and 23 law enforcement officers from the New York City Police Department. World Trade
Center Towers I (North Tower) and II (South Tower) were completely destroyed, as were other
buildings in the World Trade Center complex. The destruction of these buildings resulted in the
disruption of interstate and international commerce for those businesses located in the World
Trade Center complex. Additionally, the offices of the U.S. Secret Service, the U.S. Customs
Service, the Bureau of Alcohol, Tobacco, and Firearms, and the Department of Housing and
Urban Development, all of which were housed in the World Trade Center complex, were
destroyed.

20. On September 11, 2001, al Qaeda operatives used force and violence to hijack
American Airlines Flight 77, bound from Virginia to Los Angeles, and crashed it into the
Pentagon, a United States government building, damaging the building and killing 189 people,
many of whom were United States government employees, including employees of the United
States Department of Defense, engaged in their official duties.

21. | On September 11, 2001, al Qaeda operatives used force and violence to hijack
United Airlines Flight 93, bound from Newark to San Francisco, which then crashed in Somerset
County, Pennsylvania, killing all on board.

23. All four airplanes identified above were flying in the special aircraft jurisdiction

of the United States at the time that they were hijacked and all were completely destroyed.

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

- a hand-held aviation radio.
After his arrest, Moussaoui lied to federal agents to allow his al Qaeda “brothers” to go forward
with the operation to fly planes into American buildings. Specifically, Moussaoui falsely denied
being a member of a terrorist organization and falsely denied that he was taking pilot training to
kill Americans. Instead, Moussaoui told federal agents that he was training as a pilot purely for
his personal enjoyment and that, after completion of his training, he intended to visit New York
City and Washington, D.C., as a tourist.

17. On September 11, 2001, al Qaeda operatives used force and violence to hijack
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 City, destroying the building and killing
thousands of people.

18. On September 11, 2001, al Qaeda operatives used force and violence to hijack
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 City, destroying the building and killing

thousands of people.

19. The World Trade Center was a complex of buildings owned by the Port Authority
of New Jersey\New York, which was constructed for the purpose of housing businesses engaged
in interstate and foreign commerce. As a result of the crashes of American Airlines Flight 1 1 and
United Flight 175, approximately 2,830 people died in or around the World Trade complex.
Among those killed at the World Trade, the dead included 343 firefighters from the New York

Fire Department, 37 law enforcement officers from the Port Authority of New Jersey/New York,

4.


FILED
1N OPEN COURT

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA APR 22 2005
Alexandria Division

CLERK, U.S. DISTRICT COI
ALEXANDRIA, VIRGINIA

UNITED STATES OF AMERICA

v. Criminal No. 01-455-A

ZACARIAS MOUSSAOUI,
Defendant

)
)
)
)
)
)
Statement of Facts
If this case were to go to trial, the Government would prove the following facts beyond a
reasonable doubt:
lL. Al Qaeda was an international terrorist group dedicated to opposing the United
States with force and violence. Usama Bin Laden was the founder and head of al Qaeda. The
leadership of al Qaeda included Abu Hafs al Masri, who served as the head of al Qaeda’s military
committee. Since 1996, al Qaeda maintained headquarters in Afghanistan. Members of al Qaeda
pledged bayat to Usama Bin Laden and al Qaeda. Al Qaeda associated with other terrorist
groups.
2. Usama Bin Laden and al Qaeda declared a jihad against the United States. Bin
Laden and members of al Qaeda issued fatwahs indicating that violent attacks on the United

States and its citizens were both proper and necessary and that Muslims should kill Americans -
including civilians - anywhere in the world, anytime.

3. Usama Bin Laden and al Qaeda provided and supported training camps and
guesthouses in Afghanistan, including camps known as al Farooq and Khalden. These camps

were used to instruct members and associates of al Qaeda and its affiliated groups in the use of

firearms, explosives, chemical weapons, and other weapons of mass destruction.



4. Defendant Zacarias Moussaoui, who also used the names “Abu Khaled al
Sahrawi” and “Shaquil,” became a member of al Qaeda and pledged bavar to Bin Laden,
Moussaoui’s “father in jihad.”

5. Moussaoui trained at al Qaeda’s Khalden Camp in Afghanistan.

6. Moussaoui managed an al Qaeda guesthouse in Kandahar. This was a position of
high respect within al Qaeda. Moussaoui communicated directly with Bin Laden and Abu Hafs
al Masri.

7. As part of its conspiracy to attack the United States, al Qaeda members conceived
of an operation in which civilian commercial airliners would be hijacked and flown into
prominent buildings, including government buildings, in the United States. To effect this attack,
al Qaeda associates entered the United States, received funding from abroad, engaged in physical
fitness training, and obtained knives and other weapons with which to take over airliners. Some
al Qaeda associates obtained pilot training, including training on commercial jet simulators, so
they would be able to fly hijacked aircraft into their targets.

8. Bin Laden personally approved those selected to participate in the operation, who
were willing to die in furtherance of their religious beliefs and al Qaeda’s agenda.

9. Moussaoui knew of al Qaeda’s plan to fly airplanes into prominent buildings in
the United States and he agreed to travel to the United States to participate in the plan. Bin
Laden personally selected Moussaoui to participate in the operation to fly planes into American
buildings and approved Moussaoui attacking the White House. Bin Laden told Moussaoui:
“Sahrawi, remember your dream.”

10. Anal Qaeda associate provided Moussaoui with information about flight schools

2-


in the United States. In September 2000, Moussaoui, who was in Malaysia. contacted the
Airman Flight School in Norman, Oklahoma, via email, seeking flight training. Moussaoui
intended to use his training as a pilot in furtherance of al Qaeda’s plan to use planes to kill
Americans.

11. Moussaoui trained in knife fighting in Afghanistan.

12. On February 23, 2001, Moussaoui traveled from London to Chicago and then on
to Norman, Oklahoma, where he attended the Airman Flight School and received training as a
pilot. At the Airman Flight School, Moussaoui received training as a pilot of smaller planes. In
Summer 2001, an al Qaeda associate directed Moussaoui to attend training for larger jet planes.

13. While in Oklahoma, Moussaoui joined a gym and bought knives. Moussaoui
selected certain knives because they had blades short enough to get past airport security.

14. Inearly August 2001, an al Qaeda conspirator using the alias of “Ahad Sabet,”
wire transferred money from Germany to Moussaoui in Oklahoma so Moussaoui could receive
additional flight training.

15. In August 2001, Moussaoui traveled to Minnesota where he trained on a Boeing
747-400 simulator at the Pan Am International Flight Academy in Eagan, Minnesota. Moussaoui
told an al Qaeda associate that he would complete simulator training before September 2001.

16. On August 16, 2001, Moussaoui was arrested in Minnesota by agents of the INS
and the FBI. At the time of his arrest, Moussaoui possessed the following items:

- two knives;
- 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,

3-