EASTERN
DISTRICT OF MICHIGAN
SOUTHERN
DIVISION
UNITED STATES OF AMERICA
,
Plaintiff,
No. 01-80778
HON. GERALD E. ROSEN
-vs-
Defendants
D-1
KARIM KOUBRITI,
D-2
AHMED HANNAN,
D-3
YOUSSEF HMIMSSA, a/k/a PATRICK J. VUILLAUME, a/k/a JALALI,
D-4
ABDELLA LNU, a/k/a JEAN PIERRE TARDELLI, a/k/a GEORGE LABIBE
a/k/a HUSSEIN MOHSEN SAFIDDINE a/k/a NABIL HAYAMM ,
and
D-5
FAROUK ALI-HAIMOUD, a/k/a "Khalid,"
OFFENSES:
Count 1:
Providing Material
Support or Resources to Terrorists
MICHAEL SAISA, a/k/a 18 U.S.C. § 2339A
Count 2:
Conspiracy to Engage in Fraud and Misuse of Visas, Permits ,
and other Documents , 18 U.S.C. § 371
Count
3: Fraud and Misuse of Visas, Permits and Other Documents 18
U.S.C. §§ 1546 (a) and 2
Count
4: Fraud and Related Activity in Connection with
Identification Documents and Information 18 U.S.C. §§ 1028
(a) (6) and 2
SECOND
SUPERSEDING INDICTMENT
THE
GRAND JURY CHARGES:
COUNT
ONE
(18
U.S.C. § 2339A -- Providing Material
Support or Resources to
Terrorists)
D-1
KARIM KOUBRITI
D-2
AHMED HANNAN
D-4
ABDELLA LNU, a/k/a JEAN PIERRE TARDELLI, a/k/a GEORGE LABIBE,
a/k/a HUSSEIN MOHSEN SAFIDDINE, a/k/a NABIL HAYAMM, and
D-5
FAROUK ALI-HAIMOUD, a/k/a "Khalid"
INTRODUCTION
1.
In the 1990s, a loose, transnational network of radical
Islamists launched an international holy war, or global
jihad, in an
effort to, among other things, drive American military
forces from the
Arabian peninsula , erode American support of
Israel
, and undermine American
support to moderate regimes throughout the
Middle East that they viewed as
insufficiently Islamic. It was at this time, that elements
of this radical Islamic network established intelligence
collection cells in the
United States
to plan and support future
terrorist acts, both within the
United States
and abroad.
A.
Salafiyya
2.
This network is heavily influenced by a factional Islamic
religious movement called the Salafiyya -- a name derived
from al-Salaf al-Salih, "the venerable
forefathers" (or true path), which refers to the
generation of the Prophet Muhammad and his contemporaries.
This movement, along with the Wahabis and Takfiris, forms
the hardcore element of
what is identified today as Sunni Islamic
Fundamentalism. Wahabis, Takfiris, and Salafists promote the
establishment of an Islamic state under the Sharia,
that is, strict Islamic law, that is ruled by a
Calyph. These groups regard the Islam that most Muslims
practice today as unpure and polluted by idolatry and
Western influence.
Salafists
seek to reform Islam by specifically emulating the first
generation of Muslims since, according to these Salafists,
later generations of Muslims have been corrupted by several
centuries of religious practices and Western influences
introduced by errant Muslims. Salafists reject any behavior
that was not specifically supported or enjoined by the
Prophet Mohammed. In almost every Sunni Muslim country, the
Salafists have spawned radical fundamentalist-Islamic
political movements, the goal of which is to compel the
state to apply the Sharia. Many Salafists believe
that the strict application
of the Sharia is necessary to ensure that Muslims
walk the true path of the Prophet. These radical
fundamentalist-Islamic groups see the world divided in two
spheres; that is, Dar-al-Islam (House of Islam or
Islamic Zone), where peace reigns (Sallam), and the Dar-al-Harb
(House of War or War Zone), which prevents a true Islamic
state.
The
latter is viewed by these radical fundamentalist-Islamic
groups to include all "infidel" areas that must
ultimately be conquered. Global jihad is the constant
effort to achieve this goal. The global jihad against
Dar-al-Harb is not exclusively directed towards the
outside world, but also against perceived internal threats,
such as any non-Muslim presence in Dar-al-Islam.
B. Al
Takfir Wal Hijira
3.
Among the global jihadist factions existing worldwide, Al
Takfir Wal Hijira ("excommunication and
emigration") or (anathema and exile) is among the most
radical and extremist in ideology and methodology. Followers
of this extremist ideology are called Takfiris. Takfiris
believe that true Muslims must depose, or excommunicate
unnatural or false rulers and can do so only through active
struggle. Takfiris take their beliefs out of the realm of
contemplation and into the realm of action. Takfiri cells
are trained to blend into Western societies, which they view
as "kufar" (atheist, corrupt, or infidel) in order
to plot terrorist attacks against those "corrupt"
societies. Members of Takfiri cells may live together, not
pray or attend Mosque, partake in alcohol and narcotics, and
dress to assimilate and integrate into the communities they
live in an attempt to avoid suspicion and/or detection.
C.
Jihad
4.
Salafists and Takfiris place greatest emphasis on jihad,
or what they perceive as holy war. The Prophet Muhammad
fought in mortal combat against his enemies in
Arabia , and Salafists and Takfiris
place great emphasis on this aspect of the Prophet's life.
Salafists, Takfiris, and other Jihadists view the Islamic
military campaigns which conquered the
Middle East and
North Africa in the Seventh Century as
righteous, and draw their call for violence from these
historical events. The Soviet invasion of
Afghanistan
in 1979 drew Salafists and
Takfiris who were encouraged to engage in jihad as an
essential element of their religious duty. A coalition of
radicals, to include ultra-extremists returning from
Afghanistan
, formed organizations such
as the Harakat ul-Ansar, Al-Gama'a Al-Islamiyya (the Islamic
Group) in
Egypt
and the Armed Islamic Group
(GIA) in
Algeria. A former GIA commander
formed an organization called the "Salafi Group for
Call and Combat," which received financial support from
Usama Bin Laden and became part of the loose network he had
formed.
5. In February 1998, the "World Front for Jihad
Against Jews and Crusaders," led by Usama Bin Laden and
which included the Salafi Group for Call and Combat, issued
a Fatwa (a religious edict) "against Jews and
Crusaders" (infidels) which described the duty of every
individual Muslim, in any country in which it is possible,
to kill Americans and their allies, both civilians and
military, in order to purge the infidels from the lands of
Islam (Dar-al-Islam), and to fight them "until
there is no more tumult or oppression, and there prevails
justice and faith in God."
6.
On
August 28, 1998 , while in U.S. Federal
Prison for his role in the first
World
Trade
Center
attack in 1993, Sheik Abdul
Rahman issued a Fatwa, mirroring the call for attacks
on American civilian targets:
Cut
all links with their country (
United States
). Destroy them thoroughly
and erase them from the face of the earth.
Ruin
their economies, set their companies on fire, turn their
conspiracies to powder and dust. Sink their ships, bring
their planes down. Slay them in the air, on land, on water.
And (with the Command of Allah) kill them wherever you find
them. Catch them and put them in prison. Lie in wait for
them and kill these infidels. They will surely get great
oppression from you. God will make you the means of wreaking
a terrible revenge upon them, of degrading them.
He
will support you against them. He will cure the afflicted
hearts of the faithful and take all anger out of their
hearts.
7.
Since 1998, this World Front for Jihad Against Jews and
Crusaders engaged in global jihad warfare against
many countries, including the
United States
. The Salafists and Takfiris
are one arm of the greater global Jihadist organization
known as "Al-Qaeda."
THE
OFFENSES
8.
That from in or about February 1998, and continuing to the
time of this indictment, said dates being approximate, in
the Eastern District of Michigan and elsewhere, Defendants,
KARIM KOUBRITI, AHMED HANNAN, ABDELLA LNU, a/k/a JEAN PIERRE
TARDELLI, a/k/a GEORGE LABIBE, a/k/a HUSSEIN MOHSEN
SAFIDDINE, a/k/a NABIL HAYAMM, and FAROUK ALI-HAIMOUD, a/k/a
"Khalid," with each other and with others known
and unknown to the Grand Jury, did combine, conspire,
confederate and agree to provide material support and
resources, knowing and intending that such material support
and resources were to be used in preparation for, and in
carrying out of:
(a)
conspiracy within the United States to damage or destroy
specific property situated within a foreign country with
which the United States is at peace; in violation of Title
18, United States Code, Section 956(b); and (b) conduct
transcending national boundaries, acts that create a
substantial risk of serious bodily injury to any other
person, by conspiring to destroy and damage structures,
conveyances, and other real and personal property within the
United States, in violation of Title 18, United States Code,
Section 2332a; All in violation of Title 18, United States
Code, Section 2339A.
OBJECT
OF THE CONSPIRACY
9.
The Defendants, KARIM KOUBRITI, AHMED HANNAN, ABDELLA LNU,
a/k/a JEAN PIERRE TARDELLI, a/k/a GEORGE LABIBE, a/k/a
HUSSEIN MOHSEN SAFIDDINE, a/k/a NABIL HAYAMM, and FAROUK
ALI-HAIMOUD, a/k/a "Khalid," operated as a covert
underground support unit for terrorist attacks within and
outside the United States, as well as a "sleeper"
operational combat cell. The object of the conspiracy was,
among other things, to cause economic harm to U.S.
businesses, to provide personnel, indoctrination,
recruitment and training, safe houses, mail drops,
intelligence target data collection, weapons, false
documentation and identification, and assistance and other
covert support for the purpose of engaging in violent
attacks against persons and buildings within the territory
of Jordan, Turkey, and the United States.
MANNER
AND MEANS OF THE CONSPIRACY
10.
In furtherance of said unlawful conspiracy, and attempting
to achieve the objective thereof, the Defendants, KARIM
KOUBRITI, AHMED HANNAN, ABDELLA LNU, a/k/a JEAN PIERRE
TARDELLI, a/k/a GEORGE LABIBE, a/k/a HUSSEIN MOHSEN
SAFIDDINE, a/k/a NABIL HAYAMM, and FAROUK ALI-HAIMOUD, a/k/a
"Khalid," performed, among other things, the
following manner and means:
(a)
Beginning on an unknown date, the Defendants, KARIM KOUBRITI,
AHMED HANNAN, ABDELLA LNU, a/k/a JEAN PIERRE TARDELLI, a/k/a
GEORGE LABIBE, a/k/a HUSSEIN MOHSEN SAFIDDINE, a/k/a NABIL
HAYAMM, and FAROUK ALI-HAIMOUD, a/k/a "Khalid,"
and with others known and unknown to the Grand Jury, formed
an agreement to covertly provide a variety of services and
tangible items to individuals, to whom they referred to as
"the brothers" (Ikhwan), in order to assist these
individuals' engagement in and promotion of violent attacks
around the world. The Defendants, KARIM KOUBRITI, AHMED
HANNAN, ABDELLA LNU, a/k/a JEAN PIERRE TARDELLI, a/k/a
GEORGE LABIBE, a/k/a HUSSEIN MOHSEN SAFIDDINE, a/k/a NABIL
HAYAMM, and FAROUK ALI-HAIMOUD, a/k/a "Khalid,"
thereafter performed such services and took steps to acquire
such items, which they intended to use to engage in or
support holy war, or global jihad.
(b)
The Defendants, KARIM KOUBRITI, AHMED HANNAN, and FAROUK
ALI-HAIMOUD, a/k/a "Khalid," resided together in
apartments in Michigan and in particular, Detroit and
Dearborn, and received direction from Defendant, ABDELLA LNU,
a/k/a JEAN PIERRE TARDELLI, a/k/a GEORGE LABIBE, a/k/a
HUSSEIN MOHSEN SAFIDDINE, a/k/a NABIL HAYAMM, who resided in
Chicago, Illinois, and was known by them to have expertise
in, among other things, airport security operations, the
fraudulent use of telephone calling calls, and the
manufacturing and acquisition of false identification.
(c)
The Defendants, KARIM KOUBRITI, AHMED HANNAN, and FAROUK
ALI-HAIMOUD, a/k/a "Khalid," were instructed by
Defendant, ABDELLA LNU, a/k/a JEAN PIERRE TARDELLI, a/k/a
GEORGE LABIBE, a/k/a HUSSEIN MOHSEN SAFIDDINE, a/k/a NABIL
HAYAMM, to use a coded form of communication, for use in
speaking to each other about their plans. Defendant, ABDELLA
LNU, a/k/a JEAN PIERRE TARDELLI, a/k/a GEORGE LABIBE, a/k/a
HUSSEIN MOHSEN SAFIDDINE, a/k/a NABIL HAYAMM, received funds
and consulted with "brothers" he had in place
throughout
Europe .
(d)
In June, 2001, an individual moved into an apartment at 1335
Riverside
,
Dearborn ,
Michigan
, with Defendants, KARIM
KOUBRITI and AHMED HANNAN, where Defendant, FAROUK ALI-HAIMOUD,
a/k/a "Khalid," was a frequent visitor.
Defendants, KARIM KOUBRITI, AHMED HANNAN, and FAROUK ALI-HAIMOUD,
a/k/a "Khalid," attempted to recruit this
individual to participate in global jihad
against states that were not sufficiently Islamic, such as
the Hashemite
Kingdom of
Jordan
,
Turkey
, and the
United States
. It was the plan of the
Defendants, KARIM KOUBRITI, AHMED HANNAN, and FAROUK ALI-HAIMOUD,
a/k/a "Khalid," to illicit the other individual's
assistance in bringing like-minded "brothers" into
the United States by creating false documentation to
facilitate their illegal entry into the United States and
travel abroad.
(e)
The Defendants, KARIM KOUBRITI, AHMED HANNAN, and FAROUK
ALI-HAIMOUD, a/k/a "Khalid," were involved in
plans to obtain weaponry to benefit operatives overseas, to
recruit persons for violent activity, to arrange for the
entry of recruits into the United States where they would be
trained for global jihad, and to arrange false
identification to facilitate such entry and training. Their
planning involved specific violent attacks, including ones
that targeted an American airbase in
Incerlik ,
Turkey, and a hospital in
Amman ,
Jordan.
These
locations were depicted in a day planner, which was found in
the apartment of Defendants, KARIM KOUBRITI, AHMED HANNAN,
and FAROUK ALI-HAIMOUD, a/k/a "Khalid," on
September 17, 2001, along with Salafist audio tapes and a
video tape that appears to depict surveillance of such U.S.
landmarks as Disneyland in Anaheim, California, and the MGM
Grand Hotel and Casino in Las Vegas, Nevada.
(f)
The Defendants, KARIM KOUBRITI, AHMED HANNAN, and FAROUK
ALI-HAIMOUD, a/k/a "Khalid," at times traveled to
Detroit
Metropolitan
Airport
, where they attempted to
locate security breaches that would allow them to, among
other things, directly access airliners. From on or about
May 16, 2001, to on or about
July 6, 2001 , Defendants,
KARIM
KOUBRITI and AHMED HANNAN, were employed by a vendor at
Detroit
Metropolitan
Airport
; and from or about
February 15, 2002 to
April 3, 2002 , Defendant, FAROUK ALI-HAIMOUD,
a/k/a "Khalid," was employed by a vendor at
Detroit
Metropolitan
Airport
.
(g)
The Defendants, KARIM KOUBRITI, AHMED HANNAN, and FAROUK
ALI-HAIMOUD, a/k/a "Khalid," took steps and
measures to disguise their plans and purposes. For example,
in an attempt to avoid the risk that written records of
their planning would be attributed to them, they located a
mentally unstable man who, in exchange for certain favors,
agreed to sign his name and provide personal information on
certain handwritten pages in notebooks that contained
various plans and sketches of an American airbase in
Incerlik, Turkey, and a hospital in Amman, Jordan, and to
temporarily hold on to these notebooks.
(h)
On or about
July 1, 2001 , an individual moved out of 1335
Riverside,
Dearborn ,
Michigan, to an apartment on Tuxedo
in
Dearborn ,
Michigan
. Defendant, FAROUK ALI-HAIMOUD,
a/k/a "Khalid," then moved into 1335
Riverside,
Dearborn,
Michigan, with Defendants, KARIM
KOUBRITI and AHMED HANNAN.
(i)
Following his departure from the apartment, this individual
remained in contact with the Defendant, ABDELLA LNU, a/k/a
JEAN PIERRE TARDELLI, a/k/a GEORGE LABIBE, a/k/a HUSSEIN
MOHSEN SAFIDDINE, a/k/a NABIL HAYAMM, and used a stolen
credit card number to obtain computer equipment that enabled
him to prepare fraudulent identification for Defendant,
ABDELLA LNU, a/k/a JEAN PIERRE TARDELLI, a/k/a GEORGE LABIBE,
a/k/a HUSSEIN MOHSEN SAFIDDINE, a/k/a NABIL HAYAMM, and
others.
(j)
In or about July, 2001, an individual's apartment on Tuxedo
in
Dearborn
was burglarized and the
false documentation he was in the process of preparing was
stolen. Shortly thereafter, Defendant, ABDELLA LNU, a/k/a
JEAN PIERRE TARDELLI, a/k/a GEORGE LABIBE, a/k/a HUSSEIN
MOHSEN SAFIDDINE, a/k/a NABIL HAYAMM, notified the
individual that the false documentation was in the
possession of Defendants, KARIM KOUBRITI, AHMED HANNAN, and
FAROUK ALI-HAIMOUD, a/k/a "Khalid." Defendant,
ABDELLA LNU, a/k/a JEAN PIERRE TARDELLI, a/k/a GEORGE LABIBE,
a/k/a HUSSEIN MOHSEN SAFIDDINE, a/k/a NABIL HAYAMM, then
brokered a payment to Defendant, KARIM KOUBRITI and AHMED
HANNAN, from a third party for whom the individual had
prepared false identification in return for the falsified
documents.
OVERT
ACTS
11.
In or about February 1998, a radical Islamic fundamentalist
network controlled by Al-Qaeda, issued a Fatwa targeting
American civilians. In a signed statement calling for
attacks on American targets, the Fatwa "declared
war" on the
United States
and the
United Kingdom, stating, "The Fatwa is
Jihad against the
U.S.
and British governments,
armies, interests, airports and institutions." In
addition, the Fatwa stated that, "The only
Islamic Fatwa against this explicit aggression is
Jihad."
12. On or about
February 23, 1998 , Usama Bin Laden issued a
statement, "In compliance with God's order, . . . we
issue the following Fatwa to all Muslims to kill the
Americans." On or about
August 7, 1998, the U.S. Embassies in
Nairobi ,
Kenya, and
Dar Es Salaam,
Tanzania, were bombed.
13.
On or about
August 28, 1998, a Fatwa was issued
by Sheik Abdul Rahman, that called for attacks on American
civilian targets.
14.
The Defendant, KARIM KOUBRITI, was born in
Morocco
and entered the
United States
through
New York
in October
2000.
15.
The Defendant, AHMED HANNAN, was born in
Morocco
and entered the
United States
through
New York City
in November 2000.
16.
The Defendant, FAROUK ALI-HAIMOUD, a/k/a "Khalid,"
was born in
Algeria
and entered the
United States
through
Chicago
in November 1999.
17.
On or about June 1, 2001, Defendants, KARIM KOUBRITI and
AHMED HANNAN, met with an individual at the Arabian Village
Café, 10421 Dix, Dearborn, Michigan.
18.
On or about
June 3, 2001 , Defendants, KARIM KOUBRITI, AHMED HANNAN, and FAROUK ALI-HAIMOUD,
a/k/a "Khalid," met with an individual at the 1335
Riverside
,
Dearborn ,
Michigan
address.
19.
In or about June, 2001, Defendants, KARIM KOUBRITI and AHMED
HANNAN, introduced an individual to Defendant, ABDELLA LNU,
a/k/a JEAN PIERRE TARDELLI, a/k/a GEORGE LABIBE, a/k/a
HUSSEIN MOHSEN SAFIDDINE, a/k/a NABIL HAYAMM, in Dearborn,
Michigan.
20.
In or about June, 2001, Defendants, KARIM KOUBRITI, AHMED
HANNAN, and FAROUK ALI-HAIMOUD, a/k/a "Khalid,"
discussed with an individual their desire to obtain false
travel and identification documents, including false U.S.
and foreign passports, Social Security Administration Social
Security Cards, and State of Michigan operators licenses,
for themselves and others to disguise, hide or otherwise
conceal the holder's identity.
21.
In or about June, 2001, Defendant, FAROUK ALI-HAIMOUD, a/k/a
"Khalid," told an individual that he planned to
send money and weapons to "the brothers" in
Algeria.
22.
In or about June, 2001, Defendant, AHMED HANNAN, described
to an individual the physical layout of the United States
Embassy in
Amman,
Jordan.
23.
In or about June, 2001, Defendant, FAROUK ALI-HAIMOUD, a/k/a
"Khalid," informed an individual that they, the
Defendants, KARIM KOUBRITI, AHMED
HANNAN, and FAROUK ALI-HAIMOUD,
a/k/a "Khalid," were attempting to obtain weapons
from an African-American male in Detroit
.
24.
In or about June, 2001, Defendant, KARIM KOUBRITI, told an
individual that he, Defendant, KARIM KOUBRITI, wanted to
obtain a commercial driver's license to transport hazardous
materials.
25.
In or about June, 2001, Defendant, KARIM KOUBRITI, spoke in
code over a public telephone with an unindicted
co-conspirator "brother" abroad to facilitate the
importation of materials concealed in shoes.
26.
In or about June, 2001, Defendants, KARIM KOUBRITI and AHMED
HANNAN, at the request of Defendant, ABDELLA LNU, a/k/a JEAN
PIERRE TARDELLI, a/k/a GEORGE LABIBE, a/k/a HUSSEIN MOHSEN
SAFIDDINE, a/k/a NABIL HAYAMM, traveled to Detroit
Metropolitan Airport to check for gaps in security.
27.
In or about June, 2001, Defendants, KARIM KOUBRITI, AHMED
HANNAN, and FAROUK ALI-HAIMOUD, a/k/a "Khalid,"
had a conversation wherein they expressed anger over the
treatment and confinement of Sheik Abdul Rahman in
U.S.
custody, and stated that
Islam permitted the killing of innocent civilians.
28.
On or about
July 5, 2001 , Defendants, KARIM KOUBRITI and AHMED HANNAN, were involved in a
traffic accident in
Dearborn ,
Michigan
.
29.
On or about July 16, 2001, Defendant, ABDELLA LNU, a/k/a
JEAN PIERRE TARDELLI, a/k/a GEORGE LABIBE, a/k/a HUSSEIN
MOHSEN SAFIDDINE, a/k/a NABIL HAYAMM, went to a location on
Dix Street in Dearborn, where Defendant, ABDELLA LNU, a/k/a
JEAN PIERRE TARDELLI, a/k/a GEORGE LABIBE, a/k/a HUSSEIN
MOHSEN SAFIDDINE, a/k/a NABIL HAYAMM, received a wire
transfer of $1,206.19, in the name of "Nassim
Hilali" from Amsterdam. The sender was identified as
"Khaled Aly," who Defendant, ABDELLA LNU, a/k/a
JEAN PIERRE TARDELLI, a/k/a GEORGE LABIBE, a/k/a HUSSEIN
MOHSEN SAFIDDINE, a/k/a NABIL HAYAMM, described as one of
the "brothers" who were at the disposal of
Defendant, ABDELLA LNU, a/k/a JEAN PIERRE TARDELLI, a/k/a
GEORGE LABIBE, a/k/a HUSSEIN MOHSEN SAFIDDINE, a/k/a NABIL
HAYAMM, throughout Europe and elsewhere.
30.
In or about July, 2001, Defendants, KARIM KOUBRITI and AHMED
HANNAN, caused several identification documents
to be removed from a residence.
31.
In or about July, 2001, Defendant, ABDELLA LNU, a/k/a JEAN
PIERRE TARDELLI, a/k/a GEORGE LABIBE, a/k/a HUSSEIN MOHSEN
SAFIDDINE, a/k/a NABIL HAYAMM, contacted an individual in
Dearborn, Michigan, told him that Defendants, KARIM KOUBRITI,
AHMED HANNAN and FAROUK ALI-HAIMOUD, a/k/a "Khalid,"
had the false documents that were stolen from his residence,
and that the false documents would be returned in exchange
for a payment.
32.
On or about
August 10, 2001 , an individual wrote Check
Number 104, from an account at TCF National Bank,
Chicago,
Illinois
for $1,000.00, payable to
Defendant, KARIM KOUBRITI.
33.
On or about
August 10, 2001 , Defendant, FAROUK ALI-HAIMOUD,
a/k/a "Khalid," deposited Check Number 104,
payable to Defendant, KARIM KOUBRITI, into Account Number
3130463909, at First Federal of Michigan.
All
in violation of Title 18, United States Code, Section 2339A.
COUNT
TWO
(18
U.S.C. § 371 -- Conspiracy to Engage in Fraud and Misuse of
Visas, Permits and Other Documents)
D-1
KARIM KOUBRITI,
D-2
AHMED HANNAN, and
D-4
ABDELLA LNU, a/k/a JEAN PIERRE TARDELLI, a/k/a GEORGE LABIBE,
a/k/a HUSSEIN MOHSEN SAFIDDINE, a/k/a NABIL HAYAMM,
D-5
FAROUK ALI-HAIMOUD, a/k/a "Khalid"
34.
The allegations contained in Count One are realleged and
incorporated herein.
35.
That from in or about November, 2000, and continuing to on
or about September 17, 2001, said dates being approximate,
in the Eastern District of Michigan, Defendants, KARIM
KOUBRITI, AHMED HANNAN, ABDELLA LNU, a/k/a JEAN PIERRE
TARDELLI, a/k/a GEORGE LABIBE, a/k/a HUSSEIN MOHSEN
SAFIDDINE, a/k/a NABIL HAYAMM, and FAROUK ALI-HAIMOUD, a/k/a
"Khalid," did combine, conspire, confederate and
agree with each other and with others known and unknown to
the Grand Jury, to engage in fraud and misuse of visas,
permits, and other documents and related activity in
connection with identification documents and information as
defined in Title 18, United States Code, Sections 1546 (a)
and (b).
All
in violation of Title 18, United States Code, Section 371.
MANNER
AND MEANS OF THE CONSPIRACY
36.
In furtherance of said unlawful conspiracy, and attempting
to achieve the objective thereof, the Defendants, KARIM
KOUBRITI, AHMED HANNAN, ABDELLA LNU, a/k/a JEAN PIERRE
TARDELLI, a/k/a GEORGE LABIBE, a/k/a HUSSEIN MOHSEN
SAFIDDINE, a/k/a NABIL HAYAMM, and FAROUK ALI-HAIMOUD, a/k/a
"Khalid," performed, among other things, the
following manner and means:
37.
Defendants, KARIM KOUBRITI, AHMED HANNAN, ABDELLA LNU, a/k/a
JEAN PIERRE TARDELLI, a/k/a GEORGE LABIBE, a/k/a HUSSEIN
MOHSEN SAFIDDINE, a/k/a NABIL HAYAMM, and FAROUK ALI-HAIMOUD,
a/k/a "Khalid," attempted to obtain and did obtain
false travel documents, including but not limited to, false
passports, both U.S. and foreign; United States Department
of Justice Immigration and Naturalization Service
Resident Alien Cards; Social Security Administration Social
Security Cards; and State of Michigan operators licences in
order to present said false documentation to others in an
effort to disguise, hide or otherwise conceal their true
identity.
38.
Defendants, KARIM KOUBRITI, AHMED HANNAN, ABDELLA LNU, a/k/a
JEAN PIERRE TARDELLI, a/k/a GEORGE LABIBE, a/k/a HUSSEIN
MOHSEN SAFIDDINE, a/k/a NABIL HAYAMM, and FAROUK ALI-HAIMOUD,
a/k/a "Khalid," attempted to obtain and did obtain
false travel documents, including but not limited to, false
passports, both U.S. and foreign; United States Department
of Justice Immigration and Naturalization Service Resident
Alien Cards; Social Security Administration Social Security
Cards; and State of Michigan operators licenses in order to
provide said false documentation to others outside of the
United States with the purpose and plan to assist others in
entering the United States illegally.
39.
Defendants, KARIM KOUBRITI, AHMED HANNAN, ABDELLA LNU, a/k/a
JEAN PIERRE TARDELLI, a/k/a GEORGE LABIBE, a/k/a HUSSEIN
MOHSEN SAFIDDINE, a/k/a NABIL HAYAMM, and FAROUK ALI-HAIMOUD,
a/k/a "Khalid," attempted to obtain and did obtain
false travel documents, including but not limited to, false
passports, both U.S. and foreign; United States Department
of Justice Immigration and Naturalization Service Resident
Alien Cards; Social Security Administration Social Security
Cards; and State of Michigan operators licences in order to
secure and maintain a mail repository in a name other than
their own in order to disguise, hide or otherwise conceal
the true identity of the actual individual to whom mail was
directed.
OVERT ACTS
40.
During the course of and in furtherance of the unlawful
conspiracy, Defendants, KARIM KOUBRITI, AHMED HANNAN,
ABDELLA LNU, a/k/a JEAN PIERRE TARDELLI, a/k/a GEORGE LABIBE,
a/k/a HUSSEIN MOHSEN SAFIDDINE, a/k/a NABIL HAYAMM, and
FAROUK ALI-HAIMOUD, a/k/a "Khalid," committed
overt acts including, but not limited to the following:
41.
On or about June 1, 2001, Defendants, KARIM KOUBRITI and
AHMED HANNAN, met with an individual at the Arabian Village
Café, 10421 Dix, Dearborn, Michigan.
42.
On or about
June 3, 2001 , Defendants, KARIM KOUBRITI, AHMED HANNAN, and FAROUK ALI-HAIMOUD,
a/k/a "Khalid," met with an individual at 1335
Riverside,
Dearborn,
Michigan.
43.
In or about June, 2001, Defendants, KARIM KOUBRITI and AHMED
HANNAN, introduced an individual to Defendant, ABDELLA LNU,
a/k/a JEAN PIERRE TARDELLI, a/k/a GEORGE LABIBE, a/k/a
HUSSEIN MOHSEN SAFIDDINE, a/k/a NABIL HAYAMM, in Dearborn,
Michigan.
44.
In or about June, 2001, Defendants, KARIM KOUBRITI, AHMED
HANNAN, and FAROUK ALI-HAIMOUD, a/k/a "Khalid,"
discussed with an individual their desire to obtain false
travel and identification documents, including false U.S.
and foreign passports, Social Security Administration Social
Security Cards, and State of Michigan operators licenses,
for themselves and others to disguise, hide or otherwise
conceal the holder's identity.
45.
In or about July, 2001, Defendants, KARIM KOUBRITI and AHMED
HANNAN, caused several identification documents to be
removed from a residence.
46.
In or about July, 2001, Defendant, ABDELLA LNU, a/k/a JEAN
PIERRE TARDELLI, a/k/a GEORGE LABIBE, a/k/a HUSSEIN MOHSEN
SAFIDDINE, a/k/a NABIL HAYAMM, contacted an individual in
Dearborn, Michigan, told him that Defendants, KARIM KOUBRITI,
AHMED HANNAN and FAROUK ALI-HAIMOUD, a/k/a "Khalid,"
had the false documents that were removed from his residence
and that the false documents would be returned in exchange
for a payment.
47.
On or about
August 10, 2001 , an individual wrote Check
Number 104, from an account at TCF National Bank,
Chicago ,
Illinois
for $1,000.00, payable to
Defendant, KARIM KOUBRITI.
48.
On or about
August 10, 2001 , Defendant, FAROUK ALI-HAIMOUD,
a/k/a "Khalid," deposited Check Number 104,
payable to Defendant, KARIM KOUBRITI, into Account Number
3130463909, at First Federal of Michigan.
All
in violation of Title 18, United States Code, Section 371.
COUNT
THREE
(18
U.S.C. §1546 (a) and 2 -- Fraud and Misuse of Visas,
Permits and Other Documents)
D-1
KARIM KOUBRITI
D-2
AHMED HANNAN
D-5
FAROUK ALI-HAIMOUD, a/k/a "Khalid"
49.
The allegations contained in Count One are realleged and
incorporated herein.
50.
Between on or about June 1, 2001, and on or about September
17, 2001, in the Eastern District of Michigan, the
Defendants, KARIM KOUBRITI, AHMED HANNAN, and FAROUK ALI-HAIMOUD,
a/k/a "Khalid," did knowingly possess an immigrant
visa, permit, border crossing card, alien registration card,
or other document prescribed by statute or regulation for
entry into or as evidence of authorized stay or employment
in the United States, that is:
A.
United States of America VISA, bearing serial number
28540988, in the name of Michael Saisa;
B.
U.S. Department of Justice Immigration and Naturalization
Service Resident Alien Card, bearing number AO91199150, in
the name of Michael Saisa; and
C.
World Service Authority Passport, bearing number 319182, in
the name of Michael Saisa which the Defendants, KARIM
KOUBRITI, AHMED HANNAN, and FAROUK ALI-HAIMOUD, a/k/a "Khalid,"
knew to be forged, counterfeited, altered, falsely made,
procured by means of a false claim or statement or otherwise
procured by fraud or unlawfully obtained, with said offense
being committed to facilitate an act of international
terrorism.
All
in violation of Title 18, United States Code, Sections 1546
(a) and 2.
COUNT
FOUR
(18
U.S.C. §1028 (a) (6) and 2 -- Fraud and Related Activity in
Connection with Identification Documents and Information)
D-1
KARIM KOUBRITI
D-2
AHMED HANNAN
D-5
FAROUK ALI-HAIMOUD, a/k/a "Khalid"
51.
The allegations contained in Count One are realleged and
incorporated herein.
52.
Between on or about June 1, 2001, and on or about September
17, 2001, in the Eastern District of Michigan, the Defendants,
KARIM KOUBRITI, AHMED HANNAN, and FAROUK ALI-HAIMOUD, a/k/a
"Khalid," did knowingly possess an identification
document that was or appeared to be an identification
document of the United States, to wit: Social Security
Administration Social Security Card, 034-54-6538, in the
name of Michael Saisa, which document was stolen or produced
without lawful authority, knowing such document was stolen
or produced without such authority.
All
in violation of Title 18, United States Code, Section 1028
(a) (6) and 2.
THIS
IS A TRUE BILL.
__________________________________________
Foreperson
JEFFREY
G. COLLINS
United States
Attorney
___________________________________
RICHARD
G. CONVERTINO Assistant
United States
Attorney
211 W. Fort St., Ste. 2001
Detroit ,
MI
48226
(313) 226-9629
DATED:
August 28, 2002
