AFFIDAVIT OF SPECIAL AGENT

I, J. Joseph Galietta, being duly sworn, depose and state as follows:

INTRODUCTION

1.

I am a Special Agent with the Federal Bureau of Investigation ("FBI"), and have

been so employed for approximately 9 years. From 2006 to October 2014, I was assigned to the
Maryland/Delaware Joint Terrorism Task Force. Since October 2014, I have been assigned to
Bostons Joint Terrorism Task Force, which is responsible for investigating offenses related to
international and domestic terrorism. Prior to my employment with the FBI, I was employed as a
police officer with Richmond Virginia Police Department for approximately 3 years.
2.

In my capacity as a Special Agent, I have received training and gained experience

in search and seizure, the use of confidential human sources, electronic and video surveillance,
international and domestic terrorism, drug offenses, violent crimes, computer crimes, money
laundering, fraud and various other crimes. As a result of my training and experience, I am
familiar with the tactics, methods and techniques of terrorist networks and their members,
including the use of computers, cell phones, social media, email, and the internet in connection
with criminal activity. I have executed numerous affidavits in support of federal search warrants
and criminal complaints and have participated in the execution of numerous search warrants.
3.

Along with other agents, I have been investigating Usaamah Abdullah Rahim

(RAHIM), who resided at 375 Blue Ledge Drive, Roslindale, Massachusetts, until his death at
approximately 7:00 a.m. yesterday morning, and David Wright a/k/a Dawud Sharif Wright a/k/a
Dawud Sharif Abdul Khaliq (WRIGHT), who resided at 208 Linden Street, Apt. 4, Everett,
Massachusetts for several federal criminal offenses, including terrorism offenses. I have
personally participated in this investigation. The information in this affidavit is based upon my

training and experience, my personal knowledge of this investigation, and information provided
to me by other agents and law enforcement officials who have assisted in this investigation and
have experience investigating international terrorism matters. All conversations and statements
described in this affidavit are related in substance and in part only unless otherwise indicated.
4.

As indicated below, there is probable cause to believe that, on or about June 2,

2015, WRIGHT did conspire with RAHIM to knowingly destroy, mutilate, conceal, and cover
up a tangible object, to wit, RAHIMs Smartphone, with intent to impede, obstruct, or influence
an investigation or the proper administration of any matter within the jurisdiction of any
department or agency of the United States, or in relation to or contemplation of any such matter
or case, in violation of 18 U.S.C. 1519, all in violation of 18 U.S.C. 371.
5.

This affidavit does not detail all of the facts known to me regarding this matter

but relates only those necessary to establish probable cause for issuance of the requested
complaint and arrest warrant.
RELEVANT LEGAL AUTHORITY
6.

Title 18, United States Code, Section 1519 makes it illegal for anyone to

knowingly alter, destroy, mutilate, conceal, or cover up a tangible object with the intent to
impede, obstruct, or influence the investigation or proper administration of any matter within the
jurisdiction of any department or agency of the United States or in relation to or contemplation of
any such matter or case. Title 18, United States Code, Section 371 prohibits conspiracies to
commit other federal offenses.

SUMMARY OF INVESTIGATION
7.

United States law enforcement agents, including members of the Boston FBIs

Joint Terrorism Task Force, have been investigating individuals located in the United States who
are providing, or are attempting to provide, material support to terrorism by planning or engaging
in violent attacks domestically.
8.

This investigation has revealed that, since on or before May 26, 2015, RAHIM, a

26-year-old private security officer, has been planning to engage in a violent attack in the United
States, which was confirmed during an interview of WRIGHT on June 2, 2015. RAHIM took
several steps in furtherance of this plan, including the purchase of three fighting knives and a
knife sharpener from Amazon.com, and discussed his plan with WRIGHT.
WHAT THE INVESTIGATION HAS DETERMINED
9.

Based upon records obtained from Amazon.com, on or about May 25, 2015,

RAHIM purchased an Ontario Spec Plus Marine Raider Bowie fighting knife (Marine fighting
knife) and a device used to sharpen knives. The Marine fighting knife Rahim purchased is 15
inches long when opened, contains a 9.75 blade, and weighs 22.4 ounces.
10.

On or about May 26, 2015, RAHIM called WRIGHT. During the call, which

was recorded:
a. RAHIM advised WRIGHT that I just got myself a nice little tool. You know
its good for carving wood and like, you know, carving sculptures . . . and you know . . .
WRIGHT and RAHIM then both began laughing. I believe that when RAHIM said nice little
tool that was good for carving, he was referring to the Marine Raider Bowie fighting knife
that he had purchased the previous day.
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b. In guarded language, RAHIM told WRIGHT about a plan, in which he was

involved, to kill a person outside of Massachusetts. RAHIM and WRIGHT discussed the
motivation for that planned attack.
c. Later in the conversation, WRIGHT told RAHIM something was like
thinking with your head on your chest. Both men then burst out laughing. Based upon my
training, experience, and involvement in this investigation, I believe this is a reference to the
practice of some foreign terrorist organizations to behead targets and place their heads on their
chests in propaganda videos.
11.

On or about May 27, 2015, before the Marine Fighting Knife was delivered, an

FBI Special Agent Bomb Technician intercepted the package and x-rayed it and determined it
contained a large knife and knife sharpener tool. Shortly thereafter, using video surveillance,
FBI agents watched as the package containing the knife and the sharpener was delivered to
RAHIMs address.
12.

Based upon records obtained from Amazon.com, on or about May 27, 2015,

RAHIM purchased a second Marine fighting knife and an Ontario Knife SP6 Spec Plus Fighting
Knife 8325 (SP6 Spec Plus Fighting Knife). The SP6 Spec Plus Fighting Knife Rahim
purchased is 13 inches long and has an eight inch blade. On Saturday, May 30, 2015, based
upon records from Amazon, these two knives were delivered to RAHIMs residence.
13.

On May 28, 2015, RAHIM sent a text message confirming with WRIGHT that

they would be meeting on Sunday, May 31, 2015 with a third person.
14.

On May 30, 2015, WRIGHT sent a text message to RAHIM indicating that he had

spoken with the third person and they had a lot to talk about.

15.

On Sunday, May 31, 2015, RAHIM, WRIGHT, and the third person met on a

beach in Rhode Island, in inclement weather, to discuss their plans. As described below,
WRIGHT later advised FBI agents that these plans included the beheading of the planned victim
in another state, as discussed above.
16.

At approximately 5:00 a.m. on June 2, 2015, RAHIM called WRIGHT and

advised him that he had changed his plans and no longer planned to commit an attack in another
state. Instead, he said that he was going to go after the boys in blue, which I believe to be a
reference to police officers. During this telephonic conversation, which was recorded, the
following statements, among other things, were made:
RAHIM:

And, ah, but I cant wait that long, I cant wait that long man.

***
WRIGHT:

Are you, are you trying to figure out where, are you trying to go to
[the other state]?

RAHIM:

No.

WRIGHT:

You are not, Im trying to understand, wait, you are not trying to
go to [the other state]?

RAHIM:

No.

***
WRIGHT:

Oh, oh wait a minute, oh ah, you are going to be, ah, youre
attempting to go on vacation I see.

RAHIM:

Yeah, Im going to be on vacation right here in

MassachusettsIm just going to ah go after them, those boys in
blue. Cause, ah, its the easiest target and, ah, the most common is
the easiest for me

Based upon my training, experience, and involvement in this case, I believe that going on
vacation, a phrase used repeatedly in conversations between WRIGHT and RAHIM, refers to
committing violent jihad.
17.

Additionally, during this conversation, RAHIM revealed to WRIGHT that he

planned to randomly kill police officers in Massachusetts either yesterday (June 2) or today (June
3). In response, WRIGHT advised him to prepare his will and leave his possessions to a
named individual.
18.

After discussing with RAHIM the plan to attack police officers, WRIGHT

directed RAHIM to delete information from, and destroy, his Smartphone and wipe his laptop
computer. Specifically, with regards to RAHIMs phone, WRIGHT instructed RAHIM:
WRIGHT:

[m]ake sure also, very important, make sure that, ah, at the
moment that you decide to that you ah, delete, you delete ah, from
your phone or you break it apart. Throw it down to the ground.

RAHIM:

Yup.

WRIGHT:

Get rid of it, before anybody gets it; make sure its completely
destroyed.

RAHIM:

I will.

WRIGHT:

Because, at the scene, at the scene ,CSI will be looking for that
particular thing and so dump it, get rid of that. At the time you are
going to do it, before you reach your destination you get rid of it.

Based upon my training, experience, and involvement in this investigation, I believe that CSI
refers to law enforcement, thus indicating WRIGHTs belief that law enforcement would be
conducting an investigation of RAHIMs actions. I believe that WRIGHTs reference to the fact
that law enforcement would be looking for that particular thing refers to some especially
sensitive information, document, or thing to be found on RAHIMs Smartphone. In addition,
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WRIGHT encouraged RAHIM to completely wipe out everything on his laptop computer to
its factory setting.
19.

Shortly after this conversation, on June 2, 2015, RAHIM was on a public street in

the Boston area, when he was approached by Boston Police Officers and FBI special agents.
RAHIM took out one of the knives he had purchased from Amazon.com when he saw the
officers and agents. One of the officers told RAHIM to drop his weapon and RAHIM responded,
you drop yours. RAHIM then moved towards the officers while brandishing his weapon, and
he was shot by law enforcement.
20.

On June 2, 2015, agents of the FBI interviewed WRIGHT shortly after RAHIM

was shot. The agents advised WRIGHT of his Miranda rights. WRIGHT waived his rights and
agreed to speak with the agents. During this interview, the agents asked WRIGHT about what
had transpired at the Sunday meeting on the beach in Rhode Island. According to WRIGHT, at
that meeting, RAHIM told WRIGHT and the third person that he was going to behead the
intended victim in another state. WRIGHT indicated that he agreed with RAHIMs plan and
supported it.

CONCLUSION
21.

Based on the information described herein, I have probable cause to believe, and

do in fact believe that on or about June 2, 2015, WRIGHT did conspire with RAHIM to
knowingly destroy, mutilate, conceal, and cover up a tangible object, to wit, RAHIMs
Smartphone, with intent to impede, obstruct, or influence an investigation or the proper
administration of any matter within the jurisdiction of any department or agency of the United
States, or in relation to or contemplation of any such matter or case, in violation of 18 U.S.C.
1519, all in violation of 18 U.S.C. 371.

___________________________
J. Joseph Galietta
Special Agent
Federal Bureau of Investigation

Sworn and subscribed before me this

3rd

day of June 2015.

_____________________________
M. PAGE KELLEY
UNITED STATES MAGISTRATE JUDGE