Case: Doc 1 Filed: 04/27/17 Page: 1 of 21 PAGEID 1 7:1. - .1 11311.1?: 1? ?fl .4 1411?- A0 91 (Rev. 11111) Criminal Complaint It?d? {17:7 [313137-35 UNITED STATES DISTRICT COHRIW 27 lit! 33 for the 5 . ill-?1 12-122,! Southern District othio 1 1 5. 1 United States ofAmerica A: I I: 7 1" V- 3:1. 1. ?1in I- WALEED ALEBBINI case ?13 3 7 MICHAEL J. NEWMAN Defendant(s) CRIMINAL COMPLAINT I, the complainant in this case, state that the following is true to the best of my knowledge and belief. on an exact date that is unknown, but at least by on On or about the date(s) of or about April 26, 2017 in the county of in the Southern District of Ohio and elsewhere the defendant(s) violated: Code Section O?ense Description 18 U.S.C. 23398 Attempt to Provide Material Support and Resources to a Foreign Terrorist Organization This criminal complaint is based on these facts: See attached affidavit if Continued on the attached sheet. Matti/1V o1np1?a1nan1 3135111111,? MichaettiEiweJBl Special Agent . Prmted?d?ge and title Sworn to before me and signed in my presence. Date: 9" City and state: Dayton, Ohio Hon. Michael Newman .3 Magistrate Judge Printag! name 1511111 11113 Case: Doc 1 Filed: 04/27/17 Page: 2 of 21 PAGEID 2 AFFIDAVIT IN SUPPORT OF COMPLAINT I, Michael Herwi g, being ?rst duly sworn, hereby depose and state as follows: INTRODUCTION AND AGENT BACKGROUND 1. I make this af?davit in support ofa Complaint charging LAITH WALEED ALEBBINI with, on an exact date that is unknown, but at least by on or about April 26, 2017, in the Southern District of Ohio and elsewhere, attempting to provide material support and resources to a foreign terrorist organization, in violation of 18 U.S.C. 2339B. 2. I am a Special Agent with the Federal Bureau of Investigation and I have been an agent since March 16, 2008. I have been assigned to the Joint Terrorism Task Force since 2008 and have worked cases involving international and domestic terrorism. 3. The facts in this af?davit come from my personal observations, my training and experience, and information obtained from other agents and witnesses. This af?davit is intended to show merely that there is suf?cient probable cause and does not set forth all of my knowledge about this matter. PROBABLE CAUSE 4. Title 18, United States Code, Section 2339B prohibits, in pertinent part, a person from knowingly providing ?material support or resources to a foreign terrorist organization,? or attempting or conspiring to do the same. 5. The term ?material support or resources? means any property, tangible or intangible, or service, including currency or monetary instruments or ?nancial securities, ?nancial services, lodging, training, expert advice or assistance, safehouses, false documentation or identi?cation, communications equipment, facilities, weapons, lethal substances, explosives, personnel. . ., and transportation, except medicine or religious materials.? 18 U.S.C. Section Case: Doc 1 Filed: 04/27/17 Page: 3 of 21 PAGEID 3 2339A(b)(1) and Section 2339B(g)(4). Section 2339B(h) provides that person may be prosecuted under this section in connection with the term ?personnel? unless that person has knowingly provided, attempted to provide, or conspired to provide a foreign terrorist organization with or more individuals (who may be or include himself) to work under that terrorist organization?s direction or control or to organize, manage, supervise, or otherwise direct that Operation of that organization. Individuals who act entirely independent of the foreign terrorist organization to advance its goals or objectives shall not be considered to be working under the foreign terrorist organization?s direction and control.? 6. On or about October 15, 2004, the United States Secretary of State designated al? Qa?ida in Iraq then known as Jam?at al Tawhid wa?al?Jihad, 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. 7. On or about May 15, 2014, the Secretary of State amended the designation of AQI as an FTO 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 FTO listing: the Islamic State ofIraq and al-Sharn (?ISIS??which is how the TO will be referenced herein), the Islamic State of Iraq and Syria, ad?Dawla al- Islamiyya f1 al??Iraq wa-sh-Sham, Daesh, Dawla al Islamiya, and AI?Furqan Establishment for Media Production. On September 21, 2015, the Secretary added the following aliases to the PTO listing: Islamic State, ISIL, and ISIS. To date, ISIS remains a designated FTO. 8. From my participation in the investigation, including my review of FBI reports and recordings, I have learned the following: Case: Doc 1 Filed: 04/27/17 Page: 4 of 21 PAGEID 4 a. ALEBBINI is a citizen ofthe country ofJordan. He is a legal permanent resident of the United States as of April 8, 2014. Immigration records indicate that ALEBBINI initially arrived in the United States from Jordan on or about July 24, 201 1. He subsequently left the United States, and returned to the United States on or about August 6, 2014, as travel records indicate that ALEBBINI arrived on a ?ight from Amman, Jordan. b. An individual identified herein as also is a citizen of the country of Jordan. He entered the United States on a student visa, which was revoked, and he is currently in the United States illegally. c. ALEBBINI is related to Q.A. and an individual identi?ed herein as all three. of whom were present in the Dayton, Ohio, area at various times as described below. d. On or about January 10, 2017, ALEBBINI was arrested for unlawful entry into the Turkish Embassy in Washington, DC. The charges against ALEBBINI subsequently were dismissed. ALEBBINI refused to say why he was on the property, but he did say ?You are going to regret this? when being escorted off the property. e. On or about January 12, 201 ALEBBIN I attempted to travel to the country of Turkey via Amsterdam with RA, but ALEBBINI was denied entry by Turkey because his Jordanian passport expired. ALEBBINI traveled with only a backpack and did not check luggage. On or about January 15, 2017, ALEBBINI returned to the United States. Case: DOC #1 1 Filed: 04/27/17 Page: 5 0f 21 PAGEID 5 11. On or about January 23, 2017, ALEBBINI was interviewed by the FBI and the US. Secret Service regarding the incident at the Turkish Embassy. During the interview, ALEBBINI admitted posting videos on his Facebook page in the past. ALEBBINI stated: am the perfect recruit for ALEBBINI admitted to supporting desire for a united Middle East, but he said he did not agree with their violence. ALEBBINI claimed he wanted to Speak with the Turkish Ambassador to discuss the conflict in the Middle East. ALEBBINI said the security at the Embassy was very lax, and that ?[i]f1 had a bomb on me, I swear to God, three embassies would have gone down.? ALEBBINI met a woman from Dayton, Ohio, who he claims to be his spouse (identi?ed herein as ALEBBINI and D.E. claimed to have been married in a private ceremony by a man at a mosque, but it is believed they are not married pursuant to any state law or certi?cate. On or about March 1, 2017, ALEBBINI moved to Dayton, Ohio, in the Southern District of Ohio, to be with D.E. From that point in time to the present, ALEBBINI has resided with D.E. in Dayton. From approximately March 3, 2017, to the present, ALEBBINI has had multiple conversations with a Con?dential Human Source in The CHS is a previously convicted felon. He/she was convicted in this Court for a weapons- related offense, as well as for benefit and wire fraud offenses. He/she has completed his/her sentence and is no longer under court supervision. The CHS hopes to receive immigration-related benefits for his/her cooperation. In this case, the FBI has paid the CHS approximately $3,500 to date, approximately $3,000 of which was to reimburse the CH8 for a personal trip that the FBI requested the CH8 cancel (for 4 Case: Doc 1 Filed: 04/27/17 Page: 6 of 21 PAGEID 6 and around Dayton, Ohio. At times, and as described below, Q.A. and/or R.A. were present for the discussions.2 i. 011 or about March 7, 2017, the CH8 met with ALEBBINI, R.A., and Q.A. During the consensually recorded conversation, ALEBBINI discussed the Jordanian pilot who was burned to death by ISIS.3 Q.A. stated: ?one who burns by ?re will be burned by it.? ALEBBINI further stated that he watches ISIS videos and said that ISIS follows the ?prophet,? which is proven by its success on the battle?eld. R.A. expressed similar sentiments. j. On or about March 9, 2017, the CH8 again met with ALEBBINI, RA, and Q.A. During the consensually recorded conversation, ALEBBINI complained about the politics of Jordan and its leaders. ALEBBINI stated he followed the news of ISIS through ?Amaq? and ?Dabiq? magazines online.4 R.A. said he read that a person was arrested after booking a one? way ticket to Turkey. R.A. also stated polls show that 98% of the Arab purposes of this case), and approximately $500 in reimbursement for other expenses incurred. In total, over the course of his cooperation in all cases, the FBI has paid the CH8 approximately $18,500. 3 Most of the conversations summarized below were conducted in the Arabic language. The summaries of, and quotes from, the conversations refer to preliminary translations provided by FBI translators. References to ?Dawla,? the ?State,? or the ?Islamic State? are interpreted as referring to ISIS, which is the FTC defined above. 3 Your af?ant is aware that ISIS publicly released a video ofa Royal Jordanian Air Force pilot who was captured and burned to death by ISIS members after his aircraft crashed in or around Raqqa, Syria, on December 24, 2014. 4 Dabiq Magazine is an online magazine published by ISIS. Amaq is an ISIS media outlet. 5 Case: Doc 1 Filed: 04/27/17 Page: 7 of 21 PAGEID 7 world supports ISIS. The group discussed what countries and groups support ISIS and how ISIS is recruiting people and obtaining weapons. At one point, ALEBBINI said: ?You need a regime like the regime right now. They come to exterminate the old regime. They don?t leave anyone.? ALEBBINI stated his Facebook account was disabled after he posted videos. ALEBBINI said: ?Allah willing, when comes, it will cut offthe head of King Abdullah. Then it will go to free Palestine. Things will be back to normal.? At urging, the four individuals watched a video on YouTube that was titled: ?The Islamic State, A to in 15 minutes.? k. On or about March 12, 2017, the CHS again met with ALEBBINI, R.A., and Q.A. During the consensually recorded conversation, ALEBBINI stated Jordan would eventually become part of ISIS. Q.A. made a statement regarding a Jordanian soldier who was recently released from prison after murdering 7 Israeli girls in 1997. Q.A. stated: ?to Hell with them, let him shoot them,? while RA. stated the murders were not justi?ed. 1. On or about March 16, 2017, RA. traveled from the United States to Amman, Jordan. He purchased a one?way ticket on the same day of his travel. RA. arrived in Jordan on or about March 17, 2017. m. On or about March 19, 2017, the CHS met with ALEBBINI and QA. During the consensually recorded conversation, the CHS claimed to have legal problems and to be facing deportation. QA. stated that the CHS 6 Case: Doc 1 Filed: 04/27/17 Page: 8 of 21 PAGEID 8 should go to ISIS. ALEBBINI agreed that the right thing was to go to ISIS, even ifthe CHS did not go there to ?ght. Q.A. and ALEBBINI both spoke ofthe bene?ts ofliving within borders, including cheap rent. The CHS said he was not aware of that until he saw the propaganda video. ALEBBINI stated he watches ISIS videos all the time and they are the ?right group.? He further stated he heard that ISIS and Syrian opposition groups were close to the border with Jordan. ALEBBINI stated that his father told him that ISIS would enter Jordan soon. When the CH8 asked how to get to ISIS, ALEBBINI advised that he should travel through Turkey, speci?cally Gaziantep, a border city in Turkey. ALEBBINI further stated to the CH8 that ISIS would welcome the CH8 and not force him to fight. ALEBBINI stated to the CHS that he (ALEBBINI) would not tell anyone about their conversation (referring to their March 19, 2017 conversation). ALEBBINI also advised that they should hide their phones in another room, or talk in a car without the presence of phones, when they meet to talk about this tOpic. Later, ALEBBIN I stated that the right place to be, from a religious point ofview, is with ISIS. ALEBBINI said that he went to a mosque and found anti?ISIS literature being distributed, and that ALEBBINI took the brochures to his car and then threw them in a garbage can. n. Later that night, on the evening of March 19, 2017, the CH8 again met with ALEBBINI and Q.A. at residence. During the consensually recorded conversation, ALEBBINI and Q.A. suddenly were 7 Case: Doc 1 Filed: 04/27/17 Page: 9 of 21 PAGEID 9 cautious about what was discussed in front of the CH8 and appeared guarded with the CH8. During the meeting, ALEBBINI and Q.A. made statements that were less supportive of ISIS and the idea of traveling to join ISIS. o. The CH later learned that D.E. mistakenly told ALEBBINI that the CH8 was a US. citizen, which made ALEBBINI suspicious ofthe CHS as potentially working with law enforcement. p. On March 21, 2017, the CH8 met with ALEBBINI and Q.A. During the consensually recorded conversation, the CH8 confronted them about their suSpicions. ALEBBIN I acknowledged they were mistaken about citizenship status and apologized to the CH8. q. On or about March 22, 2017, the CH8 had a consensually recorded phone call with ALEBBINI. During the call, ALEBBINI turned down an offer to do yard work for the CH8, claimed that he had received his tax return, and stated he would be ?ying back to Jordan in one week. r. On or about March 27, 2017, the CH8 met with ALEBBINI at residence. The conversation was consensually recorded. The CHS had brought a phone to ALEBBINI purportedly for the purpose of having ALEBBINI deliver the phone to one of the family members in Jordan. In addition: 1. ALEBBINI stated RA. is not staying in Jordan; rather, he was going to get married and then move with his wife. ALEBBINI then Case: DOC #1 1 Filed: 04/27/17 Page: 10 0f 21 PAGEID 10 ii. iv. vi. stated they were in the ?implementation phase? and that his own wife, D.E., knows what is being planned. ALEBBINI said he will be leaving in one week on a train from Cincinnati to Virginia. ALEBBINI said: ?They want us to fight them. They wish that we come down to the ground. . . The situation is not easy. . . They also thinking that Arabs are sheep and do not realize that is really I happening and that the resistance is growing and they are feeding it, and the people want their freedom, and they want one country, and one decision.? He later added, ?The best choice is the Islamic State, best choice for the Muslims. The Islamic State and the Mujahid in Syria.? He also decried that there was a heinous war being waged on ISIS. ALEBBINI also stated that he will throw away his Permanent Resident ?Green Card? one day, because he believes he was living amongst apostates who kill Muslims and that it will be used against him on judgment day. ALEBBINI stated he wanted to follow RA. and there was a good chance that Q.A. would follow too. He said he would go and make sure the ?group? is right ?rst, seemingly referring to the prior discussion of ISIS. ALEBBINI spoke at length about ISIS and the perceived righteousness of 1818?s activities. ALEBBINI then added that he 9 Case: DOC #1 1 Filed: 04/27/17 Page: 11 0f 21 PAGEID 11 would rather stay 10 years in prison than 1 year in America. If he became a prisoner, ALEBBINI stated he could at least say that he tried to support the cause, but he was prevented from doing so. He further lamented that others are going to fight for ISIS, ?while we are sitting here.? vii. At the end of the meeting, ALEBBINI reiterated that, like he told Q.A., ALEBBINI will be the ?rst to go ?look for a way and see what the story is. . . If anything happen to me, you see and learn. If nothing happen to me and group turns out to be right, on the phone . . . and then you spread . . . Anticipate that there will be a call.? ALEBBINI stated the CH8 should go through Turkey because he has no interest in Amman. ALEBBINI, however, stated he will go to Jordan and see family that lives in lrbid, a town that is near an ISIS border. The CI-IS asked ALEBBINI ifhe is afraid about being questioned when he goes over the border (presumably to ISIS). ALEBBINI said no because ?Abu Bakr al?Bhagdadi called.?5 5. On or about March 28, 2017, the CHS and ALEBBINI met for breakfast. During the consensually recorded conversation, ALEBBINI received a phone call. ALEBBINI went outside to speak on the phone. demeanor changed after his return. 5 Abu Bakr al-Bhagdadi is the claimed leader of ISIS. 10 Case: Doc 1 Filed: 04/27/17 Page: 12 of 21 PAGEID 12 t. Later that same day (March 28, 2017), the CH8 and ALEBBINI went ?shing. During the consensually recorded conversation, ALEBBINI told the CH8 that he learned RA. had been arrested by Jordanian authorities. ALEBBINI believed that the arrest occurred because there was a meeting of Middle Eastern leaders in Jordan, so the authorities were arresting a lot of people. ALEBBIN I also said he believed the Jordanians must have received information about RA. from the United States, or from videos that R.A. might have watched. 11. On or about March 29, 2017, ALEBBINI met with the CH8 for approximately 77 minutes. During the conversation, which was consensually recorded, ALEBBINI and the CH8 discussed travel plans, including his plans to travel by train to Washington, DC. ALEBBINI then intended to travel from Washington, DC, to Jordan, where he could continue to Syria and ?ght with ALEBBINI indicated his plan was to leave at approximately 3:00 am. on Friday morning, the context indicating that he was referring to Friday, March 31, 2017. ALEBBINI indicated that his family knows that he (ALEBBINI) wants tojoin ISIS, but that his family is against himjoining ISIS and, for that reason, took his passport. v. ALEBBINI indicated that when he joins ISIS, it will be to please God. They ended the conversation with a discussion of intentions regarding his travel overseas, with ALEBBINI indicating that his intention was to ?ght with ISIS for the purpose of ?ghting against the II Case: DOC #1 1 Filed: 04/27/17 Page: 13 0f 21 PAGEID 13 Syrian leadership. ALEBBIN I explained: ?Our duty is to support the Islamic State. Those are the words, what is your duty? Jihad. A person is supposed to stay away from the people of sins . . . and what happens, happens . . . caught? Let them arrest you, then, let them arrest me. This is the true conversation.? w. Consistent with the conversations above, information from Amtrak con?rms that ALEBBINI obtained a ticket to travel by Amtrak train from Cincinnati, Ohio, to Washington, DC, departing on March 31, 2017, at approximately 3:30 am. x. Based on physical surveillance, it is believed that ALEBBINI did not leave his residence overnight, and he did not board, or otherwise travel on, the above?mentioned scheduled train. y. On or about April 3, 2017, ALEBBINI met with the CH8 for approximately 40 minutes. Q.A. joined them after the ?rst 20 minutes of the meeting. During the consensually recorded conversation, ALEBBINI stated that he got into ?100 argument? with his cousins because he told them he ?will be going down to Jihad?. The CHS asked ALEBBINI: ?Okay, what happened to the ticket your brother booked for you?? responded: ?We canceled that one. Because I wanted to go there, now the passport is with me.? ALEBBINI further stated that he let his cousin know his intentions, so if he is arrested by the Jordanian of?cials, his family ?can see what they can do to take me out.? ALEBBINI stated that he told his cousins that ?my wife will [be] coming 12 Case: DOC #1 1 Filed: 04/27/17 Page: 14 0f 21 PAGEID 14 to Jordan and raise my son there. die, she does not want to be divorced in America, she decided to come to Jordan.? ALEBBINI stated: ?Because. . . to be honest, before I was planning anything, I decided to go ?ght in Jihad, the same way Umar Ibn al?Khattab did.? ALEBBINI instructed the CH8 that the best plan for travel is to book a Turkish airline ?ight to Jordan going through Turkey. Then, during the layover in Turkey, instead of boarding the ?ight to Jordan, ?you take yourself and leave?. ALEBBINI later stated: do not have money, I swear, from where can I The responded: told you we will manage the situation. This is not a problem.? ALEBBINI stated: ?We will manage the situation, okay, we will manage the situation, that is to say, til now I want to support ALEBBINI later stated: . . . I was planning if I go there, I do not want to just support ?ghting the oppressors, we want to ?ght with weapons, with tongue, and we want to protect the Muslims.? Later during the meeting, an unidenti?ed male?who ALEBBINI referred to as his cousin and to whom ALEBBINI was communicating with via audio text in the presence of the CHS?could be heard on the phone quoting the ISIS motto ?remaining and expanding, God willing", and saying that he (the unidenti?ed male) will be looking for ALEBBINI when he comes and to not fear or hesitate. ALEBBINI stated that even if hejoins Al-Dawlah (ISIS) and only ?res a couple shots before he is killed, it would be good, because he would be inciting the faithful. Case: DOC #1 1 Filed: 04/27/17 Page: 15 0f 21 PAGEID 15 aa. bb. On or about April 4, 2017, ALEBBINI met with the CH8 for approximately 10 minutes. During the consensually recorded conversation, ALEBBINI and the CH8 discussed airline ?ights on Turkish Airlines. The CHS asked ALEBBINI if he wanted to travel together. ALEBBINI stated that he would like to do so, but ALEBBINI expressed concern that if they go together, he does not want anything bad to happen to the CH8. ALEBBINI went on to state that the CH8 could decide, but ALEBBINI would be going, with or without the CH8. ALEBBINI then asked the CH8 for a loan, because he did not have the money for a ticket. ALEBBINI stated he had asked his cousin for help the day prior, but his cousin told him to forget about it. ALEBBINI stated he would ?write a paper,? and if he died, his cousins or his brothers would pay his debt. On or about the evening of April 4, 2017, the CH8 met with ALEBBINI and Q.A. at their residence. During the consensually recorded conversation, the CH8 brought up their conversation from earlier in the day and began to ask ALEBBINI ifhe was sure about the plan. ALEBBINI changed the subject and stated that family had received news that R.A. would be released soon from jail in Jordan. ALEBBINI stated that family had received this information from a high-ranking Intelligence Services of?cer. On or about the evening of April 6, 2017, the CBS met with ALEBBINI and Q.A. at their residence. The conversation was consensually recorded. 14 Case: DOC #1 1 Filed: 04/27/17 Page: 16 0f 21 PAGEID 16 CC. During a discussion of the Islamic State and the current conflict in the Middle East region, ALEBBINI contrasted the defeat in Palestine to the resistance in Mosul and said that the Islamic State has been holding steadfast against attacks from US, Russia, Shi?ites, and Arab nations. Q.A. stated that the Islamic State has not been holding off anyone and asked ifthe United States is incapable of beating the Islamic State. ALEBBINI screamed in response, and stated that the United States is incapable and asked who forced the United States to leave Iraq. ALEBBINI then said that the Islamic State has weapons now and is wreaking havoc, and that the Islamic State has built a complicated tunnel system. On or about the evening of April 8, 2017, the CH8 met with ALEBBINI and Q.A. at their residence. During the consensually recorded conversation, ALEBBINI discussed how R.A. was currently in jail in Jordan, and ALEBBINI explained that he believed R.A. would tell Jordanian of?cials that he and ALEBBINI had watched videos, got foolish and wanted to go to the Islamic State. ALEBBIN I added that the Jordanian officials knew that RA. wanted to go to the Islamic State when RA. started to ask about the matter of how to get there. Later in the meeting, ALEBBINI discussed a statement issued by the Islamic State, addressed to Jordan, vowing to come for King Abdallah, and how the Islamic State beheaded four Syrians who were trained by the Jordanian government. ALEBBINI also explained that many Jordanians were 15 Case: DOC #1 1 Filed: 04/27/17 Page: 17 0f 21 PAGEID 17 66. dd. joining the Islamic State and that the Jordanian government would not be able to handle it when its citizens returned to Jordan from Syria. Later in the conversation, Q.A. stated to the CH8, ?When Laith and go, go, go, go, to be honest I was planning to go with them. I am supposed to go ahead of them. That was the intention. But I divorced and problems happenedf? On or about the evening of April 18, 2017, the CH8 met with ALEBBINI and Q.A. During the consensually recorded conversation, ALEBBINI stated his father would not purchase a ticket for him to travel to Jordan, and ALEBBIN I asked whether the CH8 would give him money for a ticket. The CI-IS suggested that ALEBBINI get a credit card, or a loan from Q.A. or someone else, and the CH8 could pay off the debt after ALEBBINI left the United States. ALEBBINI discussed the Islamic State and how 4,000 persons from Jordan were ?ghting with the Islamic State. ALEBBINI stated, ?My goal is my goal is not to gojust to Al? Dawlah (ISIS). My goal is to be active in Al?Dawlah (1818).? On or about March 2, 2017, the FBI contacted ALEBBINI by phone after learning that former residence in Virginia had been vacated. During the phone interview, ALEBBINI con?rmed that he had moved from Virginia to Dayton, Ohio, and he provided his new address to the FBI. ALEBBINI told the FBI that he would be receptive to a follow?up interview, in person, if necessary. The FBI did not thereafter seek to contact however, on Saturday, April 15, 2017, ALEBBINI 16 Case: DOC #1 1 Filed: 04/27/17 Page: 18 0f 21 PAGEID 18 contacted the FBI about the status of the Bl?s investigation and asked about his ability to travel overseas. The FBI returned call and left a voicemail telling ALEBBINI that the investigation did not prohibit ALEBBINI from traveling. On or about the evening of April 18, 2017, ALEBBINI told the CH8 about his contact with the FBI. ff. On or about the evening of April 19, 2017, the CH8 met with ALEBBINI. During the consensually recorded conversation, the CH8 asked ALEBBINI how much money he needed and ALEBBINI stated that he only needed enough for his ticket. With prior approval from the FBI, the CH8 stated that he would give the money to DB. as a bonus.6 ALEBBINI said he was going to book the cheapest ?ight and stated that he was ready to travel. ALEBBINI indicated that he would book a ?ight from Cincinnati to Chicago, and then from Chicago to Jordan. ALEBBINI stated that if he was unable to get into Turkey, he would go to Jordan, and from there, his father could help him. ALEBBINI added that once he entered Jordan, he would not remain in his father?s home until he is arrested, instead, he would ?ee to Sal (a village in northern Jordan). ALEBBINI suggested that he might be arrested at the airport. gg. On or about April 21, 2017, the CH8 met with DB, who stated that family was now unwilling to purchase a ticket for DE. 6 DE. has been employed at a business operated by the CH8 since on or about March 16, 2017. DE. had been employed by the CH8 at the same business in prior years. 17 Case: DOC #1 1 Filed: 04/27/17 Page: 19 0f 21 PAGEID 19 hh. 11- With prior approval from the FBI, the CH8 discussed with DB. a bonus of $1500, to be used to purchase two tickets on Turkish Airlines. The conversation was consensually recorded. On or about April 22, 2017, the CH8 met again with DB and, with prior approval from the FBI, gave D.E. $1500 (which funds the FBI provided). The CHS cautioned D.E. to not discuss the money with anyone because of what ALEBBINI was planning to do traveling for the purpose of joining ISIS). D.E. acknowledged this and agreed. The conversation was consensually recorded. On or about April 24, 2017, the CH8 met again with DB During this meeting the CH8 gave D.E. her final wages for her work, which included pre?payment for her scheduled hours on April 25, 2017. The CHS also gave D.E. a bonus of $200, as a going?away bonus for being a good employee. The CHS previously gave similar bonuses to DB. and other employees in the past. On or about April 25, 2017, the CH8 met again with DB. During the meeting, DE. stated, ?And I know whatever happens, I know 1 say. . .we?re going together, uh, I don?t know, but I know there are gonna be questions.? D.E. then stated, ?When Laith gets, cause he?s not going to Jordan.? D.E. then stated, ?If they do though, I know I am supposed to ask for the Embassy, right? Yeah, that?s the first thing I do, if I?m questioned, I will, talk to the Embassy. But if they do, I don?t know nothing, I just, we planned on going together and then he just disappeared. 18 Case: DOC #1 1 Filed: 04/27/17 Page: 20 0f 21 PAGEID 20 If I am questioned.? The CHS then stated: ?yeah if he gets down in Turkey, what are you going to tell them?? D.E. responded: ?Mmm, hmm, that 1 don?t know, like, we booked the tickets together and you D.E. then stated that she would tell them that he watched YouTube videos. The CHS then asked D.E. if ALEBBINI told her to say that. D.E. responded, Yes.? 9. On or about April 24, 2017, 1 received information from the United States Department of Homeland Security showing that tickets have been issued in the name of ?Lath Alebbini? and in name for travel as passengers on flights from and to the following locations on the following dates: (1) from Cincinnati?Northem Kentucky International Airport to Chicago O?Hare International Airport on April 26, 2017 (Turkish Airlines Flight 9576 operated by United Airlines under Flight 1560); (2) from Chicago O?Hare International Airport to Ataturk International Airport (Istanbul, Turkey) on April 26, 2017 (Turkish Airlines Flight and (3) from Ataturk International Airport to Queen Alia International Airport (Amman, Jordan) on April 27, 2017 (Turkish Airlines Flight 812). Records indicate that the tickets were purchased using a Visa card under name, and that the purchaser provided a telephone number and email address associated with DB. in connection with the reservation. 10. On or about April 26, 2017, at approximately 2:00 pm, ALEBBINI and DE. left their residence and traveled to the Cincinnati/Northem Kentucky International Airport. relative drove them to the airport. ALEBBINI and DE. proceeded to the United Airlines ticket counter, where they obtained their boarding passes. After ALEBBINI obtained his boarding passes and walked towards TSA security, law?enforcement of?cers arrested him. Law- enforcement of?cers advised ALEBBINI of his Miranda rights after his arrest. 19 Case: Doc 1 Filed: 04/27/17 Page: 21 of 21 PAGEID 21 11. Law?enforcement of?cers subsequently sought to interview ALEBBINI at of?ce in Cincinnati. The interview was video and audio recorded. ALEBBIN I once again was advised of his Miranda rights. ALEBBINI expressed an understanding of his rights and agreed to speak with law-enforcement of?cers. He signed a Miranda?waiver form. During the interview, ALEBBINI admitted that he intended to travel to Turkey and then join and ?ght for ISIS. 12. Based on the foregoing, I believe there is probable cause to believe that on an exact date that is unknown, but at least by on or about April 26, 2017, in the Southern District of Ohio and elsewhere, ALEBBINI attempted to provide material support or resources to a foreign terrorist organization, in Violation of Title 18, United States Code, Section 23398. ReSpectfully submitted, NJ Michael H?rwig Special Agent, FBI Subscribed aw before me on April 27, 2017 925% \5/3 4 1 Hon. Wire aeLI Newmaii I go) 't ?t Jud n1 ?xes Mang 1?3 e? 20