June 16, 2005


by B.Raman, Camp: Mhow, Madhya Pradesh

The US Federal Bureau of Investigation (FBI) is reported to have uncovered an Al Qaeda sleeper cell in Lodi , near Sacramento in California . All of those so-far arrested in this connection ---- Hamid and his father Umer Hayat, Muhammed Adil Khan, Shabbir Ahmed Mohammed and Khan's son Hassan Adil - are Pakistanis or American nationals of Pakistani origin. amid is alleged to have attended an Al Qaeda training camp at a place called Tamal near Rawalpindi in 2003-04.Khan and Mohammed are described as two Imams from the Lodi Mosque.

2.The Muslim community to which these people belong is predominantly from Pakistan . It is said there are about 2,500 Pakistanis or American nationals of Pakistani origin in Lodi 's 60,000-strong population.

3.The FBI has already filed an affidavit before a court to justify its request for the continued detention of the arrested persons. The charge as levelled aginst them so far is not participating or planning to participate in a terrorist act or belonging to a terrorist organisation, but telling a lie in order to cover up the fact of Hamid having undergone training in an Al Qaeda training camp. It is alleged that Hamid initially denied it, but only subsequently admitted it when put through a lie detector test.

4. It is not clear how the FBI zeroed in on Hamid. Some Pakistani sources allege that their community at Lodi is a divided one with a lot of politics and that some sections opposed to those arrested had planted false information on the FBI against the arrested persons.

5.There are some loose links in the case as so far put up by the FBI.Among questions inadequately or unsatisfactorily answered are:

(a). Would it have been possible for the Al Qaeda to run such a training camp at or near Rawalpindi , considering the fact that the General Headquarters (GHQ) of the Pakistan Army are located there?

(b). Who was responsible for running the camp---Maulana Fazlur Rahman, the leader of the Deobandi-Wahabi organisation called the Jamiat-ul-Ulema Islam (JUI) Pakistan or Maulana Fazlur Rahman Khalil, the former Amir of the Harkat-ul-Mujahideen (HUM)? It is said that the FBI had initially mentioned the name of Maulana Fazlur Rahman, but subsequently withdrew it?

(c). It is also said that some of the arrested/suspected persons had condemned the 9/11 terrorist strikes in the US and had been members of inter-religious groups, which were campaigning against terrorism. How can they be so deceptive---seemingly working overtly against terrorism and covertly assisting the Al Qaeda and other jihadi terrorist organisations?

(d). How come Gen.Pervez Musharraf, the Pakistani President, who projects himself as a stalwart ally of the US, allows such anti-US activities to go on in Pakistani territory?

(e). How does the US continue to trust and pamper him despite such instances?

6. My comments on these questions are given in the following paragraphs:

QUESTION 1: Would it have been possible for the Al Qaeda to run such a training camp at or near Rawalpindi , considering the fact that the General Headquarters (GHQ) of the Pakistan Army are located there?

7. It is very unlikely. All the identified Al Qaeda training camps of the past were located in the Afghan territory or in the remote tribal areas of Pakistan adjoining the Afghan border in the North-West Frontier Province (NWFP) or the Federally Administered Tribal Areas (FATA). There has been no instance of an Al Qaeda training camp having been found in a non-tribal area away from the Afghan border.

8. However, there have been instances of individual Al Qaeda leaders sheltering in and operating from non-tribal urban areas. Abu Zubaidah was arrested in a safe house of the Lashkar-e-Toiba (LET) in Faislabad in Punjab . Ramzi Binalshib and Khalid bin Attash, the suspect in the case relating to the October,2000, attack on USS Cole, were arrested in Karachi . Khalid Sheikh Mohammad (KSM) orchestrated the entire 9/11 terrorist strikes in the US , at the instance of bin Laden, from hide-outs in Karachi and he was finally arrested in the house of an office-bearer of the women's wing of the Jamaat-e-Islami (JEI) in Rawalpindi .

9. It is unlikely that Pakistan 's Inter-Services Intelligence (ISI) would allow the Al Qaeda or any other jihadi terrorist organisation to run a full-fledged terrorist training camp from Rawalpindi or near it. It would be afraid that such camps may be detected by foreign intelligence officers posted in their Embassies in Islamabad .

10. However, it is quite possible for Hamid to have been trained by any Pakistani jihadi organisation in one of its madrasas in the Rawalpindi area. The jihadi terrorist training infrastructure falls into two categories-- full-fledged training camps, where religious education and motivation are part of the jihadi terrorist training and the madrasa courses for religious education where jihadi military training forms part of the course.

11. The Al Qaeda does not directly control any madrasa in Pakistan . It runs full- fledged training camps in the remote tribal areas where full-time jihadi training is imparted by Arab, Chechen, Uzbeck or other foreign instructors. It does not run any madrasa courses for religious education. It takes into its full-time jihadi training courses volunteers, who have already gone through the madrasa courses and are found to be well-motivated.

12. However, the Pakistani jihadi organisations run full-time jihadi training courses as well as courses in religious education in the madrasas controlled by them. For example, the Lashkar-e-Toiba (LET) runs full-time jihadi training courses at its headquarters at Muridke, near Lahore , as well as courses in religious education plus jihadi training in the madrasas controlled by it all over Pakistan . So too, the Harkat-ul-Mujahideen (HUM) runs full-time jihadi training courses in special camps in the North-West Frontier Province (NWFP) and the Pakistan-Occupied Kashmir (POK) and religious education courses in the madrasas controlled by it all over Pakistan.

13. The brother of Hambali of the Jemaah Islamiya (JI), and other Indonesians and Malaysians, who were arrested and deported by the Pakistani authorities in 2003, were undergoing religious education courses, with jihadi training as part of the course, in a madrasa controlled by the LET in Karachi. The Pakistani jihadi organizations use retired Pakistani military personnel for jihadi training and not foreign instructors.

14.It is, therefore, my assessment that if Hamid had really been trained in an Al Qaeda camp, it could not have been at or near Rawalpindi.If he had really been trained at or near Rawalpindi , it must have been by one of the Pakistani jihadi organisations and not by the Al Qaeda.Either he has been misleading the FBI or it has not properly interrogated him. I have noticed even in the past that the interrogation of the jihadi terrorists by the FBI and other US agencies---whether in Afghanistan or Pakistan or Iraq or elsewhere--- tends to be superficial and the jihadi terrorists find it easy to mislead the Americans, who understand very little of Islam and the Muslims.

QUESTION NO.2:Who was responsible for running the camp---Maulana Fazlur Rahman, the leader of the Deobandi-Wahabi organisation called the Jamiat-ul-Ulema Islam (JUI) Pakistan or Maulana Fazlur Rahman Khalil, the former Amir of the Harkat-ul-Mujahideen (HUM)? It is said that the FBI had initially mentioned the name of Maulana Fazlur Rahman, but subsequently withdrew it.

15. Maulana Fazlur Rehman is a member of the National Assembly ( lower House) of the Pakistan Parliament and leader of the opposition. The fact that the FBI mentioned his name initially as the runner of an Al Qaeda training camp, if true, shows how little they understand even Pakistan, which the Bush Administration describes as its stalwart ally.

16. His party, which advocates the Deobandi-Wahabi ideology, is an active member of the Muttahida Majlis-e-Amal (MMA), the coalition of Islamic fundamentalist parties, which has been strongly opposing Gen. Musharraf's pro-US policies and calling for the resignation of Musharraf as the Chief of the Army Staff (COAS).

17. He used to be a close personal friend of the late Mufti Nizamuddin Shamzai of the Binori madrasa of Karachi , who was assassinated last year. Shamzai was considered the religious mentor of bin Laden and inspired and influenced the Al Qaeda's religious thinking and its anti-US and anti-Israeli policies.

18. Maulana Fazlur Rahman personally knew bin Laden through Shamzai. After the terrorist strikes near the US Embassies in Nairobi and Dar-es-Salaam in 1998, the Clinton Administration pressed Nawaz Sharif, the then Pakistani Prime Minister, to allow a US commando group to operate from Pakistani territory in order to capture bin Laden. Karl Inderfurth, the then Assistant Secretary of State, conducted secret negotiations with Nawaz Sharif and his officials in this connection.

19. This information was allegedly leaked to the media by Musharraf, in order to embarrass Nawaz and alert Mullah Mohammad Omar, the Amir of the Taliban, and bin Laden. On coming to know of this, Maulana Fazlur Rahman issued a public statement warning the US that no American would be safe in Pakistan , if the US captured or killed bin Laden.

20. A diplomat of the US Embassy in Islamabad called on Maulana Fazlur Rahman and warned him that the US would hold him personally responsible if any harm came to Americans in Pakistan . Thereafter, he toned down his anti-US rhetoric in support of bin Laden.

21. Five Pakistani jihadi organisations are members of bin Laden's International Islamic Front (IIF) for Jihad Against the Crusaders and the Jewish People formed in February,1998. These are the Harkat-ul-Mujahideen (HUM---previously known as the Harkat-ul-Ansar HUA), the Harkat-ul-Jihad-al-Islami (HUJI), the Jaish-e-Mohammad (JEM), the Lashkar-e-Toiba (LET) and the Lashkar-e-Jhangvi (LEJ).

22. Of these, the HUM, which now has an international wing called HUM--Al Alami, is a founding member of the IIF. Its then Amir, Maulana Fazlur Rahman Khalil, different from the JUI leader mentioned above, was a co-signatory of bin Laden's first fatwa against the US . The other organisations joined the IIF subsequently.

23. Of these, the HUM is the most virulent anti-US organisation, which has sleeper cells in the black Muslim and Pakistani communities in the US since the early 1990s. It had been calling for attacks on US nationals and interests all over the world even before bin Laden moved to Afghanistan from the Sudan in 1996.The HUM has not only been involved in acts of jihadi terrorism in India 's Jammu & Kashmir, but has also been assisting for many years the jihadi terrorist groups of southern Philippines , particularly the Abu Sayyaf, Myanmar (the Rohingyas), Tajikistan and Chechnya.Its cadres had infiltrated into Iraq before the US-led invasion of that country in 2003.

24. The concept of a global jihad against the US and Israel was first enunciated by it and then borrowed from it by bin Laden. It has always been projecting Pakistan 's atomic bomb as an Islamic bomb, which should be available for use by any Muslim country. It was the first to talk of the right and the obligation of the Muslims to acquire and use weapons of mass destruction (WMD), in irder to protect their religion, if left with no other alternative.

25. The HUM has also been projecting the black Muslims of the US as an important asset to be utilised in the jihad against the US and had trained some of them in its camps in Pakistan in the 1990s. It has also been recruiting members of the Pakistani diaspora in the West.It has the long-term objective of creating Muslim homelands in Spain, Belgium, the UK and the USA.Before 9/11, it had also started a drive for promoting solidarity amongst Muslims serving in the Armerd Forces of non-Muslim countries.

26.Of the five Pakistani jihadi organisations, which are members of the IIF, the HUM, the HUJI and the JEM are the closest to Maulana Fazlur Rahman of the JUI. All these three once constituted a single organisation called the HUA, which was involved in the kidnapping of some Western tourists in J&K in 1995 under the name Al Faran. At the request of the US Embassy in Islamabad , Mrs. Benazir Bhutto, the then Prime Minister, had requested Maulana Fazlur Rahman of the JUI to visit India and persuade the HUA in J&K to release the Western hostages. The then Government of India headed by Prime Minister Narasimha Rao was not prepared to let him go to J&K because of his long-known links with Deobandi-Wahabi terrorist organisations. His visit was, therefore, unsuccessful, and he went back to Pakistan .

27.In October 1997, the US State Department designated the HUA as a Foreign Terrorist Organisation (FTO) under a 1996 US law. Thereafter, the HUA split into two organisations called the HUM and the HUJI, which started operating separately in public. But, they co-operated with each other in secret. The HUM underwent another ostensible split in 2000 leading to the formation of the JEM.

28. Before 9/11, the HUM, the HUJI, the JEM and the LEJ used to have their training camps in Afghan territory. Arab and Chechen instructors of the Al Qaeda used to impart training to the inmates of these camps. Only the LET preferred to have its recruits trained in its headquarters at Muridke, near Lahore .

29. The US Cruise missile attacks on the training camps in the Afghan territory in October,1998, destroyed the camps of the HUM inflicting many casualties among the trainees and instructors. They also destroyed some make-shift mosques and a large number of copies of the Holy Koran kept there for the use of the trainees, including some of historic value.

30. Maulana Fazlur Rahman Khalil, its then Amir, had, in a statement condemning the attacks by the US , warned:" You had come and attacked us in our territory with your Cruise missiles. We will come and attack you in your territory with our Cruise missiles." Many sources assert that the 9/11 terrorist strikes in the US homeland were in retaliation for the Cruise missile attacks of 1998.

31.Similarly, now the HUM and the other jihadi terrorist organizations close to it have been calling for a major terrorist strike against the Pentagon in Washington DC in retaliation for the alleged desecration of the Holy Koran by the US guards in the detention centre at Guantanamo Bay . Even Omar Sheikh, the Pakistani from the UK, the main conspirator in the case relating to the kidnapping and murder of Daniel Pearl, the US journalist in January-February,2002, has been circulating messages from his jail, with the complicity of the jail authorities, calling for retaliatory attacks against the US for allegedly desecrating the Holy Koran. It is my assessment that the next 9/11 in the US homeland, if there is one, would be a sequel to what happened at Guantanamo Bay .

32.The post-Madrid investigations in West Europe have given rise to concerns in the West that the Moroccan and Pakistani diasporas in West Europe have been developing into the new hub of jihadi terrorism. Moroccans and Pakistanis and persons of Moroccan and Pakistani origin constituted the largest number of terrorist suspects detained in West Europe last year. The alleged discovery of a sleeper cell in the Pakistani community at Lodi in California has come in the wake of the discovery of an LET cell in the US in 2003.

33. It is, therefore, not without surprise that the US authorities and public opinion have been greatly concerned over the arrests at Lodi . From the indications available so far, Hamid seems to be more a sleeper agent of the HUM than of the Al Qaeda.

34. Another Pakistani jihadi organisation with a long and well-established history of sleeper cells not only in the US , but also in Canada and the Caribbean is the Jamat-ul-Fuqra (JUF) headed by Sheikh Mubarik Ali Gilani. It used to be very active in Canada and the US in the late 1980s and the 1990s and had carried out attacks on members of the Jewish and Hindu communities in the US.Daniel Pearl had gone to Karachi mainly to investigate reports of its suspected links with Richard Reid, the so-called shoe bomber, when he was trapped and kidnapped by Omar Sheikh and his associates.

QUESTION No.3:It is said that some of the arrested/suspected persons had condemned the 9/11 terrorist strikes in the US and had been members of inter-religious groups, which were campaigning against terrorism. How can they be so deceptive---seemingly working overtly against terrorism and covertly assisting the Al Qaeda and other jihadi terrorist organisations?

35.To answer this question, one can do no better than quote from the comments of the North-East Intelligence Network, a terrorism analysis group of the US . It said on June 9,2005: " Lodi-- From the terrorist training camps in Pakistan to the mosques in America , we are engaged in war of deception. That "war of deception" is being waged on us as the recent arrests in Lodi illustrate. The very same Islamic Imams who vociferously "condemned" the 9/11 attacks are embroiled in the alleged training of Islamic terrorist operatives planning to use their skills to kill us here in America . This is a perfect example of the contemptuous intolerance of Islam again all other faiths, and the deceit permitted by the Islamic Qu'ran and Hadith when justified in "fighting the enemy."

36."Muhammed Adil Khan led efforts to build the Farooqia Islamic Center, including an Islamic school for young children. He also joined the leaders of local Christian churches and a synagogue to issue a "Declaration of Peace" condemning terrorism and stressing the common origins of each religion. Yet, that same Imam is alleged to bem among up to a dozen others in the same group or "cell" involved in providing material support to potential terrorist operatives inside the U.S.

37."We are being provided with ample warning signs about the intentions of Islamic militants in the U.S. who live and work among us. According to law enforcement sources close to the Lodi investigation, there will be additional detentions and possible arrests. But the story does not stop there. The Lodi case is a virtual template of Islamic groups across the country, feigning religious tolerance while actively engaged in Al-Takeyya, which permits Muslims to engage in lies and deceit to further their cause of Jihad. (The basis for this practice can be found in the Quranic verse Surah 3:28). The question is will we recognize this practice and become proactive before it is too late? Don't be fooled - what is happening in Lodi is also happening in small towns and large cities across the U.S," it concluded.

38.In the history of jihadi terrorism, there are innumerable instances of jihadi leaders and their groups feigning peace overtly and practising terrorism covertly.We have seen this in the case of Pakistan's military-intelligence establishment and Gen.Pervez Musharraf too. Before the US-led military operations started in Afghanistan on October 7,2001, Musharraf delivered a long telecast speech to his people explaining his decision to assist the US in its operations against the Taliban and the Al Qaeda. He quoted from the Holy Koran and the history of Islam to claim that their religion approved tactical compromises in order to achieve strategic gains. He described Pakistan 's strategic objectives as the safeguarding of its military nuclear capability and the annexation of J&K and justified his decision to support the US as meant to preserve these strategic objectives. Even while pretending to co-operate with the US in its so-called war against terrorism, he helped the Amir of the Taliban and his senior colleagues take shelter in Balochistan and operate from there. Deception and dissimulation come naturally to the jihadi terrorists, their supporters and State-sponsors.

QUESTION No.4:How come Musharraf, who projects himself as a stalwart ally of the US , allows such anti-US activities to go on in Pakistani territory?

39. Musharraf's co-operation with the US has been subject to three unexpressed, but clearly seen exceptions. Firstly, the preservation of the Taliban as a fighting force to use it to regain Pakistan 's strategic objectives in Afghanistan if and when the Americans leave. Secondly, preservation of the terrorist infrastructure of the Pakistani jihadi organisations in order to re-escalate terrorism against India should the current peace talks fail. Thirdly, to ensure that his co-operation with the US does not aggravate the sectarian and other religious and social tensions in Pakistani society.

40. Most of his genuine actions in support of the US have been against the Al Qaeda and its foreign leaders and cadres operating from the Pakistani territory. He has refrained from any genuine action against the Taliban and the Pakistani jihadi organisations while pretending to act against them too.

41.The religious and jihadi training infrastructure of these organisations continues to function as before and it should not, therefore, be a matter of surprise if Hamid had visited Pakistan from the US and got trained in one of these camps or madrasas.

QUESTION NO.5:How does the US continue to trust and pamper him despite such instances?

42.In Iraq , the US had convinced itself that it was in its national interest to have Saddam Hussein removed. All reports, which spoke against him, were believed and used for this purpose, even when they were false or should have been known to be false. The report of the UN Inspectors that there was no evidence of Iraq having weapons of mass destruction was disregarded.

43. In Pakistan , it has convinced itself that it has no alternative to Musharraf if it has to win its war against terrorism. All reports, which speak against Musharraf, are disregarded even when they are or should be known to be true.

44. It has been paying a heavy price in Iraq . It will pay a heavy price in Pakistan .

45. The text of the FBI affidavit, dated June 6,2005, as carried by www.bharat-rakshak.com is attached.

(The writer is Additional Secretary (retd), Cabinet Secretariat, Govt. of India, New Delhi , and, presently, Director, Institute for Topical Studies, Chennai, and Distinguished Fellow and Convenor, Observer Research Foundation (ORF), Chennai Chapter.. E-mail: itschen36@gmail.com)


United States of America v. Hamid Hayat

I. Background and experience of agent

I, Pedro Tenoch Aguilar, Special Agent of the Federal Bureau of Investigation (FBI), United States Department of Justice, having been duly sworn, do depose and state the following:

1. I have been a Special Agent of the FBI since June 2004. I am currently assigned to the Sacramento Division, Stockton Resident Agency.

2. Based upon my training and experience, I know that it is a violation of Title 18, United States Code, Section 1001 (a) (2) to make any materially false, fictitious or fraudulent statement or representation in any matter within the jurisdiction of the Federal Bureau of Investigation.

3. Based on my personal participation in this investigation, including my discussion with other investigating agents, or other law enforcement agencies, and interviews with reliable witnesses, I am familiar with the facts and circumstances of this investigation. The information set forth herein, in this Affidavit, reflects my personal knowledge or has been provided to me by other law enforcement officers, investigative analysts and agents with whom I have spoken, or whose reports I have reviewed.

4. Based on the information contained in this affidavit I believe there is probable cause to believe that Hamid Hayat and Umer Hayat violated Title 18, United States Code, Section 1001, when both individuals separately denied that Hamid Hayat had attended a jihadist training camp in Pakistan .

II. Individuals to be arrested

5. This affidavit is made in support of a complaint to arrest the following individuals:

a) Hamid Hayat

b) Umer Hayat

III. Probable cause

6. On Sunday, 5/29/05 at approximately 5:30 a.m., the Sacramento Division of the FBI was notified, via FBI Headquarters (FBIHQ), that Hamid Hayat, a United States Citizen, was attempting to gain access to the United States via an inbound flight which was scheduled to arrive at San Francisco International Airport at approximately 1:50 p.m. on 5/29/05. During his travel from Korea to the United States , while in flight, it was determined that Hamid was on the "No Fly" list. The plane was immediately diverted, and was ultimately allowed to land in Japan for refueling purposes. While in Japan , Hamid was interviewed by an FBI agent and denied having any connection to terrorism or terrorist activities. Based on Hamid's statements verbal authority was granted to downgrade Hamid from the "No Fly" list to the "Selectee list" so that Hamid could continue his planned travel to the United States . Immigration records indicate that Hamid had departed from the United States on 4/19/03, arriving in Islamabad , Pakistan on 4/21/03. Immigration records also indicate that he departed from Pakistan on 5/27/05, arriving in the United States on 5/29/05.

A. Interview of Hamid Hayat

7. On June 3, 2005, Hamid Hayat was interviewed by special agents of the FBI. During that interview he was specifically asked if he had ever attended any jihadi camps. He was also asked if he had ever attended any terrorist training camps in Pakistan or in general. He was also asked if he had ever attended a jihadi madrassah (religious school.) Hamid stated that he has never attended any type of terrorist training camp or school and is not a jihadi member. He stated that he would never be involved with anything related to terrorism.

8. On June 4, 2005 Hamid Hayat voluntarily appeared at the Sacramento Office of the FBI to take a polygraph examination that had been requested by the FBI. Hayat, who brought his father with him to the FBI, was informed in advance that the purpose of the polygraph examination was to resolve questions about his possible involvement with terrorist activities. After a brief interview with an FBI agent who showed Hamid some photographs, the polygraph examination was administered and his answers to the relevant questions were found to be indicative of deception. After approximately two more hours of questioning, Hamid admitted that he had, in fact, attended a jihadist training camp in Pakistan .

9. Hamid admitted that he attended a jihadist training camp in Pakistan for approximately 6 months in 2003-2004. Hamid stated that Al-Qaeda supports the camp and provides instructors for the camp. Hamid later confirmed this camp was run by Al-Qaeda. Hamid described the camp as providing structured paramilitary training, including weapons training, explosives training, interior room tactics, hand to hand combat, and strenuous exercise. Classroom instruction included ideological rhetoric detailing opposition towards the United States and other non-Muslim countries. Hamid stated that during his weapons training, photos of various high ranking U.S. political figures, including President Bush, would be pasted onto their targets. Hamid further stated that he and others at the camp were being trained on how to kill Americans. Hamid stated that although he did not participate in all the available instruction he was aware the other training was ongoing.

10. Hamid advised that he specifically requested to come to the United States to carry out his Jihadi mission.

B. Interview of Umer Hayat

11. On June 3, 2005, Umer Hayat, Hamid Hayat's father, was interviewed by a special agent of the FBI at the same time that Hamid was interviewed. During that interview Umer was specifically asked if his son, Hamid Hayat, was a terrorist. He specifically denied that.

12. On June 4, 2005, Umer Hayat, United States citizen, accompanied his son, Hamid Hayat, to the Sacramento Office of the FBI. On that date he was specifically asked if he had a knowledge about terrorist training camps in Pakistan . Umer replied that there were no such training camps in Pakistan .

13. Following the interview of Hamid Hayat in which Hamid admitted attending a jihadi training camp, Umer Hayat was interviewed again by FBI agents. At the outset of the interview Umer was shown a videotape of his son's confession. Shortly after viewing that videotape, Umer confirmed that Hamid Hayat attended a jihadist training camp in Pakistan in 2003-04. Umer admitted that he paid for Hamid's flight and had provided him with an allowance of $100 per month, knowing that his intention was to attend a jihadi training camp.

14. Umer Hayat described Hamid Hayat as first being interested in attending a jihadi training camp during his early teenage years, and being influenced by a classmate at the madrassah (religious school) Hamid attended in Rawalpindi , Pakistan . Hamid was also influenced by his uncle, who fought with the mujahedeen in Afghanistan . Umer Hayat claimed Hamid was at the training camp for 6 months, but had been able to leave for home on the weekends.

15. The madrassah was operated by Hamid Hayat's grandfather, and Umer Hayat's father-in-law. According to Umer Hayat, Qazi Saeed Ur Rehman sends the students from this madrassah to jihadi training camps in Pakistan . After completing his education at the madrassah, Hamid Hayat went to a training camp near Rawalpindi , Pakistan . Umer Hayat stated that the operator of the camp is a close personal friend of Umer Hayat's father-in-law.

16. Umer stated that he was invited to observe several operational training camps. According to Umer, he was assigned a driver who drove him from camp to camp. While visiting these training camps he observed weapons and urban warfare training, physical training, and classroom education.


17. Based on the foregoing there is probable cause to believe that Hamid Hayat and Umer Hayat have committed violations of Title 18, United States Code, Section 1001, by making false statements of material fact in a matter within the jurisdiction of the FBI.

Sealing request

18. Based on the fact that this investigation is ongoing and due to the sensitive nature of the information contained in this affidavit, the government respectfully requests that the complaint be sealed until further order of this court.

I declare under penalty of perjury that the foregoing is true and correct and that this affidavit was executed at Sacramento California on June 6, 2005.

Pedro Tenoch Aguilar

Special Agent

FBI, Stockton