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20121119_112049_ON20-TERRORISM-COMPLAINT(1)

20121119_112049_ON20-TERRORISM-COMPLAINT(1)

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Published by Ryan Gallagher

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Published by: Ryan Gallagher on Nov 29, 2012
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91
CRIMINALCOMPLAINT
UNITED STATES
DISTRICT
COURT
(COIPY
CENTRAL
DISTRICT OF
CALIFORNIAUNITED STATES
OF
AMERICA
v.
SOHIEL OMAR KABIR,
RALPH
KENNETH DELEON,MIGUEL ALEJANDRO SANTANA VIDRIALES,
and
ARIFEEN DAVID GOJALI,DEFENDANTS.
DOCKET
NO.
MAGISTRATE'S CASE
NO.
12-
CL' -
r>
K
'J
15
' -
-
COURT
mi 
11**CE^iRAL
DISTRICT
OF GhLi, A
2
(yolff
Complaint for Violation of Title 18, United
States
Code, Section 2339A: Conspiring to Provide Material
Support
and
Resources
to
Terrorists
NAME
OF
Mj^STSAfE
JUDGE
HONORABLE
SpERI
PYM
DiVTE
OF
OFFENSE
UNITED STATESMAGISTRATE JUDGE
LOCATION
Riverside, California
1
August 2010 tijPrei^nt
PLACE
OF
OFFENSE
Riverside, San Bernardino,and Los Angeles
Counties
ADDRESS
OF
ACCUSED
(IF
KNOWN)
COMPLAINANT
1
|^TMeMENT
;
rpF
FACTS CONSTITUTING THE OFFENSE
OR
VIOLATION:
Beginning on or
about
August 2010 and continuing to the
present, defendants
SOHIEL OMAR KABIR, RALPHKENNETH DELEON, MIGUEL ALEJANDRO SANTANA VIDRIALES,
and
ARIFEEN DAVID GOJALI
conspired
to
provide
material
support
and
resources,
including but not limited to
property, services,
and
personnel,
including
themselves,
knowing and
intending
that
they
be
used
in
preparation
for, and in carrying out,
crimes
of 
terrorism
in violation of Title 18, United
States
Code, Section 2339A.
BASIS
OF
COMPLAINANT'S CHARGE AGAINST
THE
ACCUSED:
(See attached
affidavit
which
is incorporated as part
of 
this
Complaint)
 MATERIAL
WITNESSES
IN
RELATION
TO
THIS
CHARGE:
Being duly
sworn,
I
declare
that
the
foregoing
is
true
an
correct
to the
 best
of my
knowledge.
SIGNATURE
OF
COMPLAINANT
N.T.
Elias
hL
OFFICIAL
TITLE
SPECIAL AGENT
-
Federal Bureau of 
Investigation
Sworn
to
before
me
and
subscribed
in
my
presence,
SIGNATURE
OF
MAGISTRATE
JUDGE(1)
SHERiPYM
DATE
November
16, 2012
1)
See
Federal Rules
of
Criminal Procedure
rules
3 and 54.
(SJD,
CDG, AWC) REC:
Detention
 
TABLE
OF
CONTENTS
INTRODUCTION 1
BACKGROUND
INFORMATION 4
SUMMARY
OF THE EVIDENCE 4THE DEFENDANTS 7
Sohiel
Omar
KABIR 7
Ralph
Kenneth
DELEON 7
Miguel Alejandro
SANTANA
Vidriales
8
Arifeen
David
GOJALI
8RELEVANT
GROUPS
8AL-QA' IDA 8THE
TALIBAN
9
SUMMARY
OF THE FACTS 9DEFENDANTS' SOCIAL MEDIA 15DEFENDANTS' STATEMENTS TO THE CS 19SANTANA
RENEWS
HIS PASSPORT 27DELEON AND SANTANA DISCUSS
JOINING
TERRORIST
GROUPS
28DEFENDANTS DISCUSS KABIR'S TRAVEL TO AFGHANISTAN 31DEFENDANTS DISCUSS TRAVELING TO AFGHANISTANTO
JOIN
KABIR 34DEFENDANTS GO TO A SHOOTING
RANGE
42DEFENDANTS DISCUSS PLANS TO LEAVE THE UNITED STATES
4
3DEFENDANTS GO TO A SHOOTING
RANGE
A
SECOND
TIME 46DEFENDANTS GO TO A PAINTBALL
FACILITY
50DELEON RECRUITS
GOJALI
TO
JOIN
THE PLOT 53DEFENDANTS GO TO A SHOOTING
RANGE
A THIRD TIME 54
i
 
TABLE
OF
CONTENTS
(CONT.)
DEFENDANTS PREPARE FOR
THEIR
DEPARTURE 55DELEON GETS HIS PASSPORT AND SEARCHES
ON-LINE
FOR
FLIGHTS
65
GOJALI
GETS HIS PASSPORT 71DELEON PURCHASES
AIRLINE
TICKETS
72CONCLUSION 74
ii

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