CHARGE SHEET
I. PERSONAl DATA
1. NAME OF ACCUSED:

Majid Shoukat Khan
2. AliASES OF ACCUSED:

Majid Shoukat Khan (aliases Bobdesi; Adnan; Yusif)
3. ISN NUMBER OF ACCUSED (LAST FOUR):

10020

,
II. CHARGES AND SPECIFICATIONS
·4.CHARGE:

VIOLATION OF SECTION AND TITLE OF CRIME IN PART IV OF M.M.C.

SPECIFICATION:

See Attached Charges and Specifications.

Sa. NAME OF ACCUSER (LAST, FIRST, ,,/)

III. SWEARING OF CHARGES
5b.GRADE
5c. ORGANIZATION OF ACCUSER

0-5

Hines, Glen R.

5d'Sht:A;eS~

Office of Military Commissions
Sa. DATE (VYYYMMDD)

20120213

AFFIOAVI-t.' Before me, the undersigned, authorized by law to administer oath in cases of this character, personally appeared the above named
accuser the ~ day of February.
2012. and signed the foregoing charges and speCifications under oath that he/she Is a person
subject to the Uniform Code of Military Justlce and that he/she has personal knowledge of or has investigated the matters set forth therein and
.
that the same are true to the best of his/her knowledge and belief.

James P. Benoit

Office of Milita~ Commissions

Typed Name of Officer

Organization of Officer

~

APM,tr
i"/9nattfre L/

MC FORM +fAN 2007

Judge Advocate
Official Capacity to Administer oath
(See R.M.C. 307(b) must be commissionad officer)

 lV. NOTICI TO THI ACCU'ID

.

13 February

8. On

2012

the ac:cuHd WH nol/lled of the charges against hlmlher (See R.M.C. 308)•

~3"'T T~_( .,f~,

'7'"8°... l\tI. -:S. WS'-!tl (2!~~ S6"'"
Typed Name and Grade of P,;;J; Who caused

-

~J.~IJ

Orpanlzatlon of the Parson Who ,used
Accu.d to Be Notified of Charges

Accused to B. NotIfItId of C1IatJea

~J~

V. RECEIPT OF CHARGeS 8Y CONVeNING AUTHORITY
7. The sworn cI1argea MAt received at

16 2 0

hours. on

l~ [~b

VA

,at AlSjllxandria ,

,Q1,

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LoceUon

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For !he Calven1ng AuIhoI'Ity:

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l}'ped NtmIfI of 0IfIcer

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VI. RIF".IW.
~ DESIGNA-qON OF cO~'(.rlNq AUTHOR\1Q
onven ng ~u or1ty,

R~OI' ;ral

a e

Alexandria, VA

f ~8 ~~Pltal
military commlallon convened by mIlitary comm'plon convening order
e ruary 2012
.
subject to the following Instructtona1:

Direction

or

the

Command, Order, 01 DIrection

k
u;-<z Zj)~A

Donne:.,. L. Wilkins, GS15

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/

20120215
12-01

,

None~

non-capital.
By

eo. DATE (YVVVMMDDt

8tJ.PLACII

U.S.C.
§ 948h, designated on 25 Mar 1 p

J

this case

~s t:!;f~t:t:~a

COD~!;n~ng autbQ~1t~

,

Convening Authority, Chapter 47A
of Title 10 U.S.C. E; 948h
OffIcial Capacity of Offfcer Signing

Nam. and Grad. of OffIcer
Slgneture

VII. IER"VIC-, OF CHAROBI

G.On

I (caused to be) served a copy theM charges on the abOVe named ac:cuMd.

•

£Ide of TtfaT Counsel

Typed Nama 01 Trial Coun,aT

j

SIgnature 01 Trial CouneeJ

Se. R.M.C. 601 ooncemIngln8tructlona. If none, ao

Me FORM 458 JAN 2007

ItS".

FOOTNOTU

J

 CHARGE I: VIOLATION OF 10 U.S.C. § 9S0t(29), CONSPIRACY

Specification: In that Majid Shoukat KHAN, a person subject to trial by military commission as
an alien unprivileged enemy belligerent, did, at various locations within the United States,
'
Pakistan, Indonesia. Thailand. and elsewhere, from about January 2002, to about August 2003,
knowingly and willfully conspire with Usama bin Laden, Khalid Sheikhh Mohammed, Ali Abdul
al-Aziz Ali; Encep Nurjamen, aIkIa Hambali (Hambali); Mohammed Nazir bin Lep, aIkIa Lillie
(Ullie); and Mohammed Farik bin Amin. a/kla Zubair (Zubatr); and other members and
associates of the at Qaeda organization and its affiliated groups, known and unknown, to commit
offenses triable by military commission, to wit: murder in violation of the law of war, providing
material support for terrorism and spying, and in order to effect the object and purpose of the
agreement, the above accused and his co-conspirators knowingly committed an overt act or acts,
to wit:
QVERIACIS

1. In about August 1996, Usama bin Laden issued a public "Declaration of Holy War
Against the Americans Who are Occupying the Land of the Two Holy Places," in
which he called for the murder of U.S. military personnel serving on the Arabian
Peninsula.
2. In about 1996, Khalid Sheikh Mohammed traveled to Malaysia and met with
Abdullah Sungkar and Abu Bakr Ba' asyir, two leaders of the Southeast Asia-based
organization, Jemaah Islamiyah. During this meeting, Khalid Sheikh Mohammed
convinced Abdullah Sungkar and Abu Bakr Ba'asyir to travel to Afghanistan to
meet with Usarna bin Laden. 'Thereafter, Khalid Sheikh Mohammed facilitated
Abdullah Sungkar and Abu Bakr Ba'asyir's travel to Afghanistan and a meeting
with Usama bin Laden. After meeting with Usama bin Laden, Abdullah Sungkar
and Abu BakI Ba'asyir told Khalid Sheikh Mohammed that Usama bin Laden had
advised them that al Qaeda and Jemaah Islamiyah should tIght together.

3. In about March 1997. in an interview with CNN, Usama bin Laden promised to
"drive Americans away from all Muslim countries," and warned the U.S. "to get
out" if it did "not want to have its sons who are in the army killed.", Usama bin
Laden could "not guarantee" the "safety" of U.S. civilifms since they were "not
exonerated from responsibility" for U.S. foreign policy "because they chose the
government and voted for it despite their knowledge of its crimes." He promised
that if his demands were unmet. he would send the U.S. "messages with no words
because" the U.S. President "does not know any words."
4. In about February 1998, Usama bin Laden and others, under the banner of the
"International Islamic Front for Jihad against the Jews and the Crusaders," issued a
fatwah (purported religious ruling) claiming that it was "God's order" and an
"individual duty for every Muslim" to "kill Americans ... wherever and whenever"

1

 found. The fatwah directed all Muslims to "kill the Americans and their alHes ..
civilians and military."
S. On or about May 28. 1998. in an interview with ABC News in Afghanistan, Usama
bin Laden reiterated the February 1998 fatwah' s call for killing Americans,
emphasizing that, "We do not differentiate between those dressed in military
unifonns and civilians. They are all targets in this fatwah:' Usama bin Laden
further stated that if his demands were not met, al Qaeda would "send" to the U. S.
"the wooden boxes and the coffins" containing "the corpses of American troops and
the American civilians." Bin Laden also noted that "American civilians were asked
to gather infonnation on Muslims and observant Muslim youth and to convey it to
the security section in the embassy."
6. On or about May 29, 1998, Usama bin Laden issued a statement entitled, "The
Nuclear Bomb of Islam," under the banner of the "International Islamic Front for
Fighting Jews and Crusaders," in which bin Laden stated that "it is the duty of the
Muslims to prepare as much force as possible to terrorize the enemies of God."

PIiOT TO USE KHAN IN POST 9/11 AITACKS
AGAINST THE gNITEQ STATES
7. On or about October 16,2001, in Baltimore, Maryland, KHAN applied to the
United States Immigration and Naturalization Service for a Refugee Travel
Document and fraudulently claimed that he intended to travel to Dubai (to get
married) and Saudi Ara~ia (for a pilgrimage).
8. On or about January 4, 2002, KHAN traveled, using the fraudulently obtained
Refugee Travel Document, from Baltimore, Maryland to Karachi, Pakistan.
9. Between about January 4,2002 and about March 21, 2002, in or around Karachi,
Pakistan, KHAN's close associate. Co-conspirator #1. who served on the at Qaeda
media committee, introduced KHAN to Khalid Sheikh Mohammed as a close
associate from the United States who could be helpful to at Qaeda.
10. Between about January 4, 2002 and about March 21, 2002, in or around Karachi.
Pakistan. KHAN met with Khalid Sheikh Mohammed and advised him that
KHAN's family owned gas stations in the United States.
11. Between about January 4, 2002 and about March,21. 2002, in or around Karachi
Pakistan. KHAN discussed with Khalid Sheikh Mohammed a plot to blow-up
underground gasoline storage tanks at gas stations within the United States .
. 12. Between about January 4,2002 and about March 21. 2002, in or near Karachi,
Pakistan. Khalid Sheikh Mohammed directed KHAN to attend training on explosive
device detonators and timers.

2

#"

i

 13. Between about January 4,2002 and about March 21,2002, in or near Karachi,
Pakistan, Khalid Sheikh Mohammed instructed KHAN that when KHAN returned
to the United States, he should conduct research about the operation and
maintenance of gas stations and fuel tanks in furtherance of a plot to explode
underground gasoline storage tanks.
14. From about January 4,2002 to about March 21, 2002, KHAN began to work for
Khalid Sheikh Mohammed, Ali Abdul al·Aziz Ali and al Qaeda, including
checking al Qaeda operational email accounts and couriering messages for al
Qaeda operatives andlor ass~iates.
15. On or about March 21, 2002, KHAN traveled from Karachi, Pakistan to Baltimore,
Maryland.

16. From about March 21, 2002 to about August 11, 2002, in or near Baltimore,
Maryland, KHAN worked at a gas station operated by his family.
17. Between about March 21, 2002 anfil about August 11,2002, in or near Baltimore,
Maryland, KHAN attempted to rectuit a close associate to work for Khalid Sheikh
Mohammed and al Qaeda.
18. In about July 2002, Khalid Sheikh Mohammed andlor another al Qaeda associate,
ordered Khan to return to Pakistan.
19. On or about August II, 2002, KHAN returned to Pakistan, again traveling from
Baltimore, Maryland to Karachi, Pakistan.
20. From about August 11,2002 to about March 5, 2003, in or near Karachi, Pakistan,
KHAN worked directly for Khalid Sheikh Mohammed, Ali Abdul al-Aziz Ali and
other al Qaeda associates, all of whom were evading capture by United States and
Pakistani authorities.
21. On or about December 22, 2002. while in or near Karachi, Pakistan, KHAN
allowed his United States Refugee Travel Document to expire.
22. Between about August II, 2002 and about March 5, 2003, in or near Karachi,
Pakistan, Ali Abdul al·Aziz Ali directed KHAN to obtain renewed travel
documents to permit him to return to the United States so that Khalid Sheikh
Mohammed could utilize him as anal Qaeda operative or facilitator within the
United States.
23. From about August II, 2002 to about March 5, 2003, in or around Karachi,
Pakistan, KHAN volunteered to go anywhere to help with an al Qaeda operation
once he resolved his passport issue.

3

 24. On or about December 30, 2002, Aafia Siddiqui (Siddiqui) opened a Post Office
Box at a United States Post Office in Gaithersburg, Maryland. Siddiqui listed
KHAN as the co-owner of the Post Office Box and falsely listed KHAN as her
husband.
25. On or about December 30, 2002, in or near Gaithersburg, Maryland, Siddiqi mailed
an application for a Refugee Travel Document to the Vnited States Immigration and
Naturalization Service on KHAN's behalf.
26. From about late January to about early February 2003, KHAN and Ali Abdul atAziz Ali met with Uzalr Paracha and Saifullah Paracha in or near Karachi, Pakistan
on at least two separate occasions. During these meetings, KHAN advised Uzair
Paracha that he did not want United States Immigration officials to learn that he
was not in the United States. KHAN directed that upon Vzair Paracha's return to
the United States, Vzair Paracha should, among other things, deposit money into
KHAN's bank account, use his credit card, retrieve immigration papers from a post
office box in Maryland and call INS from a pay phone, posing as KHAN.
27. Between about late January and about early February 2003, in or near Karachi
Pakistan, Khan attempted to recruit Uzair Paracha to work for al Qaeda.
28. On or about February 17, 2003, Vzair·Paracha traveled from Karachi, Pakistan to
New York, New York.
.
29. Between about February 17,2003 and about March 28, 2003, in or near New York,
New York, Uzair Parcha called a United States Immigration and Customs
Enforcement telephone number posing as KHAN.
30. Between about February 17,2003 and about March 28, 2003, in or near New York,
New York, Vzair Parch a visited a website named'''Visapro,'' where he entered the
receipt number for KHAN's Refugee Travel Document Application in order to
check on its status as KHAN had instructed.
I

31. Between about January 30, 2003 and about February 13,2003, in or near Karachi,
Pakistan, KHAN and Co-conspirator #1 showed one of KHAN's close associates a
videotape, produced by Co-conspirator #1, depicting al Qaeda training.

ATtEMfT TO ASSASSINATE PRESIDENT MUSHARRAF
32. Between about January 4,2002 and about March 21, 2002, in or near Karachi.
Pakistan, KHAN told Khalid Sheikh Mohammed that he was willing to conduct a
suicide attack against Pakistani President Pervez Musharraf. At Khalid Sheikh
Mohammed's direction, KHAN recorded a "martyr video," wore an explosive vest
and sat in a Mosque waiting for President Mushal'raf to arrive.

4

 ATTACK ON J.W. MARRIOTT IN JAKARTA, INDONESIA
33. In about mid January 2002, Mohammed Jabarah, an operative sent by Khalid
Sheikh Mohammed, met with Hambali in Thailand. Hambali stated that he planned
to have his group conduct bombings against soft targets such as bars, cafes or
nightclubs frequented by "Westerners" in Thailand, Malaysia, Singapore,
Philippines and Indonesia. Hambali also stated that he had one ton of explosives in
Indonesia.
34. In about January 2002, Hambali instructed his lieutenants, Lillie and Zubair, to
travel from Hat Yai Thailand, to Hambali's location in Bangkok, Thailand.
35. Between about January 2002 and about June 2003, in or near Bangkok, Thailand,
Hambali provided Lillie and Zubair with money to procure false identification
documents for Hambali.
36. In about late 2002, Khalid Sheikh Mohammed and Ali Abdul al-Aziz Ali, who were
located in or near Karachi, Pakistan, directed KHAN to deliver $50,000 United:
States Dollars (USD) to Hambali in Bangkok, Thailand. Khalid Sheikh Mohammed
directed that KHAN should arrange the money transfer in the "black market," to
avoid detection and the carrying of cash from Pakistan to Thailand.
37. In about late 2002. Ali Abdul al·Aziz Ali instructed KHAN to conduct Internet
research about tourist activities in Thailand so that KHAN could dress appropriately
and "blend in" unnoticed. Ali instnlcted KHAN to travel with his wife and use his
honeymoon as a "cover story" for his trip to Thailand.
38. In about late 2002, Hambali's brother, Rusman Gunawan, aIkIa/ Abdul Hadi,
(Gunawan), located in or near Karachi, Pakistan, notified Hambali that Khalid
Sheikh Mohammed was sending $50,000 USD to Hambali in Thailand.
39. In about late 2002, in 01' near Bangkok Thailand, Hambali told Zubair that they
would be receiving $50,000 USD from al Qaeda. Zubair gave Hambali his
telephone number to pass on to KHAN, sO that KHAN could contact Zubair when
he arrived in Thailand. Hambali told Zubair that the money was to be used for an
"operation," such as a bombing or similar type of terrorist attack. Hambali
subsequently provided Zubair's telephone number to Gunawan.
40. In about late 2002, Gunawan provided Ali Abdul al·Aziz Ali with Zubair's
telephone number in Bangkok, Thailand. Ali Abdul al-Aziz Ali then provided
Zubair's phone number to KHAN.
41. On or about December 24,2002, KHAN and his wife traveled from Pakistan to
Bangkok, Thailand.

5

 42. On 01' about December 24, 2002 to about December 29,2002, KHAN and his wife

stayed at the Sofitel Hotel in Bangkok, Thailand.
43. On or about December 24,2002 to about December 29.2002, in or near BangkOk,

Thailand, KHAN adopted a codewname and used coded methods to communicate
with Ali Abdul al-Aziz Ali. who was located in or near Karachi, 'FkailanEi ?'" \l~(!l,t'\. ~~~~ \144. On or about December 26.2002. KHAN received a message on the Sofitel Hotel's

automated message system asking'him to call "Mr. Farooq" at a Thailand-based
telephone number. KHAN called that phone number from his hotel room on or
about December 28, 2002.
45, From about December 24,2002 to about December 29,2002, in or near Bangkok,

Thailand, KHAN exchanged several e-mail messages with Ali Abdul al-Aziz Ali
discussing the $50,000 USD money transfer to Hambali.
46. Between about December 24, 2002 and about December 28, 2002, KHAN

telephoned Zubair and arranged to meet with him at a set location in Bangkok,
Thailand.
.
47. On or about December 28, 2002 Zubair and KHAN met at a location in Bangkok,
Thailand. At this meeting, KHAN delivered approximately $30,000 USD to
Zubair. KHAN and Zubair arranged to meet again later that day so that KHAN
could deliver the balance of the $50,000 USD to Zubair.
48. On or about December 28, 2002, Zubair and KHAN met a second time at a location
in Bangkok, Thailand. KHAN delivered the remaining balance of the $50,000 USD

to Zubair.

.

49. On or about December 28, 2002, KHAN sent an e·mail message to Ali Abdul alAziz Ali confirming that he had successfully received the $50,000 USD and that he

was delivering the money to Zubair.
50. On or about December 28. 2002, at Hambali's instruction, Zubair took the $50,000

USD he had received from KHAN to an apartment in or near Bangkok. Thailand,
shared by Zubair and Lillie. for safekeeping.
51. In or about January 2003. at Hambali's instruction, Zubair met with a second at
Qaeda money courier in or near Bangkok. Thailand. At this meeting. the al Qaeda
money courier gave Zubalr approximately $49,000 USD. Zubair took this money
to the apartment he shared with Lillie in or near Bangkok for safekeeping as well.
52. In or about February 2003. in or near Bangkok, Hambali directed Lillie and Zubair

to take the money that they had received from KHAN and other conspirators and
change it into other currencies.

6

t_<

 53. In or about Spring 2003, at Hambali's direction, Lillie transferred the money to a
fellow Malaysian and instructed him to hand-deliver the money to Indonesia, using
codes and code names. Hambali told Lillie that this money was intended for
Jemaah lslamiyah member Dr, bin Hussein Azahari (Azahari).
54. In or about late Spring or early Summer 2003, Jemaah lslamiyah associate
Mohammed Ikhwan, a/kJa Ismail (Ismail), received the money delivered to him in
Indonesia at Hambali's instruction.
55. In or about June 2003, Hambali contacted Zubair, at or near Bangkok, Thailand,
and instructed him to remind Azahari that that some of the money that had been
derived from the co-mingled funds, a portion of which had been delivered to
Thailand by the Accused, and subsequently delivered to Indonesia by Hambali, was
for families of Jemaah Islamiyah members and a portion was for a terrorist
operation.
56. In or about late Spring or early Summer 2003, a group of Jemaah Islam/yah
members began planning for a terrorist bombing, using the funds that had been
delivered 1;>y Hambali, which were derived from the co-mingled funds that KHAN
had delivered to Thailand in December 2002.
57. In or about early Summer 2003, Jemaah Islamtyah associates Nordin mat Top
(Top) Ismail, and Azahari traveled to Jakarta, Indonesia, to construct a truck bomb.
In order to covertly construct the truck bomb, Asmar and Tohir rented a safe hOl"lse
with a garage.
58. In or about mid-July 2003, Top and Azahari settled on the J.W. Marriott Hotel in
Jakru1:a, Indonesia, as the target of the terrorist attack. They did so in large part
because they believed it had a large American presence.
59. On or about August 5, 2003, after allowing the selected suicide bomber to stop in a
mosque to pray, Azahari joined Ismail on the motorcycle, and led the bomber in the
truck bearing the bomb to the J.W. Marriott Hotel in Jakarta, Indonesia. Ismail and
Azahari turned left on the street immediately prior to the J.W. Marriott Hotel and
paused to ensure that the bomber turned into the J.W. Marriott Hotel driveway.
60. On or about August 5, 2003, in Jakarta, Indonesia, the suicide bomber drove the
truck into the front entrance of the J.W. Marriott Hotel and detonated the bomb,
killing eleven people, wounding at least eighty-one others, and severely damaging
the J .W. Marriott Hotel.
61. All of the groups' expenses for conducting the bombing of the August 5, 2003 J. W.
Marriott hotel were paid for using the funds that were delivered by Hambali from
the co-mingled funds he received from KHAN and another al Qaeda money
courier.

7

 CHARGE II: VIOLATION OF 10U.S.C. § 950t(15), MURDER IN VIOLATION
OF THE LAW OF WAR.
Specification: In that Majid Shoukat KHAN, a person subject to trial by military
commission as an aUen unprivileged enemy belligerent, did. on or about August 5,2003.
at or near Jakarta, Indonesia, in the context of and associated with hostilities,
intentionally and unlawfully kill one or more protected persons in violation of the law or
war by detonating a vehicle laden with explosives in front of the J.W. Marriott Hotel
. located in Jarkarta, Indonesia, resulting in the deaths of 11 persons. (See Charge Sheet
Appendix A for a list of victims killed in the attack).
.
CHARGE III: VIOLATION OF 10 U.S.C. § 950t(28), ATTEMPTED MURDER IN
VIOLA TlON OF THE LAW OF WAR.
Specification 1: In that Majid Shoukat KHAN, a person subject to trial by military

commission as an alien unprivileged enemy belligerent, did, on or about August 5, 2003,
at or near Jakarta, Indonesia, in the context of and associated with hostilities,
intentionally and unlawfully attempt to commit murder in violation of the law of war by
intentionally detonating a vehicle laden with explosives in front of the J.W. Marriott
Hotel located in Jarkarta, Indonesia, with the intent to kill protected persons in and
around the hotel, which actions amounted to more than mere preparation and apparently
tended to effect the commission of the offense of Murder in Violation of the Law of war.
(See Charge Sheet Appendix B for a list of victims).
Specification 2: In lhat Majid Shoukat KHAN, a person subject to trial by military

commission as an alien unprivileged ene"my belligerent, did, on or about March 8, 2002.
at or neal' Karachi, Pakistan, in the context of and associated with hostilities, intentionally
and unlawfully attempt to kill Pakistani President Pervez Musharraf in violation of the
law of war, by wearing a vest containing an improvised explosive device and traveling to
a mosque where he expected President Musharraf to be with the intention of detonating
the vest and killing President Musharraf, which actions amounted to more than mere
preparation and apparently tended to effect the commission of the offense of Murder in
Violation ofthe Law of war.
CHARGE IV: VIOLATION OF 10 U.S.C. § 950t(25), PROVIDING MATERIAL
SUPPORT FOR TERRORISM
Specification 1: In that Majid Shoukat KHAN, a person subject to trial by military

commission as an alien unprivileged enemy belligerent, did, from about January 2002 to
about March 2003, at various locations within the United States, Pakistan, and Thailand,
and elsewhere, in the context of and associated with hostilities, provide material support
or resources, to wit: property, including currency or monetary instruments, and services,
including financial services and personnel, inclu9ing himself, knowing or intending that
they were to be used in preparation for, or in carrying out, an act of terrorism as set forth
in 10 U.S.C. § 950t(24).
8

m

 Specification 2: In that Majid Shoukat KHAN, a person subject to trial by military
conunission as an alien unprivileged enemy belligerent, did, from abou~. January 2002 to
about March 2003. at various locations within the United States. Pakistan, Thailand, and
elsewhere, in the context of and associated with hostilities, provide material support 01'
resources, to wit: property, including currency or monetary instruments. services,
including financial services, lodging, false documentation or identification,
conununications equipment, explosives, personnel, including himself, and transportation,
to an international terrorist organization engaged in hostilities against the United States,
to wit: al Qaeda and Jemaah Islamtyah, with the intent to provide such material support
to al Qaeda and Jemaah Islamiyah, and knowing that al Qaeda and JeflUUlh Islamiyah
has engaged in or engages in terrorism as set forth in 10 U.S.C. § 950t(24).

CHARGE V: VIOLATION OF 10 U.S.C. § 950t(27), SPYING
Specification: In that Majid Shoukat KHAN, a person subject to trial by military
commission as an alien unprivileged enemy belligerent, cUd, in the context of and
associated with hostilities, from about January 2002 to about March 2003. at or near
Karachi, Pakistan and Baltimore, Maryland, collect or attempt to collect information by
clandestine means or while acting under false pretenses, intending or having reason to
believe the information collected would be used to injure the United States or to provide
an advantage to a foreign power and intending to convey such information to an enemy
of the United States or one of the co-belligerents of the enemy, in violation of the law of
war.

9

 · CHARGE SHEET: APPENDIX A
The names of persons killed as a result of the August S, 2003 attack on the J. W. Marriott

The following are persons who were killed on August S, 2003. in or around Jakarta. Indonesia, as
a result of the attack on the J. W. Marriott Hotel:
1. Edi Haryanto

2. Edi Sucipto

3. Eyoh Zakaria
4. Hans Winkelmolen
5. Hidayat
6. Johanes Bolan

7. Miptah Tobiin
8. Rudi Dwi Laksono

9. Slamet Heriyanto

to. Syamsudin Bin Kosim
11. Ujang Hama

 CHARGE SHEET: APPENDIX B
The names of persons who suffered serious bodily injury as a result of the August 5,
2003 attack on the J.W. Marriott

The following people, and others not named below, evidence about whom will be
presented at trial, are persons who suffered serious bodily injury and/or great bodily harm
on August 5, 2003, in or around Jakarta, Indonesia. as a result of the attack on the J.W.
Marriott Hotel:
.

•• •

I_

I_
I_
•
••
.••
•
·.-.
••
.•

I
I-

II

••

;

••

7