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14Jan16


Text of the indictment charging Aws Mohammed Younis Al-Jayab with making a false statement involving international terrorism


BENJAMIN B. WAGNER
United States Attorney
JILL M. THOMAS
Assistant U.S. Attorney
501 I Street, Suite 10-100
Sacramento, CA 95814
(916) 554-2700

ANDREW SIGLER
Trial Attorney, National Security Division
U.S. Department of Justice
950 Pennsylvania Avenue
Washington, D.C. 20530

Attorneys for Plaintiff
United States of America

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF CALIFORNIA

UNITED STATES OF AMERICA,
         Plaintiff,
    v.
AWS MOHAMMED YOUNIS AL-JAYAB,
         Defendant.
CASE NO.
VIOLATION: 18 U.S.C.
1001(a)(2)- False Statements
Involving International Terrorism

INDICTMENT

The Grand Jury charges: THAT

AWS MOHAMMED YOUNIS AL-JAYAB,

defendant herein, on or about October 6, 2014, in the County of Sacramento, State and Eastern District of California, in a matter within the jurisdiction of the Executive Branch of the Government of the United States, to wit: the United States Citizenship and Immigration Services (USCIS), a component of the United States Department of Homeland Security (DHS), did knowingly and willfully make the following materially false, fraudulent, and fictitious statements and representations:

1) When directed to list the countries he visited during the last time he traveled outside the United States, in 2013 to 2014, AL-JAYAB responded that he went to Turkey, and from Turkey he went to Britain and returned to the United States. This response was false because, as defendant AL-JAYAB then and there well knew, he traveled to Syria, and his travel was not confined to Turkey and Britain before returning to the United States;

2) When asked the purpose of his trip, AL-JAYAB responded that he went to Turkey to see his grandmother and to visit the place. This response was false because, as defendant AL-JAYAB then and there well knew, he went to Turkey to get to Syria and for reasons other than to visit his grandmother;

3) In response to the question "Have you ever been a member of any rebel group, militia, or insurgent organization?" AL-JAYAB responded "No." This response was false because, as defendant AL-JAYAB then and there well knew, while he was in Syria between on or about November 19, 2013 and on or about January 17, 2014, he was a member of a rebel group, militia, and insurgent organization.

4) In response to the question "Have you ever assisted any rebel group, militia, or insurgent organization?" AL-JAYAB responded "No." This response was false because, as defendant AL-JAYAB then and there well knew, while he was in Syria between on or about November 19, 2013 and on or about January 17, 2014, he assisted a rebel group, militia, and insurgent organization.

5) In response to the question "Have you ever solicited membership or funds for any terrorist group or organization?" AL-JAYAB responded "No." This response was false because, as defendant AL-JAYAB then and there well knew, he had solicited in April 2013 a person known to the grand jury and referred to herein as Person A to become a member of a terrorist group or organization.

6) In response to the question "Have you ever provided any type of material support to any person or group that engages in terrorist activity?" AL-JAYAB responded, "No." This response was false because, as defendant AL-JAYAB then and there well knew, while he was in Syria between on or about November 19, 2 013 and on or about January 17, 2014, he provided material support to a person and group engaged in terrorism.

7) In response to the question "Have you ever called for, helped with, or committed the killing of any person?" AL-JAYAB responded, "No." This response was false because, as defendant AL-JAYAB then and there well knew, while he was in Syria between on or about November 19, 2013 and on or about January 17, 2014, he called for and helped with the killing of a person.

8) In response to the question "Have you ever called for, helped with, or committed the intentional and severe injury of any person?" AL-JAYAB responded, "No." This response was false because, as defendant AL-JAYAB then and there well knew, while he was in Syria between on or about November 19, 2 013 and on or about January 17, 2014, he called for and helped with the intentional and severe injury of a person.

9) In response to the question "Have you ever been a member of a group of any kind in which you used or threatened to use any type of weapon against any person?" AL-JAYAB responded, "No." This response was false because, as defendant AL-JAYAB then and there well knew, while he was in Syria between on or about November 19, 2013 and on or about January 17, 2014, he was a member of a group in which he used and threatened to use a weapon against a person.

10) In response to the.question "Have you ever assisted in a group where other people used or threatened to use a weapon against any person?" AL-JAYAB responded, "No." This response was false because, as defendant AL-JAYAB then and there well knew, while he was in Syria between on or about November 19, 2013 and on or about January 17, 2014, he assisted a group where other people used and threatened to use a weapon against a person.

This offense involved international terrorism.

In violation of Title 18, United States Code, Section 1001(a)(2).

A TRUE BILL.
FOREPERSON

[Signed]
BENJAMIN B. WAGNER
United States Attorney


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small logoThis document has been published on 17Mar16 by the Equipo Nizkor and Derechos Human Rights. In accordance with Title 17 U.S.C. Section 107, this material is distributed without profit to those who have expressed a prior interest in receiving the included information for research and educational purposes.