The United States of America v. Ali Saleh Kahlah Al-Marri
Approved:
________________________________________
MICHAEL G.
McGOVERN/JONATHAN S. KOLODNER
Assistant
United States Attorneys
Before: HONORABLE
MICHAEL H. DOLINGER
United States
Magistrate Judge
Southern
District of New York
THE UNITED
STATES OF AMERICA
v.
ALI SALEH
KAHLAH AL-MARRI,
a/k/a "Abdullakareem
A. Almuslam, Defendant.
COMPLAINT
Violations
of
18 U.S.C.
§§ 1001
1014 &
1028
COUNTY OF
OFFENSE: PEORIA, ILLINOIS
SOUTHERN
DISTRICT OF NEW YORK, s.s.:
NICOLAS A.
ZAMBECK, being duly sworn, deposes and says that he is a Special
Agent with the Federal Bureau of Investigation ("FBI"),
and charges as follows:
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COUNT I
1.On or about
October 2, 2001, in the Central District of Illinois, ALI SALEH
KAHLAH AL-MARRI, a/k/a "Abdullakareem A. Almuslam,"
the defendant, in a matter within the jurisdiction of the executive
branch of the United States, unlawfully, willfully, and knowingly
falsified, concealed, and covered up by trick, scheme, and device
a material fact, and made a materially false, fictitious, and
fraudulent statement and representation, to wit, AL-MARRI falsely
informed an agent of the Federal Bureau of Investigation ("FBI")
that AL-MARRI had not entered the United States between 1991
and September 10, 2001.
(Title 18,
United States Code, Section 1001.)
COUNT 2
2.On or about
December 11, 2001, in the Central District of Illinois, ALI
SALEH KAHLAH AL-MARRI, a/k/a "Abdullakareem A. Almuslam,"
the defendant, in a matter within the jurisdiction of the executive
branch of the United States, unlawfully, willfully, and knowingly
falsified, concealed, and covered up by trick, scheme, and device
a material fact, and made a materially false, fictitious, and
fraudulent statement and representation, to wit, AL-MARRI falsely
informed an agent of the FBI that AL-MARRI had not called a
telephone number in the United Arab Emirates associated with
Mustafa Ahmed al-Hawsawi.
(Title 18,
United States Code, Section 1001.)
COUNT 3
3.On or about
July 21, 2000, in the Central District of Illinois, ALI SALEH
KAHLAH AL-MARRI, a/k/a "Abdullakareem A. Almuslam,"
the defendant, unlawfully, willfully, and knowingly made a false
statement and report, for the purpose of influencing the action
of an institution the accounts of which were insured by the
Federal Deposit Insurance Corporation, upon an application,
to wit, AL-MARRI provided a false name and stolen Social Security
number in connection with an account application at Citizen's
National Bank in Macomb, Illinois.
(Title 18,
United States Code, Section 1014.)
COUNT 4
4.On or about
August 3, 2000, in the Central District of Illinois, ALI SALEH
KAHLAH AL-MARRI, a/k/a "Abdullakareem A. Almuslam,"
the defendant, unlawfully, willfully, and knowingly made a false
statement and report, for the purpose of influencing the action
of an institution the accounts of which were insured by the
Federal Deposit Insurance Corporation, upon an application,
to wit, AL-MARRI provided a false name and stolen Social Security
number in connection with an account application at the First
Federal Bank in Macomb, Illinois.
(Title 18,
United States Code, Section 1014.)
COUNT 5
5.On or about
August 3, 2000, in the Central District of Illinois, ALI SALEH
KAHLAH AL-MARRI, a/k/a "Abdullakareem A. Almuslam,"
the defendant, unlawfully, willfully, and knowingly made a false
statement and report, for the purpose of influencing the action
of an institution the accounts of which were insured by the
Federal Deposit Insurance Corporation, upon an application,
to wit, AL-MARRI provided a false name and stolen Social Security
number in connection with an account application at Mid-America
National Bank in Macomb, Illinois.
(Title 18,
United States Code, Section 1014.)
COUNT 6
6.In or about
July 2000 through in or about August 2000, in the Central District
of Illinois and elsewhere, ALI SALEH KAHLAH AL-MARRI, a/k/a
"Abdullakareem A. Almuslam," the defendant, unlawfully,
willfully, and knowingly used, without lawful authority, a means
of identification of another person with the intent to commit
an unlawful activity that constitutes a violation of Federal
law, to wit, AL-MARRI used a stolen Social Security number that
was not issued in his name to file false account applications
with three banks in Macomb, Illinois, in violation of Title
18, United States Code, Section 1014.
(Title 18,
United States Code, Section 1028(a)(7))
The bases
for my knowledge and for the foregoing charges are, in part,
as follows:
7. I am a
Special Agent with the FBI, and I have been personally involved
in the investigation of this matter. This affidavit is based
upon my conversations with other law enforcement agents and
upon my examination of various transcripts, reports, and records.
Because this affidavit is being submitted for the limited purpose
of establishing probable cause for the offenses cited above,
it does not include all of the facts that have been learned
during the course of the investigation. Where the contents of
documents or statements of others are reported herein, they
are reported in substance and in part, unless otherwise indicated.
The September
11 Terrorist Attacks
8. On Tuesday,
September 11, 2001, in a series of coordinated attacks, terrorists
attacked the World Trade Center ("WTC") in lower Manhattan
in New York City and the Pentagon in Arlington, Virginia (the
"September 11 Attacks"). The attack plan included,
among other things, the hijacking of four commercial airliners:
(a) American Airlines Flight 11 ("AA11"), a Boeing
767, which departed Logan Airport in Boston, Massachusetts,
at approximately 7:45 a.m., en route to Los Angeles, California;
(b) United Airlines Flight 175 ("UA175"), a Boeing
767, which departed Logan Airport at approximately 8:00 a.m.,
en route to Los Angeles, California; (c) American Airlines Flight
77 ("AA77"), a Boeing 757, which departed Dulles Airport
in Washington, D.C., at approximately 8:20 a.m., en route for
Los Angeles, California; and (d) United Airlines Flight 93 ("UA93"),
a Boeing 757, which departed Newark Airport in Newark, New Jersey,
at approximately 8:42 a.m., en route to San Francisco, California.
9. At approximately
8:45 a.m., AA11 was flown into the North Tower of the WTC. Approximately
twenty minutes later, UA175 was flown into the South Tower of
the WTC. Within approximately 50 minutes, the South Tower collapsed.
The North Tower followed, collapsing at approximately 10:25
a.m. The attack on the Twin Towers resulted in the murders of
thousands of people and the destruction of several additional
buildings in the complex.
10. At approximately
9:40 a.m., AA77 was crashed into the Pentagon. A large portion
of the building was destroyed, collapsing at approximately 10:10
a.m. The attack resulted in the murders of hundreds of people.
11. At approximately
10:10 a.m., UA93 was crash landed in Somerset County, Pennsylvania,
killing all aboard.
The Initial
Interview Of Al-Marri
12. In connection
with the investigation into the SeptemberÊ11 Attacks,
on or about October 2, 2001, another FBI agent and I interviewed
ALI SALEH KAHLAH AL-MARRI, a/k/a "Abdullakareem A. Almuslam,"
the defendant, at his apartment in Peoria, Illinois. During
the interview, AL-MARRI stated, among other things, that he
is a Qatari national and that he had been in the United States
since September 10, 2001. AL-MARRI also stated that he possessed
a student visa issued by the United States and that he was studying
for a master's degree in computer information systems at Bradley
University in Peoria, Illinois.
13.During
the October 2, 2001 interview, I asked AL-MARRI when he had
previously traveled to the United States. AL-MARRI responded
that, prior to his arrival in the United States on September
10, 2001, he had last been in the United States from approximately
1983 to 1991, when he obtained a bachelor of science degree
from Bradley University.
The Moussaoui
Indictment and Mustafa Ahmed al-Hawsawi
14. On or
about December 11, 2001, an Indictment was unsealed in the Eastern
District of Virginia, charging Zacarias Moussaoui, a/k/a "Shaqil,"
a/k/a "Abu Khalid al Sahrawi," with Conspiracy to
Commit Acts of Terrorism Transcending National Boundaries (18
U.S.C. §§ 2332b(a)(2) & (c)), Conspiracy to Commit
Aircraft Piracy (49 U.S.C. §§ 46502(a)(1)(A) and (a)(2)(B)),
Conspiracy to Destroy Aircraft (18 U.S.C. §§ 32(a)(7)
& 34), Conspiracy to Use Weapons of Mass Destruction (18
U.S.C. § 2332a(a)), Conspiracy to Murder United States
Employees (18 U.S.C. §§ 1114 & 1117), and Conspiracy
to Destroy Property, (18 U.S.C. §§ 844(f), (i), (n)),
all relating to the September 11 Attacks. The Moussaoui Indictment
names, among others, Mustafa Ahmed al-Hawsawi, a/k/a "Mustafa
Ahmed," a/k/a "Hashem Abdollahi" (hereinafter
"al-Hawsawi"), as an unindicted co-conspirator. The
Moussaoui Indictment alleges numerous connections between al-Hawsawi
and various of the alleged hijackers. The Moussaoui Indictment
alleges, for example, that:
a. On June
25, 2001, al-Hawsawi used a cash deposit to open a checking
account at a Standard Chartered Bank branch in Dubai, United
Arab Emirates (hereinafter "UAE").
b. On June
25, 2001, at the same Standard Chartered Bank branch in Dubai,
UAE, Fayez Ahmed, alleged to be a hijacker of UA175, used
a cash deposit to open a savings account and also opened a
checking account.
c. On July
18, 2001, Fayez Ahmed gave power of attorney to al-Hawsawi
for Fayez Ahmed's Standard Chartered Bank accounts in the
UAE.
d. Between
July 18 and August 1, 2001, al-Hawsawi caused Fayez Ahmed's
VISA and ATM cards to be shipped from the UAE to Fayez Ahmed
in Florida.
e. On September
8, 2001, Mohammed Atta, alleged to be a hijacker of AA11,
wired $2,860 to "Mustafa Ahmed" in the UAE.
f. On September
8, 2001, Mohammed Atta wired $5,000 to "Mustafa Ahmed"
in the UAE.
g. On September
9, 2001, Waleed M. al-Shehri, alleged to be another hijacker
of AA11, wired $5,000 to "Ahamad Mustafa" in the
UAE.
h. On September
10, 2001, Marwan al-Shehhi, alleged to be another hijacker
of UA175, wired $5,400 to "Mustafa Ahmad" in the
UAE.
i. On September
11, 2001, in the UAE, approximately $16,348 was deposited
into al-Hawsawi's Standard Chartered Bank account.
j. On September
11, 2001, in the UAE, at approximately 9:22 a.m. local time
(the early morning hours of Eastern Daylight Time), al-Hawsawi
transferred approximately $6,500 of the approximately $8,055
in Fayez Ahmed's Standard Chartered Bank accounts into his
own account, using a check dated September 10, 2001, and apparently
signed by Fayez Ahmed. Al-Hawsawi then withdrew approximately
$1,361, nearly the entire remaining balance in Fayez Ahmed's
accounts, by ATM cash withdrawal.
k. On September
11, 2001, in the UAE, approximately $40,871 was prepaid to
a VISA card connected to Al-Hawsawi's Standard Chartered Bank
account.
l. On September
11, 2001, al-Hawsawi left the UAE for Pakistan.
Al-Hawsawi
and the UAE Telephone Number
15. I have
spoken with other agents, who have advised me of the following
information regarding a telephone number used by al-Hawsawi
in the UAE (hereinafter "the UAE Telephone Number"):
a. On or
about September 8, 2001, al-Hawsawi provided the UAE Telephone
Number on a cash withdrawal slip from his account at the Standard
Chartered Bank in the UAE.
b. On or
about September 4, 2001, Mohammed Atta sent a federal express
package that was later received in the UAE on or about September
8, 2001. The package was addressed to "Almohtaram,"
which is Arabic for "the respected one," and Atta
gave to Federal Express the UAE Telephone Number as the point
of contact for the recipient.
c. A telephone
calling card known to have been in the possession of Mohammed
Atta was used to make telephone calls to the UAE Telephone
Number.
d. The
UAE Telephone Number was used by "Hashem Abdollahi,"
which is believed to be another name used by al-Hawsawi, on
a September 3, 2001 wire transfer to Ramzi Bin al-Shibh, a/k/a
"Ahad Sabet," a/k/a "Ramzi Mohamed Abdellah
Omar," another unindicted co-conspirator named in the
Moussaoui Indictment.
AL-MARRI's
Calls to the UAE Telephone Number
16. I have
learned the following from other federal agents and from my
own review of telephone records:
a. On or
about September 23, 2001, a telephone call was attempted from
a pay telephone in a store in Peoria, Illinois, to the UAE
Telephone Number, using a calling card and dedicated pin number
issued by Network IP (hereinafter "the Network IP Calling
Card and Pin Number").
b. On or
about September 27, 2001, a telephone call was attempted from
a cellular telephone subscribed to by ALI SALEH KAHLAH AL-MARRI,
a/k/a "Abdullakareem A. Almuslam," the defendant
(the "AL-MARRI CELLPHONE"), using the Network IP
Calling Card and Pin Number.
c. On or
about October 14, 2001, between 1:42 a.m. and 1:52 a.m., a
telephone call was attempted from a pay telephone in a gas
station in Springfield, Illinois, (1) to the UAE Telephone
Number, using the Network IP Calling Card and Pin Number.
At approximately 1:08 a.m. on October 14, 2001, the AL-MARRI
CELLPHONE was activated in a cell site located in Lincoln,
Illinois, approximately 20 miles north of Springfield. (2)
At approximately 2:15 a.m. on October 14, 2001, the AL-MARRI
CELLPHONE was activated in a cell site located in Springfield.
d. On or
about October 24, 2001, a telephone call was made from a telephone
subscribed to by AL-MARRI in AL-MARRI's Peoria, Illinois apartment
(the "AL-MARRI HOME PHONE") to a telephone number
in Houston, Texas, using the Network IP Calling Card and Pin
Number.
17. I have
also learned the following from other federal agents:
a. On or
about November 4, 2001, telephone calls were attempted from
two pay telephones in Chicago, Illinois, to the UAE Telephone
Number and to telephone numbers in Pakistan and Saudi Arabia,
using a calling card and dedicated pin number issued by Qwest
Communications (hereinafter "the Qwest Calling Card and
Pin Number"). (3) Between 1:29 a.m. and 5:18 p.m. on
November 4, 2001, the AL-MARRI CELLPHONE was activated in
cell sites located in Chicago and, in particular, was used
to check the voice mail on the AL-MARRI CELLPHONE and to call
the AL-MARRI HOME PHONE in Peoria.
b. On or
about November 7, 2001, telephone calls were made from the
AL-MARRI HOME PHONE using the Qwest Calling Card and Pin Number.
The Second
Interview of AL-MARRI and the Searches
18. On or
about December 11, 2001, after the FBI performed the telephone
analysis described above, another agent and I revisited ALI
SALEH KAHLAH AL-MARRI, a/k/a "Abdullakareem A. Almuslam,"
the defendant, at his Peoria, Illinois apartment. We asked him
to come to the Peoria, Illinois office of the FBI to answer
some additional questions. AL-MARRI agreed. In addition, we
asked AL-MARRI for permission to search his apartment. AL-MARRI
consented to the search. During this search, we found, among
other things, a laptop computer. I asked AL-MARRI for consent
to search the laptop. AL-MARRI gave his consent and retrieved
a laptop computer carrying case that was in his closet. AL-MARRI
then put the laptop computer in the carrying case.
19. During
the interview that was conducted later on December 11, 2001,
ALI SALEH KAHLAH AL-MARRI, a/k/a "Abdullakareem A. Almuslam,"
the defendant, stated the following, in substance and in part:
a. AL-MARRI
denied knowing anyone named Mustafa Ahmed al-Hawsawi and denied
ever calling the UAE Telephone Number or anyone associated
with that telephone number.
b. AL-MARRI
acknowledged that he had telephoned an individual in Houston,
Texas (the "Houston Resident"). The Houston Resident
is the registered subscriber to the Houston, Texas telephone
number to which a telephone call was made, on or about October
24, 2001, from the AL-MARRI HOME PHONE using the Network IP
Calling Card and Pin Number. (See supra º 16(d)).
c. AL-MARRI
stated that he had not traveled to any countries other than
Qatar, Saudi Arabia, and the United States.
20. On December
12, 2001, an FBI computer systems analyst, with whom I have
spoken, opened the computer carrying case provided to the FBI
the day before by ALI SALEH KAHLAH AL-MARRI, a/k/a "Abdullakareem
A. Almuslam," the defendant, and found, among other things,
a folded two-page handwritten document that listed approximately
36 credit card numbers together with the names of the account
holders, an indication as to whether each credit card number
was VISA or Mastercard, and the expiration dates of each card.
The expiration dates on the list indicated that each of the
cards had expired. AL-MARRI was not listed as the account holder
for any of the approximately 36 credit cards. Approximately
17 of the 36 credit card numbers appeared to be issued by domestic
banks. I have learned from other agents that records from the
issuing domestic banks showed that the approximately 17 domestically
issued credit card numbers were either once or currently valid,
and that they were issued to persons other than AL-MARRI. (4)
In addition, during their search of AL-MARRI's laptop computer,
the FBI computer systems analysts found:
a. An Arabic
oath or prayer, which states, among other things, that "[n]either
the U.S. nor anyone living in it will dream of security/safety
before we live it in Palestine and before the infidel armies
leave the land of Mohammed," and that God should "protect"
and "guard" Usama Bin Laden.
b. Computer
audio files containing Arabic lectures by Usama bin Laden
and his associates, concerning, among other things, the importance
of jihad and martyrdom and the merits of the Taliban regime
in Afghanistan. The lectures instructed, among other things,
that Muslim scholars shouldorganize opposition to Jewish and
Christian control of "Palestine," Lebanon, and Saudi
Arabia; that ordinary Muslims should train in Bin Laden's
camps in Afghanistan by entering through Pakistan; and that
clerics who claim that Islam is a religion of peace should
be disregarded.
c. Photographs
of the September 11 Attacks on the World Trade Center; photographs
of various Arab prisoners held by authorities in Kabul, Afghanistan;
and a map of Afghanistan.
d. Computer
files containing lists of websites that are titled, among
other things, "Jihad arena"; "Taliban";
"Arab's new club - Jihad club"; "Tunes by bullets";
and "martyrs."
e. A computer
folder called "chem" containing favorite bookmarked
internet web sites, including sites providing factsheets for
hazardous substances and other sites providing the amounts
of certain hazardous chemicals that are "immediately
dangerous to life or health." (5) The folder also contains
websites designed for the acquisition of industrial chemicals.
f. Other
computer folders containing additional favorite bookmarked
internet web sites, including sites relating to weaponry and
satellite equipment.
g. Computer
files containing an aggregate of over approximately 1,000
apparent credit card numbers, stored in various computer files,
as well as a list of numerous favorite bookmarked internet
web sites relating to, among other things, computer hacking,
fake driver's licenses and other fake identification cards,
buying and selling credit card numbers, and processing credit
card transactions. Preliminary examination of records for
the approximately 1,000 credit card numbers found on AL-MARRI's
computer has confirmed that the majority of these cards have
been subjected to fraud.
21. On or
about December 14, 2001, other agents and I searched the apartment
of ALI SALEH KAHLAH AL-MARRI, a/k/a "Abdullakareem A. Almuslam,"
the defendant, pursuant to a search warrant authorized by a
United States Magistrate Judge sitting in the Central District
of Illinois. During the search, we found, among other things:
(a) an Arabic prayer seeking, among other things, the defeat
of the "villainous" Christians and Jews, and victory
for Muslims in "Palestine," Afghanistan, Kashmir,
and Chechnya (6); and (b) an almanac with bookmarks in pages
that provided information about major United States dams, reservoirs,
waterways, and railroads.
"Abdullakareem
A. Almuslam" and AL-MARRI's August 2000 Visit to the United
States
22. I have
reviewed the reports of FBI analysts who have examined the credit
card numbers found in the laptop carrying case and on the laptop
computer belonging to ALI SALEH KAHLAH AL-MARRI, a/k/a "Abdullakareem
A. Almuslam," the defendant. From these reports, I have
learned the following:
a. Several
of the credit card numbers found in AL-MARRI's possession
had been used to make fraudulent purchases at a business called
"AAA Carpet."
b. AAA
Carpet is a fictitious entity with no actual physical location.
The address provided for AAA Carpet is actually that of the
Time Out Motel, Room 209, in Macomb, Illinois.
c. In or
about July and August 2000, several bank accounts in Macomb,
Illinois, were opened for AAA Carpet by an individual identifying
himself as "Abdullakareem A. Almuslam." Specifically,
"Almuslam" opened accounts for AAA Carpet at three
banks in Macomb -- Citizen's National Bank, First Federal
Bank, and Mid-America National Bank (the "AAA Carpet
Accounts"). In addition, "Almuslam" opened
an account with Card Services International, a credit card
processing company, which allowed AAA Carpet to process credit
card transactions.
d. According
to Card Services International records, 12 credit cards were
charged by AAA Carpet during the period that AAA Carpet's
account with Card Services International was active, purportedly
for services rendered by AAA Carpet. All 12 transactions were
later voided when the credit card account holders advised
that they had not authorized any charges to their credit cards
by AAA Carpet. Six of the 12 credit card numbers that were
charged fraudulently by AAA Carpet were later found on the
laptop computer of ALI SALEH KAHLAH AL-MARRI, a/k/a "Abdullakareem
A. Almuslam," the defendant.
23. In connection
with his applications for the AAA Carpet Accounts, "Almuslam"
provided a home address that corresponded to the Time Out Motel
in Macomb, Illinois. I have reviewed records from the Time Out
Motel, which show that an individual identifying himself as
"Abdullakareem Almuslam" stayed at the hotel from
July 2000 to August 2000. In addition, on or about October 22,
2002, I visited the hotel and spoke with an employee of the
hotel. I showed the employee a photographic array containing
a picture of ALI SALEH KAHLAH AL-MARRI, a/k/a "Abdullakareem
A. Almuslam," the defendant, and the employee identified
AL-MARRI as the individual who had stayed at the Time Out Motel
in July and August 2000 under the name "Abdullakareem Almuslam."
24. I have
also obtained the signature cards and account opening documents
(the "Bank Documents") from the three banks in Macomb
at which "Almuslam" opened the AAA Carpet Accounts.
In addition, I have obtained a handwriting exemplar from ALI
SALEH KAHLAH AL-MARRI, a/k/a "Abdullakareem A. Almuslam,"
the defendant, of his signature. The signature used by "Almuslam"
in the Bank Documents appears similar to AL-MARRI's signature.
25. In addition,
I sent the Bank Documents to the FBI laboratory for examination.
Latent print analysis of these documents resulted in at least
three positive fingerprint identifications for the fingerprints
of ALI SALEH KAHLAH AL-MARRI, a/k/a "Abdullakareem A. Almuslam,"
the defendant.
26. I have
obtained the telephone toll records from the Time Out Motel
for the room occupied by "Almuslam." These records
reflect a telephone call from the "Almuslam" room
to the Travel Company, a travel agency in Macomb, Illinois.
I also have obtained records from the Travel Company, which
show that, on August 17, 2000, the Travel Company made an airline
reservation for an "Ali Al-Marri" for travel on August
18, 2000, from Peoria, Illinois, to New York, New York, with
return to Peoria, all on American Airlines. According to records
from American Airlines, a passenger named "Ali Al-Marri"
traveled from Peoria to Chicago's O'Hare Airport, and then to
New York's LaGuardia Airport on or about August 18, 2000. This
"Al-Marri" then returned from New York to Chicago
on August 19, 2000, but did not connect with his flight to Peoria.
27. The telephone
toll records for the "Almuslam" room at the Time Out
Motel also showed a telephone call from that room to Lufthansa
Airlines on August 17, 2000. According to records of Lufthansa
Airlines, a passenger named "Ali S. Al-Marri" used
Lufthansa Airlines on or about August 21, 2000, to travel from
Frankfurt, Germany, with a connection to Dahmam, Saudi Arabia.
This "Ali S. Al-Marri" also traveled on Lufthansa
on or about May 25-26, 2000, from Dahmam, Saudi Arabia, to Frankfurt,
Germany, and on to Chicago's O'Hare Airport.
28. Based
on the investigation described above in paragraphs 18 through
27, I believe that ALI SALEH KAHLAH AL-MARRI, the defendant,
is the "Abdullakareem A. Almuslam" who opened the
AAA Carpet Accounts.
29. In opening
the AAA Carpet Accounts, ALI SALEH KAHLAH AL-MARRI, a/k/a "Abdullakareem
A. Almuslam," the defendant, used a Social Security number
that is not assigned to AL-MARRI but, according to a law enforcement
database, is instead assigned to a woman.
30. I also
have contacted the three banks identified above -- Citizen's
National Bank, First Federal Bank, and Mid-America National
Bank. The accounts of all three banks are insured by the Federal
Deposit Insurance Corporation.
The Non-Immigrant
Visa Application
31. 31. Finally,
in connection with my investigation, I have obtained the Non-Immigrant
Visa Application (the "Visa Application") completed,
on or about September 9, 2001, by AL-MARRI prior to his entry
into the United States. In the Visa Application, AL-MARRI answered
"yes" to the question "Have you ever been in
the U.S.A." In response to the question "When,"
he stated "1990," and in response to the question
"For how long?" he answered "8 months."
WHEREFORE,
deponent prays that an arrest warrant be issued and that the
defendant be imprisoned or bailed as the case may be.
———————————————————————————
NICOLAS A.
ZAMBECK
Special Agent
Federal Bureau
of Investigation
Sworn to
before me this ___ day of December 2002.
———————————————————————————
UNITED STATES
MAGISTRATE JUDGE
1. Springfield
is located approximately 65 miles from Peoria, Illinois.
2. I am aware
that cellular telephone networks are divided into grids of "cells,"
each of which contain transmitters and receivers for cellphone
signals that connect a cellphone to the network. When a cellphone
is used or activated, it generally transmits its signals to
the nearest cell, and law enforcement can obtain the location
of the cell site in which a particular cellphone is activated.
3. Chicago
is located approximately 165 miles from Peoria, Illinois.
4. On December
12, 2001, AL-MARRI was arrested as a material witness in connection
with the investigation of the September 11 Attacks. AL-MARRI
was subsequently indicted by a grand jury sitting in this District
for the unauthorized possession of 15 or more access devices
-- credit card numbers -- with the intent to defraud, in violation
of Title 18, United States Code, Section 1029(a)(3). That case,
02 Cr. 147 (VM), is currently pending before the Honorable Victor
Marrero, and trial is set for January 13, 2003.
5. The "immediately
dangerous to life or health," or "IDLH," value,
is a recognized standard published by the National Institute
for Occupational Safety and Health ("NIOSH"), which
is part of the Centers for Disease Control and Prevention ("CDC").
The IDLH value refers to the concentration at which a toxic
chemical becomes hazardous to life or health.
6. I have
been advised that all translations and descriptions of Arabic
documents and files contained herein were provided by FBI or
other federally employed interpreters.
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