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EXHIBIT 2
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UNCLASSIFIED
0.
* FEDERAl.. BUREAU OF INVESTIGATION
* POLICY DIRECTIVE
0012D
1 Policy Directive Title FBI Information Sharing Activities with Other Government Agencies
2. Publication Date. 1-
20O80402
3, Effective Date. 2008-0402
4, Review Date. 20180402 -
S. Date of Last Renewal.
6. Authorities:
6.1. This policy is created under the authority of the Information Sharing Policy Board (ISPB), which has
primary authority within the Federal Bureau of Investigation (FBI) to develop policy direction for
information and intelligence sharing. This policy can only be rescinded or modified by the Director of the
FBI, the Director's designee, or the ISPB. It must be modified as required by other FBI policy
requirements, regulations, Attorney General's Guidelines, other Department of Justice (DO)) policy, or
Directives from the Office of the Director of National Intelligence (ODNI).
6.2. The FBI has the legal responsibility and authority to share terrorism information with Federal, state,
focal, tribal, and foreign partners as required by the Intelligence Reform and Terrorism Prevention Act of
2004 (IRTPA) and related executive orders. The FBI has the legal responsibility and authority to share
terrorism, foreign intelligence and counterintelligence information with agencies having national security
responsibilities, as required by the USA PATRIOT Act of 2001 and related procedures approved by the
Attorney General. The FBI has the legal responsibility and authority to share Terrorist Information as
required by Homeland Security Presidential Directive (HSPD)-6, The FBI has the legal responsibility and
authority to share crime information, including information from criminal investigations, with Federal,
state, local, tribal and foreign law enforcement agencies, as required by Title 28 United States Code
(U.S.C.) Section () 533 and 28 U.S.C. § 534, subject to the limitations imposed by Title 28 Code of
Federal Regulations (CFR) Part .16.
6.3. The FBI has the legal responsibility to share terrorism and criminal information in a manner that
protects the information privacy and other legal rights of Americans and is consistent with the Privacy Act
of 1974 (Privacy Act), Section 1016(i) of !RTPA, Executive Order (EO) 13388, and the Presidential
Memorandum of December 16, 2005, concerning Guideline 5 of the information Sharing Environment
(ISE Guideline 5) The FBI has the legal responsibility to comply with the privacy requirements of the
Privacy Act, E-Government Act of 2002, and the Federal Information Security Management Act of 2002
(FISMA), as required by DO) Order 30I1-1A.
6.4. The FBI has the legal responsibility to conduct Privacy Impact Assessments (PIAs), as required by
Section 208 of the E-Government Act of 2002, and in accordance with OMB guidance, OMB-0322
(September 26, 2003), and the DO) guidance, "Privacy Impact Assessments Official Guidance"
published on April 18, 2006.
7. Purpose:
This policy establishes standard and uniform requirements for assessing information sharing activities
with Other Government Agencies (OGAs) on a common basis, so the risks and benefits of the sharing are
clearly understood. This policy establishes a system whereby Information sharing activities with OGAs are
,centrally recorded.
8. Policy Statement:
:8.1. The FBI will share substantive investigative and intelligence information with OGAs in a manner that
is consistent with law, Executive Orders, DO) Policy, QONI Directives, mission justification, and the lawful
authority of the requeser. The FBI will share information with due regard for the security of operations
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and the protection of sources and methods, in a manner that protects the privacy and civil liberties of US
persons.
8.2. This policy establishes and governs the processes and responsibilities for the review of information
sharing activities with OGAs. Information sharing activities are subject to this policy if they:
8.2.1. Are continuous, or
8.2.2. Access large quantities of FBI internal data, or
8.2.3. Access FBI systems, applications, networks or services, or
8,2.4. Require review and approval of the information assurance governance at the FBI or the OGA, or
8.2.5. Might expose sensitive FBI information, operations., sources or methods.
8.3. All information sharing activities governed by this policy should undergo an information sharing
assessment. The assessment would result in assigning a risk level of high, medium, or low to the activity.
Approval authority for the activity is contingent upon this level of risk.
8.4. All high risk proposals would include a plan for risk mitiaation, control, and appropriate monitoring or
auditing that clearly identifies necessary resources, actions and the associated FBI roles, responsibilities
and authorities for each action, prior to final approval of the activity. (For example, if the plan requires
that extraction of particular information from an FBI database be supervised by the FBI, it must specify
the responsible FBI role and level of supervision.)
83+ Medium risk proposals may include a plan for risk mitigation, control, and appropriate monitoring or
auditing that clearly identifies necessary resources, actions and the associated FBI roles, responsibilities
and authorities for each action, prior to final approval.
8.6. Low risk proposals would not require a risk mitigation and control plan prior to final approval.
8.7. A written governing document, such as an FBI Policy Directive, Interconnection Security Agreement
(ISA), or Memorandum of Understanding (MOU), must be created to control each information sharing
activity. A Privacy Threshold Analysis and Privacy Impact Assessment must be performed or updated as
'necessary in accordance with FBI policy currently described in the Privacy Policy Guide, 0299P6.
8.8. Risk assessments and mitigation plans should be periodically reviewed (at least annually for high risk
activities) during the lifetime of all information sharing activities governed by this policy. Changes in the
risk level should initiate appropriate changes in such documents.
8.9. All information sharing activities, systems, and programs governed by this policy should be
catalogued in a central database containing the initial sharing proposal, a completed initial risk
assessment, all decisions made in regard to the proposed sharing activity, any required risk mitigation
plan, and all modifications of the risk assessment and risk mitigation plan.
8.10. In all information sharing activities governed by this policy, the FBI, through the ISPB, reserves the
right to suspend information sharing without consultation with the partner OGA when such sharing may
jeopardize the mission of the FBI, threaten to reveal protected sources and methods, in the event of a
violation by the OGA of the terms of its information sharing activity agreement or for other reasons solely
within the discretion of the FBI. The ISPB can terminate or reinstate all or some of the suspended
information sharing activities with or without changes to documents controlling that activity.
8.11. To the extent permitted by law and policy, the FBI will retain responsibility for compliance with
Freedom of Information Act and Privacy Act requests, civil and criminal discovery, and other attempts by
third parties to compel production of the information shared with OGAs pursuant to this policy. Unless
authorized by the FBI to share FBI information with third parties, OGAs in possession of FBI information
under this policy who receive third party requests or demands for the information will refer the requests
or demands to the FBI. This understanding should be reflected in the written governing documents
controlling the information sharing activity.
9. Scope;
This policy applies to all FBI programs and activities engaged in a process of information sharing with
OGAs, including the sharing of terrorism information through the ISE, except as specifically exempted
below.
10. Proponent:
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Office of Chief Information Officer
11. Roles and Responsibilities:

11.1. ISPB must:
11.I.1. Review and approve or reject changes to this policy;
11.1.2. Review and approve or reject all high risk information sharing proposals;
1 1.1.3. Review authorization for medium risk information sharing activities each quarter;
11.1.4. Review all issues of aggregate information sharing risk brought to the ISPB; and
11.2. ISPB, or its designee, must:
11.2.1. Manage the information sharing process defined in this policy, including development and
modification of forms, database, and reports, as necessary;
11.2.2. Perform a quarterly review of the information sharing database, specifically for issues of
aggregate risk;
11.2.3. Coordinate new policy development with the internal Policy Office (IPO);
11.2.4. Coordinate appropriate information sharing activities with the Life Cycle Management (LCM)
Framework;
11.2.5. Assist each FBI sponsor in performing detailed risk assessments for all approved high risk
proposals, and for medium risk proposals as requested by Division Heads; and
11.2.6. Assist each FBI sponsor in developing a plan for risk mitigation, control and monitoring for all
approved high risk proposals, and for medium risk proposals as requested by Division Heads.
11.3, Division Heads must:
11.3.1. Review and approve or reject all medium risk information sharing proposals;
11.3.2. Review and approve or reject all low risk information sharing proposals, or delegate such
authority to a staff member, who must hold a position no lower than section chief (SC) or assistant
special agent in charge (ASAC).
11.3.3. Notify the 1SP8 of decisions on all low and medium risk information sharing proposals;
11.3.4. Request the ISPB to develop a risk mitigation strategy for appropriate medium risk proposals;
11.3.5. Designate an FBI sponsor for the information activity who should complete the information
sharing risk assessment, and, when required, a detailed risk assessment and risk mitigation and control
plan; and
11.3.6. Ensure that the FBI sponsor prepares a PIA as appropriate, that the PIA is reviewed and approved
within the division, and forwarded for final review and approval in accordance with FBI and DO) policy.
11.4. Security Division must:
11.4.1. Ensure that all information sharing activities governed by thi s policy are in compliance with the
requirements of the FBI's Certification and Accreditation Handbook.
11.4.2. Ensure that all appropriate information sharing activities governed by this policy include the
appropriate Information System Security Manager (ISSM).
11.5. IPO must:
11.5.1. Coordinate with the ISPB, or its designee, on all new information sharing policy developed as a
result of this policy, per the established policy development and approval process.
11.6. FBI Privacy and Civil Liberties Officer must:
11.6.1. Review information sharing activities to ensure compliance with privacy laws and regulations, and
ISE guidelines; and
11.6.2. Review policy documents controlling information sharing activities to ensure compliance with
privacy laws and regulations, and ISE guidelines.
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12. Exemptions:
12.1 Current FBI information sharing programs or activities are exempt from the risk assessment and
risk mitigation requirements (sections 6.3-6.5) of this policy if-
f:
12.1. 1. They are already ongoing prior to the effective date of this policy; and
12.1.1.
12.1.2. They are explicitly designed for the purpose of sharing information outside the F81; and
12.1.3. They already have explicit policy associated with the process of information sharing that
incorporates appropriate privacy and civil liberties protections.
12.1.4. An example of such a program is the Integrated Automated Fingerprint Identification System
(IAFIS) operated by Criminal Justice Information Services Division (01S). This exemption is void if the
purpose or scope of the sharing activity, or the FBI information source, is different from the specifications
of the controlling policy. This exemption does not pertain to the requirement to document all information
sharing activities in a central database (section 6.6).
12.2. Also exempted from the requirements of this policy is dissemination of information through
activities that are discrete, share limited data, do not require system access by an employee of an OGA,
protect sensitive information in accordance with established FBI dissemination requirements, and are
conducted in accordance with clearly established information sharing governance authorities at both the
FBI and the OGA. An example of such activity is the sharing of the results of an interview with a state or
local police representative engaged in a criminal investigation.
12.3. Dissemination of intelligence products specifically prepared for dissemination is exempted from the
requirements of this policy. Examples of this are Intelligence Bulletins, Intelligence Assessments, and
Intelligence Information Reports (liRs). Notwithstanding this exemption, the sharing of intelligence
products must still comply with ISE Guideline 5.
12.4. Access to FBI data or systems by detailees including task force members from OGAs operating
under the supervision of an FBI employee is exempted from the requirements of this policy, if there are
clearly established requirements for FBI approval of transmission of information to the home agency of
the detailee or task force member.
12.5. Information sharing activities related to human resource, personnel, and FBI administrative
activities are not covered by this policy.
13. Supersession:
None
14. References, Links, and Forms:

i4.1. References
14.1.1. Intelligence Reform and Terrorism Prevention Act of 2004
14.1.2. USA PATRIOT Act of 2001, amended in 2005
14.1.3. Privacy Act of 1974
14.1.4. HSPD-6
14.1.5. information Sharing Environment
14.1.5.1. ISE Guideline S
14.1.5.2. FBI Electronic Communication (EC) 319W-HQ-A1487699. serial 660, Updated guidance for
.Privacy Impact Assessments, etc.
14.1.6. FBI Life Cycle Methodology Framework
14.2. Links
14.2.1. None
14.3. Forms
.14.3.1.
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14.3.2. 'information Shanna Detailed Risk Assessment and CntroI fn Form
15. Key Words, Definitions, and Acronyms:

15.1. Key Words
15.1.1. Information Sharing
15.1.2. Information Dissemination
15.1.3. Information Access
15.1.4. Other Government Agencies
15.1.5. Risk assessment
15.1.6. Terrorism Information
15.1.7. Privacy Impact Assessment
15.2. Definitions
15.2.1. Aggregate information sharing risk: The possibility of an adverse event occurring, when
considering the total cumulative risk across all information sharing activities.
15.2.2. Continuous: Any information sharing activity that is not discrete.
15.2.3. Discrete: An information sharing activity where each request is specifically approved, operates
with a fixed start and end time period, and Is distinct and independent from any other information sharing
activity.
15.2.4. Division Head: Assistant Director of the division, or ADIC/SAC of a field office, that will manage
the information sharing activity.
15.2.5. FBI Sponsor: Primary FBI point of contact for the proposed information sharing activity.
15.2.6. Governance authority: A party explicitly responsible for managing Information assurance
practices, including security of and access to systems and data.
152.7. Information sharing activity: Any action that results in or allows:
15.2.7.1. Dissemination of investigative or Intelligence information or data outside the FBI; or
15.2.7.2. Access to an FBI system or database containing raw (not reviewed by an FBI employee)
information or data; or
15.2.7.3. Access to an FBI system or database containing information or data reviewed by an FBI
employee with regard to the sensitivity of the contents of the system or database.
15.2.8. Information sharing risk: The possibility that FBI investigative or intelligence information will be
improperly used by an OGA, and the severity of the consequences of any such misuse that does occur
15.2.9. Life Cycle Management (LCM) Framework: The current and all future policy documents governing
the FBis development of Information Technology (IT) products and services.
15.2.10. OGA: The agency or organization with whom the FBI is considering sharing information.,
including both the exchange of data and access to FBI systems. This includes other Federal Agencies, US
Regional, State, Local or Tribal governments or their representatives, and foreign law enforcement and
intelligence services.
15.2.11. Risk Mitigation Plan: A statement of how the risks associated with a particular information
sharing activity will be prevented, corrected, or managed. It must identify required resources, responsible
roles, activities and dates for each action.
15.3. Acronyms
15.3.1. ASAC: assistant special agent in charge
15.3.2. CFR: Code of Federal Regulations
15.3.3, CJIS: Criminal Justice Information Services Division
15.3.4. DO): Department of Justice
15.3.5. EC: electronic communication
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1536 EO: executive order

15.37. FBI: Federal Bureau of Investigation
15.38,, FISMA: Federal Information Security Management Act of 2002
15.3.9. HSPD: Homeland Security Presidential Directive
15.3.10. IAF1S: Integrated Automated Fingerprint Identification System
15.3.11. 11R..intelligence information report
13.3. 12. IPO: Internal Policy Office
15.3.13. IRTPA: Intelligence Reform and Terrorism Prevention Act of 2004
15.3.14. ISE: Information Sharing Environment
15.3.15. ISM, Information Sharing Policy Board
15.3.16. ISSM: Information System Security Manager
15.3.17. LCM: Life Cycle Management
15.3.18. NA: Privacy Impact Assessment
15.3.19. ODNI: Office of the Director of National Intelligence
15.3.20 OGA: other government agency
15.3.21 SC: section chief
15.3.22. U.S.C.: United States Code
16. Appendices and Attachments:

None
Iinal Approval.
hur ft Cummn.s
Title xecutive Assistant Director-NSE
UNCLASSIFIED
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EX
],ibit C
Order from Unit-e.d States V.

K-areem, 2:15-CR-707 (Ii
A. Jan. 23, 20,17) (Dkt* #
469)
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A.
IN THELINITEI) STATES DISTRICT COLTRT

7 FOR Till DISTRICT OF ARIZONA
() ( iii lied Slates of America, No. ('R 15-00707-001 PI IXSI

10 114,lint ill'. ANJENI)li) ORI)IR
11
12 Abdul MauL Abdul Karceni.
I )etIn(ant.
14
At issue are 1)e6endant's Motion flr Judgmcnt ol' Acquittal i I's
( ("MJA") (Doe. 302) and Delendani 's Motion lr Ncv 'Irial Rased on Prusecutorial
17 Misciidt (*"MN'l (Doe. 303). Ihe Court heard oral argument on the Motions on JUI
18 22. 2016. (Doe. 378. Minute intrv) The Court took the Motions under advisement
19 pending 1)elindant's supplemental brkling. (Id: see I )ocs. 384. 410. 423.) the
supplemental briefing was conipktcd on l)eeeuther lb. 2() 16. (Sec Doe. 432. SuppL Ur.
III Supp. of MN] ("Supp. MN'I"): Doc. 44 1. Resp. to Snpp. MNT: Doc. 452. Reply
22 Supp. MNF.)
I. HA(:K;ROuND
Plaintiff VaS indicted on live counts: knowingly and intentionally conspiri1g lo
25 transport firearms and ammunition in interstate commerce with the intent In commit
i mprisonment exceeding one year in violation ni 1 8 I JSC,
etimes punishable by
27 924(h) wacts in lutihetanu. thcieol in iolation of 18 U.S.0

iiIi ol 71 Wount I
2.8 knoving1) and intentional iv transporting firearms and ammunition

in interstate
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. oi . .1
commerce with the intent to commit crimes punishable b impriso

nment exceeding one
year. in violation of 18 LLSC.§ 924(h) (Count 2): knoinglv and MINUM makin' filse.
frauduknt. and lktitious materia.i statements and representations to the 1:cdenil 13111-Callof
Investigation (1131"'). In aioknion ()f 18 U.S.C. I001a(2) (Count 3): having been
convicted ol'a crime punishable by imprisonment br a term exceeding a year. knowingl
posSessing. in and alThciin interstate commerce. lirearms. in violation of 18 U.S.0
92.2(g)(1) (Count 4): and koo ingly and intentionall conspiring to provide "inateilal
41
support or resources" to a Ibreign terrorist organization (Count 5). (one. 158. Second
Superseding Indictment.) 1)e1ndants charges arose lioni his afleged aid ()I* I dma
Simpson and Nadir Snofi in their planning and preparation lbr the Garland. Texas attacic
A jury trial 1:eht.t1,I\ 16. 2016 and concluded on March 17. '10 16. (Does. 209 &
276. Minute Fntries.) The i t,,- \. returned verdicts of guilty on all live counts. (Doc. 285.
Jury Verdict.) On March 3 1 . 2016. I)elndant moved lbr acquittal and a new trial based
on prosecutorial misconduct. (See ,teflcqyj//i' MNT and MJA.) ()n Ju1 22. 2016. the Court
heard oral argument on the Motions and took the matters under advisement because
Defendant argued that he would need to supplement his bricls pending additional
disclosures by the Government, (Doe. 378. Minute k'ntrv: one. 383. Mot. to Delay
Ruling on MN] and on Sentencing.) The ('otirt now considers the I )elindant's Motions.
IL LE(;AL STANDARD AND ANALYSIS
Pursuant to the Supreme Court's holding in Ifrar lka-rlantl 373 1 .5. 83. 87.
r4
(1963). prosecutors arc constitutionally oblivaied to disclose evidence t arivorab1e to an
accused that is material either to guilt or to punishment. Kites v. 'Uniter. 514 U.S. 419.
432 (1995): .Jonex t'. Rrwi. 733 F.3d 825. 837 (9th ('ir.2013).
4 'l'o establish a 1) 1. violation, a defendant must show thin: 1) the
evidence at issue IA Iitvorahle to the accused. either because it is
25 exculpatory or because it is impcachin: (2) the evidence was suppressed
by the government, regardless of whether the suppression was illilil or
The Garland Texas attack ("Garland attack") was an attempted attack on a

Prophet Muhammad drawing contest held in Garland. 'Fexas on May 3. 201 5. wherein
Simpson and Sooli were shot and killed hef'ore enterint44,the center where the Contest Was
beine held.
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inadvertent' and (3) the evidence is material to the guilt or innocence of the
defendant.
UniteciSiules r. Seckiglzaii'. 728 1'. "d 885. 899 (901 ( ii'. 2013). Evidence is 1norahk
the accused for !irtidt' purposes
'S
it is either exculpatory or impeaching. Sirie.Ier
Greene. 527 U.S. 263. 281-801 (1999). 11 information would he ' advantagetnss in the
0
defendant or '%uld Lend to call the government's cise into don

it
favorable."" (oinsiork r. !iuinphries. 786 1'.3d 701.`708 (9t1i ('ii. 2015, (quoting Bunks t'.
L)reike, 540 U.S. 668. 691 (2004) and %IiIke r. Rivi 11 l.3d 998. 1012 9th Cir. 2013))
(internal citations omitted). The suppression of' lavorabk evidence is prpudcia1
41
that
evidence was "material" for !Jrafr purposes. Sirkkkr. 527 U.S. at 282. Fvidence i
"material" If it "could reasonably he taken to put the whole case in such a dilThrent it
as to undermine confidence in the verdict." At at 290 (citing Ar/e.r. 514 (1.5. at 435). 'F
establish materiality. a dehndant need not demonstrate "that disclosure of' the suppressed
evidence would have resulted ultimately in 111iSl acquittal." Ky/es. 514 (.1.5. at 434.
Rather. the deflndant need only

AW establish "a 'reasonable pmbabilitv' of a dilThrent
result." Al. (quoting United Stales r BcigIçi 473 t .S. 667. 678 (1 985 0. .\ 'reasonable
probahi I iiv" exists if "the government's evidentiary suppression 'undermines confidence

in the outcome of' the trial" W. (quoting. Bog/e)., 473 U.S. at 67$): see
U/.S1) Lnited Slates r, cIat,'hatr, 728 F.3d 885. 900 (9th Cir. 20 13) ("In cva1uatin
materiality. we focus on whether the withholding of the evidence undermines our trust in
the fairness of the trial and the resulting verdict.").
Dekndant argues that the Government violated lIraci,t' by f'ailin to pro'. ide tiiucl
discovery necessary for his dthnse, (MN'l' at ) XI l)eIndant alleges that the
Government's disclosure of numerous exhibits during trial and post-trial disclosure about
an undercover agent who had been in contact with Mr. Simpson. One of the participants
Defendant's Motion for Judgment of Acquittal is premised on insuliicieucv of'

the evidence and the Government's alleged misconduct. (MJ\ at 1.) For purposes of the
S Motion Ddendant Incorporates the tauual allegations and kgal ugumLnts of ilK Motion
for New 'Frial. (hi.) The Court denies Delindant's Motion for Judgment of Acquittal fbi'
he same reasons it denies Defendant's Motion for New Trial.
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in th (larkind attach. violated Del' s due process and Sixth A mcndmeni 1<1gb
(id, at 1 2: Supp. MNT at 1 .) The Government argues that 1)e1ndant is not entitled to a
new trial because its disclosures iflci' October 12. 2015 did not viol
ate /?ru(1v. (Doc. 324..
4 Gov't's Consul. Resp. Dels MN'I' and i\1i\ ("Resp.") at 4.) The (i veriinent tisrihe
argues that even if I )efendant was prejudiced by the late disclosure, the appropriate
remedv was seeking a continuance. (1<CS)). at 56.)

oe
7 A. Disco v ery Abuses

8 1)e6endant argues that the (inveniment deprived him of due process and a Fair trial
9 bv making disclosures between No c.mb'.. i 2() 1 S and I chi nat ' I 201 ' itid durino trial.
10 (MN'V at 26.) The Government argues that the pre-trial disclosures in No ember 2015
ii and after were not material and were provided in enough time lbr Defendant to use them
at trial. (Resp. at 7.) iic Government also argues that the disclosures during trial were
largeN about witnesses Defendants already had knowledge of and documents which it
14 already disclosed but provided in a diFferent lirniat during trial. (Resp. at 7-8.) A
defendant alleging a Brad' violation based on the late disclosure of evkkncc also must
show he was prjudiced by the delay. ilump/iriex. 76 F.3d at 708. Thus. W it dehndant
17 is able to make effective use of exculpatory or impeachment inlbrmation that is disclosed
18 mid-trial, no Rradv claim will lie. (lu/ted Sta/es r. ll,'mrne. 829 l"..2d 760, 765-66 (9th
19 c',*11% 1987),
7() 10 Pre-trial flis e l os u res
While 1)et'ciid tall t complains about a number (W exhibits disclosed aFter the October
1 2. 2() 1 .5 deadline but beibre trial. Delndant has tidIed to a1Iec how he was prejudiced
23 by the disclosures. The disclosures were made beFore trial and defense counsel used some
24 of the disclosed exhibits during cross-examination. See Browne. 839 10.2d at 765-66.
ThereFore, the ('ow't does not grant a new trial on this ground.
2. Trial Disclosures
27 Defendant contests a number of trial disclosures. The Court considers them in

28 turn.
-4 No
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a February 18 2016
On 1:ehrLr11,? 18. 2-016. the (iovernment disclosed a number oF exhibits and Form
302 reports' fiw James Bell. Abduliah Muharak and Amy Vaughn. who erc called as
witnesses the next day. WNI` at 3.) On February 19. 2016. the Court ordered the
Government to disclose their witnesses 2.4 hours in advance. Mr. Bell was not on the
(iovernments final witness list and did not teslil at trial. Mr. Muharak's interview was
not conducted until February 3. 201 6 and II)ek'ndant received a hard copy of'the Forni
302 on February 1 5. 2016 and an em, ikd copy on February 18. 2016. Amy Vaughn as
not disclosed until the night prior to her first day ol' testimony. but l)elèiidant conducted
an extensive cross-examination on her second day of testimon. February 23. 2016..
While Defendant complains about the magnitude of the disclosures, he does not allege.
with any specificity. how he was prejudiced by the late disclosures. 1)etCndant used the
exhibits durin, his cross-examination ol Ms. Vaughn. See Bmwnc'. 839 l:,2d at 765-66.
The Court does not grant a new trial on this ground.
b. February 23, 2016
On February 23 2016. the Government made a disclosure of 23 CAN and 22 ne
exhibits, some of which were used that day with Ms. Vau,thn. (MNT at 3-4.) 1 )efi.mdani
argues that he was prejudiced because he was not able consult his own computer
4)3 The Government argues that its
(brensic c pert prior to cross-examination. (MNI- at
February 23 2011 disclosures were re -peat disclosures and or the person disc loscd 'as
FBI Form 302 is a form used by agents to provide summaries of witness

interviews and oilier investigation actions. for example.. execution of' a search warrant.
"
DclCndant also argues that the Government inappropriately used excerpts of
Dcknd ml s post arrest intcr tcc because the spccitit. excerpts had not hccn discloscd
(MNT at 5 Dckndant hoccr had a topv of the cntirc interview and the (aoctnmcnI
apparently provided 1)ekndant with a list of start and stop times from the inki 1c
c\CtIpts SLc' Resp at 11 Doc 24-1 Discocr Matrix at 18 ) I hervloic this is not a
V, basis lot a ncw trial Dckndant further argucs that t he Gotrnnicni s disdosurc of
-Carlos and Juan s redacted 102 was in crror hut Provides no other inlor nnt ion
icgatding %~Iiv this as material or prejudicial Dekndant apparent received unedited
copies 01 the video rccording of Juan and (ai los s Jiilcr ic.s thtch included thLir
telephone numhcrs (1)iscoscr' Matrix at 1 8-19): tiinicI Suites k'ui 427 t S 97
101 1976) (noting that Thacli applies on1 to niloimation 'unkuossn to the dcknsc.").
I heretore. the Court does not grant a new trial on this ground.
APP'X 063
a 7-cv-02692M Doumeot 10 Filed 01/11/18 Eaae 66 of 107
ase 2:1b-cruo7Ofst uocument469 HICI Oi/ri
FpgelD 175
aqe t of
not called as a witness. (Resp. at 9-11.) The evidence shows that the disclosed exhibits
had been previously disclosed on February 1 7. 2016 or September 2. 20 1 5. (See I )uc.
324-1. 1)iscovcrv Matrix at 9. 13.) 13ecausc 1)ef'endant had access to the exhibits prior to
(he date IXkndant alleges. the Court does not gLmt an Li ial on this ground Intetl
S/ales r. Agnrx. 427 U.S. 97. 103 (1976) (notin that llraclr applies only to inFormation
"unknown to the d.iense").
7 C. Februtany 24, 2016
On February 24. 2016. the Government disclosed three documents prepared b
Jeffrey 1.vans. who testified the next day: an exhibit For a finger print exj?ert: and six
I( other exhibits that were admiued the next day. (MNT at 5.) The Government points out
ii that Mr. Evans report was drafled on February 4204. 2016 and disclosed the same day.
(Resp. at 12.) The Court also ranted De1'en1aiit an extension until February 26. 2016 to
cross-examine lir. Evans because of' the timing of' the disclosure. (Resp. at 13,) The
14 exhibit Ir the linger print expert was demonstrative and the underlying reports had been
13 disclosed in hard copy on February 18. 2016 and February 23. 2016. (Id. ) Defndaiii has
16 not demonstrated that he was pre judice1 by these disclosures, thereFore the Court does
17 not grant a new trial on this ground.
18 d. February 25, 2016
19 On February 25. 2016. the Government disclosed two reports relating to
20 De!ndant's laptop. (MN'l' at 5.) The Government notes that the browsing history data
21 had been previously disclosed in conjunction with an image of the entire laptop but were
supplied separately From the laptop image as a courtesy to i)ekndant. (Resp. at 14.) The
Court does not tmini a, new trial on this ground as the image was previously disclosed.
24 C. February 29, 2916
On 1ebrt,a' 29. 2016. the Government disclosed nine new exhibits t'clatcd to
Def end.-Li nt's computer.. Simpson's cell phone. and pictures in Simpson 's apartment.
(MNT at 6.) The Government argues that the inFormation was not disclosed until
February 29.. 2016 because it did not become relevant until it became aware that ihe
APP'X 064
3i7-cv412692&q?qg'e t 10 FILeL1 of 1 ageID 176
ea (1 lO Bocumen t tt açje
I )elendani S lila I St ategS10disV Wi don

hisel iiLOflL1ci i,npoi
knowledge of the Garland attack. (Resp. at 15-16,) Additionally, various exhibits Iioin
i)eltidant's laptop. Simpsons cell phonef, and pictures in Simpson's apartmenL had been
4 dhclflSuJ thRUghOUt dlS40W mid Ii iil prior to their di'clow on I dii un 29 201 6
(Id. at 161 7.) The Court does not grant a new trial on this ground.
B. flrai' Violations
7 Defendant argues that the ( i ovcrneut
m Failed to proidc material exculpatory
evidence including texts from All I31,11z and Christian Leon: statements from Saahir
Nurse. ,tames Bradley Bell., and John Sabari: and an investigation by it 11.31 undercover
agcnL (MNT at 7-12: Supp. MNT at 1 8.) Evidence is material Ii there is a reasonable
probability that. had the evidence been disclosed to the dek'nse. the result ol the
12 ptou.u.ling would 1111c htcii dilkient u/t €1 S!cit s v,, Kohi,,Wg.67 F.3d 9i 90" 19th
I3 ("it.. 2() 11). "There is a 'reasonable probability of' pre judice when suppression of the
14 evidence 'undermines con tidence in the outcome of' the trial." Id (quoting IKviex. 514
15 (J.S. at 434). The mere possibility that an item of* undisclosed inFarniation might have
16 helped the dcInse or might have aiTheted the outcome of the trial does not establish
" in the constitutional sense. ,I,mv. 427 U.S. at 109-110. Further. the rule of
17-materiality
18 flradt' applies only to information "unknown to the definse." Id. at 1031
I. AU Bali. and Christian Leon
i)e1ndant objects to the disclosure of Raiz and Leon's interviews the week
ielorc trial when they were interviewed in May 2015. (NINT' at 7-8,) 1 )eIudant argues
that he was unable to contact them and "belicvefsj the Government halsI additional
inlorniatton ii lailed to disclose." (MN1 at 8.) The Government argues that Raiz and
24 1 eon s poit do not t.onLun e\Lulpatol\ evidence spcul'kaII\ aiguinu that (lie 1,11,011,111S
h3aiz and Leon sold Sooli were not used in the (iarland attack. (Resp. at 1 8.) The
(ioveniment additionally argues that Dc1'ndant had Bali. and Leon's phone numbers as
27 disclosed in September 2015 and used sonic of the text messages regarding their sale of
a1 and Leon communicated with Nadir Soot" regard it IC ol' lircas
.7-
APP'X 065
Ca-.e il i fagelD 177
firearms in his erossexan 4. esp. at 18 -) The Court concludes that there was no
Brculv violation because Defendant had access to Baiz and Leon's reports and phone
numbers belore trial and used the inibrmation therein during trial. Th'nrnc'. 839 F2d at
4 76566. Furthermore, the evidence is not exculpatory as the firearms they sold were not
present at the scene of the Garland attack. Therctbre. the Court does not grant a ne' trial
on this ground.
7 2. Saahir Nurse, James Bradley Bell and John STabari
Defendant argues that the Government has inlhrmation obtained ti'oin Mr. Nurse's
9 text messages that were never disclosed and that Form 302's related thereto were
I disclosed late. (MN'r at 8-10.) The Government argues that hite Mr. Nurse was listed
on l)efendant's witness list, he was not called at trial and that Mr. Nurse's phone was
never subject to a search warrant, so there is no additional intbrmation to disclose. (Re!
at 19.) Defendant has not met his burden of showing that the late disclosure of t
documents was material to his defense.
Defendant argues that any intbrniation the FBI has rgading an investigation ot
of Sabari should have been disclosed because he believes Mr. Sahari had
17 communication with a Jamaican Cleric with whom Simpson also spoke. (MNT at 10.:
1. The Government argues that Defendant never requested inlbrmation on Mr. Sahar I am
19 that the three reports it has Since disclosed do not contained exculpatory material. Resp.
20 a and
at 2 1) The (JO\ u nmt.nt 1150 irgues that Dekndmt knewof MI ahi s chose not to
mention his involvement with Simpson during trial. (Resp. at 2 0: Ii,?ifrd
Shelton. 588 F.2d 1 22. I 2I9 (9th Cir. 1 978) (denying motion for new trial when witness
was not "unknown" to Defendant). Because there can only be a Th?idy violation for
inlormation that was unknown to Defendant before trial, the Court denies a new trial on
this ground.
26 Defendant argues that the disclosures regarding Mr. Bell were late and showed
27 that Agent Whitson lied about who knew about the Muhammad drawing contest beibre
28 the Garland attack (MNT at 10-1 1 ) I hc Government argucs that Dckndmt had tim to
APP'X 066
3:17-cv-02692-M. JDocumerit 10 Flu -11~y 6 R € Lc pgetD 178
Lase 2:ib-cr4'u7u L)ocument
subpoena Mr. Bell and use the reports at trial, and that there is no evidence that the
disclosure contains exculpatory material. (Rcos p. at 202 I.) While it app ears that Mr. 13e11
had knowledge of the Muhammad drawing contest. Dekndani has not linked that
knowledge to evidence that would exculpate Defendant of his involvement, De 's
lhcorv that the evidence could have been used 11w impeachment will be discussed below.
113ccause the evidence of Mr. Bell's prior knowledge is not exculpatory. the Court does
not grant new trial on this ground O
3 Undercover Agent Investigation
Defendant argues that the (iovcrnnient had a duty to disclose an undercover
agent's investigation of an unrelated terrorism suspect and corresponding 302s because
he could have raised an entrapment delinse that was Ilivorable to his case. (Supp MNl
at 8-10.) The (overnnicnt argues that the newIydiscloscd materials are not c.xrulpator)
and do not detract honi Dckndant s participation in (hc charged umspiiaus. (Rcsp. in
Supp. MNT at 1.) The undercover agent conducted an investigation of another man.
Hendricks. who had had communications with Simpson. The Government's disclosure
revealed that the undercover agent and Simpson communicated through social media
only on April 23 and 24. 20E5. While they spoke about the Muhammad drawing contest
in Garland. Texas, Simpson dkl not disclose his intent to go to Garland. Texas to attack
the contest. Rather than showing any conspiracy between Hendricks and Simpson.
Simpson expressed suspicion of I lendricks. The Government's d isclosure that the
undercover agent was in fuel on the scene at the time the attack occurred may he new and
surprising but it does not support anything other than the undercover agent's expressed
intention to holster his credibility with I lendricks. It had nothing to do with Simpson. I he
Government's disclosure does not create any nexus between the undercover agent's
investigation and Defendant. The disclosure does wt call into question I )ei1ndant's
involvement: watching videos with Sooli and Simpson. taking Simpson and Sooli
shootingS or supplying Simpson and Soo(i with firearms. Therefore, the disclosure is not
exculpatory or material to his dcftnse.
APP'X 067
C 3l7-cv-O269ZM DgWT~)
t cuinent
10 Filed O1/flhl& Pa 79 of 102 PagelD 179
Lase. :JcNJU /0 4b9 HIeIJ ui/31ri faqe 10 of 11
(... Agent Whiison's Testimony
1)t1ixLint irt.',tis that 1131, \gent W ilsonpi

provided Ltk. vIdLntI
stating that only Carlos. Juan. and Mr. Verdugo knew about the Muhainniud drawing
contest beibre the Garland attack when he had interviewed Nathaniel Soofl and Hell who
also knew about the contest. (MNT at 14.) The Government argues that Agent \Vhitson
did not knowingly present lt1se testimony.(Resp. at 2 1 22.) The Goverwncnt speciticall
7 argues that Agent Wiitson stated that he 'did not rcea11 i1 anyone else had told him
about the contest. Agent Whitson had not conducted Mr. Bells interview% and the
statement was immaterial to the outcome because t)ciendant impeached Agent Whitson
10 about Nathaniel Soofl. at 2325): see iJrowne, 8.39 14.2d at 765-66, The ('nun
11 agrees. Agent Whitson did not know about Mr. Hell's knowledge because he did not
1I. conduct Mr. Bell's interview and I)ctbndant had the opportunity and did impeach Agent
13 Whitson rezardint
46- Nathaniel Soohi's knowledt;.e. ThereFore. the Court does not grant a
14 new trial on this ground.
IlL CONCLUSION
As dthnse counsel admitted at oral argument. 1)elbndant had a trial strategy of
17 pushing the case to trial in the shortest time period permitted. It is evident to the Court
18 that the speediness Of this trial led to the late disclosure of much more in Formation than is
I) generally acceptable. This. however, does not rise to the level of /frtuly or other
constitutional violations warranting a new trial. The Court thereFore denies DeFendant's
Motion fOr a New Trial and Motion For Judgment of Acquittal.
11 IT IS ORDERED denvintrn [)etèndant's Motion For Judgment of Acquittal
Pursuant to Rule 29 (Doc. 302)

24
- 10-
APP'X 068
317-cv-O2692~O pg%TEROt 10 FiI Aqll~JJl8. 71 of
je107 PagelD 180
ease it ct-uu cunient fl?U Iiol Ii,
EIFR ORI)I RI' I) den yi ng Ikkndan s Motion for Ntv 1i,i

I I IS FURTHER SC
on !rosccuioria! ?11.SCOIIdLICt (Doc. 303).

I )nuI this 2 id day ol'J a nu.-IiAr. 20 1 7.
Susan R. Bolton
United Staics District Judge
APP'X 069
Case 3:17cv02692M Document 10 Filed 01/11/18 Page 72 of 107 PagelD 181
Exhibit P
Media Articles
APP'.X 070
Case. 7-cv-02692-M Document 10 Filed 01/11/18 Page 73 of 107 PagelD 182
Texas shoo- Outgunned traffic officer sto pped

1
attackers
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Replay
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APP'X 071
Case 3:17-cv-02692-M Document 10 Filed 01/11/18 Page 74 of 107 PagelD 183
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APP'X 073
Case 3:17-cv-02692M Document 10 Filed 01/11/18 Page 76 of 107 PagelD 185
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APP'X 075
Case 3:17cv-02692-M Document 10 Filed 01/11118 Page 78 of 107 PagelD 187
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APP'X 076
Case 3:17-cv-02692-M. Document 10 Filed 01/11/18 Page 79 of 107 PagelD 188
• ixpert isays (iarland police otlicer was 1tr omgmined tbtil) Car liciter trained"
• 1t.Iitt. st\ 10 Men nh isauti Fill-es -kind NvcZiring hods armor timid at. poifti In xas
• 1 hc'v arc %hot dead hN an officer itIi a pis iol who 'actcd qtüciv and decisively
(('NN)lt vasnt a fair tiin.
On one side you had to men in body armor. 101mg assault rifles and showing e LI
willinuness to open lire now and count their vi ctims later. On the other. you had a
security officci' - a traffic officer by day -- with a pistol.
Somehow. the o flicer won.
Authorities have not released the name olthe overmatched Garland. Texas. police
offilcer who stopped a pair of gunmen Sunday night outside that citv' ( uuis C ulill
(7 enter., huc people had gathcR.d at an event lcatw ing controversial cartoons of the
Muslim Prophet Mohammed. But they have described what he did. actions that could
be characterized as equal parts skillful, heroic and miraculous.
U.S. I k--u 'ccuru ScLtU\
U kb Johnson laudLd the poliic olliw t'0 r ha tag
If
quickly and decisively, and thereby likely (saving ) a number of innocent lives,"
"He did what lie was trained to do," added Garland police spokesman Joe Main. "And
under the fire that he was put L111der. he did avery good job."'
ISIS threatens ziltacks 4at.aiiis•1 the U.S.
Precedent for extremist attack

Authorities knew ahead oltime that there could be trouble this weekend in Garland,
Many Muslims firmly denounce cartoons that depict Mohammed as oliènsive to their
biith. And some extremists have turned in violence to express their opposition, by
attacking those behind such drawintys. as the> did in the lanual) masstacre at Ihi Pat is
OIIices of (11(al I ie I kbdo mnaga/mnt. and a Fcbtuai incident ii C mpnhaui
I )uiinai I lot uni altLndcd In Swcdili cartoonists I\ ilks at-'.
APP'X 077
Case 3:17cv02692-M Document 10 Filed 01/11118 Page 80 of 107 PageD 189
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As ii the Mohammed cartoons weren't enough to make Sunday's tcafl a target, there
as Liko IhL presence ol it l"'eynote Speaker, ( w t \Vildus 1"h i ight i ng l)u.h
litician is on an al Qaeda hit list for 11,18 shortIihn, "Fitna," which pairs (isirhin
iiflt2CS of kitot ist act') ith tvi Isoui hit. Qutan and iecoidt ng' of incitcmenh by
extremist lslanic authorities?
The potential of a new attack was why the Garland police of was at the
convent ion center, which the Texas city's school district operates. Fie had plenty ot'
ceent of licers on site . but did
umber of law enfhrm
company: I ILIJ-11 didn't specify tilenumber
say flie event's organizers paid $ 10.000 lbr beeted-Up security.
"Garland police of liccis os k at the convention centerall the time as an off duty job."
I kim said. "And that was the case ror everyone?"
(111"11101 'stai'ted shooting at the police'

'The of lieuwho'd later be praised as a hew as parked ina patrol Car in Front of' the
lust cnuance Iwm the cast ott Naaman I otest l3oulev tid into the ceritu's pat king
lot. Alln una Garland school district sec urity oflicci' sat in the car with him
ostensibiNf to check the identification of those coming ill.
APP'X 078
Case 3:17cv02692-M Document 10 Filed 01111/18 Page 81 of 107 PagelD 190
The event started, h all accounts. withouta hitch around 5 p.m. p_ni. and [or
nearly two hours, nothmL serious happened.
I. that is. about 6:5() p_rn.. kvIienadiark-colored vehicle pulled into the entrance
I. 'flu
the Garland officer and school district officer were blocking.
111111 all= '2 unht1tn ki kd a harnnied cartoon cieflI I exas't ciass"nicdia image"
sic " cJn.cnn.cni cnnncx St
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Vhen that car pulled up and ..topped. those officers began to exit that vehicle, and
two men Le(1 the darkcoLorcd sedan." 11am said. "Roth of them had assault rifles,
came around the hack ol'thc car and started shooting at the police car."
APP'X 079
Case 3:17cv-02692M Document 10 Filed 01/11/18 Page 82 of 107 PagelD 191
Ace rd in. to a law ethreemeut

n source close to the inv tion. the two men had six
estiga
t L111\ 01 1S1Ultt\ IL Lmhtuton1atiL ii Iks and handguns that ai t. being
traced back to various parts of Arizona.
( unhre reverberated around the coniplex. ti'oni the two gunmen4 and the arnied
A short time lkatcr%iur Member's o a nearby SWAT teani came in tiring their high-
powered ri ties. according to a source 1imiliar with the ofticers involved. But by the
time they did. the Garland trallic oiflcer was the only one standing.
The school district Officer had been hit in the let l according to [tarn.
And the two attackers were Ircady down on the ground by their car. hay Shot
Lw t h e t raffi c offi c e r,
Within 15 seconds. the chaotic eruption was basically. over.
Police vet: 'You cannot downplay what he did'
I lo w?
t ic had a ,45-caliber Giock pistol, a much less powerful weapon than the i'illes used
by the attackers, who have since been identified by federal law enforcement oflicials
aS l'ilton Simpson and Nadir Sooli.
iIfl It"Who VCIL I cxas gisnili 'n?'1 cIass'nndin .— inulge to

s,C "i/cdn ci i,c;/cnnnext/d ni/assets! 150%411180 ietis"shtot 1nLSUSeCIS.S 169. pg">
APP'X 080
Rep Ia v
MUST W.
"There's no advanta2e (or a haiidun over an assault rifle." said Dick Fall-burn. a
veteran law enft'rcement officer who is a columnist lbr PoliceOnecosm "An assault
'Ile has more distance. more accuracy more power. more penetration.
"You cannot downplay what he did there."
Granted. the officer likely had on some sort oiproteetive jacket. But Tom Fuentes. a
Cormer 11 131 assistant director and current CNN contributor, said that the thin KevIar
vests often \%OIfl by p&ii. sould be uskssagunst an assault isik tound that "will go
throuh that Like a hot knife dii-oqth butter."
The same can't be said tr but Lets coming from the officer's pistol: The attackers' body
armor likely would have blocked those.
ilnis, aimim.t ibi the suspects' torso as officers are tmined first to do, since ii is their
biggest possibletaigu is no longer an option But still sOIliLh&n\ the 11-1,1111CtIkt.i
manated to down both men in seconds.
"it speaks to his skill level." Fairburn. who is 'Cal-Ills trainer tbr law en tircement.
said of the Garland otlicer. In terms of weap ic hr outuinncd. But he was
fiar better trained."
E x - F 131 o ffi ci ii N A
JflL COD could make him a dLl
APP'X 081
i'lcnty oiexampks exist of oflicers who aren't so cooL under tire. or at Least not as
accurate.
For all the mandatory firetru-nis and other training police ollicers undergo from
stationary tarets to computer simulations to live exercises "you also have to have
the composure and the concenliati oil " to lilt vow taigel I ucntcs notes. his one ilimg
to aim at a cat dhou d 111 gct at a 'un range, HI S another to shoot sti aight when the
targets arc shooting back with assault r ifles,
( lcai k the (rat kind police ollicci had his wits about him Both I ucuics and I aubuin
P01111 out that hitting one suspect could he an accident, but not two.
5i :Iio is this oflicer? Fuenies believes we may not flnd out anytime soon because.
thc momcul you idClItifyhim you also put a tat uU on his hack (and perhaps those of
W,
his kimilv members) that wi l l stay there for years.

I think t liii's \\11V thc 't c not (going. ) to plu-i"ide him out," thc eI RI ol 1k 1i1 said
to'boYOLI have one heroic cop who kills two (Islamist extremist) soldiers. He needs to
be cautious about not celebrating in the end zone."
Still. just because the oflicer hasn't been named, doesn't mean he hasn't been praised.
Iach Horn, a lawyer ibr the officers involved, said that it* it weren't fbi.' their actions.
"we'd he hearing a di flèrent k i n d of s to ry."
"They laced death hcadon," Horn said, "And, with incredible skill and bravery. (the
were able to save a lot ol' people."
CNN's Fd Lavandera, Sonia Moghe and Alma Machindu cii to this re
APP'X 082
SCOhosi hitp vveb.axtysit: uliicotn/efmsVdeliery?sidO4ectTk724Ø455h-
Case 3:17-cv-02692-M Document 10 Filed 01/11118 Page 85 of 107 PagelD 194
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punctuation guidelines
Bibliography
Martin, Naomi "Security guard injured in Garland terror attack tormented by belief that FBI knew of
ISIS plot" Dallas Morning News, The (TX), May 26, 2017. Newspaper Source, EBSCOhost
(accessed December 12. 2017).
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Security guard injured in Garland terror attack tormented by belief that FBI knew of ISIS
plot
-1W Ohm Aft. ftw
Naomi Martin
May 26--The Garland cop and the school security guard stood beside each other in the shade
through most of the day, trading stories about chasing bad guys and raising kids.
Just before 650 pm., a voice crackled over the radio saying the event they were guarding was
over, it had been controversial and dangerous a cartoon contest sponsored by antiMuslim
activists to see who could make the most outrageous drawings of the prophet Muhammad
"Looks like we might get out a little early," said the unarmed security guard, a Sunnyvale man
named Bruce Joiner
Joiner had no idea that, at the same moment court records show, an undercover FBI agent
investigating terrorism was sitting in a nearby car, snapping a cellphone photo of him and
Garland police Officer Greg Stevens.
Seconds later, a black sedan pulled up. Two men with assault rifles jumped out and began
shooting. Joiner was struck in the left calf as he ran behind a tree His wounds marked him as
the first ISIS victim on US. soil Stevens returned fire with his service pistol. striking the
shooters, Elton Simpson and Nadir Soofi, who both died on the scene
Stevens became a hero for his actions that day but has said little to nothing publicly about wha
he did
APP'X 083
20)" Will AN
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Case 3:17cv-02692-M Document 10 Filed 01/11/18 Page 86 of 107 PagelD 195

Joiner, meanwhile, feels compelled to speak out, traumatized by how close he came to dying
His torment is exacerbated, he said in a recent interview, by unanswered questions about what
truly happened the night of May 3, 2015 at the Curtis Cuiwell Center He wonders whether the
F.1 could have prevented the shooting. He wonders if agents knew he was about to be
attacked. He wonders if his own government knowingly let him - and the dozens of other
officers and event attendees - be placed in danger.
Since August court records have revealed that the undercover FBI agent was at the scene in
close proximity to the shooters. Looking at the evidence, Joiner believes the FBI had some prior
knowledge of the plot. That bothers Joiner deeply.
"It's been pretty aggravating to know that there's more to the story," Joiner, 60, said this week.
"There was no provision to get unarmed civilians like myself out of harm's way if there was
going to be this conflict. So that s very disturbing That's not the kind of thing we do in the United
ft
States with our citizens
The FBI agent's presence that day was known to Joiner shortly after the shooting. As Simpson
and Soofi stepped from their car, the agent, in a car just behind them, drove around them and
sped away. the court records show. But he was quickly stopped and detained by Garland police,
who apparently didn't know he was a federal agent
Garland police won't say if they knew anything before the attack Joiner has requested records
about the incident from the Garland Police Department, but the department has denied his
1
recuest, citing an vongoing criminal investigation," despite the fact that the two gunmen are
dead and a third suspect has been convicted in Phoenix and sentenced to 30 years.
"The case is closed why is the city of Garland hiding this?"' asked Trenton Roberts. Joiner's
son-in-law and attorney. "The fact that at the end of the day, you can't get any information out of
them does seem a bit like a slap in the face'
In tight of the news that an undercover FBI agent was on the scene the day of the attack
several members of Congress are demanding answers from the FBI about its handling of the
case.. They include Sen. Charles Grassley. R-lowa, chairman of the Judiciary Committee, and
San Ron Johnson, R-Wis, chairman of the Homeland Security and Government Affairs
Committee
If the attack had turned into a massacre, the FBI's handling of the case would be a far bigger
scandal. Joiner believes As it turned out the terrorists were amateurs, and Stevens was a cool-
headed cop and an amazing shot. Joiner said.
But it could have gone much different. The suspects wore body armor. They had six guns and
hundreds of rounds. They also carried a photocopied black ISIS flag
This week's deadly ISIS attack at a concert in Manchester. England, makes it all too clear that
authorities need to prioritize counterterrorism efforts, Joiner said. But the FBI also needs to own
up to what he believes was a botched undercover operation in Garland that gambled with public
APP'.q8 AM
ISCOhost ~Nccfflc "4140435
safety..
10
"I want to stop the practice, Joiner said. "If this ;s the FBI strategy, it's a bad strategy."
In the days after the shooting, the FBI acknowledged that investigators had (earned that one of
the suspects Simpson, 30 might go to the event. Simpson had driven to Garland with the
other gunman. Soofi, 34, from their homes in Phoenix. The FBI had investigated Simpson from
2006 to 2014
Then-FBI Director James Comey said the FBI sent a bulletin to Garland police three hours
before the attack warning them that Simpson might show up. But Comey also said he didn't
believe Garland police at the scene were aware of the bulletin. Garland police confirmed at the
time that officers on the ground didn't know about the warning
Garland police referred all questions this week to the FBI. The FBI declined to answer questions
regarding whether it sufficiently warned Garland police in advance, and Instead issued a one
sentence statement.
"There was no advance knowledge of a plot to attack the cartoon drawing contest in Garland.
Texas," said Lauren Hagee, a spokeswoman for the FBI's Dallas office..
FBI records show that an undercover agent posing as an Islamic extremist communicated with
Simpson about the cartoon contest 10 days before earlier.
Last August. FBI Agent Shawn Scott Hare filed a public affidavit in Cleveland in the case of
Erick Jamal Hendricks, who was accused of conspiring to help ISIS by recruiting domestic
terrorists in the US. To build the case, the affidavit detailed Hendricks' connections to Simpson.
Hendricks has pleaded not guilty.
The affidavit revealed excerpts of conversations the undercover FBI agent had with Simpson
and Hendricks on social media. On April 24, 2015, Simpson alluded to targeting the cartoon
contest to the agent The day before Simpson had tweeted a link to a story about the contest
"Did u see that link I posted? About texas?" Simpson asked the agent.
"Tear up Texas," the undercover agent replied.
"Bro, u don't have to say that. U know what happened in Paris," Simpson said, apparently
referring to the ISIS-inspired attack that January, on the Charlie Hebdo magazine that had
published cartoons of Muhammad. "So that goes without saying,. No need to be direct,"
On May 1, two days before the Garland attack, the agent exchanged messages with Hendricks
about the cartoon contest. Hendricks suggested the agent could "link with" Simpson. "That's
your call," Hendricks wrote, according to the affidavit.
On May 2, Hendricks told an FBI informant at a meeting in the Baltimore area that ISIS wanted
to target the cartoon contest in Garland. The FBI informant met with agents "immediately after"
the meeting, the affidavit said.
APP'X 085
11212017, 9:50 A 0
0
St. UkuM h(tp: '.'Webact I 4

Also that day, the undercover FBI agent and Hendricks exchanged messages about Garland
Typing in code language, Hendricks suggested the agent organize with Simpson and launch a
good solid protest 9 adding, "At least be heard"
On May 3, the day of the attack, the undercover agent traveled to the Curtis Culwell Center in
Garland and messaged Hendricks, saying he was nearby. Hendricks asked a series of
questions about the security and media presence, and urged the agent to target the organizer of
the event. Pamela Geller.
"If you see that pig make your voice' heard against her," Hendricks wrote He also asked the
agent if he was armed, and the agent replied that he had 'tools of the trade' and "not a small
hand tool"
"Lol" Hendricks replied. "The ppl doing the drawing and hosting and observing are the ones
needed to protest against" He seemed to suggest the agent target Geller after the event ended
as she held a news conference
"They will be outside yapping their mouths and thanking the pigs," Hendricks wrote
The shooting has changed Joiner He has trouble sleeping. He cries more often now. sometimes
out of the blue while watching TV His emotions seem more intense.
He doesn't think he has post-traumatic stress disorder because he can't replay the shooting in
his mind. He doesn't remember all of the shooting his mind didn't record memories during the
minute or so when he was trying to survive
But he can vividly see in his mind Simpson's eerie, evil grin and eye contact with him just before
the bullets flew, "It was like the Cheshire cat from Alice in Wonderland," Joiner said. "He was
Ott
like, 'I got ya
What upsets Joiner most is thinking about what could have happened had Stevens "forever
my hero" not been as good a shot, or if the terrorists would've been more strategic.
"I could have died," Joiner said. "I could have missed walking my daughter down the aisle
could have not been there It's just wow"
(c)2017 The Dallas Morning News Visit The Dallas Morning News at wwwallasnews.com
Distributed by Tribune Content Agency, LLC,
Copyright of Dallas Morning News, The (TX) is the properly of Dallas Morning News, The (TX)
The copyright in an individual article may be maintained by the author in certain cases Content
may not be copied or emailed to multiple sites or posted to a listserv without the copyright
holder's express written permission, However, users may print, download, or email articles for
individual use
Source: Dallas Morning News, The (TX), May 26, 2017
APP' 1 2(}l7, 95tJ AN

Case 3:17-cv02692-M Document 10 Filed 01111/18 Page 89 of 107 PageD 198
Item: 2W61722905450
APP'X 087
1 2 i22(I7. A'
Garland ISD Securl*ty Guard Shares Story Of

Being Shot In Attack Exclusively
With CBS11
By J. Mi1eMay 11 2015 at 8:14 pm
Filed Under: Bruce Joiner. -_- Cc
.--- - __i -s - -Cuiwell
--- - - ------- CurtI 11
('Jarkt 4 uhan A
eçpritv gqa
ily guard shot durfnt aIic'wk a! Cuhrel/
Follow CRSDF%.COM: Face hook liter
(MRLANO(CBSDF\V.COM ) The lone casualty of last weeks attempted terrorist attack

outside a Garland events center spoke exclusivetv sith CBSI I
ADVERIISING
inkead in eiUed
\Vhiic Bruce Joiner says he. not ready to do an on camera Interview. lie did show us his injury
and shird his thoughts on his first day back at ork is a Garland schools secunt gu tid hich
Was Iuesthtv%
4 1
ills assault rifle wound is still healinu
APP'X 088
Case 3:17-cv02692M Document 10 Filed 01/11/18 Page 91 of 107 PagelD 200
lie said he was standing outside the Curtis Cuiweil Center and unarmed when he walked up to a
suspicious cur and two men got out and started firing
1k says he it a sting" and didift realize he had been shoi"
But he believes he was able to be a decoy" for a Garland police officer by drawing the attention
of the to suspected terrorists who were shot and killed
Inside his hospital room. Joiner says he worried he would lose his kg and wouldi be able to
walk his datu2h1tr don the aisle then she got married in two months
Rut the bullet only brushed his bone and today Joiner is already up and walking. He says l was
lust doing in job I m glad to be alive
The incident has raised concerns about security within Garland ISD which oversees the Cutwell
Center.
The school board met behind closed doers Tuesday night to discuss possibly arming securi
guards or creating if 's on police torce
(:c 2015 CBS Local Met/ia. a diviskm a/CBS Radio Inc. All Rights Reserved. This inaterkil nav
not he pulhshtd hroadasi re t, if ftn vii disi, thuied)
APP'X 089
Records: Undercover FBI agent was at

Garland,, Texas attack
Jacques Bilkaud. Associated Press Published 9:42 am MT Feb. 10.2-0 17
CLOSE.
Two suspects are dead after police say they opened lire outside a Muhammad cartoon exhibit in
Garland Texas. I he ehihtt katurcd images ot the prophet. !both historic andcontemporary":
according to a press release. VPC
1 RI inestiiators work a erme scene outside of the Curtis CulweU Center. Police shot and killed
the men alter theyopened fire on a securit officer outside the suburban Dallas venue. hich
was hosting it contest for Prophet Muhaimuad CaFLOUn Photo: Ben I orres/Geny Images)
C()NNEC 'IAN K LI ) I CO1 MENTEMA I LMORE
PIU)LNIX An undercover FRI agent who was investigating terrorism was driving past two
\rj'oni men fii. they opened fire outside a Prophet Muhammad cartoon contest in
suburban Dallas in 2015. court records show. raising questions about whether authorities could
have done mre to stop the attack.
APP'X 090
The records became available to The Associated Press in the criminal case against Abdul Malik
Abdul Karee.m. a Phoenix man who was sentenced this week to 30 years in prison on criminal
Ofl\ ict ions that included pros iding support to 1st unic State.
Kareem wasn't at [lie event in Garland. Texas. but authorities say he provided guns used by
Elton Simpson and Nadir Soofi in the attack, instructed them on how to use weapons and
watched violent jihadist videos with them.
READ N'IORE:Phocnix nii 3() years
Kareeni was one of the first people brought to trial in the U.S. on charges related to Islamic
State.
Abdul Malik Abdul Karcem (Photo: Maricopa County Sheri)'s 0111cc)
The court records also show that the unidentified agent had exchanged social media messages
with one of the gunmen days before the attack that left the two attackers dead and a securn
guard wounded.
Drawings such as the ones shown at the contest are considered offensive to Muslims and have
sparked violence around the world.
The Texas contest was heki nearly four months after an attack on the French satirical magazine
Charlie liebdo in what extremists claim was retaliation tor the publication of cartoons about the
Prophet Muhammad.
The fact that there was an Fill agent at the contest in Texas who Was in contact with Simpson
has drawn cntiusm horn Karcem s lawet and the security guard's lawyer.They hcy sa the
government has not been forthcoming about the agent's role in the plot and have questions wh
the agency didn't break up the plot.
$ 1t", Ihe r )
,- We .are convinced that there is much more to this story than the FBI has admitted " said
I rcnu'n Roberts, an ,,attorney for secut it guard RI ucc luincr
The FRI declined to comment on whether the agency believed beforehand that Simpson and
Sooli would launch an attack and on Kareem's claim that the agent's presence wasn't revealed
avoid embarrassmcnL The Garland Police Department also declined to comment
APP'X 091
The agent ha been sitting in a vehicle outside the Garland convention cen CT .is( as even
wrapped up at the cartoon contest.
A dark sedan in front of the agent made an abrupt stop. As the agent drove around the car. two
men with an Islamic State flagwearing, body armor and carring rnihIansIle ntics got out
and opened tire.
The agent drove away and was later stopped by police. The Iwo men were killed in a shootout
ith la eniorcemnt assigned to guard the ontroerial e%ent and the secur . ity guard wits shot
in the k2
1 icebookl'-wi ttcr ro .le *I. i iikcd In

ISIS-inspired attack in Garland. Texas
hilkcteen
I4ip of* 1-orin
Uouorn Of I'onn
Posted!
A link has been txstcd to your
FBI investigators work a crime scene outside of the Curtis Cuiwell center. Police shot and killed
the men afler they opened lire on a security officer outside the suburban Dallas venue, which
as hosting a contest for Prophet Muhammad cartoons Ben Torres/Getty nImages
F uliscreen
APP'X 092
A police officer walks around the perimeter of the Curtis Culwell Center in Garland. Texas. A
contest for cartoons depictions of the Prophet Muhammad in the Dallas suburb is on lockdown
after authorities reported a shooting outside the building. Gregory Castillo/The Dallas Morning
News via Al)
l:ul lscrcn
Members of the police and swat ask people 1oii the audience it' they heard or witnessed
anything at the Curtis Culwell Center. Larry W. Smith/European PressPholo Agency
Fullscreen
Members of the Garland Police Department keep people inside the locked down Curtis Culwell,
Center. in Garland, Texas. Nomaan Merchani/AP
luliscreen
Personnel remove the bodies of two gunmen I(iarlancl. Texas. Brandon Wade/AP
l'ul Iscreen
Police officers keep members of the audience inside the Curtis Culwell Center. Larry W.
Sill ith/liuropean PressPhoio Agency
l:ttllsctve,
Heavily armed police patrol before the keynote address at the Muhammad Art Exhibit and
Contest at the Curtis Culwell Center. Larry W. Smith/European PressPhoto Agency
Full screen
Members of the Garland Police Department keep people inside the Curtis Culwe
Center. Nomtmn
Fulisereen
A member ot'the Ff31 Evidence Response Team investigates the crime scene outside of the
Curtis Culwell Center outside of the Curtis Culwell Center. Ben Torres/Getty Images
lullserecn
People are sequestered by members of the Garland Police Department inside the Curtis Culwell
Center. Nomnan Merchant. All
l:Lm l Isereen
APP'X 093
the outside of the Curtis Cuiwell Center during the American Freedom Defense lniti.tive
program in Garland, Texas. Gregory CastiilofThc Dallas Morning News via AP
or
l'ullscreen
Members of the Garland Police Department inside the Curtis Cuiwell Center. Nomaan
Merchant/AP
luilsereen
A police officer walks around the perimeter of the Curtis C.ulwell Center. in Garland.
I txas (lrLgoi\ Cast itlo1l ht. Dallas Morning Nes \ ia AP
I'ul ls.een
A police officer keeps members of the audience inside after reports of shots fired outside after a
Dutch member of paritament and leader of the 1irright Party Ibr Freedom. Geert Wilders
delivered the keynote address at the Muhammad Art Exhibit and Contest at the Curtis Cuiwell
(enter. I arr W. Smith Europtan PressPhoto Ageniv
I:ti l Iscreen
Geert Wilders. a Dutch member of parliament and leader of the f'arright Party for Freedom gives
the keynote address at the Muhammad Art Exhibit and Contest at the Curtis Cuhvcll
Center. Larry V. Smith. European PressPhoto Agency
Ful----lscr'cen
.. ...... ......
A ine;tnber of the police department keeps members of the audience inside t Curtis Cuiwell
Center. [..,arry W. "mtth Luropan PrtssPhoto Agency
Lul Iscreen
Like this topic? You may also like these photo galleries:
Replay
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16 Photos
ISIS-inspired attack in Garland. Texas
The agent's presence at the contest wasn't publicly revealed until 15 months later and has raised
questions about whether authorities could have done more to stop the attack.
Top of Form
l3ononi cii l-o
APP'X 097
There was no mention at Karcems trial last year that an undercover agent witnessed the shooting
and had exchanged social media messages with one of the men days before the attack.
The agent's presence at the event was first revealed in August in court records in a criminal case
in Cleveland against Erick Jamal Hendricks, a North Carolina man accused oftryinto, to recruit
people to join Islamic State.
I lendrieks says he had been paid by the FBI since 2009 to help identit\ potential terrorists. He
has pleaded not guilty to charges of conspiring to provide material support to the Islamic State.
More details emerged in December in court records in Kareern's ease, revealing for the first hole
the olilcer's proximity to the shooters.
Kareem's attorney said in court records that Hendricks put the undercover agent into contact
with Simpson about 10 days before the attack. In one encounter with the agent. Simpson. who
had a prior terrorism-related conviction, referred to the upcoming contest in Texas.
wOf
On the day of the attack, the agent communicated ith Hendricks while the agent was outside
the convention center. Hendricks asked about the size of the crowd. whether snipers were present
and other questions, according to records.
The agent, according to an 1`131 record tiled in Kareem's case. snapped two photos from the
convention center parking lot moments before the shooting. One shows a police officer and
another person standing in the distance near a tree. The second image was taken less than 30
seconds before the shooting.
An estimated 25 to 30 officers were at the contest in Garland. Snipers were posted in nearby
buildings, and officers stood guard in parking lots and drove around the convention center on
motorcycles looking for anything suspicious.
In the days after the shooting, FBI Director James Comey said federal investigators learned only
hours before the contest that a man tinder investigation for extremist activities might show up at
the contest and alerted local authorities. Comey also said investigators had no indication that the
man planned to attack the event.
Daniel Maynard. an attorney for Kareern, said in court records that the government hasn't
explained the agent's presence at the contest. Maynard said the agent did little to stop the attack.
accordine to court records.
Much of the evidence about the agent supports his client's view that 'this was not an unbiased
investigation by the FBI to determine the truth. but a rush to judgment to get a conviction and to
cover up the 1-13I's own ineptness and misdeeds," Maynard wrote.
TERROR IN ARIZONA: Phoenix man 'cts30vcars for ISIS-ins ircd attack J.Womoan arrested
onsu,pkion pftcrmrism Arizona man sentenced to 8 years I tucson termr case could set nc
LuigIqhaI terror hunt led to 5 I'lloenix men
APP'X 098
i rial starts in Attack at Exhit.it of Anti-Islam Cartoons The New York Times Parc I of 3
Case 3:17cv02692M Document 10 Flied 01/11/18 Page 101 of 107 PagelD 210
15he 0vvetu
0
, rk 91#MC5 https//nyti. ms/2OFIgaR
us
Trial Starts:in Attack at Exhibit of Anti*

Islam Cartoons
B FER.NANDA SANTOS V 04
Pil()ENIX - Federal prosecutors opened their case here on Wednesday agait a

man accused of being the mastermind behind a thwarted attack last year at an a ii
Islam cartoon exhibit in Texas that left twa gunmen dead in a shootout.
In her opening statement, an assistant United States attorney, Kristen Brook,

accused the man. Abdul Malik Abdul Kareem. of being the ban krol ler, [Ine trainer
and the motivator in in plot to travel to Garland. Tex, and open tire on an CVCIII that
showtasccl aU'oik and (Airtoon.s (1ej**t:"ig the Piophet Muhanmiid The gunmen
kiton Simpson .3(), aiid Nadir Soofi :34. were shot and killed.
Ms. Brook described Mr. Karcem as "the third man on a team set on mass
inn rder with "a desire to kill dishelic.ving Americans." The trial is the first 1w the
federal government linked to a terrorist act inspired bv the Islamic extremists.
'l'he dcff'iisc lawyer, Dii iiid ft T'nard rejected the governmen t's
characterization of Mr. Karec.m as being the instigator of the attack, labeling the
au usations as i ris e of o eri tive inuaginit ion bv the go ci nruent.'
Mr. Kareem, 4.4, has denied having any knowledge of the plot or of the cartoon
contest until after the attack. Tiring to link Mi Kareem to Islamic extremists, Jir.
M i ii ud said w4Is an aU. nipt to makt him gui1t b issot tttiou
M r. M avita I'd ii) trod need ti ro entirel different man - an African

American I\I usi i in con vert. 01- c $on iihadelphua police officet'. v110 owned a
APP'X 099
lilt ps:// ' w.n limes.coni.'20 I 6 t12/ I #rus/ -sutirts- j n -i'tt tack -at-ex h. i bi t-o f-a nti - isl am -cartoons. ht... I 2/I I /201 7
na) Starts in Attack at Exhibit of Anti-Islam Cartoons The New York Times 1agc 2 of 3
Case 3:17-cv02692-M Document 10 Filed 01/11/18 Page 102 of 107 PagelD 211
inuving eoinian and often took in. workers Win) had no Place to jj \~(~ . I Ic ask('d Mr.
Ktareell ) to stand up. which Mr. Kareem did. cracking a html smile to jurors. "This is
.
,
the man that the government has accused of all of these heinous crimes," M r.
Maynard told them.
Mm'. Kareem is facingtwo counts of conspiracy and one each of transportig

n
tii'ttrmits and ammnunitiovi (Wet' state lines, being a felon ill possession of firearms
and king to investigators about uk role in and knowledge of the Garland attack.
On Ilav !0 15. Mr. Simpson. :o. and Mr. Sooti, 3414 dressed in body arnior,
.
sLel),)e(l into the parking lot of the Curtis CuIwcH Center and opened tire with
'em ia ut )ma tic rtt1e, h tt ing an unarmed Security guard. Mr. Simpson and -Mr. Sooli,
who lived together in Phoenix, WCJ'C killed by a Garland traffic oflicer,
Mr. Maynard said his client was having dinner with a nephew at a Red Lobste
ill Phoenix at the time and was unaware that the attack was taking place.
Ms. Brook' argued that Mr. Kai'eem urged the two men to commit violence ill the
name of the Islamic State. Together, they watched videos of beheadings and
executions, she said. researched travel to the Middle East to join the terrorist group
and considered blowing up the stadium outside Phoenix during last year's Super
iowl, but could not get the explosives in time.
On April 21. l\'Is. Brooks said. Mt'4 Karcem downloaded a 5-muinute English-
language video titled "lames of' War," used by Islamic exta'crnists as a tool of'
recruitment and uigk.n'ihcation of the lighters in its ranks. Two clays later, Mr.
Simpson wa'otc' about the cartoon contest on Twitter "Will they ever learn." In
moments before the Garland attack, he posted, "May .;\llah accept us as
M uja h ideen
,N1 it. Karcem slouched at the defendant's table Wednesday, his lips palled as he
listened to the prosecution's first witness. Bruce ,Joincr, the security guard injured in
(arland. Gone were the shaggy heard he sported in previous hearings and the chains
that hound his wrists and ankles.
APP'X 100
https: '/www,nyt imcs.com/20 1 6/02/1 8/us/irjal-stants-in-auack-at-exhjbjt-ofantjisIain-eartoons,ht.,, 1 2/11/201

7
rial Starts in Attack at Exhibit of Antilsiam Cartoons - The New York Times Page 3 of 3
\1 r. Joncr painstakingly described his encounter with Mr. Simpson and Mr.
Soofi at the centers parking lot.: lie reealkd one of the nicu's surrea1 cmik. " Mr.
Joiner said he ducked behind a tree., not realizing he had been hit in his left kg, just
above the boothile.
The trial is expected to last five weeks and include testimony from dozens- o
witnesses, including Mr. Soofis 9-year-old son and younger brother, who
prosecutors said watched the videos with Mr. Simpson and Mr. Soofl.
A version of this artcie aopcars in onni on February t. 201$ on Page Al 7 of the New York edition with
the headfne 1 na! Starts. ri Attack at Exhibit of Ant,tstarr Cartoons.
© 2017 The New York Times Company
APP'X 101
hups:/fwww.nytjmes.comJ2oJ 6/02/I 12/11/42017

Case 3:17cv02692.M Document 10 Filed 01111118 Page 104 of 107 PagelD 213
Garland, Texas, shooter bought gun in

20 1 0 during F.. ast and Furious
I-
Jl(II (Cl
1it %:fl ik tI ckiitt in 11t L4i1id rsi il -411hr nih wiLtd owo m utiumkrn t'hn
Nut. N hin
rndhmiici pih1
A ttiiiist. t ii Wti1 trij.i ('ii

jst,1i U;i was i OLIOC VI
nnn *mtrnu von iniuj lmIhCIr ikiP flucasni rid titI, Stiolles
1111 iam tj i$s at ibm.- Smd'fjt 1i111iq Lml
i
. hist4my 44 tilfAvilivativ
?1V1 K....
APP'X 102
10K TIll. RV( ORD: In the Aug. 1 Seelion A, an artik, about a guti purchased by the alleged perpenalot of a lenorist attack in (Jar land i'cas saidthat
use stoic in which the Wt'dfk)fl was twu.gln. loit' WoIr trading (o was known among guru siiuuggk:rs for selling sllegal fSrearms It was the purchases,
not the sseapouus, that would have been considered diegal. As the article slated, lone Wolfnia& the sates as pan eta lkra1 goveosnent sting operStion
knos%11 as East and l'trfiuus in wiudu smugglers reallowedto buy weapons illegally so federal agents could track smuggling networks Also, due articles
hcadbne said that the ksas gunman was tied to Fast and furious Ike weapon was sold during the time Fast and Furious was in rflkct but was not pan or
tire smug
titsirk mIte store Ii Iirdgcd some hicts 0311111: hum rutquuired ol'would'hc grin bu> ers
What Siroli could mum have known was that Lone Wolf was ii the center ola t'dcral sting operation knussu as I rauj1rus targeting Meracatu drug
lotds and tr4uiliekers. The idea oldie secret program was to allow Lone Wolf to sdl illegal tscapors to ennimals and straw purchasers, and track the guns
bark to large stntrggling networks and drug cartels.
lit till 11
Instead, kderul agents lost track of the weapons and the Oficral HVI tieeanie a litiu'u, paruucularls alter several ol' the missing guns were linked to shornuiigs
III Meieo rind Ow 2010 kullrng ott 1 S flonkr Patrol Agent Ikirm iCfty in Ariona
rouuI's ailouuut to tua '611;41.11 caught the attention ul'ruutliorihie, who slapped a sesenday hold ru the Irrinsacturn, urxrurdu,g to Ins Feb 24, 2010, l'nrearins
I ransf kIurKi iruord s%liah was ltitrl 1w liii, I or Asigeltz I'livios lhr,n liar nisons that rrrnaau unlr,ar, tin hold was luftid aiki 23 hours arid Souli rot
the ')mihhinseter
As the ott tier ut a small piierirr, the i)all;irr4sui ii Suuii, sour of a lukustaiui Aruucrretni engineer and American nurse would not have 1xvii the priivatt 1oCs
441 lideril tushorriuc,, who back tluoi wCir' looking 101 anugg1ers and drug lord'
APP'X 103
Case 3:17cv02692M Document 10 Filed 01/11118 Page 106 of 107 PagelD 215
1k v. fl4
inta 45(11, tsJ In roonunn, LJi'n 3n, iluta upon 1110 Site ui a (41r1a11d cOinnci awtgnoptI Owl was nfl tn a ttn 101
M dipiction of Il
prnpti -i Mutumns.. o.mnbin , t)60vavc to nuns Mu$nns E)sd in bodt humor anil und with thna pistoLs thrix nths and
round% of
JuutIunuKln, iLs pot undd a suruv t4it hh* dsy ssin iutlit by local puhir
A dat after ihc attack. ttvi 1)puniuctit of' hbocc scat an uqtcat. firearms dispogturn rcqed us Lonc Wnt1 sccl(ng mon rnforniausi *nut
rustui hctouthi in fl1fl. accoidiin In if Junc I kncr irnin %cn Run Johitson I.Wis
*(Ow %cmlle I Ioiiiclaiid Stcurtt Cominttus. to U S
Aits thai I utcua 1 .snch
1isuuh its rcqucst did nut ipccils whLihcr Usc gun wts uscd in thc (aiLsnd ;iiud usassiaxnt oIhcnds said i
as needed to assist
III it CfarnrnaJ
i tigafton. i orduig to h'hiisun Icuct, also rcsicstd isv 1 tic funcs
The 1111 so iat ha reliiscd to release aiss details osdudme serial tumhcrs. ahout Usc ns used in Garland 1w Suoli aai Snnpsms Senate nt0gators
WC floss prcsmg lass ent eeme*n agencies lot art cr. raising the dulluig pmmbifity that a gun sold throng tire tatilied last and Fnus operation ended
up beug. used in a ierrssrut ainick ;sgauuu Americans
Among tither thmgs IOItPsiWS is ikmiandimiu to know wheihem ledimI authorities hase tctust'ted tbt gun Smiti bought in 2(I11I ss
hcre it was recuveictl and
sststlicr ii had hen dsuhard aicorduri to th kUst lie aLso tkvnund ii in tp1au3110n about ssbs its mu ii scseiidas hold was placid on the 20111
pistol purchase and ssbs it was filled alter 24 lsønis
Asked terxtnh Tot an irdatc iisi the Garland shooting 1111 ltrmior )iiiie IT Coiner earlier this month declined to en nment Wtfrc still sorting I
Ire said
I "Wv i)tpartrnini and the 1111 dseIind lo answer iluertionc alrssiO whether the Osnillmsiica pistol was 1)1St of the guns 0j in lit (iarland
iUk Or soct at Sii1is alrtrlIC,lt
It remains unclear sshethcr Soolic 2(110 suIt to I one Wish r a huaur niniidt..lies: tit a mrsstd oppurtuflth lii its us put Sis1i on their radar
vC4Is 1slnre his contacts with Ishmiuc s.strcrnmst Inoughi him to their atleutium.
I luougli Islamic State multirwis base claimed us base hdçsed uruanu,e (lie (arlauid nuneL 11 S otticials are still nmscsttgantsg whether Suoli and Smipon
reicut d direct suç'. U trout thu gloup ni were ms:rel unspired hi lis calls tot srslcrtcc agimst the West
APP'X 104
Cume tiggtied that the attack rots the peir, olioreign tenurgt groups Indoctrinating. Amman
rdsewrong 1ttionsni * ettiiens through the lntwnet He r rted to it as the
in a I uiihmtten kuer aprussid mailed hours hewie the attack. SOOLIsaid he was msp*red
citizen Iii led in a 2011 1) S drone stoLe in Yemen IN: writings of Islamic cleric Anwar Awhik,. an American
I kite tou Simli tunic to his mother. Sharon Stsnl, and hope to see you in eteriiitt in a wlsphone ilitersiew. Sharon Sool described the kiter and said
her sot, had hessi shot twice in the head and once in the chest. according to autopsy flndmg she receised
At she time olihe tJ!O gun purdase, suoii ran a Phueni pliaii prtor, 11w mother said that w about the saute
time he met Simpson,who worked for
Sooll as the siaursnt Ihes hirer shared art meia. a short drise from the Lone Wolf gomz
Readied In tekphone. Andie Iknsard. owner or lone Wolf. dciiicd that his store sold the gun to Soofl "Not here" Iluward said before hanging up
Sliaroti Snti sjid her sort had told her he wanted fli pistol lot priseetion because his restaurant was in a "rough area." She said he also acquired an AK-47
is5301 title ot the end oil last sear or catty this %Vjr. when authorities hehese lie and Simpson were plotting an attack on the Super liossi in Arizona
1 tried is convince hint that what in die wield dii sii mxd an At47 tot'" she said in a telephone interview. SWIll told her they practiced target shooting
in the desert tier 'ntiisger son Mi Sunk, watt living with Pus brother and Sinipson at the time, shc said, tint left altt becoming thglnencd by the weapons,
ammunition iiid imlicant Ishinust lrler,iturc
Site bkinied Simpson ir radnats7Jng her son, who she said had no history or rchgioes extremism . A month beture Soot" boutt the pistol, Simon ps was
indiied tm charges of lsirig iuithc till jhutrt hn, plans to travel to Sunutia and engage in "vi0kntphad7 acurdmg to l'cderal court documents
Simpson was tailed otml Mardi 20II and conucted nt nuksig lalte statements But the judge ruled there was insuflierent evidence to prove the 141 S
e
statenlerits were connected to international terrorism Simpson was released and placed on probation
Aiwt. the t umrland attack, the Flit arrested a third man, About Malik Abdul Karecin, and charged hint with planning the (iarland ;ttuicl At a ds'tentiurs
Itearitig on .Jun th, plosecittors and an Flit agent p idemi derails about the pint, hut avoided discussing the history ot' the knarius
Sharon Stink said she kmnd her soi4 letter in her post oi.1ie bos It was dated the Saturday before the attack, and postmarked in i)atLis on Monday, the
day tiller the assault, suggesting he dropped it in the maulbos heloiche and Simpson arrived in Garland "In she name ut' Allah," the It. began, "I iii"
sum for IN gnat' i havecatssed"
tIc teleised to "those Muslims sstm arc being killeit slandered, imprisoned, etc hit their religion," and eiaivlisd,,d, "1 truly love voti, Morn, bin this tile is
nuithirig but shade under th tree and a mimes 'the :realit% is the eternal esissertee in the herealkr"
to limo! %u'at.c?m,t/ufOmrrs u tOfl
lnrffrm uF(au1,,5er,ws,/,f/
APP'X 105

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Case 3:17cv02692-M Document 10 Flied 01/11118 Page 53 of 107 PagelD 162

Imps: ; fonuisportalibinet. fbi/forms/id I 02/PoIicy%20and%2OGuidancc%2OLibrary'O0 I 211... 1 3 201 S

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Office of Chief Information Officer

11. Roles and Responsibilities:

14. References, Links, and Forms:

14.3.2. 'information Shanna Detailed Risk Assessment and CntroI fn Form

15. Key Words, Definitions, and Acronyms:

1536 EO: executive order

16. Appendices and Attachments:

Order from Unit-e.d States V.

IN THELINITEI) STATES DISTRICT COLTRT

() ( iii lied Slates of America, No. ('R 15-00707-001 PI IXSI

27 924(h) wacts in lutihetanu. thcieol in iolation of 18 U.S.0

2.8 knoving1) and intentional iv transporting firearms and ammunition

commerce with the intent to commit crimes punishable b impriso

(1963). prosecutors arc constitutionally oblivaied to disclose evidence t arivorab1e to an

The Garland Texas attack ("Garland attack") was an attempted attack on a

defendant or '%uld Lend to call the government's cise into don

Rather. the deflndant need only

probahi I iiv" exists if "the government's evidentiary suppression 'undermines confidence

Defendant's Motion for Judgment of Acquittal is premised on insuliicieucv of'

remedv was seeking a continuance. (1<CS)). at 56.)

7 A. Disco v ery Abuses

27 Defendant contests a number of trial disclosures. The Court considers them in

FBI Form 302 is a form used by agents to provide summaries of witness

I )elendani S lila I St ategS10disV Wi don

a1 and Leon communicated with Nadir Soot" regard it IC ol' lircas

(... Agent Whiison's Testimony

1)t1ixLint irt.',tis that 1131, \gent W ilsonpi

Pursuant to Rule 29 (Doc. 302)

EIFR ORI)I RI' I) den yi ng Ikkndan s Motion for Ntv 1i,i

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Case 3:17cv-02692-M Document 10 Filed 01/11/18 Page 86 of 107 PagelD 195

"Tear up Texas," the undercover agent replied.

Case 3:17-cv-02692-M Document 10 Filed 01/11/18 Page 88 of 107 PagelD 197

APP' 1 2(}l7, 95tJ AN

Garland ISD Securl*ty Guard Shares Story Of