Monday, October 06, 2014
Criminal Complaint Against Mohammed Hamzah Khan
AO 91 (Rev. 11/11) Criminal Complaint AUSAs Matthew Hiller and Angel M. Krull (312) 697-4088
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
UNITED STATES OF AMERICA
v.
MOHAMMED HAMZAH KHAN
CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best of my knowledge
and belief.
On or about October 4, 2014, at Chicago, in the Northern District of Illinois, Eastern Division,
and elsewhere, the defendant(s) violated:
Code Section Offense Description
knowingly attempting to provide material support and resources, namely, personnel, to a foreign terrorist organization, namely, the Islamic State of Iraq and the Levant, knowing that the organization was a designated terrorist organization and that organization had engaged in and was engaging in terrorist activity and terrorism
Title 18, United States Code, Section
2339B(a)(1)
This criminal complaint is based upon these facts:
X Continued on the attached sheet.
Sworn to before me and signed in my presence.
Date: October 6, 2014
City and state: Chicago, Illinois SUSAN E. COX, U.S. Magistrate Judge
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
I, DANA C. MCNEAL, being duly sworn, state as follows:
1. I am a Special Agent with the Federal Bureau of Investigation, and
have been so employed since approximately October 2002. My current
responsibilities include the investigation of violations relating to international
terrorism, including the provision and attempted provision of material support or
resources to foreign terrorist organizations, in violation of Title 18, United States
Code, Section 2339B(a)(1).
2. This affidavit is submitted in support of a criminal complaint alleging
that MOHAMMED HAMZAH KHAN has violated Title 18, United States Code,
Section 2339B(a)(1). Because this affidavit is being submitted for the limited
purpose of establishing probable cause in support of a criminal complaint charging
KHAN with knowingly attempting to provide material support and resources,
namely, personnel (to wit, himself), to a foreign terrorist organization, namely, the
Islamic State of Iraq and the Levant, knowing that the organization was a
designated terrorist organization and that organization had engaged in and was
engaging in terrorist activity and terrorism, I have not included each and every fact
known to me concerning this investigation. I have set forth only the facts that I
believe are necessary to establish probable cause to believe that the defendant
committed the offense alleged in the complaint.
3. This affidavit is based on my personal knowledge, information from
other law enforcement personnel and from persons with knowledge regarding
relevant facts, and on my training and experience, which includes receiving
information from other law enforcement personnel and sources of information
regarding relevant facts.
4. This affidavit includes summaries and quotations of certain documents
that were obtained by law enforcement. Some of these documents included writings
in Arabic and English. While translators have attempted to translate the writings
accurately, to the extent that quotations are included, they are preliminary, not
final translations. In addition, the bracketed words and phrases that have been
inserted into the communications provide my understanding of such
communications based on my training and experience, and the context of the
communications.
MOHAMMED HAMZAH KHAN
5. According to his United States passport, which was issued on or about
May 2, 2014, KHAN is a nineteen year-old United States citizen who resides at
Residence 1. According to U.S. State Department records, KHAN’s passport
application listed Individual A as KHAN’s father and Residence 1 as KHAN’s
address.
6. According to Individuals A and B, they are the parents of KHAN and
other siblings, all of whom live at Residence 1. Also during interviews of Individuals
A and B, they referred to KHAN by his middle name.
The Islamic State of Iraq and the Levant
7. On or about October 15, 2004, the United States Secretary of State
designated al-Qaeda in Iraq, then known as Jam’at al Tawhid wa’al-Jihad, as a
Foreign Terrorist Organization under Section 219 of the Immigration and
Nationality Act and as a Specially Designated Global Terrorist entity under section
1(b) of Executive Order 13224.
8. On or about May 15, 2014, the Secretary of State amended the
designation of al-Qaeda in Iraq as a Foreign Terrorist Organization under Section
219 of the Immigration and Nationality Act and as a Specially Designated Global
Terrorist entity under section 1(b) of Executive Order 13224 to add the alias Islamic
State of Iraq and the Levant (“ISIL”) as its primary name. The Secretary also added
the following aliases to the ISIL listing: the Islamic State of Iraq and al-Sham, the
Islamic State of Iraq and Syria, ad-Dawla al-Islamiyya fi al-‘Iraq wa-sh-Sham,
Daesh, Dawla al Islamiya, and Al-Furqan Establishment for Media Production.
9. Based on my training and experience, I know that: (a) Sunni
extremists, who are not citizens or residents of Syria and Iraq, are traveling to
Syria and Iraq to join ISIL and commonly enter Syria by crossing the border from
Turkey; (b) foreign fighters from Western countries are traveling to locations in
Turkey, including Istanbul, and then traveling to towns closer to the border where
they are brought into Syria to join ISIL; (c) Abu Bakr al-Baghdadi is the current
leader of ISIL; (d) ISIL is also frequently referred to as “ISIS” (an acronym for the
Islamic State of Iraq and al-Sham or the Islamic State of Iraq and Syria); and
(e) the following flag is affiliated with ISIL:
KHAN’s Attempt to Travel Overseas
10. According to information received from Austrian Airlines, on or about
September 26, 2014, roundtrip tickets were purchased for KHAN to: (a) travel on
October 4, 2014, in the afternoon, from Chicago O’Hare International Airport to
Vienna, Austria, and from Vienna, Austria, to Istanbul, Turkey, arriving on October
5, 2014; FN1 and (b) travel on October 8, 2014, from Istanbul, Turkey, to Zurich,
Switzerland, and from Zurich, Switzerland, to Chicago O’Hare International
Airport, arriving on October 9, 2014.
11. On or about October 4, 2014, in the afternoon, KHAN was observed by
law enforcement agents passing through the security screening checkpoint within
the international terminal at Chicago O’Hare International Airport. Subsequently,
law enforcement agents came into contact with KHAN, who possessed Austrian
Airline tickets for travel that day from Chicago to Vienna, and tickets for travel
from Vienna to Istanbul on October 5, 2014. Further information concerning this
encounter is described below.
= = = = =
FN 1 As noted above, Turkey is a common transit point for foreign fighters from the United
States and other western countries to travel to Syria to join ISIL.
= = = = =
The Search of KHAN’s Home
12. On or about October 4, 2014, while KHAN was at the airport, law
enforcement agents executed a search warrant at Residence 1. During the search,
agents recovered multiple handwritten documents that appeared to be drafted by
KHAN and/or other persons, and which expressed support for ISIL. The following
are descriptions of just some of the items agents seized from Residence 1.
13. In what appeared to be a common room, agents recovered a
handwritten notebook, which includes the following:
a. A page that contains the word “Purchased” with the following
steps listed below: “(1) $4,000.00 ticket to Istanbul Cred,” “(2) supplies via credit
card,” “(3) cash for hotel in Istanbul $(70),” “(4) bus ride to Esekir ($),” “(5) Esekir ->
Koya -> Adana,” FN2 “(6) get in touch with” a list of four individuals, including
Individual C, FN3 “(7) Most likely go to Urfa.” FN4 Above this list was a drawing of what
appeared to be the United States and Turkey. That drawing included an arrow from
the United States to northwest Turkey, two arrows across Turkey, and one arrow
pointing across what appeared to be the border of Turkey and Syria or Iraq. Also on
this page were the following words (in Arabic): “Al-Raqqah Province. In the Islamic
State in Iraq and Levant. Abu-‘Ikasha Al-Amriki. For the Islamic State in Iraq and
Levant.”
= = = = =
FN2 Based on my training and experience, the context of this writing, and my knowledge of the
investigation, I believe these are references to the Turkish cities of Eskisehir, Konya, and
Adana.
FN3 Two of the four names were written in Arabic.
FN4 I believe this to be a reference to a city in southeastern Turkey which is near the Syrian
border.
= = = = =
b. A page with a drawing and the following words (in Arabic): “The
Commander of the Ranks under Abu-Bakir Al-Baghdadi, Abu-Mariyah Al-Hariri,
the Commander of the Ranks.”
c. A page that included the following words (in Arabic): “Islamic
State in Iraq and Levant. Here to stay. We are the lions of the war [unintelligible].
My nation, the dawn has emerged.”
d. A page with drawings that appeared to depict the ISIL flag and
that of another designated foreign terrorist organization.
e. One page in the notebook had a drawing of what appeared to be
an armed fighter with an ISIL flag behind him. Above and below these drawings
were the words in Arabic: “Come to Jihad.” FN5
f. Different pages containing the handwritten names of “Hamza
Khan” and that of another person.
14. In what appeared to be a living room, agents recovered a calendar book
with various handwritten notations, including a drawing of what appeared to be the
ISIL flag and written references (in Arabic) to “the Islamic State of Iraq and the
Levant,” “Abu Bakir Al-Baghdadi,” and Individual C, as well as killing a “Nusayri
[Alawite].” FN6
= = = = =
FN5 “Jihad” is an Arabic term meaning “struggle,” referring to one’s struggle on behalf of
Islam. In this context, I understand this to be a reference to a violent form of jihad.
FN6 I know that Alawites are a part of Shia Islam and that ISIL is a Sunni Islamic terrorist
organization. Based on my training and experience, I know Sunni Islamic terrorists, like
ISIL, support the eradication of Shia Islam.
= = = = =
15. In a bedroom identified by KHAN’s parents as belonging to KHAN and
a sibling agents recovered, among other things, a handwritten, 3-page letter, which
appears to have been written by KHAN and left for his parents to explain his
October 4, 2014 travel. In summary, in the letter, which is signed “Your loving son,
Hamza [KHAN’s middle name],” KHAN advised his parents that: (i) they should not
contact the “authorities” about his trip (“FIRST and FOREMOST, PLEASE MAKE
SURE TO NOT TELL THE AUTHORITIES For if this were to happen it will
jeopardize not only the safety of us but our family as well.”); (ii) he was on his way
to Syria (“My dear parents, there are a number of reasons I will be going to the
blessed land of Shaam, FN7 and leaving my home.”); (iii) there is an obligation to
“migrate” to the “Islamic state [ISIL controlled territory]” now that it has “been
established;” (iv) he was upset that, as an adult, he was obligated to pay taxes that
would be used to kill his “Muslim brothers and sisters”; (v) he was upset with the
decline of western societies (“We are all witness that the western societies are
getting more immoral day by day. I do not want my kids being exposed to filth like
this . . ..”); and (vi) “I extend an invitation, to my family, to join me in the Islamic
State.”
= = = = =
7 Sham is a frequent alternative name for Syria.
= = = = =
16. During the execution of the search warrant, Individual A consented in
writing to a search of a vehicle owned by him. According to Individual A, he gave
KHAN a key to the vehicle and allowed KHAN to drive it to work and school.
Individual A brought agents to the vehicle, opened the door to the vehicle for them,
and the vehicle was then searched. Among other items, agents found in the vehicle
a spiral-bound notebook containing the following words and symbols:
a. The name of KHAN;
b. Islamic State in Iraq and the Levant (in Arabic);
c. Al-Qaeda in the Levant (in Arabic);
d. The Syrian Resistance (in Arabic); and
e. The ISIL flag and the flag of another designated foreign terrorist
organization.
Information Provided by KHAN
17. On or about October 4, 2014, at approximately 2:28 pm, KHAN was
approached and interviewed by Customs and Border Protection (“CBP”) officers in
the area of international departure gates M14 and M15 at the airport. During the
interview, KHAN told CBP officers, among other things, that he did not have any
family in Istanbul and that he planned to stay at a hotel in Istanbul for two or three
days, with a return flight on Thursday. KHAN thereafter was interviewed by FBI
agents at another location within the airport. That interview lasted approximately
three hours. At the conclusion of the interview, law enforcement escorted KHAN
back to the international terminal.
18. Later in the evening, KHAN was placed under arrest. Thereafter, he
was interviewed by different FBI agents at the airport. According to agents who
conducted the interview, KHAN was provided Miranda warnings, which KHAN
agreed to waive verbally and in writing. During the interview, KHAN advised that
Individual C, whom he had met online, had provided him the phone number of a
person KHAN was to contact once KHAN arrived in Istanbul. This contact was to
take KHAN to where ISIS was. When asked where that was, KHAN said the area
in Syria and Iraq. KHAN also said he planned on remaining there permanently and
that he knew that he would be arrested if he returned to the United States. When
asked what he was going to do there, KHAN advised that he expected to be involved
in some type of public service, a police force, humanitarian work, or a combat role.
19. Based on the above information, I respectfully submit that there is
probable cause that MOHAMMED HAMZAH KHAN has violated Title 18, United
States Code, Section 2339B(a)(1).
SUBSCRIBED AND SWORN to before me on October 6, 2014.
SUSAN E. COX
United States Magistrate Judge
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
UNITED STATES OF AMERICA
v.
MOHAMMED HAMZAH KHAN
CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best of my knowledge
and belief.
On or about October 4, 2014, at Chicago, in the Northern District of Illinois, Eastern Division,
and elsewhere, the defendant(s) violated:
Code Section Offense Description
knowingly attempting to provide material support and resources, namely, personnel, to a foreign terrorist organization, namely, the Islamic State of Iraq and the Levant, knowing that the organization was a designated terrorist organization and that organization had engaged in and was engaging in terrorist activity and terrorism
Title 18, United States Code, Section
2339B(a)(1)
This criminal complaint is based upon these facts:
X Continued on the attached sheet.
Sworn to before me and signed in my presence.
Date: October 6, 2014
City and state: Chicago, Illinois SUSAN E. COX, U.S. Magistrate Judge
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
I, DANA C. MCNEAL, being duly sworn, state as follows:
1. I am a Special Agent with the Federal Bureau of Investigation, and
have been so employed since approximately October 2002. My current
responsibilities include the investigation of violations relating to international
terrorism, including the provision and attempted provision of material support or
resources to foreign terrorist organizations, in violation of Title 18, United States
Code, Section 2339B(a)(1).
2. This affidavit is submitted in support of a criminal complaint alleging
that MOHAMMED HAMZAH KHAN has violated Title 18, United States Code,
Section 2339B(a)(1). Because this affidavit is being submitted for the limited
purpose of establishing probable cause in support of a criminal complaint charging
KHAN with knowingly attempting to provide material support and resources,
namely, personnel (to wit, himself), to a foreign terrorist organization, namely, the
Islamic State of Iraq and the Levant, knowing that the organization was a
designated terrorist organization and that organization had engaged in and was
engaging in terrorist activity and terrorism, I have not included each and every fact
known to me concerning this investigation. I have set forth only the facts that I
believe are necessary to establish probable cause to believe that the defendant
committed the offense alleged in the complaint.
3. This affidavit is based on my personal knowledge, information from
other law enforcement personnel and from persons with knowledge regarding
relevant facts, and on my training and experience, which includes receiving
information from other law enforcement personnel and sources of information
regarding relevant facts.
4. This affidavit includes summaries and quotations of certain documents
that were obtained by law enforcement. Some of these documents included writings
in Arabic and English. While translators have attempted to translate the writings
accurately, to the extent that quotations are included, they are preliminary, not
final translations. In addition, the bracketed words and phrases that have been
inserted into the communications provide my understanding of such
communications based on my training and experience, and the context of the
communications.
MOHAMMED HAMZAH KHAN
5. According to his United States passport, which was issued on or about
May 2, 2014, KHAN is a nineteen year-old United States citizen who resides at
Residence 1. According to U.S. State Department records, KHAN’s passport
application listed Individual A as KHAN’s father and Residence 1 as KHAN’s
address.
6. According to Individuals A and B, they are the parents of KHAN and
other siblings, all of whom live at Residence 1. Also during interviews of Individuals
A and B, they referred to KHAN by his middle name.
The Islamic State of Iraq and the Levant
7. On or about October 15, 2004, the United States Secretary of State
designated al-Qaeda in Iraq, then known as Jam’at al Tawhid wa’al-Jihad, as a
Foreign Terrorist Organization under Section 219 of the Immigration and
Nationality Act and as a Specially Designated Global Terrorist entity under section
1(b) of Executive Order 13224.
8. On or about May 15, 2014, the Secretary of State amended the
designation of al-Qaeda in Iraq as a Foreign Terrorist Organization under Section
219 of the Immigration and Nationality Act and as a Specially Designated Global
Terrorist entity under section 1(b) of Executive Order 13224 to add the alias Islamic
State of Iraq and the Levant (“ISIL”) as its primary name. The Secretary also added
the following aliases to the ISIL listing: the Islamic State of Iraq and al-Sham, the
Islamic State of Iraq and Syria, ad-Dawla al-Islamiyya fi al-‘Iraq wa-sh-Sham,
Daesh, Dawla al Islamiya, and Al-Furqan Establishment for Media Production.
9. Based on my training and experience, I know that: (a) Sunni
extremists, who are not citizens or residents of Syria and Iraq, are traveling to
Syria and Iraq to join ISIL and commonly enter Syria by crossing the border from
Turkey; (b) foreign fighters from Western countries are traveling to locations in
Turkey, including Istanbul, and then traveling to towns closer to the border where
they are brought into Syria to join ISIL; (c) Abu Bakr al-Baghdadi is the current
leader of ISIL; (d) ISIL is also frequently referred to as “ISIS” (an acronym for the
Islamic State of Iraq and al-Sham or the Islamic State of Iraq and Syria); and
(e) the following flag is affiliated with ISIL:
10. According to information received from Austrian Airlines, on or about
September 26, 2014, roundtrip tickets were purchased for KHAN to: (a) travel on
October 4, 2014, in the afternoon, from Chicago O’Hare International Airport to
Vienna, Austria, and from Vienna, Austria, to Istanbul, Turkey, arriving on October
5, 2014; FN1 and (b) travel on October 8, 2014, from Istanbul, Turkey, to Zurich,
Switzerland, and from Zurich, Switzerland, to Chicago O’Hare International
Airport, arriving on October 9, 2014.
11. On or about October 4, 2014, in the afternoon, KHAN was observed by
law enforcement agents passing through the security screening checkpoint within
the international terminal at Chicago O’Hare International Airport. Subsequently,
law enforcement agents came into contact with KHAN, who possessed Austrian
Airline tickets for travel that day from Chicago to Vienna, and tickets for travel
from Vienna to Istanbul on October 5, 2014. Further information concerning this
encounter is described below.
= = = = =
FN 1 As noted above, Turkey is a common transit point for foreign fighters from the United
States and other western countries to travel to Syria to join ISIL.
= = = = =
The Search of KHAN’s Home
12. On or about October 4, 2014, while KHAN was at the airport, law
enforcement agents executed a search warrant at Residence 1. During the search,
agents recovered multiple handwritten documents that appeared to be drafted by
KHAN and/or other persons, and which expressed support for ISIL. The following
are descriptions of just some of the items agents seized from Residence 1.
13. In what appeared to be a common room, agents recovered a
handwritten notebook, which includes the following:
a. A page that contains the word “Purchased” with the following
steps listed below: “(1) $4,000.00 ticket to Istanbul Cred,” “(2) supplies via credit
card,” “(3) cash for hotel in Istanbul $(70),” “(4) bus ride to Esekir ($),” “(5) Esekir ->
Koya -> Adana,” FN2 “(6) get in touch with” a list of four individuals, including
Individual C, FN3 “(7) Most likely go to Urfa.” FN4 Above this list was a drawing of what
appeared to be the United States and Turkey. That drawing included an arrow from
the United States to northwest Turkey, two arrows across Turkey, and one arrow
pointing across what appeared to be the border of Turkey and Syria or Iraq. Also on
this page were the following words (in Arabic): “Al-Raqqah Province. In the Islamic
State in Iraq and Levant. Abu-‘Ikasha Al-Amriki. For the Islamic State in Iraq and
Levant.”
= = = = =
FN2 Based on my training and experience, the context of this writing, and my knowledge of the
investigation, I believe these are references to the Turkish cities of Eskisehir, Konya, and
Adana.
FN3 Two of the four names were written in Arabic.
FN4 I believe this to be a reference to a city in southeastern Turkey which is near the Syrian
border.
= = = = =
b. A page with a drawing and the following words (in Arabic): “The
Commander of the Ranks under Abu-Bakir Al-Baghdadi, Abu-Mariyah Al-Hariri,
the Commander of the Ranks.”
c. A page that included the following words (in Arabic): “Islamic
State in Iraq and Levant. Here to stay. We are the lions of the war [unintelligible].
My nation, the dawn has emerged.”
d. A page with drawings that appeared to depict the ISIL flag and
that of another designated foreign terrorist organization.
e. One page in the notebook had a drawing of what appeared to be
an armed fighter with an ISIL flag behind him. Above and below these drawings
were the words in Arabic: “Come to Jihad.” FN5
f. Different pages containing the handwritten names of “Hamza
Khan” and that of another person.
14. In what appeared to be a living room, agents recovered a calendar book
with various handwritten notations, including a drawing of what appeared to be the
ISIL flag and written references (in Arabic) to “the Islamic State of Iraq and the
Levant,” “Abu Bakir Al-Baghdadi,” and Individual C, as well as killing a “Nusayri
[Alawite].” FN6
= = = = =
FN5 “Jihad” is an Arabic term meaning “struggle,” referring to one’s struggle on behalf of
Islam. In this context, I understand this to be a reference to a violent form of jihad.
FN6 I know that Alawites are a part of Shia Islam and that ISIL is a Sunni Islamic terrorist
organization. Based on my training and experience, I know Sunni Islamic terrorists, like
ISIL, support the eradication of Shia Islam.
= = = = =
15. In a bedroom identified by KHAN’s parents as belonging to KHAN and
a sibling agents recovered, among other things, a handwritten, 3-page letter, which
appears to have been written by KHAN and left for his parents to explain his
October 4, 2014 travel. In summary, in the letter, which is signed “Your loving son,
Hamza [KHAN’s middle name],” KHAN advised his parents that: (i) they should not
contact the “authorities” about his trip (“FIRST and FOREMOST, PLEASE MAKE
SURE TO NOT TELL THE AUTHORITIES For if this were to happen it will
jeopardize not only the safety of us but our family as well.”); (ii) he was on his way
to Syria (“My dear parents, there are a number of reasons I will be going to the
blessed land of Shaam, FN7 and leaving my home.”); (iii) there is an obligation to
“migrate” to the “Islamic state [ISIL controlled territory]” now that it has “been
established;” (iv) he was upset that, as an adult, he was obligated to pay taxes that
would be used to kill his “Muslim brothers and sisters”; (v) he was upset with the
decline of western societies (“We are all witness that the western societies are
getting more immoral day by day. I do not want my kids being exposed to filth like
this . . ..”); and (vi) “I extend an invitation, to my family, to join me in the Islamic
State.”
= = = = =
7 Sham is a frequent alternative name for Syria.
= = = = =
16. During the execution of the search warrant, Individual A consented in
writing to a search of a vehicle owned by him. According to Individual A, he gave
KHAN a key to the vehicle and allowed KHAN to drive it to work and school.
Individual A brought agents to the vehicle, opened the door to the vehicle for them,
and the vehicle was then searched. Among other items, agents found in the vehicle
a spiral-bound notebook containing the following words and symbols:
a. The name of KHAN;
b. Islamic State in Iraq and the Levant (in Arabic);
c. Al-Qaeda in the Levant (in Arabic);
d. The Syrian Resistance (in Arabic); and
e. The ISIL flag and the flag of another designated foreign terrorist
organization.
Information Provided by KHAN
17. On or about October 4, 2014, at approximately 2:28 pm, KHAN was
approached and interviewed by Customs and Border Protection (“CBP”) officers in
the area of international departure gates M14 and M15 at the airport. During the
interview, KHAN told CBP officers, among other things, that he did not have any
family in Istanbul and that he planned to stay at a hotel in Istanbul for two or three
days, with a return flight on Thursday. KHAN thereafter was interviewed by FBI
agents at another location within the airport. That interview lasted approximately
three hours. At the conclusion of the interview, law enforcement escorted KHAN
back to the international terminal.
18. Later in the evening, KHAN was placed under arrest. Thereafter, he
was interviewed by different FBI agents at the airport. According to agents who
conducted the interview, KHAN was provided Miranda warnings, which KHAN
agreed to waive verbally and in writing. During the interview, KHAN advised that
Individual C, whom he had met online, had provided him the phone number of a
person KHAN was to contact once KHAN arrived in Istanbul. This contact was to
take KHAN to where ISIS was. When asked where that was, KHAN said the area
in Syria and Iraq. KHAN also said he planned on remaining there permanently and
that he knew that he would be arrested if he returned to the United States. When
asked what he was going to do there, KHAN advised that he expected to be involved
in some type of public service, a police force, humanitarian work, or a combat role.
19. Based on the above information, I respectfully submit that there is
probable cause that MOHAMMED HAMZAH KHAN has violated Title 18, United
States Code, Section 2339B(a)(1).
SUBSCRIBED AND SWORN to before me on October 6, 2014.
SUSAN E. COX
United States Magistrate Judge
# posted by Cal Skinner : 9:24 AM
