Case Document 1 Filed 06/10/15 Page 1 of 4 IN THE UNITED STATES DISTRICT COURT i FILED RECEIVED LODGED cow JUN 1 0 2015 CLERK DISTRICT COURT DISTRICT OF ARIZONA BY DEPUTY 3504075 Olga/?5 FOR THE DISTRICT OF ARIZONA (MHB) United States of America, No. Plaintiff, IND I TME NT V. VIO: 1.8 U.S.C. 371 (Conspiracy) Count 1 Abdul Malik Abdul Kareem, aka Decarus Thomas, V10: 18 U.S.C. 924(b) 2 (Interstate ransportation of Flrearms Defendant. with Intent to Commit a Felony) Count 2 18 U.S.C. 1001(a)(2) (False Statements) Count 3 THE GRAND JURY CHARGES: Background On or about February 11, 2015, the organizers of the Muhammad Art Exhibit and Contest announced that the contest would be held at the Curtis Culwell Center in Garland, Texas, on May 3, 2015. After the announcement but prior to April 23, 2015, ABDUL MALIK ABDUL KAREEM Elton Francis Simpson (?Simpson?), Nadir Hamid Soo? and others known and unknown to the grand jury began a plot to disrupt the contest. On the day of the contest, Simpson and Soo? drove toward the Curtis Culwell Center, stopped their car, got out, and began. shooting Case Document 1 Filed 06/10/15 Page 2 of 4 with assault ri?es at security personnel and law enforcement. The security guard was struck by a bullet and injured, and Simpson and Soo? were shot and killed by police of?cers. Count 1 Beginning on or about January 7, 2015, and continuing through May 3, 2015, at or near Phoenix, in the District of Arizona, and elsewhere, KAREEM, together with other persons known and unknown to, the grand jury, conspired to violate Title 18, United States Code, 924(b), in that they knowingly and intentionally conspired to transport ?rearms and ammunition in interstate commerce with the intent to commit crimes punishable by imprisonment exceeding one year and with knowledge and reasonable cause to believe that an offense punishable by imprisonment exceeding one year was to be committed therewith, including murder in violation of Texas Penal Code 19.02 and aggravated assault in Violation of Texas Penal Code 22.01(a) and 22.02(a) Overt Acts In furtherance of the conSpiracy and to effect the objects of the conspiracy, the following overt acts, among others, were committed in the District of Arizona: 1. On dates between January 7, 2015, and May 3, 2015, KAREEM, Simpson, Soo?, and other persons known and unknown to the grand jury traveled to remote desert areas near Phoenix, Arizona, to practice shooting ?rearms. 2. On dates between January 7, 2015, and May 3, 2015, KAREEM provided ?rearms to Simpson and Soo?. 3. On dates between January 7, 2015, and May 3, 2015, KAREEM hosted Simpson, Soo?, and other persons known and unknown to the grand jury inside his home to discuss the Muhammad Art Exhibit and Contest and their plan to travel from Phoenix, Arizona, to Garland, Texas, to conduct an attack on the contest. All in violation of Title 18, United States Code, Section 371. Case Document 1 Filed 06/10/15 - Page 3 of 4 Count 2 Beginning on or before May 1, 2015, and continuing through May 3, 2015, at or near Phoenix, in the District of Arizona, and elsewhere, KAREEM did knowingly and intentionally transport ?rearms and ammunition in interstate commerce with the intent to commit crimes punishable by imprisonment exceeding one year and with knowledge and reasonable cause to believe that an offense punishable by imprisonment exceeding one year was to be committed therewith, that is, murder in violation of Texas Penal Code 19.02 and aggravated assault in violation of Texas Penal Code 22.01(a) and 22.02(a) All in violation of Title 18, United States Code, Sections 924(b) and 2. Count 3 On or about May 5, 2015, at or near Phoenix, in the District of Arizona, in a matter within the jurisdiction of the Federal Bureau of Investigation, an agency of the United States, KAREEM did knowingly and willfully make false, fraudulent, and ?ctitious material statements and representations; that is, (1) that he did not go shooting in the desert with Simpson and Soo? before May 3, 2015; (2) that before May 3, 2015, neither Simpson nor Soo? ?red the weapons they used in connection with the attack in Garland, Texas; (3) that Simpson and Soo? did not ask him to participate in an attack of any kind on or before May 3, 2015; (4) that he did not know in advance that Simpson and Soo? planned to conduct an attack in Garland, Texas; and (5) that he did not know about an event, that is, the Muhammad Art Exhibit and Contest that was to take place in Garland, Texas, on or about May 3, 2015, until after Simpson and Soo? were killed while Case Document 1 Filed 06/10/15 Page 4 of 4 attempting to conduct an attack on the contest. All in Violation of Title 18, United States Code, Section 1001(a)(2). A TRUE BILL FOREPERSON OF THE GRAND JURY Date: June 10, 2015 JOHN S. LEONARDO United States Attorney District of Arizona Joseph E. Koehler Kristen Brook Ass1stant US. Attorneys