswat,'' the defendants, and others known- and unknown, a t l e a s t one of whom was f i r s t brought to and arrested i n the Southern District of New York, within the United States, provided material support and resources and concealed and disguised t h e nature, location, , ' source, and ownership of material support and resources, knowing and intending that they were t o be used in preparation for, and i n carrying out, a violation of Section 956 of T i t l e 18, United States Code (conspiring t o k i l l , kidnap, maim, and injure persons and t o damage and destroy property i n a foreign country), and i n - preparation for, and i n carrying out, the concealment and an escape from the commission of such violation. (Title 18, United States Code, Sections 2339A and 2 . ) COUNT FIVE CONSPIRACY TO PROVIDE MATERIAL SUPPORT AND RESOURCES TO A FOREIGN TERRORIST ORGANIZATION - (THE BLY, OREGON JIHAD TRAINING CAMP) * * The Grand J u r y f u r t h e r c h a r g e s : 9. From i n or about October 1999, up t o and i n c l u d i n g i n or about e a r l y 2000, i n t h e Southern District of New York and elsewhere, MUSTAFA KAMEL MUSTAFA, a / k / a "Abu Warnza," a / k / a "Abu Hamza al-Masri," a / k / a "Mustafa Kamel," a / k / a "Mostafa Kamel Mostafa," OUSSAMA ABDULLAH KASSIR, a/k/a "Abu ~ b d u i l a h , " a/k/a "Abu Khadi-ja," and HAROON RASHID ASWAT, a/k/a "Haroon," a / k / a "Haroon Aswat," t h e d e f e n d a n t s , and o t h e r s known-and unknown, a t l e a s t one of whom was first brought t o and a r r e s t e d i n t h e Southern District of New York, . u n l a w f u l l y and knowingly combined, c o n s p i r e d , c o n f e d e r a t e d and a g r e e d t o g e t h e r and with each o t h e r t o v i o l a t e I J' S e c t i o n 23398 of T i t l e 18, United S t a t e s Code. 10. It was a p a r t and an o b j e c t of t h e c o n s p i r a c y t h a t MUSTAFA KAMEL MUSTAFA, OUSSAMA ABDULLAH KASSIR, and HAROON RASHID ASWAT, t h e d e f e n d a n t s , and o t h e r s known and unknown, would and d i d , w i t h i n t h e United S t a t e s and subject t o t h e j u r i s d i c t i o n of t h e United S t a t e s , knowingly p r o v i d e m a t e r i a l s u p p o r t and r e s o u r c e s t o a foreign t e r r o r i s t o r g a n i z a t i o n , t o w i t , a t e r r o r i s t o r g a n i z a t i o n known as "a1 Qaeda" and l e d by Usama Bin Laden, which was - d e s i g n a t e d by t h e S e c r e t a r y of S t a t e as a f o r e i g n terrorist I - .- o r g a n i z a t i o n on o r about October 8, 1999, p u r s u a n t to S e c t i o n 219 of t h e Imrnigra'cion and N a t i o n a l i t y Act, and was redesignated as such on or about October 5, 2001, and October 2, 2003. Overt Acts - * 11. I n f u r t h e r a n c e of s a i d c o n s p i r a c y , and t o e f f e c t t h e i l l e g a l o b j e c t t h e r e o f , t h e following o v e r t act, and t h e o v e r t a c t s set out i n Count Three of this Indictment which are i n c o r p o r a t e d herein by t h i s r e f e r e n c e , were committed i n t h e Southern District of New York and elsewhere: a. On o r about October 25, 1999, MUSTAFA KAMEL MUSTAFA, t h e defendant, received a f a c s i m i l e p r o p o s a l i n London, England, regarding t h e c r e a t i o n of a j i h a d training camp i n Bly, Oregon. ( T i t l e 18, United S t a t e s Code, Section 2339B ( a ) (1) . ) COUNT SIX , , PROVIDING MATERIAL SUPPORT AND RESOURCES TO A FOREIGN TERRORIST ORGANIZATION JTHE BLY, OREGON JIHAD TRAINING CAMP) The Grand Jury f u r t h e r charges: 12. From i n or about October 1999, up t o and i n c l u d i n g - i n o r about e a r l y 2000, i n t h e Southern District of New York and elsewhere, MUSTAFA KAMEL MUSTAFA, a/k/a "Abu Hamza," a/k/a "Abu Hamza dl-Masri," a/k/a "Mustafa Kamel," a/k/a "Mostafa Kamel - Mostafa, " OUSSAMA ABDULLAH KASSIR, a/k/a "Abu Abdullah, " a/k/a "Abu I " . Khadi ja, " and HAROON RASHID ASWAT, a/ k/a "Haroon, " a/ k/a "Haroon Aswat," t h e d e f e n d a n t s , and o t h e r s known and unknown, a t l e a s t one of whom was first brought to and a r r e s t e d i n t h e Southern District of New York, w i t h i n t h e United S t a t e s and s u b j e c t t o t h e - I j u r i s d i c t i o n of t h e United S t a t e s , u n l a w f u l l y and knowingly did p r o v i d e , and a t t e m p t t o p r o v i d e , m a t e r i a l s u p p o r t and r e s o u r c e s t o a f o r e i g n t e r r o r i s t o r g a n i z a t i o n , t o w i t , a t e r r o r i s t o r g a n i z a t i o n known a s "a1 Qaeda" and l e d by Usama Bin Laden, which was d e s i g n a t e d by t h e S e c r e t a r y of S t a t e as a f o r e i g n terrorist o r g a n i z a t i o n on o r about October 8, 1999, pursuant to S e c t i o n 219 of t h e I m m i g r a t i o n a n d N a t i o n a l i t y Act, and was r e d e s i g n a t e d as such on o r about October 5, 2001, and October 2, 2003. ( T i t l e 18, United S t a t e s Code, S e c t i o n s 2339B(a) (1) and 2 . ) COUNT SEVEN CONSPIRACY TO KILL, KIDNAP, MAIM, AND INJURE PERSONS I N A FOREIGN COUNTRY (THE BLY, OREGON JIHAD TRAINING CAMP) The Grand Jury f u r t h e r c h a r g e s : 13. From i n or about October 1999, up t o and i n c l u d i n g i n o r about May 2002, i n the Southern District of New York and - e l s e w h e r e , OUSSAMA ABDULLAH KASSIR, a / k / a "Abu Abdullah," a/k/a "Abu Khadija," t h e d e f e n d a n t , and o t h e r s known and unknown, at: least one of whom was first brought t o and a r r e s t e d i n t h e Southern District of New York, w i t h i n t h e j u r i s d i c t i o n of t h e United S t a t e s , 1 _ _- " u n l a w f u l l y and knowingly combined, c o n s p i r e d , c o n f e d e r a t e d and agreed t o g e t h e r and w i t h each o t h e r t o commit a t a place oucsi.de t h e United S t a t e s an a c t t h a t would c o n s t i t u t e t h e offense of murder, kidnapping, and maiming i f committed i n t h e s p e c i a l . . maritime and t e r r i t o r i a l j u r i s d i c t i o n of t h e United S t a t e s . -Ov ert A c t s 1 4 . In f u r t h e r a n c e of s a i d c o n s p i r a c y , and t o e f f e c t t h e i l l e g a l o b j e c t s t h e r e o f , t h e following o v e r t a c t s , and the o v e r t acts set out i n Count Three of t h i s Indictment which a r e incorporated h e r e i n by t h i s r e f e r e n c e , were committed: a. I n o r about December 1999, after he a r r i v e d a t t h e Bly, Oregon p r o p e r t y , OUSSAMA ABDULLAH KASSIR, t h e defendant, taught two i n d i v i d u a l s how t o k i l l a person by s l i t t i n g t h e i r t h r o a t w i t h a knife and how t o f i g h t with a k n i f e i n hand-to-hand combat. b. I n o r about December 1999, a f t e r he a i r i v e d at t h e Bly, Oregon p r o p e r t y , OUSSAMA ABDULLAH KASSIR, t h e defendant, d i s t r i b u t e d t o several i n d i v i d u a l s a cd-rom c o n t a i n i n g i n s t r u c t i o n s on how t o make bombs and poisons, and t o l d them t h a t they should l e a r n these techniques because they might have t o use them i n t h e - f u t u r e . c. I n or about May 2002, OUSSAMA ABDULLAH KASSIZ, the defendant, c a l l e d one of t h e i n d i v i d u a l s who had been presenr a t the Bly, Oregon property t o inquire a'bout the arrest of another " * individual who had been present a t the Bly, Oregon property by counterterrorism a g e n t s i n the United S t a t e s . ( T i t l e 18, United S t a t e s Code, Section 956 ( a ) . ) COUNT EIGHT . CONSPIRACY TO PROVIDE AND CONCEAL MATERIAL SUPPORT AND RESOURCES TO TERRORISTS (KASSIR' S TERRORIST WEBSITES) The Grand Jury f u r t h e r charges.: 15. From i n or about a t l e a s t December 2001, up t o and including on or about December 11, 2005, i n the Southern D i s t r i c t of New York and elsewhere, OUSSAMA ABDULLAH KASSIR, a/k/a "Abu Abdullah," a/k/a "Abu Khadija," the defendant, and o t h e r s known and unknown, a t l e a s t one of whom was f i r s t brought t o and a r r e s t e d i n t h e Southern District of New York, unlawfully and knowingly combined, conspired, confederated and agreed together and with each other t o v i o l a t e Section 2339A of T i t l e 18, United States Code. - 16. It was a p a r t and an object of the conspiracy t h a t OUSSAMA ABDULLAH KASSIR, the defendant, and others known and unknown, would and did provide material support and resources and - conceal and disguise the nature, location, source, and ownership of I _ - 7 . material support and resources, knowing and intending t h a t they were to be used in preparation for, and in carrying out, a violation of Secrion 956 of Title 18, United States Code (conspiring t-o--killk,i dnap, maim, and injure persons and to damage " * and destroy property in a foreign country), and in preparation for, and in carrying out, the concealment of an escape from the commission of such violation. Overt Acts 17. In furtherance of said conspiracy, and to effect the illegal object thereof, the following overt acts, among others, were committed in the Southern District of New York and elsewhere: a. In or about December 2001, OUSSAMA ABDULLAH KASSIR, the defendant, established a website with the web address mii.faithweb.com, which contained, among other things, terrorist materials and information and instructions on how to build a bomb. b. In or about March 2002, OUSSAMA ABDULLAH KASSIR, the defendant, established a website on an internet server in White Plains, New York, with the web address www.alqqa3qa3.8rn.com, which contained, among other things, terrorist materials and information and instructions on how to build bombs and make poisons. c. From in or about March 2002, up to and including in or about October 2003, OUSSAMA ABDULLAH KASSIR, the . defendant, stored on his personal computer images of firearms, , - -- - bombs, and other weapons which he had accumulated in connection with the operation of a website with the web address ( T i t l e 18, United States Code, Section 2339A(a) . ) COUNT NINE PROVIDING AND CONCEALING MATERIAL SUPPORT AND RESOURCES TO TERRORISTS (KASSIR' S TERRORIST WEBSITES) The Grand J u r y f u r t h e r charges: 18. From i n or about a t l e a s t December 2001, up t o and including on or about December 11, 2005, i n the Southern District of New York and elsewhere, OUSSAMA ABDULLAH KASSIR, a/k/a "Abu Abdullah, " a/k/a "Abu Khadija, " the defendant, and others known and unknown, a t l e a s t one of whom was f i r s t brought t o and a r r e s t e d in the Southern District of New York, unlawfully and knowingly did provide, and attempt to provide, material support and resources and conceal and d i s g u i s e the nature, l o c a t i o n , source, and ownership of material support and resources, knowing and intending t h a t they were t o be used i n preparation f o r , and i n c a r r y i n g o u t , a v i o l a t i o n of Section 956 of T i t l e 18, United S t a t e s Code {conspiring t o kill, kidnap, maim, and i n j u r e persons and t o damage - and destroy property i n a foreign country), and i n preparation f o r , and in carrying out, the concealment and an escape from t h e commission of such v i o l a t i o n . ( T i t l e 18, United States Code, Sections 2339A and 2 . ) COUNT TEN CONSPIRACY TO PROVIDE MATERIAL SUPPORT AND RESOURCES TO A FOREIGN TERRORIST ORGANIZATION (KASSIR'S TERRORIST WEBSITES) 1 ) The Grand Jury f u r t h e r charges: 19. From in o r about a t l e a s t December 2001, up to and including on or about December 11, 2005, in t h e S o u t h e r n District of New York and elsewhere, OUSSAMA ABDULLAH KASSIR, a / k / a "Abu Abdullah," a/k/a "Abu Khadija," t h e defendant, and o t h e r s known and unknown, a t least one of whom was first brought t o and a r r e s t e d i n the Southern District of New York, unlawfully and knowingly combined, c o n s p i r e d , c o n f e d e r a t e d and agreed t o g e t h e r and with each o t h e r t o v i o l a t e Section 2339B of T i t l e 18, United S t a t e s Code. 20. It was a p a r t and an o b j e c t of t h e c o n s p i r a c y t h a t OUSSAMA ABDULLAH KASSIR, t h e defendant, and o t h e r s known and unknown, would and d i d knowingly provide m a t e r i a l support and r e s o u r c e s to a f o r e i g n t e r r o r i s t o r g a n i z a t i o n , t o w i t , a t e r r o r i s t o r g a n i z a t i o n known as "a1 Qaeda" and led by Usama Bin Laden, which was designated by t h e S e c r e t a r y of S t a t e a s a f o r e i g n t e r r o r i s t o r g a n i z a t i o n on o r about October 8, 1999, pursuant t o Section 219 - of the Immigration and N a t i o n a l i t y A c t , and was redesignated a s such on o r about October 5, 2001, and October 2, 2003. Overt A c t s 21. In f u r t h e r a n c e of s a i d c o n s p i r a c y , and t o e f f e c t t h e I _ _ - "I i l l e g a l o b j e c t t h e r e o f , t h e following o v e r t act, and t h e overr a c t s set out in Count Eight of this Indictment which are incorporated herein by this reference, were committed in the Southern Districr of New York and elsewhere: - * a. In or about March 2002, OUSSAMA ABDULLAH KASSIR, the defendant, posted a document entitled "The Mujahideen Explosives Handbook" to a website he was operating with the web address www.alqqa3qa3.8rn.com. (Title 18, United States Code, Section 2339B(a) (1) . ) COUNT ELEVEN PROVIDING MATERIAL SUPPORT AND RESOURCES TO A FOREIGN TERRORIST ORGANIZATION (KASSIR' S TERRORIST WEBSITES) The Grand Jury further charges: 22. From in or about at least December 2001, up to and , ,' including on or about December 11, 2005, in the Southern District of New York and elsewhere, OUSSAMA ABDULLAH KASSIR, a/k/a "Abu Abdullah," a/k/a "Abu Khadija," the defendant, and others known and unknown, at least one of whom was first brought to and arrested in the Southern District of New York unlawfully and knowingly did - provide, and attempt to provide, material support and resources to a foreign terrorist organization, to wit, a terrorist organization known as "a1 Qaeda" and led by Usama Bin Laden, which was . designated by the Secretary of State as a foreign terrorist - . organization on or about October 8, 1999, pursuant to Section 219 of the Immigration and Nationality Act, and was redesignatled as such on or about October 5, 2001, and October 2, 2003. (Title 18,- United States Code, Sections 2339B(a) (1) and 2.) COUNT TWELVE CONSPIRACY TO KILL, KIDNAP, MAIM, AND INJURE PERSONS IN A FOREIGN COUNTRY (ISASSIR'S TERRORIST WEBSITES) The Grand Jury further charges: 23. From in or about at least December 2001, up to and including on or about December 11, 2005, in the Southern District of New York and elsewhere, OUSSAMA ABDULLAH KASSIR, a/k/a "Abu Abdullah," a/k/a "Abu Khadija," the defendant, and others known and unknown, at least one of whom was first brought to and arrested in the Southern District of New York, within the jurisdiction of the United States, unlawfully and knowingly combined, conspired, confederated and agreed together and with each other to commit at a place outside the United States an act that would constitute the offense of murder, kidnapping, and maiming if committed in the special maritime and territorial jurisdiction of the United States. Overt Acts 24. In furtherance of said conspiracy, and to effect the illegal objects thereof, the following overt act, and the overt . acts set out in Count Eight of this Indictment which are I - - - incorporated herein by this reference, were committed in the Southern District of New York and elsewhere: a. In or about March 2002, OUSSAMA ABDULLAH KASSIR, the defendant, posted a document entitled "The Mujahideer! * . Poisons Handbook" to a website he was operating with the web address www.alqqa3qa3.8m.com. (Title 18, United States Code, Section 956(a) . ) COUNT TRIRTEEN DISTRIBUTING INFORMATION RELATING TO EXP~OSIVES, DESTRUCTIVE DEVICES, AND WEAPONS OF MASS DESTRUCTION (KASSIR'S TERRORIST WEBSITES) The Grand Jury further charges*: 25. From in or about at least December 2001, up to and including on or about December 11, 2005, in the Southern District of New York and elsewhere, OUSSAMA ABDULLAH KASSIR, a/k/a "Abu , < Abdullah, " a/k/a "Abu Khadija, " the defendant, and others known and unknown, at least one of whom was first brought to and arrested in the Southern District of New York, taught and demonstrated the making and use of explosives, destructive devices, and weapons of mass destruction, and distributed information pertaining to, in - whole and in part, the manufacture and use of explosives, destructive devices, and weapons of mass destruction, with the ineent that the teaching, demonstration, and information be used for, and in furtherance of, activities that constitute Federal I - -. crimes of violence, to wit, KASSIR established and operated numerous websites, which contained, among other things, terrorist materials and information and instructions on how to build bombs and make poisons. - _. (Title 18, United States Code, Sections 842 (p) (2) fAf and 2. ) COUNT FOURTEEN PROVIDING ASSISTANCE AND INDUCEMENT IN THE DEVELOPMENT, PRODUCTION, AND USE OF CHEMICAL WEAPONS (KASSIR'S TERRORIST WEBSITES) The Grand Jury further charges: 26. From in or about at least December 2001, up to and including on or about December 11, 2005; in the Southern District of New York and elsewhere, OUSSAMA ABDULLAH KASSIR, a / k / a "Abu Abdullah, " a/k/a "Abu Khadi j a r " the defendant, and others known and unknown, at least one of whom was first brought to and arrested in the Southern District of New York, assisted and induced to develop, produce, otherwise acquire, transfer directly and indirectly, receive, stockpile, retain, own, possess, use, and threaten to use chemical weapons, to wit, KASSIR established and operated numerous websites, which contained, among other things, terrorist materials and information and instructions on how to build bombs and make poisons. (Title 18, United States Code, Sections 229 (a) and 2. ) COUNT FIFTEEN CONSPIRACY TO PROVIDE AND CONCEAL MATERIAL SUPPORT AND RESOURCES TO TE-RRORISTS (FACILITATING VIOLENT JIHAD I N AFGHANISTAN) . * The Grand J u r y further charges: 27. From i n or about June 2000, up to and including on or about December 19, 2001, i n the Southern District of New York and elsewhere, MUSTAEA KAMEL MUSTAFA, a/k/a "Abu Hamza, " a/k/a "Abu Hamza al-Masri," a/k/a "Mustafa Kamel," a/k/a "Mostafa Kamel Mostafa, " the defendant, and others known and unknbwn, at l e a s t one of whom was f i r s t brought to and arrested i n the Southern District of New York, unlawfully and knowingly combined, conspired, ' confederated and agreed together and with each other t o violate Section 2339A of T i t l e 18, United States Code. 28. It was a part and an object of the conspiracy that MUSTAFA KAMEL MUSTAFA, the defendant, and others known and unknown, would and did provide material support and resources and conceal and disguise the nature, location, source, and ownership of material support and resources, knowing and intending that they were to be used i n preparation for, and i n carrying out, a violation of Section 956 of T i t l e 18, United States Code (conspiring to k i l l , kidnap, maim, and injure persons and to damage and destroy property i n a foreign country), and in preparation for, - and i n carrying out, t h e concealment and an escape from the L - -- commission of such violation. Overt Acts 29. In furtherance of said conspiracy, and t o effecr the i l l e g a l o b j e c t t h e r e o f , the following overt acts, among others, were committed i n the Southern District of New York and elsewhere: * - a. In or about June 2000, Co-Conspirator 2 traveled from London, England, t o New York, i n p a r t , t o r a i s e money f o r the Finsbury Park Mosque's h i j r a h fund from worshipers ac local mosques. During t h i s t r i p , Co-Conspirator 2 t r a v e l e d through Manhattan, New York, on h i s way t o attempt t o c o l l e c t money a t a mosque i n Long Island, New York. The money c o l l e c t e d by Co- Conspirator 2 during t h i s t r i p was added t o the Finsbury Park Mosque's h i j r a h fund when Co-Conspirator 2 returned t o London. b. I n or about November 2000, MUSTAFA KAMEL MUSTAFA, the defendant, asked Co-Conspirator 2, a U.S. c i t i z e n , t o escort another co-conspirator not named as a defendant herein ("Coconspirator 3") , who was one of MUSTAFA KAMEL MUSTAFA' s foilowers, from London, England, t o a jihad t r a i n i n g camp i n Afghanistan operated by a " f r o n t - l i n e commander." c. I n or about November 2000, Co-Conspirator 2 took money out of the Finsbury Park Mosquef s h i j r a h fund, which was - t o be used f o r c e r t a i n t r a v e l expenses r e l a t i n g t o the t ~ i pt o Afghanistan with Co-Conspirator 3. d. In or about November 2000, MUSTAFA KAMEL . MUSTAFA, the defendant, introduced Co-Conspirator 2 t o another co- I - -. conspirator not named as a defendant herein ("Co-Conspirator 4 " ) for purposes of arranging safehouses and lodging i n Pakistan and safe passage and t x a n s p o r t a t i o n into A f g h a n i s t a n . e . In o r about November 2000, Co-Conspirator 2 and Co-Conspirataq. 3 t r a v e l e d t o g e t h e r from London, England, t o " I P a k i s t a n . Both men s e p a r a t e l y e n t e r e d Afghanistan s h o r t l y t h e r e a f t e r . ( T i t l e 18, United S t a t e s Code, S e c t i o n 2339A.) COUNT SIXTEEN PROVIDING AND CONCEALING MATERIAL SUPPORT AND RESOURCES TO TERRORISTS (FACILITATING VIOLENT JIHAD I N AFGHANISTAN) The Grand J u r y f u r t h e r charges: 30. From i n o r about June 2000, up t o and i n c l u d i n g on o r about December 19, 2001, i n t h e Southern District of New York and e l s e w h e r e , MUSTAFA KAMEL MUSTAFA, a / k / a "Abu Wamza, " a / k / a "Abu Harnza al-Masri," a / k / a 'Mustafa K a m e l , " a / k / a " ~ o s t a f H ' Karnel Mostafa," t h e d e f e n d a n t , and o t h e r s known and unknown, a t l e a s t one of whom was first brought t o and a r r e s t e d i n the Southern District of New York, p r o v i d e d m a t e r i a l support and r e s o u r c e s and concealed and d i s g u i s e d t h e n a t u r e , l o c a t i o n , s o u r c e , and ownership of m a t e r i a l s u p p o r t and r e s o u r c e s , knowing and i n t e n d i n g t h a t t h e y were to be used i n p r e p a r a t i o n f o r , and i n c a r r y i n g o u t , a v i . o l a t i o n of S e c t i o n 956 of T i t l e 18, United S t a t e s Code - ( c o n s p i r i n g t o k i l l , kidnap, maim, and i n j u r e p e r s o n s and t o damage , - - - and d e s t r o y p r o p e r t y i n a f o r e i g n c o u n t r y ) , and i n p r e p a r a t i o n f o r , and i n c a r r y i n g o u t , t h e concealment and an e s c a p e from t h e commission of such v i o l a t i o n . ( T i t l e 18, United S t a t e s Code, SecZions 2339A and 2.) COUNT SEVENTEEN CONSPIRACY TO PROVIDE MATERIAL SUPPORT AND RESOURCES TO A FOREIGN TERRORIST ORGANIZATION (FACILITATING VIOLENT JIHAD IN AFGHANISTAN) The Grand Jury f u r t h e r charges: 31. From i n o r about June 2000, up t o and i n c l u d i n g on o r about December 19, 2001, i n t h e Southern District of New York and elsewhere, MUSTAFA KAMEL MUSTAFA, a/k/a "Abu Hamza, " a/k/a "Abu Hamza al-Masri, " a/k/a "Mustafa KameI, " a/k/a "Mostafa Kame1 Mostafa, " t h e defendant, and o t h e r s known and unknown, a t l e a s t one of whom was f i r s t brought t o and a r r e s t e d i n t h e Southern District of New York, unlawfully and knowingly combined, conspired, , *' confederated and agreed t o g e t h e r and with each o t h e r t o v i o l a t e Section 2339B of Title 18, United S t a t e s Code. 32. It was a p a r t and an o b j e c t of t h e conspiracy t h a t MUSTAFA KAMEL MUSTAFA, t h e defendant, and o t h e r s known and unknown, would and did, within t h e United S t a t e s and s u b j e c t t o t h e - j u r i s d i c t i o n of t h e United S t a t e s , knowingly provide m a t e r i a l support and resources t o a f o r e i g n terrorist o r g a n i z a t i o n , to w i t , a t e r r o r i s t organization known as "a1 Qaeda" and led by Usama Bin . Laden, which was designated by t h e S e c r e t a r y of State a s a f o r e i g n L - - terrorist o r g a n i z a t i o n on o r about October 8, 1999, p u r s u a n t t o Section 219 of the Immigration and N a t i o n a l i t y A c t , and was redesignated as such on or about October 5, 2001, and October 2, 2003. Overt Acts - " 33. I n furtherance of said conspiracy, and to effect t h e i l l e g a l object thereof, the following overt act, and the overt a c t s set out in Count Fifteen of this Indictment which are incorporated herein by t h i s reference, were committed i n the Southern District of New York and elsewhere: a. In or about March or April 2001, MUSTAFA KAMEL MUSTAFA, the defendant, sent directions t o Co-Conspirator 3, who was i n Afghanistan a t the time, to seek out the "front-line 'commander" i n Afghanistan who was expecting Co-Conspirator 3. (Title 1 8 i United States Code, Section 2339B(a) (1). ) I ' COUNT EIGHTEEN PROVIDING MATERIAL SUPPORT AND RESOURCES TO A FOREIGN TERRORIST ORGANIZATION (FACILITATING VIOLENT JIHAD I N AFGHANISTAN) The Grand Jury further charges: 34. From i n or about June 2000, up t o and including on - or about December 19, 2001, i n the Southern District of New York and elsewhere, MUSTAFA KAMEL MUSTAFA, a/k/a "Abu Hamza," a/k/a "Abu Harnza al-Masri," a/k/a "Mustafa Kamel," a/k/a "Mostafa Kame1 . Mo'stafa, " t h e defendant, and others known and unknown, a t l e a s t one I I .- -' of whom was first brought to and arrested i n the Southern District of New York, within t h e United S t a t e s and subject ra t h e j u r i s d i c t i o n of the United S t a t e s , knowingly provided m a t e r i a l support and resources t o a f o r e i g n t e r r o r i s t organization, t o wit, - I a t e r r o r i s t organization known as "a1 Qaeda" and led by Usama B i n Laden, which was designated by t h e Secretary of S t a t e as a foreign t e r r o r i s t organization about October pursuant Section 219 of the Immigration and NaCionality Act, and was redesignated as such on or about October 5, 2001, and October 2, ( T i t l e 18, United S t a t e s Code, Sections 2339B(a) (1) and 2 . ) COUNT NINETEEN CONSPIRACY TO SUPPLY GOODS AND SERVICES TO THE TALIBAN JIEEPA VIOLATIONS) The Grand Jury f u r t h e r charges: 35. On July 4 , 1999, President of the United S t a t e s W i l l i a m J. Clinton declared a n a t i o n a l emergency i n Executive Order 13129 t o deal with t h e t h r e a t posed by a1 Qaeda and the Taliban, Afghanistan's dominant p o l i t i c a l force a t that t i m e . S p e c i f i c a l i y , - the President found t h a t : The actions and p o l i c i e s of the Taliban i n Afghanistan, i n allowing t e r r i t o r y under its control i n Afghanistan t o be used as a s a f e haven and base of operations f o r Usama bin Laden and the [a1 Qaeda] organization who have committed and threaten t o continue t o commit a c t s of violence a g a i n s t t h e United S t a t e s a n d l i t s n a t i o n a l s , - - c o n s t i t u t e an unusual and extraordinary t h r e a t t o the national s e c u r i t y and f o r e i g n p o l i c y of the U n i t e d S t a t e s . 36. In h i s Executive Order 13129, the President prohibited, among other things, United States persons from making - 1) or receiving any contribution of funds, goods, or services t o or for t h e b e n e f i t of the Taliban, and from supplying, d i r e c t l y or i n d i r e c t l y , any goods, software, technology, or services t o the Taliban or t o the t e r r i t o r y of Afghanistan controlled by the Taliban. 37. On June 30, 2000, the n a t i o n a l < emergency w i t h respect t o the Taliban was continued. One year l a t e r , the national emergency was again continued, pursuant t o a finding by President 'of the United States George W. Bush that " [ t l h e Taliban continues t o allow t e r r i t o r y under its control in Afghanistan t o be used as a safe haven and base of operations for Usarna bin Laden and t h e [a1 Qaedal organization who have committed and threaten t o contlhue t o commit a c t s of violence against the United S t a t e s and its nationals." 38. From i n or about t h e Spring of 2000, up t o and including in or about l a t e 2001, i n t h e Southern District of New - York and elsewhere, MUSTAFA KAMEL MUSTAFA, a/k/a "Abu Hamza," a/k/a "Abu Mamza al-Masri, " a/k/a "Mustafa Kamel, " a/k/a "Mostafa Karnel Mostafa," the defendant, and others known and unknown, a t l e a s t one . of,whom was f i r s t brought t o and arrested i n the Southern D i s t r i c t I - .. of New York, unlawfully and knowingly combined, conspired, confederated and agreed together and w i t h each other t o v i o l a t e 28 -a - . S e c t i o n 1705(b) of Title 50, United States Code, and Seccions 545.204 and 545.206(b) of Title 31, Code of Federal RegulaEions. 39.- It was a part and an object of the c o n s p i r a c y char MUSTAFA KAMEL MUSTAFA, the defendant, and others known and unknown, did u n l a w f u l l y and knowingly v i o l a t e a regulation issued under Chapter 35 of Title 50, United States Code, in t h a t at least one United States person, along with others known and unknown, did c o n s p i r e to u n l a w f u l l y supply funds, goods, and services t o the Tabiban, to the territory of Afghanistan controlled by the Taliban, and to persons whose property and interests in property were blocked pursuant to Title 31, Code of Federal Regulations, Section 545.201. Overt Acts. 40. In furtherance of said conspiracy, and to effect t h e i l l e g a l object thereof, the following overt acts, arnong'others, were committed in the Southern District of New York and elsewhere: a. From in or about the Spring of 2000, up to and including at least September 6, 2001, MUSTAFA KAMEL MUSTAFA, the defendant, posted messages on the Supporters of Shariah ("SOS") website, with the assistance of Co-Conspirator 2, a U.S. citizen, urging the defendant's f o l l o w e r s to donate money, goods, and services to Taliban-sponsored programs in the area of Afghaniscan controlled by the Taliban. - .- b. In or about l a t e 2000, at the request of MUSTAFA KAMEL MUSTAFA, the defendant, Co-Conspirator 2 agreed to 29 deliver Co-Conspirator 3, a person desiring to undergo violent jihad training, to an individual located in the territory of Afghanistan con-trolled by the Taliban. - . c. In or about late 2000, at the request of MUSTAFA KAMEL MUSTAFA, the defendant, Co-Conspira tor 2 delivered compact discs containing MUSTAFA KAMEL MUSTAFA's statements to certain individuals located in the territory of Afghanistan controlled by the Taliban. d. From in or about March 2601, up to and including at least September 6, 2001, MUSTAFA KAMEL MUSTAFA, t h e defendant, and Co-Conspirator 2 discussed plans to establish a computer lab in Afghanistan. During these discussions, MUSTAFA KAMEL MUSTAFA, the defendant, stated that he wanted the computer lab to be located in Kandahar and to service Taliban officials and the Afghani people located in Kandahar, which was then cokrolled by the T a l i b a n . e. Or: or about September 6, 2001, Co-Conspirats- 2 departed London, England for Pakistan, and then ?.fghanist;r.. P r i o r to his departure, MUSTAFA KAMEL MUSTAFA, the defendant, gzve . I Co-Conspirator 2 approximately s i x t h o u s a n d B r i t i s h Pounds which were, in part, to be used to lease a building which would house i5e computer lab and to pay for some of the start up expenses for The computer lab. (Title 18, United States Code, Section 371; Title 50, United States Code, Section 1705(b) ; and T i t l e 31 Code of Federal Regulations, Sections 545.204 and 545.206(b).) MICHAEL J. GARCIA United S t a t e s Attorney Form No. USA-33s-274 (Ed. 9 - 2 5 - 5 8 } UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERXCA MUSTAFA KAMEL MUSTAFA, a/k/a "Abu Hamza," a/k/a "Abu Hamza al-Masxi," a/k/a "Mustafa Kamel," a/k/a "Mostafa Kamel MostafaIW OUSSAMA ABDULLAH KASSIR, a/k/a "mu Abdullah,,' a/k/a "Abu Khadija," and HAROON RASHID SWAT, a/k/a "Haroon, a/k/a "Haroon Aswat, " Defendants. 52 04 Cr. 356 (JFK) (Title 18, United States Code, Sections 2, 229 (a), 371, 842 (p) (2) (A) , 956(a), 1203, 2339~,and 2339B, a n d - ~ i t l e50 , United States Code, Section 1705 (b) ) MICHAEL J. GARCIA United States Attorney. A TRUE BILL -- - L -.=- -Lp 8 Foreperson. 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