On or about July 11, 1994, the defendant OSAMA BIN LADEN created the London office of al Qaeda, naming it the “Advice and Reformation Committee” and placing the defendant KHALID AL FAWWAZ in charge;

In or about 1994, the defendant OSAMA BIN LADEN, working together with KHALID AL FAWWAZ, a/k/a “Khaled Abdul Rahman Hamad al Fawwaz,” a/k/a “Abu Omar," a/k/a “Hamad,” set up a media information office in London, England (hereafter the “London office”), which was designed both to publicize the statements of OSAMA BIN LADEN and to provide a cover for activity in support of al Qaeda’s “military” activities, including the recruitment of military trainees, the disbursement of funds and the procurement of necessary equipment (including satellite telephones) and necessary services. In addition, the London office served as a conduit for messages, including reports on military and security matters from various al Qaeda cells, including the Kenyan cell, to al Qaeda’s headquarters.