The Grand Jury further charges:

          94. From at least in or about October 2000 through in

or about early November 2000, in the Southern District of New

York, MAMDOUH MAHMUD SALIM, a/k/a "Abu Hajer al Iraqi," a/k/a

"Abu Hajer," the defendant, who is not a national of the United

States, together with others known and unknown to the Grand Jury,

unlawfully, willfully, and knowingly combined, conspired,

confederated and agreed together and with each other to seize and

detain, and threaten to kill, to injure, and to continue to

detain other persons in order to compel third persons and

governmental organizations to do and abstain from doing acts as

an explicit and implicit condition for the release of the persons

detained, to wit, MAMDOUH MAHMUD SALIM, the defendant, conspired

with others to take hostages (including correction officers,

other prison officials, attorneys, and other civilians) in the

Metropolitan Correctional Center, in New York, New York, in order

to compel the release of persons confined by the Bureau of

Prisons in the United States.

          95. In furtherance of the conspiracy and to effect the

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illegal objects thereof, the following overt acts, among others,

were committed in the Southern District of New York:

               a. On or before November 1, 2000, MAMDOUH MAHMOUD

SALIM, the defendant, possessed in his cell on the high security

wing of the Metropolitan Correctional Center a note containing

entries including "Dividing the work of hunting," "Preparation,"

and "Attack."

               b. On or before November 1, 2000, MAMDOUH MAHMOUD

SALIM, the defendant, possessed in his cell on the high security

wing of the Metropolitan Correctional Center a note containing

entries including "The guard," "Taking things from the room (...,

the knives, the paper for the window)," and "Quick arming the

electricity."

               c. On or before November 1, 2000, MAMDOUH MAHMOUD

SALIM, the defendant, possessed in his cell on the high security

wing of the Metropolitan Correctional Center a note containing

entries including "Handling and identifying the keys," "The video

and stopping it," "Electricity and its layout," and "Luring the

hunt and opening the door for him."

               d. On or before November 1, 2000, MAMDOUH MAHMOUD

SALIM, the defendant, possessed in his cell on the high security

wing at the Metropolitan Correctional Center a note stating, in

part, "we have captured the tenth flr. in the MCC and we have

several lawyers and officials," and further stating that "[i]f

the government worrys (sic) about the safty (sic) of its

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citizines (sic) it has to comply with all our demands, otherwise,

it will be responsible for any consequences."

               e. On or about November 1, 2000, at

approximately 10:15 a.m., MAMDOUH MAHMUD SALIM, the defendant,

agreed to meet, and did meet with, his attorneys in a room on

Unit 10 South of the Metropolitan Correctional Center.

          f. On or about November 1, 2000, at approximately

10:30 a.m., MAMDOUH MAHMUD SALIM, the defendant, asked a

corrections officer (hereafter "Corrections Officer One") to

allow SALIM to return to his cell at the Metropolitan

Correctional Center for the stated purpose of obtaining

additional legal materials.

          g. On or about November 1, 2000, at approximately

10:35 a.m., Corrections Officer One was assaulted, placed in

handcuffs, and stabbed in the eye with a makeshift knife,

fashioned by sharpening a comb obtained from the prison

commissary, in or near the cell occupied by the defendant MAMDOUH

MAHMUD SALIM and another person known to the Grand Jury, named as

a coconspirator but not as a defendant herein.

          h. On or about November 1, 2000, the keys to

certain doors on the 10 South high security unit of the

Metropolitan Correctional Center were taken by force from

Corrections Officer One.

          i. On or about November 1, 2000, the electrical

junction box located immediately outside the cell shared by

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MAMDOUH MAHMUD SALIM and another person known to the Grand Jury

on the 10 South high security unit of the Metropolitan

Correctional Center was tampered with.

          j. On or about November 1, 2000, the lens of the

surveillance camera located inside the cell shared by MAMDOUH

MAHMUD SALIM and another person known to the Grand Jury on the 10

South high security unit of the Metropolitan Correctional Center

was blocked.

          k. On or about November 1, MAMDOUH MAHMUD SALIM,

the defendant, and another person known to the Grand Jury, each

assaulted corrections officers responding to the aid of

Corrections Officer One who had been stabbed in the eye, by

spraying the responding officers with irritants consisting of

liquids obtained as food items.

          l. On or about November 1, 2000, MAMDOUH MAHMUD

SALIM, the defendant, attacked various of the responding

corrections officers with his fists and stabbed one of the

responding officers with another improvised weapon.

(Title 18, United States Code, Section 1203(a).)
 
 

          The Grand Jury further charges:

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          96. On or about November 1, 2000, in the Southern
 

District of New York, MAMDOUH MAHMUD SALIM, a/k/a "Abu Hajer al

Iraqi," a/k/a "Abu Hajer," the defendant, who is not a national

of the United States, and at least one other person known to the

Grand Jury, unlawfully, willfully, and knowingly attempted to

seize and detain and threaten to kill, to injure, and to continue

to detain another person in order to compel third persons and

governmental organizations to do and abstain from doing acts as a

condition for the release of the person detained, to wit, MAMDOUH

MAHMUD SALIM, the defendant, and another person known to the

Grand Jury attempted to take hostages at the Metropolitan

Correctional Center, in New York, New York.

(Title 18, United States Code, Sections 1203(a) and 2.)

          The Grand Jury further charges:

          97. From at least in or about October 2000 through in

or about early November 2000, in the Southern District of New

York, MAMDOUH MAHMUD SALIM, a/k/a "Abu Hajer al Iraqi," a/k/a

"Abu Hajer," the defendant, together with others known and

unknown to the Grand Jury, unlawfully, willfully, and knowingly

combined, conspired, confederated and agreed together and with

each other to violate the laws of the United States relating to

homicide.

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          98. It was a part and an object of the conspiracy that

MAMDOUH MAHMUD SALIM, the defendant, together with others known

and unknown to the Grand Jury, as part of an effort to take

hostages to compel the release of persons detained in United

States detention facilities, would and did agree to kill and

attempted to kill officers and employees of the United States and

of agencies of the United States Government while such officers

and employees were engaged in, and on account of, the performance

of official duties, as was necessary in order to carry out their

hostage-taking plan, in violation of Title 18, United States

Code, Section 1114.

          99. In furtherance of said conspiracy, and to effect

the objects thereof, MAMDOUH SALIM, a/k/a "Abu Hajer al Iraqi,"

a/k/a "Abu Hajer," the defendant, and others known and unknown to

the Grand Jury, committed the overt acts set forth in Count Three

Hundred Nine of this Indictment, which are fully incorporated by

reference herein.

          The Grand Jury further charges:

         100. On or about November 1, 2000, in the Southern

District of New York, MAMDOUH MAHMUD SALIM, a/k/a "Abu Hajer al

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Iraqi," a/k/a "Abu Hajer," the defendant, and another person

known to the Grand Jury, named as a co-conspirator but not as a

defendant herein, unlawfully, willfully, and knowingly attempted

to commit the murder, as that term is defined in Title 18, United

States Code, Section 1111(a), of an officer and employee of the

United States and an agency of the United States Government while

such officer and employee was engaged in and on account of the

performance of official duties, to wit, MAMDOUH MAHMUD SALIM, the

defendant, and another person known to the Grand Jury attempted

to kill Corrections Officer One at the Metropolitan Correctional

Center, in New York, New York, by stabbing him in the eye with a

sharpened comb and by forcibly resisting other corrections

officers who came to his aid.

(Title 18, United States Code, Sections 1114, 1114(1), and 2.)

          The Grand Jury further charges:

          101. On or about November 1, 2000, in the Southern

District of New York, MAMDOUH MAHMUD SALIM, a/k/a "Abu Hajer al

Iraqi," a/k/a "Abu Hajer," the defendant, and another person

known to the Grand Jury, unlawfully, willfully, and knowingly did

forcibly assault, resist, oppose, impede, intimidate, and

interfere with an officer and employee of the United States and

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an agency of the United States Government while engaged in and on

account of the performance of official duties, and, in the

commission of such acts, did use a deadly and dangerous weapon

and inflict bodily injury, to wit, MAMDOUH MAHMUD SALIM, the

defendant, and another person known to the Grand Jury worked

together to stab Corrections Officer One at the Metropolitan

Correctional Center, in New York, New York, with a knife

fashioned from a sharpened comb.

          The Grand Jury further charges:

          102. On or about November 1, 2000, in the Southern

District of New York, MAMDOUH MAHMUD SALIM, a/k/a "Abu Hajer al

Iraqi," a/k/a "Abu Hajer," the defendant, unlawfully, willfully,

and knowingly did forcibly assault, resist, oppose, impede,

intimidate, and interfere with officers and employees of the

United States and an agency of the United States Government while

engaged in and on account of the performance of official duties,

and, in the commission of such acts, did use a deadly and

dangerous weapon and inflict bodily injury on the corrections

officers, to wit, MAMDOUH MAHMUD SALIM, the defendant, after

Corrections Officer One was stabbed in the eye with a sharpened

comb at the Metropolitan Correctional Center, in New York, New

York, stabbed with a weapon made from a sharpened brush a

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corrections officer known to the Grand Jury ("Corrections Officer

Two") who responded to the scene of the earlier stabbing.

          The Grand Jury further charges:

          103. From at least in or about October 2000 through in

or about early November 2000, in the Southern District of New

York, MAMDOUH MAHMUD SALIM, a/k/a "Abu Hajer al Iraqi," a/k/a

"Abu Hajer," the defendant, together with others known and

unknown to the Grand Jury, unlawfully, willfully, and knowingly

combined, conspired, confederated and agreed together and with

each other to commit an offense against the United States in

violation of Title 18, United States Code, Section 751(a).

          104. It was a part and an object of the conspiracy that

the defendant and others would and did attempt to escape from the

custody of the Attorney General and her authorized

representatives, and from custody under and by virtue of process

issued under the laws of the United States by a court and judge,

to wit, MAMDOUH MAHMUD SALIM, the defendant, who was charged

with, among other things, the felony offense of conspiring to

kill United States nationals and who was detained pursuant to

Court order pending trial of that and other offenses, and others

would and did attempt to escape from the Metropolitan

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Correctional Center, in New York, New York.

          105. In furtherance of said conspiracy, and to effect

the objects thereof, MAMDOUH SALIM, a/k/a "Abu Hajer al Iraqi,"

a/k/a "Abu Hajer," the defendant, and others known and unknown to

the Grand Jury, committed the overt acts set forth in Count Three

Hundred Nine of this Indictment, which are fully incorporated by

reference herein.

          The Grand Jury further charges:

          106. On or about November 1, 2000, in the Southern

District of New York, MAMDOUH MAHMUD SALIM, a/k/a "Abu Hajer al

Iraqi," a/k/a "Abu Hajer," the defendant, and another person

known to the Grand Jury, named as a co-conspirator but not as a

defendant herein, unlawfully, willfully, and knowingly attempted

to escape from the custody of the Attorney General and her

authorized representatives, and from custody under and by virtue

of process issued under the laws of the United States by a court

and judge, to wit, MAMDOUH MAHMUD SALIM, the defendant, and

another person known to the Grand Jury, who were both charged

with, among other things, the felony offense of conspiring to

kill United States nationals and who were detained pursuant to

Court order pending trial of that and other offenses, attempted

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to escape from the Metropolitan Correctional Center, in New York,

New York.

          The Grand Jury further charges:

          107. On or about November 1, 2000, in the Southern

District of New York, MAMDOUH MAHMUD SALIM, a/k/a "Abu Hajer al

Iraqi," a/k/a "Abu Hajer," the defendant, and another person

known to the Grand Jury, being inmates of a prison, as that term

is defined in Title 18, United States Code, Section 1791(d)(4),

unlawfully, willfully, and knowingly made, possessed and

obtained, and attempted to make, possess and obtain, a prohibited

object, to wit, a weapon and an item designed to be used as a

weapon, as that term is defined in Title 18, United States Code,

Section 1791(d)(1)(B), to wit, MAMDOUH MAHMUD SALIM, the

defendant, and another person known to the Grand Jury made,

possessed and obtained a sharpened comb in the high security unit

at the Metropolitan Correctional Center, in New York, New York.

The Grand Jury further charges:

108. On or about November 1, 2000, in the Southern

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District of New York, MAMDOUH MAHMUD SALIM, a/k/a "Abu Hajer al

Iraqi," a/k/a "Abu Hajer," the defendant, being an inmate of a

prison, as that term is defined in Title 18, United States Code,

Section 1791(d)(4), unlawfully, willfully, and knowingly made,

possessed and obtained, and attempted to make, possess and

obtain, a prohibited object, to wit, a weapon and an item

designed to be used as a weapon, as that term is defined in Title

18, United States Code, Section 1791(d)(1)(B), to wit, MAMDOUH

MAHMUD SALIM, the defendant, made, possessed and obtained a

sharpened brush in the high security unit at the Metropolitan

Correctional Center, in New York, New York.

          The Grand Jury further charges:

          109. On or about November 6, 2000, in the Southern

District of New York, MAMDOUH MAHMUD SALIM, a/k/a "Abu Hajer al

Iraqi," a/k/a "Abu Hajer," the defendant, being an inmate of a

prison, as that term is defined in Title 18, United States Code,

Section 1791(d)(4), unlawfully, willfully, and knowingly made,

possessed and obtained, and attempted to make, possess and

obtain, a prohibited object, to wit, a weapon and an item

designed to be used as a weapon, as that term is defined in Title

18, United States Code, Section 1791(d)(1)(B), to wit, MAMDOUH

MAHMUD SALIM, the defendant, while detained in a hospital

facility for inmates, secreted and possessed a needle taken from

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an intravenous line that had been inserted in his arm for medical

treatment purposes.

(Title 18, United States Code, Sections 1791(a)(2) and 2.)
 
 
 
 
 
 
 

____________________           _________________________
FOREPERSON                     MARY JO WHITE
                               United States Attorney