- - - _.- Defendants.

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1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA v MOHAMMED A. SALAMEH and NIDAL AYYAD, _.- Defendants x,. -."'". I. w.~ 11,..~y,. INpICTMENT.- C) f'r,:" ;" : '-~ 9l." C~ ',',..... '..,, ",, JUpSE DUFf(' ~ The Grand Jury charges: On or about February 26, 1993, in the Southern District of New York, MOHAMMED A. SALAM H and NIDAL AYYAD, the defendants, unlawfully, wilfully, knowingly, and maliciously did damage and destroy, by ~eans of fire and an explosive, a building used in interstate and foreign commerce and in activities affecting interstate and foreign commerce, and death did result, to wit, MOHAMMED A. SALAMEH and NIDAL AYYAD did damage the World Trade Center co~plex located in New York, New York by use of an explosive device, causing the death of six persons. (Title 18, United States Code, Sections 844{i) and 2. ) FOREPERSON,, 4s~ ::;. United States Attorney -... c,..,

2 - _.10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT O~ NEW YORK UNITED STATES OF AMERICA - V - MOHAMMED A. SALAMEH, NIDAL AYYAD, MAHMUD ABOHALIMA, a/k/a "Mahmoud Abu Halima," and RAMZI AHMED YOUSEF, Defendants. The Grand Jury charges: COUNT ONE. : - x S 93 Cr. 180 On or about February 26, 1993, in the Southern District of New York, MOHAMMED A. SALAMEH, NIDAL AYYAD, MAHMUD ABOHALlMA, a/k/a "Mahmoud Abu Halima," and RAMZI AHMED YOUSEF, the defendants, and others known and unknown to the Grand Jury, unlawfully, wilfully, knowingly, and maliciously did damage and destroy, by means of fire and an explosive, a building used in interstate and foreign commerce and in activities affecting interstate and foreign commerce, and death did result, to wit, MOHAMMED A. SALAMEH, NIDAL AYYAD, MAHMUD ABOHALlMA, a/k/a "Mahmoud Abu Halima," and RAMZI AHMED YOUSEF, the defendants, did damage the World Trade Center complex located in New York, New :E '-J.. gl York by use of an explosive device, causing the death of six ~ persons. (Title 18( United states Code, sections 844(i) and 2.).'.. I. ~ ~~.~ ROGER~ HA ES united states Attorney

3 / :. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA - v - : : RAMZI AHMED YOUSEF, a/k/ a "Azan Muhammad," a/k/a "Khurram Khan," a/k/a "Rashed," a/k/a "Kamal Ibraham," a/k/a "Abdul Basit," a/k/a "Adam Ali Qasim," a/k/a "Naji Haddad, a/kia' "Dr. Paul Vijay," a/k/a "Dr. Adel Sabah," a/k/a "Amaldo Forlani," a/k/a "Muhammed Ali Baloch,fi ABDUL RAHMAN YASIN, a/k/a "Aboud," and ABDUL HAKIM MURAD, a/k/a "Saeed Ahmed," Defendants. : x :tnpictment S8 94 Cr. 180 (KTO) COUNT ONE The Grand Jury charges: 1. From at least in or about April 1992, through at least the date of the filing of this Indictment, in the Southern District of New York and elsewhere, RAMZI AHMED YOUSEF, a/k/a IIAzan Muhammad, II a/k/a "Khurram Khan, II a/k/a "Rashed, II a/k/a "Kamal Ibraham," a/k/a "Abdul Basit, a/k/a "Adam Ali Qasim," a/k/a "Naji Haddad," a/k/a "Dr. Paul Vijay,1I a/k/a "Dr. Adel Sabah," a/k/a IIAmaldo Forlani, a/k/a IlMuhammed Ali Baloch,1I and ABDUL RAHMAN YASIN, a/k/a IIAboud, II the defendants, along with Mohammad Salameh, a/k/a IIKamal Ibraham," Nidal Ayyad, Mahmud Abouhalima, and Ahmad Mohammad Ajaj, a/k/a "Khurram Khan," co-

4 conspirators not named as defendants herein, and others known and unknown to the Grand Jury, unlawfully, wilfully and knowingly did combine conspire, confederate and agree together and with each other to commit offenses against the United States, to wit, to violate Sections 844(i), 844(f), 844(d), and 33 of Title 18, United States Code. 2. It was a part and object of the conspiracy that RAMZI AHMED YOUSEF, a/k/a "Azan Muhammad," a/k/a "Khurram Khan," a/k/a "Rashed," a/k/a "Kamal Ibraham," a/k/a Abdul Basit, a/k/a "Adam Ali Qasim," a/k/a "Naji Haddad," a/k/a "Dr. Paul Vijay," a/k/a RDr. AdelSabah,R a/k/a "Arnaldo Forlani,R a/k/a RMUhammed Ali Baloch," and ABDUL RAHMAN YASIN, a/k/a "Aboud," the defendants, along with Mohammad Salameh, a/k/a "Kamal Ibraham," Nidal Ayyad, Mahmud Abouhalima, and Ahmad Mohammad Ajaj, a/k/a "Khurram Khan," co-conspirators not named as defendants herein, and others known and unknown to the Grand Jury, unlawfully, wilfully, knowingly and with malice would and did damage and destroy, and attempt to damage and destroy, by means of fire and explosives, buildings, vehicles and other real and personal property used in interstate commerce, in violation of Title 18, United States Code, Section 844(i). 3. It was a further part and object of the conspiracy that RAMZI AHMED YOUSEF, a/k/a "Azan MUhammad," a/k/a "Khurram Khan," a/k/a Rashed, a/k/a "Kamal Ibraham," a/k/a "Abdul Basit, a/k/a "Adam Ali Qasim," a/k/a "Naji Haddad, a/k/a "Dr. Paul Vijay, a/k/a "Dr. Adel Sabah, a/k/a "Arnaldo Forlani," 2

5 . a/k/a "Muhammed Ali Baloch," and ABDUL RAHMAN YASIN, a/k/a "Aboud," the defendants, along with Mohammad Salameh, a/k/a "Kamal Ibraham," Nidal Ayyad, Mahmud Abouhalima, and Ahmad Mohammad Ajaj, a/k/a "Khurram Khan," co-conspirators not named as defendants herein, and others known and unknown to the Grand Jury, unlawfully, wilfully, knowingly and with malice would and did damage and destroy by means of fire and explosives, buildings, vehicles, and other personal property in whole or in part owned, possessed, used by, and leased to the United States and departments and agencies thereof, in violation of Title 28, United States Code, Section 844(f). 4. It was a further part and object of the conspiracy that RAMZI AHMED YOUSEF, a/k/a "Azan Muhammad," a/k/a "Khurram Khan," a/k/a "Rashed," a/k/a "Kamal Ibraham," a/k/a "Abdul Basit," a/k/a "Adam Ali Qasim," a/k/a "Naji Haddad," a/k/a "Dr. Paul Vijay," a/k/a "Dr. Adel Sabah," a/k/a "Amaldo Forlani," a/k/a "Muhammed Ali Baloch," and ABDUL RAHMAN YASIN, a/k/a "Aboud," the defendants, along with Mohammad Salameh, a/k/a "Kamal Ibraham," Nidal Ayyad, Mahmud Abouhalima, and Ahmad Mohammad Ajaj, a/k/a "Khurram Khan," co-conspirators not named as defendants herein, and others known and unknown to the Grand Jury, unlawfully, wilfully, and knowingly would and did transport in interstate commerce explosives with the knowledge and intent that the explosives were to be used unlawfully to damage and destroy buildings, vehicles and other real and personal property, in violation of.. Title 28, United States Code, Section 844 (d) 3

6 5. It was a further part and object of the conspiracy that RAMZI AHMED YOUSEF, a/k/a "Azan Muhammad," a/k/a wkhurram Khan, W a/k/a "Rashed," a/k/a "Kamal Ibraham, W a/k/a "Abdul Basit," a/k/a "Adam Ali Qasim," a/k/a "Naji Haddad," a/k/a "Dr. Paul Vijay," a/k/a -Dr. Adel Sabah," a/k/a "Amaldo Forlani," a/k/a "Muhammed Ali Baloch," and ABDUL RAHMAN YASIN, a/k/a "Aboud," the defendants, along with Mohammad Salameh, a/k/a "Kamal Ibraham," Nidal Ayyad, Mahmud Abouhalima, and Ahmad Mohammad Ajaj, a/k/a "Khurram Khan," co-conspirators not named as defendants herein, and others known and unknown to the Grand Jury, unlawfully, wilfully, knowingly, and with a reckless disregard for the safety of human life, would and did damage, disable, destroy, and place and cause to be placed explosives and other destructive substances in, upon and in proximity to, motor vehicles which were used, operated and employed in interstate commerce in violation of Title 18, United States Code, Section 33. OVert Acts 6. In furtherance of said conspiracy and to effect the objects thereof, RAMZI AHMED YOUSEF, 'a/k/a "Azan MUhammad," a/k/a "Khurram Khan," a/k/a "Rashed," a/k/a "Kamal Ibraham," a/k/a "Abdul Basit," a/k/a "Adam Ali Qasim," a/k/a "Naji Haddad," a/k/a WDr. Paul Vijay, a/k/a "Dr. Adel Sabah," a/k/a "Amaldo Forlani," a/k/a "Muhammed Ali Baloch," and ABDUL RAHMAN YASIN, a/k/a "Aboud," the defendants, along with Mohammad Salameh, a/k/a "Kamal Ibraham;" Nidal Ayyad, Mahmud Abouhalima., and Ahmad 4

7 Mohammad Ajaj, a/k/a RKhurram Khan,R co-conspirators not named as defendants herein, and others known and unknown to the Grand Jury, committed the following overt acts in the-southern District of New York and elsewhere: a. On or about September 1, 1992, Ahmad Mohammad Ajaj, using an airline ticket issued in the name of RKhurram Khan,R and RAMZI AHMED YOUSEF, using an airline ticket issued in the name of RAzan Muhammad, R travelled together from Pakistan to John F. Kennedy International Airport, in Queens County, New York (RKennedy AirportR). b. On or about September 1, 1992, Ahmad Mohammad Ajaj transported from Pakistan to Kennedy Airport, manuals and other materials containing, among other things, instructions on the construction and use of explosive devices, including improvised explosive devices using urea and nitric acid and oi trog.lycerine. c. On or about October 14, 1992, Mohammad Salameh and Nidal Ayyad opened a joint bank account and deposited $8,567 in cash into that bank account. d. On or about October 22, 1992, Mohammad Salameh and Nidal Ayyad withdrew $8,560 in cash from their joint bank account. e. On or about October 22, 1992, Mohammad Salameh deposited $8,570 in cash into a separate bank account in his own name. 5

8 f. On or about November 30, 1992, Mohammad Salameh cashed a check in the amount of $3,400 drawn on the bank ac~ount referred to in paragraph (e) above. g. On or about November 3D, 1992, one of the coconspirators, using the name llllkamal Ibraham," rented a storag.e shed from Space Station Storage, located at 69 Mallory Avenue, Jersey City, New Jersey (the "Storage Shed fi ). h. On or about November 3D, 1992, RAMZI AHMED YOUSEF, using the name "Kamal Ibraham,1III ordered certain chemicals,' including urea and nitric acid, for delivery to the Storage Shed. i. On or about November 30, 1992, RAMZI AHMED YOUSEF paid approximately $3,615 in cash for the chemicals referred to in the paragraph (h) above. j. On or about February 2, 1993, Nidal Ayyad ordered certain chemicals from the same supplier as did YOUSEF. k. From on or about Novemper 30, 1992, through in or about February 1993, the co-conspirators, including Mohammad Salameh and RAMZI AHMED YOUSEF, entered and exited the Storage Shed. 1. From in or about January 1993, through in or about February 1993, the co-conspirators, including Mohammad Salameh, RAMZI AHMED YOUSEP, and ABDUL RAHMAN YASIN, mixed chemicals to produce explosive materials, including urea nitrate and nitroglycerine, in an apartment located at 40 Pamrapo Avenue, Jersey City, New Jersey.,

9 m. On or about February 23,1993, Mohammad Salameh rented a Ryder van (the RRyder van") from an office located in Jersey City, New Jersey. n. On or about February 25, 1993, Nidal Ayyad placed a telephone call from Ayyad's place of business to a supplier of compressed gases. o. On or about February 25, 1993, Mohammad Salameh and another coconspirator placed telephone calls from the Storage Shed, including a telephone call to Nidal Ayyad at Ayyad's place of business. p. On or about February 25, 1993, Mohammad Salameh accepted delivery of three tanks of hydrogen gas at the Storage Shed from the same supplier of compressed gases referred to in paragraph (n) above. q. On or about February 25, 1993, Mohammad Salameh, among others, loaded the three tanks of hydrogen gas into the Ryder van. r. On or about February 25, 1993, Mohammad Salameh reported the Ryder van stolen to the police. s. On or about February 2.6, 1993, the coconspirators transported an improvised explosive device that was inside the Ryder van from New Jersey to New York. t. On or about February 26, 1993, the coconspirators caused an improvised explosive device that was inside the Ryder van to explode in the garage area beneath the Vista Hotel, located at the World Trade Center Complex in New 7

10 York, New York, causing personal injury to numerous persons and the death of six persons. u. On or about February 26, 1993, RAMZI AHMED YOUSEF, us~ng an airline ticket issued in the name of -Abdul Basit, 'boarded a flight from Kennedy Airport to Karachi, Pakistan. v. On or about March 2, 1993, Mahmud Abouhalima boarded a flight from Kennedy Airport to Jeddah, Saudi Arabia. w. On March 4, 1993, Mohanunad Salameh returned to the Ryder office in Jersey City, New Jersey. x. On or about March 5, 1993, ABDUL RAHMAN YASIN, boarded a flight from Kennedy Airport to Amman, Jordan. y. In or about late February or early March 1993, Nidal Ayyad prepared a letter claiming responsibility for the bombing of the World Trade Center on behalf of the RLiberation Army Fifth Battalion Al Fareeq Al Rokn, Abu Baki Al Makkee,R listing certain political demands and threatening future acts of terrorism. z. On or about March 9, 1993, Nidal Ayyad had a conversation with a co-worker concerning certain chemicals. aa. On or about March 10, 1993, Nidal Ayyad possessed a modified timing device. (Title 18, United States Code, Section 371.) 8

11 COUNT TWO The Grand Jury further charges: 7. On or about February 26, 1993, in the Southern District of New York, RAMZI AHMED YOUSEF, a/k/a BAzan MUhammad," a/k/a "Khurram Khan, B a/k/a "Rashed," a/k/a "Kamal Ibraham," a/k/a "Abdul Basit," a/k/a "Adam Ali Qasim," a/k/a "Naji Haddad," a/k/a "Dr. Paul Vijay," a/k/a "Dr. Adel Sabah,B a/k/a "Arnaldo Forlani," a/k/a "Muhammed Ali Baloch," and ABDUL RAHMAN YASIN, a/k/a "Aboud,fi the defendants, along with Mohammad Salameh, a/k/a "Kamal Ibraham," Nidal Ayyad, Mahmud Abouhalima, and Ahmad Mohammad Ajaj, a/k/a fikhurram Khan," co-conspirators not named as defendants herein, and others known and unknown to the Grand Jury, unlawfully, wilfully, knowingly, and maliciously did damage and destroy, by means of fire and an explosive, a building used in interstate and foreign commerce and in activities affecting interstate and foreign commerce, and personal injury and death did result, to wit, the defendants did damage the World Trade Center complex located in New York, New York by use of an improvised explosive device, causing personal injury to numero~s persons and further causing the death of six persons: John DiGiovanni, Robert Kirkpatrick, Stephen Knapp, William Macko, Wilfredo Mercado and Monica Smith. (Title 18, United States Code, Sections 844(i) and 2.} 9

12 COUNT THREE The Grand Jury further charges: B. On or about February 26, 2993, in the Southern District of New York, RAMZI AHMED YOUSEF, a/k/a "Azan Muhammad," a/k/a "Khurram Khan," a/k/a "Rashed," a/k/a "Kamal!braham," a/k/a "Abdul Basit," a/k/a "Adam Ali Qasim," a/k/a "Naji Haddad," a/k/a "Dr. Paul Vijay," a/k/a "Dr. Adel Sabah," a/k/a "Arnaldo Forlani," a/k/a "Muhammed Ali Baloch," and ABDUL RAHMAN YASIN, a/k/a "Aboud," the defendants, along with Mohammad Salameh, a/k/a "Kamal Ibraham," Nidal Ayyad, Mahmud Abouhalima, and Ahmad Mohammad Ajaj, a/k/a "Khurram Khan," co conspirators not named as defendants herein, and others known- and unknown to the Grand Jury, unlawfully, wilfully, knowingly, and maliciously did damage and destroy, by means of fire and an explosive, a building, vehicles, and other real and personal property, in whole or in part owned, possessed, used by, and leased to the United States and departments and agencies thereof, and personal injury and death did result, to wit, the defendants did damage the World Trade Center complex, which was in part used and leased by the United States CUstoms Service and the United States Secret Service, and numerous vehicles owned, possessed and used by the United States Secret Service, by use of an improvised explosive device, causing personal injury to numerous persons and further causing the death of six persons: John DiGiovanni, Robert 10

13 Kirkpatrick, Stephen Knapp, William Macko, Wilfredo Mercado and Monica Smith. (Title 18,United States Code, Sections 844(f) and 2.) COUNT FOUR The Grand Jury further charges: 9. On or about February 26, 1993, in the Southern District of New York, RAMZI AHMED YOUSEF, a/k/a "Azan MUhammad," a/k/a "Khurram Khan," a/k/a "Rashed," a/k/a "Kamal Ibraham," a/k/a "Abdul Basit, " a/k/a "Adam Ali Qasim,ft a/k/a ftnaji Haddad," a/k/a "Dr. Paul Vijay," a/k/a "Dr. Adel Sabah," a/k/a "Amaldo Forlani," a/k/a "MUhammed Ali Baloch," and ABDUL RAHMAN YASIN, a/k/a "Aboud," the defendants, along with Mohammad Salameh, a/k/a "Kamal Ibraham," Nidal Ayyad, Mahmud Abouhalima., and Ahmad Mohammad Ajaj, a/k/a "Khurram Khan," co-conspirators not named as defendants herein, and others known and unknown to the Grand Jury, unlawfully, wilfully, and knowingly did transport in interstate commerce an explosive with the knowledge and intent that the explosive was to be used unlawfully to damage and destroy, a building, vehicles and other real and personal property, and personal injury and death did result, to wit, the defendants did transport an improvised explosive device from New Jersey to New York knowing that the improvised explosive device was to be used to damage the World Trade Center complex, and any vehicles and other property within the complex, causing personal injury to numerous persons and further causing the death of six 11

14 persons: John DiGiovanni, Robert Kirkpatrick, Stephen Knapp, William ~cko, Wilfredo Mercado and Monica Smith. (Title 18, United States Code, Sections 844(d) and 2.) COUNT FIVE The Grand Jury further charges: 10. On or about February 26, 1993, in the Southern District of New York, RAMZI AHMED YOUSEF, a/k/a HAzan Muhammad," a/k/a "Khurram Khan, R a/k/a "Rashed," a/k/a "Kamal Ibraham," a/k/a "Abdul Basit," a/k/a Adam Ali Qasim," a/k/a RNaji Haddad," a/k/a "Dr.' Paul Vijay," a/k/a "Dr. Adel Sabah," a/k/a "Arnaldo Forlani," a/k/a "Muhammed Ali Baloch," and ABDUL RAHMAN YASIN, a/k/a "Aboud," the defendants, along with Mohammad Salameh, a/k/a "Kamal Ibraham," Nidal Ayyad, Mahmud Abouhalima, and Ahmad Mohammad Ajaj, a/k/a "Khurram Khan," co-conspirators not named as defendants herein, and others known and unknown to the Grand Jury, unlawfully, wilfully, knowingly, and with a reckless disregard for the safety of human life, did damage, disable, destroy, and place and cause to be placed an explosive and other destructive substances in, upon and in proximity to, a motor vehicle which was used, operated and employed in interstate commerce, and death did result, to wit, the defendants did place and cause to be placed an improvised explosive device inside a Ryder rental van bearing Alabama license plate number XA70668, which improvised explosive device exploded inside the van, causing damage to and destro.ying the van, and causing the death 12

15 of six persons: John DiGiovanni, Robert Kirkpatrick, Stephen Knapp, William Macko, Wilfredo Mercado and Monica Smith. (Title 18, United States Code, Sections 33, 34 and 2.) COUNT SIX The Grand Jury further charges: 11. On or about February 26, 1993, in the Southern District of New York, RAMZI AHMED YOUSEF, a/k/a "Azan Muhammad," a/k/a RKhurram Khan,- a/k/a "Rashed,R a/k/a "Kamal Ibraham," a/k/a "Abdul Basit," a/k/a -Adam Ali Qasim," a/k/a RNaji Haddad," a/k/a -Dr. Paul Vijay," a/k/a "Dr. Adel Sabah," a/k/a "Arnaldo Forlani," a/k/a "Muhammed Ali Baloch," and ABDUL RAHMAN YASIN, a/k/a "Aboud," the defendants, along with Mohammad Salameh, a/k/a "Kamal Ibraham," Nidal Ayyad, Mahmud Abouhalima., and Ahmad Mohammad Ajaj, a/k/a "Khurram Khan," co-conspirators not named as defendants herein, and others known and unknown to the Grand Jury,.unlawfully, wilfully, knowingly, and with a reckless disregard for the safety of human life, did damage, disable, destroy, and place and cause to be placed an explosive and other destructive substances in, upon and in proximity to, motor vehicles which were used, operated and employed in interstate commerce, and death did result, to wit, the defendants did place and cause to be placed an improvised explosive device inside a Ryder rental van bearing Alabama license plate number XA70668, which improvised explosive device exploded inside the van, causing damage to and destroying numerous. mot.or vehicles which were in proximity to the van, causing damage to the World Trade 13

16 Center complex and the death of six persons: John DiGiovanni, R.obert Kirkpatrick, Stephen Knapp, William Macko, Wilfredo Mercado and Monica Smith. (Title 18, United States Code, Sections 33, 34 and 2.). COUNT SEVEN The Grand Jury further charges: 12. On or about September 1, 1992, in the Eastern District of New York and elsewhere, RAMZI AHMED YOUSEF, a/k/a "Azan Muhammad," a/k/a "Khurram Khan," a/k/a "Rashed," a/k/a liikamal Ibraham," a/k/a "Abdul Basit," a/k/a "Adam Ali Qasim;" a/k/a "Naji Haddad," a/k/a "Dr. Paul Vijay," a/k/a "Dr. Adel Sabah," a/k/a "Arnaldo Forlani,R a/k/a "MUhammed Ali Baloch," the defendant, and Ahmad Mohammad Ajaj, a/k/a "Khurram Khan," a coconspirator not named as a defendant herein, unlawfully, wilfully, and knowingly did travel in foreign commerce and used a facility in interstate and foreign commerce with the intent "to (i) commit crimes of violence to further unlawful activity, namely, arson, and (ii) promote, manage, establish, carry on, and facilitate the promotion, management, establishment, and carrying on of such unlawful activity, and thereafter perfor.med and attempted to perfor.m acts described in (i) and (ii) above. (Title 18, United States Code, Sections 1952 and 2.) COUNT EIGHT The Grand Jury further charges: 13. On or about February 26, 1993, in the Southern District of New York, RAMZI.AHMED YOUSEF', a/k/a "Azan Muhammad,R 14

17 a/k/a "Khurram Khan," a/k/a "Rashed," a/k/a "Kamal J:braham," a/k/a "Abdul Basit, " a/k/a "Adam Ali Qas~," a/k/a "Naji Haddad," a/k/a "Dr. Paul Vijay," a/k/a "Dr. Adel Sabah," a/k/a "Arnaldo Forlani," a/k/a IllMuhammed Ali Baloch," and ABDUL RAHMAN YASIN, a/k/a "Aboud," the defendants, along with Mohammad Salameh, a/k/a "Kamal J:braham," Nidal Ayyad, Mahmud Abouhalima, and Ahmad Mohammad Ajaj, a/k/a "Khurram Khan," co-conspirators not named as defendants herein, and others known and unknown to the Grand Jury, unlawfully, wilfully, knowingly and forcibly did assault, oppose, ~mpede, intimidate, and interfere with a person designated in Section 1114 of Title 18 of the United States Code, while that person was engaged in and on account of the performance of his official duties, and in doing so, the defendants did use a deadly and dangerous weapon, to wit, the defendants did cause an explosion at the World Trade Center complex by use of an improvised explosive device, the force of which explosion injured three Special Agents with the United States Secret Service. (Title 18, United States Code, Sections 111 and 2.) COUNT NINE The Grand Jury further charges: 14. On or about February 26, 1993, in the Southern District of New York, RAMZI AHMED YOUSEF, a/k/a "Azan Muhammad;" a/k/a "Khurram Khan," a/k/a "Rashed," a/k/a "Kamal Ibraham," a/k/a "Abdul Basit," a/k/a"adam Ali Qasim," a/k/a "Naji Haddad,". a/k/a "Dr. Paul Vijay,W a/k/a "Dr. Adel Sabah," a/k/a "Arnaldo. 15

18 Forlani," a/k/a "Muhammed Ali Baloch," and ABDUL RAHMAN YASIN, a/k/a "Aboud," the defendants, along with Mohammad Salameh, a/k/a "Kamal Ibraham, " Nidal Ayyad, Mahmud Abouhalima, and Ahmad Mohammad Ajaj, a/k/a "Khurram Khan," co-conspirators not named as defendants herein, and others known and unknown to the Grand Jury, unlawfully, wilfully, and knowingly, and during and in relation to a crime of violence for which they may be prosecuted in a Court of the United States, namely, the forcible assault of federal officers in violation of Title ls, United States Code, Section 111 as set forth in Count Eight of this Indictment, which is incorporated by reference herein, did use and carry a firear.m, as that ter.m is defined in Title ls, United States Code, Section 921(a) to include any destructive device, to wit, the defendants did use and carry an improvised explosive device during and in relation to Count Eight of this Indictment. (Title ls, United States Code, Sections 924(c) and 2.) COUNT TEN The Grand Jury further charges: 15. On or about February 26, 1993, in the Southern District of New York, RAMZI AHMED YOUSEF, a/k/a "Azan Muhammad," a/k/a "Khurram Khan," a/k/a "Rashed," a/k/a "Kamal Ibraham," a/k/a "Abdul Basit, " a/k/a "Adam Ali Qasim,R a/k/a "Naji Haddad," a/k/a "Dr. Paul Vijay," a/k/a RDr. Adel Sabah," a/k/a RArnaldo Forlani," a/k/a RMuhammed Ali Baloch," and ABDUL RAHMAN YASIN, a/k/a "Aboud," the defendants, along with Mohammad Salameh, a/k/a "Kamal Ibrahami" Nidal Ayyad, Mahmud Abouhalima, and Ahmad 16

19 ,;.- Mohammad Ajaj, a/k/a -Khurram Khan,- co-conspirators not named as defendants herein, and others known and unknown to the Grand Jury, unlawfully, wilfully, and knowingly, and during and in relation to a crime of violence for which they may be prosecuted in a Cour~ of the United States, namely, the conspiracy to damage and destroy buildings, vehicles, and other property by means of explosives in violation of Title 18, United States Code, Section 371 as set forth in Count One of this Indictment, which is incorporated by reference herein, did use and carry a firearm, as that term is defined in Title 18, United States Code, Section 921(a) to include any destructive device, to wit, the defendants did use and carry an improvised explosive device during and in relation to Count One of this Indictment. (Title 18, United States Code, Sections 924(c) and 2.) COUNT ELEVEN The Grand Jury further charges: 16. From in or about November 1994 through the date of the filing of "this indictment, in the Philippines and elsewhere out of the jurisdiction of any particular state or district, RAMZI AHMED YOUSEF, a/k/a -Azan Muhammad, - a/k/a "Khurram Khan," a/k/a "Rashed," a/k/a -Kamal Ibraham,- a/k/a -Abdul Basit,- a/k/a -Adam Ali Qasim,- a/k/a -Naji Haddad," a/k/a -Dr. Paul Vijay," a/k/a "Dr. Adel Sabah, - a/k/a -Amaldo Forlani," a/k/a "Muhammed Ali Baloch, being first brought to and first arrested in the Southern District of New York, and ABDUL HAKIM MURAD, a/k/a "Saeed Ahmed,"-the defendants, and others known and unknown to 17

20 the Grand Jury, unlawfully, wilfully and knowingly combined, conspired, confederated and agreed to commit an offense against the United States, to wit, to violate Title 18, United States Code, Section 32(a). 17. It was a part and object of the conspiracy that RAMZI AHMED YOUSEF, ABDUL HAKIM MURAD, and others known and unknown to the Grand Jury, would set fire to, damage, destroy, disable and,wreck aircraft in the special aircraft jurisdiction of the United States, and civil aircraft used, operated and employed in interstate, overseas, and foreign air conunerce, in violation of 18 U.S.C. 32(a) (1). 18. It was a further part and object of the conspiracy that RAMZI AHMED YOUSEF, ABDUL HAKIM MURAD and others known and unknown to the Grand Jury, would place and cause to be placed a destructive device and substance in, upon, and in proximity to, and otherwise make and cause to be made unworkable and unusable and hazardous to work or use, aircraft in the special aircraft jurisdiction of the United States, and civil aircraft used, operated and employed in interstate, overseas, and foreign air conunerce, and any part and other materials used and intended to be used in connection with the operation of such aircraft, thereby endangering the safety of such aircraft, in violation of 18 U.S.C. 32(a) (2). 19. In furtherance of the conspiracy and to effect the objects thereof, the following overt acts were committed: 18

21 a. On or about December 8, 1994, RAMZI AHMED YOUSEF, using the name Naji Haddad, rented apartment 603 in the Dona Josefa Apartment Building, located at 711 President Quirino Boulevard, Manila, Philippines (the -Apartment"). b. On or about December 11, 1994, RAMZI AHMED YOUSEF placed a bomb aboard Philippine Airlines flight 434 bound for TOkyo, Japan, that exploded while the airplane was in flight, causing the death of one passenger. c. In or about January 1995, RAMZI AHMED YOUSEF and ABDUL HAKIM MORAD resided in the Apartment. d.' In or about January 1995, RAMZI AHMED YOUSEF and ABDUL KAHIM MORAD possessed in the Apartment a computer that contained among other things, information relating to flight numbers and departure times of commercial airliners, including civil commercial aircraft of the United States, times for detonation of bombs aboard such airliners, and a letter threatening to attack American targets, signed by the "Fifth Battalion of the Liberation Army -- Abu Baker Al Maki." e. In or about January 1995, RAMZI AHMED YOUSEF and ABDUL HAKIM MORAD possessed in the Apartment, among other items, modified timing devices, components for nitroglycerine, and manuals containing formulae for various explosives. f. On or about January 6, 1995, RAMZI AHMED YOUSEF and ABDUL HAKIM MURAD mixed chemicals inside the Apartment. (Title 18, United States Code, Section 371.) 19

22 COUNT TWELVE The Grand Jury further charges: 20. In or about January 2995, in the Philippines and elsewhere out of the jurisdiction of any particular state or district, RAMZI AHMED YOUSEF, a/k/a "Azan MUhammad," a/k/a "Khurram Khan," a/k/a -Rashed," a/k/a -Kamal Ibraham," a/k/a "Abdul Basit," a/k/a "Adam Ali Qasim," a/k/a "Naj i Haddad,," a/k/a -Dr. Paul Vijay,- a/k/a "Dr. Adel Sabah,- a/k/a IIArnaldo Forlani,R a/k/a RMuhammed Ali Baloch,R being first brought to and first arrested,in the Southern District of New York, and ABDUL HAKIM MURAD, a/k/a RSaeed Ahmed,R the defendants, and others known and unknown to the Grand Jury, unlawfully, wilfully and knowingly attempted to set fire to, damage, destroy, disable, and wreck aircraft in the special aircraft jurisdiction of the United States, and civil aircraft used, operated and employed in interstate, overseas, and foreign air commerce, to wit, the' defendants attempted to damage, destroy, disable, and wreck United States commercial airliners servicing air routes in East Asia. (Title 18, United States Code, Sections 32 (a) (1) and (7).) COUNT THIRTEEN The Grand Jury further charges: 21. In or about January 1995, in the Philippines and elsewhere out of the jurisdiction of any particular state or district, RAMZI AHMED YOUSEF, a/k/a "Azan Muhammad," a/k/a "Khurram Khan,"- a/k/a "Rashed, II a/k/a IIKamal Ibraham,R a/k/a 20

23 ., -Abdul Basit, a/k/a WAdam Ali Qasim, a/k/a RNaji Haddad," a/k/a -Dr. Paul Vijay," a/k/a Dr. Adel Sabah,R a/k/a Arnaldo Forlani, a/k/a WMUhammed Ali Baloch, being first brought to and first arrested in the Southern District of New York, and ABDUL HAKIM MORAD, a/k/a wsaeed Ahmed, the defendants, and others known and unknown to the Grand Jury, unlawfully, wilfully and knowingly, attempted to place and cause to be placed a destructive device and substance in, upon; and in proximity to, and otherwise make and cause to be made unworkable and unusable and hazardous to work or use, aircraft in the special aircraft jurisdiction of the United States, and civil aircraft used, operated and employed in interstate, overseas, and foreign air commerce, and any part and othe'r materials used and intended to be used in connection with the operation of such aircraft, which was likely to endanger the safety of such aircraft, to wit, the defendants attempted to place bombs on United States commercial airliners servicing air routes in East Asia. (Title 18, United States Code, Sections 32(a) (2) and (7).) COUNT FOURTEEN The Grand Jury further charges: 22. On or about December 11, 1994, in the Philippines and elsewhere out of the jurisdiction of any particular state or district, RAMZI AHMED YOUSEF, a/k/a Azan MUhammad, a/k/a RKhurram Khan,w a/k/a Rashed, a/k/a wkamal Ibraham,w a/k/a wabdul Basit,W a/k/a -Adam Ali Qasim, a/k/a Naji Haddad, a/k/a -Dr. Paul Vijay, a/k/a RDr. Adel Sabah,- a/k/a Arnaldo Forlani, 21

24 . a/k/a RMuhammed Ali Baloch, the defendant, being first brought to and first arrested in the Southern District of New York, and others known and unknown to the Grand Jury, unlawfully, wilfully and knowingly placed and caused to be placed on a civil aircraft registered in a country other than the United States while such aircraft was in service, a device or substance which was likely to destroy that craft and to cause damage to that craft which likely endangered that aircraft's safety in flight, to wit, the defendant placed a bomb aboard Philippine Airlines flight 434 which exploded while that aircraft was in flight, causing the death of one passenger. (Title 18, United States Code, Sections 32(b) (3), 34 and 2.) fi1~vn MARY~~TE United States Attorney 22

25 UNITED STATES DISTRICT COURT SOUTDD DISTRICT 01' OW you UNITED STATES 01' AMERICA - V - RAMZI ABKED YOUSELI', a/k/a "AZO Xuhammad, II a/k/a "lthurram ltho, a/k/a "Rashed," a/k/a.akamal Ibraham, II a/k/a 8'A))dul :aasit," a/k/a &BAdam Ali gasam, au a/k/a IINaji Haddad,.' a/k/a "Dr. Paul Vijay," a/k/a 88Dr. Adel Sabah," a/k/a ".Amaldo I'orloi," a/k/a "Kuhammed Ali Baloch," ABDUL RAHMAN YASIN, a/k/a "Aboud," od ABDUL HAKIM KURAn, a/k/a "Saeed Ahmed," Defendots. INDICTMENT S8 94 Cr. 180 (KTD) (Title 18, united states Code, sections 111, ~952, 32(a)(1), 32(a)(2), 32(a)(7), 32(b)(3), 3238, 33, 34, 371, 844(4), 844(f), 844(i), 924(c) od section 2.) KARY JO WHITE united states Attorney

26 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA - v - RAMZI AHMED YOUSEF, a/k/a "Azan Muhammad," a/k/a "Khurram Khan," a/k/a "Rashed," a/k/a "Kamal Ibraham," a/k/a "Abdul Basit," a/k/a "Adam Ali Qasim," a/k/a "Naji Haddad, a/k/a "Dr. Paul Vijay," a/k/a "Dr. Adel Sabah," a/k/a "Amaldo Forlani, " a/k/a "Muhammad Ali Baloch," EYAD ISMOIL, a/k/a "Eyad Ismail," a/k/a "Iyad Mahmoud Ismaeel Najim," ABDUL RAHMAN YASIN, a "Aboud ", a/k/a "Saeed Ahmed," WALl KHAN AMIN SHAH, a/k/a "Grabi Ibrahim Hahsen," and KHALED SHAIKH MOHAMMAD, a/k/a "Khalid Shaikh," a/k/a "Salem Ali," INDICTMENT S~ 93 Cr. 180 (KTD) Defendants. - x COUNT ONE The Grand Jury charges: 1. From at least in or about April 1992, through at least the date of the filing of this Indictment, in the Southern District of New York and elsewhere, RAMZI AHMED YOUSEF, a/k/a "Azan Muhammad," ajkja "Khurram Khan," ajkja "Rashed," a/k/a "Kamal Ibraham," ajkja "Abdul Basit," ajkja "Adam Ali Qasim," a/kja "Naji Haddad," ajkja "Dr. Paul Vijay," a/k/a "Dr. Adel Sabah," a/k/a "Amaldo Forlani," a/k/a "Muhammad Ali Baloch," EYAD

27 ISMOIL, ajkja "Eyad Ismail," ajkja "Iyad Mahmoud Ismaeel Najim," and ABDUL RAHMAN YASIN, ajkja "Aboud," the defendants, along with Mohammad Salameh, ajkja "Kamal Ibraham," Nidal Ayyad, Mahmud Abouhalima, and Ahmad Mohammad Ajaj, ajkja "Khurram Khan," coconspirators not named as defendants herein, and others known and unknown to the Grand Jury, unlawfully, wilfully and knowingly did combine, conspire, confederate and agree together and with each other to commit offenses against the United states, to wit, to violate sections 844(i), 844(f), 844(d), and 33 of Title 18, United states Code. 2. It was a part and object of the conspiracy that RAMZI AHMED YOUSEF, ajkja "Azan Muhammad," ajkja "Khurram Khan," a "Rashed " a a "Kamal Ibraham " a a "Abdul Basit " a a "Adam Ali Qasim," ajkja "Naji Haddad," ajkja "Dr. Paul Vijay," ajkja "Dr. Adel Sabah," ajkja "Amaldo Forlani," ajkja "Muhammad Ali Baloch," EYAD ISMOIL, ajkja "Eyad Ismail," ajkja "Iyad Mahmoud Ismaeel Najim," and ABDUL RAHMAN YASIN, ajkja "Aboud," the defendants, along with Mohammad Salameh, ajkja "Kamal Ibraham," Nidal Ayyad, Mahmud Abouhalima, and Ahmad Mohammad Ajaj, ajkja "Khurram Khan," co-conspirators not named as defendants herein, and others known and unknown to the Grand Jury, unlawfully, wilfully, knowingly and with malice would and did damage and destroy, and attempt to damage and destroy, by means of fire and explosives, buildings, vehicles and other real and personal property used in interstate and foreign commerce, in violation of Title 18, United states Code, section 844(i). 2

28 3. It was a further part and object of the conspiracy that RAMZI AHMED YOUSEF, ajkja "Azan Muhammad," ajkja "Khurram Khan," ajkja "Rashed," ajkja "Kamal Ibraham," ajkja "Abdul Basit," ajkja "Adam Ali Qasim," ajkja "Naji Haddad," ajkja "Dr. Paul Vijay," ajkja "Dr. Adel Sabah," ajkja "Amaldo Forlani," ajkja "Muhammad Ali Baloch," EYAD ISMOIL, ajkja "Eyad Ismail," ajkja "Iyad Mahmoud Ismaeel Najim," and ABDUL RAHMAN YASIN, ajkja "Aboud," the defendants, along with Mohammad Salameh, ajkja "Kamal Ibraham," Nidal Ayyad, Mahmud Abouhalima, and Ahmad Mohammad Ajaj, ajkja "Khurram Khan," co-conspirators not named as defendants herein, and others known and unknown to the Grand Jury, unlawfully, wilfully, knowingly and with malice would and did damage and destroy~y means of fire and exrlosives, buildings, vehicles, and other personal property in whole or in part owned, possessed, used by, and leased to the united states and departments and agencies thereof, in violation of Title 18, united states Code, Section 844(f). 4. It was a further part and object of the conspiracy that RAMZI AHMED YOUSEF, ajkja "Azan Muhammad," ajkja "Khurram Khan," ajkja "Rashed," ajkja "Kamal Ibraham," ajkja "Abdul Basit," ajkja "Adam Ali Qasim," ajkja "Naji Haddad," ajkja "Dr. Paul Vijay," ajkja "Dr. Adel Sabah," ajkja "Arnaldo Forlani," ajkja "Muhammad Ali Baloch," EYAD ISMOIL, ajkja "Eyad Ismail," ajkja "Iyad Mahmoud Ismaeel Najim," and ABDUL RAHMAN YASIN, ajkja "Aboud," the defendants, along with Mohammad Salameh, ajkja "Kamal Ibraham," Nidal Ayyad, Mahmud Abouhalima, and Ahmad 3

29 Mohammad Ajaj, ajkja "Khurram Khan," co-conspirators not named as defendants herein, and others known and unknown to the Grand Jury, unlawfully, wilfully, and knowingly would and did transport in interstate commerce explosives with the knowledge and intent that the explosives were to be used unlawfully to damage and destroy buildings, vehicles and other real and personal property, in violation of Title 18, United states Code, section 844(d). 5. It was a further part and object of the conspiracy that RAMZI AHMED YOUSEF, ajkja "Azan Muhammad," ajkja "Khurram Khan," ajkja "Rashed," ajkja "Kamal Ibraham," ajkja "Abdul Basit," ajkja "Adam Ali Qasim," ajkja "Naji Haddad," ajkja "Dr. Paul Vijay," ajkja "Dr. Adel Sabah," ajkja "Amaldo Forlani," ~ a=/kla "Muhammad Ali Baloch l " EYAD ISMOIL,~/k/~ "Eyad Ismail," ajkja "Iyad Mahmoud Ismaeel Najim," and ABDUL RAHMAN YASIN, ajkja "Aboud," the defendants, along with Mohammad Salameh, ajkja "Kamal Ibraham," Nidal Ayyad, Mahmud Abouhalima, and Ahmad Mohammad Ajaj, ajkja "Khurram Khan," co-conspirators not named as defendants herein, and others known and unknown to the Grand Jury, unlawfully, wilfully, knowingly, and with a reckless disregard for the safety of human life, would and did damage, disable, destroy, and place and cause to be placed explosives and other destructive substances in, upon and in proximity to, motor vehicles which were used, operated and employed in interstate commerce in violation of Title 18, United states Code, section 33. 4

30 6. In furtherance of said conspiracy and to effect the objects thereof, RAMZI AHMED YOUSEF, ajkja "Azan Muhammad," ajkja "Khurram Khan," ajkja "Rashed," ajkja "Kamal Ibraham," ajkja "Abdul Basit," ajkja "Adam Ali Qasim," ajkja "Naji Haddad," ajkja "Dr. Paul Vijay," ajkja "Dr. Adel Sabah," ajkja "Amaldo Forlani," ajkja "Muhammad Ali Baloch," EYAD ISMaIL, ajkja "Eyad Ismail," ajkja "Iyad Mahmoud Ismaeel Najim," and ABDUL RAHMAN YASIN, ajkja "Aboud," the defendants, along with Mohammad Salameh, ajkja "Kamal Ibraham," Nidal Ayyad, Mahmud Abouhalima, and Ahmad Mohammad Ajaj, ajkja "Khurram Khan," co-conspirators not named as defendants herein, and others known and unknown to the Grand Jury, committed the following overt acts in the _~ "_" S_o_uthern_D_is_tr_i_c_t~Qf_Ke_W_Y_Qr:k_~a"nd~e_l_s_ewb_er_e~ " a. On or about September 1, 1992, Ahmad Mohammad Ajaj, using an airline ticket issued in the name of "Khurram Khan," and RAMZI AHMED YOUSEF, using an airline ticket issued in the name of "Azan Muhammad," travelled together from Pakistan to John F. Kennedy International Airport, in Queens County, New York ("Kennedy Airport"). b. On or about September 1, 1992, Ahmad Mohammad Ajaj transported from Pakistan to Kennedy Airport, manuals and other materials containing, among other things, instructions on the construction and use of explosive devices, including improvised explosive devices using urea and nitric acid and nitroglycerine. 5

31 c. On or about October 14, 1992, Mohammad Salameh and Nidal Ayyad opened a joint bank account and deposited $8,567 in cash into that bank account. d. On or about October 22, 1992, Mohammad Salameh and Nidal Ayyad withdrew $8,560 in cash from their joint bank account. e. On or about October 22, 1992, Mohammad Salameh deposited $8,570 in cash into a separate bank account in his own name. f. On or about November 30, 1992, Mohammad Salameh cashed a check in the amount of $3,400 drawn on the bank account referred to in paragraph (e) above. g. On or about November 3D, 1992, one of the coconspirators, using the name "Kamal Ibraham," rented a storage shed from Space station Storage, located at 69 Mallory Avenue, Jersey City, New Jersey (the "Storage Shed"). h. On or about November 30, 1992, RAMZI AHMED YOUSEF, using the name "Kamal Ibraham," ordered certain chemicals, including urea and nitric acid, for delivery to the Storage Shed. i. On or about November 30, 1992, RAMZI AHMED YOUSEF, paid approximately $3,615 in cash for the chemicals referred to in paragraph (h) above. j. On or about February 2, 1993, Nidal Ayyad ordered certain chemicals from the same supplier as did RAMZI AHMED YOUSEF. 6

32 k. From on or about November 30, 1992, through in or about February 1993, the co-conspirators, including Mohamm~d Salameh and RAMZI AHMED YOUSEf, entered and exited the storage Shed. 1. From in or about January 1993, through in or about February 1993, the co-conspirators, including Mohammad Salameh, RAMZI AHMED YOUSEF, and ABDUL RAHMAN YASIN, mixed chemicals to produce explosive materials, including urea nitrate and nitroglycerine, in an apartment located at 40 Pamrapo Avenue, Jersey City, New Jersey. m. On or about February 9, 1993, at approximately 1:00 a.m., RAMZI AHMED YOUSEF placed a call from a coin-orerated telephone located at Pamrapo Avenue to EYAD ISMOIL at the Casa View Grocery in Dallas, Texas. n. On or about February 9, 1993, EYAD ISMOIL purchased an airline ticket in Dallas, Texas. o. On or about February 21, 1993, EYAD ISMOIL travelled from Dallas, Texas to Kennedy Airport. p. On or about February 23, 1993, Mohammad Salameh rented a Ryder van (the "Ryder van") from an office located in Jersey City, New Jersey. q. On or about February 25, 1993, Nidal Ayyad placed a telephone call from Ayyad's place of business to a supplier of compressed gases. r. On or about February 25, 1993, Mohammad Salameh and another co-conspirator placed telephone calls from 7

33 the storage Shed, including a telephone call to Nidal Ayyad at Ayyad's place of business. s. On or about February 25, 1993, Mohammad Salameh accepted delivery of three tanks of hydrogen gas at the Storage Shed from the same supplier of compressed gases referred to in paragraph (q) above. t. On or about February 25, 1993, RAMZI AHMED YOUSEF and Mohammad Salameh, among others, loaded the three tanks of hydrogen gas into the Ryder van. u. On or about February 25, 1993, EYAD ISMaIL registered at a hotel in Brooklyn, New York, using a fictitious address on Kennedy Boulevard in Jersey City, New Jersey, and I the make of his car as a van. v. On or about February 25, 1993, Mohammad Salameh reported the Ryder van stolen to the police. w. On or about February 26, 1993, the coconspirators transported an improvised explosive device that was inside the Ryder van from New Jersey to New York. x. On or about February 26, 1993, EYAD ISMaIL drove the Ryder van into the public garage area beneath the World Trade Center complex in New York, New York. y. On or about February 26, 1993, the coconspirators caused an improvised explosive device that was inside the Ryder van to explode in the garage area beneath the Vista Hotel, located at the World Trade Center complex in New 8

34 York, New York, causing personal injury to numerous persons and the death of six persons. z. On or about February 26, 1993, RAMZI AHMED YOUSEF, using an airline ticket issued in the name of "Abdul Basit," boarded a flight from Kennedy Airport to Karachi, Pakistan. aa. On or about February 26, 1993, EYAD ISMaIL boarded a flight from Kennedy Airport to Amman, Jordan. abo On or about March 2, 1993, Mahmud Abouhalima boarded a flight from Kennedy Airport to Jeddah, Saudi Arabia. ac. On or about March 4, 1993, Mohammad Salameh returned to the Ryder office in Jersey City, New Jersey. =a=d~. O~n~. or about March 5l~93, ABDUL RAHMAN YASIN, boarded a flight from Kennedy Airport to Amman, Jordan. ae. In or about late February or early March 1993, Nidal Ayyad prepared a letter claiming responsibility for the bombing of the World Trade Center on behalf of the "Liberation Army Fifth Battalion Al Fareeq Al Rokn, Abu Bakr Al Makkee," listing certain political demands and threatening future acts of terrorism. af. On or about March 10, 1993, Nidal Ayyad possessed a modified timing device. (Title 18, United States Code, section 371.) 9

35 COUNT TWO The Grand Jury further charges: 7. On or about February 26, 1993, in the Southern District of New York, RAMZI AHMED YOUSEF, ajkja "Azan Muhammad," ajkja "Khurram Khan," ajkja "Rashed," ajkja "Kamal Ibraham," ajkja "Abdul Basit," ajkja "Adam Ali Qasim," ajkja "Naji Haddad," ajkja "Dr. Paul Vijay," ajkja "Dr. Adel Sabah," ajkja "Amaldo Forlani," ajkja "Muhammad Ali Baloch," EYAD ISMaIL, ajkja "Eyad Ismail," ajkja "Iyad Mahmoud Ismaeel Najim," and ABDUL RAHMAN YASIN, ajkja "Aboud," the defendants, along with Mohammad Salameh, ajkja "Kamal Ibraham," Nidal Ayyad, Mahmud Abouhalima, and Ahmad Mohammad Ajaj, ajkja "Khurram Khan," co-conspirators not named as defendants herein, and others known and unknown to the Grand Jury, unlawfully, wilfully, knowingly, and maliciously did damage and destroy, by means of fire and an explosive, a building used in interstate and foreign commerce and in activities affecting interstate and foreign commerce, and personal injury and death did result, to wit, the defendants did damage the World Trade Center complex located in New York, New York by use of an improvised explosive device, causing personal injury to numerous persons and further causing the death of six persons: John DiGiovanni, Robert Kirkpatrick, Stephen Knapp, William Macko, Wilfredo Mercado and Monica smith. (Title 18, United States Code, sections 844(i) and 2.) 10

36 COUNT THREE The Grand Jury further charges: 8. On or about February 26, 1993, in the Southern District of New York, RAMZI AHMED YOUSEF, ajkja "Azan Muhammad," ajkja "Khurram Khan," ajkja "Rashed," ajkja "Kamal Ibraham," ajkja "Abdul Basit," ajkja "Adam Ali Qasim," ajkja "Naji Haddad," ajkja "Dr. Paul Vijay," ajkja "Dr. Adel Sabah," ajkja "Amaldo Forlani," ajkja "Muhammad Ali Baloch," EYAD ISMaIL, ajkja "Eyad Ismail," ajkja "Iyad Mahmoud Ismaeel Najim," and ABDUL RAHMAN YASIN, ajkja "Aboud," the defendants, along with Mohammad Salameh, ajkja "Kamal Ibraham," Nidal Ayyad, Mahmud Abouhalima, and Ahmad Mohammad Ajaj, ajkja "Khurram Khan," co-conspirators. ~not named as defendants herein, and others known and unknown to the Grand Jury, unlawfully, wilfully, knowingly, and maliciously did damage and destroy, by means of fire and an explosive, a building, vehicles, and other real and personal property, in whole or in part owned, possessed, used by, and leased to the united states and departments and agencies thereof, and personal injury and death did result, to wit, the defendants did damage the World Trade Center complex, which was in part used and leased by the united States Customs Service and the united states Secret Service, and numerous vehicles owned, possessed and used by the United States Secret Service, by use of an improvised explosive device, causing personal injury to numerous persons and further causing the death of six persons: John DiGiovanni, Robert 11

37 Kirkpatrick, stephen Knapp, William Macko, Wilfredo Mercado and Monica smith. (Title 18, united states Code, sections 844(f) and 2.) COUNT FOUR The Grand Jury further charges: 9. On or about February 26, 1993, in the Southern District of New York, RAMZI AHMED YOUSEF, ajkja "Azan Muhammad, II ajkja "Khurram Khan," ajkja "Rashed,1I ajkja IIKamal Ibraham," ajkja "Abdul Basit," ajkja "Adam Ali Qasim," ajkja "Naji Haddad," ajkja "Dr. Paul Vijay," ajkja "Dr. Adel Sabah," ajkja "Arnaldo Forlani," ajkja "Muhammad Ali Baloch," EYAD ISMOIL, ajkja "Eyad Ismail," ajkja "Iyad Mahmoud Ismaeel Najim,1I and ABDUL RAHMAN YASIN, ajkja "Aboud, II the defendants,~ong with Mohammad Salameh, ajkja "Kamal Ibraham," Nidal Ayyad, Mahmud Abouhalima, and Ahmad Mohammad Ajaj, ajkja "Khurram Khan," co-conspirators not named as defendants herein, and others known and unknown to the Grand Jury, unlawfully, wilfully, and knowingly did transport in interstate commerce an explosive with the knowledge and intent that the explosive was to be used unlawfully to damage and destroy, a building, vehicles and other real and personal property, and personal injury and death did result, to wit, the defendants did transport an improvised explosive device from New Jersey to New York knowing that the improvised explosive device was to be used to damage the World Trade Center complex, and any vehicles and other property within the complex, causing personal injury to numerous persons and further causing the death of six 12

38 persons: John DiGiovanni, Robert Kirkpatrick, Stephen Knapp, William Macko, Wilfredo Mercado and Monica smith. (Title 18, United states Code, sections 844(d) and 2.) COUNT FIVE The Grand Jury further charges: 10. On or about February 26, 1993, in the Southern District of New York, RAMZI AHMED YOUSEF, ajkja "Azan Muhammad," ajkja "Khurram Khan," ajkja "Rashed," ajkja "Kamal Ibraham," ajkja "Abdul Basit," ajkja "Adam Ali Qasim," ajkja "Naji Haddad," ajkja "Dr. Paul Vijay," ajkja "Dr. Adel Sabah," ajkja "Amaldo Forlani," ajkja "Muhammad Ali Baloch," EYAD ISMOIL, ajkja "Eyad Ismail," ajkja "Iyad Mahmoud Ismaeel Najim," and ABDUL RAHMAN YASIN,~L~La "Aboud," the defendants, along with Mohammad ~ Salameh, ajkja "Kamal Ibraham," Nidal Ayyad, Mahmud Abouhalima, and Ahmad Mohammad Ajaj, ajkja "Khurram Khan," co-conspirators not named as defendants herein, and others known and unknown to the Grand Jury, unlawfully, wilfully, knowingly, and with a reckless disregard for the safety of human life, did damage, disable, destroy, and place and cause to be placed an explosive and other destructive substances in, upon and in proximity to, a motor vehicle which was used, operated and employed in interstate commerce, and death did result, to wit, the defendants did place and cause to be placed an improvised explosive device inside a Ryder rental van bearing Alabama license plate number XA70668, which improvised explosive device exploded inside the van, causing damage to and destroying the van, and causing the death 13