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Page 1 of 14
PEG_Shahzad 061710
Copyright © 2009 UNLOCKDOCS.COM. All rights reserved. Patent Pending
* Grand Jury Indictment/FAISAL SHAHZAD* Action

COUNT 1
Attempted Use of a Weapon of Mass Destruction

MAY 1, 2010: Faisal Shahzad, having crossed state lines and countries while exchanging goods
and services, attempted to use a weapon of mass destruction. He traveled from Connecticut to
New York in an attempt to detonate that weapon, which he installed in an SUV and parked in
Times Square near 45th Street and 7th Avenue.

Page 2 of 14
PEG_Shahzad 061710
Copyright © 2009 UNLOCKDOCS.COM. All rights reserved. Patent Pending
* Grand Jury Indictment/FAISAL SHAHZAD* Action

COUNT 2
Conspiracy to Use a Weapon of Mass Destruction

From December 2009 through May 3, 2010, Shahzad and others conspired to violate US laws
which prohibit travel across state lines or countries with the intent to use a weapon of mass
destruction.

The plan was that they would use a weapon of mass destruction against persons and property in
the US.

OVERT ACTS

In order to complete the mission, Shahzad did the following things:

Page 3 of 14
PEG_Shahzad 061710
Copyright © 2009 UNLOCKDOCS.COM. All rights reserved. Patent Pending
* Grand Jury Indictment/FAISAL SHAHZAD* Action

DECEMBER 2009: He took explosives training in Waziristan, Pakistan from trainers connected
with Tehrik-e-Taliban, an extremist group.

FEBRUARY 25, 2010: He received $5,000 while in Massachusetts from someone he knew worked
for Tehrik-e-Taliban (CC-1).

MARCH 15, 2010: He bought a semi-automatic rifle in Connecticut.

APRIL 10, 2010: He received $7,000 in Ronkonkoma, New York from CC-1.

APRIL 16, 2010: He bought a prepaid cell phone in Connecticut.

Page 4 of 14
PEG_Shahzad 061710
Copyright © 2009 UNLOCKDOCS.COM. All rights reserved. Patent Pending
* Grand Jury Indictment/FAISAL SHAHZAD* Action

APRIL 24, 2010: He bought a Nissan Pathfinder in Connecticut.

APRIL (month) 2010: He bought parts for a bomb he would later install in the Pathfinder.

MAY 1, 2010: He drove the Pathfinder, full of explosives, into Times Square and parked.

MAY 1, 2010: He tried to detonate the bomb in the Pathfinder.

MAY 1, 2010: After trying to detonate the bomb, Shahzad left the Pathfinder and headed back
to his home in Connecticut.

MAY 3, 2010: He drove to JFK Airport with his semi-automatic rifle to flee the country.

Page 5 of 14
PEG_Shahzad 061710
Copyright © 2009 UNLOCKDOCS.COM. All rights reserved. Patent Pending
* Grand Jury Indictment/FAISAL SHAHZAD* Action

COUNT 3
Possession and Use of a Firearm During and in Relation To a Crime of Violence

MARCH 15, 2010: From March 15th through May 3rd Shahzad used a semi-automatic rifle and
carried it around with him as he prepared for and committed this crime.

Page 6 of 14
PEG_Shahzad 061710
Copyright © 2009 UNLOCKDOCS.COM. All rights reserved. Patent Pending
* Grand Jury Indictment/FAISAL SHAHZAD* Action

COUNT 4
Attempted Act of Terrorism Transcending National Boundaries

MAY 1, 2010: Shahzad and others attempted a crime that involved goods and services across
state lines and countries. If it had been successful, it would have killed and injured persons and
property within the US.

To be specific, after Shahzad received bomb-making training in Pakistan, he traveled to the US


and attempted to detonate a bomb planted in an SUV he drove into Times Square.

COUNT 5
Conspiracy to Commit an Act of Terrorism
Transcending National Boundaries

From December 2009 until May 3, 2010 Shahzad conspired with others to commit an act of
terrorism beyond national boundaries.

Page 7 of 14
PEG_Shahzad 061710
Copyright © 2009 UNLOCKDOCS.COM. All rights reserved. Patent Pending
* Grand Jury Indictment/FAISAL SHAHZAD* Action

The object of the conspiracy was to maim persons within the US and damage property.

OVERT ACTS

To do this, Shahzad took the steps described in paragraph 4.


[See Count 2.]

Page 8 of 14
PEG_Shahzad 061710
Copyright © 2009 UNLOCKDOCS.COM. All rights reserved. Patent Pending
* Grand Jury Indictment/FAISAL SHAHZAD* Action

COUNT 6
Attempted Use of an Explosive Device in Relation to a Crime of Violence

MAY 1, 2010: Shahzad intentionally loaded an SUV with explosives and parked it in Times
Square with the intention of detonating it as planned and charged in Count 5 above. [Conspiracy to
commit an act of terrorism transcending national boundaries.]

Page 9 of 14
PEG_Shahzad 061710
Copyright © 2009 UNLOCKDOCS.COM. All rights reserved. Patent Pending
* Grand Jury Indictment/FAISAL SHAHZAD* Action

COUNT 7
Transportation of an Explosive

MAY 1, 2010: Shahzad intentionally transported explosives inside an SUV and parked it in Times
Square knowing it would kill and maim others, and damage property.

COUNT 8
Conspiracy to Transport an Explosive

From December 2009 until May 3, 2010, Shahzad worked with others to come up with a plan to
transport a bomb.

He knew the reason for transporting the bomb was to intentionally kill or injure people and
damage property.

Page 10 of 14
PEG_Shahzad 061710
Copyright © 2009 UNLOCKDOCS.COM. All rights reserved. Patent Pending
* Grand Jury Indictment/FAISAL SHAHZAD* Action

OVERT ACTS

In order to complete this mission, Shahzad took the steps listed in paragraph 4.
[See Count 2]

COUNT 9
Attempted Destruction of Property by Fire and Explosive

MAY 1, 2010: Shahzad tried to detonate a bomb installed in his SUV parked in Times Square so
that it would destroy a building, vehicle, and other property. He crossed state lines and
countries while exchanging goods and services to do it.

Page 11 of 14
PEG_Shahzad 061710
Copyright © 2009 UNLOCKDOCS.COM. All rights reserved. Patent Pending
* Grand Jury Indictment/FAISAL SHAHZAD* Action

COUNT 10
Conspiracy to Destroy Property by Fire and Explosive

From December 2009 until May 3, 2010, Shahzad planned with others and agreed to destroy
property using a bomb.

The plan was that they would destroy a building, vehicle, and property through their dealings
across state lines and countries.

OVERT ACTS

In order to complete this act, Shahzad took the steps listed in paragraph 4.
[See Count 2]

Page 12 of 14
PEG_Shahzad 061710
Copyright © 2009 UNLOCKDOCS.COM. All rights reserved. Patent Pending
* Grand Jury Indictment/FAISAL SHAHZAD* Action

FORFEITURE ALLEGATION

Because Shahzad planned and committed crimes of terrorism against the US, he will surrender
the following:

Page 13 of 14
PEG_Shahzad 061710
Copyright © 2009 UNLOCKDOCS.COM. All rights reserved. Patent Pending
* Grand Jury Indictment/FAISAL SHAHZAD* Action

a. All assets
b. All assets connecting him with the Tehrik-i-Taliban
c. All assets acquired with the intention of committing a federal crime of terrorism against
the US
d. All assets received with the intention of using them in a federal crime of terrorism
against the US

This includes money that represents the value of any of the property he must give up.

END

Page 14 of 14
PEG_Shahzad 061710
Copyright © 2009 UNLOCKDOCS.COM. All rights reserved. Patent Pending

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