I, Gary S. Cacace, being duly sworn, depose and state as follows: INTRODUCTION 1. I am a special Agent with the Federal ("FBI"), and have been so employed twenty years. Since January Special Agent which Bureau of for

Investigation approximately assigned Worcester multiple

2007, I have been in charge of the for investigating

as the Supervisory Resident violations Agency,

is responsible

of federal law under the FBI's jurisdiction. of Counter Terrorism matters in

This includes

the investigation

Central, Massachusetts. investigated and domestic crimes. federal

During my employment violations

at the FBI, I have to international and economic




as well as drug offenses as a special agent,

In my capacity

I have received the use of

training and gained confidential international human

experience sources,

in search and seizure, and video

electronic terrorism,

surveillance, violent

and domestic crimes,

drug offenses,

crimes, computer other crimes.

money laundering, numerous

fraud and various in support of

I have executed


federal search warrants participated warrants. 2.

and criminal


and have search

in the execution

of more than one hundred

Along with other agents whom I supervise,

I am



investigating residing




a United

States citizen, Massachusetts personally involved

at 22 Coburn Drive, Ashland, federal criminal offenses. I have

for several


in this investigation

and have been from its inception. and

in all aspects of the investigation
in this affidavit knowledge

The information experience, information officials experience affidavit probable

is based upon my training of this investigation, and

my personal provided

to me by other agents and law enforcement

who have assisted investigating is submitted

in this investigation

and have matters. This


for the limited purpose of the issuance

of establishing complaint

cause in support

of a criminal

and arrest warrant.


it does not set forth each and

every fact that I have learned during the course of this investigation. this affidavit otherwise 3. complaint destroy All conversations are related and statements described in

in substance

and in part only unless

indicated. I am submitting charging FERDAUS this affidavit with in support of a criminal to damage and in

(1) attempting

federal governmental of 18 U.S.C.


using an explosive


§844(f) (1) i premises

(2) attempting in violation

to injure and

destroy national


of 18 U.S.C. support and in violation of 18


(3) attempting

to provide material organization


to a foreign terrorist


U.S.C. 4.

§2339B. As described in detail below, I have probable cause to


and do in fact believe,

that from no later than in or until in or about September to damage and destroy 2011,

about March 2011 and continuing FERDAUS did maliciously to wit, the Pentagon and possessed, an explosive attempt


and U.S. Capitol Building,

which are owned States, using In addition, that until in

in whole or in part, by the United of 18 U.S.C.

in violation

§844(f) (1).

I have probable

cause to believe,

and do in fact believe,

from no later than in or about March 2011 and continuing or about September

2011, FERDAUS did, with the intent to injure, the national defense of the United defense §2155.

interfere with, and obstruct States, willfully premises, Lastly, attempt

to injure and destroy in violation


to wit, the Pentagon,

of 18 U.S.C.

I have probable

cause to believe,

and do in fact believe, through in

that, beginning

in or about June 2011 and continuing 2011, FERDAUS did knowingly material

or about September attempt to provide is defined devices,

and unlawfully (as that term

support and resources

in 18 U.S.C.

§2339A(b) (I)), to wit, detonation equipment, weapons, training, and expert namely of

communications and advice FERDAUS

assistance al Qaeda.

to a foreign terrorist

organization, employees

gave these items to undercover "UCEs")

the FBI ("UCE1," "UCE2," and collectively believed were members

who he that they

of al Qaeda, and did so intending


would use the devices overseas. Further, video,



service members

serving devices

when FERDAUS provided

said detonation

and training terrorist engaging

he knew that al Qaeda was a designated that al Qaeda had engaged activity (as defined and was

organization, in terrorist

in Section Act), and that al (as defined in

212(a) (3) (B) of the Immigration Qaeda had engaged Section

and Nationality in terrorism

and was engaged

140{d) (2) of the Foreign Relations



Fiscal Years 1988 and 1989) . RELEVANT 5. prohibits attempting explosive,

LEGAL AUTHORITY 844 (f) (1) or

Title 18, United anyone

States Code, Section damaging

from maliciously

or destroying,

"to damage or destroy, any building

by means of fire or an owned or possessed or agency

.,. or real property States

or leased to, the United ...

or any department


In addition


it is unlawful

under Title 18


States Code, Section attempt

2155 to willfully

injure, destroy, defense


to injure or destroy,

any national

premises, the

"with the intent to injure, interfere national 6. defense of the United

with, or obstruct

States." 2339B makes it support or The United

Title 18, United to attempt

States Code, Section to provide material

illegal for anyone resources

to a designated



States Secretary

of State designated

al Qaeda as a foreign


terrorist designated 7. resources"

organization to this day. For purposes is defined

on October

8, 1999 and it remains


of Sections as:



support or

any property, tangible or intangible, or service, including '" training, expert advice or assistance, '" communications equipment, weapons, explosives, personnel (lor more individuals who may be or include oneself) 18 U.S.C. purposes §2339A(b) (I) (omitting non-pertinent of Sections 2339A and 2339B "training" designed provisions). constitutes skill, as "Expert from For

"instruction opposed

or teaching

to impart a specific

to general

knowledge." means

18 U.S.C.

§2339A(b) (2) .

assistance scientific, U.S.C.

and training" technical,

"advice or assistance

derived 18

or other specialized




This investigation

has revealed

that beginning University

in or

about 2010, FERDAUS, graduate

a 26 year-old Degree

Northeastern in physics,

with a Bachelorrs

began planning


commit violent considers

"jihad"l against

the United

States, which he the

an enemy of Allah.

With the goal of terrorizing its "military center,"

United States, decapitating

and killing as

lWhile "jihad" is an Arabic term that refers to both "an internal struggle" as well as a military struggle on behalf of Islam, based upon my experience and training, I believe in this context FERDAUS is using this term to refer to his proposed violent acts against the United States.




i.e., an Arabic extensively

term meaning planned





and attempted

to attack the controlled controlled (including

Pentagon and U.S. Capitol aircraft2 aircraft


using large remote explosives. Remote

filled with C-4 plastic are capable of carrying

a variety

of payloads

a lethal payload

of explosives),

can use a wide range of take-off flight patterns than

and landing environments, commercial 9. airlines,

and fly different

thus reducing

detection. has revealed that

In addition,

the investigation built,

FERDAUS has designed, phones,

and supplied more than 7 mobile to act as an device ("lED"), 3 to

each of which FERDAUS had modified switch for an improvised



2As described in detail belowr FERDAUS selected two models for his attack plans, the F-4 Phantom and F-86 Sabre. These remote controlled airplanes are a smaller scale version of U.S. military fighter jetsr ranging from 60 to 80 inches in length and having a wingspan range of 44 inches to 63 inches. For instance, the F-4 phantom FERDAUS chose to use in his attack on the Capitol Building was 1/10th the size of the actual F-4 Phantom II U.S. fighter jet. A photograph of such a remote controlled aircraft is attached as Exhibit 1. A photograph of a F-86 Sabre remote controlled aircraft is attached as Exhibit 2. 3During meetings with the FBI UCEs, FERDAUS referred to these devices as rrdetonatorsr" "detonation devices," and "phones." To build these devices, FERDAUS purchased mobile phones, unscrewed the back cover of each phone, and then soldered wires to the phone. On several occasions, FERDAUS explained to the UCEs how these devices worked: when the mobile phone's number is dialed, the phone sends an electrical current through these wires, which would act as the "electrical switch" for the detonation device. Based upon my discussions with members of the FBI Explosives Unit, IEDs commonly consist of (a) a switch/trigger; (b) an initiator; (c) a power sourcei and (d) explosives. The FBI Explosives Unit has evaluated the mobile 6

FBI undercover and recruiters American


who FERDAUS believed to purportedly

were members


for, al Qaeda, stationed

be used to kill below, during appeared



As described

a meeting with two FBI UCEs on June 27, 2011, FERDAUS gratified detonation when the UCEs told him device had succeeded

(falsely) that his first phone in killing three U.S. soldiers "That was FERDAUS

and injuring

four or five others in Iraq and responded, After each subsequent delivery,

exactly what I wanted." was anxious

to know how well each of his detonation they had killed. devices,

devices had

worked and how many Americans wanted

When asked why he explained that

to build these detonation


he "want [ed] to hit the kafir many people as possible.n 10. utilized, During


armies and

[kill] as

the course of the investigation,

FBI agents

among other things, a cooperating in consensually


who with

met with and engaged FERDAUS beginning and engaged beginning



in January

2011, and two FBI UCEs who met with recorded conversations with FERDAUS physical

in consensually 2011.

in March

The FBI also conducted

phone devices FERDAUS built and delivered to the UCEs. The FBI Explosives Unit determined that FERDAUS' modified mobile phones are components of an lED detonation device. More specifically, the FBI Explosives Unit has concluded that the mobile phone devices FERDAUS built and delivered to the FBI UCEs whom he believed to be al Qaeda operatives constitute the electrical switch or trigger component of an lED, which could be used to trigger an explosion as FERDAUS had intended.


and obtained FERDAUS'

FERDAUS' phone and e-mail efforts to procure

records/ for his

which documented attack plans. 11. During




with the CW and UCEs/ FERDAUS using model filled with system (nGPS") his plan to

stated that he planned airplanes explosives equipment. similar

to attack the Pentagon

to "small drone airplanes"

and guided by global positioning

In or about April 2011/ FERDAUS expanded

include an attack of the U.S. Capitol Building. 2011, FERDAUS delivered contained detailed two thumb drives

In May and June

to the UCEs, which instructions as

attack plans with step-by-step to attack the Pentagon

to how FERDAUS planned Capitol Building people

and the u.s. aircraft and 6

using three remote controlled himself whom he described


as an "amir,

i. e. r

an Arabic

term meaning


In May 2011, FERDAUS


to of

Washington, his targets photographed

D.C., conducted


and took photographs and identified

(Pentagon and Capitol Building), sites at the East Potomac filled with explosives. researched,


Park from which to launch Between May 2011 and (with for (F-86

his airplanes September

2011, FERDAUS assistance


and acquired components aircraft

the financial

of the UCEs) necessary

his attack plans, Sabre)


one remote controlled

25 pounds

of C-4 explosives,

6 fully-automatic



assault rifles ordering Winfield.

(machine guns), and grenades.4

For the purpose


the F-86 Sabre,

FERDAUS created a false identity,


He opened a PayPal account under this false identity why he was seeking to of a Florida for his son. In June 2011,

and even created a cover story explaining buy this plane. distributor FERDAUS

told representatives the plane

that he was purchasing

(FERDAUS is unmarried

and has no children). facility

FERDAUS also rented a storage Massachusetts,

in Framingham,

under a different

false name, to use to build his Indeed, this is

attack planes and maintain where FERDAUS

all his equipment.

told the UCEs he built the detonation of killing

devices he

supplied to them for the purpose 12. Moreover,

U.S. soldiers. with the

during numerous

recorded meetings in committing

UCEs, FERDAUS attacks. agd


his motivation



told the UCEs that he realized

more than a year

from viewing

jihadi websi tes and v i.deos" "how evil" America As a result, he decided to,

is and that jihad is the solution. in his own words, "terrorize

the United

States by attacking

4AS described below, FERDAUS ordered the explosives and firearms from the UCEs who supplied FERDAUS the materials he had requested at the last meeting shortly before his arrest. SAt a time which predates and CWo his meetings with both the UCEs

6In this context, "jihadi websites and videos" refers to websites and videos promoting violence against non-Muslims, including the United States and other western countries.





that by so doing, he wanted "military center" and to FERDAUS

to "decapitate"

the U.S. government's

"severely disrupt further envisioned killing Americans,

... the head and heart of the snake." causing a large "psychological" including women and children,

impact by whom he referred excitement at

to as "enemies of Allah." the prospect of gunning FERDAUS

FERDAUS also expressed

down politicians confided

at the Capitol

Building. in

Most recently, "making money;"

that he has no interest is, in his own words,

his only desire

to "change

the world" using the skills Allah has given him to strike the "infidels" components by carrying out his planned


and building desire


to kill the "kafir armies.


to attack "I

the United states

is so strong that he confided

to the UCEs:

just can't stop; there is no other choice FACTS SUPPORTING 13. Initially, PROBABLE

for me." CAUSE in conversations against December the United 2010 and

FERDAUS met and engaged his planned attacks occurred between

with an FBI CW7 regarding States.

These conversations

April 2011; the majority Beginning continued 2011. in March

of them were consensually


2011, FERDAUS began meeting

with the UCEs and 28,

to meet with them until his arrest on September of several,

Below is a description and the actions

but not all, of these to complete his planned


taken by FERDAUS

7The CW has a criminal

record and has served time in prison. 10

attacks against 14. meeting

the United

States. This

On January was recorded.

7, 2011, FERDAUS met with the CWo During this meeting, FERDAUS

told the CW

that he was planning

to attack the Pentagon litodisable their explained

using explosive States1]

filled drone airplanes military center.

[the United


to the CW:

It's a small, at that target airplane that will detonate 15. meeting,

drone aircraft that would be programmed and it can just hit that ...a model can carry a good enough payload and it on impact. during the January 7, 2011 recorded


FERDAUS asked the CW how much it would cost to procure to AK-47 assault rifles. grenades FERDAUS asked the the CW With

10 AKs, which refers

CW how much it would cost to procure could procure regards enough explosives

and whether

for an "improvised device, FERDAUS


to an improvised


stated that

"the detonators

are easy" and explained

to the CW that he switch, and

(FERDAUS) would only need a spark plug, mechanical cell phone. 16. On January 11, 2011, at FERDAUS'


the CW

drove to FERDAUS' During

house and picked FERDAUS up so they could talk. meeting, FERDAUS requested the CW s

this recorded


in his planned

attack on the Pentagon

and said that

his goal for the sake of Allah was "to make the plan, to build up the resources CW if he could and do it right." "obtain highly In particular, powder FERDAUS and those asked the [sic]

explosive 11

type of stuff"

for him.

FERDAUS also asked the CW whether that would be able to gather,


(CW) had "a connection material

ah, some

where we can build some of the explosive like three football The CW responded instructed fields,

enough to take

out a target that's one or two blocks?" get back to him. that's important."

say a radius, of

that he

(CW) would have to


the CW to "learn about that, the CW that after


further advised

using the explosives, using "AKs" because

they would

"carry out the rest" of the plan we can take

"once we cut off the military, ..." during this conversation, to blow

care of the politicians 17. FERDAUS In addition, "why

the Cwasked FERDAUS

[he wanted]

[up] the Pentagon."

responded: because that, that's the target to eliminate and terrify all enemies of Allah. We have this project started ... This is, this is what we have to do. This is the righteous way ... [to] terrorize enemies of Allah. 18. On January 20, 2011, the CW met with FERDAUS. At this

recorded meeting,

among other things, FERDAUS attacking

told the CW that he the Capitol to the

(FERDAUS) was considering Building, and a military

a subway station, in addition

base in Colorado

Pentagon and that "it would be nice to ... gun down some politicians ..." he FERDAUS advised the CW that "[t]he main thing" explosive stuff." FERDAUS

(FERDAUS) needed was "high powered

also inquired

about the price of grenades.


also told the



that they needed

to get "a model airplane ... it's programmed,

that can carry

enough weight, and coordinates, 19.

so when it hits the it."

.. , it will detonate during

the bomb and that's

In addition,

the January

20, 2011 meeting, building

FERDAUS advised

the CW that he explosive

(FERDAUS) was considering

his own improvised raise enough money

device if he

(FERDAUS) could not and using such

to buy high powered


a device to attack a subway station. (FERDAUS) wanted "to do that."

The CW asked FERDAUS why he FERDAUS stated:

In response,

cause that would be a huge scare. A huge attack. The point is you want to scare them so they know not to mess with you ... All the kafir [non-believers], in this land, are enemies and if you ... they're all, they're all part of it. They have have killed from us, our innocents, our men, women, and children, they are all enemies. 20. On March 2, 2011, FERDAUS met with the CWo At this

recorded meeting,

the CW met FERDAUS at his house. components


showed the CW electrical

and remote controlled

that he had built and indicated robotics" and enjoyed

that he "used to be into -- taking stuff apart, trying I learned a lot of too.


to do electronics, stuf f on my own 21. advised During

[and] learning on my own.

... from doing it and reading, this meeting,

among other things,


the CW that he

(FERDAUS) needed airplanes

to "find out how much can hold.

[weight the remote controlled) explained

FERDAUS also with

to the CW that he planned

to fill the "airplanes"



"a particular


device or ... handheld

[grenades] 22.



on March 4, 2011, the CW took could conduct was

FERDAUS to a public research recorded. FERDAUS on remote

library so that FERDAUS controlled aircraft.

This meeting

While at the library,

using the library computers, that sold remote controlled could carry approximately but before 38

located a number of websites that such planes

planes and learned to 42 pounds. the library,

After completing FERDAUS erased

his research


the browser history

on the computer as a means to the

he was using and then visited of evading detection. CW's vehicle, FERDAUS

several other websites

When FERDAUS and the CW returned

asked the CW, "How much do you think one that he did not know. FERDAUS

grenade weighs?"

The CW responded

then opined that a grenade might weigh FERDAUS concluded explosive. 23. After leaving the library,

"less than a pound." to make his own

that it would be cheaper

the CW took FERDAUS

to three

stores where they purchased battery, and ammonia.

a spark plug, a relay,

a 9 volt

In addition,

among other things, during (referring

this meeting,

FERDAUS asked the CW to get him "the AK rifle) ... so I can practice.

to an AK-47 assault how to do it." woods somewhere

So I can learn



that he and the CW "go into the [shooting].n

and we'll just practice



On or about March

9, 2011, the CW introduced

two UCEs While to

to FERDAUS as "brothers"

who were "down with the cause./I with the UCEs, FERDAUS

eating lunch at a restaurant the UCEs his plan to attack controlled recorded. 25. On March 16
l 1


the Pentagon using a remote This meeting was


filled with explosives.



FERDAUS met with the CWo


this recorded brothers, brothers



talked to the CW about the "other

i.e., the UCEs.

FERDAUS told the CW that the other


have their own plans, which he would consider, FERDAUS asked for that

but that he thought his idea was preferable. the CW's support of his Pentagon

attack plan and suggested to buy the remote advised

they should both put their money together controlled aircraft. In addition, FERDAUS

the CW that he

was still working 26. the CWo On March During

on building

the detonator

for the explosives.

18, 2011 and March 23, 2011, FERDAUS met with meetings, among other things, to detonate

these recorded

FERDAUS explained

to the CW how he aircraft

(FERDAUS) planned

the remote controlled

by hooking up a cell phone to a powder and could be the CW

rocket motor, which would contain explosive used as the "preliminary drove to Toys motors purpose boom." At FERDAUS'


'R' Us where FERDAUS bought

a rocket and rocket the

to test out his plan. in buying

FERDAUS advised


that his {i.e., so

the rocket was purely

"a diversion"


as not to highlight 27.

his purchase

of the rocket motors) . with the UCEs and

On March 28, 2011, FERDAUS discussed the progress

CW, in the UCEs' vehicle, attack the Pentagon. other things, FERDAUS weekend,

he had made on his plan to was recorded. Among

This conversation

stated that while in New York the prior (which from the context and refers to an

he went to an Internet place

FERDAUS' prior conversation Internet cafe) and conducted secure." FERDAUS indicated aircraft

with the CW, I believe research

"in a way that's more that sells

that he found a website

remote controlled carry a payload

that can fly 100 miles per hour and FERDAUS explained the plane

of up to 50 pounds.

would be filled with 10 grenades using a built-in an aircraft expressed 28. the CWo GPS system.

and that he would further

fly the plane that such



costs less than $3,000. to go overseas

In addition, for training.


his desire On March During

29, 2011, FERDAUS met with the UCEs without meeting, the UCEs questioned FERDAUS and stated

this recorded

FERDAUS about his willingness told the UCEs that he wanted

to carry out his plan. to attack the Pentagon FERDAUS

that no one was forcing him to do it. that he believed that he wanted 29.

further explained capability" and

his plan was "within my unique to victory

"to contribute

for the sake of Allah." during this meeting, the Pentagon

In addition,

among other things,

FERDAUS explained

that he had this idea of attacking


long before he met the CW UCEs). FERDAUS advised

(and by implication


he met the discussed

the UCEs that he had initially

his remote controlled Dorchester. FERDAUS


attack plans with a friend from friend had

told the UCEs that his Dorchester idea" -- his friend's ... a recruitment

a "less complicated weapons and go after

idea was to "just get The UCEs asked FERDAUS that he wanted


FERDAUS what was wrong with that idea, to which responded: "nothing./I FERDAUS indicated,


"to go bigger." interested


FERDAUS advised to Afghanistan

the UCEs that he was the by teaching

in traveling

and assisting whether

"overseas brothers physics or making 30. On April


in a technical



with technology. meeting with the

6, 2011, during a recorded

CW, FERDAUS confided after his planned

in the CW that he intended to train with other

to go overseas Among his that to



other things, during

this meeting,

FERDAUS also discussed

planned attack with the CWo although he still desired

In so doing,

FERDAUS mentioned he wanted

to attack the Pentagon,

conduct a second attack on the U.S. Capitol Building, described as a smaller target. FERDAUS

which he

With regard to his plan to attack stated that he would fly the second

the Capitol Building,

BIn the context of this conversation, I believe "overseas brothers" refers to individuals overseas who share FERDAUS' ideology and are engaged in violent jihad against those viewed as non-believers. 17

plane right into the center of the dome, which would cause it to cave in. FERDAUS advised the CW that he would have to take a bus

trip to Washington, the planes. 31. FERDAUS

D.C., to find a place from which to launch

concluded for the CW:

the April 6, 2011 meeting

with words

of encouragement

nations that were bad, very bad groups of individuals, like say Sodom .. , they be punished with some type of natural disaster. Maybe stones would come from the sky or they get a flood, they get drowned out. For us, we've gotta [sic] do that. Allah has given us the privilege ... he punishes them by our hand. We're the ones. 32. On April 18, 2011, during a recorded that he understood progress" meeting with the



that he needs to show the UCEs "to with

the UCEs "technological propose" FERDAUS,

if he wished

his plan to the other brothers.

(In prior meetings

the UCEs had told FERDAUS that they and "brothers" financial assistance for his

overseas might be able to provide attack plan.) two planes Building.



the UCEs that he now wanted to fly into the Capitol

into the Pentagon FERDAUS described

and one plane

his plan to the UCEs as "simple:" with a GPS system

"My plan is to have a fast model airplane

9During the recorded meetings with the UCEs, FERDAUS often referred to the Pentagon as the np-Buildingn and the U.S. Capitol Building as the nC-Building.n 18

stuffed with handheldslo and it's on a timer and it ... has the coordinates target." "within meeting, research of the targets ... All it has to do is crash into the further advised the UCEs that this plan was In addition, FERDAUS during this


[his] reach" and capabilities. the UCEs inquired on his targets. as to whether

had done "to do

FERDAUS replied

that he needed

more reconnaissance." 33. On April 19, 2011, FERDAUS met the UCEs. this meeting, This meeting the

was recorded. feasability


the UCEs questioned


plan, noting that he responded

(FERDAUS) had manner that

"nothing tangible." he had made progress; three components


in a defensive

said that he knew where to get two of the for his plan, and said that all he FERDAUS acknowledged that

he needed

needed to do was secure some funding. he needed to obtain FERDAUSr however, completion. information


the launch sites. to assistance


his plan as "very close" with the financial


this meetingr purchased

of the UCEs, FERDAUS Washington, 34.

a plane ticket to travel to

D.C. on May 13, 2011. during the April 19, 2011 meeting, with FERDAUS


FERDAUS described

to the UCEs what he hoped to accomplish with regard to the Pentagon attack,

his planned attacks.

lOIn conversations with the CW and the UCEs, FERDAUS used the terms "grenades" and "handhelds" interchangeably. 19

stated: What I envision is that it's going to ... essentially decapitate the entire empire. [It will be the] final nail in the coffin ... because it's going to ... severely disrupt the head and heart of the snake. With regard to the Capitol Building, FERDAUS described this

target as a softer target and that he wished "right place,

to hit it in the ... business as

say the dome" so as to "decapitate impact.

usual" and have a "psychological" 35.

On May 3, 2011, UCE1 called FERDAUS and advised to Boston on May 5, 2011. During this


that he was coming conversation, changed

UCE1 also told FERDAUS that "a lot of things have This was a reference on May 1, 2011. UCE1 began this

... My boss has just been killed."

to the fact that Usama bin Laden had been killed 36. On May 5, 2011, UCE1 met with FERDAUS. with FERDAUS by stating that

recorded meeting are pretty

"right now things

rough" with the death of "our boss. times in prior meetings,

As UCE1 had told


UCE1 again advised that FERDAUS "who do

"You don't have to do this. who he was "dealing with, Hussein

To ensure



UCE1 asked FERDAUS, responded:

you think me and brother

are?l1 FERDAUS

I think you guys are wonderful brothers; and I feel utterly privileged to have met you ... men of the past ... excellent men of the past. And to be more specific, I think you are al Qaeda. 37. After demonstrating his understanding that he was FERDAUS told UCE1

meeting and working

with al Qaeda operatives,


that he had performed report" for UCE1.


for his plans and prepared his report, FERDAUS


In constructing

indicated FERDAUS

that he "tried to cover as much ground as possible." handed UCE1 a thumb drive, which FERDAUS explained contained a narrative of his planned

to UCE1

attack as well as and Capitol Buildings


of his targets

-- the Pentagon

-- and launch sites. information preferred FERDAUS

Included downloaded

on this thumb drive was also from the Internet regarding his


the F-4 Phantom remote controlled of grenades,

aircraft, he

and pictures planned 38.

and specifications

the explosives

to use in the aircraft. In addition to giving UCE1 an electronic copy of his his an

plan, during

the May 5, 2011 meeting, FERDAUS

FERDAUS described

attack plan to UCE1. "excellent an aircraft location"


that he had identified and chosen to

from which to launch his planes the F-4 Phantom,

attack vehicle,

which according Phantom.

FERDAUS was a "1/10th model"

of the U.S. military

FERDAUS told UCE1 that his plan required 4 phantoms. Earth using FERDAUS explained

the purchase

of three F-

to UCE1 that he could use "Google as the plane would be flown

... to pick the coordinates" "GPS." 39. FERDAUS described

the flight plans

for the three F-4


The "trajectory"

of the first plane was to be the intended to hit "at the middle of

Capitol Building,



the dome, IIIIblow[ing] the dome to smithereens. II With regards to the second and third planes, IItrajectoryllof those planes FERDAUS indicated that the

was lIoppositellsides of the Pentagon stated that further

at the lIaltitude of ... the fourth floor. II FERDAUS each plane would be filled with 16 grenades. advised UCE1 that the timing of the detonation planes would be IIthree seconds prior to '" IIdetonation servo II device, 11 the grenades]


for all three

impactll using a lIall the pins [of

which would cause

[to] get pulled out.


also indicated in

that he IIneed[ed] to be able to see what's on the ground" Washington, 40. D.C. to finalize his plans. In addition, during this meeting, this planned FERDAUS



UCE1 his goals in committing the UCE that his plan in the downfall



lIought to terrorize

... it ought to result place. Okay, and attack

of this entire disgusting

that's the goal."

UCE1 noted the likelihood In response, is an enemYi


might kill women and children. that "every kafir kafir [sic] blood [non-believer]

explained llevery it is

therefore, to FERDAUS,

is okay. II In other words,

permissible 41.

to kill women and children. repeatedly emphasized to UCE1 the feasibility FERDAUS stated:


of his plan during

this meeting.

For instance,

llFERDAUS also referred a "high torque servo.

to this device during

the meeting as


IIThis is realistic ...

I can make these things

happen." and


also told UCE1 that his plan was "extremely something


that I really want to do. II FERDAUS, that although



he "was trying to do explosives, IIhe the explosives handhelds and asked that UCE1 that you his of

needed assistance

in obtaining

get him 1148of the most powerful can find." FERDAUS


also indicated

that he could accomplish

attack plan, which in FERDAUS' a lifetime, IIon a quicker of the UCEs. 42. Lastly,

words would be "the achievement with the financial



at the May 5, 2011 meeting,

FERDAUS device that he

demonstrated had built.

for UCE1 a mobile phone detonation FERDAUS described

to UCE1 how it worked

and indicated together.

that he "can instruct"

others how to put such devices MAY 5, 2011 ATTACK PLAN

FERDAUS' 43. I have reviewed

FERDAUS' May 5, 2011 written


plan, which he provided detailed, well-written,

to UCE1.

This plan is extremely with numerous pictures

and annotated

(copied from encyclopedias the Internet) introduction, and diagrams. entitled

or resource materials

from library and an

FERDAUS' plan contains


which states as follows:

The concept is to utilize certain resources seeking the objective of sending 3 aircrafts [sic], 1 to the Cbuilding and 2 to the P-building at particular locations on each, from a similar location, with an effective payload, and all on autopilot. This requires the collaboration of hardware, software, payload and 23

location setups meeting specifications relative to achieving this end. This document shall discuss the specifics of each component with respect to its mission characteristics. As well, as a [sic] financial assessment shall be included. 44. components FERDAUS's written plan is then divided (1) The Aircraft; Configurationi

into the various Hardware;

of his plan: and Aircraft Procedure

(2) Autopilot (4) Software

(3) Hardware (5) Software



(6) Location and

(with highlighted (8) Total

maps, pictures, Financial 45.

and diagrams);

(7) Payload;

Estimate. With regard to "The Aircraft,

FERDAUS wrote:

The preferred aircraft as viewed on the website granted there is still an availability[,] is the F-4 Phantom II, a scale model of the McDonnell-Douglas F-4 Phantom II .... It is a 100%, 1/10 scale model ... [with] speeds up to 160 mph [and its dimensions are] 68 in. Length 44 in. Wingspan. 46. With regard to "Autopilot Hardware,



that "it can come fully assembled, programmable software

and with a gpsl1 and I1runs on such modes as autopilot entered gps

that can execute

where it can fly the aircraft coordinates. 47.

to already




portion of FERDAUS' and photographs

plan included of the Pentagon For example, and the


maps, diagrams,

Capitol Building

as well as the launch site.

text and highlighted describing explosive

map on the next page appear from which FERDAUS

in FERDAUS' plan to launch his

the location laden planes.



Location: A location in the vicinity to the targets has been Located.

3. p}mi)








with superimposed intended

arrows and

text describing



to strike his in his plan. on the

targets with his attack aircrafts These photographs following page.

were also included

and the pertinent

text are reproduced


Now here is a look at the P-building. Notice the washington monument in the back. The building is 5 stories high, and sits in 29 acres with a 5 acre ground in the middle. The circumference is 1 mile. To the right is the destination of aircraft 2. To the left is the chosen destination of aircraft 3. Both are to be on the middle of the sides and at a level where it can arrive on the 4tl• story.

This is a look of the back end facing east. The striking point would be on the side and at the level above. The width where the dome stands is 145ft, 44m, and that could mean the circle or its individual building or more. Notice the washington monument at the far west. This is the destination of aircraft 1.



In the "Payload" could

section of his plan, FERDAUS capacity


that each aircraft

"have a payload

of 10-12 Ibs.,

and thus it is deemed each." FERDAUS

to contain

16 handhelds

[grenades] in how


for the reader, using a diagram,

16 grenades FERDAUS

would be arranged

within each of his three aircraft. would be detonated on the

further explained

how the grenades

using a "high-torque thumb drive pictures grenades 50.

servo motor."

FERDAUS also included for several

and specifications

light weight

that could be used in his plan. On May 13, 2011, FERDAUS D.C. to conduct flew from Boston to his


surveillance He returned

and to photograph

targets and launch sites. 15, 2011. observed During

to Massachusetts

on May

his trip to Washington,

D.C., FBI agents surveillance and

and photographed

FERDAUS conducting

taking pictures Potomac Park 51.

of the Pentagon,

Capitol Building,

and Eastern

(his proposed

launch site) . UCE1

On June 9, 2011, FERDAUS met with the UCEs.

picked FERDAUS up in Ashland Framingham

and drove him to a hotel in During this meeting, FERDAUS

where they met UCE2.

advised the UCEs that he made a thumb drive for them containing his expanded plan and photographs from his Washington, FERDAUS previewed D.C. trip.

At the hotel, using his computer, materials with the UCEs.

these with

After reviewing

these materials

the UCEs, the UCEs drove with FERDAUS to a Framingham



facility FERDAUS had selected components recorded. 52. After getting for his plan.

to build and maintain

the were

All of these conversations

into the UCEs' vehicle,


told UCE1

that he had brought UCES.12 In response,

a mobile phone detonation


for the

UCE1 told FERDAUS that UCE2 had plans for to get more phones from FERDAUS to use out of Iraq.

the phone and was hoping in operations overseas



troops pulling

FERDAUS responded


to that idea: "That sounds more of those devices." devices FERDAUS

excellent ... I can generate acknowledged "brothers"

that his phone detonation

would help the that he could


and advised UCE1 that, provided [phone],13 it wouldn't

find "the right model all" to build them. UCE2, FERDAUS an additional

take much time at at the hotel with

Later, during the meeting that this detonation

explained power

device might require to cause an

source such as a 9 volt battery

12At the May 5, 2011 meeting, FERDAUS had demonstrated a similar "experimentation" detonation device he had built. To build this detonation device, as explained above, FERDAUS purchased a cellular phone, unscrewed the back cover of the phone, and then soldered wires to the phone. FERDAUS explained to UCE1 that when the cellular phone's number is dialed, the phone would send an electrical current through these wires, which would act as the "electrical switch" triggering the detonation for an lED. FERDAUS hid the wires inside the phone for purpose of sending it overseas. 13FERDAUS had explained to the UCEs that some phone models were easier to take apart than others. 28

explosion. 14 53. explained After entering the hotel and greeting UCE2, FERDAUS

to both UCEs how he came up with the idea to prepare FERDAUS decided to write and ...

his May 5, 2011 attack plan in writing. a report to answer any questions "figure out everything including FERDAUS

that "came to

[his] headu

... it takes to build these aircrafts

the load, which is going to be some type of explosive." that his original plan contained "every last


detail" as to how the plan will work and that the only thing he had left to do on the original FERDAUS advised had completed his plan. plan was "reconnaissance." UCE1 in May, he of

the UCEs that since last meeting necessary

the reconnaissance

for the execution

He had arrived

in Washington,

D.C. on Friday, May 13,

2011, and left on Sunday morning. 54. During the June 9, 2011 meeting, FERDAUS described in

detail how he came up with his idea to attack

the united


on his own "a real long time ago," before meeting or CWo FERDAUS stated the following:

either the UCEs

A real long time ago before I met you guys I was walking through the woods one day and I thought I want to do some type of aerial plan. It came to me that I should do some type of aerial assault on particular targets and after a while it all came to me that I should do the P-building as a target and afterwards the C-building as a target and I should continue with this

14During the meeting on this subject, FERDAUS and the UCEs discussed that such a refinement of the device could be done overseas so as to avoid detection in transit.


the aerial assault. I already knew about this technology [referring to the remote controlled aircraft] from previous research going on the internet and I was, like, this is perfect. This could easily work. FERDAUS technology further advised the UCEs that he considered aircraft) this

(i.e., remote controlled

IIquite s Le " and aptitude ...

noted that although

"you do need to have a certain

I've been doing this type of stuff since I was a little kid." 55. In addition, during this meeting, FERDAUS extensive area. told the UCEs surveillance As a

that during his trip to D.C., he conducted of the Pentagon and even walked

in a restricted

result, FERDAUS decided

that "more stuff ha[d] to be done;" his so as to "totally ... cut out ...

plan needed to be expanded everything of the snake."

Thus, FERDAUS decided

to couple his FERDAUS

"aerial assault" indicated

plan with a "ground directive." involved

that his ground assault firearms

the use of six people, into two teams.

armed with automatic FERDAUS described

and divided

his expanded

attack as follows:

with this aerial key locations of in order to take only as a squeeze isolated, they'll Once isolated,

assault, we can effectively eliminate the P-building then we can add to it out everything else and leave one area where the individuals will be be vulnerable and we can dominate. to 110pen up on them" and "keep FERDAUS

FERDAUS planned

firing" to create provided

"chaos" and "take out" everyone. version 30

the UCEs an electronic

of his new expanded plan

on a thumb drive, which he summarized


this meeting. to use grenades during this as



initially planned

the explosive meeting,

component advised

in his attack planes,


the UCEs that he thought explosives

it would be

"better" to use homemade Because of public to experiment homemade 57. safety

rather than grenades. FERDAUS not

issues, the UCEs admonished or to attempt

with any chemicals

to create his own

explosives. Lastly, among other things, during this meeting, facilities and

FERDAUS told the UCEs that he researched located one in Framingham components advised facility


to use to receive and store the the aircraft. FERDAUS

for his plan and build/design

the UCEs that he had spoken to the manager and told the manager that FERDAUS intended

of the storage to use the

rented space for "music." JUNE 9, 2011 SURVEILLANCE




I have reviewed

the contents

of the thumb drive FERDAUS This thumb drive D.C. trip

gave to the UCEs at the June 9, 2011 meeting. contained a detailed report of FERDAUS'


documenting visitedt

every aspect of his trip

(i.e., every location he how he accessed

what he observedt

people he encounteredt

the locations

and the photographs

he took)15 and his expanded

15An example of one of the photographs Pentagon is attached hereto as Exhibit 3. 31

he took of the

attack plan. that the

In his June 9, 2011 attack plan,



[o]verall goal is to shut down this target by eliminating key entrances/exits

[referring and as many an or

to the pentagon] individuals

as possible." divided

FERDAUS' attack plan includes into fifteen separate phases

"Order of Actions" "steps" detailing the attack, 59.

what actions would occur during

each phase of

as well as a time table.

On June 15, 2011, FERDAUS called UCE1 and requested so he could start working on obtaining

that UCE1 wire him money the components

for his attack plan.

Later on June 15, 2011, and phone number UCE1 to send the

FERDAUS provided

UCE1 with the name, location,

of the money transmitter money. 60.

to which FERDAUS wanted

On June 17, 2011, FERDAUS told UCE1 during a telephone which FERDAUS had initiated, that he was "100%"

conversation, committed

to the plan and that he "really want [ed] to get the Based upon the context of this conversation, I

custom cars." believe aircraft

that "custom cars" refers to the remote controlled FERDAUS planned to use to attack the Pentagon and

Capitol Building. telephone

In addition,

during the June 17, 2011


FERDAUS also asked UCE1 to provide him space to

(FERDAUS) with $450 so that FERDAUS could rent storage build and maintain his attack aerial vehicles. by UCE1r FERDAUS

Later that day,

using money supplied

rented a storage unit at a


storage facility 61. UCE11s

in Framingham,


under a false name. on

On June 20, 2011, FERDAUS left a coded message the following:

phone stating

Are we good to go on vehicles [i.e., the remote controlled aircraft]? The customers want to know and also if I am able to fix the engine and the transmission can you do everything else [this refers to obtaining the explosives and weapons for FERDAUS' attack plan] to have in time for when the customer wants it? They really want it bad on that date because they want to take it ... There is a car show actually tha t they have.16 62. On June 27, 2011, FERDAUS met with the UCEs. this one was recorded. Shortly Like the

prior meetings,

after getting

into the UCEs' vehicle,

FERDAUS told the UCEs

"I want to give you

guys some little gifts here, okay, one for each of you -- one for [UCE1] and one for [UCE2] .1117 FERDAUS handed UCE2 device and handed UCE1 a key to the storage facility.

another cell phone detonation

space FERDAUS had rented at the Framingham FERDAUS explained overseas

to the UCEs that the phone it was "unlocked." FERDAUS

"can be used tested the phone in that it In


the presence

of the UCEs using LED lights to demonstrate an explosion the device, if plugged

would work and trigger reference to building

into an lED.

FERDAUS assured

the UCEs, "I

160riginally, FERDAUS had indicated that he wanted to launch his attack on July 5, 2011 to coincide with the Independence Day holiday. 17The undercover names of the FBI UCEs have been redacted. 33

did this all by myself. II 63. After FERDAUS had delivered device and demonstrated the the

cellular phone detonation UCEs falsely advised

(his second such delivery),


that the other phone detonation

device he had supplied

had IIworked.

The UCEs falsely

told and

FERDAUS that his device had killed three U.S. soldiers injured four or five others. FERDAUS was visibly

excited by this the

news and told the UCEs he felt lIincredible world. II The UCEs asked FERDAUS whether people. two more FERDAUS responded [phones] today.1I

welre changing

he was okay with killing

"yes" and indicated FERDAUS advised


... get

the UCEs that the

phone he had just delivered the other

to them was the IIsame exact build as than the other

[phone] IIbut it IImight even work better" the IIcurrent might be higher this meeting,

one because 64.

than the other one. II FERDAUS that the

Later during

UCE1 advised devices

they needed two more phone detonation "brothers" overseas wanted


to do at least two more


FERDAUS told the UCEs that he was 11100%11 at "peace" with the fact that his devices are killing American soldiers. FERDAUS stated,

this is exactly what I wanted and I feel so blessed ... I feel that Ilm seeing the fruits of my labor ... I want to work with you guys and I want to hit the snake on the tail and I want to choke it right in the head ... The world will never be the same. 65. grenades Additionally, the UCEs and FERDAUS discussed whether

are indeed the best explosive 34

to be used in the aircraft

attack vehicles

FERDAUS was constructing. to use plastic


concluded rather than the UCEs


it would be "excellent" grenades provided instructed FERDAUS

explosives Because

they are "obtainable." not to experiment

with any chemicals,


said that he was relying upon the UCEs to obtain FERDAUS told the UCEs that he also needed nautomatics," a side arm with a silencer,

the explosives. six for

two vans,

and nine grenades what he

his attack plan.

The UCEs asked FERDAUS to describe FERDAUS explained

meant by "automatics." automatic firearms,

that he wanted


which you "squeeze and

[they] keep going." was "good machine

FERDAUS also told the UCEs that what he wanted guns that are 66. ... of good weight and good use." then brought


the UCEs to the storage

unit it.

FERDAUS had rented FERDAUS advised

in Framingham

so the UCEs could inspect

the UCEs that he had paid for the unit in cash but avoided providing an and

and had to fill out some paperwork address by telling

the storage manager

that he was "homeless"

"sleeping at a friend 1 shouse. 67.

On July 21, 2011, FERDAUS met the UCEs. FERDAUS



recorded meeting,

advised the UCEs that he had ordered a supplier of "fully FERDAUS

two more phones online assembled" forwarded

and he identified planes

remote controlled

"in Florida."

to UCEI via e-mail a copy of price quotes he had for two Sabre

received under the false name of "Dave Winfield,"


(F-86) remote controlled FERDAUS explained


and one F-4 Phantom


that he intended to purchase

the F-4 Phantom to

use to attack the C-building to attack the Pentagon. to order one Sabre plane plane would be delivered 68. FERDAUS

while the two Sabres would be used the UCEs that he planned

FERDAUS advised first.

FERDAUS told the UCEs that this facility. telephonic In these

to the storage


that he had numerous in Florida.

conversations communications,

with plane distributor FERDAUS advised

that he had made up a cover story that

for his plane purchases. he was planning unmarried 69.

FERDAUS told the plane distributor the planes for his son.

to purchase


and has no children) . During this meeting, UCEl gave FERDAUS $4,000 ln cash in turn to a PayPal

to place the order for the F-86 Sabre, which FERDAUS deposited into his bank account and then transferred After conducting these

account held under an alias. transactions, FERDAUS

allowed UCEl to look up FERDAUS' FERDAUS provided


account information. password verified

UCEl both the e-mail and PayPal account history

for his PayPal account. that FERDAUS


(under the name Dave Winfield)

had indeed to the plane two

placed an order for the plane, that a $3,000 payment distributor was then pending,

and that FERDAUS had ordered

phones using his PayPal account 70. In addition, during

for a total price of $49.50. FERDAUS explained

this meeting,


that "because

[he] want [ed] to blow up parts of the building and make it so it can't be used

... ...

[referring to the Pentagon]

so instead of using those grenades use something that's like a plastic to maximize

... I think we should try to [explosive].11 the explosive FERDAUS told

the UCEs that he wanted attack planes

impact of his

and thus, wanted the UCEs to get him "24 pounds" of 15 pounds of the explosives

plastic explosives. planes -- 115pounds

were for the to

per plane.

FERDAUS said that he planned

use the remaining surrounding

9 pounds of explosives

to blow up the bridges the UCEs that,

the Pentagon.

FERDAUS further advised

through his planned

aerial and ground attack,

he "want [ed]

to ...go for the throat, you know, we go for the center." 71. FERDAUS was anxious to know how his second detonation "Do you know how that The UCEs

device had worked. 18 He asked the UCEs, the phone, indicated

the blue one, -- the other phone did?1I that they believed

it had been used in Iraq but didn't FERDAUS that they would find out

know the results.

They assured

for their next meeting. 72. On August I, 2011, FERDAUS met with the UCEs. FERDAUS During

this recorded meeting, increase his production

told the UCEs that he wanted to devices.

of the cellular phone detonation

18Indeed, since this meeting, during numerous telephone conversations between FERDAUS and UCEl, FERDAUS has asked how his detonation device worked.


He stated: I got this idea ... I think that I should really up the phone production [and] try to do as many phones as I can and obviously as many as we can ship across or bring across. FERDAUS suggested the phones" that he could either send a shipment overseas devices or send them FERDAUS of "just

and he could send the brothers


on how to make the detonation "pre-packaged

one box of "50 phones" indicated that he could

and all ready."

"write instructions"

or make a video on In these to the

how to construct instructions,

the cell phone detonation



told the UCEs that he could explain

"brothers" how to make the detonation types of phones. 73. meeting,

devices using different

FERDAUS again asked, as he had during whether

the July 21, 2011 overseas. that it

his second phone device had worked

UCE2 falsely told FERDAUS had "killed Americans responded 74.

that it had worked perfectlYi

and they are asking

for more. II FERDAUS

IIThat's excellent. II During this meeting, FERDAUS brought and delivered The UCEs had

three more phone detonation only asked FERDAUS determined detonation for two.


to the UCEs.

FERDAUS advised

the UCEs that he had by creating FERDAUS cheaper

that he could

IIreally contribute" Indeed,

devices using Tracfones.

told the a

UCEs that he had gone to CVS on that day and had bought



on sale for less than ten dollars.


said that he

had taken this phone to the storage unit and built the detonation device before meeting devices he supplied "once [you] dial 75. FERDAUS the UCEs. With respect to the three the UCEs that

to the UCEs, FERDAUS assured

[the] number, advised

[they] will detonate.

the UCEs that he could make

"20 to 30 UCE1 with the

[detonation devices] questioned

per week" at the storage unit.

FERDAUS as to what he wanted to accomplish devices. FERDAUS explained:

phone detonation

I want them [the detonation devices] to have a huge punch in a short period of time; say like 10 one day and 10 the next day and so forth ... I want to hit the kafir armies [and kill] as many people as possible ... If you get a lot of them in a short period of time maybe, you're really going to hurt them hard. UCE1 also asked FERDAUS, responded, I want to totally destroy [and] take out the enemy and kill as many as kafir [non-believers] as possible. And that's why I thought that if I could do this thing with the phone thing, we could make a huge change in the world. Imagine if our brothers were able to set off 20 phones [detonation devices] in a day at a time. 76. had started last year. I realized I should try to do something to attack them here. I should try to go down to Washington or something like that. I should try to get them here. That is the best thing. FERDAUS told the UCEs that from visiting and viewing jihadi During this meeting, FERDAUS revealed that his jihad "what do you want to do?" FERDAUS



he "realized FERDAUS


... evil" America

is and that jihad is

the solution. make money;


the UCEs that he is "not trying to

he is "trying to change the world. that "Allah ha[d] shown then stated:



stated his belief productive.

[him] how to be


"I just canlt stop; there is

no other choice 77.

for me." 2[ 2011[ FERDAUS met with the UCEs. meeting[ among other things[ the UCEs balance on the

On August

During this recorded provided

FERDAUS with $3500 to pay the remaining aircraft

F-86 remote controlled Additionally[ during

FERDAUS had ordered. FERDAUS told the UCEs that he to as "plastic

this meeting[

now needs 25 pounds plastic explosives) that for him. 78. devices On August

of what he referred

(i.e. [

for his attack plan and asked them to get

24[ 2011, FERDAUS delivered

2 more detonation

to the UCEs with the intention

that they be used in

attacks on U.S. soldiers 79. On August

located overseas. aircraft

29, 2011, the F-86 remote controlled storage facility

was delivered rents a unit. containing facilityls

to the Framingham On August

where FERDAUS the boxes

31[ 2011[ FERDAUS obtained airplane

the F-86 remote controlled management

from the storage and moved

who had signed for the packages unit.

them into his storage 80. On September

20, 2011[ FERDAUS made a training





on "how to make cell phone detonators" to be al Qaeda operatives. After

for the UCEs who he believed making

this video, which was filmed by one of the UCEs, FERDAUS mobile phone detonation on September device to UCE2.

gave an additional 81.

As instructed,

28, 2011, the UCEs obtained 3

the explosives grenades,

and firearms

(25 pounds of C-4 explosives, AK-47 assault rifles) that

and 6 fully automatic

FERDAUS had requested

for his attack plan.


delivering them.

them to FERDAUS,19 the UCEs allowed FERDAUS After inspecting storage unit. and firearms arrested. CONCLUSION 82. Based on the information I believe described the components, FERDAUS

to inspect

FERDAUS brought

them to his


took possession

of the explosives

and locked them in his storage unit, FERDAUS was


and on my cause to

training and experience, conclude (a) that REZWAN

there is probable

FERDAUS: 2011 and

from no later than in or about March until in or about September attempt

continuing maliciously

2011, did buildings, to wit,

to damage and destroy

the Pentagon possessed,

and U.S. Capitol Building,

which are owned and States using

in whole or in part, by the United

19A1though FERDAUS asked the UCEs 25 pounds of C-4 explosives, the UCEs only delivered 1.25 of actual C-4 to FERDAUS. 41



an explosive (b)

in violation

of 18 U.S.C.

§844(f) (1);

from no later than in or about March 2011 and until in or about September interfere 2011, did, with the the national to injure


intent to injure,

with, and obstruct attempt

defense of the United and destroy national in violation (c)

States, willfully defense premises, §2155; and

to wit, the Pentagon,

of 18 U.S.C.

from in or about June 2011, and continuing 2011, did knowingly material

through in

or about September attempt to provide

and unlawfully (as that

support and resources

term is defined detonation training, terrorist

in 18 U.S.C. weapons,

§2339A(b) (1)), to wit, communication and advice, equipment, to a foreign


and expert assistance organization,

namely al Qaeda, devices

in that defendant

FERDAUS provided


and a training video on whom he believed to

how to build such devices be members of al Qaeda,

to individuals

in violation


of Investigation of September

Sworn and subscribed 2011.

before me