Talib Abu Salam Ibn Shareef
STATE OF ILLINOIS)
)
COUNTY OF COOK)
AFFIDAVIT
1. I, Jared Ruddy, Federal Bureau of Investigation, being duly sworn, state as follows: I am a Special Agent in the Federal Bureau of Investigation (“FBI”) and have been so employed for more than two years. I am currently assigned to an FBI Counterterrorism squad as well as the Chicago Joint Terrorism Task Force (“JTTF”). My duties include the investigation of individuals who criminally violate the criminal laws of the United States Code. The information contained in this affidavit is based on personal knowledge, information supplied to me by other law enforcement officers, conversations with a confidential source that participated in this investigation, and review of certain documents and records related to this investigation. This Affidavit is submitted for the limited purpose of showing that probable cause exists to charge defendant DERRICK SHAREEF, also known as (“a.k.a.”) “Talib Abu Salam Ibn Shareef,” with (1) attempting to maliciously damage and destroy, by means of fire and an explosive, a building and real and personal property used in interstate commerce and in any activity affecting interstate commerce, in violation of 18 U.S.C. § 844(i) and (2) attempting to use a weapon of mass destruction against persons and property within the United States, and the offense and the results of the offense would have affected interstate commerce, in violation of 18 U.S.C. § 2332a(a)(2)(D). Thus, I have not set forth each and every fact known concerning this investigation.
Background of the Investigation
2. Beginning in September 2006, SHAREEF became acquainted with an individual in Rockford, Illinois. During the course of their acquaintance, SHAREEF advised this individual that he (SHAREEF) wanted to commit acts of violent jihad against targets in the United States as well as commit other crimes in order to obtain funds to further his (SHAREEF’s) goals of violent jihad. Unbeknownst to SHAREEF, his acquaintance (“CS”) was cooperating with the FBI.1 During their acquaintance, SHAREEF advised the CS that he (SHAREEF) wanted to obtain weapons to commit violent jihad. The CS advised SHAREEF that he (the CS) had a friend who was able to obtain weapons and that he (the CS) would introduce SHAREEF to the friend. In fact, the CS’s purported friend was an undercover law enforcement agent (“UCA”).
SHAREEF and the CS Discuss Potential Targets and Visit CherryVale Shopping Center
3. On or about Wednesday, November 29, 2006, in a recorded conversation, SHAREEF and the CS discussed SHAREEF’s goals regarding an attack. The CS said to SHAREEF, “when you were talking to me earlier, you seemed really upset.” SHAREEF responded: “I was already upset from previous things.” The CS then asked: “So, what you wanna do? I was thinking about it upstairs.” SHAREEF responded: “A target? . . . I want some type of city hall-type stuff right now, federal court houses.” The CS then asked: “I didn’t know how serious you are, ‘cause I gotta know . . .” SHAREEF interrupted: “No, hell no, I don’t talk calm when it comes to this. I’m talking about stuff that’s like, . . . ‘cause man the courthouse in DeKalb where I be going every month them niggers do weak as hell. You go in there and you clock the first three niggers at the door that they got, and you up in there, you know what I’m saying? And everything else is gonna have to be tactical. But see when you dealing with stuff like that, the courthouse, there’s always a PD [police department] right down the block. Know what I’m saying? I just want to smoke a judge.” After some additional discussion, the CS asked SHAREEF: “When you wanna plan on doing this? Because we have to make specific plans and dates, time.” SHAREEF responded: “Well, I wanna case one first, we can case one when you get the car back.” The CS then asked: “What about time frame? . . . ‘Cause you got to prepare for everything?” SHAREEF responded: “What do you think? I like the Holiday season.” A few moments later, SHAREEF stated: “You gotta do stuff, hell we ain’t gotta hit nobody, just blow the place up. You gotta do stuff under severe weather conditions. That helps too. Doing stuff in the snow, rain because you see less pigs out there. That’s tactical.” Later in the conversation, SHAREEF stated: “I’m thinking stuff like courthouses, city hall, government places, government facilities.” The CS then asked: “So, you serious,” and SHAREEF responded: “I’m serious. . . .”
4. The following day, on or about Thursday, November 30, 2006, at approximately 6:00 p.m., the CS advised SHAREEF that he (CS) had received a call from the UCA. The CS stated that the UCA had asked during the call whether SHAREEF planned to purchase any weapons from the UCA. The CS and SHAREEF then engaged in a discussion about places where they could conduct an attack against civilians. Specifically, the CS then asked if SHAREEF believed it was a better idea to “hit the mall,” and SHAREEF responded that the mall was “just one potential place.” The CS then stated: “I mean, alright, we gotta look at it this way, we want to disrupt Christmas.” SHAREEF responded: “Oh hell yeah, the mall is where it’s at.” The CS then asked SHAREEF if he believed that they needed grenades for the attack, and SHAREEF responded that they did. The CS stated: “You go in there and toss a grenade, and no one’s gonna know who did it.” SHAREEF responded: “No one’s gonna be expecting no shit like that.” SHAREEF then stated: “The last thing anybody gonna be thinking about at the mall is a damn grenade.” Later in the conversation, the CS asked SHAREEF: “What targets you wanna hit, the mall’s good?” SHAREEF responded: “Any place that’s crowded, like a mall is good, anything, any government facility is good.” SHAREEF told the CS: “I swear by Allah man, I’m down for it too, I’m down for the cause, I’m down to live for the cause and die for the cause, man.” In the same conversation, SHAREEF stated: “Here, we’re gonna check out some places, see where you could possibly lob one, do you toss it, do you, could you just sit it down and tip off, speed walk away.”
5. At approximately 6:15 p.m., on November 30, 2006, FBI surveillance personnel who were following SHAREEF observed SHAREEF and the CS arrive at the CherryVale Shopping Center in Rockford, Illinois. As they arrived at the mall, SHAREEF and the CS continued their conversation which was still being recorded. Specifically, SHAREEF stated: “I think, ah, if we do, do something like this, we gotta do, we gotta do it simultaneously, like you would have to hit one spot and I’ll do another one.” The CS responded: “That’s fine.” SHAREEF then stated: “Just meet back up, so it would create more pandemonium, and nobody will really be looking at, you know, nobody will be looking for anyone suspicious ‘cause it’ll be 80 million people running.” SHAREEF and the CS then continued walking around the mall property and discussing the layout of the mall.
While they were in the mall, the CS asked SHAREEF: “But if you ever wanna back out, ‘cause you gotta let me know before I make the phone call, ‘cause I’m checking your heart now. . . ‘Cause I have to call my boy, man.” SHAREEF responded: “I’m down.” The CS then stated: “We ain’t gonna get caught, don’t worry.” SHAREEF responded: “I’m not worried about getting caught, not alive.” The CS then stated: “If we die, then we die.” SHAREEF responded: “I’m gonna fast for like three days before.” During this conversation at the mall, FBI surveillance personnel were following SHAREEF.
SHAREEF and the CS Visit the CherryVale Shopping Center a Second Time
6. The following day, on or about Friday, December 1, 2006, the CS advised SHAREEF: “He said he had an order for 11, . . . 11 pineapples.” SHAREEF responded: “Shit, did he do that so he could give ‘em to us wholesale?” The CS stated: “No, he said that he’d sell them to us for $50 a pop.” The CS then stated, you can change the time up to 15 seconds.” SHAREEF asked: “How do you do that?,” and the CS answered: “You crank it, there’s a crank on it.” SHAREEF then asked: How do you know you cranking that shit the right way?,” and the CS responded: You gotta listen.” SHAREEF then responded: “And then explode.” The CS then stated: “He said the longer you take, the harder the pin, the harder the hammer.” SHAREEF responded: “So that shit gonna be like Boom!” Based on my training and experience as well as the context of the call, I believe that the CS and SHAREEF were discussing purchasing hand grenades from the UCA. Specifically, I believe that the CS and SHAREEF were discussing the timing mechanism on the grenades which SHAREEF and the CS intended to purchase from the UCA. Approximately fifteen minutes after the preceding part of the discussion occurred, the CS and SHAREEF got into the CS’s vehicle. The two men then engaged in a discussion about shaving their body hair and meditating to prepare. Based on my training and experience as well as the context of the call, I believe that the CS and SHAREEF were discussing the preparations they would undertake prior to committing an attack.
7. A few minutes after SHAREEF and the CS discussed shaving their body hair and meditating, SHAREEF stated: “I’m ready man, these Kafirs [a term translated as “infidel”] don’t give a damn about us, niggers don’t care what happens to the Umma [an Arabic word meaning community or nation that is commonly used to mean the collective nation of Islamic states], about sisters getting raped, about brothers losing their (UI). They don’t care, man. All they care about is (UI). . . I probably would have eventually ended up just stabbing the shit outt a some Jews or something. Just stabbing them niggers with a steak knife. Dude, I ain’t gonna lie. Because during that war with Hezbollah, man, I had already started to look at synagogues out here and in the DeKalb area and everything. I was looking at synagogues, I was doing Mapquest. . . . One of them was down the block from the masjid [mosque], I knew that they do their thing on Saturdays, right. I was like, I’m gonna lay low out here, I’m gonna camp out overnight, be out there on Friday night after Jumma” [Friday payer] or Saturday morning about 12:00 or 1:00 o’clock., I be there. And as soon as I see them fools going in the building, I had planned on trying to grab one, depending on how it was, niggers trying to run in the building all at once and open up shop, I was just going to go over there and shank one or two of them.” A few minutes later, SHAREEF stated: “They definitely gonna know that this shit ain’t over, and they not as safe as they thought.”
8. Several minutes later, SHAREEF and the CS arrived again at the CherryVale Shopping Center. When they arrived at the mall, the CS stated: “This place gonna be tore up in about two weeks.” SHAREEF responded: “Damn, dude, niggers gonna be gloomy as hell out here, I don’t know how the nationwide effect gonna be, but . . . .” The CS then asked: “You don’t think it’s gonna be gloomy nationwide?,” and SHAREEF responded: “I don’t think it’s gonna be gloomy nationwide like 9/11 . . . ” The CS then asked: “You don’t think so?” SHAREEF answered: “No, not this. This ain’t big enough. It’s big enough here locally.” At about the time this conversation was taking place, FBI surveillance personnel observed SHAREEF and the CS enter the mall. After they entered the mall, SHAREEF and the CS walked around the mall measuring the amount of time it would take to walk from one point in the mall to other points. The two men also discussed placing grenades in the garbage cans at the mall. At one point in the conversation, SHAREEF stated: “It would be hard trying to do three, though, ‘cause that’s three pins you gotta pull.” The CS then stated: “I’m glad you came up with the idea, though, the garbage can. That’s sweet,” and SHAREEF responded: “That’s pandemonium. The garbage going to be shrapnel.” A few minutes later, the CS stated: Don’t forget, man, we should get the grenades some time next week,” and SHAREEF responded: “Yeah.” The CS then stated: “So you should try to get as much flous [an Arabic term for money] as you can get ‘cause we need it,” and SHAREEF responded: I got a little change in the bank.” The CS then stated: “All you need is like $100, that’s two grenades,” and SHAREEF answered: “I’m pretty sure I can get more than that from my sister.” Several minutes later, SHAREEF stated: “If Allah wills a lot of people around that garbage can, that place is crowded.” The CS responded: “It’s gonna be crowded and that can is going to blow that whole area out. Upstairs and everything. You know that. And your favorite term is sprinkler systems coming on.” SHAREEF then laughed, and stated: “Sprinklers coming on.”
SHAREEF Makes a Videotaped Statement
9. The following day, on or about Saturday, December 2, 2006, FBI surveillance personnel observed the CS and SHAREEF driving around Rockford in the CS’s vehicle. During this period that SHAREEF and the CS were driving in the CS’s vehicle, the CS and SHAREEF discussed providing a set of stereo speakers that SHAREEF owned to the UCA in exchange for four hand grenades and two handguns. Again, the two men discussed their plans to detonate the grenades in the garbage cans at the mall. Specifically, the CS stated: “I told him just to get us four grenades. You think that’ll be enough?” SHAREEF responded: “Yeah, and the sidearms, right.” SHAREEF then asked the CS: “How much do we need for ‘Cap’ [the UCA]?” The CS answered: “He didn’t say, I think what he gonna do is just take the speakers and say ‘even,’ you know what I am saying, for the grenades and the two pistols.” During this conversation, the CS asked SHAREEF if he (the CS) died before the attack, would SHAREEF carry the attack out on his own. SHAREEF responded: “Uh huh. I’ll still do this.” After this part of the conversation occurred, SHAREEF and the CS arrived at a residence where SHAREEF kept the speakers. At the residence, SHAREEF and the CS obtained a set of speakers.
10. Later that day, on or about Saturday, December 2, 2006, the CS and SHAREEF each videotaped each other making statements. Agents assigned to this investigation obtained a copy of the video from the CS and have viewed it and transcribed it. In the video, SHAREEF states: “This may be my last will and testament, the last words that I have spoken to those who know me, to those who do not know me. My name is Talib Abu Salam Ibn Shareef. I am 22 years of age. I am from America, and this tape is to let you guys know, who disbelieve in Allah, to let the enemies of Islam know, and to let the Muslims alike know that the time for jihad is now. . . . Be strong, oh Mujahideen. Be strong oh brothers who want to fight for jihad. . . . This is a warning to those who disbelieve, that we are here for you, and I am ready to give my life. . . . May Allah protect me on this mission we conduct. . . . So do not cry, do not mourn for me. Do not believe what the kafir [infidel] will say about me when you read in the newspapers and when you see the television articles about me. Do not believe this. Understand that your son is a strong man. . . who believes and fears his Lord to the degree that he will give his life.” Based on my training and experience, it is common for individuals planning attacks on civilians as part of violent jihad to make videotaped statements.
11. On or about Monday, December 4, 2006, the UCA contacted the CS by telephone. This call was recorded and an initial transcription of the call has been prepared. In the call, the UCA asked the CS if he could speak with SHAREEF. The UCA then asked SHAREEF: “So, you’re finally ready to do something, huh?,” and SHAREEF responded: “Yeah, we ready to put it down.” The two men then agreed to exchange the stereo speakers for the weapons. The UCA then stated: “What I got lined up for you, is a, I got four of them pineapples, and then I got that 9 . . .” SHAREEF responded: “Alright.” The UCA then stated: “So I’m gonna try and get you that. But, it’s gonna work out nice, so we should be all set.” SHAREEF responded: “That’s good news, man. This is good news.” The UCA then advised SHAREEF: “I’m gonna roll through on Wednesday – I’m gonna roll through there.” Based on my training and experience as well as the context of the call and my discussions with the UCA, I believe that the UCA and SHAREEF were discussing the delivery of four hand grenades and a hand gun to SHAREEF on Wednesday, December 6, 2006.
12. On or about Wednesday, December 6, 2006, at approximately 11:50 a.m., the UCA contacted the CS by telephone and asked the CS if he (the CS) and SHAREEF were ready to meet to exchange the stereo speakers for the weapons. The CS responded that he (the CS) and SHAREEF were ready. The CS and the UCA then agreed to meet at a store parking lot located on Walton Road in Rockford, Illinois a short time later. At approximately 12:25 p.m., agents assigned to the investigation observed the CS and SHAREEF arrive at the parking lot where the UCA was already waiting. After the CS and SHAREEF arrived, the UCA, SHAREEF, and the CS greeted each other near the CS’s car. (This meeting was recorded in video and audio format.) SHAREEF then opened the trunk to the CS’s vehicle and showed the UCA a set of speakers. After a brief discussion about the speakers, SHAREEF picked up the speakers and carried them to the open trunk of the UCA’s vehicle. The CS did not walk with SHAREEF and the UCA to the UCA’s car. At the trunk of the UCA’s vehicle, the UCA advised SHAREEF that he had locked the weapons in a lock box, and he kept them in a lock box in the event police ever stopped him. The UCA then opened a lock box in the trunk of his vehicle and showed SHAREEF four non-functioning grenades, a 9 millimeter hand gun, and several rounds of non-functioning ammunition. SHAREEF and the UCA then discussed the operation of the grenades. Specifically, SHAREEF asked the UCA how long between the time the grenade pin was pulled and the time that the grenade went off. The UCA explained that the time was approximately three to five seconds. The UCA then closed the lock box, SHAREEF took key to the lock box, and SHAREEF picked up the lock box. SHAREEF then placed the lock box containing the purported weapons inside the trunk of the CS’s car. At the time that SHAREEF placed the lock box in the trunk, the UCA gave a pre-determined signal to agents who were surveilling the transaction, and the agents arrested SHAREEF without incident.
13. Based upon the aforementioned information obtained from tape recordings, documents and witnesses, coupled with my experience investigating federal crimes, I believe that there is probable cause to believe that DERRICK SHAREEF violated (1) 18 U.S.C. § 844(i) by attempting to maliciously damage and destroy, by means of fire and an explosive, a building and real and personal property used in interstate commerce and in any activity affecting interstate commerce and (2) 18 U.S.C. § 2332a(a)(2)(D) by attempting to use a weapon of mass destruction against persons and property within the United States, and the results of the offense would have affected interstate commerce.
FURTHER THE AFFIANT SAYETH NOT
Jared Ruddy Special Agent, FBI
Sworn to me before and subscribed in my presence on this day of December 2006
United States Magistrate Judge
Shoppers walk through the CherryVale Mall Friday, Dec. 8, 2006 in Rockford, Ill. where federal authorities said a Muslim convert planned to wage jihad against civilians by setting off hand grenades in garbage cans during the Christmas rush.