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1 THOMAS E.

MOSS
UNITED STATES ATTORNEY 25$, /;,;;; _ , , ^,
2
KIM R. LINDQU1ST
3 ASSISTANT UNITED STATES ATTORNEY ;C
^•"'•i- ...; '.' . " ; '•' •

4 TERRY L. DERDEN Cl r, «'.:.
FIRST ASSISTANT UNITED STATES ATTORNEY
5 and CRIMINAL CHIEF
6 DISTRICT OF IDAHO

7 DAVTDB, DETTCH
TRIAL ATTORNEY, UNITED STATES DEPARTMENT OF JUSTICE
8
WELLS FARGO BUILDING
9 877 WEST MAIN STREET, SUITE 201
BOISE, IDAHO 83702
10 TELEPHONE: (208) 334-1211
MAILING ADDRESS:
11 BOX 32
BOISE, IDAHO 83707
12

13
14 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF IDAHO

15

)) SECOND
cr.No.CR 0 3 ~ 0 0 4 8 f c C - E M*•
16 UNITED STATES OF AMERICA,

17
Plaintiff,
SUPERSEDING INDICTMENT
18 vs.
(Viu. 18 U.S.C. 371 , 956, 2339A,
19
SAMT OMAR AL-HUSSAYEN, 233915,1546(a), 1001(a)(2), 3237,
3238)
Defendant
20
21
Tllli GRAND JURY CHARGES:
22
COUNTS 1 THROUGH 3:
23 THE MATERIAL SUPPORT AND RESOURCES CHARGES

24 Introduction

25 1. From on or about September 13, 1994, to on or about February 26, 2003, the defendant,

26 SAMI OMAR. AL-HUSSAYEN, provided and conspired with others to provide material support and

27 resources (a) to persons engaged in acts of terrorism and (b) to at least one prohibited terrorist

28 1

fy
1 THOMAS E. MOSS
UNITED STATES ATTORNEY
2 -3 #/
KIM R. LINDQUIST
3 ASSISTANT UNITED STATES ATTORNEY
4 TERRY L. DERDEN 1'-'• .1(••"•
,V
FIRST ASSISTANT UNITED STATES ATTORNEY
5 and CRIMINAL CHIEF
6 DISTRICT OF IDAHO
7 DAVID B. DEITCH
TRIAL ATTORNEY, UNITED STATES DEPARTMENT OF JUSTICE
8
WELLS FARGO BUILDING
9 877 WEST MAIN STREET, SUITE 201
BOISE, IDAHO 83702
10 TELEPHONE: (208)334-1211
MAILING ADDRESS:
11 BOX 32
BOISE, IDAHO 83707
12
13
14
15 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF IDAHO

16 UNITED STATES OF AMERICA, CT.NO. C R 0 3 - Q U 4 8 - C - E J L
17 Plaintiff, SUPERSEDING INDICTMENT
18 vs. (Vio. 18 U.S.C. 371 , 956, 2339A,
1546(a), 1001(a)(2), 3237, 3238
19 SAMI OMAR AL-HUSSAYEN,
20 Defendant.
21
22
THE GRAND JURY CHARGES:
23
24
At all times pertinent to this Superseding Indictment:
25
26
27
28
AO 106 (Rev. 7/87) Affidavit for Search Warrant

United States District Court
DISTRICT OF IDAHO

In the Matter of the Search of
(Name. addiuss ur Uriel descripifort oi person, property or premises to be searched)
APPLICATION AND AFFIDAVIT
A white 1992 Pontiac Bonneville 4-door sedan FOR SEARCH WARRANT
bearing Idaho license plate # 1L57028 and
VIN1G2HX53L1N1273021 CASE NUMBER: £(2, & £ ..

I, Michael E. McLennan . being duly sworn, depose and say:

I am a(n> Special Agent of the Federal Bureau of Investigation and have reason to believe

that on the person of or X on the property or premises known as (nama. description and/or location) a white 1992 Pontiac

Bonneville 4-door sedan bearing Idaho license plate # 1L57028 and VIN 1G2HX53L1N1273021,

in the District of Idaho ,

there is now Concealed property, namely (ctescrifte Ihe person or property to be wired)

See Attachment A,

which is (state one or more bases for search and seizure set forth under Rule 41 (b) of the Federal Rytes of Criminal Procedure) property that Constitutes

evidence of the commission of a criminal offense; or the fruits of crime or things otherwise criminally possessed; or property

designed or intended for use or which is or has been used as the means of committing a criminal offense,

concerning a violation of Title 18 . United States Code, Section(s) 1001 faM1) and (2). and 1546(a) . The facts to

support a finding of Probable Cause and the issuance of a Search Warrant are as follows:

See Attached Affidavit of Special Agent Michael E. McLennan.

Continued on the attached sheet and made a part hereof. ._X_. Yes No

Signature of Affiant

Sworn to before me, and subscribed in my presence

February 21.2003 at Boise. Idaho
Date City and State

Mikel H. Williams
United States Maistrate J u d e
Name and Title of Judicial Officer Signature of Judicial Officer
Electronic lik evidence, nidudin.if compiuer;, hird drives. 50th\are and storage advices (rr.onncr.
keyboard, central processing unii (CPU;, modem, diskettes, laser disks, external dnvex, tape.1;, hard
disks arid others).

.Documents and things, electronic or otherwise, containinginformationrelating to SAJVfl OMAR AL-
HUSSAYEN's computer website and business activities with the IANA and other organizations
and/or individuals that go beyond his statedpurpose for entering and remaining in the United States,
including, but not limited to, the following:

Books, records, receipts, ledgers, buyer lists, seller lists, address books, airline tickets,
vehicle rental, receipts, credit card receipts, hotel receipts, meal receipts, travel agency
vouchers, travel schedules, diaries, phone tolls, telephone answering tapes, records pertaining
to wire transfers of money, money order receipts, cashier's check receipts, documents
relating to domestic or foreign travel, documents relating to the expenditure of funds,
documents containing names and/or information relating of business associates, any and all
state or fcdera] tax returns and/or records or data which could have been or could be used to
prepare tax returns for the years 1995 to the present, corporate charters, corporate minute
books, corporate ledgers, any records of corporate ownership and official corporate actions,
photographs, videotapes, personal correspondence;

.Financial records, including, bill not limited to, the following: credit card documents,
deposit books, income records, expense records, canceled checks, bank statements, records
of wire transfers in/or out, debit memos, credit memos, cash receipts, cash expenditures,
records of savings accounts and certificates of deposit (includingpassbooks and statements),
log books, records of attendance and/or membership at fund raising events or conventions,
real property purchase and/or sale documents, investment documents, stock documents,
purchasing account documents, bank account documents, loan documents (including
applications and supporting documents), financial statements, balance-sheets, income
statements, audit reviews or reports (including supporting documents), phone cards, phone
card records, travel-related documents, payroll documents, correspondence and/or notes
reflecting financial transactions and/or instructions, any such .financial records relating to
associates of SAMI OMAR AL-HUSSAYEN;

SAMT OMAR ALJTUSSAYEN's passport, student copies of his JNS 1-20 forms and any
related non-immigrant documents;

ATTACHMENT'A'
1
2 STATE AND DISTRICT OF IDAHO
3 BOISE, IDAHO
4 UNITED STATES OF AMERICA )
5 v- )
6 SAMI OMAR AL-IIUSSAYEN )
7

8

9 AFFIDAVIT
.10 I, MICHAEL E. MCLENNAN, the undersigned, being duly sworn, depose
11 and state as follows:
12 1 am a Special Agent of the FBI currently assigned to the Boise, Idaho,
13 Resident Agency of the Salt Lake City Division. I have been a Special Agent of the FBI Tor
14 six years and have been involved in multiple investigations involving crimes under Title 18
]5 of the United States Code. This Affidavit is based upon facts acquired by fellow FBI
16 Special Agent Michael James Gncckow and other law enforcement officials pertaining to
:iv the investigation. On February 21, 2003, Special Agent Michael James Gneckow advised
18 your affiant of the following:

19 1) Gneckow is a Special Agent with the Federal Bureau of Investigation
20 (FBI), currently assigned to the Coeur d'Alene, Idaho Resident Agency, within the FBI's Salt.
21 Lake City Division. He have been a Special Agent with the FBI for six (6) years and has
22 :cn (10) additional years of Federal law enforcement experience as a Special Agent with the
23 U.S. Naval Criminal Investigative Service (NC1S). He has a Masters Degree hi National
24 Security Affairs and have spent the majority of his career investigating matters relating to
25 the national security of the United States.
26 2) Based upon his own observation and those of other law enforcement
27 officers involved in the subject investigation, this affidavit is made in support of an
28 application for search warrants to search the following three locations (collectively the
Pittsburgh Tribune Investigation
A call for 'holy war1
By Betsy Hiel and Chuck Plunkett Jr.
TRIBUNE-REVIEW
Sunday, August 4, 2002

In July 2000, the last edition of Assirat Al-Mustaqeem, an Arabic-language magazine
published in Pittsburgh, advocated jihad - "holy war" - against the West.

Ten months later - and four months before Sept. 11 — the Islamic Assembly of North
America (IANA) posted Web-site justifications of "martyrdom operations," such as
crashing an airplane "on a crucial enemy target."

Like all extremists, radical Islamists speak with hateful tongues.
""'!<?' o •'"
But the militancy promoted in Assirat Al-Mustaqeem (The Straight Path) between 1991
and 2000 alarms experts consulted by the Pittsburgh Tribune-Review. They say it echoed
the virulent anti-Americanism of Osama bin Laden's videotaped rants - years before he
became the global face of terrorism.

The magazine's quality, its duration and its presence in an American city such as
Pittsburgh surprise them, too.

More disturbing, an eight-month Trib investigation found close connections between
Assirat and Islamist organizations such as IANA across the United States. Those groups
endorse an extreme strain of Islam — one that labels the United States an enemy, defines
American values as evil and clamors for "holy war."

Assirat and IANA maintained close operating ties for years. A number of Assirat writers
left Pittsburgh to work for IANA in Michigan •- and for an Islamic charity in Illinois that
U.S. authorities accuse of terrorist ties.

Several experts say the movement between groups suggests a loose network intent on
radicalizing Muslims here and abroad.

Some of those individuals and groups are under surveillance by U.S. authorities, sources
say. An FBI spokesman in Pittsburgh "cannot confirm or deny" a local investigation.

In addition, the magazine cast a shadow over two other Pittsburgh organizations:
Attawheed Foundation, made up mostly of Middle Eastern graduate students at local
universities, and Al Andalus School, attended by many of their children.

Attawheed members deny ties to Assirat or extremism. But Assirat's publisher and editor
were officers of Attawheed; one of its writers taught at the school. The school's Web site
Groups" relationships raise questions
By Betsy Kiel and Chuck Plunkett Jr.
TRIBUNE-REVIEW ;v v
Sunday, August 4, 2002 : ;

At the end of a wooded, one-lane road in Green Tree, Attawheed Foundation - dominated
by Saudi students at area universities - plans to expand its operations. Its intended
headquarters is a million-dollar property that once hosted an American Legion post.

Attawheed (pronounced "aht-taw-HEED") has grown from a student club in the 1980s
into a well-financed foundation. It has shared board members with Al Andalus, an
Arabic-language elementary and middle school opened here in 1990.

Like many religious groups, Attawheed (Arabic for "the oneness of God") sees its
mission as spreading the faith — in this case, Islam. Its Web site talks of providing a
mosque, a school and living quarters for'Muslims in "bilad al-kufr" - the "land of
infidelity." ^ rf ~<

But Attawheed and Al Andalus School are overshadowed by Assirat Al-Mustaqeem, the
Arabic-language magazine once published in Pittsburgh.

"The magazine is shut down for two years now," says Nazeeh Alothmany, Attawheed's
spokesman. "What do we have to do with it?"

The answer is three things: people, ideology, and ties to other groups.

Two Attawheed officers ran Assirat, and some writers for the magazine attended
Attawheed's religious services. At least one Assirat writer taught at Al Andalus, and the
school posted Web links to extremist groups embracing Assirat's ideology - links that a
school official could not explain and-that remained in place until pointed out by the Trib.
• ,i'<:: ... _ t
Attawheed also maintains close ties to the Islamic Assembly of North America, an
Islamist group associated with Assirat.

Only two Attawheed representatives agreed to be interviewed for this article, and both
denied any extremist connection. They objected to the Trib's translations of Arabic words
and dismissed questions about their activities as anti-Muslim.

Experts consulted by the Trib disagree, however.

Mary-Jane Deeb, an Arab specialist at the Library of Congress, is disturbed by the
school's Web links to what U.S. authorities define as terrorist groups. Deeb - who
stresses her views are personal, not official - thinks the aim was to mobilize "young
people ... to become mujahideen."
Magazine writers moved on to Islamist groups
By The Tribune-Review
Sunday, August 4, 2002

YPSILANTI, Mich. - A militant religious message is spread worldwide from this city
outside Detroit by a group of Islamists with connections to Pittsburgh.

Working hi the onetime office of an accountant, the Islamic Assembly of North America
promotes its views through books, magazines, Internet sites, a radio program, a prison
ministry and conferences.

Two Algerians who wrote for Assirat Al-Mustaqeem, the Arabic-language magazine
once published hi Pittsburgh, are now on lANA's staff. They are among a number of
former Assirat staff and other men who have moved between Pittsburgh and other U.S.
cities, associating with organizations or individuals with known or suspected ties to
Islamist movements.

Other names connected with IANA have surfaced repeatedly over a decade with Islamist
movements in the United States and in Middle Eastern countries.

The two former Assirat writers are just the latest incarnation of a Pittsburgh-connected
relationship that began in the 1990s.

Assirat regularly published articles about IANA; lANA's officers contributed articles to
the magazine or sat on its advisory board., :

The relationship did not end when Assirat folded in July 2000.

Attawheed Foundation, made up mostly of Saudi graduate students attending Pittsburgh-
area universities, retains IANA as one of two beneficiaries of its assets. Attawheed also
listed IANA as a financial reference for donors, .And ,A1 Andalus, the private school in
Pittsburgh attended by many Attawheed members' children, maintained links on its Web
site to LANA's Internet sites.

One IANA site reprinted three fatwas — Islamic legal opinions — that encouraged
"martyrdom" attacks against enemy targets just four months before Sept. 11. Among the
examples cited in one fatwa was the crashing of an airplane into an enemy target.

Spokesmen for Attawheed insist "no special relationship" exists between their foundation
and IANA.

But an IANA employee said he is familiar with Attawheed and described the two groups'
relationship as financial.

Like a 'father'
INTERNATIONAL POLICY

$2.50
REPORT January 2003
Dirty Money and Its Global Effects
By Raymond Baker
Brionne Dawson, Research Associate
Ilya Shulman and Clint Brewer, Interns

Preface
The globalizing era has produced an sums from the southern hemisphere into the north-
explosion in the volume of illegitimate ern hemisphere, finances current wars and con-
commercial and financial transactions, flicts in Latin America, Africa and Asia, and played
North American and European banking and an enabling role in the events of September 11,
investment institutions have been flooded 2001. That tragedy led to the greatest assault ever
with laundered and ill-gotten gains, on a network that generates and utilizes money for
Amounting to trillions illegal purposes. And yet in
of dollars, most of these the midst of the post-Sep-
sums are generated tember nth pursuit of ter-
through secretive ar- rorist funds, Osama bin
rangements between co- Laden said that attempts
operating but distant to find and freeze such as-
private-sector entities. sets "... will not make any
Lagging legal codes have difference to Al Qaeda or
proven inadequate to other jihad groups. Al
deal with the situation. Qaeda is comprised of
Much of this subject is modern, educated young
taboo in business and people who are as aware of
government circles, yet the cracks in the western
this torrent of stolen, financial system as they
disguised and hidden re- are of the lines in their own
sources poses a major hands. These are the very
Compliments of Matt Wuerker
risk to state security, flaws in the western finan-
corporate stability, de- cial system which are be-
mocracy, free enterprise, the effectiveness coming a noose for it."
of international aid programs and the lives Given political will, these "flaws" can be
and well-being of billions across the world. largely corrected.
International financial statistics can neither Dirty Money
clearly trace the flow of illegal money nor firmly
establish its total magnitude. However, we do know "Dirty money" is money that is illegally
its effects. We know, for example, that it drives the earned, illegally transferred or illegally utilized. If
drug trade, has moved hundreds of billions of dol- it breaks laws in its origin, movement or use, then
lars out of Russia in recent years, has shifted vast it qualifies for the label.
FindLcrw
WWW.FINDLAW.COM
[THOMAS E: MOSS U.S. «.y-^-••-"•>
. 1 --^ r-^ •— ! . "—.

' UNITED STAXES ATTORNEY
KIMR-LINDQUIST
ASSISTANT UNITED STATES ATTORNEY- .
B.FS S3 P - : r ! .
. 3 TERRY L.DERDEN
FIRST ASSISTANT UNITED STATES ATTORNEY
4 . • and CRIMINAL CHIEF
DISTRICT OF IDAHO -
.5 WELLS FARGO BUILDING
877-WEST MAIN STREET, SUITE 201 •
6 BOISE, IDAHO 83702 '
TELEPHONE: (208)334-1211
7 MAILING ADDRESS:
BOX 32
"8 BOISE, IDAHO 83707
9
-.•iq
11
UNTIED STATES DISTINCT CplXRT FOR THE DISTRICT OF IDAHO
. 13

is UNITED STATES OF AMERICA.
INDICTMENT'

15
vs. (Vjo. 18 US.C. I5dg(a); igol(a)(l) aad
(1), 3237 and 3238)
SAM OMAR AL-HUSSAYJEN,
.'iff
17 Defendant

18
19
THE GRAND JURY CHARGES: ,
20

•21
At all timfes pertinent to this Indictmajxt:, -
22
23
^ISA FRAUD AJND.FALSE STATEMENT ' ' • .
The Student Visas
25
Backgrtumd , •
25
1. Ill order for a foreign student to study in the United States on an F-1 student visa
27

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