Criminal complaint in U.S. v. Mohammed Osman Idris
IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA
UNITED STATES OF AMERICA)
) CRIMINAL NO.
MOHAMMED OSMAN IDRIS,)
A F F I D A V I T
I, John V. Wyman, being first duly sworn, depose and say:
1) I am a Special Agent (SA) with the Federal Bureau of Investigation (FBI), assigned to the Washington Field Office. I have been a Special Agent of the FBI for approximately 31/2 years and am currently assigned to the Washington Field Office. I have training and experience in the preparation, presentation, and service of criminal complaints and arrest and search warrants, and have been involved in the investigation of numerous types of offenses against the United States, including crimes of terrorism, as set forth in 18 U.S.C. § 2331, et seq. My knowledge of the facts and circumstances contained within this affidavit is based upon my personal investigation as well as reports made to me by other law enforcement agents.
2) This affidavit is submitted in support of a criminal complaint charging the following individual with unlawfully making false declarations before a grand jury, in violation of Title 18, United States Code, Section 1623:
MOHAMMED OSMAN IDRIS
4510 Airlie Way
1) This affidavit is also made in support of an application for a warrant to search IDRIS's residence at 4510 Airlie Way, Annandale, VA. This property is described as a brick, two-story, single family townhouse, set back from Airlie Way by a short sidewalk. Posted to the left of a gray-colored front door are gold-colored numbers, "4510."
1) On 12/19/2001, I was advised by FBI Agents assigned to the Legal Attache Office in Tel Aviv, Israel and FBI Headquarters in Washington, D.C. of the activities surrounding the travel of Mohammed Hassan El-Yacoubi and MOHAMMED OSMAN IDRIS. On 12/13/2001, the two individuals appeared at JFK International Airport, New York, for El Al Flight #008 bound for Tel Aviv. The two individuals were carrying United States passports, identifying themselves as Mohammad Hassan El-Yacoubi, born 09/25/1978, U.S. Passport No. 017037014, and MOHAMMAD OSMAN IDRIS, born 03/09/1978, U.S. Passport No. 017037007.
2) A search conducted by El Al security personnel revealed that El-Yacoubi and IDRIS were carrying approximately $2,000 in U.S. currency, a cellular telephone, a compass, a calculator, and a video camera. Furthermore, El-Yacoubi was carrying a letter in an envelope addressed to himself: Mohammed El-Yacoubi, 11716 Lakewood Lane, Fairfax, VA, with a return name/address of: Abdalmuhssin El-Yacoubi, 457-1 Lambeth Field, Charlottesville, VA. The letter consisted of four handwritten pages, in Arabic, written on lined notebook paper. The envelope had no U.S. post-markings or stamps.
3) While the subjects were being interviewed, their items were taken to a different location for examination by El Al security personnel. At the completion of the interview, the subjects were rushed to board their plane and, as a result, left behind the items that were being examined. Both men flew to Israel on Flight #008. Yet, once the plane arrived they were denied entry into the country. Both returned to the United States on El Al flight 001, that landed at JFK International Airport on 12/16/2001.
4) When questioned about the letter in New York and upon his arrival at Ben-Gurion National Airport in Israel, El-Yacoubi could not provide a logical explanation for the letter, adding that he did not read Arabic. El-Yacoubi originally denied knowledge of the letter to El Al security and advised that he was not aware who had placed the letter in his luggage.
5) On 12/19/2001, a copy of the letter carried by Mohammed El-Yacoubi was translated by language specialists at the FBI Washington Field Office. Based upon my experience, the experience and impression of the two language specialists who translated the letter, and the experience of other law enforcement agents with whom I work, the letter appears to be a farewell letter to Mohammed El-Yacoubi from his younger brother, Abdalmuhssin El-Yacoubi, for a suicide mission in the name of "Jihad".
6) The two language specialists who translated the letter are both native Arabic speakers with extensive experience translating Arabic documents. The translators also have extensive experience in analyzing documents related to terrorism and activities in preparation thereof. The following is the translation of the letter, as prepared by the aforementioned FBI language specialists:
O, Ye Clement, O Ye Omniscient, O Ye The Most High, O Ye great, (Help us)
In The Name of Allah, The Compassionate, The Merciful
To my brother in Islam, my mother's son, the dearest of my friends
Muhammad Hassaan Hasan Al-Ya'qubi
In the name of Allah, the Compassionate, the Merciful, peace and blessing be upon the Messenger of Allah, his family and his companions:
When I heard what you are going to carry out, my heart was filled with the feeling of grief and joy because you are the closest human being to my heart and the dearest friend to me and my love to you is more than my love to myself, and when I see you contented and happy, I myself will be contented.
I do know that Allah says in the Holy Qur'an: "NOTHING IS THE LIFE OF THIS WORLD BUT PLAY AND AMUSEMENT. BUT BEST IS THE HOME IN THE HEREAFTER." There is the true life, in the presence of Allah and His Messenger, may peace and blessing of Allah be upon him. Therefore, I have no right to prevent you from your migration to Allah and his holy messenger, but it is incumbent upon me to encourage you and help you, because Islam urges Jihad for the sake of Allah. Our period in this life is a short trip in our complete trip and we must do for our hereafter as if we were dying tomorrow and the best actions for Allah, to whom be ascribed all perfection and majesty, is Jihad for the sake of Allah as He says in Chapter Al Umran, verse 195.: "THOSE WHO HAVE LEFT THEIR HOMES, AND WERE DRIVEN OUT THEREFROM, AND SUFFERED HARM IN MY CAUSE AND FOUGHT AND WERE SLAIN, VERILY, I WILL BLOT OUT FROM THEM THEIR INIQUITIES AND ADMIT THEM INTO GARDENS WITH RIVERS FLOWING BENEATH; A REWARD FROM ALLAH AND FROM ALLAH IS THE BEST OF REWARDS."
My dear brother, you are a man and a true Muslim because you want Allah, his messenger and the hereafter. You will always and forever remain in my heart and my invocation. You will, by your action, give honor to our family and the name of Ya'qubi
I ask God to love you and be your hearing with which you hear and your sight with which you see, and your hand with which you attack (*) and your leg with which you walk. I also ask Allah that your action be in compliance with Allah's order and sacrifice for His sake and propagation of Tawhid (**) doctrine and in defense of Islam and the homelands and territories of Muslims, and to raise high the word of Allah, this is the Jihad for the sake of Allah.
My dear brother, I did not say good bye properly and as you deserve when you were in my presence on Saturday, and therefore I hope that this letter will arrive before you travel to Allah and His messenger, peace and blessing of Allah be upon him, so I promise you that we will meet, Allah willing either in the present life in various types of jihad for the sake of Allah or in the hereafter, in Paradise in the presence of Allah and His holy messenger, may peace and blessing of Allah be unto him.
My brother Muhammad, Allah be with you, Allah be with you, Allah be with you, entrust to Allah your faith, your reliability and the consequences of your action may Allah keep and protect you.
Peace and the mercy and blessings of Allah be with you
Your brother in Islam
Abd Al-Muhsin Hassaan Hasan Al-Ya'qubi
night of 25 Ramadan 1421 H
[Equivalent to December 10, 2001]
(*) The phrase "hand with which you attack" was confirmed by the translating language specialists and demonstrated to me by the definitions contained in two different Arabic Dictionaries as connoting violence. While there are other definitions of the word chosen by the author, they all carry the same forceful or violent connotations by the one acting; such as "to assault, to knock (out), strike sharply; to destroy, ruin, devastate, ravage, crush, or stamp out."
The quotations in capital letters are extracts from the Qur'an.
1) Through my investigation, I have learned that MOHAMMED IDRIS, Mohammed El-Yacoubi, and Abdalmuhssin El-Yacoubi all received their elementary and high school education at the Islamic Saudi Academy, in Alexandria, VA. There, in the course of their studies, all three learned to read and write Arabic.
2) Abdalmuhssin El-Yacoubi has advised that when he learned that his brother, Mohammed, was going to Israel he wrote this letter with the purpose of conveying his concern that his brother might not return simply because he was going to an area fraught with danger. However, conversations that I have had with the language specialists regarding the letter and the message conveyed therein, leads me to believe that the letter was indeed a farewell letter from Abdalmuhssin to Mohammed El-Yacoubi as he embarked on his trip to Israel.
3) The references to Jihad in an overwhelmingly violent context cannot be confused with a letter written to someone traveling to Israel solely with the purpose of sightseeing or praying at the Al Aqsa Mosque, as both Mohammed El-Yacoubi and IDRIS later claimed in interviews with law enforcement. I know that the term "Jihad" does not necessarily refer to violence; yet the overall tone of the letter clearly implies the use of violence and/or loss of life. The translators both believe that the letter indicates that Mohammed El-Yacoubi was going to place himself at grave risk of injury or death for the sake of his Jihad.
4) Jihad cannot be confused with the term "hijrah," meaning a trip, or "haj," meaning a pilgrimage; or the term "da'wah", meaning spreading the message of Islam to those who are un-enlightened. The only place that the word "hijrah" is used within the letter is when the author says "migration to Allah and his holy messenger." As described by the two FBI language specialists, the person migrating to Allah is not expected to return, implying death. The term "Jihad," used throughout the letter, further indicates that the purpose of El-Yacoubi's and IDRIS' trip to Israel was for the sake of terrorism or supporting terrorism. From my experience, I have learned that the term "Jihad" is frequently used by militant Islamic fundamentalists to explain their violent actions in support of Islamic or political goals.
5) In an effort to further understand the letter and its meaning, I interviewed Reuven Paz, Director of the Project for the Research of Radical Islam, Haifa, Israel. Paz has recently served as a Senior Fellow at the Washington Institute for the Middle East and formerly as the Academic Director for the International Policy Institute for Counter-Terrorism. He is a published academic who is a recognized authority on suicide letters carried by "martyrs" involved in terrorist attacks by militant Palestinian resistance groups in Palestine and Israel. Paz reviewed a copy of the letter, without being provided any background on the context of where the letter was found or the identities of the parties involved. Following a review of the letter, Paz surmised that the letter was written from a younger sibling to an older brother. It appears that the older brother was going to commit suicide. A particular verse from the Qur'an quoted in the letter, Al Umran Verse 195, which contains: "those forced to leave their homes" is commonly used by Palestinians in support of their cause against Israel. This verse is consistent with what Paz has seen in other Hamas and/or Palestinian Islamic Jihad (PIJ) terrorist suicide letters. Paz said that the author appears concerned that the older brother will die in an attack.
6) On or about 01/14/2002, I searched the Internet and located a Web-Site published by El-Yacoubi's mother and father. The Web-Site, located at , indicates that El-Yacoubi's parents have published a number of books. Two of the books publicized on their Web-Site appear to contain anti-Western themes. One such book is entitled The Cultural Collapse of Eastern and Western Satanic "Civilization", while the other book is entitled Deadlock of Eastern and Western Kufur Secular Concepts of Rights. Based on my experience and consultation with FBI language specialists, I have determined that the term "Kufur" means "infidelity," "blasphemy," and "disbelieving in the Qur'an or in any of the tenets of the Muslim religion." The topics of these books appear to be consistent with some themes asserted by Osama bin Laden regarding the past triumph of Islam over the Soviet Union in Afghanistan, and the imminent clash with, and triumph over, America and Western civilization.
7) In January and February 2002, a grand jury in this district was investigating whether Mohammed El-Yacoubi and MOHAMMED IDRIS, among others, were providing or attempting to provide material support to Hamas, Islamic Jihad (each of which has been designated as a terrorist group by the United States) and/or other international terrorists, in violation of 18 U.S.C. §§ 2339A and/or 2339B. Pursuant to that investigation, IDRIS appeared and testified twice before Grand Jury 00-4, first, on January 9, 2002, and then again on February 14, 2002. Based on my review of IDRIS's grand jury testimony, interviews with a number of his associates, and a review of documents, as described below, IDRIS made numerous false statements under oath on both occasions in which he testified.
8) Mohammed El-Yacoubi told me that in late November 2001, he and IDRIS decided to take a trip to Israel for the purpose of sightseeing and praying at the Al Aqsa Mosque. According to El-Yacoubi, at the time he decided to take his trip to Israel, he was working for American Express Financial Advisors and studying for a securities industry examination. El-Yacoubi was part of a training class and his continued employment with American Express was contingent upon him passing the securities industry examinations. El-Yacoubi had come to the realization that he would not pass the examination, scheduled for 12/07/2001, and as a result would soon be unemployed. El-Yacoubi prepared for his trip to Israel assuming that he would fail the examination and therefore be free to travel.
9) A travel agent at Millenium Travel in Vienna, Virginia advised me that on 11/29/2001, El-Yacoubi contacted Millenium Travel to make reservations for the trip, requesting two round-trip tickets to Jerusalem. El-Yacoubi did not explore any other travel destinations with the travel agent and advised that he did not need assistance with lodging accommodations because he had family and friends with whom he would be staying during the trip. The travel agent advised that on 11/30/2001 El-Yacoubi purchased the two tickets using approximately $2,000 in cash. El-Yacoubi advised that he obtained the cash for the tickets from IDRIS. El-Yacoubi said that he did not have the funds available at the time he purchased the tickets, and therefore needed IDRIS to finance the purchase until funds were wired into his account.
10) El-Yacoubi had saved about $8,000 from earnings made during previous employment and from his investment activities. When El-Yacoubi made his decision to travel to Israel, most of his money was still in his brokerage account and therefore not accessible when needed to purchase airline tickets. El-Yacoubi liquidated his brokerage account and transferred the funds to his personal account at Chevy Chase Bank. El-Yacoubi then withdrew his funds from Chevy Chase in the form of cash and took a portion of these funds with him on his trip, leaving the remainder in his desk drawer at home. El-Yacoubi advised that he took approximately $3,000 to $4,000 with him on his trip. An interview with El Al security indicates that El-Yacoubi only had $2,000 with him on his trip.
11) El-Yacoubi further advised that on 12/08/2001, he traveled to Charlottesville, Virginia to visit his younger brother, Abdalmuhssin, at the University of Virginia (UVA). While at UVA, Mohammed El-Yacoubi told Abdalmuhssin about his intended trip to Israel. Following Mohammed El-Yacoubi's departure from UVA, Abdalmuhssin began drafting the letter that his older brother would later carry with him on his trip. Abdalmuhssin said that he spent the remainder of the night and the following day preparing for and drafting this letter, even though he had a full schedule of final examinations the following week. I believe that Abdalmuhssin drafted this extraordinary letter to his brother under these circumstances because, based on his conversations with Mohammed, he believed that his brother was about to engage in terrorist activity that he might not survive.
12) During sworn testimony before the grand jury on 01/09/2002, IDRIS advised that he and El-Yacoubi had considered going to the Vatican, Israel, and Saudi Arabia when planning their trip. They decided on Israel because it was the cheapest destination found by their travel agent. As described above, the only destination considered by El-Yacoubi and IDRIS was Jerusalem. The travel agent advised that El-Yacoubi was adamant about Jerusalem as their destination and did not explore any other alternatives. El-Yacoubi advised that, while he and IDRIS had discussed travel to various destinations in the past, including Europe and the Middle East, Israel was the only destination discussed by them for this particular trip.
13) Mohammed El-Yacoubi has advised that IDRIS came up with the idea of getting new passports for their trip to Israel because both he and El-Yacoubi had entry stamps from prior travel to Saudi Arabia in their existing passports. IDRIS believed that the Saudi stamps would cause problems with the Israeli authorities and could possibly inhibit their entry into Israel. El-Yacoubi advised that prior to their going to the U.S. Passport Office on 12/10/2001, IDRIS called and made reservations, using an automated reservation system to make their applications for passports. I have probable cause to believe that IDRIS and El-Yacoubi wanted new passports that lacked references to prior travel to Saudi Arabia in order to enhance the likelihood that they would be allowed into Israel and to avoid suspicion by Israelis that they were there to commit or support acts of terrorism.
14) During interviews with IDRIS on 12/20/2001 and 12/26/2001, he was asked about his previous passport. IDRIS advised that he had misplaced his old passport and wanted a new one because the misplaced one had a Saudi Arabia stamp in it and that he did not want this to cause problems in getting into Israel. On 12/20/2001, IDRIS also denied that he fabricated the story of losing his old passport in order to get a new one.
15) El-Yacoubi stated that on 12/13/2001, the day of departure, Mohammed Anaim, also known as Mohammed Naim, drove El-Yacoubi and IDRIS to the U.S. Passport Office where they picked up their new passports and then to Dulles International Airport to catch their flight to New York. El-Yacoubi stated that he and IDRIS brought their old passports with them in the event that their new passports were not ready. El-Yacoubi advised that he and IDRIS went into the passport office together and obtained their new passports. After receiving his new passport, El-Yacoubi provided his old passport to Anaim to be returned to him when he came back from his trip.
16) IDRIS' False Testimony Regarding Loss of Passport:
17) In his sworn testimony before the grand jury on 1/9/2002, IDRIS claimed that he obtained a new passport for the trip to Israel because he had previously lost or misplaced his old passport. He pinned down the last time he used his old passport as the date he used it for identification at the Virginia DMV to get his driver's license, which was in January 2001. IDRIS testified that he gave the old passport to his mother after going to the DMV and that he discovered it was missing a "couple of weeks [later], not more." In sum, IDRIS testified that he lost his passport in January or February 2001 and never found it again.
18) On 12/31/2001, Halima Karar Idris, MOHAMMED IDRIS' mother, advised me that sometime around the middle of Ramadan, possibly in the beginning of December 2001, she became aware that her son was planning a trip to Israel. Halima Idris advised that she attempted to locate MOHAMMED's United States passport for the trip, however, she was unable to find it, after a thorough search of their residence. She concluded that she had lost his passport.
19) I have determined from a review of United States passport applications that on 12/10/2001 IDRIS and El-Yacoubi went to the United States Passport Office in Washington, D.C. to apply for new passports to use during their upcoming trip to Israel. Both claimed that they had lost or misplaced their current passports. With respect to IDRIS' passport, number Z8018075, he submitted a form entitled "Statement Regarding Lost or Stolen Passport," in which he stated:
I left it in my girlfriends house in Chicago. She left last week to France, I wanted to surprise her so I purchased tickets to Paris. But there is no way for me to get to my Passport in Chicago.
IDRIS further claimed that the loss was discovered "last Tuesday,", which would have been 12/04/2001.
1) El-Yacoubi advised that about one week after purchasing the tickets from Millenium Travel, he re-paid IDRIS for a portion of the ticket expenses using a $650 check. El-Yacoubi provided the FBI with a copy of the canceled check, number 258, dated 12/05/2001, written to "MOHAMMED IDRIS," on the account of Mohammed H. El-Yacoubi. The endorsement on the back of the check contains a signature clearly resembling that of MOHAMMED IDRIS. Written directly below IDRIS' signature is a driver's license number and a passport number -- Z8018075.
2) Based on a review of bank surveillance photographs and bank teller interviews, I have determined that on 12/06/2001, IDRIS cashed the check at the Annandale branch of Chevy Chase Bank, located at 7030 Little River Turnpike, Annandale, Virginia. In order to cash this check, IDRIS used, for identification, a Virginia Driver's license, number 579-19-8976, and a United States Passport, number Z8018075. This is the same passport that four days later in his written application for a new passport, IDRIS claimed had previously been lost in Chicago. And, this is the same passport that IDRIS told the grand jury he has not seen since losing it after going to the DMV in January 2001.
3) IDRIS' False Testimony Regarding Middle East Issues:
4) When questioned in the grand jury on 1/09/2002 about events in the Middle East, IDRIS was asked whether suicide bombers are ever justified. He replied, "No, of course not." When asked if he knows "anyone who believes that suicide bombings sometimes can be justified," he responded, "No, sir."
5) In his sworn testimony before the grand jury on 02/14/2002, IDRIS denied that his friend Mohammed Anaim encouraged him to be more interested in the political situation in the Middle East. IDRIS also testified Anaim was "not usually" interested in the Israel-Palestinian situation. He also again testified that "no suicide bombings are justified" and that no one in his circle of friends believed that suicide bombings could be justified, even as a defensive measure, in Israel or the area some might refer to as Palestine. IDRIS also testified that he has never heard any of his friends say, nor does he know anyone that espouses the belief, that the bombing on September 11th was the work of a Jewish conspiracy or a Zionist conspiracy.
6) In the course of this investigation, I have interviewed some of IDRIS' close personal acquaintances. Three of these cooperating witnesses, CW1, CW2, and CW3 have known IDRIS for a number of years. All have described how Mohammed Anaim was particularly interested in, and vocal about, the Israel-Palestinian situation, guiding IDRIS, in particular, to a heightened interest in such matters.
7) CW1 said that in July 2000, IDRIS, El-Yacoubi, and other members of their group of friends, underwent a significant change in personality when a mutual friend was involved in a serious car accident. The entire group of friends became more focused on Islam. CW1 further advised that over time, IDRIS and El-Yacoubi became particularly attached to an individual named Mohammed Anaim (mentioned above and often referred to as Mohammed Naim). Anaim was very vocal in his support of Palestinians and his hatred of the Israelis/Jews. Anaim was also very knowledgeable about Palestinian issues and would often discuss them with the group. According to CW1, "Anaim breathes, drinks, sleeps, talks the Palestinian cause." El-Yacoubi, IDRIS and Anaim were more focused on Palestinian issues than others in the group, sitting around for hours watching the news to see the latest reports on events taking place in Israel. It seemed as though the three kept up with the events occurring in "Palestine" and Israel more than people actually living there. The three would become emotionally upset about the events, and visibly excited when news of suicide or other bombing attacks against Israelis were broadcast, making comments like "payback's a bitch." CW1 believes that, over time, IDRIS surpassed the others in his Jewish paranoia and hatred. IDRIS would complain that everything bad that happened was the fault of the Jews, saying in one instance: "the Jews are probably behind this." IDRIS and El-Yacoubi were present while Anaim discussed his theory that the Israelis were behind the 9/11 attacks.
8) CW2 provided similar information to that of CW1 regarding a transformation of personality that occurred around July 2000, coinciding with a mutual friend's car accident. According to CW2, the entire group became more focused on their religion and the events affecting Islam, specifically including the struggle between the Palestinian people and the Israeli forces throughout Israel and "Palestine." CW2 advised that IDRIS, El-Yacoubi and Anaim developed an increased interest in the current events and politics in the region, coinciding with the recent uprising or "intifada" in Palestine. CW2 advised that he, IDRIS, and their entire group of close friends discussed suicide bombings as a justified alternative for the Palestinian people and that the Israeli enemy was a justified target.
9) CW2 continued that IDRIS and El-Yacoubi both believed that suicide bombings were an effective defensive measure for the Palestinian people, in that it was the only weapon that they have left. This was a common feeling among the group. Suicide bombings were effective in that they helped stem the flow of Jews to Israel, in general, and, specifically, to the occupied territories, stating that approximately one million Jews have left Israel and no new ones are coming in. CW2 said the group believed and discussed that suicide bombings are sometimes good and sometimes bad. They discussed that suicide bombings are justified, particularly since there is a large population of unemployed, displaced young Palestinian men that have no apparent way to improve their plight or assist in the cause against Israel. They agreed that, unfortunately, this is the only technique that some men have left.
10)CW3 advised that IDRIS, El-Yacoubi, and Anaim were among a group of friends that would often watch the news, particularly events in the Middle East. They talked about the Palestine/Israel struggle "more than a million times." The group, including IDRIS and El-Yacoubi, always watched the news. Everyone was talking about the Palestinian/Israeli conflict, but Anaim seemed particularly interested. CW3 said that Anaim asserted that the Israelis were behind the September 11 attacks in the United States and that their entire group discussed this theory. CW3 also said that the group of friends would often discuss Hamas.
1) As described above, it was material to the grand jury's investigation to determine whether MOHAMMED IDRIS and Mohammed El-Yacoubi planned to participate in any acts of terrorism or violence in their aborted December 2001 trip to Israel. Accordingly, any false declarations IDRIS made with respect to his beliefs about suicide bombings in Israel were material to the grand jury's investigation. Furthermore IDRIS' alleged false testimony about losing his passport was material, in that had he testified truthfully (i.e., that he had not lost his passport), the grand jury would have been more likely to determine that his travel to Israel was not merely as a tourist but as one intending to commit, or provide material support for, acts of terrorism.
2) Based on the foregoing, there is probable cause to believe that on or about January 9, 2002 and February 14, 2002, in Alexandria, Virginia, within the Eastern District of Virginia, MOHAMMED IDRIS, while under oath, did unlawfully and knowingly make false material declarations before a grand jury, in violation of Title 18, United States Code, Section 623.
3) There is also probable cause to believe that within the residence of MOHAMMED IDRIS, at 4510 Airlie Way, Annandale, VA, there exists both IDRIS's prior and recently issued passports, as described above, as well as other documentation related to the application and issuance of passports to him, all of which constitute fruits, evidence, and instrumentalities of crimes against the United States, to wit: the offense of false statements in the application and use of a passport, in violation of Title 18, United States Code, Section 1542.
John V. Wyman
Federal Bureau of Investigation
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