‘EXBIBIT A
APEIDAVIT OF HEIDI L.. WILLIAMS
I, Heidi L. Williams, a Special agent of the Federal Bureau
of Investigation ("FBI"), in Boston, Massachusetts, being duly
sworn, depose and state:
1. Tam employed by the PBI as a Special agent and am
assigned to the Joint Terrorism Task Force ("JTTF"). I have been
‘a Special Agent of the FBI for over five years. Ihave been
assigned to the OTT for over four years. In my current
assignment, I am involved in investigations and prosecutions of
terroriem and terrorism offenses. I am currently assisting other
TTF agents in the investigation of TAREK MEHANNA (*MEHANNA‘) and
AHMAD ABOUSANRA ("ABOUSAMRA”) and others, for several offen:
including, material support for terrorists and designated
terrorist organizations, conspiracy to kill in a foreign country,
and conspiracy to violate the laws of the United States, in
violation of 18 U.S.C. §§ 2339A & B, 956, and 372.
2. The information contained in this affidavit is based
upon interviews of witnesses, review of witness statements or
reports of others who conducted interviews, my conversations with
fellow members of the JTTP who have personal knowledge, my review
of recorded conversations and documents related to this
investigation, as well as personal observations or reports of the
observations of other agents, and inferences I have drawn from=P 109. mumerous files on the Computer revealed that MEHANNA
and others glorified the September 11, 2001 terrorist attack.
For example, the Computer contained photographs depicting MEHANNA
and others at the construction site at Ground Zero (the site of
the World Trade Center complex) in New York with large grins and
MEHANNA has one finger pointed up in the air. Another
communication revealed that MEHANNA sought out internet links to
a tribute video to the September 11, 2001 hijackers. Ina
communication from June 2006, he laughed after saying that New
York was no longer the land of the two towers without the two
towers. Instead, he suggested calling it the land of rape
MEHANNA then stated that instead of asking for God’s mercy for
the victims in the World Trade center, he suggested asking for
vallah’s [] mercy on just the buildings[,] not the sinners that
were in it [,] ae at least the buildings weren't sinners(.]*
110. Communications and files located on the Computer also
indicated that MEHANNA gave advice to another like-minded
individual on where to go in Yemen, since he had been there. For
example, in May 2006, MEHANNA said that when he was there, it was
very tribal, full of bandits and al-ga’idah, and he advised going
to a particular school there. .
111. The Computer revealed that MBHANNA and others reveled
in the death of United States servicemen overseas. For example,
40butter and jelly," which was aleo referred to as “P, BJ.”
MBHANWA told CH2 that when Maldonado told MEHANNA that he was
“making peanut butter and jelly sandwiches." NEHANNA warned
Maldonado that he shoulda’t say things Like that over the
telephone. #2 asked MBHANWA what the phrase meant. MBHANNA
stated that, in general, it meant “I'm here fighting.”
85. CW2 pressed MBHANNA on what Maldonado knew and what
ABOUSAMRA might have told him, MEHANNA could not say
specifically vhat he was told, but stated because “people are not
freaking idiots,” it ie not necessary to “sit down and explain
these things to people like Dan (i.e., why they went to Yemen
and why ABOUSAMRA went to Iraq). MEHANNA added, if you told Dan
(tardonado) “1 was in Afghanistan’ he wouldn't say “what were you
doing there? (I believe he meant that, without having to
explicitly say s0, Dan would obviously understand that the reason
one of them would go to Afghanistan is to engage in jihad.)
85. MBHANNA admitted to C#2 that he hung out with Maldonado
at least once a month before Maldonado moved to Houston, MBHARNA
stated that he has also stayed in contact with ABOUSAMRA, since
ABOUSAMRA eft the United States.
=D 07. cw? also asked MBHANWA if his parents knew why he went
to Yemen. MEHANWA told CW2 “they know I didn’t go there to graze
goats." MEHANNA opined that Daniel Maldonado and others know
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