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19Jul17

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Text of the indictment charging Ikaika Erik Kang
with attempting to provide material support to ISIS

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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF HAWAII

UNITED STATES OF AMERICA, Plaintiff, vs. IKAIKA ERIK RANG, Defendant.

cr. no. CR 17 -00 446 SOM INDICTMENT 18 U.S.C. § 2339B(a)(1)

INTRODUCTION

1. On or about October 15, 2004, the United States Secretary of State designated al-Qaeda in Iraq (AQI), then known as Jam'at al Tawid wa' al-Jahid, as a Foreign Terrorist Organization (FTO) under Section 219 of the Immigration and Nationality Act and as a Specially Designated Global Terrorist entity under section 1(b) of Executive order 13224.

2. On or about May 15, 2014, the Secretary of State amended the designation of AQI as an FTO under Section 219 of the Immigration and Nationality Act and as a Specially Designated Global Terrorist entity under section 1(b) of Executive Order 13224 to add the alias Islamic State of Iraq and the Levant (ISIL) as its primary name. The Secretary of State also added the following aliases to the FTO listing: The Islamic State of Iraq and al-Sham ("ISIS" - which is how the FTO will be referenced herein), The Islamic State of Iraq and Syria, ad-Dawla al-Islamiyya fi al-Iraq wa-sh-Sham, Daesh, Dawla al Islamiya, and Al-Furquan Establishment for Media Production. On September 21, 2015, the Secretary added the following aliases to the FTO listing: Islamic State, ISIL, and ISIS. To date, ISIS remains a designated FTO.

COUNT 1
(Attempt To Provide Material Support or Resources to Designated Foreign Terrorist Organization)

The Grand Jury charges:

Paragraphs 1 and 2 of the Introduction Section of this Indictment are incorporated herein by reference.

That on or about June 21, 2017, in the District of Hawaii, IKAIKA ERIK KANG, the Defendant, did knowingly attempt to provide "material support or resources," as that term is defined in Title 18 United States Code, Section 2339A(b), including property, that is, military documents, some of which were not available to the public, to a foreign terrorist organization, to wit, ISIS, which at all relevant times was designated by the Secretary of State as a foreign terrorist organization, knowing that ISIS was a designated foreign terrorist organization and that ISIS engages in and has engaged in terrorist activity and terrorism.

All in violation of Title 18, United States Code, Section 2339B(a)(1).

COUNT 2
(Attempt To Provide Material Support or Resources to Designated Foreign Terrorist Organization)

The Grand Jury further charges:

Paragraphs 1 and 2 of the Introduction Section of this Indictment are incorporated herein by reference.

That on or about June 23, 2 017, in the District of Hawaii, IKAIKA ERIK KANG, the Defendant, did knowingly attempt to provide "material support or resources," as that term is defined in Title 18 United States Code, Section 233 9A(b) including property, that is, military documents, some of which were not available to the public, including some documents classified at the SECRET level pursuant to Executive Order 13526, to a foreign terrorist organization, to wit, ISIS, which at all relevant times was designated by the Secretary of State as a foreign terrorist organization, knowing that ISIS was a designated foreign terrorist organization and that ISIS engages in and has engaged in terrorist activity and terrorism.

All in violation of Title 18, United States Code, Section 2339B(a)(1).

COUNT 3
(Attempt To Provide Material Support or Resources to Designated Foreign Terrorist Organization)

The Grand Jury further charges:

Paragraphs 1 and 2 of the Introduction Section of this Indictment are incorporated herein by reference.

That on or about July 8, 2 017, in the District of Hawaii, IKAIKA ERIK KANG, the Defendant, did knowingly attempt to provide "material support or resources," as that term is defined in Title 18 United States Code, Section 2339A(b), including property, that is, a GoPro Karma drone, a chest rig (which is a piece of military-style equipment worn over the shoulders that has chest pouches and is typically used to hold tactical equipment, ammunition, and other military gear), and other military-style clothing and gear, to a foreign terrorist organization, to wit, ISIS, which at all relevant times was designated by the Secretary of State as a foreign terrorist organization, knowing that ISIS was a designated foreign terrorist organization and that ISIS engages in and has engaged in terrorist activity and terrorism

All in violation of Title 18, United States Code, Section 2339B(a)(1).

COUNT 4
(Attempt To Provide Material Support or Resources to Designated Foreign Terrorist Organization)

The Grand Jury further charges:

Paragraphs 1 and 2 of the Introduction Section of this Indictment are incorporated herein by reference.

That on or about from July 8, 2017, in the District of Hawaii, IKAIKA ERIK KANG, the Defendant, did knowingly attempt to provide "material support or resources/' as that term is defined in Title 18 United States Code, Section 2339A(b), including training in hand-to-hand combat techniques, combatives, firearms, and weaponry to a foreign terrorist organization, to wit, ISIS, which at all relevant times was designated by the Secretary of State as a foreign terrorist organization, knowing that ISIS was a designated foreign terrorist organization and that ISIS engages in and has engaged in terrorist activity and terrorism.

All in violation of Title 18, United States Code, Section 2339B(a)(1).

DATED: July 19, 2017, at Honolulu, Hawaii.

A TRUE BILL

/s/ Foreperson
Foreperson, GRAND JURY

ELLIOT ENOKI
Acting United States Attorney
District of Hawaii

[Signature]
LAWRENCE L. TONG
Chief, Fraud and Financial Crime Section

[Signature]
KENNETH M. SORENSON
Assistant U.S. Attorney

[Signature]
MARC A. WALLENSTEIN
Assistant U.S. Attorney

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This document has been published on 11Aug17 by the Equipo Nizkor and Derechos Human Rights. In accordance with Title 17 U.S.C. Section 107, this material is distributed without profit to those who have expressed a prior interest in receiving the included information for research and educational purposes.