According to the charges, an unnamed Lashkar member A, who served as a "handler" for terror suspect David Coleman Headley and another person associated with LeT, advised him in late 2005 that he would be travelling to India to perform surveillance of potential targets for Lashkar.
Arrested by the FBI in October last year, Headley, a Pakistani-American, has been charged with planning terrorist attack in India and being involved in the Mumbai terrorist attack.
His school-time friend Tahawwur Hussein Rana has also been arrested and indicted on similar charges.
In an indictment filed before the Chicago court on Friday, federal prosecutors said, as per direction given by his LeT handlers Headley changed his given name of Daood Gilani on February 15, 2006, in Philadelphia, enabling him to present himself in India as an American who was neither Muslim nor Pakistani.
In the spring of 2006, Lashkar Member A and a Lashkar associate discussed with Headley the idea that he could open an immigration office in Mumbai as a cover for his surveillance activities.
In June 2006, Headley allegedly traveled to Chicago, advised Rana, a Canadian citizen, of his assignment to scout potential targets in India, and obtained approval from Rana, who owned 'First World Immigration Services' in Chicago and elsewhere, to open an office in Mumbai as cover for his activities.
The prosecutors said Rana allegedly directed an individual associated with First World to prepare documents supporting Headley's cover story of opening a First World office in Mumbai, and advised Headley how to obtain a visa for travel to India.
Headley misrepresented his birth name, his father's true name and the purpose of his travel in his visa application, the indictment alleges.
In July 2006, unnamed Person A in Pakistan gave Headley approximately US $25,000 to establish and operate the Mumbai office of First World and to pay for living expenses while Headley carried out his assignment for Lashkar, the charges add.
Before each trip, Lashkar members and associates allegedly instructed Headley regarding specific locations where he was to conduct surveillance, and Headley travelled to Pakistan after each trip to meet with Lashkar members and associates, report on the results of his surveillance, and provide the surveillance photos and videos, the indictment.
During his meetings with Lashkar members and associates in Pakistan after the September 2007 surveillance trip to Mumbai, Lashkar Member A showed Headley a styrofoam mock-up of the Taj Mahal hotel, and Person A provided Headley with approximately US $2,000 worth of Indian currency for expenses, according to the indictment.
Before the April 2008 surveillance trip, Lashkar Member A provided Headley with an additional US $1,000 worth of Indian currency.
In addition, Lashkar Members A and B provided Headley with a global positioning system device and showed him how to use it to record the locations of possible landing sites and potential targets in Mumbai, which Headley then used during his surveillance trips in April and July 2008, the charges state.
Before the July 2008 visit, Person A provided an additional US $1,500 worth of Indian currency to Headley to keep the First World office open, but approved closing that office in the future and opening a new business in Delhi to be used as cover for future activities.
During Headley's July 2008 surveillance mission, Person A communicated with Headley by passing messages to him through Rana, the indictment alleges.
From November 26 to November 28, 2008, 10 attackers trained by LeT carried out multiple assaults with firearms, grenades and improvised explosive devices against multiple targets in Mumbai, including the Taj Mahal and Oberoi hotels, the Leopold Caf, the Chabad House and the Chhatrapati Shivaji Terminus station, each of which Headley allegedly had scouted in advance, killing approximately 164 people including six US nationals.
The six Americans killed during the three-day siege are identified in the charges as Ben Zion Chroman, Gavriel Holtzberg, Sandeep Jeswani, Alan Scherr, his daughter Naomi Scherr, and Aryeh Leibish Teitelbaum.
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