The Sept. 23 indictment outlines the case against Zazi. It says not only did Zazi conspire with others to detonate an "improvised explosive device" within the United States, he also "received detailed bomb-making instructions in Pakistan, purchased components of improvised explosive devices, and traveled to New York City on September 10, 2009 in furtherance of his criminal plans."
The indictment states Zazi purchased most of the components for making the IED's in Aurora and even practiced making the devices at an Aurora hotel before traveling to New York.
The court paperwork lists several chemicals Zazi and his associates were using to make the explosive "Triacetone Triperoxide" or "TAPT," which is the explosive used in the 2005 London train bombings and intended to be used in the 2001 "shoe bomb" plot by Richard Reid.
The government alleges Zazi and others associated with him purchased unusually large quantities of hydrogen peroxide and acetone products from beauty supply stores in the Denver metropolitan area.
The indictment states there are surveillance videos and receipts that Zazi purchased six bottles of "Liquid Developer Clairoxide" from a beauty supply store in Aurora on July 25.
The document goes on to describe how videos and receipts also show that on Aug. 28 Zazi purchased 12 32oz bottles of "Ms. K Liquid 40 Volume", another hydrogen peroxide based product form the same store.
Records cited by the government in the indictment also show Zazi stayed at a nearby hotel suite in Aurora on Aug. 28 that was equipped with a stove to practice working with the chemicals.
Others associated with Zazi made purchases at beauty supply stores, according to the indictment. One person purchased a one-gallon container of a product containing 20 percent hydrogen peroxide. A second person purchased an acetone product during the first week of September. Yet another person purchased 32 ounce bottles of "Ion Sensitive Scalp Developer" a product with high levels of hydrogen peroxide on three occasions over the summer of 2009.
The government alleges Zazi rented the same Aurora hotel suite on Sept. 6 and 7. The indictment states surveillance cameras prove Zazi checked into the hotel at 2:32 p.m. on Sept. 6. FBI testing of the suite revealed the presence of acetone residue in the vent above the stove, according to the indictment. It goes on to state the bomb-making notes contemplate heating the components in order to make them highly concentrated.
A search of Zazi's laptop computer shows on Sept. 8, the Aurora man did several searches of home improvement stores within the zip code 11354, the zip code for the Flushing neighborhood of Queens, New York where the FBI did the initial raids in the case on Sept. 14. He also did searches, according to the indictment, of several types of "muriatic acid" and viewed one type - "Klean Strip green Safer Muriatic Acid" - multiple times. According to the government this product claims to have lower fumes and is safer to handle than standard muriatic acid.
The following day, Zazi drove from Colorado to New York with his lap-top computer in a rental car, according to the government. During the search of the Queens residence, the government states, agents found an electronic weight scale in the close. The scale and batteries found both contained Zazi's fingerprints, according to the indictment.
According to the court documents, the government states, "The evidence at trial will show that Zazi remained committed to detonating the explosive device up until the date of his arrest, as exemplified by, among other things, traveling overseas to receive bomb-making instructions, conducting extensive research on the Internet regarding components of explosive devices, purchasing - on multiple occasions - the components necessary to produce TATP and other explosive devices, and traveling to New York City on September 10, 2009 in furtherance of the criminal plan."
The government goes on to state, "eyewitness testimony, intercepted email and telephone communications and internet searches, direct evidence that Zazi actually purchased the component parts of improvised explosive devices and extensive forensic analysis all point to the inescapable conclusion that Zazi and others conspired to use an improvised explosive device and that Zazi took substantial steps toward carrying out the plan."
The paperwork describes Zazi as a "danger to the community" and says he should remain in custody because the government says he is a flight risk.
Zazi and his attorney Arthur Folsom have maintained Zazi's innocence since his name surfaced as a target of the FBI and Joint Terrorism Task Force investigation. Zazi also told 9NEWS in his first interview on Sept. 15 he is "not a terrorist" and has not associated with any one associated with al-Qaeda.
The organization that claimed responsibility for 9-11 and other world-wide terror attacks was not mentioned by name in the indictment.
Read Najibullah Zazi's indictment
Read Najibullah Zazi's detention motion
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