Justice Department reveals well-known Islamic State operative in touch with Boston man

Federal prosecutors said British militant Junaid Hussain, who was killed in a drone strike in Syria last year, communicated directly with a terrorist suspect in Boston. Authorities say Hussain instructed Usaamah Abdullah Rahim to kill Pamela Geller, who had organized a Muhammad cartoon contest in Texas. Authorities shot and killed Hussain before he could carry out an attack.

Case Document 60 Filed 04/21/16 Page 1 of 16

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS

UNITED STATES OF AMERICA Criminal No. 15-10153-WGY

v. Count One: Conspiracy to Provide Material
Support to Designated Foreign Terrorist
Organization 18 U.S.C. 2339B(a)(1) and
(1) David Daoud Wright, Aiding and Abetting - 18 U.S.C. 2
a/k/a Dawud Sharif Wright, (Wright and Rovinski);
a/k/a Dawud Sharif Abdul Wright,
a/k/a Dawud Sharif Abdul Khaliq, and Count Two: Conspiracy to Obstruct Justice -
18 U.S.C. 371 (Wright);

(2) Nicholas Alexander Rovinski, Count Three: Obstruction ofJustice
a/k/a Nuh Amriki, 18 U.S.C. 1519 and
a/k/a Nuh Andalusi, Aiding and Abetting 18 U.S.C. 2 (Wright);

and
Defendants. Count Four: Conspiracy to Commit Acts of
Terrorism Transcending National Boundaries -
18 U.S.C. 2332b(a)(2)
(Wright and Rovinski)
FIRST SUPERSEDING INDICTMENT
The Grand Jury charges:

INTRODUCTORY ALLEGATIONS
1. David Daoud Wright a/k/a Dawud Sharif Wright a/k/a Dawud Sharif Abdul Wright
a/k/a Dawud Sharif Abdul Khaliq is a United States citizen who at all pertinent
times lived in Everett, Massachusetts. uncle, Usaamah Abdullah Rahim (?Rahim?),
resided in Roslindale, Massachusetts until his death at approximately 7:00 am. on June 2, 2015.
Nicholas Rovinski a/k/a Nuh Amriki a/k/a Nuh al Andalusi is a United States
citizen who at all pertinent times lived in Warwick, Rhode Island.

2. In or about June 2014, WRIGHT began discussing with Rahim his

Case Document 60 Filed 04/21/16 Page 2 of 16

support of the Islamic State of Iraq and the Levant and the need to commit acts of
violence in support Additionally, in or about November 2014, WRIGHT met
ROVINSKI online and began communicating with him. WRIGHT, ROVINSKI, and Rahim
shared a common goal to support ISIL.

I. Background of ISIL

3. On October 15, 2004, the United States Secretary of State designated al-Qa?ida in
Iraq, then known as Iam?at a1 Tawhid wa?al-Jihad, as a Foreign Terrorist Organization
under Section 219 of the Immigration and Nationality Act and as a Specially Designated Global
Terrorist under section 1(b) of Executive Order 13224. On May 15, 2014, the United States
Secretary of State formally amended the existing designation of al-Qa?ida in Iraq as a Foreign
Terrorist Organization to add the alias Islamic State of Iraq and the Levant as its primary name.
The Secretary also added the following aliases to the ISIL listing: the Islamic State of Iraq and
al-Sham (ISIS), the Islamic State of Iraq and Syria (ISIS), ad-Dawla al-lslamiyya f1 aI-?lraq
wa-sh-Sham, Daesh, Dawla a1 Islamiya, and Al-Furqan Establishment for Media Production (all
collectively referred to herein as On September 21, 2015, the Secretary added the
following aliases to the ISIL listing: Islamic State, ISIL, and ISIS. To date, ISIL remains a
designated FTO.

4. The State Department has reported that, among other things, ISIL has committed
systematic abuses of human rights and violations of international law, including indiscriminate
killing and deliberate targeting of civilians, mass executions and extrajudicial killings, persecution
of individuals and communities on the basis of their identity, kidnapping of civilians, forced

displacement of Shia communities and minority groups, killing and maiming of children, rape, and

Case Document 60 Filed 04/21/16 Page 3 of 16

other forms of sexual violence. According to the State Department, ISIL has recruited thousands
of foreign ?ghters to Iraq and Syria from across the globe and has used technology to spread its
violent extremist ideology and to incite others to commit terrorist acts.

5. Beginning in 2014, using social media, ISIL has called for attacks against
citizens?civilian and military?of the countries participating in the United States-led coalition
against ISIL. For instance, on September 21, 2014, ISIL released a speech of Abu Muhammed
Al-Adnani, a senior leader and of?cial spokesman of ISIL. In this speech, entitled, ?Indeed Your
Lord is Ever Watchful,? Al-Adnani calls on Muslims who support ISIL from around the world to
?defend the Islamic State? and to ?rise and defend your state from your place where you may be.?
Additionally, since in or about June 2014, ISIL has been distributing beheading videos to
demonstrate, among other things, an acceptable method of killing people who are believed to be
non-believers, or in?dels.

6. Since late 2014, using social media, members of ISIL have encouraged individuals
to kill specific persons or groups of persons such as members of the military and law enforcement
within the United States. For example, in March 2015, ISIL posted the names and addresses of
100 US. military service members on the intemet and instructed their supporters to ?kill them in
their own lands, behead them in their own homes, stab them to death as they walk their streets
thinking they are safe

II. The Plot to Support ISIL

7. Beginning in or about January 2015, WRIGHT began discussing calls to kill
the ?kufar,? non-believers, in the United States with Rahim and ROVINSKI.

8. On January 20, 2015, ROVINSKI downloaded all six issues of Dabiq

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magazine.

9. By at least February 2015, WRIGHT and Rahim had heeded the call to
attack non-believers in the United States and began plotting and recruiting members for their
operation. For this initiative, in or about March 2015, WRIGHT obtained and
studied a jihadist manual, entitled ?How to Survive in the West,? which details ?how to become a
Sleeper-cell? in the West until ordered to attack.

10. In or about April 2015, WRIGHT drafted organizational documents for a
Operations Cell.? Between in or about April 2015 and in or about June 2015,
WRIGHT also conducted extensive research using the intemet in furtherance of this operation.
Among other things, WRIGHT conducted intemet searches on ?rearms, tranquilizer guns, and law
enforcement capabilities, and performed search queries such as the following: ?what is the most
?ammable chemical;? ?which tranquilizer puts humans to sleep instantly;? and ?how to start a
secret militia in [the]

11. By at least April 2015, WRIGHT, Rahim, and ROVINSKI had decided to commit
attacks and kill persons inside the United States, which they believed would support
objectives. By May 2015, they had agreed that their attack plan would include the beheading of at
least one person (Intended Victim-1), a New York woman, whom ISIL had identi?ed for murder
through a ?fatwah,? or religious decree, to ISIL supporters. Intended Victim-l had organized a
Muhammad Art Exhibit and Contest at the Curtis Culwell Center in Garland, Texas on May 3,
2015, which included cartoons depicting the Prophet Muhammad. Separately, the contest was
attacked by two armed men, Elton Simpson and Nadir Soofi, who wounded a security guard before

law enforcement shot and'killed both attackers.

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12. Beginning in or about February 2015, and continuing until his death on June 2,
2015, Rahim had communicated with ISIL members located overseas. One of the ISIL members
with whom he communicated was Junaid I-Iussain (?Hussain?). Hussain, an English speaking
ISIL member who used the nom de guerre or kunya Abu Hussain al-Britani, used Twitter to
encourage terrorist attacks in the United States and Europe against persons whom ISIL believed
should be targeted for execution, including Intended Victim-1. Shortly before the attempted
attack on the Garland event organized and attended by Intended Victim?1, Elton Simpson issued a
tweet in which he proclaimed his allegiance to Abu Bakr al-Baghdadi, the leader of ISIL, and
asked that ?Allah accept us [Simpson and Soo?] as mujahideen [those engaged in violent jihad].?
Minutes after the thwarted Garland attack on May 3, 2015, Hussain, using Twitter, stated that ?2 of
our brothers just opened ?re at the Prophet Mohammad art exhibition in texas!? and instructed
supporters to ?Kill Those That Insult the Prophet - #GarlandShooting.? Beginning in or
about May 2015, Hussain directly communicated with Rahim, and Rahim in turn communicated
Hussain?s instructions with regard to the murder of Intended Victim-1 to WRIGHT.

13. Between on or about May 25, 2015, and May 27, 2015, Rahim purchased three
knives ranging in length from 13 to 15 inches on Amazon.com, the last of which were delivered to
Rahim on May 30, 2015.

14. ROVINSKI also communicated with people overseas about his desire to support
ISIL and his ?intention? to engage in acts of violence on behalf of ISIL. Between in or about
April 2015 and in or about June 2015, ROVINSKI researched knives and weapons using the
intemet. For instance, ROVINSKI viewed videos about making weapons on YouTube and

downloaded them to his account.

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15. On May 31, 2015, WRIGHT, ROVINSKI, and Rahim met for more than two hours
on a secluded beach in Rhode Island. During that meeting, the three men discussed a plan to
behead Intended Victim-l. On May 30, 2015, in preparation for his meeting with WRIGHT and
Rahim on May 31, 2015 to discuss beheading enemies of ISIL, ROVINSKI researched saws and
cutting and chopping tools using the intemet.

l6. WRIGHT, ROVINSKI, and Rahim all understood that law enforcement was
investigating persons in the United States that supported ISIL and that their actions in support of
ISIL would similarly be investigated by law enforcement. Accordingly, they agreed not to share
information about their plans with anyone who had not pledged allegiance, or given ?bayah,? to
ISIL.

17. On the morning of June 2, 2015, Rahim informed WRIGHT that he could not wait
until July 4, 2015 to go a?er their target (Intended Victim-l) and intended to ?go after? the ?boys
in blue,? a slang term used to describe police of?cers, in Massachusetts on that day or the next day.
WRIGHT encouraged and supported Rahim?s plan to attack the police and die as a ?martyr.?

18. WRIGHT, knowing that law enforcement would be conducting an investigation of
Rahim?s actions after Rahim attacked the police, instructed Rahim to ?completely? destroy his
smartphone and ?completely wipe out everything? from his laptop computer. Rahim followed
instructions and initiated the process of restoring his computer to the original factory
operating system so as to delete or wipe all the data it contained.

19. Less than two hours after WRIGHT encouraged Rahim to attack police of?cers in
Massachusetts, Rahim was in a public parking lot in Roslindale, when he was approached by

Boston Police Officers and FBI Special Agents. Rahim took out one of the three knives he had

Case Document 60 Filed 04/21/16 Page 7 of 16

purchased from Amazon.com when he saw the of?cers and agents. The of?cers and agents told
Rahim to drop his weapon and Rahim responded, ?you drop yours.? Rahim then moved towards
the of?cers and agents while brandishing his weapon, and he was shot by law enforcement.

20. The Federal Bureau of Investigation?s Joint Terrorism Task Force
led the investigation into Rahim?s actions and the ISIL-motivated attack plans of Rahim,
WRIGHT, and ROVINSKI. As part of that investigation, on June 3, 2015, JTTF executed
a search warrant at Rahim?s residence. ln Rahim?s bedroom, they found a running laptop
computer, which was being restored to its original ?factory settings? and deleting its contents.
The agents also found a handwritten will signed by Rahim on a desk in the living room area.

21. On or about June 12, 2015, Hussain used Twitter to publicly and openly describe
?Usaamah Rahim? as a martyr in Boston who was involved in a beheading plot to kill Intended
Victim-l. Hussain further acknowledged that he had spoken to Rahim and during their last
conversation, Hussain had instructed Rahim to carry a knife in case the ?feds? tried to arrest him.
On or about August 24, 2015, Hussain was killed in an airstrike in Raqqah, Syria, a city which ISIL
considers to be its capital.

22. Since his arrest on June 11, 2015, ROVINSKI has continued to engage in activity
designed to further the conspirators? plan to commit violent attacks inside the United States. In or
about August 2015, ROVINSKI again pledged his allegiance to ISIL and its leader, ?Abu Bakr
al-Baghdadi,? by writing his pledge of support on the back of the criminal complaint that had
charged him in this case. Additionally, while in jail, ROVINSKI has attempted to recruit people
to assist in the execution of their plan to commit violent attacks in the United States and to

decapitate non-believers.

Case Document 60 Filed 04/21/16 Page 8 of 16

COUNT ONE: (18 U.S.C. 2339B(a)(l) Conspiracy to Provide Material Support
to a Designated Foreign Terrorist Organization); and
(18 U.S.C. 2 Aiding and Abetting)
The Grand Jury further charges that:
The allegations contained in paragraphs 1-22 are hereby re-alleged and incorporated by
reference as if fully set forth herein.
From a date unknown but no later than in or about February 2015 and continuing until the
present, in the District of Massachusetts and elsewhere,
(1) DAVID DAOUD WRIGHT,
a/k/a DAWUD SHARIF WRIGHT,
a/k/a DAWUD SHARIF ABDUL WRIGHT,
a/k/a DAWUD SHARIF ABDUL KHALIQ, and

(2) NICHOLAS ALEXANDER ROVINSKI,
a/k/a NUH AMRIKI, a/k/a NUH ANDALUSI,

defendants herein, did knowingly conspire and agree with each other, with Usaamah Abdullah
Rahim, and with others known and unknown to the grand jury, to provide material support and
resources, as that term is de?ned in Title 18, United States Code, Section 2339A(b), to wit,
services and personnel, including themselves, to a foreign terrorist organization, namely, the
Islamic State in Iraq and the Levant, which the Secretary of State has designated as a foreign
terrorist organization, knowing that the organization was a designated foreign terrorist
organization, and that the organization had engaged in and was engaging in terrorist activity and

terrorism.

All in violation of 18 U.S.C. 2339B(a)(1) and 2.

Case Document 60 Filed 04/21/16 Page 9 of 16

COUNT TWO: (18 U.S.C. 371 - Conspiracy to Obstruct Justice)

The Grand Jury further charges that:

The allegations contained in paragraphs 1-22 are hereby re-alleged and incorporated by
reference as if fully set forth herein.

On or about June 2, 2015, in the District of Massachusetts,

(1) DAVID DAOUD WRIGHT,
a/k/a DAWUD SHARIF WRIGHT,
a/k/a DAWUD SHARIF ABDUL WRIGHT,
a/k/a DAWUD SHARIF ABDUL KHALIQ,
defendant herein, did knowingly conspire, combine, confederate and agree with Usaamah
Abdullah Rahim to commit an offense against the United States, to wit, Obstruction of Justice, in
violation of 18 U.S.C. 1519, by agreeing to knowingly alter, destroy, mutilate, conceal, and
cover up tangible objects belonging to Rahim, namely a smartphone and laptop computer, with the
intent to impede, obstruct, and in?uence an investigation and proper administration of a matter
within the jurisdiction of the Federal Bureau of Investigation, an agency of the United States
Government, and in relation to and contemplation of such investigation and matter.
OVERT ACTS

In furtherance of the conspiracy, and to effect its objects, the defendant and his
co-conspirator committed overt acts, including, but not limited to, the following:

a. On the morning of June 2, 2015, after Rahim informed WRIGHT that he intended
to ?go after? the ?boys in blue,? WRIGHT instructed Rahim to ?completely destroy? his
smartphone.

b. On the morning of June 2, 2015, WRIGHT also told Rahim to delete and

?completely wipe out everything? from his laptop computer by restoring the operating system to

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the original ?factory setting.?

c. As instructed, before leaving his residence on June 2, 2015 and encountering law
enforcement, Rahim took steps to restore his laptop computer to the original factory operating
system so as to delete the contents of his computer.

All in Violation of 18 U.S.C. 371.

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COUNT THREE: (18 U.S.C. 1519 - Obstruction of Justice); and
(18 U.S.C. 2 Aiding and Abetting)

The Grand Jury further charges that:
The allegations contained in paragraphs 1-22 are hereby re-alleged and incorporated by
reference as if fully set forth herein.
On or about June 2, 2015, in the District of Massachusetts,
(1) DAVID DAOUD WRIGHT,
a/k/a DAWUD SHARIF WRIGHT,
a/k/a DAWUD SHARIF ABDUL WRIGHT,
a/k/a DAWUD SHARIF ABDUL KHALIQ,
defendant herein, did knowingly cause Usaamah Abdullah Rahim to alter, destroy, mutilate,
conceal, and cover up a tangible object, namely a laptop computer, with the intent to impede,
obstruct, and in?uence an investigation and proper administration ofa matter within the
jurisdiction of the Federal Bureau of Investigation, an agency of the United States Government,

and in relation to and contemplation of such investigation and matter.

All in violation of 18 U.S.C. 1519 and 2.

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COUNT FOUR: (18 U.S.C. 2332b(a)(2) Conspiracy to Commit Acts
of Terrorism Transcending National Boundaries)

The Grand Jury further charges that:

The allegations contained in paragraphs 1-22 are hereby re-alleged and incorporated by
reference as if fully set forth herein.

From a date unknown but no later than in or about February 2015 and continuing until the
present, in the District of Massachusetts and elsewhere, and involving conduct transcending
national boundaries,

(1) DAVID DAOUD WRIGHT,
a/k/a DAWUD SHARIF WRIGHT,
a/k/a DAWUD SHARIF ABDUL WRIGHT,
a/k/a DAWUD SHARIF ABDUL KHALIQ, and

(2) NICHOLAS ALEXANDER ROVINSKI,
a/k/a NUH AMRIKI, a/k/a NUH ANDALUSI,

defendants herein, did knowingly conspire and agree with each other, with Usaamah Abdullah
Rahim, and with others known and unknown to the grand jury, to kill and maim persons within the
United States in violation of the laws of Massachusetts and New York, that is, Massachusetts
General Laws Chapter 265 1 and 15, and New York State Penal Law
and and (1) one or more facilities of interstate and foreign commerce were used in
furtherance of the offense. and (2) the offense affected interstate and foreign commerce and would
have affected interstate and foreign commerce if completed, in violation of 18 U.S.C.
2332b(a)(l).
OVERT ACTS

In ?trtherance of the conspiracy, and to effect its objects, the defendants and their

co-conspirators committed overt acts, including, but not limited to, the following:

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a. Between in or about February 2015 and continuing until June 2015, Rahim
communicated with members of ISIL located overseas using various messaging applications. For
example, in or about May 2015, Junaid Hussain directly communicated instructions to Rahim with
regard to the murder of Intended Victim-1.

b. On or about March 18, 2015, WRIGHT forwarded Rahim a link to a ?le
entitled, ?how to survive in the west (2015) which WRIGHT stated is ?perfect for the
initiative? and was written by an ISIL leader. WRIGHT advised Rahim that he is ?now studying?
it and instructed Rahim to ?read it tonight.?

c. On or about March 18, 2015, WRIGHT and Rahim exchanged text messages regarding
the recruitment ofa ?brother? to assist them in their plans without ?exposing? themselves ?because
[the brother?s] intention maybe to live under the law die under it.?

d. On or about April 11, 2015, WRIGHT sent text messages to Rahim that read, in
pertinent part: ?it may take about a year to mobilize. Not because brothers ain?t willing but
because they?re ignorant just as we once were. I?ve been studying and by the time these things
work out in shaa Allah it will be a great success. Allaahu akhbar.?

e. On or about April 19, 2015, WRIGHT conducted several intemet search queries using

66

Google including: ?which tranquilizer put humans to sleep instantly; purchase tranquilizer gung?
?purchase ?rearms online;? and ?purchase taser gun.?

f. On or about April 28, 2015, WRIGHT forwarded a document he found on the internet
entitled ?Internal Conquest? to a acebook user. The ?Internal Conquest? document solicits the

?Lions of Allah? living in the United States to attack their fellow citizens and become in

the name of leader Abu Bakr al-Baghdadi.

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g. On or about April 28, 2015, WRIGHT drafted an organizational document for a
?Command and Control Cell? and Operations Cell."

h. On or about May 9, 2015, WRIGHT and ROVINSKI met in Rhode Island to discuss
their plans.

i. On or about May 19, 2015, WRIGHT conducted an intemet search query ?what is the
most ?ammable chemical.?

j. On or about May 20, 2015, using a social media application, ROVINSKI told a
person located in the United Kingdom that he no longer intended to go to Syria to ?ght. Rather,
he stated he ?[would] be carrying out things? in the United States.

k. On or about May 25, 2015, WRIGHT conducted an intemet search query ?how to
start a secret militia in

I. On or about May 25, 2015, Rahim conducted social media searches for the name of
Intended Victim-l and the name of a relative of Intended Victim-1.

m. On or about May 25, 2015, Rahim purchased an Ontario Spec Plus Marine Raider
Bowie ?ghting knife (?Marine ?ghting knife?) and a device used to sharpen knives from
Amazon.com. The Marine ?ghting knife Rahim purchased is 15 inches long when opened,
contains a 9.75? blade, and weighs 22.4 ounces.

11. On or about May 27, 2015, Rahim purchased a second Marine ?ghting knife and an
Ontario Knife SP6 Spec Plus Fighting Knife 8325 Spec Plus Fighting Knife") from
Amazon.com. The SP6 Spec Plus Fighting Knife Rahim purchased is 13 inches long and has an
eight inch blade.

0. Between in or about May 2015 and in or about June 2015, ROVINSKI viewed videos

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on how to make weapons on YouTube and downloaded them to his account.

p. On or about May 31, 2015, WRIGHT, ROVINSKI, and Rahim met for more than two
hours on a secluded beach in Rhode Island. During that meeting, the three men discussed a plan
to behead Intended Victim-1.

q. On May 30, 2015, in preparation for his meeting with WRIGHT and Rahim on May 31,
2015 to discuss beheading enemies of ISIL, ROVINSKI researched saws and cutting and chopping
tools using the intemet.

r. On or about June 2, 2015, after Rahim informed WRIGHT that he could not wait until
July 4, 2015 to go after their target (Intended Victim-1) and instead wanted to ?go after? the ?boys
in blue,? in Massachusetts that day or the following day, WRIGHT encouraged Rahim to pursue

5. Less than two hours after WRIGHT encouraged Rahim to attack police of?cers in
Massachusetts, Rahim was in a public parking lot in Roslindale, when he was approached by
Boston Police Of?cers and FBI Special Agents. Rahim took out one of the three knives he had
purchased from Amazon.com when he saw the of?cers and agents. The of?cers and agents told
Rahim to drop his weapon and Rahim responded, ?you drop yours.? Rahim then moved towards
the of?cers and agents while brandishing his weapon, and he was shot by law enforcement.

t. In or about August 2015, ROVINSKI pledged his allegiance to ISIL and its leader,
?Abu Bakr al-Baghdadi,? in writing.

u. In or about August 2015, while in jail, ROVINSKI wrote letters to WRIGHT
describing ways they could continue to execute their plans to take down the United States

government and decapitate non-believers.

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All in violation 01?18 U.S.C. 2332b(a)(2), 2332b(c), and 2.

A TRUE BILL

FORERERSON OF THE GRAND JURY

Gregory R. Gonzalez
Trial Attorney
US. Department ofJustice. National Security Division

DISTRICT OF MASSACHUSETTS. Boston, MA

Returned into the District Court by the Grand Jurors and ?led.

Deputy ClerII

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April21,2016