"Six Americans were killed during the three-day attacks. Mir allegedly served as the chief planner of the attacks, directing preparations and reconnaissance, and was one of the Pakistan-based controllers during the attacks. Additionally, Mir allegedly conspired to commit a terrorist attack against a newspaper and its employees in Denmark between 2008 and 2009," it said.
1. At all relevant times from in or about 1989until the date of the filing of this Indictment, an international terroristgroup existed which was dedicated to opposing non-Islamic governments withforce and violence. This organization grew out of the "mekhtab al khidemat"(the "Services Office") organization which had maintained offices in variousparts of the world, including Afghanistan, Pakistan (particularly in Peshawar),and the United States. The group was founded by Usama Bin Laden and MuhammadAtef, a/k/a "Abu Hafs al Masry," together with "Abu Ubaidah al Banshiri," andothers. From in or about 1989 until the present, the group called itself "alQaeda" ("the Base"). From 1989 until in or about 1991, the group (hereafterreferred to as "al Qaeda") was headquartered in Afghanistan and Peshawar,Pakistan. In or about 1991, the leadership of al Qaeda, including its "emir"(or prince) Usama Bin Laden, relocated to the Sudan. Al Qaeda was headquarteredin the Sudan from approximately 1991 until approximately 1996 but stillmaintained offices in various parts of the world. In 1996, Usama Bin Laden andother members of al Qaeda relocated to Afghanistan. At all relevant times, alQaeda was led by its emir, Usama Bin Laden. Members of al Qaeda pledged an oathof allegiance (called a "bayat") to Usama Bin Laden and al Qaeda. Those whowere suspected of collaborating against al Qaeda were to be identified andkilled.
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2. Bin Laden and al Qaeda violently opposed theUnited States for several reasons. First, the United States was regarded as an"infidel" because it was not governed in a manner consistent with the group'sextremist interpretation of Islam. Second, the United States was viewed asproviding essential support for other "infidel" governments and institutions,particularly the governments of Saudi Arabia and Egypt, the nation of Israel,and the United Nations organization, which were regarded as enemies of thegroup. Third, al Qaeda opposed the involvement of the United States armedforces in the Gulf War in 1991 and in Operation Restore Hope in Somalia in 1992and 1993. In particular, al Qaeda opposed the continued presence of Americanmilitary forces in Saudi Arabia (and elsewhere on the Saudi Arabian peninsula)following the Gulf War. Fourth, al Qaeda opposed the United States Governmentbecause of the arrest, conviction and imprisonment of persons belonging to alQaeda or its affiliated terrorist groups or those with whom it worked. Forthese and other reasons, Bin Laden declared a jihad, or holy war, against theUnited States, which he has carried out through al Qaeda and its affiliatedorganizations.
6. Usama Bin Laden and al Qaeda also forgedalliances with the National Islamic Front in the Sudan and with representativesof the government of Iran, and its associated terrorist group Hizballah, forthe purpose of working together against their perceived common enemies in theWest, particularly the United States.
7. Since at least 1989, until the filing of thisIndictment, Usama Bin Laden and the terrorist group al Qaeda sponsored,managed, and/or financially supported training camps in Afghanistan, whichcamps were used to instruct members and associates of al Qaeda and itsaffiliated terrorist groups in the use of firearms, explosives, chemicalweapons, and other weapons of mass destruction. In addition to providingtraining in the use of various weapons, these camps were used to conductoperational planning against United States targets around the world andexperiments in the use of chemical and biological weapons. These camps werealso used to train others in security and counterintelligence methods, such asthe use of codes and passwords, and to teach members and associates of al Qaedaabout traveling to perform operations. For example, al Qaeda instructed itsmembers and associates to dress in "Western" attire and to use other methods toavoid detection by security officials. The group also taught its members andassociates to monitor media reporting of its operations to determine theeffectiveness of their terrorist activities.
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