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IN OPEN COURT

JUN 2 2 2012
IN THE UNITED STATES DISTRICT COURT FOR THE
EASTERN DISTRICT OF VIRGINIA
Alexandria Division
CLERK, U.S. DISTRICT COURT
ALEXANDRIA. VIRGINIA

UNITED STATES OF AMERICA

) )

v.
AMINE MOHAMED EL-KHALIFI,

) CRIMINALNO. l:12-CR-37
) ) ) )

Defendant.

STATEMENT OF FACTS

Were this matter to go to trial, the United States of America would prove the following
facts beyond a reasonable doubt:
1. From on or about December 1, 2011, and continuing through on or about February

17,2012, in the Eastern District of Virginia and elsewhere, defendant AMINE MOHAMED EL-

KHALIFI did knowingly and unlawfully attempt touse a weapon of mass destruction, that is,a
destructive device consisting of an improvised explosive device, against property that is owned

andusedby the United States, namely the United States Capitol Building, in Washington, D.C.,

and against persons andproperty within the United States, and a facility of interstate commerce
was used in furtherance of the offense, the property is used in interstate and foreign commerce

and in an activity that affects interstate and foreign commerce, a perpetrator traveled in interstate
commerce in furtherance of the offense, and the results of the offense would have affected interstate and foreign commerce.

In order to attempt to use a weapon of mass destruction against the United States Capitol Building, EL-KHALIFItook the following actions, among others:

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