Count 1: From in or about May 2001 through in or about December 2001 the defendant did unlawfully and knowingly outside the United States engage in a conspiracy to kill nationals of the United States, while such nationals were outside the United States.
Count 2: From in or about March 2001 through in or about May 2001 the defendant, subject to the jurisdiction of the United States, but outside of the jurisdiction of any particular state or district did unlawfully, willfully and knowingly provide material support and resources ... to a foreign terrorist organization, mainly Harakat ul-Mujahideen (HUM) and attempted and conspired to do so in violation of (U.S. law).
Count 3: From in or about May 2001 through in or about December 2001, the defendant, subject to the jurisdiction of the United States, but outside the jurisdiction of any particular state or district, did unlawfully, willfully and knowingly provide material support and resources ... to a foreign terrorist organization, namely al-Qaida, and attempted and conspired to do so in violation of (U.S. law).
Count 4: From in or about May 2001 through in or about December 2001, outside of the jurisdiction of any particular state or district, the defendant, being a United States person, subject to the jurisdiction of the United States, did willfully and knowingly contribute goods and services to, and for the benefit of, the Taliban, and did supply directly and indirectly goods and services to the territory of Afghanistan controlled by the Taliban and to the Taliban and to persons whose property and interests in property are blocked pursuant to (U.S. law and executive order).