12. The defendant's assistance to al Qaeda, including: researching and providing information about ultralights, extending travel tickets, researching gas cutters, asking other individuals about gas cutters, surveying a target (the bridge) and then reporting his assessment, constituted felony offenses that involved, or were intended to promote, a federal crime of terrorism within the meaning of U.S.S.G. § 3A1.4, in that this conduct provided material support or resources to al Qaeda, a designated foreign terrorist organization.
13. Al Qaeda is an organization that was established in Afghanistan by Osama bin Laden and others. On October 8, 1999, al Qaeda was designated by the Secretary of State as a foreign terrorist organization pursuant to Section 219 of the Immigration and Nationality Act, and was re-designated as such on or about October 5, 2001. Accordingly, al Qaeda is a designated foreign terrorist organization within the meaning of Title 18, United States Code, Section 2339B.
14. At all times during the above-described incidents in which the defendant assisted al Qaeda and its operatives, he acted unlawfully and knowingly and not by mistake or other innocent reason.
Paul J. McNulty United States Attorney
By: _______________________________ Neil Hammerstrom, Jr. Assistant United States Attorney
_______________________________ Joseph N. Kaster Trial Attorney, Criminal Division Counterterrorism Section U.S. Department of Justice
After consulting with my attorney and pursuant to the plea agreement entered into this day between the defendant, Iyman Faris, and the United States, I hereby stipulate that the above Statement of Facts is true and accurate, and that had the matter proceeded to trial, the United States would have proved the same beyond a reasonable doubt.
____________________________________ Iyman Faris Defendant
I am counsel for the defendant. I have carefully reviewed the above Statement of Facts with him. To my knowledge, his decision to stipulate to these facts is an informed and voluntary one.
_____________________________________ J. Frederick Sinclair Counsel for Defendant Iyman Faris