As alleged in the complaint, Thomas posted on Twitter the following statement: “If we truly knew the realities . . . we all would be rushing to join our brothers in the front lines pray ALLAH accept us as shuhada [martyrs].” The complaint further alleges that Thomas applied for a U.S. passport and advised an associate that she had deactivated her Twitter “till i leave for sham [greater Syria]. . . . don’t want to draw attention of the kuffar [non-believers].” Thomas then allegedly engaged in electronic communications with an ISIL fighter in Syria, who asked Thomas if she wanted to be a part of a martyrdom operation. Thomas responded by stating, “that would be amazing….a girl can only wish.” Thomas also allegedly conducted online research into various indirect travel routes to Turkey, and allegedly purchased an electronic visa to Turkey. The complaint alleges that Turkey is known to be the most common and most direct transit point for individuals traveling from locations in Europe who are seeking to enter Syria and join ISIL. On or about March 26, 2015, Thomas allegedly purchased airline tickets to fly overseas on March 29, 2015.
If convicted, the defendant faces a maximum possible sentence of 15 years’ incarceration.
