# United States of America v. Sufyian Barhoumi

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| UNITED STATES OF AMERICA v. SUFYIAN BARHOUMI a/k/a Abu Obaida a/k/a Ubaydah Al Jaza'iri a/k/a Shafiq | CHARGE: CONSPIRACY |

## JURISDICTION

| 1. | Jurisdiction for the Military Commission is based on the President's determination of July 6, 2004 that Sufyian Barhoumi (a/k/a Abu Abaida a/k/a Ubaydah Al Jaza'iri a/k/a Shafiq hereinafter "Barhoumi") is subject to his Military Order of November 13, 2001. |
| 2. | The charged conduct alleged alleged against Barhoumi is triable by a military commission. |

## GENERAL ALLEGATIONS

| 3. | Al Qaida ("the Base"), was founded by Usama bin Laden and others in or about 1989 for the purpose of opposing certain governments and officials with force and violence. |
| 4. | Usama bin Laden is recognized as the emir (prince or leader) of al Qaida. |
| 5. | A purpose or goal of al Qaida, as stated by Usama bin Laden and other al Qaida leaders, is to support violent attacks against property and nationals (both military and civilian) of the United States and other countries for the purpose of, inter alia, forcing the United States to withdraw its forces from the Arabian Peninsula and in retaliation for U.S. support of Israel. |
| 6. | Al Qaida operations and activities are directed by a shura (consultation) council composed of communities, including: political committee; military committee; security committee; finance committee; media committee; and religious/legal committee. |
| 7. | Between 1989 and 2001, al Qaida established training camps, guest houses and business operations in Afghanistan, Pakistan, and other countries for the purpose of training and supporting violent attacks against property and nationals (both military and civilian) of the United States and other countries. |
| 8. | In 1992 and 1993, al Qaida supported violent opposition of US. property and nationals by, among other things, transporting personnel, weapons, explosives, and ammunition to Yemen, Saudi Arabia, Somalia, and other countries. |
| 9. | In August 1996, Usama bin Laden issued a public "Declaration of Jihad Against the Americans," in which he called for the murder of U.S. military personnel serving on the Arabian peninsula. |
| 10. | In February 1998, Usama bin Laden, Ayman al Zawahir, and others, under the banner of "International Islamic Front for Fighting Jews and Crusaders," issued a fatwa (purported religious ruling) — requiring all Muslims able to do so to kill Americans y whether civilian or military — anywhere they can be found and to "plunder their money." |
| 11. | On or about May 29, 1998, Usama bin Laden issued a statement entitled "The Nuclear Bomb of Islam," under the banner of the "International Islamic Front for Fighting Jews and Crusaders" in which he stated that "it is the duty of the Muslims to prepare as much force as possible to terrorize the enemies of God." |
| 12. | Since 1989 members and associates of al Qaida, known and unknown, have carried out numerous terrorist attacks, including, but not limited to: the attacks against the American Embassies in Kenya and Tanzania in August 1998; the attack against the USS COLE in October 2000; and the attacks on the United States on September 11, 2001. |

## CHARGE: CONSPIRACY

| 13. | Sufyian Barhoumi, Jabran Said bin al Qahtani, and Ghassan al Sharbi in the United States, Afghanistan, Pakistan, and other countries, from on or about January 1996 to on or about March 2002, willfully and knowingly joined an enterprise of persons who shared a common criminal purpose and conspired and agreed with Usama bin Laden (a/k/a Abu Abdullah), Saif al Adel, Dr. Ayman al Zawahiri (a/k/a "the Doctor"), Muhammed Atef (a/k/a Abu Hafs al Masri), Zayn al Abidin Muhammad Husayn (a/k/a Abu Zubayda, hereinafter "Abu Zubayda"), Binyam Muhammad, Noor al Deen, Akrama al Sudani and other members and associates of the al Qaida organization, known and unknown, to commit the following offenses triable by military commission: attacking civilians; attacking civilian objects; murder by an unpriviledge belligerent; destruction of property by an unprivileged belligerent; and terrorism. |
| 14. | In furtherance of this enterprise and conspiracy, al Sharbi, Barhoumi, al Qahtani, Abu Zubayda, Binyam Muhammad, Noor al Deen, Akrama al Sudani, and other members or associates of al Qaida committed the following overt acts: |
| | a. In 1998 Barhoumi, and Algerian citizen, attended the electronics and explosives course at Khalden Camp in Afghanistan, an al Qaida-affiliated training camp, where he received training in constructing and dismantling electronically-controlled explosives. b. After completing his training, Barhoumi became and explosives trainer for al Qaida, training members of al Qaida on electronically-controlled explosives at remote locations. c. In or about August 2000, al Sharbi, a Saudi citizen and Electrical engineering graduate of Embry Riddle University, in Prescott, Arizone, departed the United States in search of terrorist training in Afghanistan. d. In July 2001, Muhammad Atef (a/k/a Abu Hafs al Masri), the head of al Qaida's military committee and al Qaida military commander, wrote a letter to Abu Muhammad, the emir of al Qaida's al Farouq Camp, asking him to select two "brothers" from the camp to receive electronically-controlled explosives training in Pakistan, for the purpose of establishing a new and independent section of the military committee. e. In July 2001, al Sharbi attended the al Qaida-run al Farouq training camp, where he was first introduced to Usama bin Laden. At al Farouq, al Sharbi's training included, inter alia, phsyical training, military tactics, weapons instruction, and firing on a variety of individual and crew-served weapons. f. During July and August 2001, al Sharbi stood watch with loaded weapons at al Farouq at times when Usama bin Laden visited the camp. g. From July 2001 to September 13, 2001, al Sharbi provided English translation for another camp attendee's military training at al Farouq, to include translating the attendee's personal bayat ("oath of allegiance") to Usama bin Laden. h. On or about September 13, 2001, anticipating a military response to al Qaida's attacks on the United States of September 11, 2001, al Sharbi and others fled the camp and were told to fire warning shots in the air if they saw American missiles approaching. i. Shortly after the September 11 2001 attacks on the United States, al Qahtani, a Saudi citizen and Electrical engineering graduate of King Saud University in Saudi Arabia, left Saudi Arabia with the intent to fight against the Northern Alliance and American Forces, whom he expected would soon by fighting in Afghanistan. j. In October 2001, al Qahtani attended a newly established terrorist training camp north of Kabul, where he received physical conditioning, and training in the PK Machine gun and AK-47 assault rifle. k. Between late December 2001 and the end of February 2002, Abu Zubayda, a high-ranking al Qaida recruiter and operational planner, assisted in moving al Sharbi, al Qahtani and Binyam Muhammad from Birmel, Afghanistan to a guest house in Faisalabad, Pakistan where they would obtain further training. l By early March 2002, Abu Zubayda, Barhoumi, al Sharbi, al Qahtani, and Binyam Muhammad had all arrived at the guest house in Faisalabad, Pakistan. Barhoumi was to train al Sharbi, al Qahtani and Binyam Muhammad in building small, hand-held remote-detonation devices for explosives that would later be used in Afghanistan against United States forces. m. In March 2002, after Barhoumi, al Sharbi and al Qahtani had all arrived at the guest house, Abu Zubayda provided approximately $1,000 U.S. Dollars for the purchase of components to be used for training al Sharbi and al Qahtani in making remote-detonation devices. n. Shortly after receiving the money for the components, Barhoumi, Noor al Deen and other individuals staying at the house went into downtown Faisalabad with a five page list of electrical equipment and devices for purchase which included, inter alia, electrical resistors, plastic resistors, light bulbs for circuit board lights, plastic and ceramic diodes, circuit testing boards, an ohmmeter, watches, soldering wire, soldering guns, wire and coil, six cell phones of a specified model, transformers and an electronics manual. o. After purchasing the necessary components, al Qahtani and al Sharbi received training from Barhoumi on how to build hand-held remote-detonation devices for explosives while at the guest house. p. During March 2002, after his initial training, al Qahtani was given the mission of constructing as many circuit boards as possible with the intent to ship them to Afghanistan to be used as timing devices in bombs. q.After their training was completed and a sufficient number of circuit boards were built, Abu Zubayda had directed that al Qahtani and al Sharbi were to return to Afghanistan in order to use, and to train others to construct remote-controlled devices to detonate car bombs against United States forces. r. During March 2002 al Qahtani wrote two instructional manuals on assembling circuit boards that could be used as timing devices for bombs and other improvised explosive devices. |
| 15. | On March 28, 2002, Barhoumi, al Sharbi, al Qahtani, Abu Zubayda and others were captured in a safe house in Faisalabad after authorities raided the home. |
This work is in the public domain in the United States because it is a work of the United States federal government (see 17 U.S.C. 105).
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