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Page:Affidavit against Ehsanul Sadequee.pdf/7

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15. During these interviews, AHMED repeatedly confirmed that he and SADEQUEE traveled together.[1] Moreover, AHMED reinforced the point that he and SADEQUEE did not stay with SADEQUEE's aunt; rather, they stayed with an individual with whom they were conspiring concerning the travel to terrorist camps and the plots against civilian and military installations in the United States.

MATERIALITY

16. The recent interviews with AHMED demonstrate that the trip to Canada was for terrorism-related planning and coordination. SADEQUEE, rather than choosing to remain silent, lied to federal agents about two material aspects of his trip to Canada: who his traveling companion was and where they stayed. Both of these facts, had they not been untruthfully withheld, would have assisted the Government in its ongoing terrorism investigation.

CONCLUSION

17. I submit that the above information establishes probable cause to believe that Ehsanul Islam SADEQUEE has committed a violation of 18 U.S.C. § 1001, in that he has made materially false statements in connection with an ongoing federal terrorism investigation, a matter within the jurisdiction of the


  1. SADEQUEE's sister has also confirmed that he traveled to Canada with AHMED. In November, 2005, SADEQUEE's sister spoke with AHMED and, during the course of the conversation, which was monitored by court-authorized electronic surveillance, stated "Shifa is traveling back and forth. You guys visited Toronto together."