lN THE UNITED STATES DISTRICT COURT FOR THE
EASTERN DISTRICT OF VIRGINIA
Alexandria Division
UNITED STATES OF AMERICA > CRIMINAL NO. 03 -
>
V. > Count 1: 18 USC $371
> Conspiracy
RANDALL TODD ROYEl$ >
(Counts 1-3, 5, 11, 16,23,27-28, 30, 33-37)) Counts 2-5: 18 USC $960 Commencing
> Expedition Against a Friendly Nation
IBRAHIMAHMEDAL-HAMDI 1
(Counts 1,3, 12, 16,24, 27, 32, 38) ) Counts 6-10: 18 USC 924(b) Receipt
> or Ammunition with Cause to Believe a
MASOUD AHMAD KHAN > be Committed Therewith
(Counts 1,3,5, 16,25,34-37,42) )
> Counts 11-12: 18 USC 924(g) Acquisition
YONG KI KWON 1 Firearm after Arrival from Foreign
(Counts 1,3,5, 11, 13-14, 16,28,35) ) Intent to Engage iu Crime of Violence
>
MOHAMMED AATIQUE > Counts 13-15: 18 USC 924(h) Transfer of
(Counts 1, 5, 16, 34-35) > Firearm for Use in a Crime of Violence
>
SEIFULLAH CHAPMAN > Count 16: 18 USC 4 924(o)
(Counts 1,3-5, ll-16,29,32) > Conspiracy to Possess and Use a Firearm in
> Connection with a Crime of Violence
HAMMAD ABDUR--EM >
(Counts 1,3,5,7-11, 13-14, 16, 18-20,40) ) Count 17: 18 USC $ 1001(a)
> False Official Statement
DONALD THOMAS SURl?ATT >
(Counts 1,3,5-6, 16, 19,21,41) ) Counts 18-41: 18 USC $924(c) Using A
> Firearm in Connection with a Crime of
CALIPH BASHA IBN ABDUR-k4HEEM )
(Counts 1, 8, 16, 18,22,39) >
>
KHWAJA MAHMOOD HASAN >
(Counts 1,5, 16-17,31,34-37) >
>
SABRI BENKHALA >
(Counts 1, 16,26) >
INDICTMENT
June 2003 Term - At Alexandria
General Allegations
SNIPPETS:
Intent to Engage iu Crime of Violence
As used in this Indictment:
"Mujahideen" describes warriors engaged in violent jihad.
Kashmir is a territory in the Indian subcontinent.
Kingdom in 1947, the Indian subcontinent was divided into two states, India and Pakistan.
of Markaz Dawa Wa `al Irshad and Lashkar-e-Taiba has been on conducting jihad against the
penetrating the national flags of the United States, Russia, the United Kingdom, India, and
THE GRAND JURY FURTHER CHARGES THAT:
Fairfax County in the Eastern District of Virginia and elsewhere, the defendants, RANDALL TODD
ROYER, also howu as "Ismail" Royer, MASOUD AHMAD KHAN, IBRAHIM ABMED AL-HAMDI, MOHAMMED
Surratt, CALIPH BASHA IBN ABDUR-RAHEEM, KHWAJA MAHMOOD HASAN, SABRI
BENKHALA, and YONG KI KWON, did unlawfully, willfuhy, and knowingly combine, conspire,
United States was at peace, in violation of Title 18, United States Code, Section 960;
It was part of the conspiracy that the defendants and their conspirators prepared to become
It was further part of the conspiracy that HAMMAD ABDUR-RAHEEM,
It was further part of the conspiracy that RANDALL TODD ROYER and IBRAHIM
AHMED AL-HAMDI recruited conspirators for service with the Lashkar-e-Tuiba.
For example, IBRAHIM AHMED AL-HAMDI used the name "Abu Ha&h," RANDALL
CALIPH BASHA IBN ABDUR-RAHEEM, KHWAJA MAHMOOD HASAN, DONALD
In or about July 2001, YONG KI KWON advised MO HAMMED AATIQUE to contact
KWON and J0IWAJA MAHMOOD HASAN how to reach the Lashkar-e-Taiba camp undetected.
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