Case 1 16-cr-00042-LMB Document 54 Filed 09 16 16 Page 1 of 19 PageID# 368 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Alexandria Division UNITED STATES OF AMERICA v ARDIT FERIZI a k a Th3Dir3torY Defendant Criminal Case No 1 16-cr-042 Hon Leonie M Brinkema Sentencing Hearing Sept 23 2016 POSITION OF THE UNITED STATES WITH RESPECT TO SENTENCING The United States of America by and through its attorneys Dana Boente United States Attorney for the Eastern District of Virginia Brandon L Van Grack Special Assistant United States Attorney and Gregory R Gonzalez Trial Attorney for the National Security Division's Counterterrorism Section in accordance with 18 U S C 3553 a and the United States Sentencing Commission Guidelines Manual U S S G or the Guidelines 6A1 2 files this Position of the United States With Respect to Sentencing of the defendant Ardit Ferizi The United States submits that a sentence of 300 months 25 years of imprisonment would be sufficient and not greater than necessary to satisfy the factors set forth in 18 U S C 3553 a I FACTUAL BACKGROUND On June 15 2016 the defendant pleaded guilty to two counts in the Indictment i providing material support to a designated foreign terrorist organization in violation of 18 U S C 2339B Count Two and ii accessing a computer without authorization and obtaining information in furtherance of his provision of material support to a designated foreign terrorist organization in violation of 18 U S C 1030 a 2 C Count Three The charges and plea stem from the defendant's actions beginning in April 2015 in support of the Islamic State of -1- Case 1 16-cr-00042-LMB Document 54 Filed 09 16 16 Page 2 of 19 PageID# 369 Iraq and the Levant ISIL a foreign terrorist organization that has called for attacks against United States citizens including members of the military The defendant supported ISIL in multiple ways on multiple occasions and has indefinitely put the lives of approximately 1 300 United States military members and government employees at risk The defendant provided ISIL with private information from hundreds of United States citizens to facilitate ISIL's efforts to spread its terror across the globe On September 21 2014 as ISIL metastasized in Syria and Iraq one of its leaders now-deceased spokesperson Abu Muhammad al-Adnani called for attacks against citizens--civilian or military--of the United States and other countries participating in the United States-led coalition against ISIL Thereafter ISIL members including now-deceased ISIL recruiter Junaid Hussain Hussain heeded Adnani's call by facilitating attacks In order to carry out ISIL's plan of crowdsourcing terrorism Hussain needed personally identifiable information PII to disseminate to ISIL supporters throughout the world For example on March 20 2015 Hussain under the name of the Islamic State Hacking Division ISHD posted a kill list that included the names and addresses of 100 United States military members With complete awareness of ISIL's expanding terrorist aims the defendant began providing support for ISIL in April 2015 At first he supported ISIL by administrating a website that hosted ISIL videos Penvid com An archived copy of Penvid com dated May 23 2015 shows that it contained ISIL videos and included a drop-down menu with the name Dabiq which is the name of ISIL's official English-language magazine 1 See Attachment A The defendant knew that ISIL videos were being posted on his website and that his website served as 1 The archived record came from the website www archive org which offers a service called the Wayback Machine The Wayback Machine is a digital archive of the World Wide Web and other information on the internet -2- Case 1 16-cr-00042-LMB Document 54 Filed 09 16 16 Page 3 of 19 PageID# 370 a force multiplier for ISIL's propaganda machine On May 6 2015 the defendant received an email stating that his website had been shut down because it was being used as a website by a terrorist organization for the promot sic of violence and criminal activity Attachment B The defendant received numerous messages over Twitter from persons who were against ISIL knew that he administered the website and questioned why he was supporting ISIL The defendant repeatedly defended ISIL and his website in these communications For example when asked about the beheadings by the now-deceased ISIL executioner known as Jihadi John the defendant replied that ISIL never kill sic someone without reason Id During a different exchange the defendant was asked whether he knew about a group calling itself the Islamic State Hacking Div which posted the names home addresses and photos of 100 American service member families In response Ferizi indicated the posting was justified because the U S military killed peoples sic in Iraq and Syria Id Although the website amplified ISIL's message the defendant wanted to do more So he began providing information to facilitate specific ISIL attacks As described in the Statement of Facts on April 26 2015 the defendant provided ISIL with what appeared to be PII belonging to people living in the United States and abroad One of those ISIL members was Tariq Hamayun also known as Abu Muslim Al-Britani a Syria-based associate of Hussain When speaking with Hamayun over Twitter the defendant said that the PII belonged to people in kuffar 2 countrys sic which attacking islamic state Id At the end of this exchange Hamayun asked the defendant to come and join us in the Islamic state to which the defendant responded inshAllah which in Arabic means If Allah wills it Id Less than two months later the defendant outdid himself On June 13 2015 he gained 2 Kuffar is a derogatory term used to refer to non-Muslims -3- Case 1 16-cr-00042-LMB Document 54 Filed 09 16 16 Page 4 of 19 PageID# 371 system administrator-level access to a server that maintained the website for an Illinois company Victim Company that sold goods to customers in the United States and abroad 3 The server contained databases with PII belonging to tens of thousands of the Victim Company's customers which included United States military and other government personnel The defendant searched for accessed and obtained customer information for tens of thousands of customers whose information was retained on the server including phone numbers e-mail addresses locations and account passwords He subsequently culled the PII belonging to United States military designated by mil and other government personnel designated by gov In total he obtained PII belonging to approximately 1 300 United States military and other government personnel including persons located here in the Eastern District of Virginia Immediately after extracting the PII for the 1 300 United States military and other government personnel the defendant provided the information to ISIL He reached out to Junaid Hussain the ISIL recruiter and attack facilitator discussed above who used the nom de guerre Abu Hussain al-Britani The defendant knew that Hussain was a member of ISIL and was actively engaged in supporting ISIL The defendant told Hussain how he obtained the information named the company it came from and stated that it contained almost 1 400 military and government email accounts Attachment C Hussain twice exclaimed that releasing this information would hit them hard and each time the defendant responded yes inshaAllah Id The defendant and Hussain also discussed how the information would be released Hussain referencing the March 2015 release of PII for 100 U S military members stated that we will make like a message inshAllah like u know the hitlist I made with addresses we will make message to kuffar and release the mil and gov sic Id Hussain further indicated that the 3 The Victim Company suffered quantifiable losses of at least $53 975 See PSR at 24 -4- Case 1 16-cr-00042-LMB Document 54 Filed 09 16 16 Page 5 of 19 PageID# 372 information would be released by the Islamic State Hacking Division Without hesitation Ferizi agreed with Hussain's plans Id On August 11 2015 Hussain acting in the name of the Islamic State Hacking Division sent communications over Twitter that contained a document with the PII of the 1 300 United States military and government personnel that the defendant had stolen from the Victim Company and provided to Hussain The beginning of the document warned the Crusaders who were conducting a bombing campaign against the muslims we are in your emails and computer systems watching and recording your every move we have your names and addresses we are in your emails and social media accounts we are extracting confidential data and passing on your personal information to the soldiers of the khilafah who soon with the permission of Allah will strike at your necks in your own lands Shortly after sending that tweet Hussain received a message from another ISIL supporter asking about the defendant's whereabouts Hussain explained that the defendant had just been busy lately and that i work with that brother akhi hes in sic our team Attachment D On September 15 2015 Malaysian authorities detained the defendant as he was attempting to leave the country On October 12 2015 Malaysian authorities provisionally arrested him at the request of the United States The defendant was extradited to the United States on January 22 2016 II STANDARDS GOVERNING SENTENCING The standards governing sentencing are well-established In United States v Booker 543 U S 220 2005 the Supreme Court rendered the Sentencing Guidelines purely advisory and emphasized that a sentencing court must consider both the Guidelines and the 18 U S C 3553 a factors when making a sentencing decision Id at 264 see also United States v -5- Case 1 16-cr-00042-LMB Document 54 Filed 09 16 16 Page 6 of 19 PageID# 373 Kimbrough 552 U S 85 2007 stating that the Guidelines formerly mandatory now serve as one factor among several courts must consider in determining an appropriate sentence In Gall v United States 552 U S 38 128 S Ct 586 2007 the Supreme Court instructed that the sentencing court should calculate the sentencing Guidelines range permit the government and the defendant an opportunity to argue for whatever sentence they deem appropriate consider all of the 3553 a factors and finally pronounce a sentence taking into account all of the relevant factors Id at 596-97 The Gall Court further instructed that in the event that the sentencing court decides to impose a variance sentence the court must consider the extent of the deviation and ensure that the justification is sufficiently compelling to support the degree of the variance Id noting that a major departure should be supported by a more significant justification than a minor one Applying these standards the Fourth Circuit has concluded that a sentencing court must 1 properly calculate the Guideline range 2 allow the parties to argue for the sentence they deem appropriate and determine whether the 3553 a factors support the sentences requested by the parties and 3 explain its reasons for selecting a sentence United States v Simmons 269 Fed Appx 272 2008 WL 681764 at 1 4th Cir March 11 2008 citing United States v Pauley 511 F 3d 468 473 4th Cir 2007 When rendering a sentence the district court must make and place on the record an individualized assessment based on the particular facts of the case United States v Cuthrell No 12-4077 2012 WL 3643677 1 4th Cir Aug 27 2012 citing United States v Carter 564 F 3d 325 328 4th Cir 2009 Ultimately the court must state in open court the particular reasons supporting its chosen sentence Carter 564 F 3d at 328 quoting 18 U S C 3553 c Courts are not left with unguided and unbounded sentencing discretion United States v Green 436 F 3d 449 455 4th Cir 2006 Instead at -6- Case 1 16-cr-00042-LMB Document 54 Filed 09 16 16 Page 7 of 19 PageID# 374 sentencing a court must first calculate the Guidelines range Nelson v United States 555 U S 350 351 2009 see also United States v Hughes 401 F 3d 540 546 4th Cir 2005 holding that a sentencing court is still required to 'consult the Guidelines and take them into account when sentencing' quoting Booker 543 U S at 264 III SENTENCING CONSIDERATIONS A Acceptance of Responsibility In accordance with Section 6A1 2 of the Guidelines and Policy Statements and this Court's policy regarding Guidelines sentencing the United States hereby represents that it has reviewed the United States Probation Office's presentence report PSR prepared in this matter The United States moves this Court pursuant to U S S G 3E1 1 b to grant the defendant an additional one-level reduction in the offense level for acceptance of responsibility if the defendant receives a two-level reduction for acceptance of responsibility The government states that the defendant has assisted authorities in the investigation and prosecution of his own misconduct by timely notifying the United States of his intention to enter a plea of guilty thereby permitting the government to avoid preparing for trial and permitting the government and the Court to allocate their resources efficiently B Sentencing Guidelines The government generally agrees with the Probation Office's Guidelines calculations The Probation Office calculated that the defendant's Total Offense Level is 40 and Criminal History Category is VI resulting in a recommended Guideline sentence of 360 months to life Since the statutory maximum for Count Two 18 U S C 2339B is 240 months and Count Three 18 U S C 1030 a 2 C is 60 months the sentence is limited by statute to 300 months 25 years -7- Case 1 16-cr-00042-LMB Document 54 Filed 09 16 16 Page 8 of 19 PageID# 375 i Count Two Providing Material Support to a Terrorist Organization The parties agree that the base offense level for Count Two is 26 pursuant to Section 2M5 3 a As stated in the Plea Agreement the parties also agree that Section 3A1 4 a applies because the defendant's actions involved a federal crime of terrorism which increases the offense level by 12 levels and automatically raises the defendant's criminal history to Category VI See Plea Agreement Doc 35 at 3-4 4 In addition to these uncontested Guideline provisions the Probation Office recommends that two other provisions apply to Count Two Sections 2M5 3 b 1 and 3A1 2 which together would increase the offense level by five levels The government agrees with the Probation Office that both provisions apply in this case 5 a Section 2M5 3 b 1 applies because the defendant provided material support to ISIL with the intent knowledge and reason to believe it would be used to assist in the commission of a violent act The Probation Office recommends and the government agrees that pursuant to 2M5 3 b 1 E the offense level for Count Two should increase by two levels because the 4 The government notes that Section 4A1 3 b should not be applied to this case Under that section a court can depart downward if a defendant's criminal history category substantially over-represents the seriousness of the defendant's criminal history or likelihood that he will commit other crimes First under the Plea Agreement both parties have recommended that the defendant's criminal history is Category VI as a result of the application of Section 3A1 4 b Second and more importantly the departure contemplated under Section 4A1 3 b should not be applied to cases where the terrorism adjustment under Section 3A1 4 b has been applied such as here Pursuant to Section 3A1 4 b the Guidelines mandate that the criminal history category in this case is Category VI due to the serious nature of terrorism offenses That section states that if the offense involved or was intended to promote terrorism the criminal history shall be Category VI The criminal history category determination in terrorism cases is thus not based on the defendant's actual criminal history or likelihood of committing another crime which are the enumerated bases for a downward departure under Section 4A1 3 Rather the sole consideration is the seriousness of terrorism Section 4A1 3 b is intended for cases when the criminal history category has been determined by calculating the defendant's actual criminal history and that category does not accurately reflect the seriousness of the defendant's conduct Here no such calculation was used to determine the criminal history category 5 In the Plea Agreement the government noted its belief that both provisions apply and its intent to argue at sentencing that they apply -8- Case 1 16-cr-00042-LMB Document 54 Filed 09 16 16 Page 9 of 19 PageID# 376 defendant provided material support to ISIL with the intent knowledge or reason to believe it would be used to commit or assist in the commission of a violent act When the defendant provided ISIL with the PII for 1 300 military members and other government employees he intended knew or at minimum had reason to believe that the information would be used to assist in the commission of a violent act As the defendant admitted in the Statement of Facts he was fully aware that ISIL was a terrorist organization that engaged in terrorist activity He knew that ISIL targeted and killed civilians of countries militarily opposed to ISIL When he communicated with people who confronted him about ISIL's violent acts such as beheadings he defended those acts He also willingly administered a website that hosted ISIL's violent videos and propagated their justifications for that violence Fully aware of ISIL's desire to target the United States the defendant searched for PII belonging to U S persons and provided that information to ISIL His intent is clear from the facts Once the defendant identified customer information from the Victim Company he began looking for and culling information for U S military members and government employees knowing full well that ISIL was seeking such information His intent was made abundantly clear when immediately upon culling the military and government personnel information he shared it with a notorious ISIL recruiter and facilitator Junaid Hussain The defendant's knowledge of what ISIL would use the information for is evidenced by the information itself and by ISIL's previous use of that type of information to disseminate a kill list What other purpose would ISIL have with the names addresses and phone numbers of U S military members and government employees if not to locate and target them Hussain indicated that they would release the PII just like the hitlist Hussain had released months earlier A hitlist does not refer to propaganda it describes a list of people to be targeted and attacked -9- Case 1 16-cr-00042-LMB Document 54 Filed 09 16 16 Page 10 of 19 PageID# 377 Hussain also twice stated that ISIL would use this information to hit them hard The defendant expressed his complete agreement with Hussain See Attachment C Accordingly as the Probation Office recommends the offense level for Count Two should increase by two levels pursuant to Section 2M5 3 b 1 E b Section 3A1 2 a applies because the victims were government officers and employees The government also agrees with the Probation Office that pursuant to Section 3A1 2 a the offense level for Count Two should increase by three levels because the victims were government officers and employees and the defendant targeted those victims because of their status The defendant searched for and isolated PII for government employees including members of the military and civilians The defendant only discussed releasing the PII for those government employees The defendant agreed with Hussain that they would hit those government employees hard When ISIL released the information they instructed their soldiers to strike at the necks of those government employees Those government employees must now live in constant fear that a member of ISIL will use that information to find and harm them There is no dispute that the defendant targeted government employees And there can be no dispute that those government employees were harmed Therefore Section 3A1 2 a applies ii Count Three Accessing a Protected Computer Without Authorization and Obtaining Information The United States generally agrees with the Probation Office's offense level calculation for Count Three The parties agree that the base offense level for Count Three is six pursuant to Section 2B1 1 a 2 Under the Plea Agreement the parties also recommend the following offense level increases six-level increase since the loss sustained by victims exceeds $40 000 Section 2B1 1 b 1 D two-level increase since the offense involved unauthorized public -10- Case 1 16-cr-00042-LMB Document 54 Filed 09 16 16 Page 11 of 19 PageID# 378 dissemination of personal information Section 2B1 1 b 17 two-level increase since the defendant used a special skill to commit the offense Section 3B1 3 The parties also agree that a three-level upward adjustment applies pursuant to Section 3A1 2 since the victims were government employees whereas the Probation Office recommends that this upward adjustment only be applied to Count Two The government's disagreement with the Probation Office stems from whether the government employees can also be considered victims of the defendant's unauthorized computer intrusion and theft of information the government and Probation Office agree that government employees were victims of the defendant's provision of material support to ISIL There is no dispute that the Illinois company was a victim when the defendant gained unauthorized access to its server and took PII from that server The government maintains that customers of that company whose PII the defendant stole were also victims That PII belonged to the company and to the customers In many ways the PII was more valuable to the customers than to the company By removing the PII from the company's server the defendant exposed the customers to all sorts of harm be it fraud or as in this case physical injury Many of those customers were government employees and officers Moreover the harm to those government employees and officers was real Those targeted individuals must live in a perpetual state of fear that they may be attacked The charges in Count Three state that the defendant took the PII to further his support of ISIL The defendant specifically targeted the PII of government employees and officers Since the defendant's theft of PII harmed and was intended to harm government employees and officers Section 3A1 2 a should be applied to Count Three The Probation Office also recommends that there be a victim related adjustment to Count Three pursuant to Section 3A1 4 a since the unauthorized computer intrusion and theft of -11- Case 1 16-cr-00042-LMB Document 54 Filed 09 16 16 Page 12 of 19 PageID# 379 information was intended to promote a federal crime of terrorism which would add 12 levels to the offense level The government agrees In the Statement of Facts the defendant admits that he gained unauthorized computer access and obtained information from that access in furtherance of the criminal act of providing support to ISIL Statement of Facts at 2 The defendant's admission virtually mirrors the language of Section 3A1 4 a Accordingly 12 levels should be added to the Guidelines calculation for Count Three C 18 U S C Section 3553 a Factors After calculating the appropriate Guidelines range the court must 'determine whether a sentence within that range serves the factors set forth in 3553 a and if not select a sentence within statutory limits that does serve those factors ' United States v Moreland 437 F 3d 424 432 4th Cir 2006 quoting Green 436 F 3d at 455 Title 18 United States Code Section 3553 a 1 provides that in determining a sentence courts must consider the nature and circumstances of the offense as well as the history and characteristics of the defendant Additional factors outlined in Section 3553 a 2 include the need for the sentence to reflect the seriousness of the offense to promote respect for the law to provide just punishment for the offense to afford adequate deterrence to criminal conduct and to protect the public from further crimes of the defendant 18 U S C 3553 a 2 A - C D Argument The recommended Guidelines sentence of 25 years of imprisonment appropriately reflects the seriousness of the offense the ongoing danger posed to 1 300 military members and government employees the critical need to deter this type of conduct and the defendant's clear knowledge of and intent to commit the harms he inflicted -12- Case 1 16-cr-00042-LMB Document 54 Filed 09 16 16 Page 13 of 19 PageID# 380 i Seriousness of the Offense The defendant's actions have threatened the lives of over 1 300 military members and civilian government employees and their families Because of the defendant's actions ISIL members now know the names of these victims their affiliation with the U S government and where they live among other identifying information The defendant also released passwords used by these 1 300 victims which could be used by ISIL to uncover additional private information This is not analogous to simply publishing information from Google The PII that the defendant stole and released was not publicly available The threat to these 1 300 victims goes beyond the release of their private information They have now been marked as enemies of ISIL Any ISIL member or sympathizer in the United States looking for a target now has the information belonging to 1 300 individuals who ISIL has specifically marked for attack The victims have a permanent target on their backs While the defendant may not have pulled a trigger he told members of ISIL where to shoot And the threat to these 1 300 victims has no end in sight Because ISIL transmitted the PII over the internet there is no way to know if the risk to these military members civilian government employees and their families will ever end It is not possible to permanently remove items from the internet which means the private information of the victims that was released in this case will remain public We do not know who or how many people downloaded and saved the PII and when they may republish the information again What we do know is that ISIL supporters have republished the PII provided by the defendant multiple times since August 11 2015 For instance an individual is presently indicted in another district for transmitting and conspiring to transmit threatening communications in interstate commerce The charges relate to -13- Case 1 16-cr-00042-LMB Document 54 Filed 09 16 16 Page 14 of 19 PageID# 381 the individual re-tweeting PII belonging to two of the victims in this case along with the phrase Wanted to kill followed by the victims' first and last names city of residence zip code and phone number These 1 300 victims can never stop wondering whether someone will accept ISIL's command to strike at their necks One of the victims a member of the military perfectly captured this fear in his victim impact statement when he wrote I have to live constantly under the threat that someone might actually arrive at my residence and harm me or my family members The defendant's conduct is particularly reprehensible because he targeted people for their service to our country In the United States we hold military members in the highest regard because of the sacrifices they make to defend our country and preserve our way of life We also respect our public servants who spend their lives furthering the public good The defendant chose the victims for those very reasons By targeting them the defendant and ISIL believed they were punishing persons responsible for the U S government's national security policies while impairing the ability of the U S government to carry out those policies While we know that such actions only strengthen our country's resolve it shows the defendant's depravity and the need for a significant sentence A 25-year sentence would signal that when given the opportunity our justice system protects and serves the military members and civil servants just as they spend their lives protecting and serving us ii Need for Adequate Deterrence The defendant's actions represent an evolving terrorist threat that requires a substantial sentence to deter others from making the same choice This case represents the first time someone has been arrested for or convicted of providing material support to a terrorist -14- Case 1 16-cr-00042-LMB Document 54 Filed 09 16 16 Page 15 of 19 PageID# 382 organization through information that came from computer hacking While the defendant will be the first terrorist hacker imprisoned for his actions he is not the first or only terrorist hacker A significant sentence is necessary to signal that the defendant is more than a hacker - he is a terrorist Hackers gain unauthorized access to computer systems and take information often for pecuniary gain or ideological reasons Stealing information to make money or to embarrass people is one thing stealing it to harm or kill people is another No court has yet had the opportunity to draw this line A sentence of 25 years would make that line unambiguous In sentencing the first terrorist hacker convicted in the United States this Court has the ability to send a clear message to other hackers who would likewise use their technical skills to support terrorist organizations A sentence of 25 years would communicate that the United States has zero tolerance for hacking in support of terrorism iii Similarly Situated Defendants As noted above this is the first instance in which a defendant has been convicted of using hacking skills to provide material support to a terrorist organization The use of cyber tools to commit this act of terrorism does not diminish the significance of the defendant's crime In September 2014 one of ISIL's leaders Adnani called for attacks against citizens of countries participating in the United States-led coalition against ISIL Thereafter ISIL members heeded Adnani's call by facilitating attacks across the globe In order to carry out ISIL's plan of crowdsourcing terrorism Hussain needed PII that he could use to disseminate to ISIL supporters throughout the world The defendant used his technical skills to provide ISIL with exactly that knowing that his actions could have deadly consequences for the named victims This is Terrorism 2 0 where attacks are no longer centrally planned in musty caves in Afghanistan by an inner circle of terrorist operatives Using social media terrorist groups can -15- Case 1 16-cr-00042-LMB Document 54 Filed 09 16 16 Page 16 of 19 PageID# 383 now achieve their goals from thousands of miles away by supplying potential operatives with digital information about who to strike where to strike and when to strike In this new landscape the defendant's actions are equivalent to someone who facilitates an attack by scouting landmarks reviewing security measures or providing weapons all of which are critical to the success of a terrorist operation While there are no cases directly on point the most analogous case occurred in this District Zachary Adam Chesser was sentenced to 25 years for posting on a jihadist website the personal contact information of individuals who had joined the Everybody Draw Muhammad Day group on Facebook and encouraging jihadists to attack the writers of South Park including highlighting their residence See United States v Chesser 1 10cr395 Doc 51 Feb 24 2011 The defendant's conduct here is arguably worse While Chesser posted contact information for nine individuals the defendant released more sensitive identifying information on 1 300 individuals iv Characteristics of the Defendant The defendant's characteristics likewise favor a sentence of 25 years He is an intelligent and skilled hacker who was fully aware of the consequences of his actions According to the defendant he has been a hacker since he was a young teenager His skills and intelligence are manifested by the fact that he created and led a group of computer hackers called Kosova Hacker's Security KHS See PSR at 10 KHS was responsible for compromising private and government websites around the world and has claimed responsibility for hacking more than 20 000 websites Id That skillset made the defendant particularly valuable to ISIL as evidenced by Hussain's pride that he was on their team The defendant was fully aware of what he was doing and the consequences of those actions when he obtained and provided the victims' personal information to ISIL As discussed -16- Case 1 16-cr-00042-LMB Document 54 Filed 09 16 16 Page 17 of 19 PageID# 384 earlier the defendant was well versed in ISIL's violence He did not make a simple mistake The defendant repeatedly supported and sought to support ISIL in multiple ways At first it was to help promote propaganda through ISIL videos When that was not enough he used his technical skills to obtain and provide information that ISIL was seeking There is no evidence that the defendant was coerced In each instance of support the defendant did so willingly He gathered and provided ISIL with the PII for the 1 300 military members and government employees He gathered customer information from the Victim Company culled the PII for the military members and government employees and provided it to ISIL The defendant freely made each of those choices while behind a keyboard thousands of miles from the war zone in Syria The defendant's previous brushes with the criminal justice system have failed to cure his criminal behavior According to the defendant he was arrested multiple times for cyber crimes in Kosovo In each instance he was promptly released because he apologized and was a juvenile Records from the Kosovo government confirm that the defendant has been charged with multiple offenses in Kosovo We are here in part because the defendant's previous arrests did nothing to deter him from committing cyber crimes The defendant should be imprisoned for the maximum available period of time that ensures he won't be able to use his specialized knowledge of hacking and computers to steal information for any purpose particularly to cause physical harm The defendant should be sentenced to 25 years' imprisonment -17- Case 1 16-cr-00042-LMB Document 54 Filed 09 16 16 Page 18 of 19 PageID# 385 IV CONCLUSION For the reasons above the Government believes that a sentence of incarceration of 25 years would be sufficient and not greater than necessary to satisfy the factors set forth in 18 U S C 3553 a Respectfully submitted Dana J Boente United States Attorney By _____ s ___________________ Brandon L Van Grack Special Assistant United States Attorney LT Eastern District of Virginia United States Attorney's Office 2100 Jamieson Avenue Alexandria Virginia 22314 Phone 703 299-3700 Email brandon van grack2@usdoj gov Gregory R Gonzalez Trial Attorney U S Department of Justice National Security Division -18- Case 1 16-cr-00042-LMB Document 54 Filed 09 16 16 Page 19 of 19 PageID# 386 CERTIFICATE OF SERVICE I hereby certify that on this 16th day of September 2016 I filed the foregoing pleading with the Clerk of Court and will send an electronic copy of such pleading to counsel of record via email Respectfully submitted Dana J Boente United States Attorney By _____ s ___________________ Brandon L Van Grack Special Assistant United States Attorney LT Eastern District of Virginia United States Attorney's Office 2100 Jamieson Avenue Alexandria Virginia 22314 Phone 703 299-3700 Email brandon van grack2@usdoj gov Case Document 54-1 Filed 09 16 16 Page 1 of 13 Page D# 387 ATTACHMENTS Case Document 54-1 Filed 09 16 16 Page 2 of 13 Page D# 388 ATTACHMENT A Case Document 54-1 Filed 09 16 16 Page 3 of 13 Page D# 389 lulu nun I GO 54 upturn Hm mum-5st II I I I PenVid HOME CATEGORY ARTICLES TOP VIDEOS NEWVIDEOS RANDOM VIDEO CONTACT US LATE 5T ARTIC LES TOP VIDEOS FEATURED uosr VICTORIES oi TH mm Islamic State Bombing at the Crusaders Upon the Ordinary Muslims Wiiayat 251 s ea Islamic State Joy ofthe Muslims theVicmries onhe Monotheists in r Islamic State Cubs of the Caliphate Brought Up in Their Environs Wil yat at View lslarnic Stale Joy of the Muj hidin With the Broken Deteat oral-aian and Elie-v 5 New video message mm The Islamic State of the Battle nn hugs h Case Document 541 Filed 09 16 16 Page 4 of 13 Page D# 390 uunl HOME ARHCLES NEWVIDEOS RANDOM VIDEO COMIACTUS FEATURED VIDEO ISLAMIC STATE OF THE MUSLIMS WITH THE TOP VIDEOS VICTORIES 0F TH ONOTHEISTS IN WILRYATAL-ANEIAR WILAY Islamic State Bombinnof use Crusatlels Upon me Oniimry Muslims Wiiyat Islamic State Juy a the Muslims lbev lclories bl me Manolhelstsin Islamic State Cub otme I 9 Caliphate Bought Up In lne Environs W I Iynl al- Islanlc Stile Joy of the Mu hh h mm the Broken Defamer-suler and Nekaleomessne from 'l'he Islamic Slale Asp-eds olme Battle on VIDEOS BEING WATCHED RIGHT NOW I I CATEGORIES videos LATEST ARTICLES EXPOSED lhe Bemural How the Islamic State lsnmic stale prisoners Reconciliation between 9 ol Jaum Mum AI came In lo cunllm with umng a speech about People by Islamlc sme woman NEW VIDEOS 5 7 IE El Shalr pmofallhe A Leadain ISIS EXPOSED The Beuayal Enamh l rmslalion of IS apostasy oftha lslarmc converse Mlnan old 01 Jenna Nusra IAI menu The bombing ol Indy Qaeda lo Islamic Stale Crusaders on Muslim men Bl laa 139 lire IE 173- le ied ICI If 11 1 3 mm l9 mnl lt 310 A um um m How the Islamic State Islamic stale pllsonels Islamic Ca phale Reconciliation between cane In In oan lct giving a speech about Repentance olMansoor People by Harlin Slate the Shailat Irlbe lhe mylhe live in Isis 3 6 3 3-39 Ame-I mm age Mir-d Isl-vam new c 2131 13mm m IE Juslicelnmelslu-nic Amman-Mashed tends raid-UH AnsweloIMus ms lo the Slate In mall pourl'nlleaence Threnl Apostate was 19 may we axe- 5 ls mums El-3 3 19 l'r'nl az ts ri ed i3 new we Answer ol'hluslimll to the The 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Hannah Slim E and 5-3 13 no 358 1 'v Newaudiamessuge from Muiahidin uITunIsia ol aI-antawin Bay'eh to Added I 61- ago New video Mileage Irom The Islamic State Glad tidings otthe Supponeu rid-35d I ago of the Enemy -IMIttyat Filed I or 43' telamic Stole Mouvauonameasagee From Yemen of and Adda-j I do 30 Islamic State Gamering ol'the Mandateisls With the Huslirn Clone r r i I Islamic State Raid ol aerating d anmuIt Refugee Canp wtliya cue I53 Islamic State Bhghazr The eming ul Slitiity Wi yal al-Barum' 42 33 Islam State Victory From God and An InminuttConquest - Aizj-i 1 27 131 Islunic Stale Shayldt Ab 'Umar ul-Baud c Hillary Training Camp 1112 3 3 Newvldeo message Irom The Islamic State Lion ol the Bame eid Atcert I 112' Ajnbd Foundation For Mattie Production presents a new release Luke-I id uh Newvideo message from The Islamic State Bans ol the De ant 41 91 I d3 30 Newvideo measagetrom The Islamic State F 'll emanation Close From kiwi 1 I as 3 Isianic Slate I Jogf oi the Monotheist With the Victories Ar d Illa ago Islamic Slate Water The Source of Life IMIaynt ol-Raqqah Axed di 1 Case Document 54-1 I Islamic Stolez BomhIng oltheCnnadas Upon meOrd mry Muslims lslunic State Declaration oI' Emma and Cutting oIFamtIy ee Ii Filed 09 16 16 Page 5 of 13 Page D# 391 Isl-mic Stole Storming Btigodea l Headquarters ollhe Safavld Amw- I 2p Islamic State Yamenl Congratulations For the Bay'oh olour Brothers In Aid 2' I 6 7 Islamic State Amputation ol' the Corruption Witt the Islunic Slate hPi-ety Tuna orcuemlr In the City clot-Nomi Mosul -11 31 17 oi F uroan Met a presents a new audio message from the Islamic State's Jud-tee I 33 J5 Newvldeo message Item The Islamic State The Rain otzmauwuayot I 1175- Newvideo message Imm Theltlamic SIAM Aspects of the name on Aided I at 33-3 Newvldeo mesonoe Irom The Islamic State The Raid of Turib al- mm I Newvldeo message from The Islamic State The Beginning and Ending ot lmed I Nequnn Manic State Joy of the Muslims With the Victories allhe 2 die 5 ego Islamic State I'ddr 2 30 Islarn't Stole Give ialanic stole Choroe ol the supporters weaan Sini'ISInoiI Uth I 11 33- New video message from The SI le Frorn Prisoner to Sacri ce A hate- 1 I my New noeomessage from The Istunic Slate a Spy of the 11121 1 3 15 New video message from The Islamic State Military Camp otthe Added Idayx ego New videomesouoe Irom Slate The Most Effective 14ij I031 390 New videomeengo from The Islamic State Graduation Clan From Aided Ida Pg Islamic State Extend Your Hand To Pledge Allegiance #3112 d3 13 Coalition terrorists attacking musllm children In How Amie May Case Document 54-1 Filed 09 16 16 Page 6 of 13 Page D# 392 ATTACHMENT ATTACHMENT Original Date Sender ID Receiver ID Message Text Sun Apr 26 11 24 06 0000 2015 Ferizi Hamayun selam alejkum Sun Apr 26 11 24 27 0000 2015 Ferizi Hamayun Sun Apr 26 11 24 34 0000 2015 Ferizi Hamayun Sun Apr 26 11 24 37 0000 2015 Ferizi Hamayun Sun Apr 26 11 24 40 0000 2015 Ferizi Hamayun Sun Apr 26 11 24 43 0000 2015 Ferizi Hamayun Sun Apr 26 11 24 46 0000 2015 Ferizi Hamayun Sun Apr 26 11 25 05 0000 2015 Ferizi Hamayun brotheri have 4 milion data of kuffar which attacking islamic state just first page and not all images coming saying big space Sun Apr 26 11 25 20 0000 2015 Ferizi Hamayun do you need them just dumped i havent sleep for 3 days Sun Apr 26 11 27 41 0000 2015 Ferizi Hamayun Sun Apr 26 22 01 57 0000 2015 Hamayun Ferizi l J Sun Apr 26 22 02 22 0000 2015 Hamayun Ferizi Sorry brother I couldnt reply back earlier on Sun Apr 26 22 02 37 0000 2015 Hamayun Ferizi just seen ur messages Sun Apr 26 22 03 20 0000 2015 Ferizi Hamayun ok brother Sun Apr 26 22 04 04 0000 2015 Hamayun Ferizi Pliz explain whats this info about Sun Apr 26 22 04 27 0000 2015 Hamayun Ferizi Sun Apr 26 22 04 38 0000 2015 Hamayun Ferizi Sun Apr 26 22 05 00 0000 2015 Hamayun Ferizi If possible come on redacted lets talk on there Redacted this is my redacted account Sun Apr 26 22 05 20 0000 2015 Hamayun Ferizi Lol get ur sleep too Sun Apr 26 22 05 39 0000 2015 Ferizi Hamayun brother im speaking with britani abu britani Sun Apr 26 22 13 55 0000 2015 Hamayun Ferizi Yes brother Sun Apr 26 22 14 14 0000 2015 Hamayun Ferizi Im muslim al britani Sun Apr 26 22 16 44 0000 2015 Hamayun Ferizi MashAllah brother I checked some of this info its really good Sun Apr 26 22 16 58 0000 2015 Hamayun Ferizi Can do some damage inshallah Sun Apr 26 22 17 21 0000 2015 Hamayun Ferizi Who are brother Sun Apr 26 22 17 33 0000 2015 Hamayun Fe rizi sound like a good person Sun Apr 26 22 17 46 0000 2015 Hamayun Ferizi May Allah SWT protect Sun Apr 26 22 33 31 0000 2015 Hamayun Ferizi Now iv checked it Wow know I was a credit card scammer in the UK Sun Apr 26 22 33 59 0000 2015 Hamayun Fen How can I thank Sun Apr 26 22 34 20 0000 2015 Ferizi Hamayun ii 00 Sun Apr 26 22 35 15 0000 2015 Hamayun Ferizi abu Hussain albritani is my friend he told me a lot about Sun Apr 26 22 35 45 0000 2015 Hamayun Ferizi Pliz brother come and join us in the Islamic state Sun Apr 26 22 50 56 0000 2015 Fen Hamayun inshAllah Wed May 06 09 42 39 0000 2015 Individual A Ferizi No one gets killed without reason eh So what about jihadi Johns beheadings What reason for that when they were trying to help Muslims Wed May 06 09 43 17 0000 2015 Ferizi Individual A man ill tell they never kill someone without reason believe me i gurante u ndo you know Wed May 06 11 01 18 0000 2015 Individual A Ferizi A group calling itself the a celslamic State Hacking Div a posted the names home addresses and photos of 100 American service member families Wed May 06 11 04 35 0000 2015 Ferizi Individual A yes cos they was the peoples who killed peoples in iraq and syria Wed May 06 11 04 52 0000 2015 Ferizi Individual A if someone kill urfamily and run would not find him and kill him Wed May 06 21 41 52 0000 2015 Individual Ferizi I think they contacted your host though I m not certain Wed May 06 21 42 08 0000 2015 Ferizi Individual yeah they have send me an email 3 nfor terrorism something Wed May 06 21 42 15 0000 2015 Ferizi Individual 8 your team Wed May 06 21 42 49 0000 2015 Individual 8 Ferizi Lol Little do they know Wed May 06 21 42 51 0000 2015 Ferizi Individual It has come to my attention that the website is being used as a website by a terrorist organization for the promot Wed May 06 21 43 01 0000 2015 Ferizi Individual of violence and criminal activity One look at the website and you can see criminal activity all over it The videos on your site are being Wed May 06 21 43 03 0000 2015 Ferizi Individual used to promote violence and encourage it Please act on this website Wed May 06 21 43 21 0000 2015 Ferizi Individual i saw it lately Wed May 06 21 43 39 0000 2015 Individual 8 Ferizi Oh So they did Wow Wed May 06 21 44 08 0000 2015 Ferizi individual yeah they send to the hosting administrator which is me The social media account names have been anonymized or changed to reflect the true names of the account users Victim information has been redacted or replaced Case 1 Document 54-1 Filed 09 16 16 Page 7 of 13 PagelD# 393 Case Document 54-1 Filed 09 16 16 Page 8 of 13 Page D# 394 ATTACHMENT Case Document 54-1 Filed 09 16 16 Page 9 of 13 PagelD# 395 Author Recipient Message Sent UTC Message Message Status Ferizi Hussain 06 13 2015 07 59 15 PM when here write me ss Sent Hussain 06 13 2015 10 01 53 PM im here Read Ferizi Hussain 06 13 2015 10 21 15 PM hows bro 55 Sent Ferizi Hussain 06 13 2015 10 21 21 PM salam alejkum Sent Ferizi Hussain 06 13 2015 10 21 23 PM was praying Sent Ferizi Hussain 06 13 2015 10 21 25 PM just came Sent Hussain 06 13 2015 10 21 28 PM walaykumsallam Read Hussain 06 13 2015 10 21 33 PM im good allhamdulilah Read Hussain 06 13 2015 10 21 34 PM ypu Read Hussain 06 13 2015 10 21 36 PM you Read Ferizi Hussain 06 13 2015 10 21 45 PM elhamdulilah brother 55 Sent Ferizi Hussain 06 13 2015 10 22 01 PM wait i prepare some dumps i got 01- Sent Hussain 06 13 2015 10 22 08 PM ok inshAllah Read Ferizi Hussain 06 13 2015 10 23 27 PM gov dump htm Sent Ferizi Hussain 06 13 2015 10 23 37 PM military dump html Sent Hussain Ferizi 06 13 2015 10 23 40 PM which website akhi Read Ferizi Hussain 06 13 2015 10 24 15 PM Victim Company 55 plus i got Sent Ferizi Hussain 06 13 2015 10 24 18 PM the credit card Sent Ferizi Hussain 06 13 2015 10 24 26 PM of airforce Sent Ferizi Hussain 06 13 2015 10 24 30 PM department Sent Ferizi Hussain 06 13 2015 10 24 32 PM waiti show Sent Ferizi Hussain 06 13 2015 10 24 46 PM Victim Company have around 190k users Sent Ferizi Hussain 06 13 2015 10 24 47 PM 55 Sent Ferizi Hussain 06 13 2015 10 26 39 PM orders html Sent Hussain Ferizi 06 13 2015 10 28 44 PM where get the mil gov dumps Read Ferizi Hussain 06 13 2015 10 28 57 PM in the website Victim Company already now im connected on it Sent Ferizi Hussain 06 13 2015 10 29 02 PM wanna come via teamviewer ss Sent Hussain Ferizi 06 13 2015 10 29 08 PM have a shell Read Hussain Ferizi 06 13 2015 10 29 21 PM ss Read Hussain 06 13 2015 10 29 22 PM Victim Company has gov and mil logins Read Ferizi Hussain 06 13 2015 10 29 22 PM have db access Sent Hussain 06 13 2015 10 29 26 PM ah ok Read Ferizi Hussain 06 13 2015 10 29 28 PM yes bro ss Sent Ferizi Hussain 06 13 2015 10 29 31 PM come see bro Sent Hussain 06 13 2015 10 29 41 PM can I see in 30mins Read Hussain Ferizi 06 13 2015 10 29 48 PM free megabytes in 30mins Read Hussain 06 13 2015 10 29 52 PM have limit Read Hussain 06 13 2015 10 29 57 PM but at 2am in 30mins its free Read Ferizi Hussain 06 13 2015 10 30 00 PM Sent Ferizi Hussain 06 13 2015 10 30 11 PM oh good bro 55 Sent Ferizi Hussain 06 13 2015 10 30 40 PM i have also another shop which have 878k clients and its military shop Sent Ferizi Hussain 06 13 2015 10 30 43 PM ss Sent Ferizi Hussain 06 13 2015 10 30 50 PM there is huge db Sent Hussain Ferizi 06 13 2015 10 30 53 PM Allahu Akbar Read Hussain 06 13 2015 10 30 57 PM we need to hit them hard Read Ferizi Hussain 06 13 2015 10 31 04 PM yes inshaAllah ss Sent Hussain 06 13 2015 10 31 12 PM ok akhi we will release biidnillah Read Ferizi Hussain 06 13 2015 10 31 14 PM just when we hit hit them strong ss Sen't Hussain 06 13 2015 10 31 17 PM but tell me no one else has this Read Ferizi Hussain 06 13 2015 10 31 20 PM noone Sent Ferizi Hussain 06 13 2015 10 31 25 PM brother only me and Allah knows Sent Hussain 06 13 2015 10 31 32 PM Allhamdulilah Read Hussain Ferizi 06 13 2015 10 31 37 PM how did get DB access Read The social media account names have been changed to reflect the true names of the account users Victim information has been redacted or replaced Case Document 54-1 Filed 09 16 16 Page 10 of 13 PagelD# 396 ATTACHMENT Ferizi Hussain 06 13 2015 10 31 43 PM easy penetration Sent Hussain 06 13 2015 10 31 50 PM Read Ferizi Hussain 06 13 2015 10 31 58 PM sqli the mobile app 55 Sent Ferizi Hussain 06 13 2015 10 32 12 PM and got access all in ss Sent Hussain Ferizi 06 13 2015 10 32 19 PM masha'Allah Read Hussain 06 13 2015 10 32 21 PM nice Read everyday 400 500 orders come in this website Victim Company ss Ferizi Hussain 06 13 2015 10 32 32 PM Sent Hussain 06 13 2015 10 32 44 PM but how got DB login info Read Ferizi Hussain 06 13 2015 10 33 34 PM Sent Ferizi Hussain 06 13 2015 10 34 16 PM penetration after penetration Sent Ferizi Hussain 06 13 2015 10 34 20 PM injection after injection ss Sent Hussain Ferizi 06 13 2015 10 35 23 PM Allahu Akbar Read Hussain Ferizi 06 13 2015 10 35 32 PM akhi maybe some of these military emails Read Hussain Ferizi 06 13 2015 10 35 37 PM the passwords work for their emails Read Hussain 06 13 2015 10 35 40 PM tried Read Ferizi Hussain 06 13 2015 10 35 51 PM didnt tried yet bro Sent Ferizi Hussain 06 13 2015 10 35 56 PM got new Sent Ferizi Hussain 06 13 2015 10 36 02 PM the other db i have 900k Sent Ferizi Hussain 06 13 2015 10 36 06 PM bro all Military Sent Ferizi Hussain 06 13 2015 10 36 13 PM i putted in map Sent Ferizi Hussain 06 13 2015 10 36 16 PM for getting Sent Ferizi Hussain 06 13 2015 10 36 22 PM it have so syntax errors but works Sent Ferizi Hussain 06 13 2015 10 36 24 PM but slowly Sent Ferizi Hussain 06 13 2015 10 36 30 PM gonna get a big servers Sent Ferizi Hussain 06 13 2015 10 36 41 PM to dump it fast Sent Hussain Ferizi 06 13 2015 10 36 49 PM this one gave me is all mil Read Ferizi Hussain 06 13 2015 10 37 02 PM no this one have 900 email mil Sent Ferizi Hussain 06 13 2015 10 37 06 PM and 500 gov Sent Ferizi Hussain 06 13 2015 10 37 09 PM with passwords Sent Hussain Ferizi 06 13 2015 10 37 13 PM but there is more in server Read Ferizi Hussain 06 13 2015 10 37 14 PM the other one is military site sent Ferizi Hussain 06 13 2015 10 37 24 PM brother its another server sent Ferizi Hussain 06 13 2015 10 37 25 PM Sent Hussain Ferizi 06 13 2015 10 37 32 PM ok so in Victim Company we have 900 mil and 500 gov Read Ferizi Hussain 06 13 2015 10 37 37 PM 55 sent Ferizi Hussain 06 13 2015 10 37 37 PM yes Sent Hussain Ferizi 06 13 2015 10 37 42 PM ok perfect Read Ferizi Hussain 06 13 2015 10 37 50 PM Hussain Ferizi 06 13 2015 10 37 54 PM all mil Read Ferizi Hussain 06 13 2015 10 37 57 PM so gonna see Sent Ferizi Hussain 06 13 2015 10 38 07 PM not all mil but 70% maybe ss Sent Hussain Ferizi 06 13 2015 10 38 10 PM yes maybe Read Ferizi Hussain 06 13 2015 10 38 11 PM lets see lets see db is big Sent Ferizi Hussain 06 13 2015 10 38 18 PM after all dump Sent Hussain Ferizi 06 13 2015 10 38 20 PM ok perfect inshAllah Read Ferizi Hussain 06 13 2015 10 38 21 PM gonna see slowly Sent Ferizi Hussain 06 13 2015 10 38 23 PM inshaAllah sent Hussain Ferizi 06 13 2015 10 38 31 PM we will only release mi and gov Read Hussain Ferizi 06 13 2015 10 38 38 PM and the others we release later Read Ferizi Hussain 06 13 2015 10 38 45 PM USAF Sent Ferizi Hussain 06 13 2015 10 38 48 PM united state air force Sent Hussain Ferizi 06 13 2015 10 38 52 PM we will make like a message inshAllah Read Ferizi Hussain i have the credit card payment they make online ss Sent 06 13 2015 10 38 53 PM The social media account names have been changed to reflect the true names of the account users Victim information has been redacted or replaced Case Document Filed 99 16 16 Page 11 of 13 Page D# 397 CHME Hussain Ferizi 06 13 2015 10 39 02 PM like know the hitlist I made Read Hussain Ferizi 06 13 2015 10 39 06 PM with addresses Read Hussain Ferizi 06 13 2015 10 39 14 PM we will make message to kuffar and release the mil and gov Read Hussain 06 13 2015 10 39 24 PM akhi work on the mil shop Read Hussain Ferizi 06 13 2015 10 39 31 PM I will check if emails match with passwords Read Hussain 06 13 2015 10 39 39 PM maybe we find some good information Read Ferizi Hussain 06 13 2015 10 41 14 PM keke html Sent Ferizi Hussain 06 13 2015 10 41 22 PM ok brother 55 Sent Hussain Ferizi 05 13 2015 10 41 51 PM Allahu Akbar Read Hussain Ferizi 06 13 2015 10 42 10 PM Akhi this will hit them hard Read Ferizi Hussain 06 13 2015 10 42 19 PM yes brother inshaAllah ss Sent Hussain Ferizi 06 13 2015 10 42 24 PM we will make a good message to the kuffar Read Ferizi Hussain 06 13 2015 10 42 30 PM yes bro 55 55 ss Sent Hussain Ferizi 06 13 2015 10 42 36 PM Will write it later Read Hussain Ferizi 06 13 2015 10 42 39 PM and check it inshAllah Read Ferizi Hussain 06 13 2015 10 42 41 PM good 55 55 Sent Hussain Ferizi 06 13 2015 10 42 43 PM and we release Read Ferizi Hussain 06 13 2015 10 42 45 PM inshaAllah ss Sent Hussain Ferizi 06 13 2015 10 42 49 PM but no names we don't release our names Read Ferizi Hussain 06 13 2015 10 42 55 PM no names Sent Ferizi Hussain 06 13 2015 10 42 56 PM of course Sent Hussain Ferizi 06 13 2015 10 43 02 PM just Islamic State Hacking Division Read Hussain Ferizi 06 13 2015 10 43 05 PM its official name Read Ferizi Hussain 06 13 2015 10 43 05 PM good ss Sent Ferizi Hussain 06 13 2015 10 43 08 PM yes yes thats good 55 Sent Ferizi Hussain 06 13 2015 10 43 11 PM no need names Sent Hussain Ferizi 06 13 2015 10 43 18 PM akhi need to make hijrah Read Hussain Ferizi 06 13 2015 10 43 22 PM We can work together here Read Hussain Ferizi 06 13 2015 10 43 24 PM full time Read Ferizi Hussain 06 13 2015 10 43 33 PM yes bro Sent Ferizi Hussain 06 13 2015 10 43 37 PM i should Sent Hussain Ferizi 06 13 2015 10 43 41 PM i can help inshAllah Read Hussain Ferizi 06 13 2015 10 43 56 PM i will give tazkiyah and when come i will get a special letter for Read Hussain Ferizi 06 13 2015 10 44 06 PM to skip everything and come straight to this work Read Ferizi Hussain 06 13 2015 10 44 12 PM wallah ss Sent Hussain Ferizi 06 13 2015 10 44 17 PM wallahi akhi Read Hussain Ferizi 06 13 2015 10 44 19 PM easy Read Ferizi Hussain 06 13 2015 10 44 27 PM cos brother know wallahi i started around 2 months to pray bro Sent Hussain Ferizi 06 13 2015 10 44 34 PM no problem akhi Read Ferizi Hussain 06 13 2015 10 44 35 PM 55 Sent Hussain Ferizi 06 13 2015 10 44 50 PM will just do 30day sharia training course Read Hussain Ferizi 06 13 2015 10 44 53 PM they teach everything Read Hussain Ferizi 06 13 2015 10 44 56 PM in english Read Ferizi Hussain 06 13 2015 10 44 57 PM thats good Sent Ferizi Hussain 06 13 2015 10 44 59 PM brother Sent Hussain Ferizi 06 13 2015 10 45 00 PM after that show them the letter Read Hussain Ferizi 06 13 2015 10 45 07 PM get fast tracked to my division Read Ferizi Hussain 06 13 2015 10 45 11 PM how much need have bro every month money there sent Hussain Ferizi 06 13 2015 10 45 27 PM dowla pays Read Hussain Ferizi 06 13 2015 10 45 29 PM minha Read Hussain Ferizi 06 13 2015 10 45 31 PM and fai Read Ferizi Hussain 06 13 2015 10 45 41 PM i mean to survive there how much i need to have Sent Ferizi Hussain 06 13 2015 10 45 42 PM every month Sent Hussain Ferizi 06 13 2015 10 45 46 PM 50 dollars per adult dowla give Read Hussain Ferizi 06 13 2015 10 45 51 PM and 100 dollars fai Read Hussain Ferizi 06 13 2015 10 45 54 PM they give 150 dollars Read Hussain Ferizi 06 13 2015 10 45 59 PM but if are not married Read Hussain Ferizi 06 13 2015 10 46 10 PM free house Read Hussain Ferizi 06 13 2015 10 46 10 PM will stay in the base Read Hussain Ferizi 06 13 2015 10 46 13 PM free food Read Hussain Ferizi 06 13 2015 10 46 15 PM free electric Read Hussain Ferizi 06 13 2015 10 46 17 PM free gas Read The social media account names have been changed to reflect the true names of the account users Victim information has been redacted or replaced Case Document 54-1 Filed 09 16 16 Page 12 of 13 Page D# 398 ATTACHMENT Case Document 54-1 Filed 09 16 16 ATTACHIVIENT text i work with that brother akhi sender_id Hussain recipient_id Individual created_at Tue Aug 11 19 37 21 0000 2015 text hes in our team sender_id Hussain recipient_id Individual created_at Tue Aug 11 19 37 37 0000 2015 Page 13 of 13 Page D# 399 text Elhamdulilah because i feared for him though kuffar maybe arrested him or anything sender_id Individual recipient_id Hussain created_at Tue Aug 11 19 38 15 0000 2015 text his fb was deleted and he didnt respond on redacted also his twitter acc was dead sender_id Individual recipient_id Hussain created_a Tue Aug 11 19 38 42 0000 2015 text no akhi hes just busy lately sender_id Hussain recipient_id Individual created_a Tue Aug 11 19 38 51 0000 2015 The social media account names have been anonymized or changed to re ect the true names of the account users Victim information and sensitive information has been redacted This document is from the holdings of The National Security Archive Suite 701 Gelman Library The George Washington University 2130 H Street NW Washington D C 20037 Phone 202 994-7000 Fax 202 994-7005 nsarchiv@gwu edu