Al-Ghazi, a 38-year-old United States Citizen, who legally changed his name from Robert C. McCollum to Amir Said Abdul Rahman Al-Ghazi in early 2015, was taken into custody without incident this morning in North Olmsted, Ohio.
Al-Ghazi, a 38-year-old United States Citizen, who legally changed his name from Robert C. McCollum to Amir Said Abdul Rahman Al-Ghazi in early 2015, was taken into custody without incident this morning in North Olmsted, Ohio.
Al-Ghazi, a 38-year-old United States Citizen, who legally changed his name from Robert C. McCollum to Amir Said Abdul Rahman Al-Ghazi in early 2015, was taken into custody without incident this morning in North Olmsted, Ohio.
AFFIDAVIT IN SUPPORT OR
AN APPLICATION FOR A CRIMINAL COMPL:
AND ARREST WARRANT
1, Ryan A. Presley, being first duly swom, hereby depose and state as follows:
1 1am a Special Agent with the Federal Bureau of Investigation and, as such, am an
investigative or law enforcement officer of the United States within the meaning of Rule
41(a)(2)(C) of the Federal Rules of Criminal Procedure. 11am engaged in the enforcement of
criminal laws and am within the category of officers authorized by the Attorney General to
request and execute search warrants.
2. Thave investigated numerous national security cases involving individuals
seeking to travel overseas to commit violent jihad and who have participated in terrorist
fundraising. Additionally, I have completed FBI administered counterterrorism classroom and
online training, at the FBI Academy, and at other FBI facilities. I also have participated in the
investigation of other federal violations to include drug trafficking, counterfeit goods, and
organized crime.
3. ‘The facts in this affidavit come from my personal observations,' my training and
experience, and information obtained from other agents and witnesses. This affidavit is intended
to show merely that there is sufficient probable cause to support a criminal complaint and arrest
warrant, Therefore, it does not set forth all of my knowledge about this matter.
" Affiant has reviewed all statements, postings, and tweets made by Al-Ghazi prior to incorporating them into this
affidavit. Moreover, a significant portion of the content within this affidavit has also been obtained through the
execution of a Search and Seizure Warrant on Amir Said Raliman Al-Ghazi's Twitter accounts. (See footnote 4.)4. Based on my training and experience as a Special Agent with the FBI, as well as
the facts as set forth in this affidavit, there is probable cause to believe that violations of Title 18,
United States Code, Section 2339B(a)(1), Attempting to Provide Material Support to a
Designated Foreign Terrorist Organization; Title 18, United States Code, Section 922(¢)(1),
Felon in Possession of a Firearm; and Title 21, United States Code, Sections 841(a)(1) and
(b)(1)(D), Distribution of Controlled Substances have been committed by Amir Said Abdul
Rahman Al-Ghazi, aka “Robert C. McCollum.”
5. Al-Ghazi is a United States citizen currently living at 5220 Bast Lake Road,
Apartment B-12, Sheffield Lake, Ohio 44054. Al-Ghazi’s name was previously Robert C.
McCollum, In early 2015, Al-Ghazi legally changed his name from Robert C, MeCollum to
‘Amir Said Abdul Rahman Al-Ghazi
6. This Court is advised that there are items within the Probable Cause section of
this affidavit that have been translated from Arabic into English. In each instance, said initial
translations were completed by a qualified FBI Linguist for the purpose of accurately
representing the statements made by Al-Ghazi. Moreover, for ease of review, the translated
material will be limited to that which is enclosed within brackets at the end of each numbered
paragraph, Where there are multiple instances of a particular term or phrase, Affiant will only
include a translation for the initial occurrence.
PROBABLE CAUSE
VIOLATION OF TITLE 18, UNITED STATES CODE, SECTION 2339B(a)(1)
7. Title 18, United States Code, Section 2339B states: “Whoever knowingly
provides material support or resour
es to a foreign terrorist organization, or attempts or conspires
to do so, shall be fined under this title or imprisoned.... To violate this paragraph, a person musthave knowledge that the organi
ion is a designated terrorist organization (as defined in
subsection (g)(6)), that the organization has engaged or engages in terrorist activity (as defined in
section 212(a)(3)(B) of the Immigration and Nationality Act), or that the organization has
engaged or engages in terrorism (as defined in section 140(4)(2) of the Foreign Relations
Authorization Act, Fiscal Years 1988 and 1989,”
8. On October 15, 2004, the United States Secretary of State designated al-Qa'ida in
Iraq (AQI), then known as Jam’at al Tawhid wa‘
ihad, 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.
9. OnMay 15, 2014, the Secretary of State amended the designation of AQI as an
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
‘eoretary
also added the following aliases for ISIL: the Islamic State of Iraq and al-Sham, the Islamic State
of Iraq and Syria (ISIS), ad-Dawla al-Islamiyya fi al“Iraq wa-sh-Sham, Daesh, Dawla al
Islamiya, and Al-Furqan Establishment for Media Production. Although the group never called
itself “Al-Qa’ida in Iraq,” this name has frequently been used to describe it through its history. In
an audio recording publically released on June 29, 2014, ISIL announced a formal name change
of ISIL name to Islamic State (IS). ISTL has remained continuously designated since the first
designation of AQI in 2004Ownership of Social Media Profites
10. A portion of the information contained in this affidavit establishing probable
cause to arrest Al-Ghazi was obtained through a review of postings by Al-Ghazi on social media,
e investigation has confirmed Al-Ghazi’s use of the relevant social media accounts.
Specifically, there is probable cause to establish that Twitter profiles “Amir Al Ghazi,” username
of “@amiralghazi76,” URL of https://twitter.com/amiralghazi76; “Amir Muwahi
“@MuwahidAmir,” URL of https://twitter.com/MuwahidAmir; US Message Board profile
“Amir Muwahid,” usemame of “amirmuwahid76,” URL of
www.tismessageboard.com/members/amirmuwahid76.53232; Google+ profile “Amir
Muwahid,” URL of hitps://plus.google.com/106169538990487418520; and another
communication application profile “abusadiq” are all utilized by Al-Ghazi.
11, Inlate Maretvearly April 2015, Affiant noted the Twitter profile “Amir Al Ghazi”
changed on two (2) occasions, The profile was first changed to “Abu Sadiq al Ghazi” and then
to “Abu Ahmed al Amriki.” Affiant noted that for both changes, the username and URL
remained as “@amiralghazi76” and https://twitter.com/ amiralghazi76. Additionally, Affiant
observed the content for profiles “Abu Sadiq al Ghazi” and “Abu Ahmed al Amriki” to be
consistent with that which was previously observed on profile “Amir Al Ghazi.”
12. Relevant facts related to Al-Ghazi’s use of referenced profiles are as follows
13. On September 30 and October 3, 201
? Affiant facilitated/conducted interviews
with Al-Ghazi. On both occasions, Al-Ghazi stated that he intended to legally change his name
to “Amir Al Ghazi” and provided his telephone number as (440) 329-4001
the September 30, 2013, interview of Al-Ghazi was conducted by a Cleveland FBI Joint Terrorism Task Force
(TTF) Officer atthe direction of your Affiant.14, In August of 2014, Al-Ghazi informed a Confidential Human Source (hereafter
referred to as CHS#1") via Twitter profile “Amir Al Ghazi,” that he intended to change his name
to “Amir Al Ghazi” or “Amir Muwahid.”
15, Subsequent to these communications, CHS#1 met in-person with Al-Ghazi, After
that meeting, Al-Ghazi utilized Twitter profile “Amir Al Ghazi” when continuing to
communicate online with CHS#1.
16. Al-Ghazi also maintains a historical Twitter profile, “abu sadiq al ghazi,”
username of “@abusadiq76,” and URL of https://twitter.com/abusadiq76. This profile contains
a publically available image of Al-Ghazi and lists his residence as Lorain, Ohio, Al-Ghazi’s
current residence is in Sheffield Lake, Ohio, which borders Lorain, Ohio, For Twitter accounts,
“Amir Al Ghazi
* and “abu sadiq al ghazi,” the number “76” is used within the usernames
(*@amiralghazi76”; “@abusadiq76”). Afiant notes that the year of birth for Al-Ghazi is 1976.
17. Publically accessible activity on Twitter profile “Amir al Ghazi,” ceased on
December 27, 2014. Twitter profile “Amir Muwahid,” was established on December 29, 2014.
‘The content observed within each profile appears to be substantially similar. On January 23,
2015, the user of Twitter profile “Amir Muwahid,” tweeted that he was “Abu Sadiq Al-Ghazi”
and that he was “Amir Al Ghazi.”
18. Based on the facts and circumstances, a portion of which can be found wit
in this
Affidavit, Affiant believes Al-Ghazi was the user of Twitter profiles “Amir al Ghazi” and “Amir
* CHS#1 isa paid confidential informant, having worked with the FBI for three (3) years, All information provided
by CHS#1 to date has been deemed to be truthful and accurate, with no known- reliability issues. Additionally,
CCHS#1 has independently documented his/her communications with Al-Ghazi, some of which were subsequently
corroborated by the Search and Seizure Warrant served to Twitter, Inc. on February 13, 2015, Moreover, the
communication between CHS#1 and Al-Ghazi that occurred on September 27, 2014 was corroborated through the
usage of consensually monitored recording devices.Muwahid.” Thereafter, on February 13, 2015, Affiant obtained and served a Search Warrant on.
‘Twitter, Inc. requesting information regarding both Twitter profiles.*
19, On February 5,201, Al-Ghazi engaged in a conversation with CHS#2,° during
which he stated that he had a profile on a“US American message board.” On February 6, 2015,
Affiant conducted a passive review of publically available information on the website,
www.usmessageboard.com. AMfiant observed the existence of a profile, “amirmuwahid76,”
URL of wwwusmessageboard.com/members/amirmuwahid76,53232. Based upon content
observed, which was substantially similar to the above referenced Twitter profiles, Affiant
believed that this profile is utilized by Al-Ghazi.
20, On February 15, 2015, user “amirmuwahid76” responded to multiple messages
from CHS#1 on the US Message Board website, confirming that he was the owner of Twitter
profile “Amir Muwahid.” As such, Affiant has concluded that Al-Ghazi is the owner of this US
‘Message Board profile.
21. On February 20, 2015, CHS#1 and Al-Ghazi conducted a conversation within the
US Message Board website, In response to a question from CHS#1 regarding the best method to
continue their online communications, Al-Ghazi responded, “Google+.” Thereafter, CHS#1
* On February 13,2015, Affiant obtained a Federal Search Warrant to search Twitter accounts, “Amir Al Ghazi”
(username “ @amiralghazi76”; URL of https:/twitter com/amiralghazi76) and “Amir Muwahid” (username
S@MuwahidAmir"; URL of hitps:/twitter.com/MuwahidAmir). Said Warrant was signed by the Honorable Nancy
Vecchiareli, Magistrate Judge - United States District Court for the Northern District of Ohio. Affiant subsequently
served the Warrant on Twitter, Inc. on the same date.
» CHS#2 is a paid confidential informant, having worked with the FBI for three (3) years. All information provided
by CHS#2 to date has been deemed to be truthful and accurate, with no known reliability issues. CHS#2 does have
‘an extensive criminal history to include receiving stolen property, domestic violence, assault/kidnapping, burglary,
drug trafficking, weapons under a disability, and fraud related offenses that spans several years. Additionally,
CCHS#2 has received sentencing benefits/avoided other agency inquiries as the result of actions of Affiant and other
Cleveland FBL agents. This notwithstanding, the majority of information contained within this affidavit that resulted.
from the activities of CHS#2 has been corroborated through the usage of consensually monitored recording devices.
6located the Google account for Al-Ghazi, which is listed as “Amir Muwahid,” with a URL of
hutps://plus.google.com/ 106169538990487418520.
oe On February 21, 2015, CHS#1 and Google+ profile “Amir Muwahid” conducted
a conversation on Google, during which the user confirmed that he was the owner of US
Message Board profile “amirmuwahid76.” As such, Affiant has concluded that Al-Ghazi is the
owner of this Google+ profile. As of June 8, 2015, this profile had 214 followers, 505
individuals in his “circles,” and had been viewed on 61,841 occasions.
23. On March 2, 2015, Affiant received results from Twitter, Inc. in response to the
previously referenced Search Warrant. A review of the Internet Protocol (IP) login history for
profiles “Amir Al Ghazi” and “Amir Muwahid” revealed a common IP address of 184.56.50.237
on December 29, 2014, Moreover, for profile “Amir Al Ghazi,” the registrant provided a
telephone number of (440) 329-4001 (the telephone number previously provided to Affiant by
AL-Gh:
As such, Affiant has concluded that Al-Ghazi is the owner of both Twitter profiles
24, A further review of the results received from Twitter, Inc, revealed that profile
“Amir Al Ghazi” had 707 followers and was following an additional 1216 profiles, while profile
“Amir Muwahid” had 219 followers and was following an additional 858 profiles,
25. On April 2, 2015, Al-Ghazi directed CHS#1 to develop a profile within another
communication application to avoid detection from law enforcement.° Upon developing his/her
profile, CHS#1 observed that he/she was added to the contact list of user “abusadig.” CHS#1
subsequently confirmed that the profile was owned by Al-Ghazi
26. As of June 8, 2015, Al-Ghazi maintained a YouTube profile, “Amir Muwahid,”
with the corresponding URL of
§ An open source, online query of this communication application revealed it to be a mobile messaging application
for text, image and voice messages.https://www.youtube.com/channel/UCI9_y36AMumY VkMIAVEZC6Q. This profile is linked
to the above referenced Google + profile “Amit Muwahid” (see paragraph 22).
Statements of Allegiance, Affiliation with, and Desire to Act on Behalf of ISIL
27. During the period of July of 2014 through June 2015, Al-Ghazi has made
multiple statements indicating his allegiance to, affiliation with, and desire to act on behalf of
ISIL. Relevant statements include the following:
28. On June 18, 2014, Al-Ghazi pledged his allegiance to ISIL in a Facebook posting
on the internet. On June 16, 2014, Al-Ghazi posted a YouTube link to a video entitled, “Stand
up and pledge allegiance to Abu Bakr Al-Baghdadi,” who is the declared leader, or Caliph, of
ISIL. CHS#1 subsequently inquired via Facebook if Al-Ghazi was ready to make “bayah.” On
June 18, 2014, Al-Ghazi responded, stating: “Naam I’m ready to make bayah.” {The term
“bayah” translates to a “pledge of allegiance”; “Naam” translates to “Yes.”]
29, On September 10, 2014, CHS#2 and Al-Ghazi had a conversation, wherein they
discussed ISIL, CHS#2 specifically asked Al-Ghazi about recent news coverage of the
beheadings of U.S. Citizens. In response, Al-Ghazi stated, *...and you really wanna know what
I think:
support that... That’s our way of life... Yeah, I go for this...I’'m uh... do this.” Al-
Ghazi added that he took his belief’ so seriously, that if the Muslims in the United States were at
war with non-Muslims, he would cut off the head of his non-Muslim son if necessary.
30. During the same conversation, Al-Ghazi also stated that he was trying to order a
flag from England. Al-Ghazi added that if law enforcement were to discover the flag, he could
potentially be arrested, Based upon the totality of the information within this Affidavit, the
logical inference is that Al-Ghazi was referring to a black flag with white Arabie seript,
commonly utilized by terrorist organizations such as ISIL. Lastly, Al-Ghazi made statementsduring this conversation that were indicative of his belief that it is permissible to behead
Christians, Jews, and Atheists.
31. On September 18, 2014, CHS#2 and Al-Ghazi had another conversation regarding,
ISIL and the beheading of a British citizen, Al-Ghazi stated that ISIL beheaded this
dual
because Britain was in league with America, He then expounded, “...We tired of them fuckin’
with us...And when I say us...and you may seem like, damn,...you erazy...Allah says a Muslim
is like a body... Surely if I prick your finger, the whole body will feel it... Those brothers and
sisters in Iraq are my brothers and sisters.”
32. On September 23, 2014, using Twitter profile “Amir Al Ghazi,” Al-Ghazi
‘tweeted, “America is worried about IS recruiting, bayah has been given they’re too late,” “The
jammat setting the best example for all of us is fighting jihad fisabillah right now!,” and “We
have to fight them we are commanded by Allah to fight.” [The term “jammat” translates to “the
group or folks”; the term “fighting jihad fisabillah” translates to “fighting for God or sacrificing
for the sake of God.”]
33. On September 27, 2014, CHS#1 and Al-Ghazi had a conversation wherein he
expressed his support of ISIL and communicated his desire to conduct a terrorist attack in the
United States. Al-Ghazi referenced attacking a police station, but then stated this would only be
possible if he had another “100 brothers” like him. Al-Ghazi then stated that he was interested in
attacking the count
°s infrastructure, specifically referencing the derailment of a train as it
would make the United States “look twice in their own backyard.” Al-Ghazi emphasized that he
‘wasn’t interested in a “martyrdom operation,” stating that he “wanted to get away with it” and
that he wanted to do something that would keep him “out of the limelight.” Al-Ghazi added thathe was not “squeamish,” he had “no qualms with killing kuffar,” but his “intentions need to be
correct.” [The term “kuffar” translates to “non-believer or infidel.”]
34. On November 18, 2014, using Twitter profile “Amir Al Ghazi,” Al-Ghazi
had is our only option to establish the law of Allah azza wajjal everywhere,” and,
“Join the Islamic State If not represent the caliphate wherever You Are America to Australia.
We Are Commanded To Fight Where Are You muslims.” [The term “azza wajjal” translates to
“God almighty.”]
35. On December 30, 2014, using Twitter profile “Amir Muwahid,” Al-Ghazi
tweeted, “Islamic State is our caliphate like it or not.”
36. On January 7, 2015, using Twitter profile “Amir Muwahid,” Al-Ghazi tweeted,
inderstand Islamic state has no borders.”
37. On January 9, 2015, using Twitter profile “Amir Muwahid,” Al-Ghazi tweeted,
“Islamic state in america.”
38. On January 12, 2015, using Twitter profile “Amir Muwahid,” Al-Ghazi
responded to a tweet from a Ck
land area news station, which read, “Hackers take control of
US military’s Central Command Twitter account.” In response, Al-Ghazi tweeted “bagiyyah!”
The term “baqiyyah” has become a popular statement or “battle ery” with those who are
affiliated with ISIL. [This term literally translates to “the rest of” or “what is left.” Within the
context of this paragraph, the phrase likely means, “We are here to stay."]
CHS#1 attempted to continue this discussion throughout October of 2014, Al-Ghazi ultimately responded,
indicating that he had been approached by a “fed” and didn’t want to bring CHSi1 to the attention of law
enforcement. Affiant is not aware of Al-Ghazi having been approached by any member of law enforcement,
Additionally, Al-Ghazi indicated that he and CHS#1 should begin making dawah videos but cease communications.
Dawah videos are Islamie-themed videos frequently produced and/or viewed by jihadists,
1039. On February 2, 2015, while using US Message Board profile “amirmuwahid76,”
Al-Ghazi stated, “Baggiyah The Islamic state will remain, it has been established woe to you
kuffar who aim your arrows in the direction of the Muslims be it here in america or abroad.”
40. On February 4, 2015, while using US Message Board profile “amirmuwahid76,”
Al-Ghazi stated, “What you all don't get is that we sunni Muslims love Allah and his prophet
more than we love our mothers. We are all Islamic state citizens. ‘This isn’t some gang in the
desert you're fighting. This is ww3 the beginning has just begun.”
41, On February 5, 2015, while using US Message Board profile “amirmuwahid76,”
Al-Ghazi stated, “We are here everywhere the caliphate has been established the rise of Islam is.
‘upon you
42. On February 22, 2015, CHS#1 observed that, while using Google+ profile “Amir
Muwahid,” Al-Ghazi made the statement (which was shared privately*), “The time grows near
when the Mujahideen of the Americas will realize that We will be the tip of the sword of the
Khilafah.””
43. On March 4, 2015, CHS#1 and Al-Ghazi, while using Google+ profile “Amir
Muwahid,” conducted a private conversation within the Google website, During this
conversation, Al-Ghazi reaffirmed his pledge of allegiance, or “bayah,” to ISIL and provided
instructions to CHS#1 on how to correctly make his/her own pledge of allegiance. Specifically,
Al-Ghazi stated, “OK bayah means you will follow all orders by the caliph... Publically and in
* When a Google+ user privately shares content on his/her profile page, itis only visible to those users who are
accepted into his/her “circles” or “hangouts.”
The term “Khilafah” is synonymous with the term “Caliphate.” Those who are supportive of ISIL believe that the
group has re-established the “Khilafah” or “Caliphate,” and Abu Bakr Al-Baghdadi (the leader of ISIL) is the
rightful “Caliph” (or leader),
WWyour heart...That's what I did... Just say I give bayah to Ibrahim al husayni al qurayshi AL
baghdadi.”
44, On March 16, 2015, during a conversation with CHS#2, Al-Ghazi again
confirmed that he has pledged his allegiance, or “bayah,” to ISIL. Additionally, Al-Ghazi
indicated that his online statements were on behalf of ISIL, stating, “...there’s nobody speaking
for the State here...just me.”
45. On April 13, 2015, Affiant learned that Al-Ghazi was communicating with
another CHS online, Al-Ghazi and the CHS had been in intermittent communication via Twitter
and another communication application for approximately one (1) year. During these
conversations, CHS has identified himself/herself as being male, having resided in the United
States and United Kingdom, and being an ISIL soldier located in Mosul, Iraq. Hereinafter, this
individual will be referred to as CHS#3.""
46. During their initial communications, Al-Ghazi made statements to CHS#3
indicating his support of ISIL and his desire to relocate his family to the Islamic State.
Additionally, Al-Ghazi stated that he was inspired by the Boston bombing attack, inquired if
CHS#3 knew of any brothers that could assist with an attack/forming an attack strategy, and
stated that he needed weapons and the assistance of a bomb maker, Lastly, Al-Ghazi stated that
he was willing to die under the name and blessing of ISTL.
47. Onthe same date, CHS#3 and Al-Ghazi had a conversation, while using
communication application account “abusadig,” wherein Al-Ghazi made statements regarding
his interest in conducting an attack in the United States. Al-Ghazi specifically referenced
°° CHS#3 is a paid confidential informant. All information provided by CHS#3 to date has been deemed to be
‘truthful and accurate, with no known reliability issues,
12theoretical attack locations that focused on areas of infrastructure in the United States such as
“oil pipelines in the middle of the country,” “country roads with gutters,” and “police stations.”
48. On May 3, 2015, while using communication application profile “abusadig,” Al-
Ghazi conducted a conversation with CHS#3, who had represented to Al-Ghazi that he/she was
an ISIL soldier in Mosul, Iraq. Al-Ghazi initiated a discussion wherein he stated that he
preferred conducting jihad in the United States as opposed to migrating to the Middle East, Al-
Ghazi added that he lacked weapons to conduct an attack, but was in contact with other
individuals throughout the United States. In response, CHS#3 offered his/her assistance and
stated that “the e:
h” (e.g., Abu Bakr al-Baghdadi, the leader of ISIL) was aware of Al-Ghazi's
intentions, Al-Ghazi closed the conversation by stating, “Tell the bros that their brother Abu
Ghazi sends salaams [greetings},” and “Send my salaams.”
49. On May 7, 2015, during a conversation with CHS#2, Al-Ghazi discussed the
recent attempted terrorist attack that occurred in Garland, Texas on May 3, 2015. AL
hazi
stated that the western media was hesitant to attribute the attempted attack to ISIL. In response,
Al-Ghazi stated, “Remember something. If you are a Muslim and you have given bayah to Abu
Bakr al-Baghdadi, you are a citizen of the Islamic State. It doesn’t matter. You can be from the
North Pole. You feel me? You don’t have to be in Iraq or Syria to be a citizen of Dawla, to the
1
Islamic...
50. During this same conversation, Al-Ghavi discussed his concerns of being arrested
by federal law enforcement personnel, specifically stating, “The Feds ever knock on my door
they're probably never gonna let me out. Once they do the bar graph and all that, It’s either die
See paragraph 9, wherein ISIL. has been alternatively described as “Dawla,” or iterations thereof, by the Secretary
of Statein jail or die right now.” Al-Ghazi further indicated that he didn’t intend to return to prison and
would instead engage law enforcement, specifically stating, “I’m not trying to spend the rest of
my life in that mother fucker. Especially when if I kill one of these mother fuckers, I go to
heaven,”
31. On May 29, 2015, during a conversation with CHS#2, Al-Ghazi discussed his
wish to die on the battlefield. Al-Ghazi specifically stated, “...but real men die on the
battlefield. I don’t want to die in a cell. I don't want to die surrounded by my children in my
bed. I want to die on the battlefield. I want to die fighting. You know what | mean? 1
mean...if... want to die [inaudible]...coming at me. I want them to have to put me down. The
best warriors, and when I say warriors, I mean those to achieve the highest rank in paradise.
nt
‘They die fighting on the battlefield, you know what I mean? This is what God says...
52. On June 4, 2015, CHS#I and Al-Ghazi had conversations within Google* and
another communication application. For this conversation, CHS#1 utilized a newly created
Within this paragraph, Al-Ghazi referenced “the bar graph and all that” when discussing his concerns of being
arrested by federal law enforcement personnel as a result of his online activities. Affiant believes that Al-Ghazi is,
likely referring tothe discovery by law enforcement of his online activities or associates.
"In addition to Al-Ghazi’s statements regarding his intentions to engage law enforcement if arrested, he has also
lized Twitter to encourage other Muslims in the United States to take similar action, On April 1, 2015, while
using Twitter profile “Abu Sadiq al Ghazi,” Al-Ghazi tweeted, “Vou fear the FBI, Police? Fear Allah and take the
safety off..Allahu AKbar [God is the greatest!!!" Additionally, Al-Ghazi tweeted, “Ihkwan [likely meaning
“brothers"] if you are in america its time. We are missing out on the blessings of martyrdom, Will you will wait til
‘they're knocking at the door?” Based upon the context of AI-Ghazi’s tweets, Affiant assesses that Al-Ghazi’s
statement to “take the safety off” isa reference to disengaging the safety on a weapon for the purpose of firing upon
FBI agents andor other law enforeement officers.
‘Again, on April 8, 2015, while using Twiter profile “Abu Ahmed al Amrik.” Al-Ghazi tweeted, “When they knock
‘on the door...what will you do? will you go for jannah? Or accept the box they'll stick you in.” [The term “jannah”
translates to “paradise."] Based upon the context of Al-Ghazi's tweets and statements made to FBI CHSs, Afiant
assesses that Al-Ghazi’s question, “When they knock on the door...wat will you do? will you go for jannah?,” is a
reference to killing law enforcement officers that approach the residences of ISIL members and/or sympathizers.
Aifiant further assesses that AI-Ghazi's statements are meant to equate the criminal act of killing a law enforcement
officer with an act of martyrdom, which he believes would be rewarded with entry to “jannah” or “paradise.”
While making this statement, Al-Ghazi appeared to raise his arms in front of his body, possibly to illustrate the act,
of discharging a fireerm.
14persona indicating that he/she is a member of ISIL and is located within the Middle East (Al-
Ghazi did not know this persona belonged to the same person he had previously communicated
with), During their conversation within communication application, while using profile
“abusadiq,” Al-Ghazi reaftirmed his allegiance to ISIL and/or Abu Bakr al-Baghdadi,
Specifically, Al-Ghazi stated, “I abu ghazi al amriki give bayah to amir ul munineen Ibrahim al
awwad Al husseni, al qureshi In good times and bad.”"*
53. During this same conversation, Al-Ghazi made statements indicating that he was
trying to recruit individuals in the United States to join ISIL. He specifically stated that he was
“trying to put a squad of believers together” and he believed the United States “can be the land of
jihad.” Al-Ghazi also made references indicating an
terest in conducting terrorist attacks in the
United States, stating, “Have to do jihad here,” “IfI had 10 brothers from Dawla and someone
who knows how to make explosive,” and “an istihadi op is no different than when the prophet
(saw) in the hadith told the man to accept islam first before he fought then grabbed two swords
and was martyred.”"®
54, On June 8, 2015, while using communication application profile “abusadiq,” Al-
Ghazi conducted a conversation with CHS#3, who had represented to Al-Ghazi that he/she was
an ISIL soldier in Mosul, Iraq. During this conversation, Al-Ghazi made multiple statements
indicating his continued allegiance to ISIL. and his desire to act on their behalf. Spe
ically, Al-
Ghazi demonstrated his allegiance to ISIL and/or its leadership with the statements, “I love
shekh adnani (referring to the official press officer for ISIL),” “You ever bump into him tell him
"= An open souree, online query of the name “amir ul munineen Ibrahim al awwad Al husseni, al qureshi” revealed
this to be an alias for Abu Bakr al-Baghdadi, the leader of ISIL.
Affiant assesses that Al-Ghazis usage of the term “istihadi” is a misspelled reference to the term “ishtihadi,”
which translates to “suicide” or “martyrdom.” In this context, Al-Ghazi is likely referring to suicide or martyrdom
‘operations.
15abu ghazi loves him lol,” and “I love my caliph all my brothers.” Additionally, Al-Ghazi stated,
“He say we have lions whose food is blood and carnage (note similar statements made in
paragraph 72),” “Forgive me but the savage in me is itching for i,” and “Everyday they] feel
safe...that will change.”
55. During this,
sme conversation, Al-Ghazi also indicated his interest in forming a
group of ISIL supporters in the United States. Specifically, Al-Ghazi stated, “Under the guise
some outing bros could connect
st to put those in proximity to reach other together” and “Lone
wolves crave a pack...Even a small one.” Al-Ghazi then attempted to illustrate the importance
of forming a group with his statement (referencing the failed terrorist attack in Garland, Texas),
“If the Texas bros had maybe 6 more with them it may have been a different story.”
‘Additionally, in response to questioning from CHS#3, Al-Ghazi stated that he had been planning
(without providing further information as to what), specifically stating, “Yes Alhamdulillah
[Thanks be to God] I have too put things in place for my fam safety ete.” CHS#3 followed by
inquiring if Al-Ghazi was “ready in the event that they interfere akhi?”"” Al-Ghazi responded
with the statement, “I gotta 45 if that’s what u mean lol.” Lastly, Al-Ghazi indicated his
consideration of home robberies for the purpose of obtaining weapons with his inquires, “Can |
rob house to get what I need? kuffar houses...Like they’re wealth is lawful right?”
‘Statements/Actions Indicating an Intention to Make Islamic Propaganda and Recruiting
Videos on Behalf of ISIL
56. On February 12, 2015, Al-Ghazi informed CHS#2 that he intended to purchase an
AK-47 assault rifle for the purpose of making propaganda videos in his residence. Al-Ghazi
further stated that he was already in possession of a ski-mask and may want a “green screen” in
" CHS#3 was referring to the possibility of Al-Ghazi being discovered by law enforcement when heishe asked the
«question, “Are you ready in the event that they interfere akhi [brother]?”
16the background when making the videos. Also, previously on February 5, 2015, Al-Ghazi
informed CHS#2 that he had purchased a machete. Affiant notes there is an abundance of open
source references that reveal machetes, and other types of knives, have been used by ISIL when
beheading individuals and/or when making propaganda videos.
57. On March 1, 2015, CHS#1 and Al-Ghazi, while using Google+ profile “Amir
‘Muwahid,” conducted a private conversation on the Google* website. During this conversation,
Al-Ghazi stated, “I wanna make dawa videos like the bros
the uk...Lol...Learn how to make
dawa vids... making vids you speaking hagq [truth]...lts YouTube you say what you
wwant,...Then get a following... Which leads to our squad. ..eel me?”
$8. On March 3, 2015, CHS#2 and Al-Ghazi had a conversation, where in addition to
discussing his interest in purchasing an AK-47, he reiterated his intentions to make videos. Al-
Ghazi stated that he intended to use the AK-47, along with a black flag as props, when making
videos. Al-Ghazi indicated that both of his parents are aware of his intentions, with his mother
being particularly unsupportive of him making videos. In response to her disagreement, Al-
Ghazi stated that he told her that she obviously hasn’t seen “any jihadi videos.’
Al-Ghazi
revealed that while he does not intend to make “terrorist videos”'*
and he does not intend to “kill
anybody,” he does view his videos as a form of jihad. He went on to describe himself as
someone who wants to fight jihad, but is unable to do so, and making dawah videos can be
considered as the next highest form according to Islam,
59. On March 4, 2015, CHS#1 and Al-Ghazi, while using Google+ profile “Amir
Muwahid,” conducted a private conversation on the Google+ website, During this conversation,
°* Al-Ghazi made this statement while discussing a video observed by CHS#2 that purportedly showed an individual
being stabbed by multiple other individuals speaking Arabic. A-Giazi stated that he did not intend to make those
types of videos.
7Al-Ghazi again stated that he intended to make videos “in the future” and instructed CHS#1 to
have “patience.”
60. On March 10, 2015, CHS#1 and Al-Ghazi, while using Google profile “Amir
‘Muwahid,” conducted a private conversation on the Googlet website. During this conversation,
Al-Ghazi reiterated his interest in making propaganda videos with the following statements, “As
‘muslims we must establish a state... First step is informing the people of their deen [faith]
...Starting with us...So that's why we learn Arabic to read for ourselves. ..Sheihks are human
jihad is obligatory so if they say no jihad but you know you must you listen to Allah not sheikh
coconut feel me... Now forms of jihad differ...Dawah vids, inciting the believers to fight,
wanting to go but forced to stay will also get you the blessings of jihad...So we getting the
blessings just by wanting too but cuz we can't we have to stay put...S0 you prolly never have to
Kill anyone... And we don't want to kill or have war we just want to be muslims correct?”
61. ‘On March 24, 2015, CHS#1 and Al-Ghazi, using Google+ profile “Amir
Muwahid,” conducted a private conversation on the Google* website. During this conversation,
Al-Ghazi stated that he and other online supporters were changing their profile images to those
commonly associated with ISIL. Al-Ghazi also stated that “the bros in Dawla said for us to keep
up jihad on the internet,” “we squading up on line lol,” and “Ls, released a vid.” In response to
comments from CHS#1, Al-Ghazi further stated his online “squad” would be called “Jund UL
Khilafah” or “Jund Ul dawla,” which he translated to mean “Soldiers of the State.” Al-Ghazi
clarified that his online activities constitute a form of “jihad,” stating, “This is real the
Mujahideen see a difference on the ground...,” “Like I say this is real...Just as real as if you had
a chopper,” and “Our posts reach to btos who don’t know."
» In Affiant’s experience, “chopper,” is a common slang term for an AK-47 or similarly styled assault rifle, Afiant
also believes that “btos” in this context is most likely a typo, and that Al-Ghazi meant “bros.
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