A O 91 (Rev. 1 1 / 1 ) C r i m i n a l C o m p l a i n t

A U S A B a r r y J o n a s and John F . K n e s s (312) 8 8 6 - 8 0 2 7

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
UNITED STATES OF AMERICA

CASE NUMBER:

HASAN R. EDMONDS and
JONAS M . EDMONDS
C R I M I N A L COMPLAINT

MAGISTRATE JUDGE FINNEGAN

I , the complainant i n this case, state that the following is true to the best of my knowledge
and belief.
Beginning no later than i n or about January 2015, and continuing until at least on or about
March 25, 2015, at Chicago, i n the Northern District of Illinois, Eastern Division, and elsewhere,
the defendants violated:
Code Section

Offense Description

Title 18, United States Code, Section
2339B(a)(l)

conspiring to knowingly provide material support
and resources, namely, personnel, to a designated
terrorist organization, namely, the Islamic State
of Iraq and the Levant, knowing that the
organization
was a designated
terrorist
organization, and that the organization had
engaged in and was engaging i n terrorist activity
and terrorism

This criminal complaint is based upon these facts:
X

Continued on the attached sheet.
Morgan A. Spurlock
Special Agent
Federal Bureau of Investigation

Sworn to before me and signed in my presence.
Date: March 25. 2015
Judge's signature
C i t y and state: C h i c a g o . Illinois

S H E I L A F I N N E G A N U . S . Magistrate Judge

RECEIVED
MAR

2 5 2015

THOMAS G. BRUTON
CLERK, U.S. DISTRICT COURT

Printed name and Title

 UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS

)
)
)

AFFIDAVIT
I , Morgan A. Spurlock, being duly sworn, state as follows:
1.

I am a Special Agent with the Federal Bureau of Investigation. I have

been so employed since approximately 2010.
2.

As part of my duties as an FBI Special Agent, I investigate criminal

violations relating to international terrorism, including providing material support
or resources to foreign terrorist organizations, i n violation of Title 18, United States
Code, Section 2339B(a)(l). As a result of my training and experience, I am familiar
with the tactics, methods, and techniques used by terrorist networks and their
members. I n addition, I have participated i n the execution of multiple federal
search warrants.
3.

This affidavit is made i n support of a criminal complaint alleging that

Hasan R. Edmonds and Jonas M . Edmonds have violated Title 18, United States
Code, Section 2339B(a)(l). Because this affidavit is being submitted for the limited
purpose of establishing probable cause i n support of a criminal complaint charging
Hasan R. Edmonds and Jonas M . Edmonds with conspiring to knowingly provide
material support

and resources, namely, personnel,

to a foreign

terrorist

organization, namely, the Islamic State of Iraq and the Levant, knowing that the
organization was a designated terrorist organization, and that the organization had
engaged i n and was engaging i n terrorist activity and terrorism, 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 probable cause to believe that the
defendant committed the offense alleged i n the complaint.
4.

The statements i n this affidavit are based on: (a) my personal

knowledge; (b) information I have received from other law enforcement personnel
and from persons with knowledge regarding relevant facts; and (c) consensually
monitored and recorded communications. Because this affidavit is being submitted
for the limited purpose of securing a search warrant, I have not included each and
every fact known to me concerning this investigation.
5.

A t various points i n the Affidavit, I offer my interpretations of certain

communications i n brackets and otherwise. These interpretations, which include
translations of certain words and phrases i n the Arabic language, are based on my
knowledge of the investigation to date and review of prior communications, the
contents and context of the communications, prior and subsequent communications,
conversations w i t h other law enforcement officers and agents, conversations with
one or more Arabic translators employed by the FBI, and my experience and
familiarity with terrorist organizations generally. Some of these summaries do not
include references to all the topics covered during the course of the communications.
I n addition, the summaries do not necessarily include references to all statements
made by the speakers on the topics that are mentioned. Finally, quotations from
written communications are as they appear i n their original form, including any

2

 grammatical or spelling errors. Although transcribers have attempted to transcribe
the

conversations

accurately, to

the

extent that

quotations from

these

communications are included, these are, preliminary, not final, transcriptions.
SUMMARY
6.

As described i n more detail below, Hasan R. Edmonds, who resides at

Subject Premises 1, and Jonas M . Edmonds, who resides at Subject Premises 2,
have conspired w i t h each other to provide material support and resources, namely,
personnel i n the form of themselves, to a foreign terrorist organization, namely, the
Islamic State of Iraq and the Levant (ISIL).
7.

As part of an undercover F B I investigation, agents have determined

that Hasan Edmonds and Jonas Edmonds have expressed their intention jointly to
(a) facilitate travel by Hasan Edmonds, a member of the Army National Guard
stationed i n Illinois, to travel overseas and fight on behalf of ISIL; and (b) to
coordinate an attack by Jonas Edmonds on a U.S. military facility located i n
northern Illinois.
8.

I n furtherance of their conspiracy to provide material support and

resources, Hasan Edmonds booked airline travel leaving on March 25, 2015, from
Chicago, Illinois, and arriving i n Cairo, Egypt, on March 26, 2015, w i t h layovers i n
Detroit, Michigan, and Amsterdam, the Netherlands, and with the intention of
traveling overseas to join ISIL and engage i n violence on ISIL's behalf.

3

 9.

On or about March 25, 2015, Hasan Edmonds was arrested at Chicago

Midway Airport i n the terminal from which his flight was to depart, while i n
possession of Subject Bag 1, and after having checked Subject Bag 2 with his
airline.
Hasan R. Edmonds and Subject Premises 1
10.

According to Illinois driver's license records and his August 2014

passport application, which was submitted to the U.S. Department of State, Hasan
R. Edmonds is a 22-year-old United States citizen who resides at Subject Premises 1
in Aurora, Illinois. According to Illinois firearm license records, i n or around
November 2014, Hasan Edmonds obtained an Illinois license that permits him to
carry a firearm.
11.

According to records from the U.S. Department of Defense, Hasan

Edmonds' middle name is Rasheed, he is a member of the U.S. Army National
Guard, and he is assigned to a National Guard unit i n the Northern District of
Illinois.
12.

Based on surveillance, law enforcement agents familiar with the

physical appearance of Hasan Edmonds have observed him at Subject Premises 1,
both during the day and overnight, on numerous occasions. More specifically, agents
have observed Hasan Edmonds present at Subject Premises 1 on or about February
3 and 27, 2015, and March 9 and 10, 2015.

4

 13.

Based on a review of various public databases, Hasan Edmonds

possesses an Illinois firearm concealed carry permit bearing the address of Subject
Premises 1. Also, as of i n or about February 2015, Hasan Edmonds was the
registrant of a vehicle registered to Subject Premises 1.
14.

I n addition, surveillance agents have observed Jonas Edmonds at

Subject Premises 1, both during the day and overnight, on numerous occasions.
More specifically, agents observed Jonas Edmonds at Subject Premises 1 on or
about January 28, 2015, February 3 and 27, 2015, and March 9 and 10, 2015. I n
addition, based on surveillance and as explained more fully below, i t appears that
Jonas Edmonds lived at Subject Premises 1 until on or about March 14, 2015.
15.

Based i n part on records obtained from Facebook, as well as other

information as set forth i n this Affidavit, the Facebook profile "Hasan Rasheed"
appears to belong to Hasan Edmonds, whose middle name is Rasheed. More
1

specifically, based on records obtained from Facebook, "Hasan Rasheed" logged into
Facebook on December 18, 2014, using a specific Internet Protocol (IP) address.
Based on records obtained from an internet service provider, the relevant IP
address was, as of December 18, 2014, assigned to Subject Premises 1. I n addition,
information provided by the user of the "Hasan Rasheed" Facebook profile stated
Based on my training and experience, I know that Facebook is an online social
medium on which users can post personal information and commentary, photographs,
videos, and other information. Facebook permits users to "friend" other users, thereby
allowing "friends" to, among other things, share information, updates, and to suggest other
"friends." To establish a friend relationship on Facebook, a user seeking to friend another
user typically sends a friend request to that user, who can then accept, reject, or ignore the
request.
1

5

 that the user graduated from "West Senior High School" i n 2011 and resided i n
Chicago, Illinois. According to information Hasan Edmonds provided to the Office of
Personnel Management, he graduated i n May 2011 from "Aurora West High School"
in Aurora, Illinois.
Jonas M. Edmonds and Subject Premises 2
16.

According to Illinois driver's license records as well as information

from a law enforcement database, Jonas Marcel Edmonds is a 29-year-old United
States citizen, who currently resides i n Aurora, Illinois.

2

I n addition, Jonas

Edmonds has a prior felony criminal conviction i n the state of Georgia that resulted
in him serving a period of incarceration.
17.

On or about March 23-24, 2015, surveillance agents familiar with the

physical appearance of Jonas Edmonds observed him at Subject Premises 2 i n
Aurora, Illinois. Also, as explained further below, on or about March 23, 2015, an
undercover F B I employee (UC2) met with Jonas Edmonds, as well as Hasan
Edmonds, inside Subject Premises 2.
The Islamic State of Iraq and the Levant
18.

On or about October 15, 2004, the U.S. Secretary of State designated

al-Qaeda i n Iraq, then known as Jam'at al Tawhid wa'al-Jihad, as a Foreign
Terrorist Organization under Section 219 of the Immigration and Nationality Act

On about February 21, 2015, Jonas Edmonds advised police officers in Aurora, Illinois,
that he resided at Subject Premises 1 and that he was moving soon.
2

6

 and as a Specially Designated Global Terrorist under section 1(b) of Executive
Order 13224.
19.

On or about May 15, 2014, the Secretary of State amended the

designation of al-Qaeda i n Iraq 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 to add the alias Islamic State
of Iraq and the Levant (ISIL) as its primary name. The Secretary also added the
following aliases to the ISIL listing: the Islamic State of Iraq and al-Sham, the
Islamic State of Iraq and Syria, ad-Dawla al-Islamiyya f i al-'Iraq wa-sh-Sham,
Daesh, Dawla al Islamiya, and Al-Furqan Establishment for Media Production.
Although the group has never called itself al-Qaeda i n Iraq, this name has
frequently been used to describe i t through its history. I n an audio recording
publicly released on June 29, 2014, ISIL announced a formal change of its name to
Islamic State.
20.

Based on my training and experience, information provided by an

Interpol informational publication, and information provided by an F B I Arabic
linguist: (a) Sunni extremists and others, who are not citizens or residents of Syria
and Iraq, have been traveling to Syria and Iraq to join ISIL and commonly enter
Syria by crossing the border from Turkey; (b) to avoid increased law enforcement
scrutiny of the common route to Syria through Turkey, foreign fighters from
Western countries have traveled to locations i n Egypt and on to Syria to join ISIL;
7

 (c) Abu Bakr al-Baghdadi is the current leader of ISIL and is frequently referred to
as "Khalifa" or "Khalifa Abu Bakr al-Baghdadi"; and (d) the terms "dowlah,"
"dawlah," "dowla," and "dawla" are Arabic terms that mean country or state and are
commonly used to refer to ISIL, which is also known as "the State."
Hasan Edmonds' Contact with an Undercover FBI Employee - UC1
21.

I n late 2014, an undercover F B I employee ("UC1") sent a "friend"

request to Hasan Edmonds' "Hasan Rasheed" Facebook profile.
22.

On or about January 19, 2015, Hasan Edmonds, using the username

"Hasan Edmonds," sent a message to UC1 through Facebook. I n his message,
Hasan Edmonds appeared to indicate that he was planning on going on a trip and
asked UC1, "Say akhi you speak arabic? I'm trying to get my affairs i n order and
3

get my funds up for the plung, thought i t was smart to plug i n with my brothers

4

while I prepair." Hasan later clarified, "And I meant plunge. I t means to dive/jump
in eagerly. I want to make sure my affairs here are set before leaving to give my all
for this deen. From the understanding I was taught this is the proper way.
5

Otherwise I would have just left months ago. insahAllah soon though. I am
6

working at i t each day."

3

"Akhi" is an Arabic word that means brother.

During subsequent communications, U C l purported to be an ISIL fighter located i n
countries outside of the United States.
4

"Deen" is an Arabic word that means "faith." I n addition, the religion of Islam is
referred to as the "deen."
5

6

"Inshallah" is an Arabic word that means "Allah willing."

8

 23.

On or about January 20, 2015, UC1 sent a Facebook message to Hasan

Edmonds asking, "Will you go to Turkey or Egypt to study then? Is there a madrasa
[Islamic school] you have applied to?" Hasan responded, " I wish to go to Dawlah
akhi. I would love to study at i n Islamic university but my first mission is simply to
show up and be accountable on judgement day i n front of our Lord." As described
above, "dawlah" is an Arabic term which means country or state, and is frequently
used to refer to ISIL, which is also known as Dawla al Islamiya.
24.

On or about January 23, 2015, Hasan Edmonds emailed UC1 from

hasan_edmonds@yahoo.com. I n his email, Hasan Edmonds wrote "Its Hasan
Rasheed. Let's pick up where we left off inshaAllah." Subsequently, the two
transitioned their communications to another electronic communication method
(hereinafter, "Communication Form 1").
25.

7

On or about January 24, 2015, Hasan Edmonds contacted

UC1

through Communication Form 1 and explained that he was preparing to travel
overseas i n April with his cousin and his cousin's family. As Hasan Edmonds
8

stated, "Now inshaAllah we can continue or talks. InshaAllah i n a few months
around April I'm on my way. I am trying to get my ummah here ready. I must get
9

Communication Form 1 and Communication Form 2 (discussed below) are both
electronic communication means that are accessible via cellular telephones.
7

Based on records obtained from the provider of Communication Form 1, the account
referenced above was linked with the email address hasan_edmonds@yahoo.com.
8

9

"Ummah" is an Arabic word that means "nation."

9

 my funds and affairs in order inshaAllah. Myself my cousin and his family are all
trying to make our hijrah."
26.

10

On or about January 24, 2015, Hasan Edmonds sent UC1 a message i n

which he indicated that i t was a "duty" to support ISIL or to be martyred i n the
process. Specifically, Hasan Edmonds stated: "Not be easy but i'd rather struggle
and strive hard i n the cause of Allah rather than sit back and live a 'comfortable'
life. And what you say is true brother but the banners are up. The State has been
established and i t is our duty to heed the call. InshaAllah we w i l l complete our task
or be granted shahada trying. And yes I look forward to the training. I am already
11

in the american kafir

12

army (back when I was still i n this dunyah

13

and not

muslim) and now I wish only to serve i n the army of Allah alongside my true
brothers." Hasan Edmonds also stated that " I joined the united states army
national guard about 3 years ago. I still currently have 3 years left that I have no
intention what so ever of fulfilling."
27.

On or about January 24, 2015, Hasan Edmonds wrote to UC1 via

Communication Form 1 and explained his familiarity w i t h certain firearms and
other weapons based on his military training, stating, among other things, " I am no
expert with our weapons but I can get the job done." He then explained to UC1 the

10

"Hijrah" is an Arabic word that means "migration."

11

"Shahada" is an Arabic word that means "martyrdom."

12

"Kafir" is an Arabic word that means "infidel."

13

"Dunyah" is an Arabic word that means "of this world."
10

 various types of firearms used by the National Guard and appeared to reference
that there were others i n the United States who were willing to either travel to join
ISIL or engage i n violence i n the United States. Specifically, Hasan Edmonds wrote,
"To be honest i'm best with my side arm (handgun) and then my rifle. We are few i n
number compared to the k u f a r army but there are believers like myself hear i n
14

america and we wait amd prepair ourselves for the orders of the Ameer.

15

Either we

will make i t to dowlah or bring the flames of war to the heart od this land w i t h
Allahs promission."
28.

During the same communication, Hasan Edmonds discussed his plans

to travel or, in the alternative, to stay i n the United States to fight, stating, " I pray
to just one time step foot i n the land ruled by the Law of the Quran but I am content
to fight and die here i n the cause of Allah whenever the target is set and the order
is given. InshaAllah my brothers will march with me as well."
29.

On or about January 27, 2015, UC1 contacted Hasan Edmonds via

Communication Form 1. During the conversation that followed, Hasan Edmonds
said that "come April or May we w i l l try," indicating that Hasan Edmonds and his
"cousin" would attempt to travel overseas i n April or May 2015. During that same
communication, Hasan Edmonds explained that his "cousin" had previously been
imprisoned and that "they try hard to keep people like him trapped i n america." He

14

"Kufar" is the plural of "kafir" and means infidels.

"Ameer" is an Arabic word that means "commander." Abu Bakr al-Baghdadi is often
referred to as "Ameer al-Mu'mineen," or "Commander of the Believers."
15

11

 also said that i f his cousin was unable to travel, his cousin would "send his family
and then seek shahada [martyrdom] here i n the heart of the kuffar state...If this
happens the way we want inshaAllah we'll all be there i f not though my sahaba

16

will put the fear of Allah i n their hearts and minds right here i n the homeland." As
described above, Jonas Edmonds has served time i n prison for a previous criminal
conviction i n Georgia.
30.

During the same communication, Hasan Edmonds advised, " I can own

handguns shotguns and rifles but no automatic weapons or heavy machine guns.
We have plenty people here who have them and hide them so we will do the same."
Also during this communication, following a discussion about Hasan Edmonds'
training with weapons and martial arts, UC1 then asked whether Hasan Edmonds'
cousin was referred to by an alias. Hasan Edmonds responded, "His name is
Yunus."

17

31.

During the same communication, UC1 and Hasan discussed Hasan

Edmonds and Jonas Edmonds' allegiance to ISIL and their desire to support ISIL's
goals. I n describing whether he had made his oath of allegiance (referred to as
"bayat") to the leader of ISIL (referred to as "khalifa"), Hasan Edmonds stated,
'Yunus did before me. He was the one whom first brought i t to my attention maybe

"Sahaba" is an Arabic term that means "companion." Given the context of this and
other communications as described i n this Affidavit, I believe that Hasan Edmonds' use of
"sahaba" i n this communication was a reference to Jonas Edmonds.
16

As described i n this Affidavit, Hasan Edmonds frequently refers to his cousin Jonas
Edmonds as 'Yunus." I n addition, Yunus is the Arabic form of the English name Jonas.
17

12

 the same month i t was annouced. Then after I looked into i t for myself I gave my
oath afrer asr. And we have been planning ever since. The harder the brother fight
the more hype we become! Until something has to give ethier we get there or we
bring the pain to them here. A l l the Muslims here are watching though. I have yet
to met a Muslim yet that isn't watching and listening to whats happening i n the
Dowlah. There are three types here. Pro Dowlah (myself, Yunus, and others), the
sleep/undecided muslims, and the munafiqeen who support the kuffar."
32.

Later during the communication, while discussing

avoiding law

enforcement of government detection, Hasan Edmonds said, among other things,
"We can surely do something. Even the kaffirs here are fighting the police and
government so we can really strick harder i n tue cause of Allah. The biggedt and
hardest thing is staying under their radar." Later, he added, "Right. Here they hide
and some even pretend to be friends . . . We'd like to cause as much damage and
mayhem as possible before being granted shahada."
33.

On or about January 27, 2015, Hasan Edmonds told UC1 that an

attack on certain public buildings would be feasible. Specifically, Hasan Edmonds
said, "It would be hard to pull off a lager scale attack on the government but police
stations and courts are pretty easy and its been done before by kufar sometimes just
one person."
34.

On or about January 30, 2015, UC1 contacted Hasan Edmonds via

Communication Form 1 and asked whether Hasan Edmonds had finished his plans.
13

 Hasan replied, "Plans have been made. Now we need to get the funds for our travels
and build our aresinal here. That's what we are working at now."
35.

During the same communication, Hasan Edmonds provided advice to

UC1 on fighting against the United States and its army, stating, " I n all honesty the
best way to bet them is to break their will. With the U.S. no matter how many you
k i l l they will keep coming unless the soldiers and the american public no longer
have the will to fight." Hasan Edmonds, after providing UC1 with specific
suggestions on how to beat the U.S. military ("attack them at all hours of the day
and night from many different directions"), stated, " I f we can break their spirits we
w i l l win. Whenever we attack them instead of killing them all t r y to take a few as
prisioners for either ransom or to show the world the hours the kufar army will
suffer at the hands of the lions of Allah."
36.

During the same communication, Hasan Edmonds stated, "Knowing

that we will never stop striving i n the cause of all will break them. They are
terrified now! This is why when they suspect someone of being pro dawlah theu
send 20 or 30 highly armed police and military personnel to arrest them. They send
20 or 30 for one or two people out of fear. Allah (swt) said for every one of us that
stands firm 10 of them will fall! Use the istihad

18

missions to strick fear i n there

hearts! They will fold." Also, during this communication, Hasan Edmonds sent UC1

"Istihad" is diligence or the effort an individual can put forth in an activity, or finding
a solution for a problem that did not occur in the Quran or during the life of the prophet. I t
is also spelled Ijitihad.
18

14

 an image of Hasan Edmonds i n what appeared to be a U.S. military uniform and
carrying a rifle. Based on a review of Hasan Edmonds' Illinois driver's license
photograph, i t appears that the person depicted i n the image Hasan Edmonds sent
to UC1 is Hasan Edmonds.
37.

During the same communication, Hasan Edmonds indicated that he

was willing to conduct an attack in the United States i f directed to do so, stating, " I f
the ameer command a target here we will follow...Now brother i f you have any
contacts with any commanders let them know we are i n the process of organizing.
[ . . . ] Its a little slower here cause of security and spies but we are on i t . Oaths
have been given. When the time is right we will strike. I f the dawlah has any high
let us know so we can link i n with them inshaAllah."
38.

On or about February 2, 2015, Hasan Edmonds informed UC1 via

Communication Form 1 that Jonas Edmonds was willing to conduct an attack i n the
United States. During this communication, while discussing hijrah (migration),
Hasan Edmonds advised, "Yes we are still planning to make hijrah. Yunus and his
family plus myself are all trying to get to the land of the believers inshaAllah. He
went today to feel out the paperwork for his passport but they were closed. We w i l l
try again tomorrow. We are still on the same timeline as far as when we are trying
to leave. During this time through we also prepair. InshaAllah my shahaba [Jonas
Edmonds] and I can stay the course and hold firm i n the w i l l of Allah." From the
context of the communications between UC1 and Hasan Edmonds, as well as

15

 communications between Jonas Edmonds and UC1 (discussed below), i t appears
that when Hasan Edmonds stated that he and Jonas Edmonds were trying to "get
to the land of the believers," he was referring to ISIL.
39.

Also during the February 2, 2015 communication, Hasan Edmonds

stated, "When the women are under the protection of the dawlah under any
province under the dawlahs rule (any country) we are ready for whatever our orders
may be. InshaAllah we can go there and come back. We'll take orders given." While
discussing law enforcement scrutiny, Hasan Edmonds advised, "[. . .] For Yunus and
myself we do both want to touch down i n the land and we are coming for jihad
fiscibilly Allah. Niether of us mind staying here i f those are our orders so long as we
get our sisters outta her first. Honestly we would love to do something like the
brother i n Paris d i d . Hit here and then go to dawlah inshaAllah. We'll fight where
19

ever need be." I n response, UC1 told Hasan Edmonds that shahada could also be
achieved i n America i f one volunteered. Hasan Edmonds replied, "We understand
fully... Shahada is blessing. We have plans i n mind. I f you know of any other
brother over here on the same path as our link us up inshaAllah." He further
stated, " i f you find us a route outta here once we get close that's all we need
inshaAllah the rest we will do here inshaAllah."

Given the context of this and other communications, I believe Hasan Edmonds'
reference to doing "something like the brother i n Paris did" was a reference to a January 7,
2015 terrorist attack i n Paris against the satirical newspaper Charlie Hebdo.
19

16

 40.

On or about February 6, 2015, Hasan Edmonds informed UC1 via

Communication Form 1 that " I have been working and Yunus and his family are
trying to get there birth certificates because they need those to get a passport here.
We are all working toward our goal but i t takes patience, this is why we gave
ourselves to at least April or May. Need to get all the documents ready. InshaAllah
our work w i l l pay off." Hasan Edmonds further stated, "Now i t seems we've found
some other brothers here with the same goals as ours akhi. Still screening them but
we w i l l let you know." Later i n the conversation, UC1 asked i f Hasan Edmonds was
planning to travel with Jonas Edmonds' family. Hasan Edmonds replied, "Yes.
Afterwards i f the mission requires Yunus and I to say here then so be i t . We won't
act until they arw safe under the care of the dawlah though. First step is all needed
paperwork and then next is their passports inshaAllah. I t take 6-8 weeks here for
passports to come i n the mail. We will let you know as soon as we have them so we
can move forward inshaAllah."
41.

On or about February 26, 2015, UC1 contacted Hasan Edmonds via

Communication Form 1. During this communication, among other things, UC1 and
Hasan Edmonds

discussed engaging

i n future communications

via another

communication method (hereinafter, "Communication Form 2").
42.

During the same communication, UC1 asked Hasan Edmonds i f he

still planned on traveling. Hasan Edmonds replied "InshaAllah i t w i l l be Sham. I f
20

"Sham" is an Arabic term that is used to refer to the geographic area commonly
known as Syria or the "Levant."
20

17

 not Egypt. I n truth I'm fine with whichever part of Dawlah I end up i n . Those are
just my top two." From the context of the communications, i t appeared that Hasan
Edmonds was indicating to UC1 that he was willing to join ISIL i n either Syria
(Sham) or Egypt.
43.

On or about March 1, 2015, Hasan Edmonds contacted UC1 via

Communication Form 2 and asked UC1 about a safe travel route and the cost of
travel. I n addition, Hasan Edmonds informed UC1:
I am wondering about your travel route (is i t still open or is the enemy
on to i t like the route from Turkey to Sham now). And home much
money is needed to make this hijrah? Yunus and I have already spoken
and we both wonder the same thing. I am ready with my passport and
such things now but his family is still preparing. I w i l l go first and
train i n the army. inshaAllah and they will follow once they have
everything then need to escape this land of kufar and shirk.
[...]
We are meeting a brother soon who claims to have connects to travel as
well but Yunus and I trust you so we ask you as well.
21

[...]

From the context and date of the statement (i.e., March 1, 2015), I believe that
Hasan's statement of "meeting a brother soon who claims to have connects to travel"
was a reference to Jonas Edmonds' meeting with UC2, which occurred on or about
March 3, 2015, and is discussed below.
44.

During the same communication, i n response to Hasan Edmonds'

question regarding the route, UC1 advised that the two routes to Syria were
through Turkey and Egypt, and that U C l could assist Hasan Edmonds w i t h

21

"Shirk" appears to mean, i n this context, the practice of idolatry or polytheism.

18

 traveling to Syria i f Hasan Edmonds took the route through Egypt. While
discussing the logistics of traveling, including within and outside of Egypt, Hasan
Edmonds, stated, "we'll i n this case all that's left is for me to find out how much
these tickets are and inshallAllah I'm on my way. I showed Yunus this message abd
he said he w i l l speak to you soon regarding his families travels all they're waiting
on is paperwork

and they plan to follow

as soon as possible from

my

understanding." Hasan Edmonds further told UC1, regarding the routes to travel,
" I know several Muslims have been caught attempting the Turkey route so tell me
why not many americans take the Egypt route. I am open to either way. I think i t
would raise less alarms on my end i f I take the second route . . . either way I'm still
coming."
Jonas Edmonds Communications with UC1
45.

On or about February 6, 2015, Jonas Edmonds contacted UC1 via

Communication Form 2. I n response, U C l asked, "This is Yunus, the cousin of
Hasan?" On or about February 9, 2015, U C l informed Jonas Edmonds that U C l
was contacting him as a result of UC1's discussions with Hasan Edmonds. During
this communication, U C l indicated that Hasan Edmonds had informed U C l that
Jonas Edmonds was seeking assistance w i t h moving his family. Jonas Edmonds
replied, "How ard you akhi. I was briefed by hasan i t is a pleasure finally being able
to connect w i t h you. As for your question na'am I seek help i n the move of my
family."
19

 46.

Later, during the same communication, U C l told Jonas Edmonds that

U C l was located i n an identified foreign country. I n response, Jonas Edmonds
advised that he (Jonas Edmonds) was located i n Chicago. U C l then asked Jonas
Edmonds about his intentions and needs. Jonas Edmonds responded, "Allah is with
those who are patient. I as of now need help with the tickets for 8 people and
assistance one they have reached the other side. Over the next couple of months
part of our preparations is gathering as much money as possible bithni Allah ta
ala." He then identified the 8 people as himself, his wife, his 5 children and Hasan
Edmonds, and stated that there may be others as well.
47.

During the same communication, U C l asked Jonas Edmonds what his

destination was. Jonas Edmonds replied, "Number one on my list is Mosul..." U C l
warned that Mosul was a dangerous place for children, and that the "raafida and
22

taghut armies attack still." According to open source information, during the time
23

of this communication, the northern Iraqi city of Mosul was under the control of
ISIL.
48.

During the same communication, Jonas Edmonds asked whether i t

was possible for him to meet other ISIL supporters i n the United States should he
be unable to travel. Specifically, Jonas Edmonds asked, "Although I am currently
working on it. I am unable to get my passport. I f I find myself stuck here. I intend
22

sect.

"Raafida" refers to Shia or Shiites, the second largest sect of Islam after the Sunni

"Taghut" refers to Arab and Muslim heads of state. I n this context, "taghut" appears
to refer to the practice of Muslim people worshipping secular leaders instead of Allah.
23

20

 to take advantage of being so close to the kuffar. Bithni allahu ta ala. Do you know
of brothers on this side. That are not looking to leave." Later, Jonas Edmonds
advised, "[. . .] Well I bring to the table very little when i t comes to resources. But
whatever I have is for Allah. [. . .]."
49.

Following Jonas Edmonds' statement, U C l indicated that resources

would be available to assist i f Jonas' intention was to travel for the purpose of
fighting and not just for hijrah. Jonas Edmonds responded, "My life is for Allah, I
am a soldier I His army. Even after I get my family to dowlah I intend to go i n the
cause. The best of mankind are the mujahideen. May Allah place me among their
ranks."
50.

During the same communication, Jonas Edmonds made clear his

intentions to the U C l : "The plans are made from two points. One consists of doing
all I can to be able to make hijrah with my family. I already let you know that I
would need for that. Two, i f I cant make hijrah then InshaAllah. I can unleash the
lion. What I would need...honestly nothing. I am prepared to go even i f its w i t h a
rock. But a small team, no more than 5 hardware and maybe a fire cracker. I do
have access to hardware." From the context of this communication and other
communications between Jonas Edmonds, Hasan Edmonds, and the U C l , I believe
that Jonas Edmonds was informing U C l that, i f he cannot travel, he was willing to
commit an attack i n the United States and that he already had access to firearms.

21

 51.

On or about March 2, 2015, Jonas Edmonds contacted U C l through

Communication Form 2. During the conversation that followed, the two discussed
Jonas Edmonds and Hasan Edmonds' intentions. At one point i n the conversation,
Jonas Edmonds stated, " . . . you spoke with hasan recently MashaAllah i read your
message. Whatever goodnss Allah swt has for us w i t h you and the brothers there,
we are ready for MashaAllah." U C l responded, "Hasan speaks of him coming here
to Dowlah's blessed walayah i n africa, i n shaa Allah i t is so. He also says you still
await the papers for you, and your family." Jonas Edmonds replied, "With that
being said we can move forward InshaAllah. InshaAllah just tell us what needs to
be done on our end."
52.

On or about March 10, 2015, Jonas Edmonds contacted U C l via

Communication Form 2, and stated, "Hasan is looking to head your direction what
assistance can we get i n the matter." U C l replied that he could get points of contact
for Hasan Edmonds but U C l needed to know when he was going to travel. Jonas
Edmonds responded that that Hasan Edmonds was waiting for the best place to
travel to before he purchased his ticket.
Meeting Between Jonas Edmonds and UC2
53.

On or about

February 19, 2015,

Jonas Edmonds

contacted

a

confidential law enforcement source via an online communication medium. As a
result of that communication, the source introduced UC2 to Jonas Edmonds via
Communication Form 2. I n summary, the source described UC2 to Jonas Edmonds
22

 as an individual who could assist Jonas Edmonds and Hasan Edmonds w i t h their
intention of traveling from the United States to support ISIL.
54.

As a result of this introduction, Jonas Edmonds and UC2 began a

series of communications via Communication Form 2 for the purpose of coordinating
an in-person meeting.
55.

On or about February 28, 2015, UC2 asked Jonas Edmonds i f he was

serious about traveling and when the travel would take place. Jonas Edmonds
replied, "Yea we are serious about answering the call to Allah. As far as when, end
of April." A t the conclusion of these communications, Jonas Edmonds and UC2
agreed to meet at a public location i n Downers Grove, Illinois, on or about March 3,
2015, for the purpose of further planning the activities discussed above.
The March 3, 2015 Meeting Between Jonas Edmonds and UC2
56.

Prior to the meeting, on or about March 3, 2015, between Jonas

Edmonds and UC2, law enforcement agents observed Hasan Edmonds, Jonas
Edmonds, and another individual travel together i n one vehicle to the meeting
location i n Downers Grove, Illinois. After arriving, surveillance agents Hasan
Edmonds observed walking around the vicinity of the meeting location while the
other individual remained i n the vehicle. Based on these observations, i t appeared
to surveillance agents that Hasan Edmonds was conducting surveillance of the
meeting while Jonas Edmonds was inside the meeting location with UC2.

23

 57.

During the meeting on or about March 3, 2015, Jonas Edmonds and

UC2 exchanged various items of personal information, including Jonas Edmonds
admission that he referred to himself as "Yunus." I n addition, Jonas Edmonds
informed UC2 that he wanted to "answer the call of Allah upon the island." Jonas
Edmonds also explained that he had been arrested when he was younger and was
still dealing with the consequences. Jonas Edmonds stated, " I f I find myself to
where they just slam the door on me . . . so let the lion go." Based on the context of
this communication, i t appeared that Jonas Edmonds was informing UC2 that, i f he
could not travel as a result of his prior conviction, he would attempt an attack i n the
United States.
58.

Also during the meeting, Jonas Edmonds informed UC2 that he was

meeting on behalf of himself and Hasan Edmonds, stating, " I am here on my behalf
and his behalf. The other brother behalf I am going to say that and my cousin."
Similarly, Jonas Edmonds later advised, 'Yea, other than that I say as far I am here
on my behalf. I am here on my sahaba's [i.e., Hasan's] behalf, right. Because, ah my
[sahaba] he got wings now [meaning that Hasan was able to travel] . . . He's
military. He [Hasan] got several things going on with himself." After UC2
responded, "OK," Jonas continued, "See what I am saying, but he [Hasan] ready to
whatever, however he is going to be. I f I can't then he is going to be my model."
59.

During the meeting, Jonas Edmonds described his role i n planning

and committing to Hasan's and his actions. As he explained to UC2, " I am glad we
24

 got to meet, right because this is a huge step for me, because at this point I been the
person kind of leading this charge into this darkness . . . You see what I am saying,
because i t real unknown to me but [unintelligible] I not going to allow a lost
[unintelligible] to keep me from answering his, ah, his call."
60.

During the meeting, Jonas Edmonds and UC2 also discussed the route

by which Hasan Edmonds would enter Syria. More specifically, UC2 informed Jonas
Edmonds that the safest route to Syria was the "southern route" (i.e., from Egypt
into Syria).
61.

During the same meeting, Jonas Edmonds discussed Hasan Edmonds'

willingness to abandon his military obligation i n order to travel. Jonas Edmonds
and UC2 also discussed the safest route to take to avoid government detection and
that i t might take longer to get to the final destination.
Jonas Edmonds and UC2's Post-Meeting
62.

Communications

On or about March 7, 2015, UC2, via Communication Form 2, asked

Jonas Edmonds to check the cost of a plane ticket from Toronto to Cairo. Jonas
Edmonds replied that he would check and then responded, "1500 at the most 1600."
63.

On or about March 8, 2015, the prior day's communication continued

via Communication Form 2. I n discussing whether Hasan Edmonds was prepared
to travel, Jonas Edmonds replied, "yea he is prepared for i t Alhumdullilah he would
need a flight from here to Toronto as well?"

25

 64.

Later during the same conversation, Jonas Edmonds asked UC2

"What's the options for those who shall remain" (i.e., those who could not travel to
support ISIL). UC2 replied that they would discuss that soon, and asked whether
Jonas Edmonds had a passport available to him. Jonas Edmonds replied that he is
"still on i t . "
65.

On or about March 10, 2015, Jonas Edmonds informed UC2 via

Communication Form 2 that: "My sahabah [Hasan Edmonds] is ready to make the
move. He has everything he needs and there is nothing holding him back. He has
asked that I reach out to you and the bros on your end i n hopes that Allah w i l l his
bless his situation thru you all." Jonas continued, "All he is requesting is a contact
on the other side to assist him."
66.

On or about March 13, 2015, UC2 provided Jonas Edmonds a list of

items Hasan Edmonds would need for his travel, including camping type gear and
clothing, and specific types of electronic equipment. Jonas replied, " I got i t . "
Hasan Edmonds' Further
67.

Communications

With UCl

On or about March 11, 2015, Hasan Edmonds informed U C l via

Communication Form 2 that Hasan Edmonds was "looking to buy my ticket i n the
next few days." He then asked about immunization shots and i f U C l knew of
anyone who had a store i n Egypt, because Hasan Edmonds needed "a spot just i n
case the army asks me for i t before allowing me to leave." Hasan Edmonds further
stated that he did not "have a visa yet but what I plan to do is since I have my
26

 passport buy a round trip ticket as i f I'm only visiting. I can tell them [the army]
that I plan to visit first before moving..." From the context of this communication, I
believe that when Hasan Edmonds asked U C l for information about a store i n
Egypt, he was preparing a false story so the military did not question his travel.
68.

Also on or about March 11, 2015, i n a later communication, Hasan

Edmonds asked U C l about the dates that "the brothers" had given. A few hours
later, Hasan Edmonds told U C l that his (Hasan Edmonds') flight "arrives Friday
March 27 at 2:15AM i n Cairo." Among other things, U C l provided Hasan Edmonds
with information on where to go once he arrived i n Egypt. Hasan replied, "The
tickets are bought and my trust is i n Allah. I can only move forward now. I am fine
being i n Egypt, Sham, or Libya to be honest akhi. I just want to answer the call."
69.

According to information provided by Delta Airlines, on or about March

13, 2015, Hasan Edmonds purchased airline tickets for approximately $856.70 for
the following itinerary departing from Chicago's Midway Airport:
Date

Departure City

3/25/2015
3/25/2015

Chicago, I L
Detroit, M I

3/26/2015

Amsterdam,
Netherlands
Cairo, Egypt
Paris, France
Detroit, M I

4/02/2015
4/02/2015
4/02/2015

Departure
Time
6:35 pm
10:34 pm

Arrival City

8:55 pm

Detroit, M I
Amsterdam,
Netherlands
Cairo, Egypt

6:40 am
1:30 pm
5:45 pm

Paris, France
Detroit, M I
Chicago, I L

27

Arrival
Time
8:39 pm
11:35 am
2:15 am
11:25 am
4:15 pm
5:58 pm

 70.

Based on my training and experience, I have learned that individuals

aspiring to travel for purposes of supporting ISIL frequently purchase round trip
tickets to avoid detection by law enforcement officers.
71.

Also on or about March 11, 2015, U C l informed Hasan Edmonds that

he (Hasan Edmonds) would be going to Derna (Libya) through the Sinai (Egypt) to
be with U C l . U C l also advised that Hasan Edwards would be used to train others
or to conduct reconnaissance. U C l then asked what he would like to do. Hasan
Edwards replied:
I will speak to my shahaba about this. I do not have any problems w i t h
your request and would be honored to help out however I can. My
original goal was simply to fight and sever as a muhadjid. I'm not
opposed to training the brother my only request is I be allowed to fight
and earn my stripes i n the field before being given such an honor
inshallAllah. Though I have trained i n the U.S. army I have not been
i n combat with them and I refuse to teach my shabaha anything I
haven't tested myself yet. This is my only request. Since I don't yet
speak Arabic fluently I will be i n need of training. Yunus and I are
working on fiq of jihad and fiq of IKhalifah right now. InshallAllah
when I arrive I will at least have the proper understanding of my
duties and we can go from there inshaAllah.
24

25

72.

During the same conversation, U C l asked Hasan Edmonds for help

with obtaining military training manuals and weapons specifications. Hasan
Edmonds asked how U C l wanted to receive the information. U C l advised Hasan
Edmonds to download the information, which he was to carry with him when he

2 4

I n this context, "muhadjid" appears to refer to an Islamic fighter.

25

"Fiq" means Shari'ah law or Islamic jurisprudence.

28

 traveled. Hasan Edmonds replied that he would seek assistance from Jonas
Edmonds, who, according to Hasan Edmonds, "is skilled with computers."
73.

On or about March 21, 2015, Hasan Edmonds and U C l communicated

via Communication Form 2. During this communication, U C l provided Hasan
Edmonds with information concerning the individual who would assist Hasan
Edmonds travel from Egypt to Derna, Libya [a city that was controlled by ISIL].
U C l also provided Hasan Edmonds with information concerning what he would be
doing once he arrived, including the performance of reconnaissance. Also during the
communication, Hasan Edmonds informed U C l that he had obtained some of the
military manuals U C l had requested.
The March 23 and 24, 2015 Meeting Between Hasan Edmonds,
Edmonds, and UC2
74.

Jonas

On or about March 23, 2015, UC2 met with Hasan Edmonds and Jonas

Edmonds i n Aurora, Illinois. During this meeting, the three initially went to Hasan
Edmonds' residence (Subject Premises 1), and then to a residence which Jonas
Edmonds identified as his own (Subject Premises 2). During this meeting, among
other things:
a.

Hasan Edmonds and UC2 met outside of Jonas Edmonds

presence. During this portion of the meeting, Hasan Edmonds informed UC2 that
he had been watching videos from "brothers from the State [ISIL]," and that he did
not want peace but wanted fighting. Hasan Edmonds also advised that he used to
follow a particular Sheik, but ceased doing so when that Sheik attempted to talk
29

 individuals out of engaging i n jihad. UC2 and Hasan Edmonds also discussed the
items that Hasan Edmonds should bring on his trip. Among other things, Hasan
Edmonds said that he would bring cargo pants, hiking boots, and one or two civilian
outfits.
b.

Hasan Edmonds, Jonas Edmonds, and UC2 then met together.

During that meeting, UC2 confirmed that Hasan Edmonds would be fighting for
ISIL and not for any other group when he traveled. Jonas Edmonds also stated that
he could not wait for Hasan Edmonds to travel because, i n effect, one who supported
a mujahid was a mujahid. Jonas Edmonds also informed UC2 that, after Hasan
Edmonds traveled, Jonas Edmonds would purchase weapons, including AK47s and
grenades, from a third-party. Jonas Edmonds also informed UC2 that he (Jonas
Edmonds) was planning to attack the military installation at which Hasan
Edmonds had been training. Jonas Edmonds also advised that he wanted to conduct
the attack with UC2 and that he anticipated a "body count" of 100 to 150
individuals. Hasan Edmonds corrected Jonas Edmonds and advised that the
number would be closer to 120. Hasan Edmonds offered to provide Jonas Edmonds
and UC2 with a list of the "rankings" (believed to be a reference to the officers).
Hasan Edmonds also advised that they should " k i l l the head." Hasan Edmonds also
confirmed that he would provide Jonas Edmonds w i t h Hasan Edmonds' military
uniforms. During this meeting UC2 indicated that he would like to see the military
installation.

30

 75.

On or about March 24, 2015, UC2 went to Subject Premises 2 and met

w i t h Hasan Edmonds and Jonas Edmonds. During this meeting, the three drove to
the military installation they had discussed the previous day. During the drive, the
three discussed purchasing weapons and how to conduct an attack. When they
arrived, the three discussed, among other things, where soldiers at the installation
trained. Also during this meeting, Hasan Edmonds described the inside of the
installation and which rooms they should avoid during the attack. Hasan Edmonds
also entered the installation and retrieved a military training schedule, which he
then gave to Jonas Edmonds.
Information From Hasan Edmonds' Facebook Pages
76.

On or about January 20, 2015, Hasan Edmonds posted the following on

his Facebook profile: "IS [the Islamic State] has been stopped i n Iraq huh? More
lies . . . .," which also contained a linked article bearing the headline, "Canada
special forces clash with IS [the Islamic State] i n Iraq." I n addition, Hasan
Edmonds posted a link to a YouTube video appearing under the name "Abu Bakr alBaghdadi-What is Terrorism."
77.

On or about January 24, 2015, Hasan Edmonds shared a link on his

Facebook profile showing a photograph of what appeared to be soldiers positioned
under the Eiffel Tower, and referring to an article regarding former French soldiers
who had joined ISIL.

31

 The March 25, 2015 Arrest of Hasan
78.

Edmonds

On or about March 25, 2015, at approximately 3:15 p.m., surveillance

agents observed Hasan Edmonds, Jonas Edmonds, and two other individuals depart
Subject Premises 1 w i t h luggage and enter a minivan. Agents then observed the
group drive to Chicago Midway Airport. After arriving there, Hasan Edmonds
exited the van and the van drove away. Hasan Edmonds then entered the airport
w i t h a black backpack and a black roller bag.
79.

A t approximately 4:25 p.m., agents observed Hasan Edmonds at the

Delta ticket counter and appeared to be checking a black suitcase, while retaining
the black backpack. A t approximately 4:50 p.m., he was observed going through the
Transportation Security Administration security area.

32

 80.

At approximately 5:21 p.m., Hasan Edmonds was arrested i n the

terminal from which his flight was to depart. At the time of his arrest, he had i n his
possession Subject Bag 1, a black ES backpack. Agents also obtained Subject Bag 2,
a black Coronado suitcase, which Hasan Edmonds had checked i n at the Delta
counter. Subject Bag 1 and Subject Bag 2 are both i n the custody of the F B I i n the
Northern District of Illinois.
FURTHER AFFIANT SAYETH NOT.

Morgan A. Spurlock
Special Agent
Federal Bureau of Investigation
Subscribed and sworn
before me this 25th day of March 2015
Honorable SHEILA F I N N E G A N
United States Magistrate Judge

33