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RMT:DWD/JEA F. #2018R02136 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK X RLED IN CLERK'S OFFICE US DISTRICT COURT E.D.N.Y.^ * OCT 0 9 2019 o BROOKLYN OFFICE ^ UNITED STATES OF AMERICA - against - MOHAMED TAHLIL MOHAMED, also known as "Tahlil Mohamed," "Mohained Tahlil," "Maxamed Tahliil Guure," "the Taliye" and "Mohamed the Taliye," and ABDI YUSUF HASSAN, Defendants. SUPERSEDING INDICTMENT Cr. No. 18-603 (S^2) (ARR) (T. 18,U.S.C.,§§ 924(c)(l)(A)(i), 924(c)(l)(A)(ii), 924(c)(l)(A)(iii), 924(c)(I)(B)(ii), 924(d)(1), 924(o), 981(a)(1)(C), 981(a)(1)(G), 1203(a), 1203(b)(1), 2332a(a), 2339A(a), 3238, 2 and 3551 ^ T. 21, U.S.C., § 853(p); T. 28, U.S.C., § 2461(c)) THE GRAND JURY CHARGES: COUNT ONE (Conspiracy to Provide Material Support for Acts of Terrorism) 1. In or about and between January 2012 and September 2014, both dates being approximate and inclusive, in an offense begun and committed in Somalia and elsewhere out of the jurisdiction of any particular State or district of the United States, the defendants MOHAMED TAHLIL MOHAMED, also known as "Tahlil Mohamed," "Mohamed Tahlil," "Maxamed Tahliil Guure," "the Taliye" and "Mohamed the Taliye," who, after the conduct required for the offense occurred, was first brought to and found in the Eastern District of New York, and ABDI YUSUF HASSAN, together with others, did knowingly and intentionally conspire to provide material support and resources, as defmed in Title 18, United States Code, Section 2339A(b), to wit; tangible and intangible property, Case 1:18-cr-00603-ARR Document 37 Filed 10/09/19 Page 1 of 10 PageID #: 530

RMT:DWD/JEA BROOKLYN OFFICE...Eastern District of New York, and ABDI YUSUF HASSAN, together with others, did knowingly and intentionally conspire to provide material support and resources,

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Page 1: RMT:DWD/JEA BROOKLYN OFFICE...Eastern District of New York, and ABDI YUSUF HASSAN, together with others, did knowingly and intentionally conspire to provide material support and resources,

RMT:DWD/JEA

F. #2018R02136

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF NEW YORK

X

RLEDIN CLERK'S OFFICE

US DISTRICT COURT E.D.N.Y.^

* OCT 0 9 2019 ★ o

BROOKLYN OFFICE ^

UNITED STATES OF AMERICA

- against -

MOHAMED TAHLIL MOHAMED,

also known as "Tahlil Mohamed,"

"Mohained Tahlil," "MaxamedTahliil Guure," "the Taliye" and"Mohamed the Taliye," and

ABDI YUSUF HASSAN,

Defendants.

SUPERSEDING

INDICTMENT

Cr. No. 18-603 (S^2) (ARR)

(T. 18,U.S.C.,§§ 924(c)(l)(A)(i),924(c)(l)(A)(ii), 924(c)(l)(A)(iii),924(c)(I)(B)(ii), 924(d)(1), 924(o),981(a)(1)(C), 981(a)(1)(G), 1203(a),1203(b)(1), 2332a(a), 2339A(a), 3238,2 and 3551 ̂ T. 21, U.S.C.,§ 853(p); T. 28, U.S.C., § 2461(c))

THE GRAND JURY CHARGES:

COUNT ONE

(Conspiracy to Provide Material Support for Acts of Terrorism)

1. In or about and between January 2012 and September 2014, both dates

being approximate and inclusive, in an offense begun and committed in Somalia and

elsewhere out of the jurisdiction of any particular State or district of the United States, the

defendants MOHAMED TAHLIL MOHAMED, also known as "Tahlil Mohamed,"

"Mohamed Tahlil," "Maxamed Tahliil Guure," "the Taliye" and "Mohamed the Taliye,"

who, after the conduct required for the offense occurred, was first brought to and found in the

Eastern District of New York, and ABDI YUSUF HASSAN, together with others, did

knowingly and intentionally conspire to provide material support and resources, as defmed in

Title 18, United States Code, Section 2339A(b), to wit; tangible and intangible property,

Case 1:18-cr-00603-ARR Document 37 Filed 10/09/19 Page 1 of 10 PageID #: 530

Page 2: RMT:DWD/JEA BROOKLYN OFFICE...Eastern District of New York, and ABDI YUSUF HASSAN, together with others, did knowingly and intentionally conspire to provide material support and resources,

Case 1:18-cr-00603-ARR Document 37 Filed 10/09/19 Page 2 of 10 PageID #: 531

Page 3: RMT:DWD/JEA BROOKLYN OFFICE...Eastern District of New York, and ABDI YUSUF HASSAN, together with others, did knowingly and intentionally conspire to provide material support and resources,

Case 1:18-cr-00603-ARR Document 37 Filed 10/09/19 Page 3 of 10 PageID #: 532

Page 4: RMT:DWD/JEA BROOKLYN OFFICE...Eastern District of New York, and ABDI YUSUF HASSAN, together with others, did knowingly and intentionally conspire to provide material support and resources,

Case 1:18-cr-00603-ARR Document 37 Filed 10/09/19 Page 4 of 10 PageID #: 533

Page 5: RMT:DWD/JEA BROOKLYN OFFICE...Eastern District of New York, and ABDI YUSUF HASSAN, together with others, did knowingly and intentionally conspire to provide material support and resources,

Case 1:18-cr-00603-ARR Document 37 Filed 10/09/19 Page 5 of 10 PageID #: 534

Page 6: RMT:DWD/JEA BROOKLYN OFFICE...Eastern District of New York, and ABDI YUSUF HASSAN, together with others, did knowingly and intentionally conspire to provide material support and resources,

Case 1:18-cr-00603-ARR Document 37 Filed 10/09/19 Page 6 of 10 PageID #: 535

Page 7: RMT:DWD/JEA BROOKLYN OFFICE...Eastern District of New York, and ABDI YUSUF HASSAN, together with others, did knowingly and intentionally conspire to provide material support and resources,

Case 1:18-cr-00603-ARR Document 37 Filed 10/09/19 Page 7 of 10 PageID #: 536

Page 8: RMT:DWD/JEA BROOKLYN OFFICE...Eastern District of New York, and ABDI YUSUF HASSAN, together with others, did knowingly and intentionally conspire to provide material support and resources,

Case 1:18-cr-00603-ARR Document 37 Filed 10/09/19 Page 8 of 10 PageID #: 537

Page 9: RMT:DWD/JEA BROOKLYN OFFICE...Eastern District of New York, and ABDI YUSUF HASSAN, together with others, did knowingly and intentionally conspire to provide material support and resources,

Case 1:18-cr-00603-ARR Document 37 Filed 10/09/19 Page 9 of 10 PageID #: 538

Page 10: RMT:DWD/JEA BROOKLYN OFFICE...Eastern District of New York, and ABDI YUSUF HASSAN, together with others, did knowingly and intentionally conspire to provide material support and resources,

Case 1:18-cr-00603-ARR Document 37 Filed 10/09/19 Page 10 of 10 PageID #: 539