FILED IN CHA$IBERS

United States District Court
NORTHERN DISTRICT OF GEORCIA

JAN

I!

U.S.

N.D.GEORGiA

UNITED STATES OF AMERICA

CRIMINAL COMPLAINT
Number: 1:19-M]-33

Case

HASHERIALLAL TAHEB

I, the undersigned complainant being duly sworn, state the following is true and correct to the best of my
knowledge and belief. On or about January 1,6,2079 in Gwinnett County, in the Northern District of
Georgia, defendant did, attempt to damage or destroy, by means of fire or an explosive, a building or real
property in whole or in part owned or possessed by, or leased to, the United States, that is: the \z\rhite
House, in violation of Title 18, United States Code, Section 844(0(1).
I further state that I am an FBI Special Agent and that this complaint is based on the following facts:
PLEASE SEE ATTACHED AFFIDAVIT

Continued on the attached sheet and made

a

part hereof. Yes

Signature of

Tyler

S.

Krueger

Based upon this complaint, this Court finds that there is probable cause to believe that an offense has
been committed and that the defendant has committed it. Swom to before me, and subscribed i. *y
Presence
Tanuary 76,2079

Atlanta, Georgia
City and State

Date

ALAN

at

J.

BAVERMAN

UNITED STATES MAGISTRATE JUDGE
Name and Title of Judicial Officer
AUSA Ryan K. Buchanan

Signature of

J

Officer

 n

AFFIDAVIT OF FBI SPECIAL AGENT TYLER S. KRUEGER
I, Tyler S. Krueger, being duly sworn, state the following:

AGENT BACKGROUND

1. I am a Special Agent with the Federal Bureau of Investigation. I have
been so employed since August, 201,4. I am currently assigned to the

Federal Bureau of Investigation (FBI) Atlanta Field Office and
responsible for investigating international terrorism activity. As part
of these investigations,I have participated in physical surveillance,

worked with informants, conducted interviews, served subpoenas, and
executed search warrants. Prior to that, I was employed as an

Intelligence Analyst with the Federal Bureau of Investigation for
approximately six years, during which time I researched and analyzed
intelligence related to counterterrorism matters.

2.

The facts set forth in this affidavit are based upon my personal

observations, my training and experience, and information I obtained

from various law enforcement agents and others. Because this affidavit
is being submitted for the limited purpose of establishing probable
cause, I have not included in this affidavit every detail of every aspect

of the investigation. Rather, I have set forth facts that I believe are

sufficient to establish probable cause in support of an application for

criminal complaint and arrest warrant for Hasher Jallal Taheb, for

a

a

violation of Title 18 U.S.C. S 844(0(1), attempt to damage by means of
explosive any building owned, possessed, or leased by the United

 States or any department or agency thereof, or any institution or
or ganization receiving Federal financial assistance. Unless specifically

indicated otherwise, all conversations and statements described in this

affidavit are related in substance and in part only.
STATEMENT OF PROBABLE CAUSE

3. In or about March

201,8, a

member of a local law enforcement agency

contacted the FBI and reported that a community member had relayed
concerns about Taheb to the local law enforcement agency.

Particularly, the community member noted that Taheb had become
radicalized, changed his name, and made plans to travel abroad.

4.

On or about August 25,2078, Taheb advertised his vehicle for sale,
after which an FBI Confidential Human Source (CHS #1) said he was

interested in purchasing Taheb's vehicle. On or about September 2,
2078, Taheb met an FBI Undercover Employee (UCE #1) for the same

reason.

5. On or about October

28,2078, Taheb met with CHS #1 in Cumming,

Georgia. Taheb advised CHS #1 that he (Taheb) planned to travel
overseas for

"hijrai'l

and planned to sell his car to fund his

travel. In

or about ]uly 2018, Taheb had applied for a United States passport and
said that his previous passport had been misplaced. Because he had
no passport, Taheb could not travel abroad, and he advised CHS #1
that he wished to conduct an attack in the United States against targets

Based on my training and experience, and information from other agents, I know that "hijra" is a term used
refer to traveling to territory controlled by the lslamic State.
1

2

to

 such as the White Flouse2 and the Statue of Liberty. Taheb advised
CHS #1 that jihad was the best deed in Islam and the peak of Islam.
Taheb further stated that it was not complicated at all to do jihad

today.

6. On or about December 2,2018,

Taheb arranged a meeting with CHS #1

and UCE #1. During the meeting, Taheb advised that if they were to
go to another country, they would be one of many, but

if they stayed

in the United States, they could do more damage. Taheb explained that
jihad was an obligation, that he wanted to do as much damage as
possible, and that he expected to be a "martyr," meaning that he
expected to die during the attack.

7. On or about December 7,2078,

Taheb met UCE #1 in Alpharetta,

Georgia. While seated in UCE # 1's vehicle, Taheb showed UCE #1

a

hand-drawn diagram of the ground floor of the West Wing of the
\zVhite House

in Washington, D.C. Taheb's drawing of the floor plan

layout was in a composition notebook. Taheb referenced his drawing

during the meeting and described his plan for attacking the West Wing
of the White House. During the meeting, Taheb told UCE #1 that
Taheb would be the leader of their "iamaat,"e which is comprised of
Taheb, UCE #1 and CHS #1. Taheb tasked UCE #1 with obtaining

weapons and explosives needed to conduct the attack.

part owned and
The White House, located in Washington, D.C., is a building and real property in whole or in
possessed by the United States.
jamaat as a group of
3
Based on my training and experience, "jamaat" means a group and Taheb further defined

2

three or more.

3

 8. On or about December7,201.8, Taheb and UCE #1 discussed selling or
exchanging their cars for weapons and explosives. They also
discussed the types of weapons and explosives Taheb wanted to use to

conduct the attack.

9.

On or about December 7 ,2018, Taheb noted that if he sold his car now,
there would be a lot of suspicion from his family,but if they were in

the final stage of their plan, then he would not mind selling

it. Taheb

added that he also believed CHS #1 would sell his vehicle. Later,
Taheb added, "at this point, since it is the three of us, it would be

considered a martyrdom operation." He said the group would fight to
the end and make it a big bang.
10.

On or about December 9,201.8, Taheb texted UCE #1 and asked,
".

.

.How's grocery shopping?" 4 UCE # 1 replie d,

"

.

..I made initial

contacts. Just getting started. I'm gonna need to go down to Columbus
at some point to keep up the shopping momentum..." When UCE #1
asked Taheb how "game day planning" \ /as going, Taheb replied, "It's

coming along well..." and offered to go with UCE #L to Columbus,
Georgia, to pursue the weapons and explosives Taheb had tasked UCE
#1 to obtain.
11.

On or about December 74,2018, UCE #1 met with Taheb in Cumming,
Georgia. Taheb broadened his prospective targets in the Washington,
D.C. area and indicated he wished to attack the Washington

Monument, the \Mhite House, the Lincoln Memorial, and a specific

4

Your affiant understands that "grocery shopping" refers to UCE #1's efforts to procure weapons

4

 synagogue. Taheb again brought hand-drawn sketches of the \zVhite
House to the meeting. Taheb again outlined the types of weapons he

wished to use in the attacks, including semi-automatic weapons,

improvised explosive devices, an AT-4,s and hand grenades. Taheb
stated to UCE #1 that he (Taheb) may have another source from which
he could obtain weapons. Also during this meeting, Taheb discussed
the need for a base and stated that it would allow them to regroup and

give them a place for Taheb to give a speech to motivate people.
Taheb wanted the base to be a place to allow for the recording of a

video. He stated he would be the narrator, clips of oppressed Muslims
would be shown, and American and Israeli flags would be burned in
the background. Taheb stated that he created a channel on a video-

sharing website to post the video before the actual attack happened.

After the meeting, Taheb and UCE #1 began communicating via an
encrypted peer-to-peer social media messaging application.
12.

On or about December 14,2018, Taheb, using the social media
messaging application noted above, sent UCE #1 a link to a document
on Google Docs. UCE #1 downloaded this document, authored by
Taheb. The file name was, in part, named "Ghurabah"6 and the

document was 40 pages long. The document, authored by Taheb,

included the importance of jihad, specifically "defensive jihad," which

s

An AT-4 is a shoulder-fired anti-armor weapon.

6Basedonmytrainingandexperience,ghurabahisanArabicwordforstrangerorforeigner. Youraffiant
understands that foreign jihadis who travel to fight often call themselves "ghurabah."

5

 Taheb noted was his justification for creating and leading his group to

conduct violent attacks.
13. On or about December 15,201.8, Taheb created a group chat on the
social media messaging platform noted above and added UCE #1 and
CHS #1 to the group. Taheb, UCE #L, and CHS #1 began

conununicating via group conversation beginning on or about
December 15,2078.
14.

On or about December 17,201.8, Taheb sent the social media messaging
group a link to a lecture by Anwar al-AwlakiT regarding lessons from
former "Mujahideen."8

15.On or about December 19,2078, UCE #1, using the social media
messaging application noted above, provided the pricing for the
weapons and explosives in which Taheb had expressed interest.
16.

On or about December 25,20L8, Taheb, using the social media
messaging application noted above, relayed to UCE #1 the necessity

for action. UCE #1 responded that they are blessed to be in

a

position

to take action. Taheb replied, in part, "Yery soon inshallah..."e
17.On or about December 28,2078, UCE #1 asked Taheb, via the social
media messaging application noted above, if the other brothers were

still thinking about the "requirement for action." Taheb responded

7

Anwar al-Awlaki was an lslamic lecturer and a leader of Al-Qaeda in the Arabian Peninsula ("AQAP"), a Yemenbased designated foreign terrorist organization that claimed responsibility for terrorist acts against targets in the
United States, Saudi Arabia, Korea, and Yemen since its inception in January 2009. Pursuant to a Presidential
Executive Order, al-Awlaki was designated by the United States as a "Specially Designated Global Terrorist" on July
12,2O1O. Al-Awlaki was killed in Yemen in September 2011.
8
Based on my training and experience, mujahideen refers to Muslims who proclaim themselves warriors for the
faith.
e
Based on my training and experience, inshallah is an Arabic word meaning, "God willing."

6

 with, "Please give about

2 weeks inshallah. Then after we can go on

our trip inshallah.Mry Allah allow us, support us, provide for us, and
protect us." Taheb also asked, "FIow long would it take for groceriesl0
to arrive?" to which UCE #1 responded "About a week after we make
the order."
L8.

On or about January 1, 2019, Taheb, using the social media messaging

application noted above, asked how many "lbs" followed by a potato
emoji. UCE #1 responded that each "potato" would fit inside a
backpack and that they would have to provide the backpacks.it Taheb
answered, "Okay just wanted to know how far the cooking oil spreads

when the fries are cut."12 Taheb also stated they were definitely
buying. On or about ]anuary 2,2019, Taheb, using the social media
messaging application noted above, sent links to the group for military
and assault backpacks, notating with the comment, "these are cool lol."
19.

On or about  anuary 4, 2079, Taheb used the social media messaging

application noted above to ask if the waiting period for the "groceries"
was a week, which UCE #1 affirmed.
20. On

or about January 6,2079 , Taheb used the social media messaging

application noted above to tell UCE #1 that he would "...definitely
give you the list tomorrow...." On or aboutJanuary 7,2019, Taheb
sent a list containing "x3 arrows =1500", "x3 flaming potatos [sic] =

10

Your affiant understands this to mean that Taheb was using the code word "groceries" when referring to
weapons and explosives that Taheb tasked UCE #1 to procure.
11
Your affiant understands this to mean Taheb was using the code word "potato" when referring to the ordered
explosives.
12
Your affiant understands this to mean Taheb wanted to know the bomb blast radius when asking how far the
cooking oil spreads when the fries are cut.

7

 3000", artd "x1, spicy pepper

- 2000".t3 In response to UCE # 1 asking

if the spicy pepper goes flying, Taheb responded that it does and
"You'llhave the honor...." Taheb asked if everything could ship
within

a week, to

which UCE #1 answered about a week to ten days.

Taheb asked where the "recipes"14 would be exchanged and UCE #1

responded that it would be in a parking

lot.

Taheb said he was low on

cash and wanted the exchange to happen closer to Alpharetta, Ceorgia.

Taheb also said they needed to arrive early so they could get a rental

(vehicle). UCE #1, informed Taheb everyone needed to provide a
backpack, and Taheb said he would look to see if he had two

backpacks. Taheb asked, "If I bring a duffle would they put more in or
the same amount as a regular backpack?" Taheb also asked UCE #1

when UCE #1 could pick up the bags.
21,.On or about January 7 , 2019, when asked by UCE # 1 about the sequence

of events, Taheb, affirmed that the plan was to pick up the groceries
and go straight to the road

trip. Taheb added, "We can go sightseeing

and then the main event on Thursday. . . ."
22.On or about  anuary 9,2079, Taheb met with UCE #1 and provided

UCE #1 with two backpacks, specifically one black backpack and one
black and gray backpack. Taheb again discussed his attack plan against
the White House, including martyrdom. Taheb stated that he wanted to

obtain the weapons on or about January L5,2079, travel to Washington,
13

Your affiant understands that Taheb was using the code word "arrow" when referring to semi-automatic rifles
and "spicy pepper" when referring to the AT-4.
1a
Your affiant understands that Taheb was referring to the exchange between the weapons and vehicles when
asking where the "recipes" would be exchanged.

8

 D.C., and conduct the attack on or about January 17,2079. After

providing UCE #1 with the backpacks, Taheb asked, "how do you . . .
detonate them?" UCE #1 told Taheb the devices would be detonated

with cell phones. Taheb again provided details of his plan to attack the
White House. Specifically, he described his plan to use the AT-4 to

blow a hole in the White House so that the group could enter. Taheb
also discussed "arrows" and asked about the recoil. He said he had

never shot a gun but could learn easily. He added that his plan was to
go in and take down as many (people) as they possibly could. When

UCE #1 brought up the AT-4, Taheb said he had watched some videos
to include videos of how grenades explode. Taheb later noted that he

wanted to drive on the road located behind the White House, pull up in
a car, cause a distraction, and keep going until the full house was
cleared or until they could no longer proceed. Taheb stated the

backpacks were for destruction and "martyrdom."
23.On or about January 9,2019, UCE #1 asked Taheb if he was still

planning to exchange his car for the weapons and explosives, and
Taheb responded that he was still planning to do so. Taheb advised he

wanted to go over plans with the group members to ensure that they

did not have any doubts in their hearts.
2L.Onlanuary 9,2019, when group members discussed the weapons and
explosives ordered via the social media messaging application
described herein, UCE #1 asked Taheb which method of detonation he

9

 preferred. Taheb responded that he wanted the explosive devices to
detonate at the press of a button.
25. On

or about ]anuary 10,2019, CHS #1 offered to bring the flags Taheb

tasked CHS #L to obtain. Taheb told CHS #1 to keep the flags until
they met for their

trip.

Taheb also asked if CHS #1 had a nice camera.

When CHS #1 indicated he had a camera Taheb could borrow, Taheb
advised CHS #1 to bring the camera and the flags to their meeting on
January 12,2019.
26.On or about January L2,2019, Taheb met with CHS #L in Cumming,
Georgia. CHS #1 provided Taheb with a camera, an American flag,
and an Israeli flag. Taheb provided details to CHS #1 about Taheb's

plan to attack the White House. Taheb stated he wanted to conduct the
attack on the upcoming Thursday (january 17,2079), using firearms,

an AT-4, and backpacks with explosives. Taheb explained to CHS #1
that each person would have

a

backpack with C4 equipped with

a

button to detonate device. Taheb explained that the group would
attack the White House by approaching from the back road, causing

a

distraction for police, and then proceeding into the \uVhite House.
According to Taheb, the AT- would be used to open a door and move

in.

Taheb said he planned to get as many people as possible and do

the most damage. Taheb specifically noted the areas where the Secret
Service and Homeland Security operated in the White House. In

addition to verbally explaining his plan to CHS #1, Taheb also opened
a composition notebook that he

10

brought to the meeting and showed

 a

CHS #1 the hand-drawn sketches Taheb had made of the attack plan.
The sketches included floor plans of the White House, with the Secret
Service and Homeland Security areas notated with stars on his

drawings. Rather than CHS #1 having to draw his own sketches,
Taheb told CHS # 1 to take the notebook with him.

27.On or about january 1.6,2019, Taheb, CHS #1, and UCE #1 met in the

parking lot of a store in Buford, Georgia for the purPose of exchanging
their vehicles for three semi-automatic assault rifles, three explosive
devices with remote initiation, and one AT-4. Taheb drove his vehicle

to the store. A second FBI Confidential Human Source (CHS #2)

arrived at the location and inspected the vehicles. CHS #2 informed
Taheb that Taheb left money in the ashtray of his vehicle. Taheb told
CHS
28.

#2to keep the change

as a donation.

A second FBI Undercover Employee (UCE #2) arcived in a tractor
trailer with the weapons and explosivesr5 ordered by Taheb. Taheb,
UCE #1, and UCE #2 then entered the trailer. UCE #2 and Taheb
discussed the firearms and how to arm and detonate the explosive
devices. UCE #2 and Taheb also handled the AT-4 and discussed how

to use it. Taheb, CHS #1, and UCE #1 then gave their car keys to CHS
#2 in exchange for the weapons and explosives from UCE#L Taheb
then took possession of two backpacks containing the inert explosives,
the inert AT-4 and placed them in the rental vehicle. UCE#1 placed
the inert assault rifles in the rental vehicle. UCE #1 then entered the

1s

The weapons and explosives had been previously rendered inert by FBI

1.1

 a

driver's door of the rental vehicle; CHS #1 entered the rear passenger
door; and Taheb entered the front passenger door and closed it.
Agents then placed Taheb under arrest.

CONCLUSION
Based on the above

information,I respectfully submit that there is

probable cause to believe that within the Northern District of Georgia, Hasher
Jallal Taheb attempted to damage or destroy the \Mhite House, a building owned,
possessed by, or leased to the United States, by means of an explosive,

violation of Title

in

18 U.S.C. S 844(0(1)

WHEREFORE, I respectfully request that a Criminal Complaint be issued.

1.2