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Nafis Complaint

Nafis Complaint

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Published by arogers8239

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Published by: arogers8239 on Oct 18, 2012
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DMB:JPL:RMTF.#2012R01575UNITED STATES DISTRICT COURTEASTERN DISTRICT OF NEW YORK- - - - - - - - - - - - - - - - - - -XUNITED STATES OF AMERICA C O M P L A I N T- against (T. 18, U.S.C., §§2332a(a)(2)(D) andQUAZI MOHAMMAD REZWANUL AHSAN NAFIS, 2339B(a)(1))Defendant.- - - - - - - - - - - - - - - - - - -XEASTERN DISTRICT OF NEW YORK, SS:JOHN NEAS, being duly sworn, deposes and says that he isa Special Agent with the Federal Bureau of Investigation, dulyappointed according to law and acting as such.Upon information and belief, on or about October 17, 2012,within the Eastern District of New York and elsewhere, the defendantQUAZI MOHAMMAD REZWANUL AHSAN NAFIS did knowingly, intentionally andwithout lawful authority attempt to use a weapon of mass destruction,to wit: an explosive bomb, against persons and property within theUnited States, and the offense and the results of the offense wouldhave affected interstate and foreign commerce.(Title 18, United States Code, Section 2332a(a)(2)(D))Upon information and belief, on or about and between July15, 2012 and October 17, 2012, both dates being approximate andinclusive, within the Eastern District of New York and elsewhere,
2the defendant QUAZI MOHAMMAD REZWANUL AHSAN NAFIS did knowingly andintentionally attempt to provide material support and resources, asdefined in 18 U.S.C. § 2339A(b), including communications equipment,explosives and personnel, including himself, to a foreign terroristorganization, to wit: al-Qaeda.(Title 18, United States Code, Section 2339B(a)(1))The source of your deponent’s information and the groundsfor his belief are as follows:
 1. I am a Special Agent with the Federal Bureau ofInvestigation (“FBI”). I have been employed by the FBI forapproximately two years. I am currently assigned to the New YorkJoint Terrorism Task Force (“JTTF”), which is dedicated to
Because this affidavit is being submitted for the limitedpurpose of establishing probable cause to arrest, I have not set forthevery fact learned during the course of this investigation. Atvarious points in this affidavit, I will offer my interpretationsof certain communications in brackets and otherwise. Myinterpretations are based on my knowledge of the investigation todate and review of prior communications, the contents and contextof the communications, prior and subsequent communications,conversations with other officers, and my experience and familiaritywith terrorist organizations generally. Summaries ofcommunications do not include references to all the topics coveredduring the course of the communications. In addition, the summariesdo not necessarily include references to all statements made by thespeakers on the topics that are mentioned. Finally, quotations fromwritten communications are as they appear in their original form,including any grammatical or spelling errors. While transcribershave attempted to transcribe conversations accurately, to the extentthat quotations from these communications are included, these arepreliminary, not final, transcriptions.
3investigating counterterrorism-related matters. As a result of mytraining and experience, I am familiar with the tactics, methods andtechniques of terrorist networks and their members.
I. The Defendant
 2. According to records from federal immigrationauthorities, the defendant QUAZI MOHAMMAD REZWANUL AHSAN NAFIS(hereinafter “NAFIS”) is a 21-year-old Bangladeshi citizen whoentered the United States on a student visa in or about January 2012.NAFIS lives in Queens, New York.
II. Al-Qaeda
 3. Al-Qaeda has been designated by the Secretary ofState as a foreign terrorist organization pursuant to section 219of the Immigration and Nationality Act. On February 23, 1998,al-Qaeda issued the following directive:[I]n compliance with God’s order, we issue thefollowing fatwa to all Muslims: The ruling tokill the Americans and their allies -- civiliansand military -- is an individual duty for everyMuslim who can do it in any country in which itis possible to do it[.]Al-Qaeda has committed and attempted to commit numerous large-scaleterrorist attacks against the United States and American citizens,including, among others, the August 7, 1998 bombings of United Statesembassies in Nairobi, Kenya, and Dar es Salaam, Tanzania, which

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