rupxt, lltev I L?rintinal L?omplaml UNITED STATES DISTRICT COURT for the Eastern District United States of America v. KEONNA THOMAS, elk/a "Fatayat AI Khilafah." elk/a "YoungLioness" Case No. tg~u 7~M CRIMINAL COMPLAINT l, the complainant in this case. state that the following is true to the best of my knowledge and belief. On or about the datets) of August 2013 - March 2015 District Of an Code Section 18 U.S.C. 23398 in the county of From or about August through in ?o'r about March 2 Philadelphia . the defendant(s) violated: Offense Desert rtirm in the 5, in the Eastern District of the ilel'endant, KEUNNA afki?a ?Fatayat Khilat'ah." ntki?a ?YotmgLioncss,? attempted to provide material support and resources, as de?ned by [8 Section including personnel. including IOMAS Iterseli" to a designated foreign terrorist organization, to wit: the [statute State of Iraq and the Levant (ISILJ, which was designated on May 1014 by the United States Secretary oI'State as a Foreign Terrorist Organization under Section 2 [9 of the Immigration and Nationality Act, and as a Specially Designated Global 'I'errorist under section lib] ot? Executive Order [3224, knowing that the organization was a designated terrorist organization, that the organization had engaged in and was engaging in terrorist activity and terrorism. and the defendant is a United States national. All in wolation ol?Section 23393 oI'TitIe IS ot?the United States Code. This criminal complaint is based on these facts: See attached Af?davit Continued on the attached sheet. Sworn to before me and signed in my presence. 4/2: ity and state: Philadelphia, PA 's signature Martin McDonald. FBI Special Agent Printed Home and ride Honorable Lynne A. Sitarski. U.S. Magi Printed Home and ri?e strate Lin 6. AFFIDAVIT I, MARTIN MCDONALD, being duly sworn, depose and say: I am a Special Agent with the Federal Bureau of Investigation within the meaning ofTitle 18, United States Code, Section 3052. and as such I am an officer of the United States who is authorized to investigate laws ofthe United States and to execute warrants issued under the authority of the United States. I have been employed as an FBI Special Agent since November 2010. I am investigating the activities of KEONNA a/k/a ?Fatayat Al Khilafah,? a/k/a "YoungLionessf? who is a United States citizen residing in Philadelphia, PA. As will be shown below, I submit there is probable cause to believe that THOMAS has committed the crime of attempting to provide material support or resources to the Islamic State of Iraq and the Levant (ISIL), a designated foreign terrorist organization, in violation ot?lS U.S.C. 23398. The information contained in this affidavit is based upon my personal knowledge ofthis investigation as well as information that I obtained from my conversations with other FBI agents, law enforcement of?cers, and civilian witnesses. Because this af?davit is being submitted for the limited purpose ol?enabling this Court to make a judicial determination of probable cause to issue an arrest warrant, I have not included each and every fact known to me concerning this investigation. I have set forth only the facts that I believe are necessary? to establish the legal basis for the issuance of an arrest warrant. A. The Islamic State of Iraq and the Levant (ISIL) On October 15, 2004, the United States Secretary of State designated al?Qa?ida in Iraq (AQI), then known as Jam?at al "I?awhid wa?aI-Iihad, as a Foreign Terrorist Organization under Section 219 of the Immigration and Nationality Act, and as a Specially Designated Global Terrorist under section 1(b) of Executive Order 13224. On May 15, 2014, the Secretary ofState amended its AQI designations to add the alias "Islamic State of Iraq and the Levant" (ISIL) as its primary name. The Secretary also added additional aliases to the listing, including '"the Islamic State of Iraq and al-Sham,? and ?the Islamic State ofIraq and Syria" (ISIS). As a consequence of these Department of State designations, there is a prohibition against knowingly providing, or attempting or conspiring to provide, material support or resources to, or engaging in transactions with ISIL. On or about August 19, 2014, ISIL claimed responsibility for the videotaped beheading of an American aid worker. On or about September 9, 2014, ISIL claimed responsibility for 10. ll. 13. 14. the videotaped beheading ol'another American aid worker. On or about September 13, 2014, claimed responsibility for the videotaped beheading ol?a British aid worker. On or about October 3, 2014, claimed responsibility For the videotaped beheading of another British aid worker. On or about February 3, 2015, ISIL released a video ol?a captured Jordanian Air Force Pilot being burned alive in a cage. On or about February 15, 2015, released a video of the beheading ot?21 Coptic Christians in Libya. On or about li?ebruary 24, 2015, kidnapped approximately 70-100 Assyrian Christians located in Northeast Syria, including men. women, and children. B. Attempt by KEONNA THOMAS, a/k/a ?Fatayat Al Khilafah,? a/k/a ?YoungLioness,? to Provide Material Support to ISIL As set forth below, there is probable cause to believe that THOMAS, a/kfa "Fatayat Al Khilafah?? a/k/a ?Younglgioness.? attempted to travel overseas in order to join, tight with, and martyr herself on behalt?ot? ISIL On or about August 18. 2013, KEONNA THOMAS. a/k/a ?Fatayat Al Khilafah,? a/k/a ?YoungLioness,? re-posted on Twitter a photograph ot?a young male child wearing ?rearm magazine pouches and camouflage attire, with the following caption: "Ask yourselves, while this young man is holding magazines for the Islamic state, what are you doing for it? #1818." On or about October 16, 2013, KEONNA THOMAS, a/kfa ?Fatayat Al Khilafah," ark/a "YoungLioness,? posted on Twitter a picture 01? US. Currency, with the following captions; Dollar notes donated by Kuwait nationals to the brothers? and ?Allahu Akbar [God is great]!! Support the Muslims by giving sadaqah [charity].? On or about December 12, 2013, KEONNA THOMAS, an/a ?Fatayat Al Khilafah,? a/k/a ?YoungLioness,? sent an electronic communication to a known Somalia?based violent jihadi tighter originally from Minnesota (Co?Conspirator (CC) who identified himselt?in his electronic communications as a ?mujahid [violentjihadi tighter].? In this message, THOMAS stated that she should be ?able to travel 1 should be getting some money soon.? On or about December 13, 2013, KEONNA THOMAS, a/k/a ?Fatayat Al Khilafah,? ark/a ?YoungLioness,? sent an electronic communication to advising that she ?plan[ned] to leave the land of kut?r but cautioning that ?[s]peaking here [online] about certain things is not . . . wise.? On or about December 17, 2013, KEONNA THOMAS, a/k/a ?Fatayat Al Khilafah," a/k/a ?YoungLioness,? sent an electronic communication to advising, have moves to make so 1 will be spending less time on here . . . On or about December 17, 2013, KEONNA THOMAS, a/kfa ?Fatayat Al Khilafah," a/kfa 16. 19. "YoungLioncss," re?posted on Twitter the following statement by another Twitter user; ""l-lappiness is the day of my Sheikh Khalid al Husainan." On or about December 23, 2013. KEONNA THOMAS, a/k/a ?Fatayat Al Khilafah,? a/k/a "YoungLioness,? re-posted on Twitter a video along with text advising that the video constitutes ?a message to #muslims in the west from a British brother with #1318 #Mujahidcen [violentjihadi lighter] #Syria.? The video is titled, message from a mujahid,? and is accompanied by the following description: mujahid gives some advice. Rayat a1 Tawheed. Official Media of the mujahideen.? On or about January I, 2014, KEONNA THOMAS, a/k/a ?Fatayat Al Khilafah," a/k/a ?YoungLioness,? posted on Twitter the following statement: ?1 see why the mujahideen [violentjihadi fighters] Sacri?ce Dunya [life on earth] for Akhirah [the afterlife] there?s no comparison." On or about January 4, 2014, KEONNA a/k/a ?Fatayat Al Khilafah," a/k/a ?YoungLioness,? posted on Twitter the following statement: ?Only thing I?mjealous of is when 1 see the smiles ofshuhadaa On or about January 15, 2014, KEONNA THOMAS, afk/a ?Fatayat Al Khilafah,? a/k/a ?YoungLioness,? posted on Twitter the following statement: want these to be my last words.? Accompanying this statement was a photograph of the following text: ?By the Lord ofthe Kaaba [a shrine in Mecca] have succeeded.? On or about January 30, 2014, KEONNA THOMAS, a/k/a ?Fatayat Al Khilafah,? a/lo?a ?YoungLioness,? re-posted on Twitter a photograph of an individual carrying an weapon, with the following text: ?Sponsor a Mujahid [violent jihadi tighter]." Accompanying the photograph, THOMAS re-posted the following statement by another Twitter user; ?Did you For as little as $100 you can provide a #Mujahid with his basic necessities for 1 month?" On or about April 10, 2014, KEONNA THOMAS, a/k/a ?Fatayat Al Khilafah," a/k/a "YoungLioness,? posted on Twitter the following statement, followed by images ofa skull, ?ames, and a gun: need a permanent vacation that can only mean one thing.? In response, another user of Twitter posted the following statement: ?istishhaadi On or about April 27, 2014, KEONNA THOMAS, a/k/a ?Fatayat Al Khilafah," a/k/a "YoungLioness,? posted on Twitter the following statement: would prefer the shahada of being in the bodies of green birds.? Based on my experience and expertise, this is a reference to the belief that the souls of are held in the hearts of green birds. On or about June 23, 2014, KEONNA THOMAS, afk/a ?Fatayat Al Khilafah," 211?an "YoungLioncss,? posted on 'liwitter the t?ollowing statement: ?When you?re a mujahid [violent jihadi tighter] your death becomes a wedding. #HoorAlAyn [pleasures in On or about October 10, 2014, KEONNA THOMAS, a/k/a ?Fatayat Al Khilafah.? a/kfa ?YoungLioness,? posted on Twitter the following statement: ?May Allah Ta Ala [God] give victory to the [violent jihadi 1i ghters] destroy the kuft?ar munab?qeen [intidels hypocrites] Ameen." On or about December 2, 2014, KEONNA THOMAS, a/k/a ?Fatayat Al Khilat?ah," a/k/a ?YoungLioness.? posted on Twitter the following statement: "If we truly knew the realities . . . we all would be rushing to join our brothers in the front lines pray ALLAH accept us as shuhada On or about December 2, 2014, a known overseas ISIL tighter sent an electronic communication to KEONNA THOMAS, a/k/a ?Fatayat Al Khilafah,? a/k/a ?YoungLioness,? stating ?i arrived and now going through training. Follow on this account until I get my phone.? THOMAS responded with the electronic communication, "I?m so happy for responded, ?You have no idea the blessing is it is to be in Raqqa [a city in Syria],? to which THOMAS responded, ?'alhumduillah Rabil Alameen [Thanks be to God].? On or about December 2, 2014, sent an electronic communication to KEONNA THOMAS, a/k/a ?Fatayat A1 Khilafah,? a/k/a ?YoungLioness,? stating, ?children ot?the syrians is the future generation mujahidin [violent jihadi ?ghters]. Walaah They love Dawla [lSlL].? On or about December 2, 2014, sent an electronic communication to KEONNA THOMAS, a/k/a ?Fatayat Al Khilafah,? a/k/a ?YoungLioness,? stating, ?trust me haven?t seens anything yet. need to be here to see it.? On or about December 6, 2014, KEONNA THOMAS, a/k/a ?Fatayat Al Khilafah,? a/k/a ?YoungLioness,? re-posted on Twitter a photograph of a small male child with an AK-47 assault ri?e around his neck, containing the following statement: ?And if I were in Shaam [greater Syria], I wouldn?t be pleased till I became soldier of the Islamic State.? On or about January 30, 2015, KEONNA THOMAS, a/k/a ?Fatayat Al Khilafah,? a/k/a ?YoungLioness,? sent an electronic communication to a radical Islamic cleric located in Jamaica stating, ?i don?t want to say much here . . . . as ofnow im still here in the states but will be leaving soon.? On or about February 4, 2015, KEONNA THOMAS, a/k/a ?Fatayat Al Khilafah," a/k/a ?YoungLioness,? submitted an application for a United States Passport. 32about February 14. 20 5, KEONNA THOMAS, a/k/a ?Fatayat Al Khilafah,? afk/a ?YoungLioness,? sent an electronic communication to stating, ?deactivated my twitter till i leave for sham [greater Syria]. . . . don't want to draw attention ofthe kuft?ar [non-believers] and it mess my plans and they take my pass port and i get stuck here.? On or about February 14, 2015, KEONNA THOMAS, a/k/a ?Fatayat Al Khilat?ah,? a/k/a ?YoungLioness,? sent an electronic communication to advising that she sought help from regarding ?routes? and her "travel plan." On or about February 2015, sent an electronic communication to KEONNA THOMAS, a/k/a ?Fatayat Al Khilat?ah," a/k/a "Younglioness," stating, ?Even my wife . . . lfshe turned out after all these to be a spy I will personally blow her brains all over the bedroom . . . Even to it'l married and betrayed wife comes and it turns out she was a spy alter all these . . . I will personally behead her.? In response, THOMAS stated, ?cutting head is more personal.? On or about February 17, 2015, sent an electronic communication to KEONNA THOMAS, afk/a ?Fatayat Al Khilafah," a/k/a ?'YoungLioness,? stating, probably want to do Istishadee operations] with me.? In response, THOMAS stated, ?that would be amazing. . . . a girl can only wish.? then responded, can make that wish come true.? In February and March 2015, KEONNA THOMAS, a/k/a ?Fatayat Al Khilafah,? a/k/a ?YoungLioness,? conducted online research into various indirect travel routes to Turkey. On or about March 23, 2015, KEONNA THOMAS, a/k/a ?Fatayat Al Khilafah,? afk/a ?YoungLioness,? purchased an electronic visa, in her own name, for travel to Turkey. Turkey is known to be the most common and most direct transit point for individuals traveling from locations in Europe who are seeking to enter Syria andjoin ISIL. In addition, an manual published in early 2015 recommends that ISIL recruits travel to Turkey in order to slip over the border into neighboring Syria. This manual further advises such travelers to purchase round-trip tickets to popular vacation spots, speci?cally suggesting Spain, and to purchase tickets to the ?nal destination once overseas. On or about March 25, 2015, KEONNA THOMAS, a/k/a ?Fatayat Al Khilafah,? a/k/a ?YoungLioness,? conducted online research into ?buses from Barcelona to Istanbul.? On or about March 26, 2015, KEONNA THOMAS, 21/an ?Fatayat Al Khilafah,? a/kfa ?YoungLioness,? purchased airline tickets to ?y on March 29, 2015 (three days later), from Philadelphia International Airport, to Barcelona, Spain, retuming to the United States on April 15, 2015. Based on the above facts, your af?ant asserts that there is probable cause to believe that KEONNA THOMAS, afk/a ?Fatayat Al Khilafah,? a/kfa ?YoungLioness,? knowingly attempted to provide material support and resources, as de?ned by 18 U.S.C. Section 2339A(b), including personnel, including THOMAS herself, to a designated foreign terrorist organization, to wit: ISIL, in violation of Title 18, United States Code Section 2339B, and that a warrant should be issued for her arrest. MQARTIN MCDONALD Special Agent Federal Bureau of Investigation or before me th' dayof ,2015 LYNNE A. SITARSKI United States Magistrate Judge