Case Document 1-1 Filed 06/18/18 JUN 8 2013 ENTERED IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND av DEPUTY UNITED STATES OF AMERICA - CaseNo. ig/i (EzerH?; V. KHALIL AHMAD AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT AND ARREST WARRANT I, Sean Regan, Special Agent, Federal Bureau of Investigation (FBI) being duly sworn, state as follows: 1. I make this af?davit in support of a criminal complaint and arrest warrant for Khalil Ahmad (hereinafter born January, 1967 for violating Title 18, United States Code, Section (Stalking). Speci?cally, I respectfully submit that AHMAD used electronic communication services or systems of interstate commerce and cellular telephones to engage in a course of conduct to harass and intimidate another person as described herein and in doing so placed that person in reasonable fear of death or serious bodily injury and caused, attempted to cause and reasonably expected to cause substantial emotional distress to that person. 2. I am an ?investigative or law enforcement of?cer? of the United States within the meaning of Title 18, United States Code, Section 2510(7), thatis, an of?cer of the United States who is empowered by law to conduct investigations of, and to make arrests for, offenses enumerated in Title 18, United States Code, Section 2516. I have been a Special Agent with the Federal Bureau of Investigation since October 2007. For the past 10 years, I have worked numerous violent crime matters, including gang and murder investigations, drug investigations, and robberies. Prior to my employment with the FBI, I was a State Trooper with the State Police for over twelve years. Case Document 1-1 Filed 06/18/18 Page 2 of '10 a. I write this af?davit based upon my personal knowledge, experience and training, and other information developed during the course of this investigation including information imparted to me by other law enforcement of?cers. Because this af?davit is being submitted for the limited purpose of establishing probable cause and securing search warrants, I have not included each and every fact known to me concerning this investigation. 4. I know that Title 18, United States Code, Section provides that: Whoever-- (2) with the intent to kill, injure, harass, intimidate, or place under surveillance with intent to kill, injure, harass, or intimidate another person, uses interactive computer service or electronic communication service or electronic communication system of interstate commerce, or any other facility of interstate or foreign commerce to engage in a course of conduct that-- (A) places that person in reasonable fear of the death of or serious bodily injury to [that] person. .. or (B) causes, attempts to cause, or would be reasonably expected to cause substantial emotional distress to [that] person. . .. is guilty of a crime. 5. On May 10, 2018, an individual contacted the Anne Arundel County Police Department (AAPD) to advise authorities that hefshe had information about an individual who wanted to have his wife killed. At the time of this application, the identity of this individual will not be named but is available to testify. For purposes of this af?davit, this reporting individual will be hereafter referred to as ?Cooperator.? 6. Cooperator agreed to meet with AAPD and was interviewed on May 10, 2018 at approximately 1430 hours. Cooperator advised that on Saturday, May 05, 2018, he/she had been contacted AHMAD, who was referred to Cooperator by a mutual third party. AHMAD advised Cooperator that he was currently going thru a divorce and as a result, wife had obtained a protective order from the courts. AHMAD also expressed concern that as a result of the divorce, wife could possibly receive a large amount of money, which could 4/3 Case Document 1-1 Filed 06/18/18 Page 3 of 10 cause ?nancial hardship with AHMAD. Cooperator and AHMAD met several times, prior to law enforcement being noti?ed. During those meetings AHMAD also expressed interest in having Cooperator commit arson on business so that AHMAD could collectithe insurance pay out from the ?re. AHMAD also expressed a second alternative to dealing with his wife in lieu of having her killed. AHMAD wanted to set his wife up to make her look like a terrorist. AHMAD and his wife are originally from a Middle Eastern country. The plan was to place a ballistic vest, ?rearm, bottles of alcohol, and extremist jihad writings in her possession, without her knowledge, and then notify law enforcement to have her arrested. 7. Based upon the information that Cooperator provided, several one party consent recorded control calls were made from Cooperator to AHMAD in the presence of law enforcement. During those recorded calls, the information that Cooperator had provided was con?rmed. The number that Cooperator contacted to communicate with AHMAD was (410) 336.5479. The number was connected to AHMAD via law enforcement databases and on previous law enforcement contacts, AHMAD used this cellular number. I know that a cellular telephone is a facility of interstate commerce. 8. Law enforcement determined that on May 08, 2018, wife had obtained a Final Protective Order ?om the Honorable Lenore R. Gelfman, Judge for the Circuit Court for Howard County. The order is ?led under Howard County case number 000057. The order directs AHMAD (the respondent) not to do the following: The respondent SHALL NOT abuse or threaten to abuse The respondent SHALL NOT contact, attempt to contact, harass (in person, in writing, or by any other means) Case Document 1-1 Filed 06/18/18 Page 4 of 10 The respondent SHALL NOT enter the residence of at 101 10 High Ridge Road, Laurel, Howard County, Maryland 20723. (Residence includes yard, grounds, outbuildings, and common areas surrounding the dwelling.) - The respondent SHALL STAY AWAY from place of employment. 9. Additionally, AAPD learned that on May 01, 2018, a criminal summons was issued for Khalil AHMAD for three counts of violating a protective order (FL.4.509) under District Court case number 0E00676998. The victim listed under the aforementioned case number is The case is currently set for trial on June 21, 2018._ During the controlled meetings and calls AHMAD made numerous statements that he wanted arrested prior to the June court date. In my opinion, AHMAD did not want to be present in court which would result in the court cases being dismissed. 10. AAPD asked for FBl?s assistance in the investigation. Cooperator agreed to make several one party consent face to face meetings with the AHMAD. The meetings were covertly audiolvideo recorded and occurred at 1350 Dorsey Road, Hanover, Anne Artmdel County, Maryland. This location is a restaurant owned by AHMAD. 11. AHMAD moved forward with his plan to make his wife look like a terrorist and have Cooperator burn down business for the insurance money. Additionally, the identity of AHMAD was con?rmed as Khalil AHMAD, via the controlled Video/audio recordings. Also during the controlled meetings AHMAD gave Cooperator $5,000 in United States currency over two separate meetings, as a down payment to have set up to look like a terrorist. That money was subsequently seized by law enforcement and placed into evidence pending the outcome of this investigation. According to C00perator when AHMAD handed him Cr) Case Document 1-1 Filed 06/18/18 Page 5 of 10 the first $3,000 it was in some type of bank envelope when AHMAD produced it from his person. 12. AHMAD also provided Cooperator with a photo of her address, cellular number, home number, and the last two digits to her Maryland license plate number in the two separate meetings. During the controlled meetings, AHMAD also discussed with Cooperator that the day his wife is arrested he would remain at the restaurant the entire time so his video surveillance system in the restaurant captures him during the time frame that his wife is arrested for terrorism. This would provide him with alibi if law enforcement questions him. 13. Throughout the controlled calls and controlled meetings AHMAD and Cooperator spoke in native language and have since been summarized by an FBI interpreter. The calls re?ect that AHMAD also wants Cooperator to make arrangements to burn down the restaurant located at 1350 Dorsey Road, Hanover, Anne Arundel County, Maryland. AHMAD advised Cooperator that he recently had representatives from the businesses insurance company come to the store where he raised the amount of insurance by approximately $200,000. Subpoenas for that information are currently outstanding. Also during one of the controlled meetings, Cooperator and AHMAD walked into the kitchen area of the restaurant to see the hot water heater and gas line to discuss how Cooperator would catch the business on ?re and make it look like an accident. Additionally, AHMAD wanted Cooperator to provide him with a fraudulent passport, for himself and a family member. Actions like these would be consistent with someone attempting to ?ee the country in the event that law enforcement would try and arrest and prosecute him. 14. On June 04, 2018, another audio/video recorded controlled meeting occurred at 1350 Dorsey Road, Hanover, Anne Arundel County, Maryland. At that time, AHMAD gave 55) Case Document 1-1 Filed 06/18/18 Page 6 of 10 Cooperator $2,000 in United States Currency for Cooperator to get a fraudulent passport for AHMAD. AHMAD provided Cooperator with a photocopy of his ?Permanent Alien Registration Car to assist Cooperator with obtaining a fraudulent passport. Also present at the meeting was an individual, identi?ed as Shabbir Ahmed (Ahmed). Investigation revealed that Ahmed is brother. Ahmed also requested that Cooperator provide him with fraudulent immigration forms as he, referring to Ahmed was in need of them. During the meeting, Ahmed took two digital images of his Maryland Driver?s license utilizing the camera on his cellular device. Ahmed then texted the two digital images to Cooperator?s'cellular device. Cooperator provided copies of the images to law enforcement immediately after the controlled meeting ended. 15. AAPD then made contact with (the victim) and advised her of plan including that AHMAD had indicated he wanted to have a third party set her up to make it appear that she was a terrorist. The victim appeared very upset at this information and went on to explain to investigators that her husband had previously threatened to kill her and her brother. She said her brother is currently in Pakistan and AHMAD said he would have her brother killed in Pakistan. The investigators have no information that the victim was a terrorist or engaged in any terrorist activities. The victim also told investigators that AHMAD had been physically abusive to her and had recently threatened to light himself on fire after dousing himself with gasoline in her presence. The victim?s daughter contacted the police when this happened and ultimately this incident led to AHMAD being committed to a hospital for evaluation and a protection order being issued against AHMAD in Howard County, Maryland. 16. On June 5, 2018, investigators staged a scene involving a traf?c stop of the victim?s vehicle and what appeared to be AAPD uniformed police of?cers and detectives [69 Case Document 1-1 Filed 06/18/18 Page 7 of 10 searching the victim?s vehicle on the side of a road. The purpose of the staged search was to provide photographs for Cooperator to show AHMAD as proof that the victim had in fact been arrested. The photographs were of the victim?s vehicle (but not the victim) and were provided to Cooperator who then proceeded with the scheduled controlled meet with AHMAD. 17. At the direction of investigators Cooperator proceeded to the pie-arranged meet location, which was at the Dunkin Donuts in the 1300 block of Dorsey Road in Hanover, Maryland. Cooperator was wired with FBI and AAPD audio/video recording equipment. At the meet location, Cooperator got into rental vehicle and AHMAD proceeded to drive around with Cooperator while FBI and AAPD surveillance units followed AHMAD and Cooperator. Cooperator later related to investigators that while with AHMAD, Cooperator showed AHMAD the staged photographs and told AHMAD that it was done. Cooperator said AHMAD told Cooperator that he would (and did) pay Cooperator $2,000.00 but would pay the remaining $7,000.00 once AHMAD could verify that the victim had actually been arrested. While under surveillance, AHMAD travelled to a bank in Anne Arundel County and entered the bank. AHMAD exited the bank a short time later and got back in the rental vehicle with Cooperator. Inside the rental vehicle, Ahmad paid Cooperator $2000.00 USC and asked for Cooperator to give back the original amount of money AHMAD had just previously paid Cooperator prior to arriving at the bank. Cooperator returned that money to AHMAD but kept the $2000.00 that AHMAD provided to Cooperator. AHMAD also gave Cooperator a small amount of money for gas. 18. AHMAD and C00perator returned to the original Dunkin Donuts parking lot. Cooperator got back in Cooperator?s vehicle, drove to restaurant on the other side of the parking lot, and waited for food to be brought out from the restaurant. Once Cooperator 4s? Case Document 1-1 Filed 06/18/18 Page 8 of 10 received the food, Cooperator left the area and met with investigators. Investigators retrieved the recording devices and the currency from Cooperator?s person and debriefed Cooperator. 19. Later that same date (06/05/2018), AAPD and FBI investigators went to residence to conduct a ruse, informing AHMAD that his wife had been arrested and asking AHMAD if investigators could talk to him about his wife. AHMAD invited investigators into his residence and proceeded to tell investigators that his wife had ?led a protection order against him and that he had a ?le with the information in it. He retrieved the ?le and then sat with investigators in his living room. AHMAD went on to tell investigators about his wife, including telling investigators that his wife would be on the phone at night taking classes about terrorism over the phone. AHMAD also told investigators that his wife attended a terrorist training camp. AHMAD agreed to meet with investigators at AAPD CID so investigators could talk to him more about his wife, his wife?s activities and his wife?s possible associates. 20. AHMAD went to AAPD CID and investigators met with him there. An FBI linguist was present for the interview. AHMAD was provided his Miranda Warnings and the FBI linguist translated same for AHMAD. AHMAD agreed to speak with investigators. He went on to talk to investigators at length about his wife. Later in the interview, investigators confronted AHMAD with recorded video of one of his meetings with Cooperator. Only AHMAD was visible on the portion of the video that AHMAD was shown. He was shown the portion of the video where he took Cooperator?s cellular telephone, held Cooperator?s cellular telephone over top of his own cellular telephone and took a picture of something on his own phone. Investigators know that the picture AHMAD took with Cooperator?s cellular telephone was a picture of a photograph of the victim that AHMAD had in his own cellular telephone. Investigators believe AHMAD took the photograph with Cooperator?s cellular telephone so a) Case Document 1-1 Filed 06/18/18 Page 9 of 10 AHMAD did not have to text or email it to Cooperator, thereby he avoided leaving an electronic evidence trail that AHMAD had provided the victim?s photograph to Cooperator. Cooperator related to investigators that it was during this same controlled meeting that AHMAD provide the victim?s address, vehicle description and last two digits of the victim?s license plate to Cooperator. 21. After being confronted by investigators during the interview, AHMAD admitted to meeting Cooperator through a mutual third party after AHMAD told the mutual third party that he was having problems with his wife-and wanted to make things hard for her. The mutual third party put AHMAD in touch with Cooperator and AHMAD told investigators that he wanted Cooperator to make things hard for his wife and to engage in a romantic relationship with his wife. When investigators confronted AHMAD about the plot to kill his wife and to set her up to look like a terrorist, AHMAD told investigators that those things were Cooperator?s ideas. When investigators confronted AHMAD about the plan he had to burn down restaurant, AHMAD told investigators that plan was Cooperator?s plan. When investigators asked AHMAD if he had raised the amount of money on the insurance policy on his restaurant, AHMAD said he had not and that he did not even have an insurance police on the restaurant because he cancelled it. He later changed his story and said he got another policy after the original police expired or was cancelled. AHMAD ultimately admitted that the new insurance policy was more that the recently cancelled policy by approximately two hundred thousand dollars. This was consistent with what AHMAD had previously told Cooperator relative to AHMAD raising his restaurant insurance policy by approximately two hundred thousand dollars. When investigators confronted AHMAD about his plan to illegally acquire a fraudulent US Passport AHMAD told investigators that C00perator had come up with the plan for AHMAD to acquire the passports. Case Document 1-1 Filed 06/18/18 Page 10 of 10 49,3 22. On June 5, 2018, AHMAD was arrested on related state charges in Anne Arundel County and held without bond following a hearing on June 7, 2018. On June 14, 2018, I learned that a new defense attorney secured release for AHMAD on June 13, 2018 without noti?cation to investigators or the victim. On the evening of June 14, 2018, investigators spent hours attempting to ?nd AHMAD and to re-arrest him on an outstanding warrant out of Howard County for violation of a protective order. Investigators were unable to locate AHMAD. 23. Based upon the foregoing, I submit that there is probable cause to believe that Khalil AHMAD has committed a violation of 18 U.S.C. Accordingly, I respectfully request that the Court authorize the criminal complaint and arrest warrant attached hereto and Respectfu?ubmitted, g. Sean Regan, Special Agent, FBI incorporated by reference. Subscribed and sworn to before me this day of June, 2018: 4' STEPHW GALLAGHER MAGISTRATE JUDGE 10