stl indictment

PUBLIC REDACTED VERSION

R091733 STL-11-01/I/PTJ F0007/A01/PRV/20110816/R091733-R091779/EN/pvkCONFIDENTIAL&EX PARTE

Case No:

Filed with:

Date of document:

Party filing:

Original language:

Type of document:

Filed by:

The Prosecutor

.1..i.J.J 4.....:sL;J\ ~\ U .. SPEC IAL TRI8UNM FOR LEBANO/\

TRIBUNA L S P~ClAL POUR lE lI BA!>

R089867

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BEFORE THE PRE-TRIAL JUDGE Special Tribunal for Lebanon

STL-11-01IIfPTJ

Pre-Trial Judge

10 June 2011

The Prosecutor

English

CONFIDENTIAL AND EX PARTE

THE PROSECUTOR

v.

MUSTAFA AMINE BADREDDINE,

SALIM JAMIL A YY ASH,

HUSSEIN HASSAN ONEISSI &

ASSAD HASSAN SABRA

INDICTMENT

Distribution to:

The Registrar D.A. Bellemare, MSM, QC Mr. Herman von Hebel


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l. The

stipulated in

Criminal

penalties

a.

I. Preamble

the Special Tribunal for

1 and 11 of the Statute for

Articles 2 and 3 of the Statute, and

Lebanese Law of l1

war and interfaith

to

on

authority

Lebanon,

Lebanese

the

HUSSEIN BADREDDINE, SALIM urU".>,JlL.J

,,IIJ,A',,'VJl, and ASSAD HASSAN SABRA, and together with:

Count I - Conspiracy aimed at committing a Terrorist Act; and

b. AMINE BADREDDlNE and SALIM each and

Count 2 Committing a Terrorist Act by means of an eXIIJIU'Sn'e device;

Count 3 Intentional Homicide (ef

explosive materials;

premeditation by

4 Intentional Homicide (of 21 persons in addition to the Intentional

Rafik HARlRl) with premeditation by explosive

Count 5 - Intentional Homicide (of in to the

Intentional Homicide ofRafik HARIRI) with premeditation

I As translated from Arabic into Lebanon. 2 As translated from Arabic into Lebanon.

STL-II-O lIIfPTJ

materia1s; and

the Languages Services Section of the

by the Languages Services Section of the

20f47

Tribunal for

Tribunal for

10 June 2011



2.

3.

PARTE

F0007/A01/201106J

c. HUSSEIN HASSAN ONEISSI and ASSAD HASSAN

together with:

Count 6 - Being an Accomplice to the felony of

by means of an explosive device;

a

R089869

STL- 11-0 lJIlPTJI

Being an Accomplice to the felony of Intentional Homicide (of

Rafik HARIRI) with premeditation by using

Count 8 - Being an Accomplice to the felony of Intentional Homicide (of 21

persons in addition to the Intentional Homicide HARIRI with

premeditation by using explosive

Count 9 Being an Accomplice to the felony

Homicide (of 231 persons in addition to

Rafik HARIRl) with premeditation

Indictment contains the Prosecutor's allegations

attack that killed Rafik HARIRl and 21 others and

As is the case in all criminal proceedings,

until proven guilty in a court of law.

case the Accused is built In large on

Attempted Intentional

14

in

are

Homicide of

2005

to 231

Circumstantial evidence, which works logically by inference and deduction, is

more reliable than direct evidence, which can suffer from memory loss or

dist0l1ion. It is a recognised legal principle evidence

weight and probative value as direct and

can be stronger than direct evidence.

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n. The Accused

4. Pursuant to Rule 68(D) of the Rules of Procedure and Evidence of the Special

Tribunal for Lebanon, the name and particulars of the Accused persons on this

indictment are as follows:

a. MUSTAFA AMINE BADREDDINE3 (BADREDDINE) (also known as

'Mustafa Youssef BADREDDINE', 'Sami ISSA' and 'Elias Fouad SAAB')

was born on 6 April 1961 in AI-Ghobeiry, Beirut, Lebanon. He is the son of

Amine BADREDDINE (father) and Fatima JEZEINI (mother). His precise

address is not known, though he has been associated with: the propeliy of Khalil

AI-Raii, Abdallah AI-Hajj Street, AI-Ghobeiry, in South Beirut; and the AI-Jinan

Building, AI-Odaimi Street, Haret Hreik, in Beirut. He is a citizen of Lebanon.

His Lebanese civil registration number is 34I1AI-Ghobeiry. BADREDDINE,

under the alias 'Elias Fouad SAAB', was convicted in Kuwait for a series of

terrorist acts there on 12 December 1983, where inter alia su icide bombers drove

trucks loaded with explosives into the French and US embassies. He was

sentenced to death but he escaped from prison when Iraq invaded Kuwait in 1990.

b. SALIM JAMIL A YYASH4 (A YY ASH) was born on 10 November 1963 in

Harouf, Lebanon. He is the son of Jamil Dakhil A YY ASH (father) and Mahasen

Issa SALAMEH (mother). He has resided inter alia at: AI-Jamous Street, Tabajah

building, Hadath, in South Beirut; and at the A YYASH family compound in

Harouf, Nabatiyeh in South Lebanon. He is a citizen of Lebanon. His Lebanese

civil registration is 197/Harouf, his Halj passport number is 059386, and his social

security number is 63/690790.

c. HUSSEIN HASSAN ONEISSI5 (ONEISSI) (also known as 'Husseiu Hassau

ISSA') was born on 11 February 1974 in Beirut, Lebanon. He is the son of Has san

ONEISSI (also known as 'Hassan ISSA') (father) and Fatima DARWISH

(mother). He has resided in the Ahmad Abbas Building, at AI-Jamous St, near the

3 In Arabic 0-J.l.!I,)J.; u.:.-\ ~ 4 In Arabic .y.\..;£70 ~ ~ 5 In Arabjc~ ~ ~ ,the birth name 'ISSA' having been changed to 'ONEISS!' by judicial declaration on 12 January 2004.

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Lycee des Arts, in Hadath, South Beirut. He is a citizen of Lebanon. His Lebanese

civil registration is 7/Shahour.

d. ASSAD HASSAN SABRA6 (SABRA) was born on 15 October 1976 in Beirut,

Lebanon. He is the son of Hassan Tahan SABRA (father) and Leila SALEH

(mother). He has resided at apartment 2, 4th floor, Building 28, Rue 58, in Hadath

3, South Beirut, also described as St. Thercse Street, Hadath, in South Beirut. He

is a citizen of Lebanon. His Lebanese civil registration is 1339/Zqaq AI-Blat.

5. The four Accused participated in a conspiracy with others aimed at committing a

terrorist act to assassinate Rafik HARlRl and their respective roles may be

summarised as foHows: BADREDDINE served as the overall controller of the

operation; A YYASH coordinated the assassination team, which was responsible for

the physical perpetration of the attack; ONEISSI and SABRA had the task of

preparing the false claim of responsibility, which served to identify the wrong people

to investigate, in order to shield the conspirators from justice. As participants in the

conspiracy, all four Accused played important roles in the attack on 14 February 2005

and therefore all four bear criminal responsibility for the results of the attack.

6 In Arabic, I..»"" ~ J.....\

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Ill. A Concise Statement of the Facts

6. The Prosecutor submits, pursuant to Rule 68(D) of the Rules of Procedure and

Evidence of the Special Tribunal for Lebanon, that the following facts have been

ascertained during the ongoing investigation.

A. OVERVIEW

7. On 14 February 2005, at 12:55 on Rue Minet el Hos'n in Beirut, Rafik HARIRl, the

former Prime Minister of Lebanon, was assassinated as a result of a terrorist act in

which a suicide bomber detonated a large quantity of high explosives concealed in a

Mitsubishi Canter van. In addition to killingHARIRI, the explosion killed 21 other

persons (listed in Schedule A) and injured 231 persons (listed in Schedule B).

8. Shortly after the explosion, Al-Jazeera news network in Beirut received a video with a

letter attached on which a man named Ahmad ABU ADASS (ABU ADASS) falsely

claimed to be the suicide bomber on behalf of a fictional fundamentalist group called

'Victory and Jihad in Greater Syria'. The video was later broadcast on television.

B. RAFIK HARIRI

9. Rafik Baha'eddine AL-HARlRI (HARIRI) was born on 1 November 1944 in the city

of Sidon, Lebanon. HARlRI served as Prime Minister of Lebanon in five

governments from 31 October 1992 to 4 December 1998, and from 26 October

2000 until his resignation on 26 October 2004.

10. From 20 October 2004 until his assassination, HARIRl was a Member of Parliament

and a prominent political figure in Lebanon. Upon resigning as Prime Minister in

2004, he started preparing for parliamentary elections to be held in June 2005.

11. In the morning of 14 February 2005, HARlRI departed his residence at Quraitem

Palace, in West Beirut, to attend a session of Parliament, located at Place de l'Etoile,

Beirut.

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13.

14.

15.

16.

17.

18.

19.

Shortly

convoy to

At about 1

had

led to

HAR1Rl.

Call Data

towers

1.

phone

a group of

STL-II-OllIlPTJ

F0007fA01l201

11 :00, HARIRI arrived at Parliament

,"',,,'UU''''- his sister, Bahia

HARIRI left Parliament to go to

for approximately 45 minutes.

left the Cafe and asked his

back to his residence for a lunch appointment.

entered his armoured vehicle

convoy then departed the Place

to Quraitem Palace along

2 minutes ahead the

R089873

STL-II-OI/I/PTIf

met with many

MP Marwan

le,

to the

by

van

final on Rue Minet el Hos'n. As the convoy the

explosives.

COMMUNICATIONS ANALYSIS

throughout the investigation, including

and Call Data Records (COR) for mobile in Let)aOCm

identification of some of the persons responsible

a call.

information such as incoming and

a call, its duration, call type

of mobile phones by r",1'F'r"'"

PHONE NETWORKS

the attack on

or text

to

presence of a number of interconnected mobile

involved in the assassination of HARlRl. Each network consisted

under false names, which had a high frequency

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49. On 14 February 2005, at about 12:52, closed-circuit TV footage shows the Mitsubishi

Canter van move slowly towards the St. Georges Hotel.

50. On 14 February 2005, at about 12:55, a male suicide bomber detonated a large

quantity of high explosives concealed in the cargo area of the Mitsubishi Canter van

with engine block number 4D33-JO 1926, killing HARIRI as his convoy of six

vehicles on Rue Minet el Hos'n passed the St. Georges Hotel.

51. The explosion took place on a busy public street and was enormous and terrifying.

Forensic examination has established the quantity of explosives was approximately

2500 kilogrammes of TNT (trinitrotoluene) equivalent. In addition to HARIRI, 8

members of his convoy and 13 members of the public were killed. Not including the

suicide bomber, the explosion killed a total of 22 persons. Due to the size of the

explosion, the attack attempted to kill a further 231 persons who were injured, and

also caused partial destruction of the St. Georges Hotel and nearby buildings.

52. Fragments of the suicide bomber were recovered at the scene and forensic

examination has established both that the remains were: (a) ofa male, and (b) not of

ABU ADASS. The identity of the suicide bomber remains unknown.

3. Delivery of the Video

53. Starting about 75 minutes after the attack, ONEISSI and SA BRA made a total of 4

calls to the offices of the Reuters and AI-Jazeera news networks in Beirut. All 4

phone calls were made using the same prepaid Telecard 6162569 fTom 4 different

public payphones:

a. At about 14:11, ONEISSI or SABRA, both acting together, claimed to Reuters

that a fictional fundamentalist group called' Victory and Jihad in Greater Syria'

executed the attack.

b. At about 14: 19, ONEISSI or SABRA, both acting together, uttered into the phone

to AI-Jazeera a claim of responsibility from 'Victory and Jihad in Greater Syria',

a report of which was broadcast shortly after.

c. At about 15:27, SABRA called AI-Jazeera and gave information on where to find

a videocassette which had been placed in a tree at the ESCW A Square near the

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IV. The Counts

66. WHEREFORE, pursuant to Rule 68(D) of the Rules of Procedure and Evidence of the

Special Tribunal for Lebanon, the Prosecutor charges the Accused persons with the

following counts:

COUNT ONE

Statement of Offence

67. Conspiracy aimed at committing a Terrorist Act,

a. pursuant to Articles 188,212, 213, 270, and 314 of the Lebanese Criminal Code,

and

b. Articles 6 and 7 of the Lebanese Law of 11 January 1958 on 'Increasing the

penalties for sedition, civil war and interfaith struggle', and

c. Article 3(1)(a) ofthe Statute of the Special Tribunal for Lebanon.

Particulars of Offence

68. MUST AF A AMINE BADREDDINE, SALIM JAMIL AYY ASH, HUSSEIN

HASSAN ONEISSI, and ASSAD HASSAN SABRA,

a. between at least the eleventh day of November 2004 and the sixteenth day of

January 2005,

b. together with others unidentified,

c. each bearing individual criminal responsibility as co-perpetrators with shared

intent,

d. concluded or joined an agreement, aimed at committing a terrorist act intended to

cause a state of terror by a predetermined means liable to create a public danger,

e. namely by the assassination by means of a large explosive device in a public place

of the former Prime Minister, and leading political figure, Rafik HARlRI,

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f. which intentionally with premeditation should,

g. or they foresaw and accepted the risk would,

h. kill and attempt to kill others in the immediate vicinity of the explosion, and cause

the partial destruction of buildings,

l. all of which they agreed as two additional goals of the said conspiracy

I. to blame falsely on others in a fictional fundamentalist group so to shield

themselves from justice, and

It. to add to the state of terror, by raising in the mind of the population

insecurity and fear of further indiscriminate public attack,

J. and in so doing thereby. together they committed a conspiracy against state

security.

COUNT TWO


69. Committing a Terrorist Act by means of an explosive device,

a. pursuant to Articles 188, 212, 213, and 314 of the Lebanese Criminal Code, and

b. Article 6 of the Lebanese Law of 11 January 1958 on 'Increasing the penalties for

sedition, civil war and interfaith struggle', and

c. Article 3(l)(a) of the Statute of the Special Tribunal for Lebanon.


70. MUSTAFA AMINE BADREOnINE and SALIM JAMIL AWASH,

a. on the fourteenth day of February 2005,

b. together with others unidentified,

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c.

d.

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individual criminal responsibility as with shared

a terrorist act intended to cause a state terror by a means I iable to

create a public danger,

e. namely by assassination by means of a in a public place

f.

of Prime Minister, and leading

bringing about the detonation at 1

at Rue Minet el Hos'n, Beirut,

2500 kilogrammes of TNT

g. it being an aggravating circumstance that, in so

i. in the deaths of Rafik

ii. in destruction

h. also attempting to kill 231

COUNT THREE


day of February

a public street, of

21 other persons, and

nearby buildings,

71. Intentional Homicide (of Rafik l:-iARlRl) with premeditation by using explosive

a.

b.

a. on

11

to Articles 188, 212, 213,

and

l)(a) of the Statute the

Particulars of

AMlL'JE BADREDDINE

fourteenth day of February

27 of 47

549(1) and (7), of the Lebanese

Tribunal for Lebanon.

,,,,mu,,,-, A YY ASH,

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b. with others unidentified,

C. individual criminal responsibility as co-perpetrators with

d. committed the intentional homicide ofRafik HARIRl,

e. in the aggravating circumstance of

i. premeditation, and

11. by about the detonation at 12:55 at Rue Minet el

Lebanon, of explosive materials of approximately

TNT equivalent.

COUNT FOUR


Intentional Homicide 21 persons in addition to

with premeditation by using explosive materials,

a. to 188,189,212,213,547 and 549(1) and (7) of the

and

b. 3(1)(a) the Statute of the Special Tribunal for Lebanon.


MUSTAFA AJ\lIlNE BADREDDINE and SALIM JAMIL A YY ASH,

a. on the fourteenth day of February 2005,

b. (or as a result of injuries sustained on the fourteenth day

c. with others unidentified,

d. bearing individual criminal responsibility as co-perpetrators,

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e. by a quantity of explosive materials in a public place with

premeditation to commit the intentional homicide of

and leading political figure, Rafik HARlRI, within his motor convoy,

f. in addition, either intending to kill members of the said convoy and

the general public in the vicinity,

g. or by reason of foreseeing and accepting the risk that deaths would occur within

the said motor convoy and among the general public in the

h. by about the detonation at 12:55 at Rue Minet el Beirut,

a public street, of approximately 2500 kilogrammes of

equivalent,

i. thereby with shared intent,

j. in the circumstance of

i.

ii. by the detonation of explosive materials,

k. homicide, as named alphabetically in Schedule

I. ofthe said convoy, namely:

l. Yahya Mustafa AL-ARAB,

2. Omar Ahmad AL-MASRI,

3. Mazen Adnan AL-ZAHABI,

4. Mohammed Saadeddine DARWISH,

5. Bassel Farid FULEIHAN (who died on 18 April 2005 as a result

injuries sustained on 14 February 2005),

6. Mohammed Riyadh Hussein GHALA YEENl,

7. Talal Nabih NASSER, and

8. Mohammed TARRAF;

m. and of thirteen members of the general public, namely:

1. Joseph AOUN,

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CONFIDENTLAl&EX PARTE R089896

75.

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2. Halim ABU RJEIL Y (who died on 15

injuries sustained on 14 February

3. Mahmoud

Saleh AL-KHALAF,

5. Mohammed AL-KHODR,

6. Rima Mohammed Raif BAZZI,

7. Abdo Tawfik BOU FARAH,

8. Yamama Kamel DAMEN,

9. Abd AI-Hamid Mohammed

10. Rawad Hussein Suleiman HAIDAR,

11. Ahmad ISSA,

12. Hassan OSFOUR, and

2005 as a result

13. Haitham Khaled OTHMAN (who died on 15 February 2005 as a result

sustained on 14 February

COUNT


Attempted Intentional Homicide (of 1 to

HARIRI) with premeditation materials,

a. to Articles 188, 189, 200, 212,213, ) (7) of the

Criminal Code, and

b. 3(l)(a) ofthe Statute ofthe Special Tribunal Lebanon.


76. AMINE BADREDDINE and SALIM JAMIL

a. on fourteenth day of February 2005,

b. with others unidentified,

c. individual criminal responsibility as I"'rI_nprnptr<>

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d. by a large quantity of explosive materials in a public

intent and premeditation to commit the intentional horn

Minister, and leading political figure, Rafik HARlRI, within

e. in addition, either intending to kill members of the said convoy

the general public in the vicinity,

f. or by reason of foreseeing and accepting the risk that deaths would occur

said motor convoy and among the general public in the vicinity,

g. bringing about the detonation at 12:55 at Rue Minet el

approximately 2500 kilogrammes of TNT equivalent,

h. intent,

I. in the circumstance of

i. premeditation, and

11. by bringing about the said detonation of explosive

j. in so causing injury in the explosion to from

public, attempted to commit the intentional homicide

named alphabetically in Schedule B.

COUNT SIX


an Accomplice to the felony of Committing a

device,

as

by means of an

a. to Articles 188,219(4) and (5), 314 """'J"''''''''", Criminal Code,

and

b. Article 6 of the Lebanese Law of 11 January 1 on the penalties for

civil war and interfaith struggle', and

c. 3(1)(a) ofthe Statute ofthe Special Tribunal

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78. HUSSEIN HASSAN ONEISSI and ASSAD HASSAN SABRA,

a. between not later than the sixteenth day of January 2005 and the fourteenth day of

February 2005,

b. knowing that others as co-perpetrators intended to, and on the fourteenth day of

February 2005 then did,

c. commit a terrorist act intended to cause a state of terror by a means liable to create

a public danger, namely by means of a large explosive device in a public place;

d. which the co-perpetrators agreed as two additional goals:

1. to blame falsely on others in a fictjonal fundamentali st group so to shjeld

themselves from justice; and

11. to add to the state of terror, by raising In the mind of the population

insecurity and fear of further indiscrim inate public attack;

e. ONEISSI and SABRA, knowing the intent of the said co-perpetrators to commit

the said terrorist act,

f. together with shared intent,

1. each bearing jndividual criminal responsibility and participating as an

accomplice to the terrorist act, and

11. each aiding and abetting the co-perpetrators of the felony,

g. agreed with the co-perpetrators to perform, and then performed, acts preparatory

to the offence, and acts to shield the co-perpetrators and themselves from justice,

which would falsely blame others in a fictional fundamentalist group so as to add

to the state of terror, as follows:

1. as preparatory to the offence, by identifying and then using a 22-year old

Palestinian man named Ahmad ABU ADASS in order to create a false

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responsibility from him on video for

a called 'Victory and Jihad in

as acts to shield the co-perpetrators and

video, with the

would be

immediately after the said offence.

COUNT SEVEN

on


forthcoming offence on

Tn~'''Yr Syria ';

from justice, by then

false claim of

television in Lebanon

79. Being an Accomplice to the felony of Intentional Homicide (of Rafik HARIRI)

80.

STL-ll

with by using explosive materials,

a. 188,219(4) and (5),

b. Article 3(1)(a) Statute of the Special

HUSSEIN

a.

b.

c.

d. which


ONEISSI and ASSAD

not than the sixteenth day of January

2005,

as co-perpetrators

did,

premeditation by

Minister, and

co-perpetrators agreed as two additional

) and (7) of the Lebanese

and the fourteenth day of

and on the fourteenth day of

intentional homicide

HARIRI;

i. to blame falsely on others in a


fundamentalist group so to shield

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11. to add to the state of terror, by raising in the mind of the population

insecurity and fear of further indiscriminate public attack;

e. ONEISSI and SABRA, knowing the intent of the said co-perpetrators to commit

the said intentional homicide of Rafik HARlRI,

f. together with shared intent,

I. each bearing individual criminal responsibility and participating as an

accomplice to the intentional homicide of Rafik HARlRl, and

11. each aiding and abetting the co-perpetrators of the felony,

g. agreed with the co-perpetrators to perform, and then performed, acts preparatory

to the offence, and acts to shield the co-perpetrators and themselves from justice,

which would falsely blame others in a fictional fundamentalist group so as to add

to the state of terror, as follows:

I. as preparatory to the offence, by identifying and then using a 22-year old


claim of responsibility from him on video for the forthcoming offence on

behalf of a group called 'Victory and Jihad in Greater Syria '; and

11. as acts to shield the co-perpetrators and themselves from justice, by then

ensuring the video, with the attached letter, of the false claim of

responsibility would be broadcast on the television in Lebanon


COUNT EIGHT


81. Being an Accomplice to tbe felony of Intentional Homicide (of 21 persons 111

addition to the Intentional Homicide of Rafik HARlRI) with premeditation by using

explosive materials,

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a. pursuant to Articles 188, 189, 219(4) and (5), 547 and 549(1) and (7) of the

Lebanese Criminal Code, and

b. Article 3(l)(a) of the Statute of the Special Tribunal for Lebanon.




February 2005,

b. knowing that others as co-perpetrators intended to, and on the fourteenth day of


c. commit with premeditation by using explosive materials the intentional homicide

of the former Prime Minister, and leading political figure, Rafik HARIRI,

d. which in addition, as shown by the large quantity of explosive materials used, they

intended, or foresaw and accepted the risk, that this act would kill others in the

vicinity of the explosion,

e. and who thereby committed the intentional homicide of21 others,

f. which the said co-perpetrators agreed as two additional goals:

I. to blame falsely on others in a fictional fundamentalist group so to shield


11. to add to the state of terror, by raising in the mind of the population

insecurity and fear of further indiscriminate public attack;

g. ONEISSI and SABRA, knowing the intent of the said co-perpetrators to kill

others in addition to killing Rafik HARIRI,

h. together with shared intent,

I. each bearing individual criminal responsibility and pm1icipating as an

accomplice to the intentional homicide of21 others, and

STL-II-0l/VPTJ 350f47 10 June 2011



CONt'IDENTIAL&EX PARTE R089902

STL-II-OI/I/PTJ/ F0007/AOl/20110GIO/R089867-R089914/EN/pvk

ii. each aiding and abetting the co-perpetrators of the felony,

I. agreed with the said co-perpetrators to perform, and then performed, acts

preparatory to the offence, and acts to shield the co-perpetrators and themselves

from justice, which would falsely blame others in a fictional fundamentalist group

so as to add to the state of terror, as follows:

I. as preparatory to the offence, by identifying and then using a 22-year old


claim of responsibility from him on video for the forthcoming offence on

behalf of a group called 'Victory and Jihad in Greater Syria '; and

11. as acts to shield the co-perpetrators and themselves from justice, by then

ensuring the video, with the attached letter, of the false claim of

responsibility would be broadcast on the television in Lebanon


COUNT NINE


83. Being an Accomplice to the felony of Attempted Intentional Homicide (of 231

persons in addition to the Intentional Homicide of Rafik HARIRI) with

premeditation by using exp]osive materia]s,

a. pursuant to Articles 188, 189,200,219(4) and (5), 547 and 549(1) and (7) of the

Lebanese Criminal Code, and

b. Article 3(1)(a) of the Statute of the Special Tribunal for Lebanon.




February 2005,

STL-l1-0 lIl/PTJ 36 of 47 10 June 2011




STL-II-O lII/PTJ/ F0007/AOl/201106JOfR089867-R0899

b. knowing that others as co-perpetrators intended to, and on the


c. commit with premeditation by using explosive materials

former Prime Minister, and leading political figure,

d. which in addition, as shown by the large quantity of explosive

e.

f.

or foresaw and accepted the risk, that this act would

others in the vicinity of the explosion,

the

i. to

committed the attempted intentional homicide of

co-perpetrators agreed as two additional

falsely on others in a fictional

from justice; and

to add to the state of terror, by raising in the mind

and fear of further indiscriminate public

g. ONEISSI and SABRA, knowing the intent

to kill others in addition to killing Rafik HARIRl,

h. with shared intent,

to kill

so to shield

the population

to

1. each bearing individual criminal and as an

i.

accomplice to the attempted intentional "~.,,._ .... _ I others, and

11. each aiding and abetting the co-perpetrators

with the said co-perpetrators to acts

to the offence, and acts to shield the

from justice, which would falsely blame others in a

so as to add to the state of terror, as follows:

fundamentalist group

1. as preparatory to the offence, by identitying and then a old

Palestinian man named Ahmad in order to create a false

of responsibility from him on offence on

a called 'Victory and Jihad in '; and

11-01lI/PTJ 37of47 10 June 2011



D.A. Bellemare, MSM QC

Original signed[Redacted]

stl indictment

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