* In approximately 1989, bin Laden and co-defendant Muhammad Atef founded
"Al Qaeda," " an international terrorist group ... which was dedicated to
opposing non-Islamic governments with force and violence."
* "One of the principal goals of Al Qaeda was to drive the United States
armed forces out of Saudi Arabia (and elsewhere on the Saudi Arabian peninsula)
and Somalia by violence."
* "Al Qaeda had a command and control structure which included a majlis
al shura (or consultation council) which discussed and approved major
undertakings, including terrorist operations." Both Atef and bin Laden sat on
* Al Qaeda had ties to other "terrorist organizations that operated under
its umbrella," including: the al Jihad group based in Egypt, the Islamic Group,
formerly led by Sheik Omar Abdel Rahman, and other jihad groups in other
countries. "Al Qaeda also forged alliances with the National Islamic Front in
Sudan and with representatives of the government of Iran, and its associated
terrorist group Hezballah, for the purpose of working together against their
perceived common enemies in the West, particularly the United States."
* The named defendants, plus other members of Al Qaeda, "conspired,
confederated and agreed to kill nationals of the United States." In furtherance
of this conspiracy,
* Bin Laden and others "provided training camps and guesthouses in various
areas, including Afghanistan, Pakistan, Somalia and Kenya for the use of Al
Qaeda and its affiliated groups,"
* Bin Laden and others provided currency and weapons to members of Al
Qaeda and associated terrorist groups in various countries throughout the
* Bin Laden established a headquarters for Al Qaeda in Khartoum, Sudan, in
1991, and established a series of businesses, including two investment
companies, an agricultural company, a construction business and a
transportation company, all of which were, "operated to provide income and
support to Al Qaeda and to provide cover for the procurement of explosives,
weapons and chemicals and for the travel of Al Qaeda operatives."
* Bin Laden issued a number of fatwahs (rulings on Islamic law) stating that US
forces stationed in Saudi Arabia, Yemen, and the Horn of Africa, including
Somalia, should be attacked.
* Al Qaeda members "provided military training and assistance to Somali tribes
opposed to the United Nations' intervention in Somalia. ... On October 3 and 4,
1993, in Mogadishu, Somalia, persons who had been trained by Al Qaeda (and
trainers who had been trained by Al Qaeda) participated in an attack on United
States military personnel serving in Somalia as part of Operation Restore Hope,
which attack resulted in the killing of 18 United States Army personnel.
* Bin Laden and others attempted to procure components of nuclear and chemical
Defendants bin Laden, Atef, Fazul Abdullah Mohammed, and Odeh, together with
other members of Al Qaeda "detonated an explosive device that damaged and
destroyed the United States Embassy in Nairobi, Kenya, and ... directly ..
caused the deaths of at least 213 persons, including Kenyan and American
Defendants bin Laden, Atef, Fazul Abdullah Mohammed, Odeh, al-'Owhali. Mustafa
Mohamed Fadhil, Khalfan Khamis Mohamed, Ahmed Khalfan Ghailani, Fahid Mohammed
Ally Msalam and Sheikh Ahmed Salim Swedan, together with other members of Al
Qaeda "detonated an explosive device that damaged and destroyed the United
States Embassy in Nairobi, Kenya, and ... directly .. caused the deaths of at
least 11 persons, including Tanzanian citizens."
In his interview with FRONTLINE, Saudi dissident Saad Al-Fagih challenges the U.S.
government's characterization of Al Qaeda.