Case 1:16-cr-00020-AJT Document 30 Filed 03/18/16 Page 1 of 11 PageID#FILED 109 INOPFN COURT

I8 IN THE UNITED STATES DISTRICT COURT FOR THI

aiRR. u s DISTRICT COURT ALEXANDRIA. VIRGINIA

EASTERN DISTRICT OF VIRGINIA Alexandria Division UNITED STATES OF AMERICA V.

JOSEPH HASSAN FARROKH, Defendant.

) ) ) ) ) ) )

No. l:16-CR-0020

STATEMENT OF FACTS

The United States and the defendant, JOSEPH HASSAN FARROKH, agree that the

United States would have proven at trial the following facts beyond a reasonable doubt with admissible and credible evidence:

1. Beginning in or about August 2015, and continuing through January 15,2016, within Prince William County in the Eastern District of Virginia and elsewhere, the defendant, JOSEPH

HASSAN FARROKH, did knowingly and unlawfully combine, conspire, confederate, and agree with Mahmoud Amin Elhassan to provide and attempt to provide material support and resources, as that term is defined in Title 18, United States Code, Section 2339A(b), to wit, personnel, to a

designated foreign terrorist organization, namely the Islamic State of Iraq and the Levant ("ISIL"), also known as the Islamic State of Iraq and Syria ("ISIS") and other names, in that, as

more particularly described below, Farrokh attempted to travel to Iraq and Syria tojoin and fight for, and at the direction of, ISIL.

2. On October 15, 2004, the United States Secretary of State designated al-Qa'ida in Iraq,

then known as Jam'at al Tawhid wa'al-Jihad, as a Foreign Terrorist Organization under Section

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Farrokh Statement of Facts.pdf

with Mahmoud Amin Elhassan to provide and attempt to provide material support andresources,. as that term is defined in Title 18, United StatesCode, Section ...
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