1. From in or about January 2000, through the date of the filing of this Information, in Singapore, Malaysia, the Philippines, Pakistan, Oman, and Afghanistan, and elsewhere outside the United States and outside the jurisdiction of any particular state or district, MOHAMMED MANSOUR JABARAH, the defendant, who was first brought to and arrested in the Southern District of New York, together with Usama Bin Laden and other members and associates of the groups known as al Qaeda and Jemaah Islamiyah, and others known and unknown, unlawfully, willfully and knowingly combined, conspired, confederated and agreed to kill nationals of the United States.
2. It was a part and an object of said conspiracy that the defendant, and others known and unknown, would and did murder United States nationals at the United States embassies in the Philippines and Singapore.
3. In furtherance of the conspiracy and to effect the object thereof, the defendant, and others known and unknown, committed the following overt acts, among others:
a. In or about March 2001, in Afghanistan, JABARAH, the defendant, attended terrorist training camps sponsored by al Qaeda;
b. In or about May 2001, in Afghanistan, JABARAH, the defendant, made “bayat,” that is, he pledged allegiance to Usama Bin Laden;
c. In or about July 2001, in Afghanistan, JABARAH, the defendant, met with Usama Bin Laden, a co-conspirator not named as a defendant herein, to convince Bin Laden of his potential as an operative for Bin Laden’s terrorist group al Qaeda;
d. In or about August 2001, JABARAH, on instructions from Usama Bin Laden, traveled to Karachi, Pakistan and met with an individual (“Co-Conspirator #1”);
e. In or about September 2001, JABARAH met another individual (“Co-Conspirator #2”) in Karachi, Pakistan, who provided JABARAH with details of a terrorist operation being planned against American and Israeli targets in the Philippines, and told JABARAH that he would be working with an individual from Malaysia (“Co-Conspirator #3”) and an individual from the Philippines (“Co-Conspirator #4”);
f. In or about September 2001, JABARAH met with Co-Conspirator #3 and others in Kuala Lumpur, Malaysia to discuss the terrorist operation being planned in the Philippines;
g. In or about September 2001, JABARAH traveled to Manila, Philippines, where he met with Co-Conspirator #4;
h. In or about early October 2001, JABARAH met with, among others, Co-Conspirator #3, and Co-Conspirator #4 in Kuala Lumpur, Malaysia, and discussed switching the target of the terrorist operation to Singapore;
i. In or about mid-October 2001, JABARAH met with Co-Conspirator #4 and others in Singapore and conducted surveillance of numerous targets, including the American embassy;
j. In or about late October 2001, JABARAH videotaped the exteriors of the potential targets of the terrorist operations in Singapore, including the American embassy;
k. In or about late October or early November 2001, JABARAH met with co-conspirators in Kuala Lumpur, Malaysia, where it was decided that the priority targets would be the American and Israeli embassies in Singapore and that they would be attacked using explosives;
l. In or about November 2001, JABARAH met with another individual in Kuala Lumpur, Malaysia, who provided approximately $50,000 to Jabarah for the plot;
m. In or about late November 2001, in Kuala Lumpur, Malaysia, JABARAH met with Co-Conspirator #2 and another individual and they discussed shifting the operation back to the American and Israeli embassies in the Philippines;
n. In or about December 2001, JABARAH learned that Co-Conspirator #3 and Co-Conspirator #4 had been arrested and he fled from Asia; and
o. In or about February 2002, Co-Conspirator #1 instructed JABARAH to travel to Oman to assist in providing a safe haven for al Qaeda members/ associates traveling from Afghanistan to Yemen.