MOUSSAOUI Lies to Federal Agents

74. On or about August 17, 2001, ZACARIAS MOUSSAOUI, while being
interviewed by federal agents in Minneapolis, attempted to explain his presence in the United

States by falsely stating that he was simply interested in learning to fly.

Jarrah (#93) Undertakes “Check Ride” At Flight School

75. | Onor about August 17, 2001, Ziad Jarrah (#93) undertook a “check ride” at a
flight school in Fort Lauderdale, Florida.

Final Preparations for the Coordinated Air Attack

76. On or about August 22, 2001, Fayez Ahmed (#175) used his VISA card in Florida
to obtain approximately $4,900 cash, which had been deposited into his Standard Chartered Bank
account in UAE the day before.

77. Onor about August 22, 2001, in Miami, Florida, Ziad Jarrah (#93) purchased an
antenna for a Global Positioning System (“GPS”), other GPS related equipment, and schematics
for 757 cockpit instrument diagrams. (GPS allows an individual to navigate to a position using
coordinates pre-programmed into the GPS unit.)

78. Onor about August 25, 2001, Khalid al-Midhar and Majed Moged purchased
with cash tickets for American Airlines Flight 77, from Virginia to Los Angeles, California,
scheduled for September 11, 2001.

79. On or about August 26, 2001, Waleed al-Shehri and Wail al-Shehri made
reservations on American Airlines Flight 11, from Boston, Massachusetts, to Los Angeles,
California, scheduled for September 11, 2001, listing a telephone number in Florida ("Florida
Telephone #1") as a contact number.

20


Atta (#11) Purchases More Flight Training Equipment

39. | Onor about December 11, 2000, Mohammed Atta (#11) purchased flight deck
videos for the Boeing 767 Model 300ER and the Airbus A320 Model 200 from the Ohio Pilot
Store.

Flight Training and Exercise

40. Between in or about January 2001 and March 2001, Hani Hanjour (#77) attended
pilot training courses in Phoenix, Arizona, including at Pan Am International Flight Academy.

41. Between on or about February 1, 2001, and on or about February 15, 2001,
Mohammed Atta (#11) and Marwan al-Shehhi (#175) took a flight check ride around Decatur,
Georgia.

42. In or about February 2001, Mohammed Atta (#11) and Marwan al-Shehhi (#175)
attended a health club in Decatur, Georgia.

MOUSSAOUI Comes to the United States

43. Onor about February 7, 2001, ZACARIAS MOUSSAOUI flew from Pakistan to
London, England.

44, On or about February 23, 2001, ZACARIAS MOUSSAOUI flew from London,
England to Chicago, Illinois, declaring at least $35,000 cash on his Customs declaration, and
then from Chicago to Oklahoma City, Oklahoma.

45. | Onor about February 26, 2001, ZACARIAS MOUSSAOUI opened a bank

account in Norman, Oklahoma, depositing approximately $32,000 cash.

14


767, which had departed from Boston at approximately 8:15 a.m. They flew Flight 175 into the
South Tower of the World Trade Center in Manhattan at approximately 9:05 a.m., causing the
collapse of the tower and the deaths of thousands of persons.

106. On or about September 11, 2001, Khalid al-Midhar, Majed Moged, Nawaf al-
Hazmi, Salem al-Hazmi, and Hani Hanjour hijacked American Airlines Flight 77, a Boeing 757,
which had departed from Virginia bound for Los Angeles, at approximately 8:10 a.m. They flew
Flight 77 into the Pentagon in Virginia at approximately 9:40 a.m., causing the deaths of 189
persons.

107. On or about September 11, 2001, Saeed al-Ghamdi, Ahmed al-Nami, Ahmed al-
Haznawi, and Ziad Jarrah hijacked United Airlines Flight 93, a Boeing 757, which had departed
from Newark, New Jersey bound for San Francisco at approximately 8:00 a.m. After resistance
by the passengers, Flight 93 crashed in Somerset County, Pennsylvania at approximately 10:10
a.m., killing all on board.

Al-Hawsawi Flees the U.A.E. for Pakistan

108. On September 11, 2001, Mustafa Ahmed al-Hawsawi left the U.A.E. for Pakistan.

109. On September 13, 2001, the VISA card connected to Al-Hawsawi’s account was
used to make six ATM withdrawals in Karachi, Pakistan.

A Co-Conspirator Calls On Muslims To Fight The United States
110. On or about October 7, 2001, in Afghanistan, Ayman al-Zawahiri called on

Muslims to join the battle against the United States.

24


members and associates to monitor media reporting of its operations to determine the
effectiveness of their terrorist activities.

8. Since in or about 1996, Usama Bin Laden and others operated al Qaeda from their
headquarters in Afghanistan. During this time, Bin Laden and others forged close relations with
the Taliban in Afghanistan. To that end, Bin Laden informed other al Qaeda members and
associates outside Afghanistan of their support of, and alliance with, the Taliban. Bin Laden also
endorsed a declaration of jihad (holy war) issued by the "Ulema Union of Afghanistan."

The September 11 Hijackers

9. On September 11, 2001, co-conspirators Mohammed Atta, Abdul Alomari, Wail
al-Shehri, Waleed al-Shehri, and Satam al-Suqami hijacked American Airlines Flight 11, bound
from Boston to Los Angeles, and crashed it into the North Tower of the World Trade Center in
New York. (In this Indictment, each hijacker will be identified with the flight number of the
plane he hijacked.)

10. On September 11, 2001, co-conspirators Marwan al-Shehhi, Fayez Ahmed, a/k/a
“Banihammad Fayez,” Ahmed al-Ghamdi, Hamza al-Ghamdi, and Mohald al-Shehri hijacked
United Airlines Flight 175, bound from Boston to Los Angeles, and crashed it into the South
Tower of the World Trade Center in New York.

11. On September 11, 2001, co-conspirators Khalid al-Midhar, Nawaf al-Hazmi, Hani
Hanjour, Salem al-Hamzi, and Majed Moged hijacked American Airlines Flight 77, bound from

Virginia to Los Angeles, and crashed it into the Pentagon.


80. On or about August 27, 2001, reservations for electronic, one-way tickets were
made for Fayez Ahmed and Mohald al-Shehri, for United Airlines Flight 175, from Boston,
Massachusetts, to Los Angeles, California, scheduled for September 11, 2001, listing Florida
Telephone Number #1 as a contact number.

81. On or about August 27, 2001, Nawaf al-Hazmi and Salem al-Hazmi booked
flights on American Airlines Flight 77.

82. On or about August 28, 2001, Satam al-Suqami purchased a ticket with cash for
American Airlines Flight 11.

83. On or about August 28, 2001, Mohammed Atta and Abdulaziz Alomari reserved
two seats on American Airlines Flight 11, listing Florida Telephone #1 as a contact number.

84. | Onor about August 29, 2001, Ahmed al-Ghamdi and Hamza al-Ghamdi reserved
electronic, one-way tickets for United Airlines Flight 175.

85. On or about August 29, 2001, Ahmed al-Haznawi purchased a ticket on United
Airlines Flight 93 from Newark, New Jersey, to San Francisco, California, scheduled for
September 11, 2001.

86. | Onor about August 30, 2001, Mohammed Atta (#11) purchased a utility tool that
contained a knife.

87. On or about September 3, 2001, in Hamburg, Germany, Ramzi Bin al-Shibh,
using the name “Ahad Sabet,” received approximately $1500 by wire transfer from “Hashim
Ahmed” in UAE.

88. | Onor about September 4, 2001, Mohammed Atta (#11) sent a FedEx package
from Florida to UAE.

21


COUNT THREE
(Conspiracy to Destroy Aircraft)

1. The allegations contained in Count One are repeated.

2. From in or about 1989 until the date of the filing of this Indictment, in the Eastern
District of Virginia, the Southern District of New York, and elsewhere, the defendant,
ZACARIAS MOUSSAOUI, a/k/a “Shaqil,” a/k/a “Abu Khalid al Sahrawi,” and other members
and associates of al Qaeda and others known and unknown to the Grand Jury, unlawfully,
wilfully and knowingly combined, conspired, confederated and agreed to willfully destroy and
wreck aircraft in the special aircraft jurisdiction of the United States, and to willfully perform
acts of violence against and incapacitate individuals on such aircraft, so as likely to endanger the
safety of such aircraft, resulting in the deaths of thousands of persons on September 11, 2001.

Overt Acts

3. In furtherance of the conspiracy, and to effect its illegal objects, the defendant,
and others known and unknown to the Grand Jury, committed the overt acts set forth in Count
One of this Indictment, which are fully incorporated by reference.

(In violation of Title 18, United States Code, Sections 32(a)(7) and 34.)

27


from the $8,055 in Fayez Ahmed’s (#175) Standard Chartered Bank account into his own
account, using a check dated September 10, 2001 and signed by Fayez Ahmed; Al-Hawsawi then
withdrew approximately $1,361, nearly all the remaining balance in Ahmed’s account, by ATM
cash withdrawal.

99. On September 11, 2001, in UAE, approximately $40,871 was prepaid to a VISA
card connected to Al-Hawsawi’s Standard Chartered Bank account.

The September 11, 2001 Terrorist Attacks

100. On or about September 11, 2001, the hijackers possessed a handwritten set of
final instructions for a martyrdom operation on an airplane using knives.

101. On or about September 11, 2001, Mohammed Atta (#11) and Abdulaziz Alomari
(#11) flew from Portland, Maine to Boston, Massachusetts.

102. On or about September 11, 2001, Mohammed Atta (#11) possessed operating
manuals for the Boeing 757 and 767, pepper spray, knives, and German travel visas.

103. On or about September 11, 2001, Ziad Jarrah (#93) possessed flight manuals for
Boeing 757 and 767 aircraft.

104. On or about September 11, 2001, Mohammed Atta, Abdul Aziz Alomari, Satam
al-Suqami, Waleed M. al-Shehri, and Waleed al-Shehri hijacked American Airlines Flight 11, a
Boeing 767, which had departed Boston at approximately 7:55 a.m. They flew Flight 11 into the
North Tower of the World Trade Center in Manhattan at approximately 8:45 a.m., causing the
collapse of the tower and the deaths of thousands of persons.

105. On or about September 11, 2001, Hamza al-Ghamdi, Fayez Ahmed, Mohald al-
Shehri, Ahmed al-Ghamdi, and Marwan al-Shehhi hijacked United Airlines Flight 175, a Boeing

23


66. Onor about July 30 and 31, 2001, in Hamburg, Germany, Ramzi Bin al-Shibh,
using the name “Ahad Sabet,” received two wire transfers, totaling approximately $15,000, from
“Hashim Abdulrahman” in UAE.

67. Onor about August 1 and 3, 2001, Ramzi Bin al-Shibh, using the name "Ahad
Sabet," wired approximately $14,000 in money orders to ZACARIAS MOUSSAOUI in
Oklahoma from train stations in Dusseldorf and Hamburg, Germany.

MOUSSAOUI Purchases Knives

68. Onor about August 3, 2001, ZACARIAS MOUSSAOUI purchased two knives in
Oklahoma City, Oklahoma.

Jarrah (#93) Returns to the United States from Germany

69. Onor about August 4, 2001, Ziad Jarrah (#93) traveled from Germany to the

United States.
MOUSSAOUI Travels from Oklahoma to Minnesota

70. | Onor about August 9 and August 10, 2001, ZACARIAS MOUSSAOUI was

driven from Oklahoma to Minnesota.
MOUSSAOUI Takes Commercial Flying Lessons in Minnesota

71. | Onor about August 10, 2001, in Minneapolis, Minnesota, ZACARIAS
MOUSSAOUI paid approximately $6,300 in cash to the Pan Am International Flight Academy.

72. Between August 13 and August 15, 2001, ZACARIAS MOUSSAOUI attended
the Pan Am International Flight Academy in Minneapolis, Minnesota, for simulator training on

the Boeing 747 Model 400.

18


Bin Laden Endorses the Nuclear Bomb of Islam

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 the
Jews and the 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.”

Usama Bin Laden Issues Further Threats in June 1999
12. In or about June 1999, in an interview with an Arabic-language television station,

Usama Bin Laden issued a further threat indicating that all American males should be

killed.
Usama Bin Laden Calls for "Jihad" to Free Imprisoned Terrorists

13. In or about September 2000, in an interview with an Arabic-language television

station, Usama Bin Laden called for a "jihad" to release the "brothers" in jail "everywhere."
MOUSSAOUI Trains at Al Qaeda Training Camp

14. In or about April 1998, ZACARIAS MOUSSAOUI was present at the al Qaeda-

affiliated Khalden Camp in Afghanistan.
The German Cell

15. Beginning in and about 1998, Ramzi Bin al-Shibh, Mohammed Atta (#11),

Marwan al-Shehhi (#175), and Ziad Jarrah (#93), and others, formed and maintained an al Qaeda

terrorist cell in Germany.


COUNT SIX
(Conspiracy to Destroy Property of the United States)

1. The allegations contained in Count One are repeated.

2. From in or about 1989 until the date of the filing of this Indictment, in the Eastern
District of Virginia, the Southern District of New York, and elsewhere, the defendant,
ZACARIAS MOUSSAOUI, a/k/a “Shaqil,” a/k/a “Abu Khalid al Sahrawi,” and other members
and associates of al Qaeda and others known and unknown to the Grand Jury, unlawfully,
wilfully and knowingly combined, conspired, confederated and agreed to maliciously damage
and destroy, by means of fire and explosives, buildings, vehicles, and other real and personal
property used in interstate and foreign commerce and in activities affecting interstate and foreign
commerce, and buildings, vehicles, and other personal and real property in whole and in part
owned and possessed by, and leased to, the United States and its departments and agencies, and
as a result of such conduct directly and proximately caused the deaths of thousands of persons on
September 11, 2001, including hundreds of public safety officers performing duties as a direct
and proximate result of the said damage and destruction.

Overt Acts

3. In furtherance of the conspiracy, and to effect its illegal objects, the defendant,

and others known and unknown to the Grand Jury, committed the overt acts set forth in Count

One of

30


within the United States, and to create a substantial risk of serious bodily injury to other persons
by destroying and damaging structures, conveyances, and other real and personal property within
the United States, in violation of the laws of States and the United States, in circumstances
involving conduct transcending national boundaries, and in which facilities of interstate and
foreign commerce were used in furtherance of the offense, the offense obstructed, delayed, and
affected interstate and foreign commerce, the victim was the United States Government,
members of the uniformed services, and officials, officers, employees, and agents of the
governmental branches, departments, and agencies of the United States, and the structures,
conveyances, and other real and personal property were, in whole or in part, owned, possessed,
and leased to the United States and its departments and agencies, resulting in the deaths of
thousands of persons on September 11, 2001.
Overt Acts

In furtherance of the conspiracy, and to effect its objects, the defendant, and others known

and unknown to the Grand Jury, committed the following overt acts:
The Provision of Guesthouses and Training Camps

1. At various times from at least as early as 1989, Usama Bin Laden, and others

known and unknown, provided training camps and guesthouses in Afghanistan, including camps

known as Khalden, Derunta, Khost, Siddiq, and Jihad Wal, for the use of al Qaeda and its

affiliated groups.
The Training
2. At various times from at least as early as 1990, unindicted co-conspirators, known

and unknown, provided military and intelligence training in various areas, including

7


12. On September 11, 2001, co-conspirators Ziad Jarrah, Ahmed al-Haznawi, Saaed
al-Ghamdi, and Ahmed al-Nami hijacked United Airlines Flight 93, bound from Newark to San
Francisco, and crashed it in Pennsylvania.

The Defendant

13. ZACARIAS MOUSSAOUL, a/k/a “Shaqil,” a/k/a “Abu Khalid al Sahrawi,” was
born in France of Moroccan descent on May 30, 1968. Before 2001 he was a resident of the
United Kingdom. MOUSSAOUI held a masters degree from Southbank University in the United
Kingdom and traveled widely.

MOUSSAOUI’s Supporting Conspirators

14. Ramzi Bin al-Shibh, a/k/a “Ahad Sabet,” a/k/a “Ramzi Mohamed Abdellah
Omar,” was born in Yemen on May 1, 1972. He entered Germany in or about 1995 and
afterwards lived in Hamburg, where he shared an apartment with hijacker Mohammed Atta (#11)
in 1998 and 1999, Bin al-Shibh also was employed with Atta as a warehouse worker at a
computer company in Hamburg.

15. Mustafa Ahmed al-Hawsawi, a/k/a “Mustafa Ahmed,” was born in Jeddah, Saudi
Arabia on August 5, 1968.

The Charge

16. From in or about 1989 until the date of the filing of this Indictment, in the Eastern
District of Virginia, the Southern District of New York, and elsewhere, the defendant,
ZACARIAS MOUSSAOUI, a/k/a “Shagil,” a/k/a “Abu Khalid al Sahrawi,” with other members
and associates of al Qaeda and others known and unknown to the Grand Jury, unlawfully,
wilfully and knowingly combined, conspired, confederated and agreed to kill and maim persons

6


MOUSSAOUI Possesses Knives and Other Items
723. On or about August 16, 2001, ZACARIAS MOUSSAOUI possessed, among
other things:

- two knives;

- a pair of binoculars;

- flight manuals for the Boeing 747 Model 400;

- a flight simulator computer program;

- fighting gloves and shin guards;

- a piece of paper referring to a handheld Global Positioning System
receiver and a camcorder;

- software that could be used to review pilot procedures for the Boeing 747
Model 400;

- a notebook listing German Telephone #1, German Telephone #2, and the
name “Ahad Sabet;”

- letters indicating that MOUSSAOUI is a marketing consultant in the
United States for Infocus Tech;

- a computer disk containing information related to the aerial application of
pesticides; and

- a hand-held aviation radio.

19


other members and associates of al Qaeda that the United States forces stationed in the Hom of
Africa, including Somalia, should be attacked.
The Fatwah Regarding Deaths of Nonbelievers

7. On various occasions, an unindicted co-conspirator advised other members of al
Qaeda that it was Islamically proper to engage in violent actions against “infidels”
(nonbelievers), even if others might be killed by such actions, because if the others were
“tnnocent,” they would go to paradise, and if they were not “innocent,” they deserved to die.

The August 1996 Declaration of War

8. On or about August 23, 1996, a Declaration of Jihad indicating that it was from
the Hindu Kush mountains in Afghanistan entitled, “Message from Usamah Bin-Muhammad
Bin-Laden to His Muslim Brothers in the Whole World and Especially in the Arabian Peninsula:
Declaration of Jihad Against the Americans Occupying the Land of the Two Holy Mosques;

Expel the Heretics from the Arabian Peninsula” was disseminated.

The February 1998 Fatwah Against American Civilians
9. In February 1998, Usama Bin Laden endorsed a fatwah under the banner of the
"International Islamic Front for Jihad on the Jews and Crusaders." This fatwah, published in the
publication Al-Quds al-‘Arabi on February 23, 1998, stated that Muslims should kill Americans -
including civilians - anywhere in the world where they can be found.
10. In an address in or about 1998, Usama Bin Laden cited American aggression

against Islam and encouraged a jihad that would eliminate the Americans from the Arabian

Peninsula.


Bin Laden Praises The September 11 Attack And Threatens More Attacks

111. On or about October 7, 2001, in Afghanistan, Usama Bin Laden praised the
September 11 attack, and vowed that the United States would not “enjoy security” before “infidel

armies leave” the Saudi Gulf.

A Co-Conspirator Solicits Violence Against United States Nationals

112. On or about October 10, 2001, Sulieman Abu Ghaith announced, on behalf of al
Qaeda, that all Muslims had a duty to attack United States targets around the world.

(In violation of Title 18, United States Code, Sections 2332b(a)(2) and 2332b(c).)

25


IN THE UNITED STATES DISTRICT COUR’

FOR THE EASTERN DISTRICT OF VIRGINL

rape!

FILED
1N OPEN COURT

BEL #1 2B

ERK, US. DISTRICT COURT
CoE EMANDRIA, VIRGINIA

ALEXANDRIA DIVISION

UNITED STATES OF AMERICA

“ve

ZACARIAS MOUSSAOUI,
a/k/a “Shaqil,”

a/k/a “Abu Khalid al Sahrawi,”

Defendant.

SS SSS SS SH SH HS SH WS SH HS SH SH SYS YS SS SESS SY

CRIMINALNO: O1- 45'S -AA

Conspiracy to Commit Acts of Terrorism
Transcending National Boundaries

(18 U.S.C. §§ 2332b(a)(2) & (c))

(Count One)

Conspiracy to Commit Aircraft Piracy
(49 U.S.C. §§ 46502(a)(1)(A) and (a)(2)(B))
(Count Two)

Conspiracy to Destroy Aircraft
(18 U.S.C. §§ 32(a)(7) & 34)
(Count Three)

Conspiracy to Use Weapons of Mass
Destruction

(18 U.S.C. § 2332a(a))

(Count Four)

Conspiracy to Murder United States
Employees

(18 U.S.C. §§ 1114 & 1117)
(Count Five)

Conspiracy to Destroy Property
(18 U.S.C. §§ 844(f), (i), (n))
(Count Six)

DECEMBER 2001 TERM - AT ALEXANDRIA.

INDICTMENT

THE GRAND JURY CHARGES THAT:


24.  Onor about August 7, 2000, $9,485 was wired from UAE into a Florida SunTrust
bank account in the names of Mohammed Atta (#11) and Marwan al-Shehhi (#175).

25. On or about August 30, 2000, $19,985 was wired from UAE into a Florida
SunTrust bank account in the names of Mohammed Atta (#11) and Marwan al-Shehhi (#175).

26. On or about September 18, 2000, $69,985 was wired from UAE into a Florida
SunTrust bank account in the names of Mohamed Atta (#11) and Marwan al-Shehhi (#175).

Jarrah (#93) Attempts to Enroll Bin al-Shibh in Flight Training Courses

27. In or about August 2000, Ziad Jarrah (#93) attempted to enroll Ramzi Bin al-
Shibh in a flight school in Florida.

28.  Onor about May 17, 2000, in Germany, Ramzi Bin al-Shibh applied for a visa to
travel to the United States, listing a German telephone number (“German Telephone #1") . This
visa application was denied.

29. Onor about June 15, 2000, in Germany, Ramzi Bin al-Shibh applied for a visa to
travel to the United States. This visa application was denied.

30. On or about August 14, 2000, in Yemen, Ramzi Bin al-Shibh arranged to wire
money from his account in Germany to the account of a flight training school in Florida.

31. | Onor about September 15, 2000, in Yemen, Ramzi Bin al-Shibh applied for a
visa to travel to the United States, listing a residence in Hamburg, Germany. This visa
application was denied in September 2000.

32. | Onor about October 25, 2000, in Germany, Ramzi Bin al-Shibh applied for a

visa to travel to the United States. This visa application was denied.

12


Hijackers Travel to the United States

16. | Onor about January 15, 2000, Khalid al-Midhar (#77) and Nawaf al-Hazmi (#77)

traveled from Bangkok, Thailand, to Los Angeles, California.
Atta (#11) Inquires About Aerial Application of Pesticides

17. At various times in 2000 and 2001, in Florida, Mohammed Atta (#11) made

inquiries regarding starting a crop dusting company.
Hijackers Receive Flight Training

18. Onor about June 3, 2000, Mohammed Atta (#11) traveled to the United States
from Prague, Czech Republic.

19. In or about early July 2000, Mohammed Atta (#11) and Marwan al-Shehhi (#175)
visited the Airman Flight School in Norman, Oklahoma.

20. Between in or about July 2000 and in or about December 2000, Mohamed Atta
(#11) and Marwan al-Shehhi (#175) attended flight training classes at Huffman Aviation in
Venice, Florida.

Money is Moved to the Hijackers

21. | Onor about June 29, 2000, $4,790 was wired from the United Arab Emirates
(“UAE”) to Marwan al-Shehhi (#175) in Manhattan.

22. On or about July 19, 2000, $9,985 was wired from UAE into a Florida SunTrust
bank account in the names of Mohammed Atta (#11) and Marwan al-Shehhi (#175).

23. On or about July 26, 2000, in Germany, Ramzi Bin al-Shibh wired money to
Marwan al-Shehhi (#175) in Florida.

11


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this Indictment, which are fully incorporated by reference.

(In violation of Title 18, United States Code, Sections 844(f), (i), and (n).)

Chufa dhusloawen
a

MICHAEL CHERTOFF 7 /
/SSSISTANT ATTORNEY GENERAL

EASTERN DISTRICT OF VIRGINIA

5
MARY 6 K Hike

UNITED STATES ATTORNEY
SOUTHERN DISTRICT OF NEW YORK

31


Afghanistan, Pakistan, and the Sudan, for the use of al Qaeda and its affiliated groups, including

the Egyptian Islamic Jihad.

Financial and Business Dealings

3. At various times from at least as early as 1989 until the date of the filing of this
Indictment, Usama Bin Laden, and others known and unknown, engaged in financial and
business transactions on behalf of al Qaeda, including, but not limited to: purchasing land for
training camps; purchasing warehouses for storage of items, including explosives; purchasing
communications and electronics equipment; transferring funds between corporate accounts; and
transporting currency and weapons to members of al Qaeda and its associated terrorist
organizations in various countries throughout the world.

The Efforts to Obtain Nuclear Weapons and Their Components

4, At various times from at least as early as 1992, Usama Bin Laden, and others

known and unknown, made efforts to obtain the components of nuclear weapons.
The Fatwahs Against American Troops in Saudi Arabia and Yemen

5. At various times from in or about 1992 until the date of the filing of this
Indictment, Usama Bin Laden, working together with members of the fatwah committee of al
Qaeda, disseminated fatwahs to other members and associates of al Qaeda that the United States
forces stationed on the Saudi Arabian peninsula, including both Saudi Arabia and Yemen, should
be attacked.

The Fatwah Against American Troops in Somalia
6. At various times from in or about 1992 until in or about 1993, Usama Bin Laden,

working together with members of the fatwah committee of al Qaeda, disseminated fatwahs to

8


89. On or about September 5, 2001, Ramzi Bin al-Shibh traveled from Dusseldorf,
Germany, to Madrid, Spain, and did not return to Germany.
90. On or about September 6, 2001, Satam al-Suqami (#11) and Abdulaziz Alomari

(#11) flew from Florida to Boston.

The Hijackers Return Excess Money to Al-Hawsawi in UAE

91. Onor about September 6, 2001, approximately $8,055 was wired from Fayez
Ahmed’s (#175) Florida SunTrust account to the Standard Chartered Bank account over which
Al-Hawsawi had power of attorney.

92. On or about September 8, 2001, an Arab male retrieved the package from
Mohammed Atta (#11) at FedEx in Dubai, UAE.

93. On September 8, 2001, Mohammed Atta (#11) wired $2,860 to “Mustafa Ahmed”
in UAE.

94. On September 8, 2001, Mohammed Atta (#11) wired $5,000 to “Mustafa Ahmed”
in UAE.

95. On September 9, 2001, Waleed M. al-Shehri (#11) wired $5,000 to “Ahamad
Mustafa” in UAE.

96. On September 10, 2001, Marwan al-Shehhi (#175) wired $5,400 to “Mustafa
Ahmad” in UAE.

97. On September 11, 2001, in UAE, approximately $16,348 was deposited into Al-
Hawsawi’s Standard Chartered Bank account.

98. On September 11, 2001, in UAE, at about 9:22 a.m. local time (the early morning
hours of Eastern Daylight Time), Mustafa Ahmed al-Hawsawi moved approximately $6,534

22


COUNT FOUR
(Conspiracy to Use Weapons of Mass Destruction)

1. The allegations contained in Count One are repeated.

2. From in or about 1989 until the date of the filing of this Indictment, in the Eastern
District of Virginia, the Southern District of New York, and elsewhere, the defendant,
ZACARIAS MOUSSAOUL, a/k/a “Shagil,” a/k/a “Abu Khalid al Sahrawi,” and other members
and associates of al Qaeda and others known and unknown to the Grand Jury, unlawfully,
wilfully and knowingly combined, conspired, confederated and agreed to use weapons of mass
destruction, namely, airplanes intended for use as missiles, bombs, and similar devices, without
lawful authority against persons within the United States, with the results of such use affecting
interstate and foreign commerce, and against property that was owned, leased and used by the
United States and by departments and agencies of the United States, with the result that
thousands of people died on September 11, 2001.

Overt Acts

3. In furtherance of the conspiracy, and to effect its illegal objects, the defendant,
and others known and unknown to the Grand Jury, committed the overt acts set forth in Count
One of this Indictment, which are fully incorporated by reference.

(In violation of Title 18, United States Code, Section 2332a(a).)

28


personnel in a number of countries to facilitate its activities, including in Kenya, Tanzania, the
United Kingdom, Germany, Canada, Malaysia, and the United States.

5. Al Qaeda had a command and control structure which included a majlis al shura
(or consultation council) which discussed and approved major undertakings, including terrorist
operations. Al Qaeda also had a "military committee" which considered and approved "military"
matters.

6. Usama Bin Laden and al Qaeda also forged alliances with the National Islamic
Front in the Sudan and with representatives of the government of Iran, and its associated terrorist
group Hizballah, for the purpose of working together against their perceived common enemies in
the West, particularly the United States.

7. Since at least 1989, until the filing of this Indictment, Usama Bin Laden and the
terrorist group al Qaeda sponsored, managed, and/or financially supported training camps in
Afghanistan, which camps were used to instruct members and associates of al Qaeda and its
affiliated terrorist groups in the use of firearms, explosives, chemical weapons, and other
weapons of mass destruction. In addition to providing training in the use of various weapons,
these camps were used to conduct operational planning against United States targets around the
world and experiments in the use of chemical and biological weapons. These camps were also
used to train others in security and counterintelligence methods, such as the use of codes and
passwords, and to teach members and associates of al Qaeda about traveling to perform
operations. For example, al Qaeda instructed its members and associates to dress in "Western"

attire and to use other methods to avoid detection by security officials. The group also taught its


46. Between on or about February 26, 2001, and on or about May 29, 2001,
ZACARIAS MOUSSAOUI attended the Airman Flight School in Norman, Oklahoma, ending
his classes early.

Nawaf al-Hazmi (#77) Purchases Flight Training Equipment

47. On or about March 19, 2001, Nawaf al-Hazmi (#77) purchased flight deck videos
for the Boeing 747 Model 400, the Boeing 747 Model 200 and the Boeing 777 Model 200, and
another video from the Ohio Pilot Store.

MOUSSAOUI Joins a Gym

48. In or about March 2001, ZACARIAS MOUSSAOUI joined a gym in Norman,

Oklahoma.

Hijackers Travel to and Within the United States

49. Onor about April 1, 2001, Nawaf al-Hazmi (#77) was in Oklahoma.

50. Between on or about April 23, 2001, and on or about June 29, 2001, Satam al-
Suqami (#11), Waleed al-Shehri (#11), Ahmed al-Ghamdi (#175), Majed Moged (#77), Marwan
al-Shehhi (#175), Mohammed Atta (#11), Ahmed al-Nami (#93), Hamza al-Ghamdi (#175),
Mohald al-Shehri (#175), Wail al-Shehri (#11), Ahmed al-Haznawi (#93), Fayez Ahmed (#175),
and Salem al-Hazmi (#77) traveled from various points in the world to the United States.

MOUSSAOUI Contacts a Commercial Flight School

51. On or about May 23, 2001, ZACARIAS MOUSSAOUI contacted an office of the

Pan Am International Flight Academy in Miami, Florida via e-mail.

15


Atta (#11) and al-Shehhi (#175) Purchase a Knife
59.  Onor about July 8, 2001, Mohammed Atta (#11) purchased a knife in Zurich,
Switzerland.
MOUSSAOUI Pays for Flight Lessons
60. | Onor about July 10 and July 11, 2001, ZACARIAS MOUSSAOUI made credit
card payments to the Pan Am International Flight Academy for a simulator course in
commercial flight training.
Fayez Ahmed (#175) Gives Al-Hawsawi Control Over UAE Account
61. On July 18, 2001, Fayez Ahmed (#175) gave power of attorney to Mustafa
Ahmed al-Hawsawi for Fayez Ahmed’s Standard Chartered Bank accounts in UAE.
62. On July 18, 2001, using his power of attorney, Al-Hawsawi picked up Fayez
Ahmed’s VISA and ATM cards in UAE.
63. Between July 18 and August 1, 2001, Mustafa Ahmed al-Hawsawi caused Fayez
Ahmed’s VISA and ATM cards to be shipped from UAE to Fayez Ahmed in Florida. (The
VISA card was then used for the first time on August 1, 2001, in Florida.)

Jarrah (#93) Travels to Germany

64. On or about July 25, 2001, Ziad Jarrah (#93) traveled from the United States to

Germany.

Bin al-Shibh Moves Money to MOUSSAOUI from UAE

65. Between on or about July 29 and August 2, 2001, in Norman, Oklahoma,

ZACARIAS MOUSSAOUI made several telephone calls from public telephones to a number in

Duesseldorf, Germany (“German Telephone # 2").

17


viewed as providing essential support for other "infidel" governments and institutions,
particularly the governments of Saudi Arabia and Egypt, the nation of Israel, and the United
Nations organization, which were regarded as enemies of the group. Third, al Qaeda opposed the
involvement of the United States armed forces in the Gulf War in 1991 and in Operation Restore
Hope in Somalia in 1992 and 1993. In particular, al Qaeda opposed the continued presence of
American military forces in Saudi Arabia (and elsewhere on the Saudi Arabian peninsula)
following the Gulf War. Fourth, al Qaeda opposed the United States Government because of the
arrest, conviction and imprisonment of persons belonging to al Qaeda or its affiliated terrorist
groups or those with whom it worked. For these and other reasons, Bin Laden declared a jihad,
or holy war, against the United States, which he has carried out through al Qaeda and its
affiliated organizations.

3. One of the principal goals of al Qaeda was to drive the United States armed forces
out of Saudi Arabia (and elsewhere on the Saudi Arabian peninsula) and Somalia by violence.
Members of al Qaeda issued fatwahs (rulings on Islamic law) indicating that such attacks were
both proper and necessary.

4. Al Qaeda functioned both on its own and through some of the terrorist
organizations that operated under its umbrella, including: Egyptian Islamic Jihad, which was led
by Ayman al-Zawahiri, and at times, the Islamic Group (also known as "el Gamaa Islamia" or
simply "Gamaa't"), and a number of jihad groups in other countries, including the Sudan, Egypt,
Saudi Arabia, Yemen, Somalia, Eritrea, Djibouti, Afghanistan, Pakistan, Bosnia, Croatia,
Albania, Algeria, Tunisia, Lebanon, the Philippines, Tajikistan, Azerbaijan, and the Kashmiri
region of India and the Chechnyan region of Russia. Al Qaeda also maintained cells and

3


COUNT TW
(Conspiracy to Commit Aircraft Piracy)

1. The allegations contained in Count One are repeated.

2. From in or about 1989 until the date of the filing of this Indictment, in the Eastern
District of Virginia, the Southern District of New York, and elsewhere, the defendant,
ZACARIAS MOUSSAOUI, a/k/a “Shagil,” a/k/a “Abu Khalid al Sahrawi,” and other members
and associates of al Qaeda and others known and unknown to the Grand Jury, unlawfully,
wilfully and knowingly combined, conspired, confederated and agreed to commit aircraft piracy,
by seizing and exercising control of aircraft in the special aircraft jurisdiction of the United
States by force, violence, threat of force and violence, and intimidation, and with wrongful
intent, with the result that thousands of people died on September 11, 2001.

Overt Acts

3. In furtherance of the conspiracy, and to effect its illegal objects, the defendant,
and others known and unknown to the Grand Jury, committed the overt acts set forth in Count
One of this Indictment, which are fully incorporated by reference.

(In violation of Title 49, United States Code, Sections 46502(a)(1)(A) and (a)(2)(B).)

26


COUNT ONE
(Conspiracy to Commit Acts of Terrorism Transcending National Boundaries)

Background: al Qaeda

1. At all relevant times from in or about 1989 until the date of the filing of this
Indictment, an international terrorist group existed which was dedicated to opposing non-Islamic
governments with force and violence. This organization grew out of the "mekhtab al khidemat"
(the "Services Office") organization which had maintained offices in various parts of the world,
including Afghanistan, Pakistan (particularly in Peshawar), and the United States. The group
was founded by Usama Bin Laden and Muhammad Atef, a/k/a "Abu Hafs al Masry," together
with "Abu Ubaidah al Banshiri," and others. From in or about 1989 until the present, the group
called itself "al Qaeda" ("the Base"). From 1989 until in or about 1991, the group (hereafter
referred to as "al Qaeda") was headquartered in Afghanistan and Peshawar, Pakistan. In or about
1991, the leadership of al Qaeda, including its "emir" (or prince) Usama Bin Laden, relocated to
the Sudan. Al Qaeda was headquartered in the Sudan from approximately 1991 until
approximately 1996 but still maintained offices in various parts of the world. In 1996, Usama

Bin Laden and other members of al Qaeda relocated to Afghanistan. At all relevant times, al

Qaeda was led by its emir, Usama Bin Laden. Members of al Qaeda pledged an oath of
allegiance (called a "bayat") to Usama Bin Laden and al Qaeda. Those who were suspected of
collaborating against al Qaeda were to be identified and killed.

2. Bin Laden and al Qaeda violently opposed the United States for several reasons.
First, the United States was regarded as an "infidel" because it was not governed in a manner

consistent with the group's extremist interpretation of Islam. Second, the United States was


COUNT FIVE
(Conspiracy to Murder United States Employees)

1. The allegations contained in Count One are repeated.

2. From in or about 1989 until the date of the filing of this Indictment, in the Eastern
District of Virginia, the Southern District of New York, and elsewhere, the defendant,
ZACARIAS MOUSSAOUI, a/k/a “Shaqil,” a/k/a “Abu Khalid al Sahrawi,” and other members
and associates of al Qaeda and others known and unknown to the Grand Jury, unlawfully,
wilfully and knowingly combined, conspired, confederated and agreed to kill officers and
employees of the United States and agencies and branches thereof, while such officers and
employees were engaged in, and on account of, the performance of their official duties, and
persons assisting such employees in the performance of their duties, in violation of Section 1114
of Title 18, United States Code, including members of the Department of Defense stationed at
the Pentagon.

Overt Acts

3. In furtherance of the conspiracy, and to effect its illegal objects, the defendant,
and others known and unknown to the Grand Jury, committed the overt acts set forth in Count
One of this Indictment, which are fully incorporated by reference.

(In violation of Title 18, United States Code, Sections 1114 and 1117.)

29


Bin al-Shibh Sends Money to al-Shehhi (#175)

33. | Onor about September 25, 2000, in Hamburg, Germany, Ramzi Bin al-Shibh
sent money via wire transfer to Marwan al-Shehhi (#175) in Florida.

MOUSSAOUI Inquires About Flight Training

34. On or about September 29, 2000, ZACARIAS MOUSSAOUI contacted Airman
Flight School in Norman, Oklahoma using an e-mail account he set up on September 6 with an
internet service provider in Malaysia.

35. In or about October 2000, ZACARIAS MOUSSAOUI received letters from
Infocus Tech, a Malaysian company, stating that MOUSSAOUI was appointed Infocus Tech’s
marketing consultant in the United States, the United Kingdom, and Europe, and that he would
receive, among other things, an allowance of $2500 per month.

Atta (#11) Purchases Flight Training Equipment

36. | Onor about November 5, 2000, Mohammed Atta (#11) purchased flight deck
videos for the Boeing 747 Model 200, Boeing 757 Model 200, and other items from a pilot store
in Ohio ("Ohio Pilot Store").

Bin al-Shibh Travels to London

37. Between on or about December 2 and December 9, 2000, Ramzi Bin al-Shibh
traveled from Hamburg, Germany to London, England.

MOUSSAOUI Travels from London to Pakistan

38. On or about December 9, 2000, ZACARIAS MOUSSAOUI flew from London,
England to Pakistan.

13


Hijackers Open Bank Accounts

52. In Summer 2001, Fayez Ahmed (#175), Saeed al-Ghamdi (#93), Hamza al-
Ghamdi (#175), Waleed al-Shehri (#11), Ziad Jarrah (#93), Satam al-Suqami (#11), Mohald al-
Shehri (#175), Ahmed al-Nami (# 93), and Ahmed al-Haznawi (#93) each opened a Florida
SunTrust bank account with a cash deposit.

MOUSSAOUI Inquires About Aerial Application of Pesticides

53. In or about June 2001, in Norman, Oklahoma, ZACARIAS MOUSSAOUI made

inquiries about starting a crop dusting company.
Other Hijackers Attend Gym Training

54. Between May and July 2001, in Florida, Ziad Jarrah (#93) joined a gym and took
martial arts lessons, which included instruction in kickboxing and knife fighting.

55. In or about June 2001, in Florida, Waleed al-Shehri (#11), Marwan al-Shehhi
(#175) and Satam al-Suqami (#11) joined a gym.

MOUSSAOUI Purchases Flight Training Equipment

56. On or about June 20, 2001, ZACARIAS MOUSSAOUI purchased flight deck

videos for the Boeing 747 Model 400 and the Boeing 747 Model 200 from the Ohio Pilot Store.
Al-Hawsawi and Fayez Ahmed (#175) Open UAE Bank Accounts

57. On June 25, 2001, Mustafa Ahmed al-Hawsawi used a cash deposit to open a
checking account at a Standard Chartered Bank branch in Dubai, UAE.

58. On June 25, 2001, at the same Standard Chartered Bank branch in Dubai, UAE,
Fayez Ahmed (#175) used a cash deposit to open a savings account and also opened a checking
account.

16