UNITED STATES DISTRICT COURT

DISTRICT OF NEW JERSEY

UNITED STATES OF AMERICA Hon. Jessica S. Allen

v. Mag. No. 22-8385

OMAR ALKATTOUL CRIMINAL COMPLAINT

I, the undersigned complainant, being duly sworn, state the following is

true and correct to the best of my knowledge and belief.

SEE ATTACHMENT A

I further state that I am a Special Agent of the Federal Bureau of

Investigation, and that this complaint is based on the following facts:

SEE ATTACHMENT B

continued on the attached pages and made a part hereof.

.:ello
Special Agent
Federal Bureau of Investigation

Special Agent Aiello attested to this affidavit by

telephone pursuant to Fed. R. Crim. P. 4.l(b)(2)(A).

_____//-+-l_q~,,__/2_7-
_______at Newark. New Jersey
1
Date I City and State

HON. JESSICA S. ALLEN

United States Magistrate Judge
JA
Name and Title of Judicial Officer
 ATTACHMENT A
(Transmitting Threat in Interstate and Foreign Commerce)

On or about November 1, 2022, in the District of New Jersey and

elsewhere, defendant

OMAR ALKATTOUL,

knowingly transmitted in interstate and foreign commerce communications

containing a threat to injure the persons of another.

In violation of Title 18, United States Code, Section 875(c).

 ATTACHMENT B
I, Jamie Aiello, am a Special Agent with the Federal Bureau of
Investigation (“FBI”). I am fully familiar with the facts set forth herein based
upon briefings with other law enforcement officers. Because this complaint is
being submitted for the limited purpose of establishing probable cause, I have
not included each and every fact known to me concerning this investigation. I
have only set forth facts that I believe are necessary to establish probable
cause. Unless specifically indicated, all conversations and statements
described in this affidavit are related in substance and in part. Dates of events
are asserted as having occurred on or about the asserted date.

1. As discussed in more detail below, on or about November 4, 2022,

law enforcement conducted a consensual search of an iPhone belonging to
Defendant OMAR ALKATTOUL (“ALKATTOUL”). The search revealed that on or
about November 1, 2022, ALKATTOUL used a social media application
(“Application-1”) to communicate with another user of Application-1
(“Individual-1”). During the conversation between ALKATTOUL and Individual-
1, ALKATTOUL referred to a document that ALKATTOUL had been writing.
ALKATTOUL told Individual-1, “I actually started writing it a long time ago. If
you want I will link it. It’s in the context of an attack on Jews.” Shortly
thereafter, ALKATTOUL sent a link to a document entitled “When Swords
Collide” (the “Document”). In an interview with law enforcement on or about
November 4, 2022, ALKATTOUL admitted that he had drafted the Document
and sent it to Individual-1. ALKATTOUL further stated that he believed
Individual-1 wanted to read the Document.

2. On or about November 5, 2022, a second individual (“Individual-

2”), who communicated with ALKATTOUL on a social media application
(“Application-2”), informed law enforcement that he/she communicated with
ALKATTOUL in a server on Application-2. 1 According to Individual-2,
ALKATTOUL shared a link to the Document in the server with four individuals
in addition to Individual-2. Individual-2 stated that he viewed the Document.
Individual-2 also stated that the server may have had 20 members at one
point, and when ALKATTOUL mentioned the Document, other users
commented “good job” or “proud of you.” Individual-2 stated that he/she
communicated with ALKATTOUL via Application-2 as well as other social
media applications. According to Individual-2, ALKATTOUL told Individual-2
that he wanted to kill in an “act of revenge” for the death of Muslims. In or
around early October 2022, Individual-2 asked ALKATTOUL about his plan for
an attack. ALKATTOUL claimed that he no longer wanted to do it. On or
about October 5, 2022, ALKATTOUL used a different social media application

1Based on my training and experience, I am aware that Application-2 allows

users to create “servers” and “channels” through which users can
communicate with groups of other users.
2
to send Individual-2 an audio recording of ALKATTOUL speaking in Arabic.
The recording has been translated into English as follows:

With God’s permission, we will conquer Andalusia, O

French! And we will conquer Jerusalem, O Jews.
With God’s permission, he will slaughter you, O swine
and monkeys, God damn you. And I pledge allegiance
to Abu-Hasan al-Hashimi al-Qurayshi,[ 2] may God
protect him; and I will obey him during hard times
and good times. With God’s permission, the Jews will
be frightened; the promise is near.

3. On or about November 4, 2022, law enforcement reviewed a copy

of the Document on ALKATTOUL’s iPhone pursuant to a consensual search. In
a section of the Document titled “Introduction,” ALKATTOUL stated, among
other things, the following:

All praise is due to Allah SWT,[ 3] I am the attacker

and I would like to introduce myself. . . I am a Muslim
with so many regrets but I can assure you this attack
is not one of them and Insha’Allah[ 4] many more
attacks like these against the enemy of Allah and the
pigs and monkeys will come.

4. In a section of the Document titled “The target,” ALKATTOUL

stated, among other things, the following:

I will discuss my motives in a bit but I did target a

synagogue for a really good reason according to
myself and a lot of Muslims who have a brain.
Let’s be aware of the fact that the Jews promote the
biggest hatred against Muslimeen even in the west.
The Jews are in fact a very powerful group in the west
which is why western countries today shill for them on

2 Based on my training and experience, al-Khurayshi refers to Abu al-Hasan al-

Hashimi al-Quarashi, who is the third and current caliph of the Islamic State
(ISIS).

3 “SWT” refers to “Subhanahu wa ta’ala,” which translates generally from

Arabic as “Glory to Him, the Exalted.”

4 “Insha’Allah” translates generally from Arabic as “if Allah (God) wills” or “God
willing.”

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 top of the murtadeen[ 5] in Saudi Arabia and every Arab
country.

(Emphasis added).

5. In a section of the Document titled “The motive of the attack,”

ALKATTOUL stated, among other things, the following:

This attack was just to remind the Jews that as

long as 1 Muslim remains in this world they will
never live a pleasant life until the Muslims in
Palestine, Syria, West Africa, and South Asia are
living a pleasant life. The Jews support terror
against the muslimeen and always have . . . . So the
motive of this attack is hatred towards Jews and their
heinous acts and I don’t want anyone to tell me for a
second that “not all Jews support terror against
Muslims” yes they do! They have since day one.
Their Torah justifies their acts and let’s keep in mind it
was a Jew that tried to kill the nebi SAW.[ 6]

(Emphasis added).

6. Other sections of the Document contained the following titles:

• “Why hatred towards Jews is a good thing even if they’re not

Zionists”
• “The right-wing ideology of the Jews”
• “The term ‘anti-Semitic’ and it’s true meaning”
• “The ‘Holocaust’”
• “The ‘good’ Jews,” in which ALKATTOUL states, “Good jews do not
exist unless if they convert to Islam. . . . I hate jews based on
their actions and their religion that justifies the actions they do.”

7. In a section of the Document titled “The Heroes,” ALKATTOUL

stated, among other things:

. . . when I say “heroes and lions” I am referring to

Osama Bin Laden, Abu Musab al-Zarqawi, Abu Bakr

5 “Murtadeen” translates generally from Arabic as “apostate,” which is one who

renounces religious or political beliefs or principals.

6Referencing Muhammad, believed to be the last Prophet and Messenger of

God.
4
 al-baghdadi, Abu Muhammad al-Adani, Anwar al-
Awlaki, Abu Omar al-Shishan, Mullah Omar and
Abdullah Azzam[ 7] . . . and of course the lone wolf
muwahideen[ 8] who have made the kuffar[ 9] shook.

8. In a section of the Document titled “Religion of peace,” ALKATTOUL

stated, among other things, “. . . I as a Muslim and disbeliever in the taghut,[ 10]
I support terrorism against the kuffar and the enemies of the deen.” 11

9. The Document also has a section titled, “A Small Few Questions

for Omar, Pt 1.” One of the questions and corresponding answer is as follows:

Q: Why have you chosen to carry this attack on behalf

of ISIS?

A: It’s not “ISIS” it is the “Islamic State”. I chose to

do it on behalf of them because they’re legitimate
mujahideen[ 12] unlike modern day al-Qaeda and
Taliban.

10. On or about November 3, 2022, law enforcement agents

interviewed ALKATTOUL at his residence. ALKATTOUL made the following
statements, in substance and in part:

a. ALKATTOUL was “radicalized” over the course of

approximately one year after viewing posts on Application-2 that
contained screenshots of a video showing Kahane-ists laughing
and sharing photos of dead Arab children and praising the people

7 All various leaders and/or spokespersons for al-Qaeda, The Taliban and/or
ISIS.

8 “Muwahideen” translates generally from Arabic as “monotheist.”

9 “Kuffar” translates generally from Arabic as “unbeliever/non-Muslim/infidel.”

10“Taghut” is a term that is specifically used to denounce everything that is

worshiped instead of Allah. It is often used in reference to an oppressive
government.

11 “Deen” translates generally from Arabic as the religion or belief of a Muslim.

12“Mujahideen” translates generally from Arabic as guerrilla fighters in Islamic

countries, especially those who are fighting against non-Muslim forces.

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 who killed them. 13 ALKATTOUL also stated that he used an
encrypted social media application (“Application-3”) to view ISIS
propaganda, and to communicate with others who were
encouraging him to carry out an attack. Specifically, ALKATTOUL
stated that he had communicated with an individual (“Individual-
3”), who ALKATTOUL believed was affiliated with al-Qaeda and
located in Pakistan, and an individual in Germany (“Individual-4”),
who introduced ALKATTOUL to Individual-3.

b. Individual-3 provided ALKATTOUL with documents and

information on how to protect his iPhone and phone applications
from being detected by law enforcement. ALKATTOUL stated that,
based on the information provided, he had taken steps to conceal
his iPhone communications and data, including changing his web
search engine.

c. ALKATTOUL communicated to Individual-3 that he

(ALKATTOUL) could conduct an attack on Jewish or gay people,
but claimed that he did not have adequate resources to do so.
Specifically, ALKATTOUL stated that he told Individual-3 that he
(ALKATTOUL) could attack synagogues or gay clubs. ALKATTOUL
told law enforcement that he considered an attack on a synagogue
in New York but would need two years to prepare for such an
attack. ALKATTOUL said that he researched how to obtain a gun,
shooting ranges, and mass shootings. He also said that if he were
to conduct an attack, it would be a shooting attack. He said he
would not feel bad for the victims but would feel bad for the
families of the victims. ALKATTOUL claimed that as of October
29, 2022, he was about “50/50” on whether or not he would
commit an attack.

d. ALKATTOUL described a terrorist as someone who killed or

hurt people. He claimed that he was not a terrorist, but admitted
that he had previously posted in Application-3 that God cursed
the Jewish people and God should burn gay people. He told law
enforcement that in September 2022, he posted in a group chat in
Application-3 that he would punch in the face or curb stomp the
next “f****t” he saw. He claimed that the group chat consisted of
individuals who were “LARP-ing” as terrorist/jihadis. He
explained that “LARP-ing” was live-action role playing.

13 Based on my training and experience, “Kahane-ists” were followers of Meir

Kahane, who, according to ALKATTOUL, believed that Jewish people were
superior to others. He also told law enforcement that if he found where the
Kahane-ist headquarters was located, he would burn it to the ground, but then
claimed that he “didn’t have the balls” to do that.
6
 e. ALKATTOUL also admitted that he posted on Application-3
that he would throw a Molotov cocktail on a Jewish person, but
claimed that it was in a joking manner. He also claimed he would
not actually do it because he did not want to disappoint his
family. He further claimed that he did not “have the balls” to
commit such an act, especially after “this visit” from the FBI.
ALKATTOUL additionally claimed that he did not want to serve a
prison term, get shot, or die.

f. ALKATTOUL admitted that he had seen information about

making bombs posted in the Application-3 group chat, but he had
never personally looked into making a bomb or posted
information about bombmaking. He admitted that on or about
October 23, 2022, he posted a statement in Application-3 saying
that he wanted to throw a bomb on Hizballah because they were
Shia, and he did not like Shiites because of their beliefs. He then
claimed, “but let’s be honest, I’m not man enough to act on any of
this.”

g. ALKATTOUL also stated that he would not give money to

individuals who wanted to commit an act of violence. He admitted
that he had hostility but would not be violent himself. He claimed
that if he heard about someone wanting to do something violent,
he would tell them not to do it because he would feel bad if they
got arrested or killed. ALKATTOUL said, however, that he would
not feel bad for the victims of violence.

h. ALKATTOUL claimed that he would not actually commit the

acts of violence about which he posted on Application-3.

i. In response to law enforcement’s question as to whether

ALKATTOUL planned to conduct an attack, ALKATTOUL
responded that it was a “possibility” and that he wanted to get to
that point as quickly as possible, but then claimed that he did not
really want to conduct an attack as soon as possible.

11. On or about November 4, 2022, law enforcement conducted

another interview of ALKATTOUL. During that interview, ALKATTOUL made
the following statements, in substance and in part:

a. ALKATTOUL admitted that he created the Document, but

claimed that this was done while LARP-ing. ALKATTOUL stated
that he wrote the Document in five days. He claimed that he
imagined being al-Qaeda and carrying out an attack. He further
claimed that he wrote the Document in the first person in the
7
 context of being a leader.

b. When ALKATTOUL was asked if he would carry out an

attack if he had his own money and did not live with his parents,
he claimed that he would not. When asked if the Document was
real or fake, he replied that part of it was real, but he then
claimed that it was fake.

12. During both interviews, ALKATTOUL gave consent to law

enforcement to search several electronic devices, including an iPhone.

13. The consensual search, as well as the search of ALKATTOUL’s

iPhone pursuant to a court-authorized search warrant, revealed the following:

a. Between on or about August 4, 2022 and on or about

August 21, 2022, ALKATTOUL exchanged a series of private
messages over Application-3 with another user of Application-3
(“Individual-5”). ALKATTOUL stated, “. . . I know my target but
idk [I don’t know] the location.” In response to Individual-5’s
question, “U planning an attack?”, ALKATTOUL responded, “Yes.”
ALKATTOUL further told Individual-5 that the attack would not
happen for about six to seven years because he needed to plan it
and gather resources. He stated, “Well you see I want this attack
to be affiliated with AQ [al-Qaeda].” ALKATTOUL added that he
would later specify “this attack and the motive,” and that the
attack was in retaliation for the New Zealand mosque shootings in
Christchurch on March 15, 2019. He noted that the attack would
involve bombings, shootings, and “maybe” beheadings.

b. On or about August 29, 2022, ALKATTOUL sent a private

message on Application-3 to Individual-2, stating, “As a Muslim I
support Dylann Roof[ 14] because he went in a n****r Christian
Janiya type church and killed 10 Christcucks while being an
atheist, a lot Muslims in the west should learn from him.”

c. On or about August 30, 2022, ALKATTOUL sent a private

message on Application-3 to another user of Application-3
(“Individual-6”). The message contained a video and photo
montage of Dylann Roof. In response, Individual-6 stated, “[M]e
in [S]hia mosque.” ALKATTOUL then responded, “Me in church
and synagogue.”

14 Dylann Roof is an American white supremacist Neo-Nazi convicted for hate

crimes for the shooting murders of nine people in a South Carolina church on
June 17, 2015.
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 d. On or about October 4, 2022, ALKATTOUL searched for an
Arabic-English translation of “[b]y God, I will slaughter you, O
Jews.”

e. On or about October 16, 2022, ALKATTOUL searched the

Internet for “beslan school seige,” which referred to a terrorist
attack on a school in Beslan, Russia in 2004, in which 333 people
were killed, including 186 children.

f. On or about October 20, 2022, ALKATTOUL searched for a

foreign language translation of “I hate Jews, and I love the Islamic
state.”

g. On or about October 21, 2022, among other things,

ALKATTOUL’s web history revealed the following: “aq [al-Qaeda]
attack on jewish school france.”

h. On or about October 27, 2022, ALKATTOUL received a

message on an encrypted messaging application (“Application-4”)
from Individual-3, who was also using Application-4. The
message stated, “brothers told me u will @ttck in US.” On or
about October 29, 2022, ALKATTOUL responded: “Yeah so
basically about 2 months ago I told [Individual-4] and [another
individual (“Individual-7”)] that I was planning an attack but it’s
gonna take me years to prepare for it because I don’t have items
and my parents do not like guns. I said I could be targeting a
synagogue or gay night club. And this would be AQ [al-Qaeda]
affiliated attack.” ALKATTOUL also stated to Individual-3, “. . .
I’ve been thinking about jihad for a while now and I just came to
this conclusion of how and where. . . . And I am taking a class in
college next year that teaches how to hack and how to go on the
dark web and I feel like that would be useful and somewhat
relevant in going on jihad.” ALKATTOUL also stated, “[Individual-
7] sent me inspire[ 15] pdf magazines.”

15 Based on my training and experience, “Inspire” is an English language online

magazine published by al-Qaeda. The magazine is one of the many ways that
al-Qaeda uses the Internet to reach its audience.

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 i. On or about October 29, 2022, ALKATTOUL sent a message
via Application-3 to Individual-2, who also had an account with
Application-3: “I got messaged by AQ [al-Qaeda]. . . . I’m try[ing]
[to] explain to the guy that I can’t go and attack but he’s urging
me to . . . TTP[ 16] recruitment.” ALKATTOUL also sent Individual-
2 a screen capture of the conversation with Individual-3
referenced above in paragraph 13.h.

14. After the interview with law enforcement, while voluntarily in an

ambulance during transport to the hospital for an examination, ALKATTOUL
told the ambulance personnel that he supported ISIS and al-Qaeda.

15. Upon arrival at the hospital, ALKATTOUL told a hospital employee

(“Employee-1”) during the intake process that ALKATTOUL identified with the
ideologies of ISIS and al-Qaeda. He also told Employee-1 that he had been
communicating on social media with someone he believed to be in al-Qaeda.
ALKATTOUL additionally stated that he told the person he believed to be in al-
Qaeda that he (ALKATTOUL) had plans to blow up a synagogue but did not
know if it was going to be in a day, a week, or year.

16. ALKATTOUL further told Employee-1 that although some things

he said on social media were a joke, one thing that was not a joke was his
wanting to plan an attack on a synagogue.

16Based on my training and experience, “TTP” is believed to reference “Tehrik-e

Taliban Pakistan,” which is a group of militant Taliban networks formed to
oppose the Pakistani military.
10