Case l:15-cr-00164-CMH

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IN THE UNITED STATES DISTRICT COURT FOR THE
EASTERN DISTRICT OF VIRGINIA
/
ALEXANDRIA DIVISION
/

UNITED STATES OF AMERICA
v.
ALI SHUKRI A M I N ,
Defendant.

)
)
) CRIMINAL NO. l:15-cr-164
)
)
)
)
)
)
STATEMENT OF FACTS

The parties stipulate and agree that the allegations in the criminal information about the
defendant, A l i Shukri Amin, and the following facts are true and correct, and that had the matter
gone to trial, the United States would have proven them beyond a reasonable doubt with
admissible and credible evidence:
1.

From in or about June 2014 through on or about February 26, 2015, within the

Eastern District of Virginia and elsewhere, the defendant, A L I SHUKRI A M I N , and others,
known and unknown, knowingly did combine, conspire, confederate and agree together and with
each other to provide material support and resources, as that term is defined in 18 U.S.C. §
2339A, specifically, personnel, service, and expert advice and assistance, to a foreign terrorist
organization, namely the Islamic State in Iraq and the Levant ("ISIL"), knowing that ISIL has
engaged and engages in terrorist activity, as that term is defined in 8 U.S.C. § 1182(a)(3)(B), and
terrorism, as that term is defined in 22 U.S.C. § 2656f(d)(2), and was a foreign terrorist
organization.

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THE ISLAMIC STATE OF IRAQ AND THE LEVANT
2.

On October 15, 2004, the United States Secretary of State designated al-Qaeda in

Iraq, then known as Jam 'at al Tawhid wa'al-Jahid, 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.
3.

On May 15,2014, the Secretary of State amended the designation of al-Qaeda in

Iraq 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 to add the alias Islamic State of Iraq and the Levant as its primary name. The Secretary
also added the following aliases to the ISIL listing: The Islamic State of Iraq and al-Sham; the
Islamic State of Iraq and Syria; ad-Dawla al-Islamiyya fi al-Iraq wa-sh-Sham; Daesh, Dawla al
Islamiya; and AI-Furquan Establishment for Media Production. To date, AQI, aka ISIS, aka
ISIL, remains a designated foreign terrorist organization.
4.

At all relevant times, the defendant knew that ISIL was a designated terrorist

organization, and that it was a violation of United States law to provide support and resources to
ISIL.
THE DEFENDANT'S USE OF @.AmreekiWitness IN FURTHERANCE
OF HIS CONSPIRACY TO SUPPORT ISIL
5.

On or about June 26, 2014, the defendant started the Twitter account:

@AmreekiWitness, which boasted over 4,000 followers. The defendant used the account as a
pro-ISIL platform during the course of over 7,000 'tweets.' Specifically, the defendant used this
account to conduct twitter-based conversations regarding ways to develop financial support for
ISIL using on-line currency, such as Bitcoin, and ways to establish a secure donation system or

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fund for ISIL.
6.

The following are examples of the defendant's use of Twitter in furtherance of his

conspiracy to provide material support to ISIL:
a. On or about July 7, 2014, using the @AmreekiWitness account, the defendant
tweeted a link to an article he authored entitled "Bitcoin wa' Sadaqat al-Jihad"
(Bitcoin and the Charity of Jihad). The link transferred the user to the defendant's
blog, where the article was posted. The article discussed how to use bitcoins and how
jihadists could utilize this currency to fund their efforts. The article explained what
bitcoins were, how the bitcoin system worked and suggested using Dark Wallet, a
new bitcoin wallet, which keeps the user of bitcoins anonymous. The article included
statements on how to set up an anonymous donations system to send money, using
bitcoin, to the mujahedeen.
b.

On approximately August 1, 2014, the defendant showed support for ISIL and his
desire to help garner financial support for those wanting to commit jihad. Through
@AmreekiWitness the defendant discussed methods to provide financial support for
those wanting to commit jihad and for those individuals trying to travel overseas.

c.

On approximately August 19, 2014, the defendant showed support for ISIL and
desire to support ISIL. The defendant tweeted that the khilafah needed an official
website "ASAP," and that ISIL could not continue to release media "in the wild" or
use "JustPaste." Through various tweets, the defendant provided information on how
to prevent the website from being taken down, by adding security and defenses, and
he solicited others via Twitter to assist on the development of the website.

7.

The defendant also operated an Amreeki Witness page on the website ask.fm. The
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defendant used these accounts extensively as a platform to proselytize his radical Islamic
ideology, justify and defend ISIL's violent practices, and to provide advice on topics such as
jihadists travel to fight with ISIL, online security measures, and about how to use Bitcoin to
finance themselves without creating evidence of crime, among other matters.
8.

The defendant also created the pro-ISIL blog entitled, "Al-Khilafah Aridat." On

this blog, the defendant authored a series of highly-technical articles targeted at aspiring jihadists
and ISIL supporters detailing the use of security measures in online communications to include
use of encryption and anonymity software, tools and techniques, as well as the use of the virtual
currency Bitcoin as a means to anonymously fund ISIL.
THE DEFENDANT'S FACILITATION OF RN'S TRAVEL TO SYRIA
9.

RN, a co-conspirator, is an 18-year-old resident of Prince William County,

Virginia.
10.

Beginning in or around September 2014, the defendant began an effort to convert

RN to a radical form of Islam.
11.

In or about late November or early December 2014, the defendant put RN in

touch with an ISIL supporter located outside of the United States via Surespot in order to
facilitate RN's travel to Syria to join and fight with ISIL.
12.

The defendant arranged for this ISIL supporter located overseas to send RN a

package containing a phone for RN's use during his travel to Syria, an encrypted thumb drive,
and a letter.
13.

On or about January 7, 2015, FBI agents took possession of a package addressed

to the defendant that contained an un-activated smart phone with international capability, a USB
thumb drive, and a hand written letter containing both Arabic and English writing.
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14.

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RN purchased airline tickets from Dulles International Airport to Athens, Greece,

with a layover in Istanbul, which was RN's intended final destination. Once in Istanbul, RN was
to meet up with a number of additional ISIL supporters, travel to Gaziantep, and then the border
town of Urfa to meet an ISIL contact and cross into Syria.
15.

On or about January 14, 2015, the defendant and another co-conspirator drove RN

to Washington Dulles International Airport. During the trip, the other co-conspirator drove, and
the defendant provided instruction to RN on where to go once he arrived in Turkey in order to
meet up with other ISIL supporters traveling to Syria to join ISIL.
16.

RN was last seen by his family on January 14,2015, when he claimed to have

departed with an unknown friend for a camping trip.
17.

According to U.S. Customs and Border Protection records, on January 14, 2015,

RN departed on Turkish Airlines Flight 8 from Dulles International Airport to Istanbul, Turkey
and arrived in Istanbul on January 15, 2015. RN had onward travel booked to Athens, Greece
aboard Turkish Airlines Flight 1843, but he did not board the aircraft.
18.

On January 16, 2015, an overseas ISIL supporter communicated to the defendant

via Surespot that the group of ISIL supporters, including RN, had successfully crossed over into
Syria.
19.

After RN's departure, the defendant and another co-conspirator delivered to RN's

family in Prince William County, Virginia a letter from RN addressed to his family and a USB
thumbdrive. The letter and contents of the thumbdrive indicated that RN did not plan to see his
family again.

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CONCLUSION

20.

The acts described above were done willfully and knowingly and with the specific

intent to violate the law, and not by accident, mistake, inadvertence, or other innocent reason.
21.

This Statement of Facts does not contain each and every fact known to the

defendant and to the United States concerning the defendant's and others' involvement in the
charges set forth in the plea agreement.

Dana J. Boente
United States Attorney

Michael P. Ben'Ary
Assistant United States Attorney
Caroline H. Friedman
Special Assistant United States Attorney

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Defendant's Stipulation and Signature
After consulting with my attorney, 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.

Ali Shukri Amin
Defendant

Defense Counsel's Signature
I am the attorney for the defendant, A l i Shukri Amin. I have carefully reviewed the
above Statement of Facts with the defendant. To my knowledge, the defendant's decision to
stipulate to these facts is informed and voluntary.

Joseph Flood, Esq.
John Zwerling, Esq.
Cary Citronberg, Esq.
C0unsel for the Defendant

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IN THE UNITED STATES DISTRICT COURT FOR TH
EASTERN DISTRICT OF VIRGINIA
Alexandria Division
UNITED STATES OF AMERICA
l:15-cr-164
ALI SHUKRI A M I N ,
Defendant.
PLEA AGREEMENT
Dana J. Boente, United States Attorney for the Eastern District of Virginia; Michael P.
Ben'Ary, Assistant United States Attorney; Caroline H. Friedman, Special Assistant United
States Attorney the defendant, A L I SHUKRI A M I N ; and the defendant's counsel have entered
into an agreement pursuant to Rule 11 of the Federal Rules o f Criminal Procedure. The terms of
the agreement are as follows:
1.

Offense and Maximum Penalties

The defendant agrees to waive indictment and plead guilty to a single count criminal
information charging the defendant with Providing Material Support and Resources to a
Designated Foreign Terrorist Organization, specifically the Islamic State in Iraq and the Levant
(ISIL), in violation of Title 18, United States Code, Section 2339B. The maximum penalties for
this offense are a maximum term of 15 years of imprisonment, a fine of $250,000, forfeiture of
assets as outlined in paragraph 14 below, a special assessment, and supervised release for life.
The defendant understands that this supervised release term is in addition to any prison term the
defendant may receive, and that a violation of a term of supervised release could result in the
defendant being returned to prison for the full term of supervised release.

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2.

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Detention Pending Sentencing

The defendant understands that this case is governed by 18 U . S . C . §§ 3143(a)(2) and
3145(c). These provisions provide that a judicial officer shall order that a person who has been
found guilty of an offense of this kind be detained unless there are statutory justifications why
such person's detention would not be appropriate.
3.

Factual Basis for the Plea

The defendant will plead guilty because the defendant is in fact guilty of the charged
offense. The defendant admits the facts set forth in the statement of facts filed with this plea
agreement and agrees that those facts establish guilt of the offense charged beyond a reasonable
doubt. The statement of facts, which is hereby incorporated into this plea agreement, constitutes
a stipulation of facts for purposes of Section IB 1.2(a) of the Sentencing Guidelines.
4.

Assistance and Advice of Counsel

The defendant is satisfied that the defendant's attorney has rendered effective assistance.
The defendant understands that by entering into this agreement, defendant surrenders certain
rights as provided in this agreement. The defendant understands that the rights of criminal
defendants include the following:
a.

the right to plead not guilty and to persist in that plea;

b.

the right to a jury trial;

c.

the right to be represented by counsel - and i f necessary have the court
appoint counsel - at trial and at every other stage of the proceedings; and

d.

the right at trial to confront and cross-examine adverse witnesses, to be
protected from compelled self-incrimination, to testify and present
evidence, and to compel the attendance of witnesses.

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5.

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Role of the Court and the Probation Office

The defendant understands that the Court has jurisdiction and authority to impose any
sentence within the statutory maximum described above but that the Court will determine the
defendant's actual sentence in accordance with 18 U.S.C. § 3553(a). The defendant understands
that the Court has not yet determined a sentence and that any estimate of the advisory sentencing
range under the U.S. Sentencing Commission's Sentencing Guidelines Manual the defendant
may have received from the defendant's counsel, the United States, or the Probation Office, is a
prediction, not a promise, and is not binding on the United States, the Probation Office, or the
Court. Additionally, pursuant to the Supreme Court's decision in United Stales v. Booker, 543
U.S. 220 (2005), the Court, after considering the factors set forth in 18 U.S.C. § 3553(a), may
impose a sentence above or below the advisory sentencing range, subject only to review by
higher courts for reasonableness. The United States makes no promise or representation
concerning what sentence the defendant will receive, and the defendant cannot withdraw a guilty
plea based upon the actual sentence.
Further, in accordance with Rule 11(c)(1)(B) of the Federal Rules of Criminal Procedure,
the United States and the defendant will recommend to the Court that the following provisions of
the Sentencing Guidelines apply:
a.

Pursuant to Section 2M5.3 of the Sentencing Guidelines, the base offense
level is 26.

b.

Pursuant to Section 3A1.4(a), there is a 12-level enhancement because the
offense is a felony that involved a federal crime of terrorism.

c.

With respect to the defendant's criminal history, the parties agree that the
defendant has no prior criminal convictions. Pursuant to Section

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3A1.4(a), the parties agree that the defendant's Criminal History Category
is enhanced from Category I to Category V I .
d.

The United States agrees not to oppose a recommendation from the Court
s

that the defendant serve any portion of his sentence prior to his 2 1 '
birthday at a juvenile facility. The parties understand that the Court's
recommendation will not be binding on the Bureau of Prisons.
e.

The United States and the defendant agree that the defendant has assisted
the government in the investigation and prosecution of the defendant's
own misconduct by timely notifying authorities of the defendant's
intention to enter a plea of guilty, thereby permitting the government to
avoid preparing for trial and permitting the government and the Court to
allocate their resources efficiently. I f the defendant qualifies for a twolevel decrease in offense level pursuant to U.S.S.G. § 3El.l(a) and the
offense level prior to the operation of that section is a level 16 or greater,
the government agrees to file, pursuant to U.S.S.G. § 3El.l(b), a motion
prior to, or at the time of, sentencing for an additional one-level decrease
in the defendant's offense level.

These recommendations are not binding on the Court or the Probation Office. The
parties have no agreement as to the applicability or inapplicability of other Sentencing
Guidelines provisions.
6.

Waiver of Appeal, FOIA and Privacy Act Rights

The defendant also understands that 18 U.S.C. § 3742 affords a defendant the right to
appeal the sentence imposed. Nonetheless, the defendant knowingly waives the right to appeal

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the conviction and any sentence within the statutory maximum described above (or the manner in
which that sentence was determined) on the grounds set forth in 18 U.S.C. § 3742 or on any
ground whatsoever other than an ineffective assistance of counsel claim that is cognizable on
direct appeal, in exchange for the concessions made by the United States in this plea agreement.
This agreement does not affect the rights or obligations of the United States as set forth in 18
U.S.C. § 3742(b). The defendant also hereby waives all rights, whether asserted directly or by a
representative, to request or receive from any department or agency of the United States any
records pertaining to the investigation or prosecution of this case, including without limitation
any records that may be sought under the Freedom of Information Act, 5 U.S.C. § 552, or the
Privacy Act, 5 U.S.C. § 552a.
7.

Special Assessment

Before sentencing in this case, the defendant agrees to pay a mandatory special
assessment of one hundred dollars ($100.00) per count of conviction.
8.

Payment of Monetary Penalties

The defendant understands and agrees that, pursuant to 18 U.S.C. § 3613, whatever
monetary penalties are imposed by the Court will be due immediately and subject to immediate
enforcement by the United States as provided for in Section 3613. Furthermore, within 14 days
of a request, the defendant agrees to provide all of the defendant's financial information to the
United States and the Probation Office and, i f requested, to participate in a pre-sentencing
debtor's examination and/or complete a financial statement under penalty o f perjury. I f the
Court imposes a schedule of payments, the defendant understands that the schedule of payments
is merely a minimum schedule of payments and not the only method, nor a limitation on the
methods, available to the United States to enforce the judgment. I f the defendant is incarcerated,

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the defendant agrees to voluntarily participate in the Bureau of Prisons' Inmate Financial
Responsibility Program, regardless of whether the Court specifically directs participation or
imposes a schedule of payments.
9.

Immunity from Further Prosecution in this District

The United States will not further criminally prosecute the defendant in the Eastern
District of Virginia for the specific conduct described in the information or statement of facts,
except that the United States may prosecute the defendant for any crime of violence or
conspiracy to commit, or aiding and abetting, a crime of violence not charged in the information
as an offense. In such a prosecution the United States may allege and prove conduct described in
the information or statement of facts. "Crime of violence" has the meaning set forth in 18 U.S.C.
§16.
10.

Defendant's Cooperation

The defendant agrees to cooperate fully and truthfully with the United States, and provide
all information known to the defendant regarding any criminal activity as requested by the
government. In that regard:
a.

The defendant agrees to testify truthfully and completely at any grand
juries, trials or other proceedings.

b.

The defendant agrees to be reasonably available for debriefing and pre­
trial conferences as the United States may require.

c.

The defendant agrees to provide all documents, records, writings, or
materials of any kind in the defendant's possession or under the
defendant's care, custody, or control relating directly or indirectly to all
areas of inquiry and investigation.

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d.

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The defendant agrees that, at the request of the United States, the
defendant will voluntarily submit to polygraph examinations, and that the
United States will choose the polygraph examiner and specify the
procedures for the examinations.

e.

The defendant agrees that the Statement of Facts is limited to information
to support the plea. The defendant will provide more detailed facts
relating to this case during ensuing debriefings.

f.

The defendant is hereby on notice that the defendant may not violate any
federal, state, or local criminal law while cooperating with the
government, and that the government will, in its discretion, consider any
such violation in evaluating whether to file a motion for a downward
departure or reduction of sentence.

g.

Nothing in this agreement places any obligation on the government to seek
the defendant's cooperation or assistance.

11.

Use of Information Provided by the Defendant Under This Agreement

The United States will not use any truthful information provided pursuant to this
agreement in any criminal prosecution against the defendant in the Eastern District of Virginia,
except in any prosecution for a crime of violence or conspiracy to commit, or aiding and
abetting, a crime of violence (as defined in 18 U.S.C. § 16). Pursuant to U.S.S.G. § IB 1.8, no
truthful information that the defendant provides under this agreement will be used in determining
the applicable guideline range, except as provided in Section I B 1.8(b). Nothing in this plea
agreement, however, restricts the Court's or Probation Officer's access to information and
records in the possession of the United States. Furthermore, nothing in this agreement prevents

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the government in any way from prosecuting the defendant should the defendant knowingly
provide false, untruthful, or perjurious information or testimony, or from using information
provided by the defendant in furtherance of any forfeiture action, whether criminal or civil,
administrative or judicial. The United States will bring this plea agreement and the full extent of
the defendant's cooperation to the attention of other prosecuting offices i f requested.
12.

Defendant Must Provide Full, Complete and Truthful Cooperation

This plea agreement is not conditioned upon charges being brought against any other
individual. This plea agreement is not conditioned upon any outcome in any pending
investigation. This plea agreement is not conditioned upon any result in any future prosecution
which may occur because of the defendant's cooperation. This plea agreement is not
conditioned upon any result in any future grand jury presentation or trial involving charges
resulting from this investigation. This plea agreement is conditioned upon the defendant
providing full, complete and truthful cooperation.
13.

Motion for a Downward Departure

The parties agree that the United States reserves the right to seek any departure from the
applicable sentencing guidelines, pursuant to Section 5K1.1 of the Sentencing Guidelines and
Policy Statements, or any reduction of sentence pursuant to Rule 35(b) of the Federal Rules of
Criminal Procedure, if, in its sole discretion, the United States determines that such a departure
or reduction of sentence is appropriate.
14.

Forfeiture Agreement

The defendant understands that the forfeiture of assets is part of the sentence that must be
imposed in this case. The defendant agrees to forfeit all interests in any terrorism-related asset
that the defendant owns or over which the defendant exercises control, directly or indirectly, as

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well as any property that is traceable to, derived from, fungible with, or a substitute for property
that constitutes the proceeds of his offense, or facilitating property or property involved in the
offense. The defendant understands that if proceeds of the offense are not available to the United
States to be forfeited, the Court must enter a forfeiture money judgment in the amount of the
proceeds. United States v. Blackman, 746 F.3d 137 (4th Cir. 2014). The defendant further
agrees to waive all interest in the asset(s) in any administrative or judicial forfeiture proceeding,
whether criminal or civil, state or federal. The defendant agrees to consent to the entry of orders
of forfeiture for such property and waives the requirements of Federal Rules of Criminal
Procedure 32.2 and 43(a) regarding notice of the forfeiture in the charging instrument,
announcement of the forfeiture at sentencing, and incorporation of the forfeiture in the judgment.
Defendant admits and agrees that the conduct described in the charging instrument and
Statement of Facts provides a sufficient factual and statutory basis for the forfeiture o f the
property sought by the government.
15.

Waiver of Further Review of Forfeiture

The defendant further agrees to waive all constitutional and statutory challenges to
forfeiture in any manner (including direct appeal, habeas corpus, or any other means) to any
forfeiture carried out in accordance with this Plea Agreement on any grounds, including that the
forfeiture constitutes an excessive fine or punishment. The defendant also waives any failure by
the Court to advise the defendant o f any applicable forfeiture at the time the guilty plea is
accepted as required by Rule 1 l(b)(l)(J). The defendant agrees to take all steps as requested by
the United States to pass clear title to forfeitable assets to the United States, and to testify
truthfully in any judicial forfeiture proceeding. The defendant understands and agrees that all
property covered by this agreement is subject to forfeiture as property facilitating illegal conduct.

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16.

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The Defendant's Obligations Regarding Assets Subject to Forfeiture

Upon request by the government, the defendant agrees to identify all assets in which the
defendant had any interest or over which the defendant exercises or exercised control, directly or
indirectly, within the past one year. The defendant agrees to take all steps as requested by the
United States to obtain from any other parties by any lawful means any records of assets owned
at any time by the defendant. The defendant agrees to undergo any polygraph examination the
United States may choose to administer concerning such assets and to provide and/or consent to
the release of the defendant's tax returns for the previous five years.
17.

Breach of the Plea Agreement and Remedies

This agreement is effective when signed by the defendant, the defendant's attorney, and
an attorney for the United States. The defendant agrees to entry of this plea agreement at the
date and time scheduled with the Court by the United States (in consultation with the defendant's
attorney). I f the defendant withdraws from this agreement, or commits or attempts to commit
any additional federal, state or local crimes, or intentionally gives materially false, incomplete, or
misleading testimony or information, or otherwise violates any provision of this agreement, then:
a.

The United States will be released from its obligations under this
agreement, including any obligation to seek a downward departure or a
reduction in sentence. The defendant, however, may not withdraw the
guilty plea entered pursuant to this agreement;

b.

The defendant will be subject to prosecution for any federal criminal
violation, including, but not limited to, perjury and obstruction of justice,
that is not time-barred by the applicable statute o f limitations on the date
this agreement is signed. Notwithstanding the subsequent expiration of

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the statute oflimitations, in any such prosecution, the defendant agrees to
waive any statute-of-limitations defense; and
c.

Any prosecution, including the prosecution that is the subject of this
agreement, may be premised upon any information provided, or
statements made, by the defendant, and all such information, statements,
and leads derived therefrom may be used against the defendant. The
defendant waives any right to claim that statements made before or after
the date of this agreement, including the statement of facts accompanying
this agreement or adopted by the defendant and any other statements made
pursuant to this or any other agreement with the United States, should be
excluded or suppressed under Fed. R. Evid. 410, Fed. R. Crim. P. 11(f),
the Sentencing Guidelines or any other provision of the Constitution or
federal law.

Any alleged breach of this agreement by either party shall be determined by the Court in
an appropriate proceeding at which the defendant's disclosures and documentary evidence shall
be admissible and at which the moving party shall be required to establish a breach of the plea
agreement by a preponderance of the evidence. The proceeding established by this paragraph
does not apply, however, to the decision of the United States whether to file a motion based on
"substantial assistance" as that phrase is used in Rule 35(b) of the Federal Rules of Criminal
Procedure and Section 5K1.1 of the Sentencing Guidelines and Policy Statements. The
defendant agrees that the decision whether to file such a motion rests in the sole discretion of the
United States.

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18.

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Nature of the Agreement and Modifications

This written agreement constitutes the complete plea agreement between the United
States, the defendant, and the defendant's counsel. The defendant and the defendant's attorney
acknowledge that no threats, promises, or representations have been made, nor agreements
reached, other than those set forth in writing in this plea agreement, to cause the defendant to
plead guilty. Any modification of this plea agreement shall be valid only as set forth in writing
in a supplemental or revised plea agreement signed by all parties.

Dana J. Boente
United States Attorney

Michael P. Ben'Ary
Assistant United States Attorney
Caroline H. Friedman
Special Assistant United States Attorney

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Defendant's Signature: I hereby agree that I have consulted with my attorney and fully
understand all rights with respect to the pending criminal information. Further, I fully
understand all rights with respect to Title 18, United States Code, Section 3553 and the
provisions of the Sentencing Guidelines Manual that may apply in my case. I have read this plea
agreement and carefully reviewed every part of it with my attorney. I understand this agreement
and voluntarily agree to it.

Date 6/3/15
A L I SHUKRI A M I N
Defendant
Defense Counsel Signature: We are counsel for the defendant in this case. We have fully
explained to the defendant the defendant's rights with respect to the pending information.
Further, we have reviewed Title 18, United States Code, Section 3553 and the Sentencing
Guidelines Manual, and we have fully explained to the defendant the provisions that may apply
in this case. We have carefully reviewed every part of this plea agreement with the defendant.
To our knowledge, the defendant's decision to enter into this agreement is an informed and
voluntary one.

Date:

6/3/15
Joseph Flood, Esq.
John Zwerling, Esq.
Cary Citronberg, Esq.
Counsel for the Defendant

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