nationalsecuritylaw United States v. Roble (D. Minn. Aug. 24, 2016) (ISIL material support charges)

August 25, 2016

The complaint and arrest affidavit are attached:

Numerous Alleged Co-Conspirators Previously Convicted at Trial and Pleaded Guilty in Minnesota

WASHINGTON –Mohamed Amiin Ali Roble, 20, formerly of Minneapolis, was charged today by criminal complaint with providing and conspiring to provide material support to the Islamic State of Iraq and the Levant (ISIL).

The charges were announced by Assistant Attorney General for National Security John P. Carlin, U.S. Attorney Andrew M. Luger of the District of Minnesota and Special Agent in Charge Richard T. Thornton of the FBI’s Minneapolis Division.

According to the complaint and documents filed in court, on Oct. 4, 2014, Roble flew to China with a family member. In November 2014, four of Roble’s associates in Minnesota attempted to travel from Minnesota to Syria to join ISIL, via JFK International Airport in New York. The four defendants were stopped by federal law enforcement agents at JFK and were prevented from flying from New York to various destinations in Europe. Also in November 2014, Roble bought airplane tickets and flew to Istanbul, but returned to China shortly thereafter.

On Dec. 27, 2014, Roble again traveled to Istanbul and, according to the complaint, subsequently made his way into Syria and joined ISIL.

A criminal complaint is merely an allegation, and the defendant is presumed innocent unless and until proven guilty beyond a reasonable doubt in a court of law.

This case is the result of an investigation conducted by members of the FBI-led Joint Terrorism Task Force (JTTF). The Minnesota JTTF includes members from the U.S. Marshals Service; Bloomington, Minnesota, Police Department; Ramsey County, Minnesota, Sheriff’s Office; Hennepin County, Minnesota, Sheriff’s Office, Federal Air Marshals Service; Customs and Border Patrol; Department of Homeland Security; Minneapolis Police Department; the Airport Police; Internal Revenue Service-Criminal Investigation; and the FBI. The National Security Division’s Counterterrorism Section and the U.S. Attorney’s Office of the District of Minnesota are prosecuting the case.

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Roble Complaint Affidavit signed.pdf


nationalsecuritylaw United States v. Young (N.D. Miss. Aug. 11, 2016) (12 year sentence in ISIL material support case)

August 14, 2016

WASHINGTON – Jaelyn Delshaun Young, 20, of Starkville, Mississippi, was sentenced today to serve 144 months in prison for conspiring to provide material support to the Islamic State of Iraq and the Levant (ISIL), a designated foreign terrorist organization.

Assistant Attorney General for National Security John P. Carlin, U.S. Attorney Felicia C. Adams of the Northern District of Mississippi and Special Agent in Charge Donald Alway of the FBI’s Jackson, Mississippi Division made the announcement.

On March 30, Young pleaded guilty before Chief U.S. District Judge Sharion Aycock of the Northern District of Mississippi, who imposed today’s sentence and ordered Young to serve a 15 year term of supervised release following her imprisonment.

Young pleaded guilty to conspiring with Muhammad Oda Dakhlalla, 23, also of Starkville, to provide material support to ISIL. Dakhlalla pleaded guilty to the same charge on March 13 and will be sentenced on Aug. 24.

The investigation was conducted by the FBI’s Jackson Division Joint Terrorism Task Force and the Washington Field Office. The case was prosecuted by Assistant U.S. Attorneys Clay Joyner and Bob Norman of the Northern District of Mississippi and Trial Attorney Rebecca Magnone of the National Security Division’s Counterterrorism Section.

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nationalsecuritylaw United States v. Lutchman (W.D.N.Y. Aug. 11, 2016) (guilty plea in ISIL material support case)

August 14, 2016

WASHINGTON – Emanuel L. Lutchman, 26, of Rochester, New York, pleaded guilty today to conspiracy to provide material support to the Islamic State of Iraq and the Levant (ISIL).

Assistant Attorney General for National Security John P. Carlin, U.S. Attorney William J. Hochul Jr. of the Western District of New York and Special Agent in Charge Adam S. Cohen of the FBI’s Buffalo, New York Division made the announcement.

Lutchman pleaded guilty before U.S. District Judge Frank P. Geraci Jr. of the Western District of New York. He has been detained in federal custody since his arrest by members of the FBI’s Rochester Joint Terrorism Task Force (JTTF) on Dec. 30, 2015. Sentencing is scheduled for Nov. 15, 2016, before Judge Geraci, where Lutchman faces a statutory maximum sentence of 20 years in prison, a $250,000 fine and a lifetime term of supervised release. The maximum statutory sentence is prescribed by Congress and is provided here for informational purposes. The sentencing of the defendant will be determined by the court based on the advisory Sentencing Guidelines and other statutory factors.

“Emanuel Lutchman admitted to conspiring with an ISIL member located overseas and planned to kill innocent civilians on U.S. soil in the name of the terrorist organization,” said Assistant Attorney General Carlin. “Countering terrorist threats remains the highest priority of the National Security Division, and we will continue our efforts to bring to justice those who conspire to provide material support to foreign terrorist organizations. I want to thank the many agents, analysts and prosecutors who contributed to the disruption of this deadly plot.”

“Residents of this community can now sleep better knowing that a person who wanted to kill in the name of an infamous terrorist group – right on the streets of our city – will no longer be a threat,” said U.S. Attorney Hochul.

As part of his guilty plea, Lutchman admitted that he conspired with an individual known as Abu Issa Al-Amriki, a now-deceased ISIL member in Syria, and planned to conduct an attack against civilians using knives and a machete on New Year’s Eve in 2015. Lutchman admitted that he intended to conduct an attack that could be claimed by ISIL and that could also help him gain membership into ISIL when he thereafter traveled overseas to join the terrorist organization.

According to court documents, Lutchman posted on social media expressions of support for ISIL, including images, videos and documents relating to ISIL and violent jihad. Lutchman also downloaded and watched terrorism-related videos, including videos relating to ISIL and the now-deceased terrorist Anwar al-Awlaki. The defendant also maintained a digital collection of documents relating to terrorism and terrorist groups, including all of the issues of Inspire magazine and other documents designed to provide guidance to individuals seeking to travel overseas to engage in violent jihad or engage in “lone wolf” terrorist attacks in the United States and elsewhere.

In December 2015, Lutchman obtained an online document written by an ISIL member in Syria, in which the ISIL member provided guidance to ISIL supporters who were seeking to travel overseas to join ISIL, including advice about preparation for violent jihad; the use of security measures while traveling to avoid apprehension by law enforcement authorities; instructions for killing non-believers and infidels, or “kuffar;” and contact information for the ISIL member and Al-Amriki.

According to the plea agreement, on Dec. 25, 2015, Lutchman initiated online contact with Al-Amriki, who identified himself as an ISIL member in Syria. In a series of subsequent communications, Al-Amriki told Lutchman to plan an attack on New Year’s Eve and kill a number of kuffar. Al-Amriki advised the defendant to write something before the attack and give it to the ISIL member so that after the attack the ISIL member could post it online to announce Lutchman’s allegiance to ISIL. Al-Amriki told Lutchman that whatever Lutchman sends to ISIL, they would keep it until the attack was complete and then post it and publicize the attack on the Internet. Al-Amriki emphasized that Lutchman is “behind enemy lines,” that Lutchman was the closest person to their most hated enemy and that Lutchman has the chance to do things that ISIL wishes it could do. Lutchman ultimately told Al-Amriki that he has a couple of “brothers” that want to make hijra and plan an attack. Al-Amriki encouraged Lutchman to complete an attack and stated that, if the Syrian borders open and the attack does not succeed, he would help Lutchman and his “brothers” make hijra. Al-Amriki told Lutchman to show ISIL how serious he is, stating, “New years is here soon. Do operations and kill some kuffar.” Lutchman told Al-Amriki that he hates it in the United States, that he wants to join the ranks of ISIL and that he is ready to “give everything up” to be in Syria with ISIL. Al-Amriki told Lutchman, for the time being, to do what he can in the United States.

In late December 2015, Lutchman was communicating with other individuals (referred to as Individuals A, B, and C in the plea agreement) who, unbeknownst to Lutchman, were cooperating with the FBI. In these communications, Lutchman made statements expressing his strong support of ISIL and his desire to travel overseas to join ISIL, and also discussed in detail his online communications with Al-Amriki and the ISIL member. In subsequent communications, Lutchman referred at various times to Individuals A, B and C as “brothers” who would be involved in the New Year’s Eve attack.

Lutchman admitted that on Dec. 27, 2015, he and Al-Amriki discussed potential targets, and Al-Amriki told Lutchman to find the most populated area and kill as many people as possible and reiterated that, after the operation was done, he would vouch for Lutchman and the other participants in the attack and he would start sending “brothers” to ISIL in Libya, to which Lutchman agreed.

Lutchman admitted that he met with Individual C on Dec. 28, 2015, and indicated that he wanted to target a club or bar and proposed that they kidnap a couple of people and kill them. Lutchman stated that they would have to wear masks during the operation in order to avoid getting caught by law enforcement authorities.

Lutchman admitted that on the evening of Dec. 29, 2015, Lutchman and Individual C went to a store in Rochester to purchase weapons and supplies for the attack, including two black ski masks, two knives, a machete, zip-ties, duct tape, ammonia and latex gloves. Lutchman told Individual C that “the operation is a go,” and noted that any victims would have to be killed. The defendant and Individual C discussed making a video before the operation, at Al-Amriki’s direction, in which they would explain their rationale for the attack and swear bayah (allegiance) to the leader of ISIL, Abu Bakr al-Baghdadi. Lutchman said that he planned to release the video after the completion of the attack.

Lutchman admitted that on Dec. 30, 2015, he made a video pledging allegiance to ISIL and al-Baghdadi, and stated that ISIL was going to establish the caliphate in the land of Islam. In reference to the planned New Year’s Eve attack, Lutchman stated, “the blood that you spill of the Muslim overseas we gonna spill the blood of the kuffar,” and asked Allah to “make this a victory.” In the video, Lutchman covered all of his face except for his eyes and he held one index finger in the air, which is a sign commonly used by ISIL members and supporters. Immediately thereafter, law enforcement agents arrested Lutchman and recovered the items purchased by Lutchman and Individual C the previous day from Lutchman’s residence.

The investigation was conducted by the FBI’s Rochester JTTF. The case is being prosecuted by Assistant U.S. Attorney Brett A. Harvey of the Western District of New York, with the assistance of Trial Attorney Larry Schneider of the National Security Division’s Counterterrorism Section.

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nationalsecuritylaw United States v. Hendricks (N.D. Ohio Aug. 4, 2016) (another ISIL material support indictment)

August 4, 2016

Press release below, arrest affidavit attached:

WASHINGTON—A Charlotte, North Carolina, man was arrested this morning on a federal complaint charging him with conspiring to provide material support to the Islamic State of Iraq and Levant (ISIL), a designated foreign terrorist organization.

Erick Jamal Hendricks, 35, tried to recruit people to train together and conduct terrorist attacks in the United States on behalf of ISIL, according to a criminal complaint unsealed today in U.S. District Court in the Northern District of Ohio.

The arrest was announced by Assistant Attorney General for National Security John P. Carlin, U.S. Attorney Carole S. Rendon of the Northern District of Ohio and Special Agent in Charge Stephen D. Anthony of the FBI’s Cleveland Office.

According to the complaint, in June 2015, an individual (CW-1) was arrested in the Northern District of Ohio after attempting to purchase an AK-47 assault rifle and ammunition from an undercover law enforcement officer. CW-1 had pledged allegiance to ISIL in social media and made statements expressing interest in conducting attacks in the United States.

Hendricks had contacted CW-1 over social media to recruit him in the spring of 2015, according to the complaint. Hendricks allegedly told CW-1 that he “needed people” and wanted to meet in person; that there were several “brothers” located in Texas and Mexico; that he was attempting to “get brothers to meet face to face;” and that he wanted “to get brothers to train together.”

According to the complaint, CW-1 said that Hendricks tested his religious knowledge and commitment, inquiring about his willingness to commit “jihad,” to die as a “martyr” and his desire to enter “jannah” (paradise). CW-1 understood these statements to mean that Hendricks was recruiting people to train together for the purpose of conducting a terrorist attack in the U.S. and to see if CW-1 was suitable for recruitment, according to the allegations. CW-1 allegedly believed that Hendricks and the “brothers in Texas and Mexico” may have been responsible for a thwarted terrorist attack in Garland, Texas, on May 3, 2015, and therefore CW-1 decided to stay away from social media for a period following the attack to minimize detection by law enforcement.

Hendricks also allegedly communicated over social media with several other people, including an undercover FBI employee (UCE-1). According to the complaint, on April 16, 2015, Hendricks instructed UCE-1 to download the document “GPS for the Ghuraba in the U.S.”, which included a section entitled “Final Advice” which advocated that “brothers and sisters” should not allow themselves to go to jail. This section also allegedly encouraged Muslims to die as a “Shaheed” (martyr), to “Boobie trap your homes,” to “lay in wait for them” and to “never leave your home without your AK-47 or M16.” According to the complaint, Hendricks also directed UCE-1 to communicate online with other people and stated “It’s hard to sift through brothers;” “Allah chooses only the few;” and “Everyday I do this day in and day out.”

Hendricks allegedly told another person that his goal was to create a sleeper cell to be trained and housed at a secure compound that would conduct attacks in the United States. He mentioned that potential targets included military members whose information had been released by ISIL and the woman who organized the “Draw Prophet Mohammad contest,” and he claimed to have 10 members signed up for his group, according to allegations in the complaint.

On April 23, 2015, Hendricks allegedly used social media to contact Elton Simpson, who, along with Nadir Hamid Soofi, was inspired by ISIL and launched the attack on the “First Annual Muhammad Art Exhibit and Contest” in Garland. Simpson and Soofi opened fire, wounding a security guard, before Garland police returned fire and killed both Simpson and Soofi. According to the complaint, Hendricks also connected UCE-1 with Simpson via social media; communicated with UCE-1 about the contest in Garland; and directed UCE-1 to go to the contest. Hendricks allegedly said: “If you see that pig (meaning the organizer of the contest) make your ‘voice’ heard against her.” According to the complaint, he also asked UCE-1 a series of questions related to security at the event, including: “How big is the gathering?” “How many ppl?” “How many police/agents?” “Do you see feds there?’ “Do you see snipers?” and “How many media?” Shortly thereafter, Simpson and Soofi committed the attack on the cartoon drawing contest.

A criminal complaint is merely an allegation, and the defendant is presumed innocent unless and until proven guilty beyond a reasonable doubt in a court of law.

If convicted, Hendricks faces a statutory maximum sentence of 15 years in prison. The maximum statutory sentence is prescribed by Congress and is provided here for informational purposes. If convicted of any offense, the sentencing of the defendant will be determined by the court based on the advisory Sentencing Guidelines and other statutory factors.

This case was investigated by the FBI’s offices in Cleveland; Columbia, South Carolina; Baltimore; and Charlotte, North Carolina, with assistance from the Justice Department’s National Security Division and the U.S. Attorney’s Offices in the Northern District of Ohio, District of Maryland, District of South Carolina and the Western District of North Carolina.

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Hendricks Affidavit.pdf


nationalsecuritylaw United States v. Young (E.D. Va. Aug. 3, 2016) (ISIL material support)

August 3, 2016

Press release below, complaint and affidavit attached…

WASHINGTON – Nicholas Young, 36, of Fairfax, Virginia, was arrested today on charges of attempting to provide material support to the Islamic State of Iraq and the Levant (ISIL), a designated foreign terrorist organization. Young is employed by the Metro Transit Police Department (MTPD) as a law enforcement officer.

Assistant Attorney General for National Security John P. Carlin, U.S. Attorney Dana J. Boente of the Eastern District of Virginia and Assistant Director in Charge Paul M. Abbate of the FBI’s Washington Field Office made the announcement. Young’s initial appearance is scheduled for 2:00 p.m. before U.S. Magistrate Judge Theresa C. Buchanan of the Eastern District of Virginia.

According to the affidavit filed in support of the criminal complaint, Young has been employed as an MTPD officer since 2003. Law enforcement first interviewed Young in September 2010 in connection with his acquaintance, Zachary Chesser, who had been arrested and subsequently pleaded guilty to attempting to provide material support to a designated foreign terrorist organization. Over the next several years, Young allegedly had numerous interactions with undercover law enforcement personnel and an FBI confidential human source (CHS) regarding his knowledge of and interest in terrorism-related activity. Many of these interactions were recorded. Law enforcement also interviewed Young’s family and co-workers. In 2011, Young met with an undercover law enforcement officer, and several of these meetings included another of Young’s acquaintances, Amine El Khalifi, who later pleaded guilty to charges relating to his plan to conduct a suicide bombing at the U.S. Capitol Building in 2012.

According to the affidavit filed in support of the criminal complaint, in 2011, Young traveled to Libya once and attempted to travel there a second time. Young told FBI agents that he had been with rebels attempting to overthrow the Muammar Qaddafi regime. Baggage searches revealed that Young traveled with body armor, a kevlar helmet and several other military-style items, according to the allegations.

According to the affidavit filed in support of the criminal complaint, on about 20 separate occasions in 2014, Young met with the CHS, who posed as a U.S. military reservist of Middle Eastern descent who wanted to travel overseas to join ISIL. During these conversations, Young allegedly advised the CHS on how to evade law enforcement detection by utilizing specific travel methods and advised the CHS to watch out for informants and not discuss his plans with others.

According to the affidavit filed in support of the criminal complaint, also in 2014, the CHS led Young to believe that he had successfully left the United States and joined ISIL. In reality, the CHS had no further contact with Young. All further communications between Young and the CHS’s email account were actually communications between Young and FBI undercover personnel posing as the CHS. In June 2015, Young emailed the CHS asking for advice from the CHS’s commanders on how to send money to ISIL. Young said, “[u]nfortunately I have enough flags on my name that I can’t even buy a plane ticket without little alerts ending up in someone’s hands, so I imagine banking transactions are automatically monitored and will flag depending on what is going on.”

In December 2015, the FBI interviewed Young, ostensibly in connection with an investigation into the whereabouts of the CHS, according to the affidavit filed in support of the criminal complaint. Young allegedly said that the CHS had left the United States to go on a vacation tour in Turkey approximately one year ago. In addition, according to the allegations in the complaint, Young said that he knew of no one in the United States or overseas who helped the CHS cross the Turkish border into Syria.

On July 18, 2016, Young allegedly communicated with a person who he believed to be the CHS regarding purchasing gift cards for mobile-messaging accounts that ISIL purportedly uses in recruiting others to join the terrorist organization. According to the affidavit filed in support of the criminal complaint, on July 28, 2016, Young sent 22 gift card codes to the FBI undercover officer posing as the CHS with a message that stated: “Respond to verify receipt . . . may not answer depending on when as this device will be destroyed after all are sent to prevent the data being possibly seen on this end in the case of something unfortunate.” The codes were ultimately redeemed by the FBI for $245, according to court documents.

A criminal complaint is merely an allegation, and the defendant is presumed innocent unless and until proven guilty beyond a reasonable doubt in a court of law.

If convicted, Young faces a statutory maximum sentence of 20 years in prison. The maximum statutory sentence is prescribed by Congress and is provided here for informational purposes. If convicted of any offense, the sentencing of the defendant will be determined by the court based on the advisory Sentencing Guidelines and other statutory factors.

The MTPD initiated this investigation and continues to work collaboratively with the FBI Washington Field Office’s Joint Terrorism Task Force on the case. The case is being prosecuted by Assistant U.S. Attorneys Gordon D. Kromberg and John T. Gibbs of the Eastern District of Virginia and Trial Attorney David P. Cora of the National Security Division.

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Young Complaint and Affidavit.pdf


nationalsecuritylaw United States v. Cornell (S.D. Ohio Aug. 1, 2016) (guilty plea in plot to attack State of the Union)

August 3, 2016

Press release below:

WASHINGTON – Christopher Lee Cornell, 22, of Green Township, Ohio, pleaded guilty today to one count of attempting to kill government employees, one count of possession of a firearm in furtherance of a crime of violence and one count of attempting to provide material support to a designated foreign terrorist organization.

The plea was announced by Assistant Attorney General for National Security John P. Carlin, Acting U.S. Attorney Benjamin C. Glassman of the Southern District of Ohio and Special Agent in Charge Angela L. Byers of the FBI’s Cincinnati Division. Cornell pleaded guilty before Senior U.S. District Judge Sandra Beckwith of the Southern District of Ohio.

Cornell was originally charged by an indictment returned by a federal grand jury on Jan. 21, 2015. On May 7, 2015, Cornell was additionally charged by superseding indictment with attempting to provide material support to a designated foreign terrorist organization.

According to the plea agreement, from on or about August 2014 through January 2015, Cornell plotted, planned and attempted to travel to Washington, D.C., in order to attack the U.S. Capitol during the State of the Union Address on January 20, 2015.

Cornell admitted that he conducted online research of weapons, the construction of bombs, the U.S. Capitol and other potential targets in the Washington, D.C., area. Cornell intended to kill officers and employees of the United States, and possessed two semi-automatic rifles and approximately 600 rounds of ammunition, according to the plea agreement.

The defendant admitted that his planned attack on the U.S. Capitol was an attempt to provide material support and resources – both personnel and services – to the Islamic State of Iraq and the Levant (ISIL).

The material support count carries a potential maximum sentence of 15 years in prison. Attempted murder of government employees and officials is a crime punishable by up to 20 years in prison. Possession of a firearm in furtherance of an attempted crime of violence is a crime punishable by a mandatory sentence of five years in prison.

Cornell was arrested on Jan. 14, 2015, by the FBI’s Joint Terrorism Task Force (JTTF). After his arrest, he posted statements online that included a call for others to join him in violent jihad against the United States and its citizens on behalf of ISIL, according to his admissions in the plea agreement.

The JTTF is made up of officers and agents from the Cincinnati Police Department; Colerain, Ohio, Police Department; Dayton, Ohio, Police Department; Ohio State Highway Patrol; University of Cincinnati Police Department; U.S. Air Force Office of Special Investigations; FBI; U.S. Immigrations and Customs Enforcement; U.S. Internal Revenue Service; U.S. Secret Service; U.S. Postal Inspection Service; West Chester, Ohio, Police Department; and Xenia, Ohio, Police Department.

Assistant Attorney General Carlin and Acting U.S. Attorney Glassman commended the JTTF for its investigation of this case. The case is being prosecuted by Trial Attorney Michael Dittoe of the National Security Division’s Counterterrorism Section and Assistant U.S. Attorney Tim Mangan of the Southern District of Ohio.

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nationalsecuritylaw United States v. Hubbard (S.D. Fla. July 22, 2016) (charges in ISIL material support case)

July 22, 2016

See the attached complaint. Press release details below:

WASHINGTON – Three Palm Beach County, Florida, residents were charged with conspiring and attempting to support the Islamic State of Iraq and the Levant (ISIL), a designated foreign terrorist organization.

Assistant Attorney General for National Security John P. Carlin, U.S. Attorney Wifredo A. Ferrer of the Southern District of Florida, Special Agent in Charge George L. Piro of the FBI’s Miami Field Office and members of the South Florida Joint Terrorism Task Force (JTTF) made the announcement.

Gregory Hubbard, aka Jibreel, 52, of West Palm Beach, Florida; Darren Arness Jackson, aka Daoud, 50, also of West Palm Beach; and Dayne Atani Christian, aka Shakur, 31, of Lake Park, Florida, were charged by a criminal complaint with knowingly conspiring and attempting to provide material support and resources to ISIL. Christian was also charged with being a felon in possession of a firearm. The detention hearing will take place on July 27, 2016, and the defendants will be arraigned on Aug. 5, 2016.

“According to the complaint, these defendants conspired and attempted to provide material support to ISIL and one of the defendants was arrested attempting to travel overseas to join and fight for the deadly terrorist organization,” said Assistant Attorney General Carlin. “The National Security Division’s highest priority is countering terrorist threats, and we will continue to work to stem the flow of foreign fighters abroad and bring to justice those who conspire and attempt to provide material support to designated foreign terrorist organizations.”

“Individuals seeking to travel and take up arms with ISIL pose a threat to the United States and humanity across the globe,” said U.S. Attorney Ferrer. “The U.S. Attorney’s Office, the FBI and the Joint Terrorism Task Force continue to work proactively in order to stifle and disrupt any potential danger posed by the terrorist organizations and their supporters.”

“Terrorism-related arrests such as this serve to remind us of the importance of being vigilant,” said Special Agent in Charge Piro. “When you see something that doesn’t seem right, report it to law enforcement. Fighting terrorism is the FBI’s number one priority. Any information that can put us on the trail of individuals intent on terrorist acts is valuable.”

According to the allegations contained in the complaint, Hubbard expressed support for ISIL and told an FBI confidential human source (CHS) that he wanted to travel to Syria and join ISIL for the purpose of engaging in violent jihad. Hubbard introduced the CHS to Christian and Jackson, both of whom provided weapons and firearms instruction to Hubbard and the CHS, whom they understood were preparing to travel overseas to join and fight for ISIL.

The complaint further alleges that Jackson and Christian also expressed a desire to join ISIL. Hubbard purchased an airplane ticket to Germany, where he planned to board a train to Turkey and then head to Syria. Hubbard was arrested on July 21, 2016, at Miami International Airport prior to the first leg of his overseas trip. Jackson, who had driven Hubbard to the airport, was arrested after he left the airport premises. Christian was arrested at his place of work.

A criminal complaint is merely an allegation, and the defendant is presumed innocent unless and until proven guilty beyond a reasonable doubt in a court of law.

If convicted, the defendants face a statutory maximum sentence of 20 years in prison for the material support charge. Christian faces a statutory maximum sentence of 10 years in prison if convicted on the charge of being a felon in possession of a firearm. The maximum statutory sentence is prescribed by Congress and is provided here for informational purposes. If convicted of any offense, the sentencing of the defendants will be determined by the court based on the advisory Sentencing Guidelines and other statutory factors.

The FBI and JTTF investigated the case with assistance from the Bureau of Alcohol, Tobacco, Firearms and Explosives; Transportation Security Administration; Miami International Airport Police Department; Boca Raton, Florida, Police Department; Palm Beach Sheriff’s Office; and City of West Palm Beach Police Department. This case is being prosecuted by Assistant U.S. Attorneys Karen E. Gilbert, Brian K. Frazier and Edward C. Nucci and Trial Attorneys Larry Schneider and David Cora of the National Security Division’s Counterterrorism Section.

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Final Criminal Complaint.pdf


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