http://www.usdoj.gov/ag/moussaouiindictment.htm
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
ALEXANDRIA DIVISION
UNITED STATES OF AMERICA
-v-
ZACARIAS MOUSSAOUI
Overt Acts
In furtherance of the conspiracy, and to effect its objects, the defendant, and others known and unknown to the Grand Jury, committed the following overt acts:
The Provision of Guesthouses and Training Camps
1. At various times from at least as early as 1989, Usama Bin Laden, and others known and unknown, provided training camps and guesthouses in Afghanistan, including camps known as Khalden, Derunta, Khost, Siddiq, and Jihad Wal, for the use of al Qaeda and its affiliated groups.
The Training
2. At various times from at least as early as 1990, unindicted co-conspirators, known and unknown, provided military and intelligence training in various areas, including Afghanistan, Pakistan, and the Sudan, for the use of al Qaeda and its affiliated groups, including the Egyptian Islamic Jihad.
Financial and Business Dealings
3. At various times from at least as early as 1989 until the date of the filing of this Indictment, Usama Bin Laden, and others known and unknown, engaged in financial and business transactions on behalf of al Qaeda, including, but not limited to: purchasing land for training camps; purchasing warehouses for storage of items, including explosives; purchasing communications and electronics equipment; transferring funds between corporate accounts; and transporting currency and weapons to members of al Qaeda and its associated terrorist organizations in various countries throughout the world.
The Efforts to Obtain Nuclear Weapons and Their Components
4. At various times from at least as early as 1992, Usama Bin Laden, and others known and unknown, made efforts to obtain the components of nuclear weapons.
The Fatwahs Against American Troops in Saudi Arabia and Yemen
5. At various times from in or about 1992 until the date of the filing of this Indictment, Usama Bin Laden, working together with members of the fatwah committee of al Qaeda, disseminated fatwahs to other members and associates of al Qaeda that the United States forces stationed on the Saudi Arabian peninsula, including both Saudi Arabia and Yemen, should be attacked.
The Fatwah Against American Troops in Somalia
6. At various times from in or about 1992 until in or about 1993, Usama Bin Laden, working together with members of the fatwah committee of al Qaeda, disseminated fatwahs to other members and associates of al Qaeda that the United States forces stationed in the Horn of Africa, including Somalia, should be attacked.
The Fatwah Regarding Deaths of Nonbelievers
7. On various occasions, an unindicted co-conspirator advised other members of al Qaeda that it was Islamically proper to engage in violent actions against "infidels" (nonbelievers), even if others might be killed by such actions, because if the others were "innocent," they would go to paradise, and if they were not "innocent," they deserved to die.
The August 1996 Declaration of War
8. On or about August 23, 1996, a Declaration of Jihad indicating that it was from the Hindu Kush mountains in Afghanistan entitled, "Message from Usamah Bin-Muhammad Bin-Laden to His Muslim Brothers in the Whole World and Especially in the Arabian Peninsula: Declaration of Jihad Against the Americans Occupying the Land of the Two Holy Mosques; Expel the Heretics from the Arabian Peninsula" was disseminated.
The February 1998 Fatwah Against American Civilians
9. In February 1998, Usama Bin Laden endorsed a fatwah under the banner of the "International Islamic Front for Jihad on the Jews and Crusaders." This fatwah, published in the publication Al-Quds al-`Arabi on February 23, 1998, stated that Muslims should kill Americans - including civilians - anywhere in the world where they can be found.
10. In an address in or about 1998, Usama Bin Laden cited American aggression against Islam and encouraged a jihad that would eliminate the Americans from the Arabian Peninsula.
Bin Laden Endorses the Nuclear Bomb of Islam
11. On or about May 29, 1998, Usama Bin Laden issued a statement entitled "The Nuclear Bomb of Islam," under the banner of the "International Islamic Front for Fighting the Jews and the Crusaders," in which he stated that "it is the duty of the Muslims to prepare as much force as possible to terrorize the enemies of God."
Usama Bin Laden Issues Further Threats in June 1999
12. In or about June 1999, in an interview with an Arabic-language television station, Usama Bin Laden issued a further threat indicating that all American males should be killed.
Usama Bin Laden Calls for "Jihad" to Free Imprisoned Terrorists
13. In or about September 2000, in an interview with an Arabic-language television station, Usama Bin Laden called for a "jihad" to release the "brothers" in jail "everywhere."
