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Steve Zissou & Associates
Case 2:17-cr-00690-JS Document 36 Filed 03/11/20 Page 1 of 84 PageID #: 133 Steve Zissou & Associates 42-40 Bell Boulevard | Suite 302 | Bayside | New York | 11361| 718.541.0716 | [email protected] March 11, 2020 BY ECF Honorable Joanna Seybert United States District Judge 100 Federal Plaza Central Islip, NY 11722 Re: USA v. Zoobia Shahnaz, 17 CR 690 (JS) Dear Judge Seybert: This letter is submitted on behalf of Zoobia Shahnaz in support of her prayer for a below- guidelines sentence. We respectfully submit that such a sentence is warranted based on Ms. Shahnaz’s history and characteristics, including her age, her lack of prior criminal record, her motivation, gateway factors, the conditions of confinement, as well as the nature and circumstances of the offense, and is “sufficient, but not greater than necessary,” to comply with the purposes set forth in 18 U.S.C. § 3553(a). On November 26, 2018, Ms. Shahnaz entered a guilty plea to Count One of a six-count indictment, accepting responsibility for her conduct. As Ms. Shahnaz acknowledged before this Court, she attempted to provide material support to a terrorist organization by sending money to what she believed to be an organization defined by law as a foreign terrorist organization and attempting to travel to Syria to join ISIS. I. The History and Characteristics of the Defendant Zoobia Shahnaz was 27 years old at the time of the offense. She is a naturalized American citizen. As accurately described in the presentence report, Ms. Shahnaz was born on February 15, 1990, in Hyderabad, Pakistan. -
A Theory of ISIS
A Theory of ISIS A Theory of ISIS Political Violence and the Transformation of the Global Order Mohammad-Mahmoud Ould Mohamedou First published 2018 by Pluto Press 345 Archway Road, London N6 5AA www.plutobooks.com Copyright © Mohammad-Mahmoud Ould Mohamedou 2018 The right of Mohammad-Mahmoud Ould Mohamedou to be identified as the author of this work has been asserted by him in accordance with the Copyright, Designs and Patents Act 1988. British Library Cataloguing in Publication Data A catalogue record for this book is available from the British Library ISBN 978 0 7453 9911 9 Hardback ISBN 978 0 7453 9909 6 Paperback ISBN 978 1 7868 0169 2 PDF eBook ISBN 978 1 7868 0171 5 Kindle eBook ISBN 978 1 7868 0170 8 EPUB eBook This book is printed on paper suitable for recycling and made from fully managed and sustained forest sources. Logging, pulping and manufacturing processes are expected to conform to the environmental standards of the country of origin. Typeset by Stanford DTP Services, Northampton, England Simultaneously printed in the United Kingdom and United States of America Contents List of Figures vii List of Tables viii List of Abbreviations ix Acknowledgements x Introduction: The Islamic State and Political Violence in the Early Twenty-First Century 1 Misunderstanding IS 6 Genealogies of New Violence 22 Theorising IS 28 1. Al Qaeda’s Matrix 31 Unleashing Transnational Violence 32 Revenge of the ‘Agitated Muslims’ 49 The McDonaldisation of Terrorism 57 2. Apocalypse Iraq 65 Colonialism Redesigned 66 Monstering in American Iraq 74 ‘I will see you in New York’ 83 3. -
Profiles of Islamic State Leaders” By: Kyle Orton ISBN 978-1-909035-25-6!
Profles of Islamic State Leaders Kyle Orton Published in 2016 by The Henry Jackson Society The Henry Jackson Society Millbank Tower 21-24 Millbank London SW1P 4QP Registered charity no. 1140489 Tel: +44 (0)20 7340 4520 www.henryjacksonsociety.org © The Henry Jackson Society 2016 The Henry Jackson Society All rights reserved The views expressed in this publication are those of the author and are not necessarily indicative of those of The Henry Jackson Society or its Trustees Title: “Governing the Caliphate: Profiles of Islamic State Leaders” By: Kyle Orton ISBN 978-1-909035-25-6! £10.00 where sold All rights reserved Photo Credits Cover Photo: Islamic State Flag http://batya-1431.deviantart.com/art/Islamic-state-flag-488615075 Governing the Caliphate: Profiles of Islamic State Leaders ! ! ! Kyle Orton www.henryjacksonsociety.org Table of Contents Introduction …………………………………………………………………………………………… 2 Background……………………………………………………………………………………………. 11 1.! The Caliph………………………………………………………………………………………… 16 2.! The Shura Council……………………………………………………………………………… 24 3.! The Military Council…………………………………………………………………………… 37 4.! The Security and Intelligence Council…………………………………………………… 52 5.! The Shari’a Council……………………………………………………………………………. 54 6.! The Media Council…………………………………………………………………………….. 58 7.! The Cabinet………………………………………………………………………………………. 62 ! ! GOVERNING THE CALIPHATE: PROFILES OF ISLAMIC STATE LEADERS ! Introduction This paper is a comprehensive compilation of the leadership of the Islamic State (IS), the personnel and the structures by which they relate to one another within the territory governed by IS, and in its external wing that launches terrorist attacks around the world. Two years on from its declaration of a caliphate in June 2014, IS has lost 45% of its territory in Iraq and between 16% and 20% of its territory in Syria.1 But the foreign attacks continue to increase in scale and frequency. -
Livability Police Dogs Are Now Members of Marketing the Cleveland Police Department, As Package the CPD Has Increased the Number of Dogs in Eyed by the K-9 Unit
T U E S D A Y 161st YEAR • NO. 285 MARCH 29, 2016 CLEVELAND, TN 18 PAGES • 50¢ Commission opens talks on new budget, taxes Finance leader says county Requested budget increases trying to avoid fire tax hike averaging about 1.8 percent By BRIAN GRAVES The mayor also remained consistent, as By BRIAN GRAVES The mayor said the largest request came Banner Staff Writer he did last year, saying the fire fund would Banner Staff Writer from the Bradley County Emergency Medical have been kept level if only the long-range Service, for $162,000. Bradley County Commissioner Milan plan had been followed. The requests are in and county depart- Second largest was for the quadrennial ment heads have kept their wish lists to a Blake, who serves as the governing body’s “It was deviated from with 28 percent Blake reappraisal program for $144,000. finance chairman, said Monday if there is a salary increases. We were already cutting it minimum. “It jumps up every four years,” Davis way to avoid an increase in the fire tax close. The salary increase put us below the Bradley County Mayor D. Gary Davis pre- explained. “It goes back down the next three there will be a diligent effort to avoid that minimum reserve benchmark,” the mayor sented the County Commission with a book years.” increase, and what is now on the table “is said in that interview. of all requests and explanations of those He said the Justice Center request came just a recommendation.” Davis continued, stating had the salary requests at the Monday night work session. -
CPD Looking for the Best Await Man Showcase Eyes After His Candidates for 4 Patrol Posts Return To
W E D N E S D A Y 162nd YEAR • No. 100 AUGUSt 24, 2016 CLEVELANd, tN 26 PAGES • 50¢ Wacker complex entering its ‘ramp up’ phase; plant longevity 50 to 100 years By BRIAN GRAVES another 100 years." kind of quiet, but of all of the new installations of Banner Staff Writer "Wacker is a very long-term thinking compa- power in the U.S., about 60 percent of them this ny," Hudson said, adding the Charleston plant year have been based on solar," Hudson said. The new operations manager at Wacker told will have 650 employees once it goes into full "Solar has been higher than all of the other base members of the Economic Development Council operations mode. energy combined, and it is projected to grow at a the plant is now in its “ramp up” phase and Hudson said the Bradley County site is the 10 to 20 percent rate." called the process “a challenge.” only polysilicon operation of the company within She said there is some pressure during the Mary Beth Hudson greeted the council mem- bers as they came to Wacker for a briefing and the United States. current ramp up phase since there is a need to tour of the county's newest industry Tuesday "Adding this 20,000 tons to the existing 60,000 still produce high quality product for the market afternoon. tons that we already have really positions us to because of a demand for the material. “There are always challenges and opportunities be the No. 2 supplier globally — just behind GCL "That's good news for us, because the market Banner photo, BRIAN GRAVES as we continue to produce and grow,” Hudson which is one of our competitors from China," she continues to grow and the demand is there. -
Infatuated with Martyrdom
Mohammad Abu Rumman Hassan Abu Hanieh Infatuated with Martyrdom Female Jihadism from Al-Qaeda to the ‘Islamic State’ Infatuated with Martyrdom: Female Jihadism from Al-Qaeda to the ‘Islamic State’ Mohammad Abu Rumman Hassan Abu Hanieh Translated by Banan Malkawi 1 The Hashemite Kingdom Of Jordan The Deposit Number at The National Library (2017/10/5568) 278 AbuRumman, Mohammad Suliman Infatuated with Martyrdom: Female Jihadism From AlQaeda To The ‘Islamic State’ Mohammad Suliman Abu Rumman, Hassan Mahmoud AbuHanieh; Banan Malkawi. Amman: Friedrich Ebert Stiftung, 2017 ترجـمة (460) p. Deposit No.: 2017/10/5568 Descriptors: /Holy War//Women//Political Condition/ يتحمل املؤلف كامل املسؤولية القانونية عن محتوى مصنفه وال ّيعب هذا املصنف عن رأي دائرة املكتبة الوطنية أو أي جهة حكومية أخرى. Published in 2017 by Friedrich-Ebert-Stiftung Jordan & Iraq FES Jordan & Iraq P.O. Box 941876 Amman 11194 Jordan Email: [email protected] Website:www.fes-jordan.org Not for sale © FES Jordan & Iraq All rights reserved. No part of this publication may be reprinted, reproduced or utilized in any form or by any means without prior written permission from the publishers. The views and opinions expressed in this publication are solely those of the original author. They do not necessarily represent those of the Friedrich-Ebert-Stiftung or the editor. Translation: Banan Malkawi Cover and Lay-out: Mua’th Al Saied Printing: Economic Press ISBN: 978-9957-484-75-0 2 Infatuated with Martyrdom: Female Jihadism from Al-Qaeda to the ‘Islamic State’ By: Mohammad Abu Rumman & Hassan Abu Hanieh 2017 3 The views and opinions expressed in this publication are solely those of the original authors.