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Judicial Watch • Abu Ghaith Indictment

Abu Ghaith Indictment

Abu Ghaith Indictment

Page 1: Abu Ghaith Indictment

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Number of Pages:10

Date Created:March 20, 2014

Date Uploaded to the Library:March 20, 2014

Tags:ghayth, sulaiman, salman, indictment, Qaeda, afghanistan, laden, al Qaeda, September, defendant, states, united, EPA, IRS, CIA


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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT NEW YORK 
----------------x 
UNITED STATES AMERICA 
-v. -INDICTMENT 
SULAIMAN ABU GHAYTH, S14 Cr. 1023 (LAK) a/k/a "Salman Abu Ghayth," 
Defendant. 
----------------x 
COUNT ONE (Conspiracy Kill United States Nationals) 
The Grand Jury charges: 
Background the From about 1989, and including the date the filing this Indictment, Qaeda has been international terrorist group that dedicated opposing non-Islamic governments with force and violence. Usama Bin Laden 
("Bin Laden") was the leader, "emir," Qaeda until his death about May 2011. Members Qaeda typically have pledged oath allegiance (called Bin Laden and Qaeda. The core purpose Qaeda, stated Bin Laden and other leaders, support violent attacks against property and nationals, both military and civilian, the 
United States and other countries. Between 1989 and 2001, 
Qaeda established training camps, guest houses, and business operations Afghanistan, Pakistan, and other countries for the purpose training and supporting its agenda violence and murder. Members and associates Qaeda, both known and unknown, have executed number terrorist attacks, all furtherance the organization's stated conspiracy kill Americans, including the attacks the United States September 11, 2001 New York, Virginia, and Pennsylvania, which killed approximately 2,976 people. 
From least about May 2001, and including about 2002, SULAIMAN ABU GHAYTH, a/k/a "Salman Abu Ghayth," the defendant, served Qaeda. Among other things, ABU GHAYTH urged others swear allegiance Bin Laden, spoke behalf and support Qaeda's mission, and warned that attacks similar those September 11, 2001 would continue. During 2002, ABU GHAYTH was smuggled from Afghanistan into Iran. 

Statutory Allegations 
From least about May 2001, and including about 2002, offense begun and committed outside the jurisdiction any particular State district the United States, SULAIMAN ABU GHAYTH, a/k/a "Salman Abu Ghayth," the defendant, who has been first brought and 

arrested the Southern District New York, and others known 
and unknown, unlawfully, willfully, and knowingly combined, conspired, confederated, and agreed kill nationals the United States. was part and object the conspiracy that SULAIMAN ABU GHAYTH, a/k/a "Salman Abu Ghayth," the defendant, and others known and unknown, would and did murder --as that term defined Title 18, United States Code, Section llll(a) --United States nationals anywhere the world. 
Overt Acts furtherance the conspiracy and effect the illegal object thereof, SULAIMAN ABU GHAYTH, a/k/a "Salman Abu Ghayth," the defendant, committed the following overt acts, among others: about May 2001, ABU GHAYTH urged individuals guest house Kandahar, Afghanistan, swear oath allegiance Bin Laden. 
Prior September 11, 2001, Afghanistan, ABU GHAYTH told Bin Laden that (ABU GHAYTH) would assist Bin Laden. Among other things, ABU GHAYTH agreed assist Bin Laden giving speeches and appearing Qaeda propaganda. ABU GHAYTH understood the objective this propaganda be, among other things, recruit additional personnel join Qaeda. ABU 
Ayman al-Zawahiri, and senior Qaeda leader Abu Hafs spoke behalf Qaeda and warned the United States and allies that "[a] great army gathering against you" and 
upon "the nation Islam" battle against "the Jews, Christians and the Americans." 
After the September 11, 2001 terrorist attacks, ABU GHAYTH gave speech which addressed the United States Secretary State and warned that "the storms shall not stop, especially the Airplanes Storm," and advised Muslims, children, and opponents the United States "not board any aircraft and not live high rises." about November 2001, ABU GHAYTH appeared propaganda video with Usama Bin Laden and others which they discuss the attacks September 11, 2001. after April 11, 2002, ABU GHAYTH 
delivered speech which, among other things, praised April 11, 2002 suicide bombing synagogue Djerba, Tunisia, and said that "[w]e were also granted victory when the world saw with its very own eyes what the Mujahidin did for the 
sake God the Almighty New York and Washington," that "we" 
possessed the capability "to actually implement these threats," that "the organization now observing, investigating, and monitoring new American targets which will strike period that not long," that "[o]ur martyrdom units are also ready and prepared carry out operations against American and Jewish targets inside and abroad," and that "we shall launching terrorist attacks America time, place, and method our choosing." 
(Title 18, United States Code, Sections 2332(b) and 3238.) 
COUNT TWO 
(Conspiracy Provide Material Support and Resources Terrorists) 
The Grand Jury further charges: 
The allegations contained paragraphs through and are hereby repeated, realleged, and incorporated reference fully set forth herein. 
From least about May 2001, and including about 2002, offense begun and committed outside the jurisdiction any particular State district the United States, SULAIMAN ABU GHAYTH, a/k/a "Salman Abu Ghayth," the defendant, who has been first brought and arrested the Southern District New York, and others known and unknown, unlawfully and knowingly combined, conspired, 

together and Code, Section part and a/k/a "Salman 
known and unknown, 
material support and resources, that 
18, United States Code, Section 2339A(b) 
knowing and intending that they were 
for, and carrying out, violation 
Code, Section 2332(b) (conspiracy 

Overt Acts 
10. furtherance the the illegal object thereof, SULAIMAN ABU Abu Ghayth," the defendant, and others committed the overt acts set forth paragraph this Indictment, which are fully incorporated reference herein. 
(Title 18, United States Code, Sections 2339A and 3238.) 
COUNT THREE 
(Providing Material Support and Resources Terrorists) 

The Grand Jury further charges: 
11. The allegations contained paragraphs through and are hereby repeated, realleged, and incorporated reference fully set forth herein. 

From about October 26, 2001, about 2002, offense begun and jurisdiction any particular State States, SULAIMAN ABU GHAYTH, a/k/a 
defendant, who has been first brought arrested the Southern District New York, and and unknown, unlawfully and knowingly did provide, provide, material support and resources, that defined Title 18, United States Code, Section wit, personnel --knowing and intending that they used preparation for, and carrying out, Title 18, United States Code, Section 2332(b) kill U.S. nationals). 
(Title 18, United States Code, Sections 2339A, 
FORFEITURE ALLEGATIONS 

13. 
The allegations contained Counts Three this Indictment are hereby re-alleged and reference for the purpose these forfeiture pursuant Title 18, United States Code, Section and Title 28, United States Code, Section 246l(c). 

14. 
The violation Title 18, United States Code, Section 2332(b) alleged Count One this Indictment, and the violations Title 18, United States Code, Section 2339A alleged Counts Two and Three this Indictment, were federal 

Title 18, United States Code,
United States, citizens and and their property. a/k/a "Salman Abu Ghayth, 
defendant, was engaged planning and perpetrating federal crimes terrorism against the United States, citizens and residents the United States, and their property. 
16. 
Upon conviction the offenses alleged Counts One, Two, and Three this Indictment, SULAIMAN ABU GHAYTH, a/k/a "Salman Abu Ghayth, the defendant, shall forfeit the United States, pursuant Title 18, UnitedStates Code, Section 98l (a) (1) (G) (i), and Title 28, United States Code, Section 246l (c), all right, title, and interest all assets, foreign and domestic, derived from, involved in, and used and intended used commit federal crime terrorism against the United States, citizens and residents the United States, and their property. 

17. 
Upon conviction the offenses alleged Counts One, Two, and Three this Indictment, SULAIMAN ABU GHAYTH, a/k/a "Salman Abu Ghayth, the defendant, shall pay the United States, pursuant Title 18, United States Code, Section 981 (a) (1) (G), and Title 28, United States Code, Section 2461 (c), money judgment equal the value the assets subject 
forfeiture under paragraphs through above. 
(Title 18, United States Code, Section 981(a) (1) (G), and Title 28, United States Code, Section 2461(c) 

PREET BHARARA 

Form No. USA-33s-274 (Ed. 9-25-58) 

UNITED STATES DISTRICT COURT -S0UTHE-RN-IH-STRG-T 0F--NEW-YGRK 

UNITED STATES AMERICA 
SULAIMAN ABU GHAYTH, 
a/k/a "Salman Abu Ghayth," 

Defendant. 
INDICTMENT 

814 Cr. 1023 (LAK) 
(18 U.S.C.  2332(b), 2339A, 3238 
PREET BHARARA 
United States Attorney TRUE BILL