(English) Transcript of Trial - United States of America V Russell Defreitas, Abdul Kadir - 7-26-2010

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UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF NEW YORK
- - - - - - - - - - - - - - - X
UNITED STATES OF AMERICA
-against-
:
:
RUSSELL DEFREITAS
ABDUL KADIR
Defendants
- - - - - - - - - - - - - - - X
BEFORE:
07-CR-543 (DLI)
U.S. Courthouse
Brooklyn, New York
July 26, 2010

9:00 a.m.
HONORABLE DORA L. IRIZARRY

United States District Judge
and a jury
APPEARANCES:
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For the Government:
LORETTA E. LYNCH
United States Attorney
271 Cadman Plaza East
Brooklyn, New York 11201
BY: MARSHALL L. MILLER
JASON ALLEN JONES
BERIT WINGE BERGER
ZAINAB AHMAD
Assistant U.S. Attorneys
For the Defendant:

Russell Defreitas
MILDRED M. WHALEN
LEN H. KAMDANG
Federal Defenders of New York, Inc.
One Pierrepont Plaza
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RONALD E. TOLKIN, RMR, CRR

OFFICIAL COURT REPORTER
U.S.A. v. DEFREITAS and KADIR
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For the Defendant:

Abdul Kadir
SANKOFA LAW FIRM

116 West 111th Street
New York, New York 10026
BY: KAFAHNI NKRUMAH
AND
TONI MARIE MESSINA
100 Lafayette Street
Suite 502
New York, New York 10013
Court Reporter:

Official Court Reporter
225 Cadman Plaza East
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Minutes Taken Stenographically.

By Computer Aided Transcription.
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Transcript Produced
****
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THE CLERK:
All rise.
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THE COURT:
Please be seated.
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(Time noted 9:18 a.m.)
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(Pause in proceeding.)
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THE COURT:
Do we know where the defendants are?
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THE CLERK:
There was a delay at the jail.
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that they are in the building and are on the way up.
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THE COURT:
All right.
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THE CLERK:
Criminal cause on trial, Docket
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07-CR-543, United States versus Defreitas and Kadir.

I'm told
U.S.A. v. DEFREITAS AND KADIR
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Please state your appearances for the record.
MR. JONES:
Berger and Zainab Ahmad for the government.
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Jason Jones, Marshall Miller, Berit
We are joined at the counsel table by Detective

Investigator Robert Addonizio.
MR. KAMDANG:
Good morning, Your Honor.
Federal Defenders by Len Kamdang and Mildred Whalen.
Mr. Defreitas is not here yet.
will waive his appearance.
For administrative matters, we
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MR. NKRUMAH:
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Kafahni Nkrumah and Toni Messina for Mr. Abdul
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Kadir.
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We waive his appearance for administrative matters.

THE COURT:
Thank you for gracing us with your
appearance at this hour, Ms. Messina.
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MS. MESSINA:
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THE COURT:
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Good morning, Your Honor.
I apologize.
Everyone was supposed to be here at
9:00.
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MS. MESSINA:
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THE COURT:
I realize that.
You realize that.
Yes, I understand.
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You always realize that.
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9:00.
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time, make sure that you could account for train delays and
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everything else was covered, everyone else was able to be
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here.
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Everyone was supposed to be here at
Whatever you had to do to make sure you were here on
I understand that there has been some delay in the

4636
production of the defendants due to something that happened at
MDC.
number of matters that we do need to address.
the attorneys waiving their clients' appearances so that we
can address these matters.
I have no idea what that is.
However, we do have a
I appreciate
Just so that the attorneys can start thinking about
what they want to counsel their clients, I understand this is
a decision --
Are they here?
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THE MARSHAL:
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THE COURT:
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We would wait for the defendants to enter the
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Thank you.
(Whereupon the defendants enter the courtroom at

9:30 a.m.)
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You can bring them out.
courtroom.
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Yes.
THE COURT:
Good morning, Mr. Defreitas and
Mr. Kadir.
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MR. DEFREITAS:
Good morning.
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MR. KADIR:
Good morning.
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THE COURT:
I was about to alert your attorneys as
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to a matter that has been brought to the Court's attention.
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First of all, we've got a couple of jurors who are running a
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bit late but they would be here.
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We have one juror, juror sits in seat number eight,

a woman, her mother called in this morning and spoke to my

She is very sick.
4637
deputy.
She is running a really high
fever.
probably another three days.
want to substitute one of the alternates at this juncture is
something that the parties are going to need to think about
and discuss.
The doctor thinks she may have the flu and will be out
So obviously, whether or not you
We are at the point of summations and charge.
Which, we were going to do the summations today and the charge
tomorrow.
So why don't -- perhaps I'll give you all a few
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minutes to discuss what you want to do with respect to the
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matter.
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(Whereupon counsel confer with their clients.)
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MR. KAMDANG:
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Mr. Defreitas.
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sit Alternate No. 1.
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THE COURT:
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MR. NKRUMAH:
We have discussed the issue with
It would be fine to release Juror No. 8 and
As to Mr. Kadir?
Your Honor, we had an opportunity to
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discuss the matter with Mr. Kadir, and we also agree to
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release Juror No. 8 and substitute Alternate No. 1.
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THE COURT:
The government?
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MR. JONES:
The government agrees.
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THE COURT:
Okay.
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That is what we will do then.
Alternate No. 1 will then became Juror No. 8.

We have a couple of other issues.
The Court, last
night, had posted the revisions that we had discussed on

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Friday.
While I was in the process of posting that, I
discovered that the government had posted an additional
request and a response to the defendant's request that the
Court include a defense theory charge if the Court were to
provide a charge that was requested by the government that
entrapment is not a defense in this case.
The additional charge requested by the government
deals with the aiding and abetting charge.
I don't understand
why, two months after the Court had provided its charge, it
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was only now requested.
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appropriate charge consistent with the evidence -- or at least
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consistent with the government's theory.
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I noted that it was not the
The Court has received a reply from counsel for
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Defreitas that it does not oppose the changed aiding and
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abetting charge.
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charge, modifying the charge, and the Court will provide a
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revised copy to the parties later on, at some point later on
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today.
The Court is in the process of changing the
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I have not heard from counsel for Kadir, although I
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requested a reply by yesterday evening as to the government's
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additional request to charge.
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MR. NKRUMAH:
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THE COURT:
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weekend? .
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something yesterday.
Is there a reply?
Your Honor, can we have one moment?
Why wasn't this considered over the
The parties knew, at least, that I was posting

I advised the parties to have everything

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submitted on Saturday so that I could work on it yesterday.
So the parties should have expected at least a filing by the
Court.
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MR. NKRUMAH:
Your Honor, we don't oppose the
government's additional charge on aiding and abetting.

THE COURT:
With respect to Defendant Defreitas'
request as to a limiting instruction concerning documents that
are admissible only against Defendant Kadir, there were -- the
three groupings of documents were laid out in defense
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counsel's filing, which is document 401, just for clarity of
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the record on the docket sheet.
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The proposed charge, while similar to the charge
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that I gave, is not quite like the charge that I gave.
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adapt it so that it is more in sync with the previous limiting
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instructions that I gave that the defense counsel requested.
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I will
However, as I mentioned in my ECF order last night,
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as to the documents that the parties did not have an agreement
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on, I ruled on that on Friday, that they were admissible as to
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both defendants.
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So to the extent that there are groupings of
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documents that are admissible as to both defendants, I don't
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think any charge is necessary because the jury can consider
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any and all of the evidence in connection with the charges as
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they see fit.
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arguments on the particular evidence.
And the parties are free to make their

4640
I don't see the need to have any inclusive charge as
opposed to a limiting instruction.
amended to date, also, to include that limiting instruction.
So the charge will be
With respect to, and just to clarify, although I
thought that I had made it clear on Friday, just to clarify, I
thought that -- I know that I had ruled on Friday because I
double checked the rough draft of the minutes from Friday.
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Which, by the way, has a lot of errors in there so

we'll to have fix those.
But those are legal proceedings and
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don't have anything to do with the fact introduction of
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evidence or anything like that.
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I had advised the parties that I would not include
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the government's requested entrapment is not a defense charge
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until after -- well, I would reserve a decision as to whether
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to include that until after summations and see what the
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party's summations were like.
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the government has called an entrapment like defense, then I
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agree with the government that the charge that is requested is
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appropriate.
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If the defense did raise what
I have to look a little bit closer at the case law.
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Since I didn't get the Government's response on that until
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yesterday, I didn't really have a chance to look at it.
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have to say that, from some of the research that I have done
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already in looking at the submissions that were made, I am not
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convinced that the defense charge as requested by the

But I
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defendants is appropriate.
Although, perhaps some mention that the defendants
here are claiming that they never joined any agreement to
engage in any of the charged conspiracies and that they never
intended to do so.
I have not thought about the language yet, but I am somewhat
persuaded by the balancing argument that defense counsel for
Defreitas raised in their papers.
I think in that streamlined way, perhaps.
Mr. Nkrumah, there is no indication in your papers
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that were faxed to chambers that they were served on anybody.
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Since the government didn't address it in their papers, it
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didn't seem to me that they had received it.
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MR. NKRUMAH:
I read the Court's order this morning,
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Your Honor.
I agree with the Court's order, and there's no
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objection on Mr. Kadir's part.
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THE COURT:
I don't understand why it wasn't filed
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electronically and then it would have automatically been
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served on everyone?
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MR. NKRUMAH:
That's correct, Your Honor.
It was
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just a little bit of confusion on my part.
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that part of your ruling where you said that you were going to
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hold the matter in abeyance, and because of that I believed
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that the filing in the chambers would give the Court an
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opportunity to decide whether the Court would allow us to --
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THE COURT:
I did understand
I do not accept ex-parte communications

in chambers, period.
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That was just inappropriate.
MR. NKRUMAH:
THE COURT:
I understand that, Your Honor.
I understand that all of our jurors are
present.
and briefly explain to her that she is now becoming Juror No.
8 so she will know to assume that seat when she comes in.
What I would like to do is bring in Alternate No. 1
Once they all come in, then the alternates will move
down one seat as they will change in their order.
objection to that procedure?
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MR. JONES:
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MR. KAMDANG:
No, Your Honor.
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MR. NKRUMAH:
No, Your Honor.
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THE COURT:
Any
No, Your Honor.
All right.
So I see that the small
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podium has been set up and the microphone has been set up.
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will give the jury, because the summations are expected by
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each side to be about two hours long, give or take -- I hope
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less than more -- but I'll give them a break after the
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government sums up.
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MR. JONES:
Just so you know how we will proceed.

Your Honor, we'd also ask that after the
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full panel has been seated, that the monitors be started up.
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I believe we will need them for our summations.
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THE COURT:
Okay.
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(Alternate No. 1 enters the courtroom.)
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THE COURT:
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Good morning.
Everyone may be seated.

ALTERNATE NO.1:
THE COURT:
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Good morning.
We have just brought you in separate
from the other jurors to let you know that unfortunately Juror
No. 8, te lady that sits diagonally from you, will not be able
to finish out her jury service.
So that means that, as our first alternate, you will
be replacing her for the duration of the trial.
So when we
are getting ready to bring everybody back in, when you all
come back in, that's the seat that you'll assume.
It's the
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one that is diagonally -- the one right next to the one in
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front of you.
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So you will now be known as Juror No. 8, okay?
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ALTERNATE NO. 1:
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THE COURT:
Yes.
I wanted you to know that up front so
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that there was no confusion.
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all you alternates are.
Now you understand how important
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ALTERNATE NO. 1:
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(Whereupon the juror leaves the courtroom.)
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THE COURT:
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bring in the rest of the panel.
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THE COURT:
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(Whereupon the jury enters the courtroom at 9:50
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Yes.
If this there is nothing else, we will
Jury entering.
All rise.
a.m.)
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THE COURT:
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Good morning, ladies and gentlemen.

THE JURY:
THE COURT:
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Good morning.
Welcome back.
I hope that you had a
nice long weekend and enjoyed it.
see, one of our jury members is not able to proceed with the
trial.
8.
understand how important your presence throughout the trial
is, because it does permit us to continue to move the case
forward without interruption and to proceed to its conclusion
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Unfortunately, as you can
As a result, our Alternate No. 1 will now be Juror No.
You see the importance of alternates.
without having to start all over again.

So this means I'm going to ask our alternates in the
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back, you're all going to move down one.
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going to change.
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Alternate No. 1 and so on, okay.
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Our alternates now
Your numbers are
And then Alternate No. 2 will become
I'm also going to ask the parties whether now,
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having reseated the jury, they agree all of the jurors are
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present and seated properly.
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MR. JONES:
Yes, Your Honor.
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MR. KAMDANG:
Yes, Your Honor.
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MR. NKRUMAH:
Yes, Your Honor.
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THE COURT:
I'm also going to ask you, ladies and
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gentlemen, if you would be so kind, to remove the monitors,
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take them out and turn them on, please.
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you will need them during the summations.
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It is expected that
Now, ladies and gentlemen of the jury, the case

4645
having been closed, we have now reached that point where you
are about to hear the summations or the closing arguments of
counsel.
Following the summations, I will instruct you as to
the principles of law that will guide you during your
deliberations and assist you in rendering your final verdict.
It is our law that the government present its
closing arguments first.
up.
Then the defense counsel will sum
And then the Assistant United States Attorney has the
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opportunity to rebut.
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prosecution has the burden of proof.
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It is done in this order because the
In their summations, counsel will review the
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evidence received at trial and suggest that you draw certain
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inferences or conclusions from the evidence.
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purpose of such summations.
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attorneys are not evidence.
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That is the
Arguments or statements by the
However, you may accept or reject these arguments
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either in whole or in part depending on whether you find the
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particular attorney's summary of the evidence is accurate and
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the inferences and conclusions you have been asked to draw are
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logical and warranted.
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I remind you that the jurors alone are the sole and
exclusive judges of the facts in this case.
We will now proceed with the summations of counsel.
We'll begin with the government, Ms. Ahmad.

SUMMATION - AHMAD
You may proceed.
(Summation - Ms. Ahmad.)
MS. AHMAD:
Good morning.
Thank you, Your Honor.

One month, hundreds of hours and
countless recordings later, the evidence at this trial has
shown exactly what Ms. Berger said it would when we first
began.
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The two men at that table are being called to

account because in 2007 they had a terrible criminal plan, a
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plan to teach America a lesson.
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of New York.
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A plan to destroy the economy
A plan to take innocent lives.
By now, you know the details of their lesson plan as
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well as anyone.
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tanks and pipeline at JFK Airport causing an explosion they
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expected would take out half of Queens.
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The defendants wanted to blow up the fuel
They spent months and months holding meeting after
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meeting and making phone call after phone call, travelling to
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country after country, to do everything they could to make
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their nightmare a reality.
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For their crimes, the defendants are charged with
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the conspiracy to destroy JFK that violate several federal
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laws.
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little while.
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crime, which is that the defendants agreed to participate in a
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plot to blow up the airport.
I'll go over the technical elements of each charge in a

But for now, let's focus on the core of each

SUMMATION - AHMAD
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The two elements common to all of the conspiracy
charges that the defendants face are, first, that two or more
people agreed to bomb the fuel tanks and pipelines at JFK
Airport.
of that agreement.
And second, that each defendant was himself a member
As to the first issue, whether or not there was an
agreement, there has been almost no dispute at this trial that
there was indeed a plot to blow up the full tanks at JFK
Airport in existence between 2006 and 2007.
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It is pretty much indisputable.
All the evidence
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you've seen at this trial has shown you that there were people
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scheming to reduce JFK to rubble.
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testimony, documents, surveillance photos.
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to Russell Defreitas, a confession.
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overwhelming.
And it's evidence like

And with respect
That evidence is
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So what you're faced with here is each defendant,
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after being caught re-handed on tape plotting their attack,
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trying to escape responsibility for his own actions saying
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sure, some people wanted to blow up the airport but I wasn't
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one of them.
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usually saying the wrong things.
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I was just in the wrong place at the wrong time,
Don't buy it.
All of the evidence you've seen, much
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of it in the defendants' own words, has proven beyond any
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reasonable doubt that Russell Defreitas and Abdul Kadir were
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members of a plot to destroy JFK.

SUMMATION - AHMAD
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They were more than mere members.
They were eager
and willing participants.
Each was motivated, among other
things, by a desire to avenge the oppression of Muslims in the
world.
Each made vital contributions to the plot's goals.
Let's talk for a minute about each of the
defendants.
the man who came up with the idea for this plot.
has shown you that Russell Defreitas is a classic homegrown
extremist.
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First, Russell Defreitas.
As you know, he was

The evidence
As a naturalized U.S. citizen, he's lived quietly in
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the city for years not attracting any special attention.
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managed to make a decent life for himself.
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supervisor at JFK.
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entrepreneurial business ventures like exporting goods from
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Guyana.
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He
He's a cargo
He started a non profit.
He had several
But the years Russell Defreitas has spent in this
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country were years of quiet seething rage.
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left him resentful and angry.
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building until when, in 2006, it boiled over.
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into concrete action.
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His experience has
His anger had been building and

Boiled over
Russell Defreitas gave voice to that anger by
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devising a plot to attack JFK and by recruiting people like
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Donald Nero, Talib Rutherford, Abdel Nur and Abdul Kadir to
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join him.
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2006, Defreitas made clear that he'd been planning for years,
And although he introduced the scheme to others in

SUMMATION - AHMAD
4649
if not decades.
Let's listen to a few examples of that.
(Audio played for the jury.)
(Audio stopped.)
MS. AHMAD:
You know there are many more examples,
but I'm not going to make you sit through all of them.
You
don't have to speculate what drove Russell Defreitas to this
violent extreme.
clear.
The recordings in evidence make that crystal
You have it in his own words.
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Defreitas talks about his anger at the treatment of
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Muslims around the world, his resentment at having been made
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to load a missile bound for Israel and his rage at the way he
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was treated at JFK Airport and in the United States.
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(Audio stopped.)
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MS. AHMAD:
Well, you just heard him talk about what
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made Russell Defreitas desperate and determined to exact
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revenge by attacking JFK Airport, the place that caused him so
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much pain.
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him say.
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total devastation would satisfy him.
He wanted to "get those bastards," as you heard

He made clear that nothing less than the airports
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Again, in his own words.
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(Audio stopped.)
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MS. AHMAD:
When you listen to him on these tapes,

SUMMATION - AHMAD
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two things, I would submit to you, are undeniable.
He is
angry and he is determined.
United States and the United States' treatment of Muslims
around the world, and determined to seek revenge by destroying
something that he knows American, and particularly New
Yorkers, hold dear.
Angry at his treatment in the
(Audio stopped.)
MS. AHMAD:
He wants the whole country to be in
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mourning.
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Defreitas took callous advantage of his ability to blend in
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because he was a citizen and not a foreigner, as he put it.
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He thought his actions would arouse far less suspicion.
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In devising his attack against the U.S., Russell
He said, "They don't expect nobody in this country
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to do things like this.
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foreigners, but not on me."
17
They have their eyes on the
His anger and determination come through not only in
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the evidence that you've seen of this scheme, his idea to
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explode the fuel tanks and pipelines at JFK, but also in the
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other ideas that he's had about attacking the airport.
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These are simpler ideas, not ones, to use his words,
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"dwarf 9/11," like the fuel line pipeline attack, but
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terrorist attacks that would have, nonetheless, caused
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significant damage and destruction.
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For example, here Defreitas talks about placing a

SUMMATION - AHMAD
4651
bomb in a mail bag delivered to the post office at the
airport.
witness, how much mail goes in and out of the airport, and it
looks like Mr. Defreitas had some role in distributing that
mail, and he thought about how easy it would be to stick a
bomb in the mail bag and walk away and let the whole thing
explode behind him.
You heard from Peter Carbonaro, the Port Authority
(Audio stopped.)
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MS. AHMAD:
Listen to what he just said.
He wants
11
to use his knowledge of the airport to help someone sneak into
12
the passenger terminal with a bomb.
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person can get in, by pretending to be a lost passenger.
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he knows exactly how they should accomplish that disguise,
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with a blank ticket, like, apparently, the one he's holding in
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his hand.
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just how determined he was to see it happen.
He knows exactly how that

And
The amount of thought he's put into this shows you
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Faced with a mountain of evidence in the form of his
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own words, of his own tape recorded words of anger towards the
20
United States, and own tape recorded words of determination to
21
cause devastating harm, Russell Defreitas mounts the only
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defense he can.
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again, but I didn't mean it.
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Okay.
That's it.
I've said it over and over
It was just empty talk.
Ladies and gentlemen, that is ridicules.

this in context for a minute.
Let's put
These statements Defreitas now

SUMMATION - AHMAD
4652
claims to be amazed that anyone took seriously weren't made in
the heat of the moment.
It's not like you find your kid brother borrowed
your car and crashed it and you yell, I'm going to kill you.
Everybody realizes you are not actually going to kill your
brother.
moment.
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You're just blowing off steam in the heat of the
That is not what we're are dealing with here.

Russell Defreitas' words on these tapes are not threats made
10
in the heat of the moment.
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collected and deadly serious.
12
Russell Defreitas is calm, cool,
How do you know that?
First, he says he is.
He
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says it again and again and again.
14
say it, you can hear the determined tone in which he states
15
his intentions.
16
Plus, you've seen evidence of the actions, the concrete steps
17
that he took to accomplish his goal.
18
And in listening to him
These aren't offhand, off the cuff remarks.
Everything he tries to do to see this through, every
19
step he takes makes clear to you that what we hear on those
20
tapes are not the words of someone just letting off steam.
21
Russell Defreitas is doing everything he can to make his
22
nightmare a reality.
23
Let's talk for a minute about the other defendant,
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Abdul Kadir.
Kadir is a man in a different mold.
25
prominent citizen in Guyana; a politician and a religious

He's a
SUMMATION - AHMAD
4653
figure.
and he heads the Guyana Islamic Information Center.
He's been mayor of his own town, member of parliament
He told you on the stand that he is recognized as a
brother of the Shiite with some standing.
Defreitas put it, Kadir has voice and he has authorities, and
he lent that voice and authority to this terrorist plot.
As Russell
A man of that position has to carry himself
differently, and Kadir does.
Kadir, like Defreitas, though,
has been seething and scheming for years.
His grievances with
10
the West are more philosophical than personal.
11
with their entire way of life.
12
He disagrees
As a devoted follow of Ayatollah Khomeini and a
13
believer in the Shiite Iranian worldwide revolution, it is his
14
belief that Shiite Muslims around the world should rise up and
15
throw off the yoke of their Western oppressors.
16
Now, let's look at the sermons of Ayatollah Khomeini
17
found in Abdul Kadir's house.
18
witness stand that he accepts the supreme leader's words of
19
religious law.
20
He told you when he was on the
Here is what he says:
"As long as the interests of
21
the earth devouring America, this enemy of the deprived of the
22
world, exists, the struggle will continue.
23
determined to destroy their interests.
24
difficult struggle against America."
25
Our country is
We have begun a
Now, Kadir told you that as a religious edict, the

SUMMATION - AHMAD
4654
words of Ayatollah Khomeini are not his to agree or disagree
with.
does agree with these because the same ideas are reflected in
Kadir's own writing.
He just accepts them as religious law.
But you know he
This is another document found in his house where he
talks about the worldwide revolution against falsehood,
tyranny, subjugation, oppression, and he says, "The day of
resurrection shall not approach until the Muslims engage the
Yahud in a war."
10
And we know that "Yahud" means Jews.
And then, "This is the first time in history that
11
the Muslims have taken it upon themselves to fight Yahud.
12
Before, Yahud was always the aggressor."
13
Over the years, Kadir developed extensive contacts
14
with like minded people around the globe.
15
extremist views.
16
organizations who'd been considered attacking JFK long before
17
Russell Defreitas brought "The Chicken Farm" to Abdul Kadir.
18
People with and
These contacts were the types of
Remember, Steven Francis told you that when they
19
first presented Kadir with the plot, he said that he already
20
knew some people with interest in that same location he was
21
going to reach out to.
22
Because of his background and because of his
23
position and his prominence, Kadir behaved differently than
24
Defreitas in seeing this plot through.
25
careful.
He's careful and
He's not as loose-lipped as Russell Defreitas.

You
SUMMATION - AHMAD
4655
can tell that, and you can see the care with which this man
chooses his word, both in the recordings and from his
testimony.
Remember when he couldn't answer yes or no directly
to whether he's a member of Hezbollah.
He wanted to set back
and clarify before he answered.
Defreitas about how the world of international intelligence
gathering works because he's been providing intelligence to
Iranian government for years.
Kadir has a better sense than
10
He knew who could be watching, he knew, as he put
11
it, that if they wanted to avoid getting caught scheming to
12
blow up JFK Airport, caution was the watch word.
13
advice he gives to Defreitas and Francis travelling to
14
Trinidad, he says, "You have to be very careful when you
15
introduce something as heavy as the chicken and the egg."
16
Chicken Farm.
17
JFK.
Look at the
The
And you know, again, that's the plot to attack
"Caution is one of the watch words, I would say."
18
But as the evidence shows, Kadir wasn't cautious
19
enough.
20
he said on the witness stand changed that one bit.
21
you to believe that the only reason he agreed to help Russell
22
Defreitas and Steven Francis to attack JFK Airport is because
23
he saw a good business opportunity in it for himself.
24
25
He was caught on tape red-handed.
And nothing that

He wanted
Ask yourself, what kind of person comes face-to-face

with committed terror, and says, you know, I wasn't into that

SUMMATION - AHMAD
4656
idea about blowing up JFK Airport, but he seemed like a great
guy to get into the import/export business with.
The very idea is laughable.
And it is laughable
because it is patently false.
it's unraveled before your very eyes during his testimony, but
we'll get into that later.
It's also laughable because
Suffice it to say, for now, Kadir was in whole hog,
and everything he said on that stand is a last minute, after
the fact attempt to talk his way out of the clear evidence of
10
his involvement in this plot and the clear evidence of his
11
guilt.
12
Before I move on to the element in the charge, let
13
me say one more important thing.
14
Muslims.
15
religion form some part of their motivation to commit these
16
crimes.
17
case.
18
it against them in any way.
19
Both of these defendants are
You have heard on the tapes that their view of their
That is the only relevance their religion has to this
You shouldn't consider it in any other context or hold
Along the same lines, don't let anyone get up here
20
and tell you that the government is singling these men out
21
because they're Muslims.
22
did, not who they are.
23
religion, is the reason they stand before you.
24
25
They are here because of what they
Their terrorist plot, and not their
So let's talk about that terrorist plot.
For their
participation in the plot to bomb JFK, the defendants are

SUMMATION - AHMAD
4657
charged with several counts of conspiracy.
Now let me remind you of what Ms. Berger said in her
opening statement.
members of any particular terrorist group like Al Qaeda or
Hezbollah.
their plan or even being close to getting it off the ground.
The defendants are not charged with being
They're also not charged with actually executing
They're charged with agreeing to bomb the fuel tanks
and pipelines at JFK.
A conspiracy is just an agreement
between two or more people that they will violate the law.
10
The very act of agreeing to do something as horrific as bomb a
11
busy international airport itself violates the law.
12
It doesn't matter whether the plan succeeds or how
13
close it was to succeeding.
14
crime that each of these two defendants are guilty of before
15
they even attempted to carry out the plan.
16
the moment they agreed with someone else to conduct the
17
terrorist act at JFK.
18
The agreement is the crime.
The
They were guilty
Everything you've heard about the steps that they
19
actually took to make that plan a reality is good evidence of
20
their agreement.
21
prove the charges against them.
22
But actually, it isn't even necessary to
Russell Defreitas was guilty the moment that he
23
agreed with Donald Nero to formulate a plan to attack JFK to
24
recruit.
25
into the plot; take four surveillance trips to JFK airport;
Everything he did after that; recruit Steven Francis

SUMMATION - AHMAD
4658
make a surveillance video so he and his coconspirators could
better figure out the composition of the tanks; seek out
well-known terrorist operatives like Adnan Shukrijumiah and
Yasin Abu Bakr to present the plan to; agree with Kareem
Ibrahim and Abdul Kadir to switch course and instead seek
backing from the revolutionary leadership in Iran.
All of that isn't even necessary to prove his guilt
of the charged crime.
All he has to do to be guilty of
conspiracy is agree to help plan the attack.
And after all
10
the evidence that you've seen, there's no reasonable doubt
11
that that's exactly what he did.
12
The same is true about Abdul Kadir.
He was guilty
13
the moment he agreed with Russell Defreitas to help plan the
14
attack on JFK Airport.
15
advising they get Google Earth satellite pictures to better
16
understand the tank layout; raising the idea with his contacts
17
in Venezuela and Iran; providing engineering advice; arranging
18
for Defreitas and Francis to meet Abu Bakr in Trinidad;
19
allowing his mock bank account to be used to launder the funds
20
for the attack; agreeing to present the plot to the
21
revolutionary leadership in Iran, and going so far as getting
22
on a plane to do just that, none of that is necessary to
23
establish Kadir's guilt.
Everything that he did after that,
24
He was guilty the moment he sat in his living room
25
with Russell Defreitas and Steven Francis and agreed to help

SUMMATION - AHMAD
4659
them further their planned attack.
That's my basic outline of conspiracy law.
And if
anything that I say is contrary to what Judge Irizarry tells
you later, ignore me and follow her.
Let's move on now and talk about the defendants'
guilt.
their guilt in this case comes straight from their own mouths.
You've heard it from them.
As you know by now, the most powerful evidence of
First, you heard them speaking about the plot in the
10
tape recorded conversations that are in evidence.
11
clear about one thing.
12
the accuracy of those recordings.
13
when a transcript says Russell Defreitas and Abdul Kadir are
14
speaking, it's Russell Defreitas and Abdul Kadir speaking.
15
Abdul Kadir, in fact, admitted that when he was on the witness
16
stand.
17
Let's be
You haven't heard any dispute about

No one has disputed that
Despite the recordings, you also heard from
18
Detective Addonizio about Russell Defreitas' confession after
19
he was arrested.
20
He tried out a few different stories on for size, but once he
21
saw how much evidence the FBI had, he realized they weren't
22
going to fit.
23
First Defreitas tried to lie his way out.
And eventually, in the face of that evidence,
24
Defreitas admitted that he had plotted to bomb JFK Airport and
25
that it had been his idea from the very beginning.

SUMMATION - AHMAD
4660
The one false story he didn't try on, by the way, is
the one he's come up with for this trial, that he didn't mean
it.
attack JFK airport.
That he was only pretending to engage in a conspiracy to
Remember Detective Addonizio told you that Russell
Defreitas never said this was all just talk.
wasn't serious, he didn't mean it.
defense, where was it three years ago when Russell Defreitas
was arrested?
10
He never said it
So this empty talk
If it were true that he never meant anything that he
11
said about blowing up JFK, he would have told that to
12
Detective Addonizio.
13
surprise that law enforcement had taken his action seriously
14
because he knew he was serious.
15
He didn't.
He never expressed any
Last in the category of the defendants' own words
16
that you've heard at this trial, you heard Defendant Abdul
17
Kadir testify.
18
there, a few different contradictory good stories.
19
He tried to spin a good story when he was up
But in the end, Kadir admitted what he could not
20
deny, that he had meetings and conversations with Russell
21
Defreitas and Steven Francis about the plot to attack JFK
22
Airport.
23
to get it off the ground.
24
25
And that he gave them advice, good advice about how
He couldn't deny that because most of it was on tape

and testified to.
All of that straight from the horse's mouth

SUMMATION - AHMAD
4661
evidence has proven to you beyond a reasonable doubt that the
defendants are guilty of conspiring to blow up the fuel tanks
and pipelines at JFK Airport.
Their goal was to destroy the economy of the United
States.
lives, and they didn't care.
lives lost would be mere collateral damage.
8
9
They knew that accomplishing that goal would take

In their view, the innocent
Remember what Donald Nero told you when he

testified, that the actual idea of the plot was to cause
10
serious economic damage to the U.S. He said they talked about
11
how much destruction there would be at the airport.
12
because there was so many people going in and out of there,
13
there would also be loss of life.
14
discussed people getting killed; women, children and pregnant
15
woman.
16
sacrifice they had to make being mere collateral damage.
17
And knew,
He said they specifically
And talked about all of that being a necessary
Let's talk for a minute about Donald Nero.
You'll
18
remember that he was one of the very first witnesses in this
19
case.
20
Defreitas proposed the idea of committing a terrorist attack
21
at JFK attack to him, and he agreed.
22
agreement, Donald Nero pled guilty to conspiracy to attack a
23
public transportation system.
24
25
He told you that in the summer of 2006 Russell
And because of that
Now, in the slides we just looked at, Nero was

describing what, he, Nero, told Steven Francis about the plot

SUMMATION - AHMAD
4662
as it existed in late 2006.
Nero and Rutherford had already started their plan to attack
JFK before Defreitas ever recruited Steven Francis into it.
Because remember that Defreitas,
Now, you'll remember that in his opening statement
Mr. Kamdang told you that Russell Defreitas was just a bitter
old man who no one could possibly take seriously.
that idea to rest.
8
9
Let's put
Exhibit A of somebody taking Russell Defreitas

seriously:
Donald Nero.
Donald Nero was radicalized by
10
Russell Defreitas.
11
and told you that Russell Defreitas brought him the plot to
12
attack JFK and he agreed to join it.
13
Mr. Defreitas'.
14
same thing.
15
that it was his idea to attack the airport.
16
He sat right there on that witness stand
Whose idea was it,
And you know what, Mr. Defreitas says the
In his confession, he told Detective Addonizio
Now, none of this excuses Nero's conduct.
You don't
17
have to be the one who came up with the idea in order to be
18
guilty of conspiracy.
19
own actions.
20
Nero's a grown man, responsible for his
And he took responsibility by pleading guilty.
Even
21
though he left the plot to blow up JFK, he took responsibility
22
for what he'd done by pleading guilty to the same charge as
23
Count One in the indictment before you, and that is the crime
24
of conspiring or agreeing, in all seriousness, to bomb JFK
25
Airport.

SUMMATION - AHMAD
4663
Well, Russell Defreitas is guilty the moment he
agreed with Donald Nero to bomb the airport.
He didn't stop
there.
reality.
guilt, they are helpful in your understanding of intent.
He took many many steps to make his nightmare a

While the steps, again, are not necessary in the
One of those steps, the unluckiest one for him it
turns out, was recruiting Steven Francis into the plot.
Donald Nero told you that when Defreitas left Guyana in May
2006, his goal was to find people in the U.S. who would help
10
advance the plot.
11
Nero described what all of their goals were at that
12
point in time.
13
to the United States and try to recruit financial and human
14
resources for the attack.
15
Francis.
16
He said that Defreitas was going to come back
Defreitas settled on Steven
Let's talk about how he chose Francis, because
17
another way you know how serious Russell Defreitas was, how
18
you know he wasn't shooting the breeze, is by seeing how he
19
gets the people he brings into this plot.
20
empty talk, he wouldn't probably care that much about who he
21
was talking with.
22
it wasn't empty talk.
23
committing a horrific crime.
24
25
If it was just
But he cared a great deal because he knew

It was serious discussion about
Because it's the nature of criminal conspiracy for

people to be careful about who they will trust and bring into

SUMMATION - AHMAD
4664
the crimes, Detective Addonizio told you that he tried very
hard to find someone who'd have a good chance of being brought
into Russell Defreitas' inner circle.
France precisely because Francis knew people in common with
Defreitas.
And he selected Steven
Defreitas didn't bite right away, though.
He waited
until he got a chance to meet Francis a few times.
asked their mutual acquaintance, Dr. Ali, if he would vouch
for Francis.
10
And he
Once Defreitas decide to trust Francis, he
11
introduced him to the plan.
12
associates in Guyana to plan a terrorist attack in the United
13
States that would rival 9/11.
14
of those associates over the phone, Nero and Ponytail.
15
they were also cautious about whether or not to trust Francis.
16
They wanted to make sure he had the proper character and
17
commitment to their cause.
18
Told him he'd been working with
He introduced Francis to some

And
You'll remember that Donald Nero caught Francis
19
completely off guard when he tried to assess his commitment to
20
Jihad by asking if he wanted to die a martyr.
21
22
(Audio stopped.)
23
MS. AHMAD:
You know what dying as a martyr means.
24
Steven Francis told you.
He said it means dying in Jihad;
25
dying fighting in the cause of God or by suicide attack.

And
SUMMATION - AHMAD
4665
Nero told you the same thing, he said being a martyr means
that your faith is really strong.
the sake of God.
When you die, you die for
Eventually, they decided to truth Francis enough to
deal with him.
late fall of 2006, and you'll remember that it was the month
of Ramadan in the Islamic calender, as you heard both Nero and
Francis testify.
But they wanted to meet him in person.
Francis and Defreitas went down to Guyana.
So in
Even at
10
that stage, the conspirators are cautious about how much
11
they're willing to reveal to Francis until they get to know
12
him better.
13
until they're sure he's on board and committed, the identity
14
of the plots leader at the time, Talib Balai Rutherford.
15
Most importantly, they're not willing to tell him
This is also seen again and again, when someone
16
prominent and well-known is involved, be it Talib Balai
17
Rutherford, a successful businessman in Guyana, or Abdul
18
Kadir, a former mayor and prominent religious figure, the
19
other plotters take care to keep their identities as secret as
20
possible.
21
And that's because they know that in the small
22
county of Guyana names like Talib Rutherford and Abdul Kadir
23
are immediately recognizable and they don't want to draw
24
unnecessary attention to the plot.
25
So even though Rutherford has been directing the

SUMMATION - AHMAD
4666
plot for sometime 2006 rolls around, Defreitas and Nero don't
tell Francis about his involvement.
to casually run into Rutherford at the mosque.
Rutherford decides Francis passes muster, they have further
discussion about the attack.
They arrange for Francis

And once
The main thing that the plotters are grappling with
at this point are what type of explosives they need to explode
the fuel tanks, and how to get their hands on it.
they were certain about, they knew what kind of explosion they
One thing
10
wanted.
11
see, so devastatingly high that it could be seen from far far
12
away.
13
Shining Light.
14
They wanted an explosion so massive that it could be
That's why Rutherford suggested they call the plot The
Nero, told you here that Rutherford came up with the
15
code name The Shining Light.
16
thing to Detective Addonizio.
17
The Shining Light.
18
Defreitas confessed the same

He said Rutherford came up with
They knew what kind of explosion they wanted, but
19
they weren't 100 percent sure about how to accomplish it.
20
first thing they needed to figure out was kind of explosive
21
could penetrate the fuel tanks.
22
chemicals or dynamite or a special gel form of dynamite.
23
The
There was debate about using
Francis told you there was a debate whether the
24
tanks were made of titanium, in which case regular dynamite
25
wouldn't work and they'd need something more powerful.

And
SUMMATION - AHMAD
4667
Nero told you the exact same thing.
The bigger issue was how to get their hands on those
explosives.
expert, Adnan Shukrijumiah, an Al Qaeda bomb maker with ties
to the Caribbean.
particular expertise within Al Qaeda, bomb maker.
told you that they wanted Shukrijumiah because he would have
skills known of them had.
make bombs.
10
And for that, they were going to turn to the
Matt Levitt told you Shukrijumiah's

And Nero
He knew how to operate guns and
The plotter's decision to present their plan to
11
attack JFK airport to be a deal Shukrijumah tells you
12
everything you need to know about their intent.
13
Nero and Rutherford were looking for a seasoned terrorist in
14
the Caribbean with explosive experience.
15
connections and the know how to make their nightmare a
16
reality.
17
Defreitas,
Someone with the
What did Dr. Levitt tell you about the man they
18
sought out?
He is a senior Al Qaeda operative with explosive
19
expertise and ties to the Caribbean.
20
wanted list.
21
West, including the United States and Europe.
He is on the FBI's most
He is accused of plotting attacks against the
22
In the same way that the plotter's decision to
23
present their plan to Mother Theresa would have made you
24
think, hey, this probably isn't a deadly terrorist attack
25
after all.
Their decision to present it to Adnan Shukrijumiah

SUMMATION - AHMAD
tells you the exact opposite.
the United States.
4668
They were determined to attack
And Shukrijumiah was a good choice.
He was the only
senior Al Qaeda with ties to their home country, Guyana and
Trinidad.
around 2006 and 2007.
And he was rumored to be hiding in the Caribbean

All they needed to do was find him.
They decided that the one person likely to know
Shukrijumiah's whereabouts was Yasin Abu Bakr.
The most
significant homegrown radical Islamic terrorist the Caribbean
10
has ever known.
11
that includes the suicide bombing of police headquarters and
12
the shooting of a head of state.
13
This is a man with a track record of violence
They decided to send an envoy to meet him with their
14
coconspirator Abdel Nur.
15
ties to Abu Bakr.
16
and he had played a role in arranging for JAM members to go to
17
Libya to receive weapons training.
18
He was one of the founding members of JAM
Now, lucky for us, the plotters never found
19
Shukrijumiah.
20
him.
21
about their intent.
22
They chose Abdel Nur because he had
But that doesn't change their decision to find
That decision tells you everything you need to know
Now, back to those meetings in the fall of 2006.
23
Everyone eventually realized that they couldn't make a
24
determination as to what kind of explosive they needed until
25
they had a better sense of what the tanks were made of.

SUMMATION - AHMAD
4669
So in order to accomplish that, Rutherford told you
-- I'm sorry, Nero told you that Rutherford decided that
Francis and Defreitas should go back to the United States and
take close up pictures of the tanks.
they did.
And that's just what
In January 2007 Francis and Defreitas took four
trips to the airport in order to determine the layout and the
composition of those fuel tanks.
area of the airport, where Peter Carbonaro, from the Port
They drove around the back
10
Authority, told you the public almost never has reason to go.
11
They went there to get as close a look as possible.
12
These are the two fuel farms that Carbonaro told you
13
about.
14
the right is a satellite fuel farm.
15
of the bulk fuel farm -- I don't know if you can see from how
16
small it is on the map, but the fuel farm is bordered by
17
Bergen Basin.
18
across Bergen Basin from the fuel farm to get as good a look
19
as possible.
20
The one on the left is a bulk fuel farm and the one on
In order to get footage
So Defreitas and Defreitas drove on the road
Now, before I start, these are three exhibits
21
compiled into one.
The video inside the car is Exhibit 212.
22
The video overhead where you can see a car from the sky is the
23
FBI surveillance video Agent Murkler told you about, it's
24
Exhibit 63.
25
Defreitas took from inside the car when they were driving
And the smaller video is the one Russell

SUMMATION - AHMAD
4670
around.
Please show it.
(Audio is played for the jury.)
(Audio stopped.)
MS. AHMAD:
Mr. Russell Defreitas says good enough.
The video at that point is good enough.
Good enough for what?
Good enough to see how the fuel system they planned to bomb
was laid out.
were made of so they could pick the best possible bomb.
Good enough to determine what the fuel tanks

Good
10
enough to figure out the best way to reach those tanks without
11
getting caught.
12
terrorist attack.
13
Good enough to help them plan the devastating
That body of water you saw them driving by, that,
14
again, was Bergen Basin.
15
on where Russell Defreitas talked about the operatives who
16
were actually going to conduct the attack being able to slip
17
in and out by water, that's the body of water he's talking
18
about.
19
You remember all those tapes later
You heard a lot of questions whether Defreitas and
20
Francis drove in restricted areas when they were taking these
21
video, but what is the relevance of that?
22
Francis wanted to get a close up views of the tanks and
23
Defreitas and his coconspirators planned to bomb.
24
25
Defreitas and
What makes it illegal is not whether they drove in a

restricted area.
What makes it illegal is the fact that they

SUMMATION - AHMAD
4671
planned to place bombs there.
those close up shots without getting caught.
risk getting caught by driving in a restricted area when it
wasn't necessary to get the pictures.
side of a fence you place a bomb on, probably going to do the
same amount of damage.
Defreitas' plan was to get

So why would he
And you know, whatever
Those four surveillance tapes got the plotters all
the information they needed about their targets.
close up shots to help figure out the fuel tank composition.
10
They got
That's the shot from the actual video.
11
As soon as they were done, Defreitas was anxious to
12
get to Trinidad to speak with Abu Bakr about finding
13
Shukrijumiah as soon as possible.
He wanted to go
14
immediately, as soon as possible.
The sense of urgency tells
15
you how determined he was.
16
Steven Francis, Nero and Rutherford were pleased.
17
They saw the video.
18
What are they pleased about?
19
they've found a vulnerable area at JFK, a chink in America's
20
armor.
21
Rutherford said, "Praise be to God."

They're happy because they think
But Defreitas says, the only time, everybody's
22
security focus is at the passenger terminal.
23
know about the fuel tanks.
24
a few hundred yards away.
25
Very few people
They're largely unguarded and just

SUMMATION - AHMAD
(Audio stopped.)
MS. AHMAD:
4672
Nero told you that the tanks were such
an unknown target, that without Defreitas having told him what
he was looking at, he wouldn't have known they were connected
to JFK.
This is what Mr. Defreitas brought to the table,
knowledge of the soft spots; knowledge of the most vulnerable
areas of the airport; knowledge about how to sneak in and out
through back routes without being caught; knowledge he'd been
10
building for years.
11
He wasn't an explosive expert and he knew some of
12
the high tech stuff about how to blow up the airport would be
13
beyond him.
14
strike a devastating blow to the U.S., and he was happy about
15
it.
But he also knew he had come up with a way to
16
17
(Audio stopped.)
18
MS. AHMAD:
He's thinking about after the attack.
19
He's thinking about after JFK has been reduced to rubble and
20
he's planning to walk around town smiling.
21
While the video initially makes the plotters happy,
22
it eventually breaks them apart.
You heard about Defreitas
23
getting suspicious that Rutherford was going to take the idea
24
of the attack to someone else and cut him out.
25
to Defreitas deleting it from Rutherford's computer which sent

How that led
SUMMATION - AHMAD
4673
Rutherford into a rage.
And you heard around that same time, Nero decided he
didn't want to be involved any longer because he was nervous
about meeting Abu Bakr.
Nero told you that, "He got really upset and angry with me.
He called me a couple of names and said you can never properly
be in a mosque.
all of it."
That sent Defreitas into a range.
You're going to be shot in your joints for
Defreitas questioned the strength of Nero's faith
10
and threatened to shoot him for backing out of the attack.
11
Not exactly the response you'd expect from someone who's just
12
engaged in empty talk.
13
Now, losing a couple of members wasn't much of a set
14
back to the conspiracy.
15
able to start looking for other like minded people.
16
no mistake about what I mean about "like minded."
17
people who would be willing and able to attack the United
18
States.
19
Defreitas, through Abdul Wahab, was

And make
He wanted
People like Shafik, who Steven Francis told you
20
about.
21
a great asset because of his connections to Al Qaeda.
22
Steven Francis told you Defreitas felt Shafik would be
Now, it doesn't take long before they land at the
23
door of Abdul Kadir, armed with the surveillance video and
24
ready to present their plan of attack.
25
Now, Steven Francis didn't record this meeting

SUMMATION - AHMAD
4674
because, he told you, he was nervous for his safety.
you the first time he'd met Kadir, Kadir put him in a martial
arts headlock and that made him aware.
He told
You'll remember that Francis was cross examined
endlessly about this decision.
expressed about his motive.
permission he'd received from Detective Napoli not to wear a
wire.
also asked a lot of questions about why he didn't have Francis
10
11
There was a lot of skepticism
He kept being asked what kind of
And then Detective Napoli took the stand and he was
wear a wire.
The implication of all of that was that Francis was
12
making up everything that took place at the meeting because he
13
didn't have it on tape.
14
later Abdul Kadir got on the same witness stand and
15
corroborated almost everything Francis said.
16
The irony of that is that one week
Francis told you that at their first meeting Kadir
17
put him in a martial arts grip.
18
Francis told you that they sat in Kadir's living room and
19
talked about business opportunities for awhile.
20
told you the same thing.
21
Kadir said the same thing.
And Francis
Francis told you they played the surveillance video
22
for Kadir on his computer.
23
Francis told you that when they were watching the video, Kadir
24
suggested they go on Google Earth to get better satellite
25
images of the tanks.

Francis told
SUMMATION - AHMAD
4675
you Kadir agreed to present the plot to his radical contacts.
And Kadir said the same.
The main point Kadir and Francis disagree on is
whether somewhere in-between advising them to get better
satellite images of the tape and telling them that he would
reach out to his radical contacts abroad to present the plot,
in-between all of that Kadir said, I, of course, am certainly
not interested in this plan.
How plausible is that?
All of the evidence you've seen in the form of later
10
conversations between Kadir, Defreitas and Francis makes clear
11
that no one was operating under the assumption that Kadir
12
wasn't interested.
13
said that to him.
14
conversations that they had, which are on tape and which you
15
heard, would make any sense.
16
Quite the opposite.
There's no way he
Because if he had, none of the further
Francis also told you that Kadir came up with a new
17
code name for them to use when they were talking about the
18
plot.
19
about the old code name, The Shining Light.
20
extra cautious, and we've seen him be throughout.
21
Kadir was worried because Rutherford and Nero knew

He was being
And Francis told you that Kadir came up with the
22
code name, The Chicken Farm.
Now, on his direct examination,
23
Kadir didn't mention the chicken farm code once.
24
way that he told the story, he wasn't even planning to
25
communicate directly with Francis and Defreitas.

In fact, the
SUMMATION - AHMAD
4676
He said he told them that all communications should
go through Abdul Wahab because he wanted to put distance
between himself and them.
Kadir was forced to admit that they did come up with the code
the Chicken Farm or the Chicken Hatchers.
Now, later, on cross-examination,
He claimed that Adbul Wahab, the real estate broker,
came up with that code.
But what did we learn from the
documents seized at Kadir's house?
chicken hatchery.
He ran a chicken farm, a
This makes Francis' version of events that
10
Kadir rather than Wahab came up with the Chicken Farm code
11
much more plausible that Kadir's more self-serving version.
12
Now, it's a little strange, because when Kadir gave
13
us his five-page resume at the beginning of his direct telling
14
us about his work at the Guyana Water Authority, the Bauxite
15
industry, the Ministry of Agriculture, the PTA, even telling
16
us about jobs he applied for and never gotten, he somehow left
17
out the fact that he'd run a chicken hatchery.
18
despite the fact that it wasn't apparently a little side
19
business, he said that his family was well-known in Guyana as
20
chicken people, known by everyone.
And this,
21
And now, once on cross-examination, Kadir is forced
22
to admit that they came up with the code, his story about how
23
they intended to communicate with one another changes.
24
you can see, it's no longer, I told Francis to direct all
25
communication through Abdul Wahab.
Now,
It's, Steven Francis is

SUMMATION - AHMAD
4677
going to call me directly.
know what he's saying and I'll know what he's talking about.
That's why we needed the code.
So that when he calls me, I'll
Look at how the story changed.
This is a classic
example of what Kadir has been doing throughout this case.
Changing his story to fit the evidence.
the evidence of his guilt.
belied by a new piece of evidence, try something else on for
size that he hopes to fit.
10
Once his original version is
This is the same thing you saw Defreitas do in his
11
confession.
12
for Kadir.
13
guilt for them to work around.
14
To try to account for
It didn't work for Defreitas and it didn't work

There's simply too much direct evidence of their
Now, as for the meeting at his house where Kadir
15
agreed to present the plot to his contacts from Venezuela and
16
Iran, Kadir told you he had a second meeting with Francis at a
17
mall in Georgetown.
18
take out a report of Francis' mugging.
19
This is where he called his friends to
Now, Kadir claimed that at that meeting he told
20
Francis that his contacts weren't interested and that that was
21
the end of that.
22
not interested, but they'd never be interested in something
23
like this because they're the kind of people who always look
24
for diplomatic ways of solving problems.
25
He said he told them that not only were they
You know that is nothing but a full blown lie.

How
SUMMATION - AHMAD
4678
do you know that?
Let's start with the phone call between
Kadir, Defreitas and Francis on March 5th, 2007.
about a week or so after Kadir is claiming he told Steven
Francis definitively that his contacts weren't interested.
(Audio stopped.)
MS. AHMAD:
This is
First, let's note who brings up The
Chicken Farm first.
All Defreitas has to do is say, I just
would like to know, like, how we are, what will we do next,
10
what we're supposed to be being do now, and Kadir knows
11
immediately what he's talking about.
12
most important thing they have going on, the plot to attack
13
JFK.
14
importation.
15
hearing from my contacts early next week, by Monday.
16
He's talking about the
He knows they're not talking about Bauxite or timber

And what does Kadir say, he says, I should be
Does it make any sense that he would say this, if,
17
as he claims, he already told Francis a week ago that his
18
contacts were definitely not interested, they'd never be
19
interested in something like this.
20
Of course not.
This conversation demonstrates unequivocally that
21
Abdul Kadir took that witness stand and lied.
All of the
22
conversations they had over the next few weeks just hammer
23
that point home.
24
Two days later on March 7, Kadir tells Francis that
25
his contacts have decided the plan is too sensitive right now

SUMMATION - AHMAD
4679
so they want to put it on hold.
(Audio stopped.)
MS. AHMAD:
Again, Kadir is the first person to
bring up The Chicken Farm in this conversation front and
center in his mind.
repeating here, in a tone that suggests it's news to everyone
what he's claiming he's already told them two weeks ago.
Does it make any sense that he's
Let's look at how many times he says "right now" in
10
this conversation.
At least four times in the space of 15
11
seconds.
12
Steven Francis weeks before this that his contacts were
13
definitely not interested, would never been interested.
14
prefer diplomatic solutions.
15
with what you just heard?
He got up on that stand and told you that he told
They
How is that remotely consistent
16
Here he's saying they would be interested, they are
17
interested, they're going to keep the plan in mind for a more
18
opportune and less sensitive time.
19
right now.
They just can't do it
20
In any event, one thing is clear.
21
conversation, is talking about his contacts' level of
22
interest, but not his own.
23
seeing this plot through and has been from the very beginning.
24
How do you know that?
25
Kadir, in these
He personally is interested in

SUMMATION - AHMAD
(Audio stopped.)
MS. AHMAD:
Francis tells him about finding the
satellite images of the fuel farm, he says, "Good, good.
can work with that."
in this plot.
4680
We
He says we because he's an active member
There's so much more evidence of Kadir's
participation in this plot.
For example, he discusses with
Defreitas and Francis who the right envoy is to send to Abu
Bakr to present the plot.
Here, you can see Steven Francis
10
telling him, "We're asking to take the Chicken Farm, before
11
you said Abdel Nur may be the right person but we don't see
12
his character."
13
Now, again, this conversation on the phone after
14
Francis is back in New York makes clear that at, some point.
15
Kadir, Francis and Defreitas had a prior about sending Abdel
16
Nur to Trinidad.
17
though you said he's the right person."
18
We know that because Francis said, "Even
This conversation is another one that Abdul Kadir
19
left out of his testimony.
20
he ever had with Francis and Defreitas in Guyana were, I'm not
21
interested and my contacts aren't interested.
22
23
He pretended the only discussion
Kadir himself agrees to accompany Defreitas and

Francis to Trinidad to present the plan of attack to Abu Bakr.
24
25
(Audio is stopped.)

SUMMATION - AHMAD
MS. AHMAD:
4681
Again, there's no dispute about what
they're talking about.
they talk about the gentleman who may be interested, that
gentleman is Abu Bakr.
is the plot to attack JFK.
Kadir told you on the stand that when
When they say interested in "it," "it"
Now, you know something came up at the last minute
and Kadir couldn't travel with them to Trinidad.
didn't stop him from doing everything he could to get the
plotters in to meet Abu Bakr and have the best possible chance
10
But that
of convincing him to support their plan.
11
All that help he gave them shows you, again, how
12
serious he was about moving this plot along.
13
the help he gave them.
14
picked up at the airport in Trinidad, to stay with Kareem
15
Ibrahim and meet with people to get him to see Abu Bakr.
16
he's telling Francis, "I called the brothers in Trinidad,
17
arranged for them to pick you up.
18
happen, if they can hook you up to meet Abu Bakr.
19
you need in terms of security, talk to them.
20
make sure the set's right."
21
Let's look at
First, he arranged for them to be
Here
They're going to see what

Anything
They're going to
He also gave them advice on how to conduct
22
themselves in Trinidad so that they would avoid getting
23
caught.
24
you.
25
with anything that could implicate you.
He told them, don't wear the tarj, they will proof
Don't wear a tarj.
When you're travelling, don't walk

The copies that you
SUMMATION - AHMAD
4682
had, and he told you he meant the Google Earth images, it's be
advisable not to walk with them in case they decide to search
you.
presented from the Internet.
You don't even need to walk with them as they can be

We don't want any implications.
Why did they need to worry about getting caught?
Because they're on the way to seek financial and operational
support for a devastating terrorist attack.
support from Yasin Abu Bakr, a man with extensive experience
conducting devastating terrorist attacks.
10
11
They're seeking
And if they caught,
they're going to be in serious trouble.

Kadir knows what they're going to Trinidad to do,
12
and he wants them to succeed so he gives them tips on how to
13
avoid attracting attention.
14
gives them advice on how to present their plan to Abu Bakr in
15
a way that will maximize their chance of success.
16
up in that same conversation.
But even more important, Kadir
17
18
(Audio stopped.)
19
MS. AHMAD:
This is good advise.
Let's pick
Someone like Abu
20
Bakr who's under surveillance from law enforcement isn't
21
likely to get involved in criminal activity with a stranger he
22
has no reason to trust.
23
these matters with somebody he knows, like Abdel Nur.
24
25
He's more likely to be dealing with
Kadir gives Steven Francis good advice because he

wants the plot to succeed.
It doesn't serve any of the other

SUMMATION - AHMAD
4683
goals he pretends to have.
little bit, but goals like getting involved in business with
Russell Defreitas, raising money for his mosque or
rehabilitating wayward Muslims.
We'll talk about these more in a
None of those goals are served by him giving them
good advice on how to get their terrorist plot off the ground.
The only goal giving them good advice serves is increasing the
chances that the plot will get the financial and operational
support that it needs to succeed.
10
Why is Kadir able to give Francis such good advice
11
about dealing with Abu Bakr?
12
is something he misled you about when he was on the stand.
13
With a straight face, Kadir testified that he only knew Abu
14
Bakr as a public figure.
15
in Trinidad and had no way of contacting him.
16
Because he knows Abu Bakr.
This
Had never once met him when he lived
How do you know that is not true?
17
Kadir own words in Exhibit 223.
18
he knew anyone was listening.
Let's listen to
Listen to what he said before
19
20
(Audio stopped.)
21
MS. AHMAD:
Ask yourself why Kadir would lie on the
22
witness stand about knowing Abu Bakr.
Why, given that,
23
according to what he told Steven Francis, he'd known the man
24
for many years?
25
with him whenever they were in the same country.
He lived with him in Trinidad and contacted

SUMMATION - AHMAD
4684
Why would he go to such lengths to pretend that he
barely knew him at all and had absolutely no reason for
getting in touch with him.
willing to admit it in May 2007 before he knew you were
listening?
Especially when he was perfectly
Let's think about who Abu Bakr is.
He's a committed
terrorist who organized the suicide bombing of the police
headquarters in Guyana; took over the Parliament, shot the
prime minister, held the members of Parliament at gunpoint and
10
seized control by force of the government run TV station.
11
This is a man who threatens Muslims in Trinidad if
12
they don't pay him tribute.
13
Kadir doesn't want you to know he deals with people like that.
14
He want you to think the only people he deals with are the
15
type of people that prefer diplomatic solutions to problems
16
and not fighting.
17
He threatens with violence.
And that's simply not true.
At this point in time, when they have this
18
conversation, Kadir was worried about doing business with Abu
19
Bakr, doing this kind of business, for the simple reason that
20
Abu Bakr was under heavy surveillance.
21
Remember, he told Steven Francis that what his
22
contacts in Trinidad was telling him was that Bakr is hot and
23
they have him under serious surveillance.
24
advice.
25
Again, this is good
Remember, you learned from the expert witness Calvin

SUMMATION - AHMAD
4685
Bennett that it was around this time that Abu Bakr was charged
with conspiracy to murder in sedition, and right around this
time they discovered a huge stash of weapons hidden underneath
the concrete floor of his mosque.
been under serious surveillance.
So he would have, in fact,
Ladies and gentlemen, you simply do not give this
kind of good advice to people that you are secretly hoping
will fail.
So the surveillance that Abu Bakr is under makes
10
Kadir wary.
Kadir, again, is extremely careful, with good
11
reason.
12
raise law enforcement eyebrows if he visits the Jamaat al
13
Muslimeen compound at this time, given all the charges pending
14
against Abu Bakr.
15
conspirators.
The person is prominent in the Caribbean and will
16
And this was well understood by his
Here, Francis tells Kadir that Defreitas had been
17
concerned about him being a public.
18
man of influence, discussed with Francis the fact that there
19
may have been issues with Kadir traveling to Trinidad at that
20
time.
21
And knowing that he's a
So Defreitas and Francis and Abdel Nur go to
22
Trinidad.
23
general overview of the plot.
24
meeting with Defreitas, Francis and Abu Bakr.
25
And Abdel Nur meets with Abu Bakr and gives him a
Abdel Nur sets up a second
But once Defreitas learns more from Nur and Ibrahim

SUMMATION - AHMAD
4686
about the kind of surveillance Abu Bakr is under, he himself
became wary of dealing with the man.
tapes and you heard that during Defreitas' confession where he
told Detective Addonizio that he was scared of Abu Bakr.
You heard that on the
But Defreitas, as always, is determined.
He
immediately starts thinking of other options and he settles on
Kareem Ibrahim, the man that Kadir arranged for them to stay
with.
in Trinidad with connections in Iran.
10
And who, he knows, is a Shi'a imam with some standing
Before Defreitas pitches the plot to Ibrahim, he
11
vets him, just what we saw him do with Francis.
12
efforts to try to determine Ibrahim's commitment to the
13
Jihadist cause and his trustworthiness before discussing the
14
plot with him.
15
determined Defreitas is to see the plot succeed.
16
He makes
Again, this is a sign of just how serious and
He doesn't want to waste his time talking with
17
someone who is not in the right frame of mind.
18
want to risk bringing someone in that will turn them in.
19
And he doesn't
In order to get a sense of whether Ibrahim is the
20
right guy for this plot, Defreitas asks some questions aimed
21
at figuring out how Ibrahim feels about America's treatment of
22
Muslims in the East.
23
How do you feel about what America does with the Far
24
East with the Arabs?
And when Ibrahim responds, America
25
fights, it's bloody outside all the time, with heavy bombs,

SUMMATION - AHMAD
4687
you know.
revolutionary who would blow up America.
that response, Defreitas knows that he's got the right guy.
But to have just enough Muslims in America who are

When he gives him
Once he's satisfied that Ibrahim has the commitment,
the bona fide for this type of Jihad, Defreitas presents him
with a plan of attack, of a way they can avenge the oppression
of Muslims around the world, Defreitas tells him, I have
something to tell you that can be very vital to Muslims.
will do it in the name of Allah because we're so much
You
10
suppressed and so much murder and so many murders committed
11
against us Muslims.
12
twin towers couldn't touch.
13
plan will destroy the economy of America for sometime.
14
He tells him he has a plan that even the

Then he goes on to say that his
And he tells him that this is why he's so careful.
15
This is why I took so many precautions figuring you out.
16
was looking for the best candidate.
17
join my plan to avenge the death and the massacres and
18
tragedies that have happened to us.
19
The best candidate to
When Defreitas is first presenting the plot to
20
Ibrahim or Ibrahim is firmly included to anticipate, Defreitas
21
is reluctant to tell him about Kadir's involvement.
22
because of Kadir's prominence as a religious and political
23
figure in the region.
24
25
Again,
This is the same play book he used when introducing

Francis to the plot.
He didn't tell Francis about the

SUMMATION - AHMAD
4688
involvement of Rutherford, the well-known Guyanese
businessman, until Francis was firmly committed and involved
in the plot.
Common sense tell you this is how criminal
organizations work.
You protect the higher up because they
have the most exposure.
whole enterprise.
And protecting them, protects the
Eventually, though, when Kareem Ibrahim makes clear
that he's very interested in being part of this attack on the
10
U.S, Defreitas and Francis tell him about Kadir's involvement.
11
They describe how they presented the plot.
12
Kadir wanted them to get Google Earth images so they could
13
display it better.
14
when they got the Google images and Muhammed Defreitas showed
15
the video to Kadir, Kadir again says they need better
16
pictures, satellite pictures.
17
They told him that
He adds that when they get the images,
After discussing the plot with Ibrahim, they decide
18
that the next best step is not going to Abu Bakr, but they
19
should present it to the revolutionary leadership in Iran,
20
with whom both Ibrahim and Kadir have connections.
21
Ibrahim is the one who first comes up with the idea.
22
We can try and send somebody up to Iran to the revolutionary
23
movement, a trusted brother, and that person can speak with
24
the top men of the revolutionary movement about the plan.
25
They let Kadir know of their change of plans and he

SUMMATION - AHMAD
4689
approves whole-heartedly.
Iran, so it makes sense that he's much more excited about
taking the plot in this direction.
Russell Defreitas have both talked to Kadir about the new
direction of the plan, they discuss his pleased reaction among
themselves.
7
8
You know what close ties he has to
Once Kareem Ibrahim and
Defreitas says, "I know Kadir's happy, very happy

with what I just told him.
10
(Audio stopped.)
11
MS. AHMAD:
Kadir is hungry.
Defreitas wants to see
12
it completed.
13
to know about their intent.
14
Defreitas was determined and Kadir was committed to seeing
15
this plot through to completion.
16
you that, but there actions, again, do as well.
17
The conversation tells you everything you want

Despite what they're saying now,
Not only do their words tell
What do Defreitas and Kadir do once they decide to
18
take the plot in a new direction to Iran?
19
a plane to Iran.
20
that when Kadir was arrested, he was on board a flight to
21
Venezuela and the final designation the Islamic Republic of
22
Iran.
23
the plot to the revolutionary leadership, to his connections
24
within that revolutionary leadership.
25
Well, Kadir gets on
You see here in this stipulation in evidence
I submit to you that he was going to Iran to present
Kadir also agrees to use his mosque bank account to

SUMMATION - AHMAD
4690
hide the money they received from the plot -- to finance the
plot.
for the building of the mosque once we get the money from the
sponsors of the Chicken Farm.
as the sponsors of the Chicken Farm give permission.
Here, Steven Francis asks him, Can we use your account
And Kadir says, Sure, as long
And we know that The Chicken Farm has only been used
in one way throughout this case.
sure, as long as the people who are sponsoring the attack on
JFK say it's okay, we can use my account.
10
What does Defreitas do?
So what Kadir is saying is
He's arranges for Ibrahim
11
to start recruiting actual operatives to undertake the attack.
12
He volunteers to train those recruits.
13
willing to do a training program and carry all those
14
operatives through training.
15
He tells Ibrahim, I am
Everything that we have just talked about is
16
evidence of the defendants' intent to attack JFK Airport.
17
the time that they were scheming about striking a devastating
18
below at the U.S., their commitment and their determination is
19
crystal clear, and nothing they're saying now, after the fact,
20
can erase that.
21
At
The main excuse that you heard from Russell
22
Defreitas is that he was just talking a big game.
He was.
23
Terrorism is not a modest enterprise.
24
terrorist attack like the ones these defendants were planning
25
was to create a spectacle of devastation, an explosion so
The entire goal of a

SUMMATION - AHMAD
4691
large it can be seen around the world.
If that's not showing off in the most gruesome way,
what is?
time, exaggerated his own credentials shouldn't surprise you
even one bit.
So the fact that Russell Defreitas may have, at
It shows you how much he wanted it.
Let's talk for a moment about what Abdul Kadir told
you on the witness stand.
so let's take it step by step.
His story changed from time-to-time
In his direct examination, Kadir said that he only
10
pretended to agree to participate in Defreitas' plan to attack
11
JFK because he didn't want to lose the chance to work with
12
Defreitas on business ventures he proposed.
13
right, "I didn't want to sever my relation with him by saying
14
I'm not interested in your terrorist plan, because the trade
15
possibility Defreitas spoke to me about seemed to be a very
16
viable venture."
17
He tells you
Now, as we discussed, the idea of coming
18
face-to-face with committed violent terrorists and they decide
19
they'd make excellent business partners is a laughable idea.
20
But Mr. Kadir didn't have much to work with, so it's no
21
surprise he came up with something so ridiculous.
22
There is a mountain of evidence in this case that he
23
had to work around.
He did his best to come up with a story
24
that would fit the evidence and exonerate him, and he failed.
25
He failed because he is guilty, and the evidence has proven

SUMMATION - AHMAD
4692
that to you beyond a reasonable doubt.
Kadir realized he'd failed when he was confronted on
cross-examination with the sworn under oath affidavit he
previously submitted in connection with this case.
He wrote
that affidavit at the very beginning of this case.
He hadn't
yet sat in this courtroom and listened to hours and hours of
himself and his coconspirators talking about the plot to
attack JFK.
He listened to himself happily greeting them on the
10
phone and expressing excitement of when they were next coming
11
to Guyana.
12
a kind of paralysis as to what devil, what slinking whisperer
13
has suddenly confronted me.
14
confusion, the source" -- he told you the source is Steven
15
Francis -- "that I knew persons might be interested.
16
seeking to put as much distance between myself and this
17
stupid, misguided, outlandish plan, I told him to give me a
18
few weeks."
Before all that, this is what he wrote, "You're in
In this state of fear, shock and
And
19
Before he saw the evidence, he tried to go with, I
20
was trying to put distance between him, not I didn't want to
21
completely sever relations.
22
Once he was shown the affidavit on cross-examination
23
and realized he was caught in another lie, Kadir shifted gears
24
one more time.
25
to tried to account for the evidence of his guilt.
As he's done throughout, he changed his story

SUMMATION - AHMAD
4693
And this is the first time, more than half-way
through cross-examination, that Kadir comes up with the idea
that these guys were devils or slinking whisperers and he was
trying to dissuade from their devilish plan.
Once he's shown that affidavit, he says, Yeah, the
reason I didn't want to cut off my relationship with them was
because I still thought and wanted to know that they could
have been rehabilitated from that bad idea.
You did not hear one word of this on his direct.
10
Not once during his direct examination did he suggest that
11
Francis and Defreitas were devils in need of rehabilitation.
12
Not once did he suggest that Francis and Defreitas were
13
anything but great guys to do business with.
14
he jumps on his new band wagon, Kadir claimed that he barely
15
cared about their plot to attack JFK.
16
horrific to even imagine.
17
In fact, before
Not that it was too
When he was asked why he responded to their
18
downloading Google Earth was "Good, good, good," was because
19
it made no difference to me.
20
they had better satellite images of the tanks they wanted to
21
bomb.
22
It made no difference to him if
But all of a sudden, half-way through
23
cross-examination, he remembers.
Oh, yes.
24
trying to talk them out of their devilish plan to destroy the
25
economy of the United States and kill people.

I was actually
SUMMATION - AHMAD
4694
There's a good reason Kadir didn't come up with the
story earlier.
evidence.
Abdul Kadir ever trying to actively distract Russell Defreitas
and Steven Francis from going through with the plan.
does he say this is not a good idea, people are going to die.
And that is, it is flatly contradicted by the
Find me one example on all the tapes you've of
What's more, there's just the opposite.
Not once
What you've
seen is example after example of Kadir giving concrete advice
and encouragement to the scheme.
10
Not just any advice, but his
best advice.
11
Remember what he said here, he was asked about how
12
you responded to Francis and Defreitas' questions to him about
13
the composition of the fuel tank, and he said he gave them his
14
best advice.
15
fuel tanks at an airport, you gave your best engineering
16
advice on the composition of those fuel tanks, is that
17
correct?"
18
"Two individuals that you knew wanted to blow up
He said, "My best advise."

THE COURT:
I hate to interrupt you, but every time
19
you move away from the mike, it's hard to hear you.
Perhaps
20
the mike on the podium, you can pull it closer that way.
21
MS. AHMAD:
Thank you, Judge.
22
Kadir is an engineer, and these people, these
23
terrorists, ask his expert opinion about what the tanks they
24
want to blow up are made of so that they can find the best
25
explosive to below them up.
What does he give them,

SUMMATION - AHMAD
discouragement, disinformation?
kind of rehabilitation is that?
No.
4695
His best advise.
What
Kadir cannot escape the truth that he agreed with
Russell Defreitas and others to blow up JFK Airport.
fact that he tried to escape it, I would argue to you, is
itself evidence of his guilty.
The fact that he lied on the witness stand is
evidence that he had something to lie about.
lie about is clear.
10
The very
What he had to
He intended to join a plot to explode the
fuel tanks and pipelines at JFK Airport.
11
I'm going to move on to the charges.
12
evidence that we have just gone over is evidence that the
13
defendants were members of a conspiracy to blow up the fuel
14
tanks and pipelines at the airport.
15
All of the
Their membership in that conspiracy is an element of
16
the five of the first six counts they're charged with.
17
of those counts require you to find that the defendants
18
engaged generally in a conspiracy to attack JFK.
19
Each
The evidence we've just gone over shows you that.
20
That element to commit an unlawful act, that is, bombing JFK,
21
is common to each count.
22
technical elements which we'll go over now.
23
The count has some separate
Count One charges the defendant with conspiring to
24
attack a public transportation facility.
25
guilty, the defendants have to have agreed to place or

In order to be
SUMMATION - AHMAD
4696
detonate an explosive in the system with either, first, to
cause death or physical injury or, second, the intent to cause
the disruption that would result in major economic loss.
So there can't really be any dispute that JFK's a
public transportation system.
that over 48 million people flew in and out of the airport in
2007.
8
9
You heard from Peter Carbonaro
And second, there really can't be any dispute that

the defendants plan to detonate explosives near the fuel tanks
10
at the airport, which they also hoped to set the underlying
11
fuel pipeline on fire, would have caused extensive destruction
12
of the airport as well as major economic damage.
13
JFK, you've heard, employs thousands of people and
14
brings in over $30 million of revenue each year.
15
defendants' intent as it relates to this count, you've seen
16
full well that they intended, both, to cause serious bodily
17
injury to others and cause extensive destruction that would
18
result in major economic loss.
19
So as to the
You need only agree unanimously to one or the other,
20
that is, either they intended to cause serious bodily injury
21
or that they intended to cause extensive destruction.
22
quickly review the evidence of both.
Let's
23
First, bodily injury.
There's no doubt that the
24
plotters knew their plan would take lives.
25
Francis, Look how dumb JFK is not protecting these tanks.

Defreitas told
SUMMATION - AHMAD
4697
They're putting a lot of people's lives in jeopardy.
told you in their early discussions about the plot they talked
about people getting killed.
Nero
Now, as Peter Carbonaro told you, there are people
who work in the areas near the full tanks.
the bulk fuel farm on the left there's a LaGuardia Sky Chef
company and one security guard posted there.
that next to the satellite fuel farm on the right, there are
airplane hangars and a police station.
10
He said next to
And he told you
Doubtless, these people would have been the first to
11
go.
But we don't know how extensive the explosion would have
12
been.
13
underground through Queens, tells you everything you need to
14
know about how many lives they intended to take.
15
it would cause devastating.
The fact that the plotters thought that it would spread
16
They thought
Let's move on to intent to cause major economic
17
damage.
18
the primary goal of Defreitas.
19
Detective Addonizio.
20
the airport was to blow up the fuel tanks and pipelines and
21
hurt the economy of the United States.
22
This, as you heard over and over on the tapes, was

Defreitas confessed as much to
He said the goal of the plan to attack
Now, each of the coconspirators is motivated by
23
desire to hurt the American economy.
Here you have Defreitas
24
telling Francis, "The World Trade Center didn't do nothing.
25
This here will break the economy of them and they will be

SUMMATION - AHMAD
4698
crying."
(Audio stopped.)
MS. AHMAD:
Everything that you just heard is
evidence of their intent to cause devastation so extensive it
would have result in major economic lose.
Finally, with respect to Count One, there is an
additional jurisdictional element.
And that is, that the
unlawful act, bombing the airport, would have taken place in
10
United States.
11
the intended target was JFK in Queens.
12
This you know is true because you know that
And that a member of the conspiracy was a national
13
of another state.
14
coconspirators, including Abdul Kadir, were Guyanese citizens.
15
The judge will instruct you that there is no dispute that his
16
jurisdictional element has been satisfied.
17
And this you know is true because several
Let's move on to Count Two.
Count Two charges the
18
defendants with conspiring to destroy a building or other real
19
property by fire or explosive.
20
land or anything built on it.
21
And "real property" just means
The building or property at issue has to have been
22
used in interstate or foreign commerce.
23
buildings and land at JFK are used in interstate commerce.
24
And the judge will instruct you that there's no dispute about
25
that here.

And obviously, the
SUMMATION - AHMAD
4699
I also don't think there can be any dispute that the
JFK Airport and its fuel tanks are built on land.
evidence that you've seen about the explosion that the
defendants intended to cause -- not going to go over it again
-- shows you that they're guilty of this count.
All of the
Count Three charges the defendants with conspiring
to attack aircraft and aircraft materials by placing a
destructive devise or substance near the aircraft.
have been likely that placing the destructive devise there
10
It has to
would endanger the safety of the aircraft.
11
Now, Donald Nero and Steven Francis both told you
12
that part of their plan to blow up airplanes and airplane
13
hangars.
14
been guaranteed to hit airplanes.
15
Even just blowing up the tanks itself would have
Let's look at our map again.
You learn that this
16
road highlighted in yellow at the bottom of the screen, right
17
next to the satellite fuel farm is a taxiway where planes
18
drive or taxi to the runway.
19
satellite fuel farm, the defendants would be placing them very
20
near airplanes.
21
So by placing bombs near the
And remember how excited they were about that when
22
Defreitas is showing the video to Ibrahim.
23
particular note how close the planes are to the tanks.
24
said, "These are the planes, and we're gonna get them all.
25
knock all of them at one time, and then you hurt the

He makes
He
We
SUMMATION - AHMAD
4700
building."
Now, this is what they were looking at when they had
this conversation.
video, Exhibit 51, that shows the airplane right next to the
satellite fuel farm.
This is a still shot from Defreitas'
Moving on to Count Four.
Count Four charges the
defendants with conspiring or agreeing to destroy or damage
international airport facilities.
undertake must have been likely to have endangered the safety
10
The act they intended to
of the airport.
11
And again, JFK International Airport is an
12
international airport facility.
And the defendants plan was
13
to destroy all of JFK Airport, that certainly counts as
14
endangering the safety.
15
every single thing.
16
tanks, the recycling plant, the generators, everything around
17
it.
18
have to get the cargo area and the cargo plane the whole
19
thing.
Defreitas said, We've got to blow up
We got to knock down the tower, the
They have a gas station in there we're gonna get.
We
20
And for Count Four there's also a jurisdictional
21
element, and that requires that the conspiracy either took
22
place in the U.S. or took place out of the U.S. but had as its
23
member someone who was found in the U.S. or a U.S. citizen.
24
Now, you know this attack was planned both inside
25
and outside the United States.
And you know that Russell

SUMMATION - AHMAD
Defreitas is a naturalized U.S. citizen.
that you there is no dispute.
been satisfied.
4701
The judge will tell
The jurisdictional element has
Count Five charges the defendants with conspiring to
place a destructive devise near a mass transportation vehicle
without having obtained the permission of the mass
transportation provider, and knowing that doing so would like
disable the mass transportation vehicle.
What does that mean?
The fuel tanks and pipelines
10
and hangars at JFK Airport are all mass transit vehicles used
11
at the airport, which is, itself, a mass transportation
12
provider.
13
explosive devise near those tanks and that they're doing so
14
would have done a lot of damage to the tanks.
15
And you know that the defendants agreed to place an
You also know that they didn't get permission to do
16
this.
17
the Port Authority records.
18
2007 asked for permission to blow up the airport.
19
write the laws.
20
proved it.
21
Peter Carbonaro told you that, just in case, he checked

And not a single soul in 2006 or
I don't
I don't know why that's in there, but we
There's also a jurisdictional element for this
22
count.
We have to prove that either, had the conspiracy been
23
completed, it would have affected a mass transportation
24
provider engaged in interstate commerce -- and you know that's
25
true because if the attack had happened, it would have

SUMMATION - AHMAD
4702
affected JFK -- or that somebody traveled across state lines
in order to commit this offense, and you've seen evidence of
all the different trips the defendants took here.
will instruct you there's no disputes, this element has
satisfied.
The last one, Count Six.
The judge
Count Six is different
from the others because it's not a conspiracy count.
Count
Six charges the defendants with conducting surveillance of a
mass transportation facility or aiding and abetting that
10
surveillance with the intent to place a destructive devise
11
near a mass transportation vehicle that would likely disable
12
it.
13
So let's deal with the second half first.
You know,
14
based on everything we've gone over, that the defendants
15
intended to place bombs near the fuel tanks at JFK Airport.
16
Those count as mass transportation vehicle.
17
knew putting bombs there would likely wreck the tanks.
18
You also know that the first half of this is
And that they
19
satisfied because the defendants surveilled the airport with
20
the goal of making this happen.
21
requires us to prove that they didn't have permission to do
22
so.
23
permission.
24
25
Once again, the statute
And once again, Peter Carbonaro told you that didn't have
Now, Russell Defreitas did his surveillance of the

tanks in person.
You need nothing more that his surveillance

SUMMATION - AHMAD
4703
video that's in evidence to know he did that.
you have the videos of them in the car driving around the
airport and the surveillance footage from the FBI plane
overhead watching them drive around.
You have more,
Kadir is charged with aiding and abetting the
electronic surveillance at the airport.
told Steven Francis and Russell Defreitas when he told them to
download Google Earth in order to get a better idea of the
tanks layout.
10
He did this when he
Aiding and abetting just means asking someone to do
11
something, which, if you'd done it yourself, would be a crime.
12
And getting satellite images, even publicly available
13
satellite images, of a mass transportation with the intent to
14
place bombs next to it, is a crime.
15
Francis to commit on his behalf; and therefore, is as guilty
16
of as if he had done it himself.
A crime which Kadir asked
17
I'm almost done.
18
Everything we have spent the past two hours going
19
over is evidence.
20
defendants who stand before you agreed to commit a terrorist
21
attack at JFK Airport.
22
Strong, irrefutable evidence that the two
We are here asking you to hold them accountable for
23
choosing to take the lives of innocent people into their own
24
hands; asking you to hold them accountable for deciding it was
25
their God given right to destroy the economy of a country they

SUMMATION - AHMAD
4704
hated; hold them accountable for choosing to plan an attack so
devastating that the best the survivors could hope for would
be to drown to their death in Jamaica Bay.
Find them guilty.
THE COURT:
Thank you.
Thank you, Ms. Ahmad.
We're going to
take a break before you hear the summations of defense
counsel.
do anything during the course of the trial because the burden
of proof is always on the government, but it's my
I remind you that the defense has no obligation to
10
understanding that the defendants wish to exercise their
11
prerogative to sum up.
12
So before we do that, we'll take a break for about
13
15 minutes or so.
14
later just so that we don't have to interrupt the next
15
summation that will be coming up.
16
We'll probably have lunch a little bit
Remember, it's still just as important right now as
17
it was from the very beginning and every single day of this
18
trial, when I told you to keep an open mind and not to form or
19
draw any conclusions about the case.
20
Remember, you still haven't heard the summations of
21
the other counsel and you also haven't heard my instructions
22
on the law yet.
23
conversing about the case once I tell you that you can
24
actually go in and start to deliberate.
25
You also haven't had a chance to start
So you need to keep your minds open.

You cannot
SUMMATION - AHMAD
4705
discuss the case or anything connected with the case among
yourselves or with anyone else.
I remind you that cannot use your cell phones during
this brief break.
Remember, also, that you cannot read, look
at, listen to or review anything that might be recorded about
this case over any kind of media or do any kind of research or
investigation connected with anything about this case over any
kind of media.
So just that you have an idea, I would expect we'll
10
probably start up around five to 12:00, on the Court's clock.
11
Thank you, ladies and gentlemen.
12
(Whereupon the jurors leave the courtroom at 11:40
13
14
15
16
a.m.)
THE COURT:
Can I ask the parties to sit for a quick
minute and I'll let you all take a break as well.

Ms. Ahmad was just under two hours.
I just wanted
17
to get an idea because we're trying to time the jury's lunch.
18
I don't want to interrupt your summation, Ms. Whalen.
19
want to have an idea.
20
MS. WHALEN:
I just
Your Honor, I think's it going to be
21
about an hour and a half.
Just to let you know, over the
22
weekend we had a major computer disaster so I'm actually going
23
to need your help to switch back and forth between the Elmo
24
and the laptop here.
25
going to come in shorter.
But given that, I think it's actually

At this point, I'm thinking an hour

SUMMATION - AHMAD
and a half.
2
3
THE COURT:
Okay.
I just wanted to have an idea.
didn't want to interrupt you.
4
5
4706
Okay.
So we'll come back here at five to 12:00.
Thank you.
(Whereupon a recess was taken at 11:40 a.m.)
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

4707
1
2
(The following takes place out of the presence of

the jury.)
(Time noted:
THE COURT:
12:00 p.m.)
Ms. Whalen, you need a few more minutes
to finish setting up?
MS. WHALEN:
Your Honor, I just realized I forgot to
hook it into the system.
it is hooked up?
THE COURT:
10
(Pause.)
11
THE COURT:
12
Sure.
You want to play it from the defense
laptop, is that what you want to do?
13
MS. WHALEN:
14
THE COURT:
15
the defense laptop.
Yes, please.
It is not coming on for some reason from
(Pause.)
16
MR. KAMDANG:
17
THE COURT:
18
Could we just test it to make sure
Sorry, Your Honor.
No, that's okay.
Better to work it out
now than in the middle of things.
19
(Pause.)
20
MR. KAMDANG:
21
THE COURT:
22
Are you all set or do you want to try anything else
23
24
25
Your Honor, it's on public?
Yes.
out before we get started?

MS. WHALEN:
No, I think we're all good and we can
just switch to the Elmo because I'll be using that in the
HOLLY DRISCOLL, CSR
Summation - Whalen
4708
beginning.
THE COURT:
MS. WHALEN:
THE COURT:
(Jury enters courtroom.)
THE COURT:
Welcome back, ladies and gentlemen.
Do the parties all agree that all of the jurors are
In the beginning, okay, got it.

Thanks so much.
Jury entering.
present and properly seated?
10
MR. MILLER:
Yes, Your Honor.
11
MS. WHALEN:
Yes, Your Honor.
12
MR. NKRUMAH:
13
THE COURT:
Yes, Your Honor.
I'm sorry for the delay, ladies and
14
gentlemen, but we had to switch the technical instruments
15
there.
16
17
Sometimes things don't want to cooperate.

We'll begin with the summation by defendant
Defreitas by Ms. Whalen.
18
You may proceed when you are ready, Ms. Whalen.
19
(Summation - Ms. Whalen.)
20
MS. WHALEN:
Ladies and gentlemen, Russell Defreitas
21
is a man with a small mind, a big mouth and an ugly
22
imagination but those are character flaws, they're not crimes.
23
The government opened their case saying that Russell
24
Defreitas was a man with a long-term plan to blow up JFK
25
Airport that he suddenly decided to bring to fruition but the
HOLLY DRISCOLL, CSR
Summation - Whalen
1
2
4709
evidence in this case hasn't shown you that.

The government also opened their case saying that
Russell Defreitas was a man who wanted to recruit U.S. Muslims
to participate in this plan but the evidence in this case
hasn't shown you that.
case by saying that Russell Defreitas was a man who knew JFK
Airport in some extraordinary way but the evidence hasn't
shown you that either.
And the government also opened their
The evidence has shown you that this was not a
10
conspiracy, that this was just a lot of stupid ugly talk.
11
the evidence has shown you that Russell Defreitas worked at
12
JFK for three years, not twenty.
13
you that Russell Defreitas can't mastermind his way out of the
14
on/off switch on a video camera.
15
And
And the evidence has shown
And the evidence has shown you that the government
16
provided Russell Defreitas with a lot of goodies in their
17
effort to manage the risk and they're now trying to claim that
18
his acceptance of these goodies was evidence of his intent to
19
commit the crimes that are charged here.
20
Now, ladies and gentlemen, the issue in this case is
21
intent and when does stupid ugly talk become the intent to
22
join a conspiracy to commit a crime and when does stupid ugly
23
talk become an agreement.
24
Mr. Defreitas' talk is stupid and ugly but it's the kind of
25
stupid ugly talk you can hear in many places from men with no
There's no doubt that
HOLLY DRISCOLL, CSR
Summation - Whalen
4710
accomplishments in life, men who sit around and talk in detail
about jobs they never really had, men who sit around and talk
about things they never really did, and men who sit around and
talk about the importance they never really achieved.
The government claims this plot started long before
Russell Defreitas met Steven Francis and they gave you Donald
Nero, also called Dawood, as a witness to that fact, and I'll
come back to whether you can believe Donald Nero as a witness
at the end of my summation, but the bottom line is Russell
10
Defreitas is the kind of man who if he meets someone boasting
11
about smuggling, like Ponytail, Russell Defreitas has to top
12
him.
13
Defreitas could get anything off.
14
off to the races.
15
come back to New York City and recruit Muslims to participate
16
in this plot, he didn't do it.
17
with was Steven Francis, the person the government sent in to
18
meet him, probably on a tip from Ponytail.
19
If Ponytail could get anything on to a plane, Russell

And this so-called plot was
But if Russell Defreitas was supposed to
The only person he hooked up
Now, Russell Defreitas, as you can see from
20
Government Exhibit 101, came back to the United States in
21
February of 2006 from his trip to Guyana where he supposedly
22
talked about these terrible things with Nero.
23
to Steven Francis, in August of 2006 Russell Defreitas tells
24
him about his mission after knowing him for less than a month.
25
And, according
Now, there's no recording of that conversation even
HOLLY DRISCOLL, CSR
Summation - Whalen
4711
though it happened in the United States, there's no recording
of that conversation even though Steven Francis never
testified that he thought Russell Defreitas was a danger, and
there's no recording of this conversation even though it
wasn't Steven Francis' first investigation as the government
pointed out to you over and over again.
working with the JTTF on a number of investigations at the
time and yet there are still no recordings of these critical
initial meetings.
Steven Francis was
10
What you do have is evidence that Steven Francis and
11
Russell Defreitas became quick friends probably because Steven
12
Francis, as he testified, was offering to drive Russell
13
Defreitas anywhere he wanted to go and help him run his
14
errands.
15
Dawood, Donald Nero, and Ponytail over the phone and Russell
16
Defreitas invites Steven Francis to Guyana for Ramadan and to
17
meet these other people.
18
to you of these initial meetings where anyone discusses the
19
details of any plot.
20
Russell Defreitas introduces Steven Francis to
But no recording has been presented
In Guyana Steven Francis meets the crew in person.
21
He meets Ponytail, he meets Nero, Donald Nero Masood; and then
22
he eventually meets Rutherford and Abdel Nur.
23
are no recordings of what was said on this trip but Steven
24
Francis tells you that they talked about a plot to blow up JFK
25
Airport but obviously other things were discussed, the import
HOLLY DRISCOLL, CSR
Again, there
Summation - Whalen
4712
and the export of Guyanese products and there must have been
some discussions that made both Donald Nero and Rutherford
believe that Steven Francis would be good for sending them
things like phones and computers when he got back to the
states.
And there must have been some discussion that made
Donald Nero think that Steven Francis would get him
immigration help and find his wife an apartment when he got
back to the United States.
10
Everyone from this crew in Guyana, Russell
11
Defreitas, Rutherford, Dawood Masood, Abdel Nur, thinks that
12
Steven Francis is going to help them out in some way when he
13
comes back to the United States and you know this from the
14
later recordings you hear.
15
Now, there's no testimony as to how this Al Qaeda
16
operative, Shukrijumah, or there is no recording of how this
17
Al Qaeda operative, Shukrijumah, comes up into the
18
conversations and you know that Shukrijumah is a wanted Al
19
Qaeda operative and the expert, Matthew Levitt, testified that
20
he was rumored to be in the Caribbean at about this time.
21
Now, Steven Francis testified that it was Dawood and
22
Rutherford who brought up Shukrijumah, Dawood saying that he
23
actually knew him and Rutherford saying that he knew of him.
24
Dawood testified, however, that it was Russell Defreitas
25
holding up a wanted poster that gave them the idea of
HOLLY DRISCOLL, CSR
Summation - Whalen
4713
Shukrijumah.
Steven Francis says that the group decided
Shukrijumah would be interested in this plan to blow up JFK.
Steven Francis says the group decided that Shukrijumah was
in Trinidad and Steven Francis said that the group decided
if Shukrijumah was in Trinidad then Abu Bakr would know where
to find him.
to meet Abu Bakr so that he could introduce them to
Shukrijumah.
10
So, they started talking about going to Trinidad
Ladies and gentlemen, at this point it's pretty
11
clear that these guys have seen too many Bruce Willis movies
12
and don't have enough to occupy their time.
13
alluded police forces all over the world but these guys think
14
that they can just meet up with him.
15
trash you hear in barber shops.
16
real plans and you know that the government didn't think that
17
these were -- this was the stuff of reality either and you
18
know that the government thought that these guys were just
19
talkers because, as Detective Addonizio testified, the
20
government had a meeting about these guys in October 2006 and
21
Robert Addonizio testified that the government didn't think
22
the group had the logistical or technical support to
23
accomplish such a plot but they decided to keep an eye on
24
things.
25
Shukrijumah has
This talk is the kind of
It's not real discussions of
The problem is that to manage the risk in this case
HOLLY DRISCOLL, CSR
Summation - Whalen
4714
the government started handing out goodies.
Russell Defreitas
when he went down to Guyana for Ramadan wasn't coming back to
New York City any time soon because he didn't have a place to
live.
back to New York City any time soon because he had a lawsuit
pending there and once Steven Francis got back to the United
States nobody was calling him back, nobody was answering his
e-mails.
Russell Defreitas once he got to Guyana wasn't coming
So, the government got an apartment for Steven
10
Francis to offer to Russell Defreitas and Steven Francis
11
starts talking to Rutherford about sending Russell Defreitas
12
back to New York City and Steven Francis talks to Dawood about
13
sending Rutherford -- about -- Steven Francis actually talks
14
to Dawood to talk to Rutherford about sending Russell
15
Defreitas back to New York City before anybody went to
16
Trinidad to supposedly meet Shukrijumah or Abu Bakr.
17
And Rutherford agrees to pay for the plane ticket
18
for Russell Defreitas to come back to New York City and
19
I'd ask you in your deliberations to listen to three
20
conversations, the conversations that took place when
21
Steven Francis was in New York City and everybody else was
22
in Guyana, and those are Government Exhibit 202, Defense
23
Exhibit RD-A and Government Exhibit 203 and in those
24
conversations you'll hear that Russell Defreitas is first
25
supposed to come back before December.
HOLLY DRISCOLL, CSR
Summation - Whalen
4715
In a later conversation Russell Defreitas is then
coming back at the end of December unless Rutherford decides
to send him to Trinidad.
call, speaks to Dawood and gets Dawood to talk to Rutherford
about sending Russell Defreitas back to New York City first.
Now, Steven Francis tells Dawood it's to save money but why is
Steven Francis talking about money.
going to be paying for anything so why talk about finances
being low.
10
So, Steven Francis then makes a
Steven Francis wasn't
Now, Steven Francis testified here that he was just
11
repeating what Ponytail and Rutherford had told him about
12
finances but why did Steven Francis in New York City have to
13
tell Dawood to talk to Rutherford, both of whom were in Guyana
14
and sharing an office, about saving money.
15
like Steven Francis knew nothing would happen if he left these
16
guys to their own devices because Steven Francis knew they
17
were all talk.
18
Well, it looks
Now, the government wants you to look at Russell
19
Defreitas' agreement to come back to New York City as evidence
20
of his intent to join this conspiracy but why wouldn't Russell
21
Defreitas come back, he had a free place to stay, he had a
22
free plane ticket, he was being treated as an important man by
23
Steven Francis and Rutherford and Rutherford had agreed to
24
take care of his lawsuit in his absence.
25
back to New York City.
Of course he came
That doesn't show any intent to join a
HOLLY DRISCOLL, CSR
Summation - Whalen
conspiracy.
when something free was on offer.
4716
It just shows that he knew when to take advantage
Now, the government has presented the conversations
from the drives around JFK to prove that Russell Defreitas had
the intent to join the conspiracy and commit the crime of
airport surveillance and you heard through the
cross-examination of Steven Francis that, again, these drives
took place when Steven Francis was chauffeuring Russell
Defreitas all over New York City helping him run his errands.
10
Russell Defreitas, if you listen to the tapes, is
11
in no hurry to go to the airport.
12
enjoying being driven around and running his errands.
13
Russell Defreitas also talks about knowing and being
14
interested in lots of different routes to avoid traffic
15
which may explain why he knows the back roads to the airport
16
so well.
17
Russell Defreitas is
Now, at the airport when they get there Russell
18
Defreitas is able to direct Steven Francis on roads that are
19
open to the public but it becomes clear that Russell Defreitas
20
doesn't really know the airport anymore.
21
recordings, the recordings are full of him directing Steven
22
Francis to go one way and then having to turn around because
23
the road he thinks they can drive on is now closed.
24
Russell Defreitas can direct Steven Francis near some hangars
25
and near some tanks but in this ride it's clear that Russell
HOLLY DRISCOLL, CSR
If you listen to the
And
Summation - Whalen
4717
Defreitas has the knowledge of a guy who used to work in the
airport in 1991 and maybe lived in the neighborhood at some
point but not the knowledge of a guy who has been scouting out
JFK ever since.
And on these drives, if you listen to the tapes,
Russell Defreitas tells Steven Francis a number of things
about the airport that just aren't true.
tells him that the air traffic control tower controls
security, that it watches everything, even the ants at the
Russell Defreitas
10
airport, but you heard from Mr. Carbonaro, the very first
11
witness in this case, that the air traffic tower doesn't
12
control security, it only controls flight traffic and
13
aeronautical ground traffic on the runways and, in fact,
14
Mr. Carbonaro testified that he thought the tower wasn't
15
even built until about 15 years ago which would have made
16
it about 1995 or 1996 which, if you look at Mr. Defreitas'
17
identification card which expires December 31st of 1991, would
18
put him there at the airport working before the tower was even
19
built.
20
Russell Defreitas said that the airport doesn't give
21
out maps anymore but you heard from Mr. Carbonaro that they do
22
give out maps to JFK and, in fact, there's one in evidence,
23
Government's Exhibit Number 22.
24
back you can look at this up close, hold it in your hands but
25
what you'll see is that while the fuel tanks aren't there,
And when you get back in the
HOLLY DRISCOLL, CSR
Summation - Whalen
every single one of the roads is marked.
here.
Train.
4718
There's no secret
They're all visible and this red route is the Air
Defreitas talked about being at JFK when they were
digging up the place talking about seeing a sketch about where
the pipeline was but Mr. Carbonaro testified that the fuel
farms were built before the 1990s.
didn't know about the real security that was at JFK Airport or
if he did, he didn't tell Steven Francis about it.
And Russell Defreitas
Russell
10
Defreitas didn't know about the perimeter cameras around the
11
fuel fields, the fuel tanks, and Russell Defreitas didn't know
12
about the delta barriers which are these large steel barriers
13
that pop up if a vehicle tries to drive through a fence.
14
Mr. Carbonaro testified that those existed.
15
apparently didn't know that they did.
16
Mr. Defreitas
So, as to having some unique and special knowledge
17
of the airport, well, after this ride the government knows
18
that Russell Defreitas is full of it and the evidence shows
19
the government and now you that Russell Defreitas was all
20
talk.
21
most of it is evidence that Russell Defreitas is just a liar.
22
He talks about loading missiles and tanks and helicopters onto
23
cargo planes from false and secret manifests but Mr. Carbonaro
24
testified there's no military cargo out of JFK and do you
25
really think that if Russell Defreitas found false or secret
And there is a lot of ugly talk on these drives but
HOLLY DRISCOLL, CSR
Summation - Whalen
4719
manifests showing that missiles and tanks were being shipped
out of JFK, that Evergreen wouldn't transfer him in a heart
beat just to get him to shut up.
And Russell Defreitas talks about speaking Yiddish
to Israeli security guards to get their secrets and alluding
the police in stealing cargo and he makes fun of good people
who work for what he calls chicken feed money and he talks
about death and destruction like a ten-year old boy who has
played too many video games.
He talks about making bombs but,
10
as you saw through Lieutenant or Detective Napoli, those bombs
11
were made of chick peas and potatoes.
12
that they had some prior conversation where he revealed that
13
they were made of metal shrapnel and grenades just wasn't true
14
because he never told Louis Napoli about it.
15
Steven Francis' claim
And you ask yourself why would someone talk like
16
this.
17
himself feel important.
18
He didn't know how to fly a plane.
19
listen to these tapes, he doesn't know how to say anything in
20
Arabic except salemoalicum and alhemdulilah.
21
make himself seem important to his friends and to this
22
relatively young man, Steven Francis, who's hanging on his
23
every word.
24
25
Well, ladies and gentlemen, he had nothing else to make

He hadn't worked at JFK for 20 years.
He wasn't an Imam.
If you
He wanted to
Russell Defreitas is not a success in America and

when he goes back to Guyana if he wants an audience to listen
HOLLY DRISCOLL, CSR
Summation - Whalen
4720
to him he has to make things up.
Russell Defreitas to the hilt.
how amazed he is, how impressed he is with Russell Defreitas'
knowledge of JFK Airport, how he never knew these roads
existed or that the tanks were there but, ladies and
gentlemen, Steven Francis was also amazed that there was a
Long Island Rail Road station there so I wouldn't let his
claims of amazement substitute for hard evidence in this
case.
10
And Steven Francis praises

In those tapes he tells him
Russell Defreitas wanted Steven Francis to tell
11
Rutherford that he knew the place and Russell Defreitas in
12
those conversations by telling Steven Francis that makes it
13
sound like Russell Defreitas thought that the Sheikhs and
14
Ponytail didn't believe him, that the Sheikhs and Ponytail
15
back in Guyana also thought he was full of it.
16
So, going to the airport with Steven Francis doesn't
17
indicate that Russell Defreitas had any intent to join a
18
conspiracy.
19
prove to everyone that he knew what he was talking about.
20
It's just evidence that he went to the airport to
And the other thing to remember is that on these
21
drives Russell Defreitas also talks to Steven Francis about
22
investment in the water machine, the water purification
23
machine to purify the water five times, it cures disease.
24
Steven Francis keeps saying to him he doesn't have the money,
25
talk to Rutherford about it but Russell Defreitas keeps on
HOLLY DRISCOLL, CSR
And
Summation - Whalen
4721
talking about it.
thinks that Steven Francis has the money or the ability to
invest in these things.
Why is he doing that, because he obviously
So, let's go to the videotapes and I'd like you when
you go into the back to listen to these recordings but right
now we're going to have to do it with some of the transcripts.
Steven Francis repeatedly testified that Russell Defreitas,
Sheikh Muhammed, instructed him to do things like go to the
camera store.
10
(Pause.)
11
Ladies and gentlemen, I'm going to show you the
12
transcript for Government Exhibit 208 beginning at page
13
five on the bottom where Steven Francis, they're talking,
14
says:
15
Internet.
16
17
I was looking in the
Oh, yeah, it's in Manhattan.

Annas:
it's in Manhattan.
18
19
There's a place on 34th.
Annas:
There's a place on 34th Street.
Oh, yeah,
That has a -- it's a big place.

That has cameras and stuff.
I don't know if
you --
20
Defreitas:
21
Annas:
22
Defreitas:
Uh-huh.
Probably you know.
Or if you know of another place.

No, I don't know no other place.
23
There's a place there -- and then they start talking about
24
driving directions again.
25
Does that sound like Russell Defreitas is
HOLLY DRISCOLL, CSR
Summation - Whalen
4722
instructing Steven Francis to do anything.
tells him about a camera store on 34th.
goes along with it.
Francis testified that Defreitas wanted a high tech camera and
Russell Defreitas says high tech in all of these recordings,
you can hear it over and over and over again.
Defreitas thinks that high tech is having a camera in the
belly of a plane to prevent theft and Russell Defreitas says
at one point in Government Exhibit 206 that he wants a camera

as small as a head piece for a phone.
11
that's the movies.
Steven
But Russell
That's not high tech,
So, let's look now at Government's Exhibit 229 and
13
Government's Exhibit 50.
14
thing.
I'm not going to show you the whole
I'm just going to play portions of each of them.
15
16
Russell Defreitas
That's not an instruction.
10
12
Steven Francis
You've seen a little of these on Ms. Ahmad's

summation.
17
(Whereupon, the videotape is played.)
18
MS. WHALEN:
So, that's the video when they're
19
inside of the truck and then this is the video that was taken
20
by the camera and just to explain, some of these exhibits may
21
look slightly different than what you've seen here before but
22
we had a major computer meltdown and our copy of the exhibits
23
were damaged so we had to substitute with some other earlier
24
ones.
25
(Whereupon, the videotape is played.)
HOLLY DRISCOLL, CSR
Summation - Whalen
MS. WHALEN:
4723
Ladies and gentlemen, if these exhibits
differ in any way with what's in evidence, what's in evidence
controls, not these, these are second best.
gentlemen, the reason I played these for you is that the
government is arguing that Russell Defreitas taking this video
is evidence of him intending to join the conspiracy but how
can the government honestly tell you that Russell Defreitas
took that video.
couldn't see what he was filming and you don't have the
But ladies and
He couldn't turn the camera on or off.
He
10
camera in evidence for yourself to judge whether it's high
11
tech or simply small and whether it's difficult to use, as
12
Steven Francis claimed, or whether Russell Defreitas is just
13
an idiot.
14
But, ladies and gentlemen, Steven Francis paid for
15
the camera so why would Russell Defreitas say no.
16
Francis is treating Russell Defreitas as someone important
17
enough to buy a video camera for and Russell Defreitas gets to
18
have a video record of how impressive his knowledge of JFK is
19
to show his friends and if you listen to those tapes, Russell
20
Defreitas is so impressed with that pathetic video, he talks
21
about it as his accomplishment, the way he talks about it
22
being an accomplishment to drive along public roads at the
23
airport and claim that he accomplished in two days by driving
24
around those roads what it would take others years to do.
25
That's just the talk of a broken man who has nothing.
HOLLY DRISCOLL, CSR
Steven
Summation - Whalen
1
2
3
4724
And ladies and gentlemen -- if we could switch back

to the Elmo.
Ladies and gentlemen, compare what you see in
Government's Exhibit 22 to what you see from the video when
they're coming around the Bergen Basin, the Air Train from
Howard Beach goes that way, and when they're coming around the
Van Wyck Expressway, when you're coming down this way towards
the terminals, the Air Train goes that way as well.
likely that everything that's recording on that video can be
10
11
So, it's
seen simply from the Air Train at JFK.

Now, although Mr. Carbonaro testified that no one
12
asked for permission to conduct surveillance at the airport,
13
the government hasn't shown you one sign at JFK that tells
14
people they can't videotape.
15
presented in evidence here that people can't photograph and
16
they can't videotape.
17
Russell Defreitas didn't get permission when there are no
18
signs putting people on notice that they need permission to
19
conduct surveillance.
20
There's not one sign that's been
So, how can the government claim that
And just because Russell Defreitas is acting like a
21
fool hiding in the back seat making a videotape doesn't mean
22
he's breaking the law.
23
through this time, just like when they first met, Steven
24
Francis is Russell Defreitas' personal chauffeur, he's driving
25
him wherever he wants to go, he's running all of his errands
It just means he's a fool.
HOLLY DRISCOLL, CSR
And all
Summation - Whalen
4725
and Steven Francis testified he did this every day they were
in New York.
agreement to be with Steven Francis isn't evidence of an
intent to join a conspiracy, it's just evidence that he takes
advantage of what's on offer.
Why would Russell Defreitas say no to this.
His
Now, eventually Steven Francis and Russell Defreitas
go back to Guyana but, again, Russell Defreitas' travel isn't
evidence that he has any intent to join the conspiracy.
Rutherford bought Russell Defreitas a return ticket so that
10
Russell Defreitas after he came to New York could go back to
11
Guyana to continue his lawsuit and there's no evidence that
12
Russell Defreitas would have come to New York City at all if
13
he didn't have a return ticket.
14
Rutherford also said that he'd pay for a ticket for
15
Steven Francis to come down as well but he never did and
16
Steven Francis ended up having to pay for his own ticket
17
through the government.
18
didn't wait for Rutherford to pay for the ticket because
19
Russell Defreitas wanted him to come back right away.
20
not wait to see whether the conspirators were willing to pony
21
up the money for a ticket.
22
Just sending somebody down doesn't demonstrate intent on any
23
of the parts of the people in Guyana.
24
25
Now, Steven Francis says that he
But why
That would be evidence of intent.
And when Steven Francis and Russell Defreitas get

back to Guyana they find there's been absolutely no action in
HOLLY DRISCOLL, CSR
Summation - Whalen
this conspiracy.
one has had contact with Abu Bakr.
supposed to be going to Trinidad, still hasn't gotten his
travel documents and they've been talking about this for
weeks.
Nobody has had contact with Shukrijumah.
No
And Abdel Nur, who is
Who in Guyana is demonstrating any intent to join a
conspiracy?
Rutherford's office in Guyana talking trash.
They're all still sitting on their butts in
9
10
11
4726
(Continued on next page.)
12
13
14
15
16
17
18
19
20
21
22
23
24
25
HOLLY DRISCOLL, CSR
4727
Whalen - Summation
11:47:19
MS. WHALEN:
Now you heard testimony from both
Steven Francis and Donald Nero that everyone was ecstatic
with the JFK video.
ladies gentlemen, you've seen the video and you might want to
take the description with a grain of salt.
Defreitas want the sound edited out of the video unless the
reason everyone was ecstatic was because they were laughing
so hard.
Rutherford cried insha'allah.
Why would Russell
Based on seeing the video, it appeared Rutherford
10
agreed to buy tickets to see Abu Bakr in Trinidad.
11
can't get himself together on time.
12
bought for him is useless.
13
But,
Abdel Nur
The ticket Rutherford
I'm going to show you what's been marked
14
If you see at the very bottom it
15
says this ticket is nonendorseable and I think it also says
16
this ticket is nonrefundable.
17
can't travel because he doesn't have the documents, Steven
18
Francis goes with him the next business day to the travel
19
office to make sure Abdel Nur gets the travel documents, not
20
Rutherford, not Russell Defreitas, not Dawood, not Donald
21
Nero, not Ponytail, people who supposedly have the intent to
22
run the conspiracy.
23
get the ticket or to get the travel documents.
24
Francis goes with Abdel Nur and you can't infer any intent on
25
Russell Defreitas' part from what Steven Francis does.
When it turns out Abdel Nur
Not one of them goes with Abdel Nur to

Steven
M. BRYMER, RPR, OCR
4728
Whalen - Summation
1
At the office Steven Francis lies to a Guyanese
government official to get Abdel Nur travel documents which
he gets.
more.
Rutherford send Steven Francis to the travel office with
Abdel Nur to get a travel document if he didn't intend to
send everyone to Trinidad?
Rutherford said he just didn't have the money anymore.
Rutherford decides he won't pay for the tickets any
Why ask that?
Why send Rutherford or why did
Steven Francis testified
You have the story of Rutherford throwing Steven
10
Francis and Russell Defreitas out of the office when he
11
learns Steven Francis is taking the video off of the
12
computer.
13
is the guy with the money and the access to explosives and
14
Dawood is the guy with access to Shukrijumah, why does Steven
15
Francis fall out with them and stick with Russell Defreitas?
16
Steven Francis knows the government wants Shukrijumah and
17
Steven Francis knows that the government theoretically wants
18
the guys who have the ability to carry out this plot.
19
Does that explanation make sense?
If Rutherford
So, why stick with Russell Defreitas and have a
20
fight with Steven Francis and -- or with Rutherford and
21
Donald Nero?
22
happened is that Rutherford realized no one was interested in
23
the conspiracy and Rutherford realized he was just being used
24
to provide tickets and that's why he's pissed off and that's
25
why he kicked everyone out of his office?
Doesn't the evidence make it more likely what
M. BRYMER, RPR, OCR
4729
Whalen - Summation
1
Now, Steven Francis testified after that Russell
Defreitas goes out and searches for someone new to get into
the conspiracy and Steven Francis testifies that Russell
Defreitas goes to Abdul Wahib who then takes them to Abdul
Kadir.
Francis'testimony.
recordings of the meeting with Abdul Kadir because of the
headlock.
Was there any testimony Steven Francis thought there was any
You have no recordings.
You just have Steven
Steven Francis told you there were no
Why not recording of the meeting with Abdul Wahib?
10
danger with Abdul Wahib.
11
have the best evidence to know whose idea this was to
12
continue.
13
Without the recording you don't
If Russell Defreitas proposed it or why Russell
14
Defreitas would agree to it without any recordings you just
15
don't know.
16
know that Russell Defreitas is still hopeful he and Steven
17
Francis can go into the import/export business.
18
in the later recordings shows that Russell Defreitas had the
19
intent to go into business and that evidence shows you why he
20
had the intent to stick with Steven Francis.
21
One thing is true from the later recordings you
The evidence
Now, Steven Francis and Russell Defreitas meet with
22
Abdul Kadir but the evidence despite the initial meeting is
23
clear Russell Defreitas didn't personally know Abdul Kadir
24
and didn't know him well enough to call him directly.
25
went through Abdul Wahid and once Abdul Wahib says, oh, let's
They
M. BRYMER, RPR, OCR
4730
Whalen - Summation
1
go see Abdul Kadir, Russell Defreitas doesn't say I will call
him directly.
you Russell Defreitas only knew Abdul Kadir as the mayor of
Linden.
of Omar Black (ph.) and that's it.
DeFreitas'own statements to Steven Francis that he tried to
meet Abdul Kadir through his driver at one point and
couldn't.
He still goes through Abdul Wahib.
That shows
Russell Defreitas only knew Abdul Kadir as a friend
And you have Russell
Starting on line 30 Mr. Defreitas says:
You know in
10
the country like for instance, Kadir, when I hear Bilal was
11
always talking about you know I must have met the man since
12
he was a mayor.
13
Annas says:
14
Defreitas:
Wow.
But I tried but he always, ah, ah, he
15
was always in Parliament.
16
Annas:
17
Defreitas:
Okay.
Yeah, I even met the driver and I asked
18
the driver to make arrangement for me to come and meet him.
19
The driver says I can try but he's so busy you know.
20
you what I told him about the driver and he said the driver
21
in America.
22
So, clearly, Russell Defreitas didn't know Abdul
23
Kadir.
24
know him.
25
Tell
He may have been trying to meet him but he didn't
Ladies and gentlemen, I will stay away from Abdul

M. BRYMER, RPR, OCR
4731
Whalen - Summation
1
Kadir's case and you have to decide each man's case
separately, but what I will say is you've seen a lot of
documents concerning Abdul Kadir and his relationship to Iran
and you've seen Abdul Kadir's family photos but you've heard
testimony there's no evidence that Russell Defreitas knew
about any of these things.
will instruct you again as to how you can consider these
items, if you can consider them in any way against
Mr. Defreitas.
And the Judge instructed you and
10
One other thing you need to know though with Abdul
11
Kadir is that business contacts and the mosque were clearly
12
discussed in Guyana because Russell Defreitas talks about
13
them when he gets back to the United States.
14
States Russell Defreitas is talking about import and export
15
and trying to get a business off the ground with Abdul Kadir.
16
In the United
When you look -- when you listen to Government's
17
Exhibit 214, the call when Russell Defreitas talks to Abdul
18
Kadir about the airport which sets off a whole other line,
19
Russell Defreitas goes into talk about import and export
20
deals and Russell Defreitas in the later conversation also
21
talks about building the mosque and is in fact recommending a
22
plumber, Ramadan, to come down and help with the building.
23
Ladies and gentlemen, after this meeting with Abdul
24
Kadir, Russell Defreitas had to borrow money to get back to
25
the States.
Once he got back to the United States he does

M. BRYMER, RPR, OCR
4732
Whalen - Summation
1
2
nothing with respect to this conspiracy.

Steven Francis is the one who gets a computer,
Steven Francis is the one who goes to Google Earth and Steven
Francis is the one who tries to map out JFK.
Defreitas does not have the ability to do that.
listen to the tail end of the recording in Exhibit 214, you
hear how little help Russell Defreitas is when looking at
Google earth.
wants to give it up and call it a night and Steven Francis is
Russell
If you
Russell Defreitas is essentially the one who
10
the one who offers to make prints.
Russell Defreitas isn't
11
directing him or instructing him to do that.
12
Then in 215, Government's Exhibit 215, which is the
13
video of the two men meeting the next day and looking at the
14
map, you hear no complaints from Russell Defreitas about how
15
the map looks.
16
is not in 3D.
17
Steven Francis tells you Russell Defreitas directed him to
18
make a 3D map.
19
There's no complaint about the fact the map

So, again, take it with a grain of salt when
On March 7, 2007, the Government Exhibit 216, Steven
20
Francis has a conversation with Abdul Kadir and Abdul Kadir
21
says his contacts aren't interested in the Chicken Far and
22
after this you have no evidence that Russell Defreitas is
23
interested in doing anything further for this conspiracy.
24
There's no evidence that Russell Defreitas looked for anyone
25
else to participate, there's no evidence that Russell

M. BRYMER, RPR, OCR
4733
Whalen - Summation
1
Defreitas made any plans to go to Trinidad and there's no
evidence that Russell Defreitas had further contact with
Abdul Wahib.
Ladies and gentlemen, the government is clearly
frustrated.
They want to get to Abdul Wahib and they want to
see if they can get to Shukrijumah.
Abu Bakr and they want to see if they can get to Shukrijumah.
You know they do because now the government really starts to
offer good things.
Or they want to get to
They offer free airline tickets to
10
Russell Defreitas through the undercover Mohammad.
11
Francis offers Russell Defreitas a place to stay in Trinidad.
12
Steven
Why would Russell Defreitas say no to any of these
13
things?
In his testimony Steven Francis testified that
14
Russell Defreitas could have paid for plane tickets to go to
15
Trinidad on his own because he was living in that FBI
16
apartment for free.
17
didn't use his own money to buy any plane tickets for that
18
trip to Trinidad.
19
City, Russell Defreitas is doing other things and the fact
20
this conspiracy is going nowhere doesn't matter to him.
21
is evidence he never intended to join it.
22
But the evidence is Russell Defreitas
Russell Defreitas is working in New York
It
Remember once undercover Mohammed had offered the
23
free plane tickets, Russell Defreitas didn't go straight to
24
Trinidad.
25
agreeing to a free trip home isn't evidence of an intent to
Russell Defreitas wanted to go to Guyana first and
M. BRYMER, RPR, OCR
4734
Whalen - Summation
1
join a conspiracy, it is just evidence Russell Defreitas
wanted a free trip home and he has to go with Steven Francis
to Trinidad to get the trip.
everyone is treating him like he's important.
Why not?
Especially because
Also, remember if Russell Defreitas says no to any
of Steven Francis'offers, Russell Defreitas may lose the free
apartment he's living in and Russell Defreitas may lose
Steven Francis driving him everywhere all day.
shows that Russell Defreitas has personal incentives to go
The evidence
10
along with anything Steven Francis proposes.
Continuing to
11
go along with those proposals is not evidence of his intent
12
to join a conspiracy.
13
Russell Defreitas goes with him freely, voluntarily,
14
but the evidence shows to take advantage of the offer and not
15
to commit any crime.
16
Ladies and gentlemen, if you're not sure and you're
17
saying, well, maybe his going shows an intent to commit a
18
crime and somebody else says maybe it shows he wants to take
19
advantage of what's on offer, you have to find Russell
20
Defreitas not guilty because the burden of proof is beyond a
21
reasonable doubt.
22
The government has to prove to you beyond a
23
reasonable doubt that it was Mr. Defreitas' intent to join
24
this conspiracy, not just that it was a possibility.
25
When Russell Defreitas and Steven Francis go to

M. BRYMER, RPR, OCR
4735
Whalen - Summation
1
Guyana, Russell Defreitas doesn't stay in Linden.
in Georgetown.
business.
in Linden with Steven Francis and Abdul Kadir?
He stays
Russell Defreitas is taking care of his own
And if it is Russell Defreitas' plot, why isn't he
Steven Francis testified Russell Defreitas went to
Linden once to show the Google map to Abdul Kadir.
Again,
there's no recording from the meeting and the later recording
of Kareem Ibrahim you know Russell Defreitas doesn't explain
the map, he leaves that to Steven Francis and that other
10
discussion in Linden and when you look at the exhibits
11
presented by the government, you'll notice that a lot of them
12
are from Government's Exhibit 223.
13
that Abdul Kadir had with Steven Francis saying, Oh, you want
14
to do this to meet Abu Bakr, you want to talk to him this
15
way.
16
about Hezbollah and later on fatwa against Salman Rushdie and
17
Iran.
18
That was the conversation
It's the recordings where they had the discussions
Ladies and gentlemen, Russell Defreitas was not
19
present for that conversation.
20
the recording, Defreitas was not there.
21
listen to that regarding about Abdul Kadir telling Steven
22
Francis how to meet Abu Bakr.
23
Look at the record, listen to

Also, look and
Look at what Steven Francis says:
24
Mohammed to speak.
25
speak?
Me, I'll allow
Steven Francis will allow Mohammed to
He quickly recovers because he knows he's wearing a

M. BRYMER, RPR, OCR
4736
Whalen - Summation
1
recording device and he says, Oh, yeah, it is not my idea
anyway.
inspire for this.
decide.
It is Sheikh Mohammed.
He's the one that said I
He comes back with:
I let him speak and decide?
I let him speak and
If Russell Defreitas is
running this thing, if Russell Defreitas is instructing
Steven Francis in everything, as Steven Francis testified,
what's this talk of allowing and letting?
evidence that Steven Francis is the one who's running the
Isn't this
10
show?
11
Russell Defreitas' intent, why isn't Russell Defreitas in
12
Linden talking to Abdul Kadir and getting the instructions
13
detailed in the recording 223.
14
And if this is Russell Defreitas' conspiracy, this is
Clearly, the evidence shows it is not Russell
15
Defreitas' conspiracy and it is not his intent.
16
shows Russell Defreitas is going along because he's being
17
offered all sorts of free things and people are listening to
18
his nonsense and treating him as if he's important.
19
weak-minded, foolish man with a big mouth wouldn't take
20
advantage of that?
21
The evidence
What
Now Steven Francis testified Russell Defreitas paid
22
for the ticket for Abdul Nur to go to Trinidad.
The
23
government wants you to believe that's evidence of Russell
24
Defreitas' intent to join the conspiracy.
25
Abdel Nur's participation and let's look at the ticket.
Let's look at
M. BRYMER, RPR, OCR
4737
Whalen - Summation
1
Russell Defreitas didn't want Abdel Nur to go to
Trinidad.
Russell Defreitas talks to Abdul Kadir about using
the third ticket they got from undercover Mohammed.
Steven Francis is the one who wants Abdel Nur to go.
Russell Defreitas eventually agrees to let Abdel Nur go
because he was begging.
But
And
Think about how that ticket was purchased.
Francis first testified Russell Defreitas bought the ticket.
Then he clarified that Russell Defreitas paid for the ticket.
10
Then he further clarified that Russell Defreitas paid for the
11
ticket out of money he had originally borrowed from
12
Shafek (ph.), not from his own money.
13
if Russell Defreitas is paying for the ticket and Abdel Nur
14
and Russell Defreitas are in Georgetown and Steven Francis is
15
in Linden, two hours away, why does Steven Francis have to
16
come to Georgetown to buy the ticket that Russell Defreitas
17
is paying for when Russell Defreitas is already in
18
Georgetown?
19
wouldn't actually buy the ticket?
20
If he thinks that, isn't that evidence that Russell
21
Defreitas' intent wasn't to belong to any conspiracy?
22
Steven
Ladies and gentlemen,
Did Steven Francis think that Russell Defreitas

Is that why he was there?
Ladies and gentlemen, Abdel Nur, no matter what the
23
government says clearly did not have any intent here.
He
24
agrees to talk to Abu Bakr for these guys because he wants
25
money and he wants to get out of Trinidad.
And look at the

M. BRYMER, RPR, OCR
4738
Whalen - Summation
1
recordings, listen to the recordings between Steven Francis
and Abdel Nur.
Nur money and then asks Abdel Nur what he thinks as to
whether Abu Bakr would be interested in the plan.
listen to it in Government's Exhibit 218 and Government's
Exhibit 221.
ticket, Steven Francis asks Abdel Nur if he thinks Abu Bakr
is going to be interested in shining.
going to say?
10
Steven Francis always promises to send Abdel
Before really committing to sending money or a
No?
What is Abdel Nur
If he says no, is he going to get the
money or the ticket to Trinidad?
11
You can
Who knows?
But if you listen to the conversations you can
12
almost hear Abdel Nur thinking about what to say to make sure
13
he gets the money and gets the ticket.
14
Trinidad Abdel Nur disappears for two days.
15
Francis'number but he doesn't call him.
16
Mr. Defreitas and Kareem Ibrahim have to go out to look for
17
him.
18
or not he told Abu Bakr about the plan, Abdel Nur's response
19
tells him nothing
Once they get to

He has Steven
Steven Francis and
When Steven Francis confronts Abdel Nur about whether
20
I think you remember this conversation, because it
21
is the one where Steven Francis says what do you mean, so,
22
so, so?
23
answers if he want to do it,he'll do it.
24
do it, if he no, ah, ah, ah, that he could get it sell
25
because he would do it in a way that he would get other
No, exactly what did you told him?
And then Nur
If he don't want to
M. BRYMER, RPR, OCR
4739
Whalen - Summation
1
contacts to sell it, to keep him out because you know he has
to be out of it but when he sell it so, so little funds can,
you know, whatever.
brother can get to sell, we can say, well, if, but then he
said it's gonna take time and Abu Bakr got the more, got the
more contacts.
them.
8
9
Once you can get to sell, if the other
He will do it faster.
The Shiites, most of
What does that mean?

Finally, how do you know that Russell Defreitas
didn't have the intent to join the conspiracy?
You know he
10
didn't have the intent because of what happened in Trinidad
11
with Kareem Ibrahim and what was recorded in Exhibit 224 and
12
230.
13
Russell Defreitas learned firsthand that Abu Bakr was
14
dangerous and Russell Defreitas decided on his own not to go
15
to Abu Bakr.
16
Russell Defreitas learned Abu Bakr has no money,
Now, Russell Defreitas and Steven Francis didn't
17
know they were going to meet Kareem Ibrahim.
18
they were staying with some student of Abdul Kadir's and they
19
had no discussion with Abdul Kadir, with anyone on any
20
recording about Kareem Ibrahim.
21
Kareem Ibrahim or Russell Defreitas tried to present
22
accomplishments to Kareem Ibrahim and butters him up with all
23
the talk and claims about Kareem Ibrahim's knowledge,
24
importance and being the best candidate.
25
They thought
But once they're there
Russell Defreitas has only known him for four days.

M. BRYMER, RPR, OCR
4740
Whalen - Summation
1
Russell Defreitas decides to show him the plan and then asks
him what do you think of our accomplishment?
gentlemen, before that video is shown, before he shows Kareem
Ibrahim his accomplishment, he tries to sell Kareem Ibrahim
the water purification machine.
trying to sell Kareem Ibrahim on a plot to blow up JFK he's
also trying to get him to invest in a water purifier?
that what he planned to do with Abu Bakr?
plot and then turn it around into a way to invest into his
But, ladies and
So, at the same time he's
Is
Talk about the
10
water purifier?
11
to be played with, that Abu Bakr was the real thing, that Abu
12
Bakr is a real terrorist?
13
decided he didn't want to be part of this anymore?
14
instead he turns to another old man, if you listen to the
15
recordings, who thinks the video is worth millions and talks
16
foolish talk.
17
tower, feed, cargo and all the death and destruction.
18
Russell Defreitas agrees to leave the video and map with
19
Kareem Ibrahim after knowing him for only four days
20
But then find out that Abu Bakr is not a guy
Is that when Russell Defreitas

So,
All the fantasies come out again, about JFK,
Steven Francis testified that Russell Defreitas did
21
all of this because he was afraid he would get caught.
22
Ladies and gentlemen, Russell Defreitas wouldn't leave that
23
video with Rutherford.
24
Defreitas was always worried someone would try to take it
25
from him.
And Steven Francis testified Russell
Why would Russell Defreitas leave the video with

M. BRYMER, RPR, OCR
4741
Whalen - Summation
1
Kareem Ibrahim, a guy he had only known for four days, unless
he was finally coming to his senses?
Ibrahim admits to Steven Francis he doesn't have anything but
scholarly contacts in Iran?
really have the ability to deal with this.
6
7
Especially when Kareem
He doesn't know anyone who could
Then we come to Government's Exhibit 230 and I'm

just going to ask you to listen to clips A, B and C.
(Recording played.)
MS. WHALEN:
I know I'm the only thing standing
10
between everybody and lunch.
11
hear the tapes you can listen to the entire tape when you're
12
back deliberating in the jury room or when you're out here
13
listening to it, but this is when Russell Defreitas realizes
14
his fantasy and his trash talking has gone too far and it is
15
when he realizes his life is in danger.
16
basically says to Russell Defreitas he's afraid to go through
17
with the plan, Russell Defreitas realizes, yeah, he is and he
18
has Abdel Nur laughing at him in the corner, what a complete
19
humiliation.
20
Nur thinking he's a joke.
21
Ladies and gentlemen, when you
When Steven Francis
Early in the conversation he talks about Abdel
What does Russell Defreitas do to save face?
He
22
continues to talk about the plan the next day, comes up with
23
new codes, talks about increasing the nonprofit to take the
24
money, he agrees to be the trainer of six good men who will
25
roll out of the back of the truck like Ninjas.

M. BRYMER, RPR, OCR
4742
Whalen - Summation
1
How does Russell Defreitas go from the guy who in
January is saying to Steven Francis how do you think this is
going to happen to Ninjas rolling out of the back of a truck
in May?
almost every day getting rides to work and such?
Russell Defreitas been with?
who testified here that he worked at security in a mosque,
Steven Francis, and who testified that security guards at the
mosque dress in black with hair -- black hats and they darken
Who has Steven Francis been with for six months

Who's
He's been with Steven Francis
10
their beards?
11
training?
12
Francis.
13
good men came out of his talk with Steven Francis.
14
Steven Francis.
Steven Francis.
Who had martial arts
Who knew about Ninjas?
Steven
It is clear these new fantasies about training six
I'm not saying Steven Francis told Russell Defreitas
15
that he would have to do this or that he should do this, but
16
when you listen to those conversations and hear how Russell
17
Defreitas just picks up on one little thing and takes off on
18
it into making it some big fantasy story, this discussion
19
doesn't show any more commitment or any more intent to commit
20
a crime on Russell Defreitas' part.
21
In the end, in Trinidad, Russell Defreitas' nonsense
22
was caught.
Russell Defreitas was afraid of a real
23
terrorist.
24
machine to Abu Bakr.
25
guy.
He didn't want to go sell his water purification

Russell Defreitas was too afraid of the
In the end, if you listen to the recordings who wants

M. BRYMER, RPR, OCR
4743
Whalen - Summation
1
to call Abdul Kadir about the changes?
Steven Francis makes the phone call and then passes the phone
to Russell Defreitas.
It is Steven Francis.
Who wants to discuss the type of communication when
you listen to this tape and hear Kareem Ibrahim and Russell
Defreitas talking?
talking about the kind of communications in this plan?
Steven Francis.
Defreitas are talking trash.
10
Who is the person who brings them back to

It is
Prior to that Kareem Ibrahim and Russell
If Steven Francis brings them back to conspiracy
11
plans that's Steven Francis's intent, not Russell Defreitas'.
12
When Russell Defreitas says to Kareem Ibrahim just deposit
13
money for the scheme in Abul Kadir's account, who is the one
14
who's desperate to call Abdul Kadir?
15
It is Steven Francis.
Steven Francis says in one of the recordings you
16
need to call him immediately and let him know, you need to
17
ask him.
18
later comes back:
19
Defreitas tells him you can tell him.
20
doesn't know if Abdul Kadir is going to agree to this.
21
pretty clear from the recordings Russell Defreitas doesn't
22
care.
23
Defreitas now that scary Abu Bakr is out of the picture.
24
25
Russell Defreitas says be my guest.

You want to tell him or I?
Steven Francis
Russell
Russell Defreitas
It is
This is all back to being a story for Russell
In some of these recordings, if you listen to them,

you see examples of how Steven Francis presents things.
M. BRYMER, RPR, OCR
4744
Whalen - Summation
1
He'll say, Oh, Sheikh Mohammed agreed to call you and allow
you to know this.
listen to the recordings, you hear Steven Francis saying we
should call so and so, we should call so and so.
get on the phone it is, Oh, Sheikh Mohammed instructed me to
call you.
Sheikh Mohammed agreed to call?
If you
When they
Listening to Exhibit 226, at the airport in
Trinidad, Steven Francis is the one who wants to make a plan.
Steven Francis is the one who wants to set up a date.
10
Francis is the one who wants everybody's address.
11
does.
12
Steven
Clearly he
He wants them for the U.S. Government.

Russell Defreitas is saying, Oh, that could wait, we
13
don't have to do that now.
14
checked out of this whole thing.
15
Russell Defreitas is clearly
And the later phone calls, there is no evidence of
16
intent on Russell Defreitas' part either.
17
of his fantasy talk.
18
Russell Defreitas knew that Abdul Kadir was traveling to
19
Iran.
20
There is just more
There's no evidence in this case that
Let's look at some of the ways the evidence has been
21
presented to you.
First of all, you heard from Donald Nero.
22
Donald Nero is either a liar or had a bad memory.
23
trust him.
24
after Russell Defreitas was arrested.
25
cooperation agreement and the ability to stay in the United
You can't
The government sought him out more than a year

They promised him a
M. BRYMER, RPR, OCR
4745
Whalen - Summation
1
States.
You he heard about the charges, knew about the
arrest.
Why wouldn't Donald Nero tell the government what
they wanted to hear in order to come to the United States
where he so desperately wanted to be?
Donald Nero's story about why he joined this
conspiracy makes no sense.
He testifies he wanted to come to
the United States for the wonderful economic opportunities,
so much so he was willing to try and come illegally and then
10
decides to join a plot to blow up JFK Airport.
11
tells you it is because he was unhappy with the way Muslims
12
were being treated in Kosovo.
13
the Muslims are being treated in Kosovo go blow up an airport
14
in Serbia.
15
he joined the conspiracy makes no sense and it is probably
16
just a lie.
17
Why?
He
If he's unhappy with the way
JFK has no connection.
The explanation as to why
Donald Nero wanted to make amends for his
18
involvement in the alleged conspiracy.
19
be a lie.
20
year before the FBI came to talk to Donald Nero.
21
Nero was so rapt with guilt, why didn't he call them and
22
confess?
23
and sat there and watched a video and he said this would be
24
the kind of explosives we should use.
25
That also appears to
Mr. Defreitas had been arrested for more than a

If Donald
Basically, his testimony was he talked to one guy
Why confess?
That was it.
Why plead guilty to a crime carrying a

M. BRYMER, RPR, OCR
4746
Whalen - Summation
1
sentence of life in prison when that's all he did?
no one could force him to come to the United States.
no one could force him to go to jail here and he knew no one
could force him to plead guilty to the crime.
He knew
He knew
Now, he has a cooperation agreement and the promises
made are pretty substantial.
a sentence as low as time served.
come to the United States maybe time served with a promise of
a visa afterwards looks like a good deal.
10
He tells you himself he can get

If he wanted to really
There's one other thing Donald Nero testified and
11
that is that he was lying when he told Annas he knew
12
Shukrijumah.
13
presented that Shukrijumah is one of the top Al Qaeda
14
operatives who lives freely throughout the Caribbean I argue
15
the evidence points in another direction.
16
Maybe Nero did lie, but on the evidence being
When Nero wasn't in custody, when he was speaking
17
with Steven Francis he admitted to knowing Shukrijumah.
18
that in fact is true and if Shurkijumah is the bad Al Qaeda
19
guy the government's expert Matt Levitt claims he is,
20
Shurkijumah might not be too happy about a long time friend
21
planning to see him with a guy who turns out to be a FBI
22
informant and to Donald Nero a U.S. jail cell might look like
23
a pretty safe place especially if it comes with a U.S. visa
24
after release.
25
If
Donald Nero's recollection about his behavior with

M. BRYMER, RPR, OCR
4747
Whalen - Summation
1
Steven Francis indicates he is a liar, bad memory and you
can't trust him as a witness.
any meetings at his house, doesn't remember taking any lead
in planning before Rutherford joined, doesn't remember asking
Steven Francis for any favors like help for his wife in
either coming to Guyana or finding an apartment, doesn't
remember asking for immigration help for himself to get
married again illegally to come to the United States.
Donald Nero didn't remember
Steven Francis doesn't remember any kind of personal
10
dispute between himself -- or Donald Nero doesn't remember
11
any personal dispute between himself and Steven Francis that
12
ended the relationship.
13
Steven Francis testified to that.
Now, Nero claims that Russell Defreitas threatened
14
to shoot him in his joints.
15
getting too long.
16
which is the first or -- the first recording from when
17
Russell Defreitas is back in New York City, he and Steven
18
Francis are talking and if you listen to that recording, the
19
part that hasn't been transcribed, you'll hear Russell
20
Defreitas talking about the fight that he had with Donald
21
Nero and how Steven Francis brought them back together and
22
Steven Francis told them that they should conciliate and
23
Steven Francis got them back together and made peace between
24
them.
25
I won't play the clip.
It is
If you listen to Government's Exhibit 204,
So, ladies and gentlemen, if there had ever been

M. BRYMER, RPR, OCR
4748
Whalen - Summation
1
this kind of threat to shoot him in his joints, Steven
Francis made it right again.
again, this whole thing might have fallen apart long before
the video in Government's Exhibit 50 was ever made.
If he hadn't made it right
So, Donald Nero's testimony adds nothing to this
case.
At best he has a bad memory and his testimony is not
proof beyond a reasonable doubt and at worst he's a liar and
that also means his testimony is not proof beyond a
reasonable doubt.
10
Then you have to look at Steven Francis.
Ladies and
11
gentlemen, you can't trust anything Steven Francis says
12
unless you can verify it on the recordings.
13
Steven Francis has too much at stake.
14
with his own little government bail out plan and basically he
15
knows if he commits a crime he can become a government
16
informant and lessen whatever sentence he faces for his own
17
crimes.
18
seems to think it is an achievable goal.
19
That's because
Steven Francis came up
You know here he wants lifetime probation and he
You've seen Steven Francis' cooperation agreement;
20
it is in evidence.
21
based upon what the special prosecutor determines is the
22
quality of his cooperation.
23
the prosecutor thinks he has had good enough cooperation.
24
25
He has varying sentences he will get
He can get lifetime probation if
Now, the government seems to imply that simply

because he testified in the grand jury he's already achieved
M. BRYMER, RPR, OCR
4749
Whalen - Summation
1
that goal.
after committing such a serious second drug offense for the
second time, he's got to do something a little bit more than
just testifying in the grand jury and to get lifetime
probation to provide substantial cooperation on a terrorism
case would probably do it.
lie, incentive to fill in the blanks, to explain what people
meant on the tapes in a way most favorable to the government
because he knows the government will be speaking or writing a
10
11
Ladies and gentlemen, I would argue to you that
That gives him an incentive to
letter on his behalf at sentencing.

Just remember his demeanor when he was being asked
12
questions by the government.
13
-- he did answer the questions.
14
answered questions when a defense attorney was asking him.
15
Rarely did he give a "yes" or "no" answer.
16
gave a lengthy answer and if he gave an answer, it was buried
17
in so much verbiage you had no idea what it was.
18
because he didn't speak English.
19
with a message, the government's message, and that was all
20
that Steven Francis was going to testify to you whether the
21
facts of the case fit that message or not.
22
His answers were wordy, but you

Compare that to the way he
He almost always
It wasn't
It was because he came here
Ladies and gentlemen, I don't know if you remember,
23
but he cried on the stand when he was talking about how
24
terrible his time in prison had been.
25
remember he got out of jail from that terrible prison
I just want you to
M. BRYMER, RPR, OCR
4750
Whalen - Summation
1
sentence in April of 2000 and in January or February of 2001
he got back involved in the drug business.
wasn't doing little half gram sales to pay the rent when hair
cutting wasn't going too good.
kilo organization that distributed large amounts of cocaine
and he got involved in that drug conspiracy about nine months
after being released from the prison sentence that drew him
to tears when he testified about it ten years later.
though the memory of it wasn't big enough or horrible enough
Steven Francis
He got involved in a multi
10
to keep him away from drugs nine months after he was
11
released.
12
Even
Remember, too, and I think this is really important,
13
when he was involved in this new crime he was reporting to a
14
Probation Officer.
15
once a month face to face and he was lying to his Probation
16
Officer every month about where he was working, about how
17
much money he was earning and whether or not he was dealing
18
drugs.
19
straight face for more than a year from 2001, when he got
20
involved in that drug conspiracy, until November 2002, when
21
he was arrested, he could lie to you.
22
He was meeting that Probation Officer
If he could lie to a Probation Officer with a
When he talks about his prior crimes, he doesn't
23
accept responsibility or show remorse.
When he was asked
24
about his indictment in the 1994 case, he said it was only
25
for 50 grams of crack cocaine.
On cross-examination it came
M. BRYMER, RPR, OCR
4751
Whalen - Summation
1
out it was for a kilo of heroin as well.
he admitted to more serious crimes in that case was given to
you or presented to you as some sort of evidence of his
trustworthiness.
crimes, but after admitting to those crimes he still got a
sentence that was lower than the one he was facing on the
original indictment.
8
9
And the fact that
But remember he admitted to more serious
So, admitting to more serious crimes and cooperating

worked out pretty well for him.
It is not evidence that he's
10
particularly trustworthy.
11
trying to act like he shouldn't be responsible for all the
12
drugs in that case, that he should only be sort of
13
responsible for the five kilos of drugs he was actually
14
caught with in his hand and what he left in his apartment,
15
they weren't really his.
16
really his just because he didn't get to keep the money from
17
the sales of those drugs, but, ladies and gentlemen, he
18
picked the drugs up, looked after the apartment where they
19
were kept, delivered those drugs and collected the money.
20
So, just because he wasn't the top guy, got to keep most of
21
the money, don't let him pretend he's not responsible for all
22
the drugs.
23
With the case he's facing now he's
Ladies and gentlemen, they weren't
Remember the way he talked about it.
24
to pick it up.
25
what I was told.
I was directed
There were other people there, too.
I did
It doesn't sound like somebody accepting

M. BRYMER, RPR, OCR
4752
Whalen - Summation
1
responsibilities for his actions.
trying to downplay his involvement with those drugs.
It sounds like somebody
Steven Francis is a smooth operator who knows how to
play the angles and you have to examine his testimony with
more than care.
comb.
someone meant, you need to think long and hard about whether
you can trust that explanation and whether you can trust it
beyond a reasonable doubt.
10
You need to go over it with a fine tooth
Anytime he fills in the blanks or explains what
Now, Steven Francis testified that Sheikh Mohammed
11
directed him to do things and, as I said before, listen to
12
those recordings.
13
directing anybody to do anything.
14
You'll hear that Russell Defreitas wasn't
You also heard that Steven Francis improvised, as
15
Detective Napoli called it, in some pretty unlawful ways.
16
lied to a government official to get travel documents and he
17
believed Steven Francis about Abdel Nur being desperate to
18
get out of Guyana.
19
Russell Defreitas to buy a ticket so Abdel Nur could flee.
20
Steven Francis is the one who convinced
You have to look at even the way the other evidence
21
was presented in the case.
22
was asked whether Russell Defreitas had worked at JFK, but
23
not how long he had worked there.
24
cross-examination.
25
He
How on direct Robert Addonizio
That had to come out on
In the testimony about the plane ticket that was

M. BRYMER, RPR, OCR
4753
Whalen - Summation
1
shown in Government's Exhibit 270, Robert Addonizio was
directed and asked these questions:
for Eversley Compton.
He was asked what's
He said an itinerary for flight
In your mind who's Eversley Compton?
Abdel Nur.
Going all the way down:
Again, you mentioned --
remind me, what is this?
The itinerary for a flight.
10
According to Government's Exhibit 270, did Compton
11
Eversley or Abdel Nur obtain a flight ticket in late January
12
2007, returning in early February?
13
"Answer:
14
Then they go through the flights.
15
What day is that?
16
28 of January 2007.
17
Was there a return flight?
18
Yes.
19
What date?
20
February 5th, 2007.
21
What date was that ticket issued, the itinerary
22
Yes, he did."
issued?
23
26th of January 2007.
24
Where did you first see this document, Government's
25
Exhibit 270?
M. BRYMER, RPR, OCR
4754
Whalen - Summation
1
In Georgetown, Guyana, on the 10th of June 2007.
About four months after the return?
Prior to that date, prior to June 10th, 2007, did
you know that Abdel Nur had a plane ticket in late January
from Georgetown to Port of Spain returning about a week
later.
No.
Is it fair to say the FBI can't track all foreign
travel?
10
Correct.
11
Ladies and gentlemen, it looks like he's being asked
12
the question and giving an answer that makes it look like
13
Abdel Nur flew when the government knew he hadn't.
14
Abdel Nur screwed up, they knew Abdel Nur hadn't gotten
15
travel documents and they knew that because Steven Francis
16
was sent two days later to go with Abdel Nur to get them.
17
They knew
Now, maybe the government didn't know the ticket had
18
actually been purchased, but they knew the tickets were in
19
the works and they knew that Abdel Nur never flew and they
20
knew it because Louis Napoli wrote it up in his 302 on report
21
from Steven Francis.
22
23
24
25
If this case is so strong, why do they have to play

games with the evidence like that?
Ladies and gentlemen, Exhibits 51, 59, 52, these are
Government's Exhibits 51 through I believe 60 or 61, and
M. BRYMER, RPR, OCR
4755
Whalen - Summation
1
these are all shots and they were presented to you as shots
that were somehow made in the course of this case, but Steven
Francis testified that they came from the video.
didn't make these shots and Russell Defreitas didn't make
these shots.
the video?
But he
Why present them to you like they're part of
Why not just show you the video?
Then, with some of these recordings, some of these
recordings are long and some portions are irrelevant.
talk to you about it and you can listen to it.
I will
I think you
10
remember and they played it for you this afternoon, Dawood
11
asking Steven Francis do you want to die as a martyr?
12
that's a pretty shocking question until you listen to the
13
very beginning of that call and you hear Steven Francis
14
saying that he was just out praying for the brothers who gave
15
their all for the events of five years before.
16
September 10th.
17
he admitted on cross-examination he was talking about the
18
brothers who had given their all, the terrorists in the
19
events of September 11th.
20
Yes,
It was
So, Steven Francis is talking -- and I think
Then, when later on Dawood asks him do you want to
21
die as a martyr, the only shocking thing is it took Dawood
22
ten minutes to decide if he was going to answer the question.
23
Finally, you're left with statements Russell
24
Defreitas made on the night of his arrests.
Who knows what
25
questions Russell Defreitas was asked to make those

M. BRYMER, RPR, OCR
4756
Whalen - Summation
1
statements.
Mr. Defreitas for almost a year, recording as many of his
conversations as they could.
he said when he was questioned after his arrest?
be usual procedure in an FBI investigation like a bank
robbery or drug bust, but in this case after the government
has been recording the guy for almost a year, why wouldn't
the FBI want you to know exactly what they asked
Mr. Defreitas and exactly what he said?
10
The government was conducting surveillance on
So, why didn't they take what

It may not
Ladies and gentlemen, the evidence shows that
11
Russell Defreitas didn't have the intent to join this
12
conspiracy.
13
business ventures, import, export, the water purifier.
14
could his intent be to cause major economic damages if he
15
also wants all of these business opportunities?
16
It shows he wanted to make money through his

How
It is clear from the recordings that Russell
17
Defreitas, Donald Nero, Rutherford and Abdul Kadir, all
18
thought that Steven Francis had the ability to go into
19
business.
20
Defreitas' participation indicates an intent to join any
21
conspiracy.
22
The evidence doesn't show that any of Russell
The evidence showed that he was just taking
23
advantage of what was offered, a free apartment, free plane
24
tickets, guy driving him all over New York City and the
25
chance to impress his friends with his trash talking.
The
M. BRYMER, RPR, OCR
4757
Whalen - Summation
1
government offered Russell Defreitas a free apartment, free
plane ticket and a driver and now wants to argue to you
acceptance of those things show intent on his part to join a
conspiracy and commit a crime.
the evidence in this case doesn't prove beyond a reasonable
doubt that Russell Defreitas' acceptance means he's part of
any plot.
takes what is on offer, when it is offered, especially if it
comes with an opportunity to talk.
10
But, ladies and gentlemen,
It could just as easily show he is just a man who
The evidence shows Russell Defreitas was all sizzle
11
and no sting.
12
and experts, with all the window dressing, at least with
13
respect to Mr. Defreitas, the evidence in this case shows
14
that Russell Defreitas was a guppy the government was trying
15
to pass off to you as a shark.
16
of money and didn't get Shukrijumah and Abu Bakr and the
17
lousy video in Government's Exhibit 50 does not show he has
18
intent to join a conspiracy.
19
small mind, big mouth and ugly imagination.
20
The evidence in this case, with its informants
The fact is they spent a lot
Just shows he is a man with a
As I said in the beginning, those aren't crimes,
21
they are character flaws.
22
looking at the evidence presented in this case, you have to
23
find Mr. Defreitas not guilty of every single one of them.
24
Thank you.
25
THE COURT:
Looking at the crimes charged and
Thank you, Ms. Whalen.

M. BRYMER, RPR, OCR
4758
Whalen - Summation
1
I know the jury must be hungry, everybody else is
probably, too.
break for lunch and probably come back at about a quarter to
three.
Your lunches are here.
We're going to take a
And once again, ladies and gentlemen, I remind you
to keep an open mind, not to form or draw any conclusions
about this case.
yourselves or with anyone else about the case during the
lunch hour.
Remember that you can't talk among
You know you are allowed to use cell phones to
10
call home, check in at work, so on.
11
your phones to talk with anybody about this case or to look
12
at or read or review or listen to anything that might be
13
reported about this case or do any kind of investigation or
14
research connected with this case.
15
either of those two things, read or look at or listen to
16
anything about this case or do any kind of research or
17
investigate this case over any kind of media.
18
19
Remember you can't use
In fact, you can't do
So, we will be with you, as I said, at about quarter

to three.
Enjoy your lunch.
20
(The jury exits the courtroom.)
21
THE COURT:
22
can have a seat.
23
we take a break?
All right.
Ladies and gentlemen, you
Is there anything you want to raise before
24
MR. JONES:
25
MR. NKRUMAH:
No, your Honor.

No, your Honor.
M. BRYMER, RPR, OCR
4759
Whalen - Summation
1
2
3
THE COURT:
charge.
All right.
The marshals can take
We'll resume at a quarter to three.

(Lunch recess.)
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
M. BRYMER, RPR, OCR
SUMMATION - NKRUMAH
4760
A-F-T-E-R-N-O-O-N
THE COURT:
You heard no rumblings back there?
All right.
MS. WHALEN:
No, Your Honor.
I will look, Your Honor.

The Marshals are not up yet with
the defendants.
THE COURT:
MR. KAMDANG:
10
11
I did say 2:45
p.m.
S-E-S-S-I-O-N
THE COURT:
All right.
I hear them now.
You can bring the defendants out,
please.
12
U.S. MARSHAL:
Yes, Your Honor.
13
(Whereupon, the defendants enter the courtroom.)
14
THE COURT:
This is the case on trial continued.
15
The parties are all present.
16
will shortly resume with summations again.
17
summations for -- on behalf of Mr. Kadir.
18
The jury is not present.
We
This is the
Just so that I have an idea, Mr. Nkrumah, more or
19
less when I can give the jury a break before the Government's
20
rebuttal, how long do you think you are going to be, more or
21
less?
22
23
24
25
MR. NKRUMAH:
More or less, Your Honor, about an
hour.
THE COURT:
All right.
And we just did a sound
check on the podium laptop.

SUMMATION - NKRUMAH
1
2
3
4761
Are you going to go back and forth between the

documents and the computer?
MR. NKRUMAH:
I have a couple of transcripts that I
am going to show on the screen.
THE COURT:
MR. NKRUMAH:
THE COURT:
Okay.
We want to put them on the computer.
Okay.
So you let us know, and I will
have my law clerk control that on the screen for you.
let us know when you need one or the other.
10
MR. NKRUMAH:
11
THE COURT:
12
Yes.
So if everyone is ready, we will go send
for the jury.
13
THE CLERK:
14
(Whereupon, the jury enters the Courtroom at
15
2:55 p.m.)
16
THE COURT:
17
18
All rise.
Do all of the parties agree that all of the jurors

are present and properly seated?
20
MR. MILLER:
21
MR. NKRUMAH:
Yes, Your Honor.
22
MR. KAMDANG:
Yes, Your Honor.
23
THE COURT:
25
Welcome back
ladies and gentlemen.
19
24
Just
Yes, Your Honor.
We are continuing, ladies and gentlemen,
with the summation by the parties.

On behalf of Mr. Kadir, Mr. Nkrumah will be summing

SUMMATION - NKRUMAH
4762
up.
You may start when you are ready.
MR. NKRUMAH:
(SUMMATION - MR. NKRUMAH.)
MR. NKRUMAH:
THE COURT:
MR. NKRUMAH:
THE JURY:
MR. NKRUMAH:
May I begin, Your Honor?
Yes, you may.

Good afternoon, ladies and gentlemen.
Good afternoon.
We are living in a dangerous world
10
today.
11
a world -- we are living in a world where people harm people
12
for no reason.
13
I think everyone will agree we are.
9/11 changed the game for us.
We are living in
It changed the game
14
for us as Americans.
15
now experience the terror that other countries have been
16
experiencing for decades.
17
It changed the game in the way that we
I agree with the Government that we, as a country,
18
should do things to protect ourselves.
19
right.
20
convicting an innocent man, it does not make our world any
21
safer.
22
more dangerous.
23
I believe it is their
I believe it is their duty to protect us.
But
As a matter of fact, it just makes it just that much
Mr. Abdul Kadir was never ever part of this
24
conspiracy.
Now, you've heard a lot of testimony.
25
heard a lot of testimony.
You've
The Government even said hundred of

SUMMATION - NKRUMAH
4763
hours of tapes, recordings, a ton of testimony.
So we are
going to talk about that testimony, me and you.
We're going
to talk about that testimony right about now.
This conspiracy started in 2006.
It is clear that
Mr. Abdul Kadir was not a member of the conspiracy in 2006.
It is clear.
That is not my client.
clear that Mr. Defreitas doesn't know my client, despite what
they say.
10
Now, there was some testimony about Abdul Kabir.

They didn't know my client.
It is
He didn't know my client.

When this conspiracy first started there were
11
certain players and there were certain objectives:
12
JFK, finding Adnan Shukrijumah; that Abdul Kadir wasn't a part
13
of that.
14
this man, Talib Rutherford, was a part of this conspiracy.
15
had nothing to do with Talib Rutherford, never spoke to him,
16
never met with him, nothing.
17
18
Blowing up
Abdul Kadir was not a part of this conspiracy when

He
Donald Nero wasn't a part of the conspiracy, never

spoke to him, never met with him, nothing.
19
Abu Bakr never spoke to him -- never spoke to him.
20
We are going to get back to Abu Bakr.
21
He never wrote him.
22
plot.
He never spoke to him.
He never called him.
Nada about this
23
You had heard a lot of testimony about Abdel Nur.
24
You have heard a lot about the things that Abdel may or may
25
not have wanted to do.
And you have the tapes.

You can
SUMMATION - NKRUMAH
4764
listen to the tapes.
does sound like what Ms. Whalen said; that he was really
trying to get money.
From what is said about Abdel Nur, it
But that is for you to decide.
But the one thing that I can tell you is you won't
hear a tape.
discussing anything with Abdel Nur.
You will not hear a tape with my client
Adnan Shukrijumah.
The bogeyman.
The bad guy.
And
if what they say about him is true, he is a bad guy, and he is
someone that should be brought to justice.
10
Kadir know him?
11
try to seek him out?
12
No.
But did Abdul
Did he speak with him?
No.
Did he ever
No.
Kareem Ibrahim.
Kareem Ibrahim.
We are going to
13
talk about him too because he pops up somewhere later on.
14
you have the tapes.
15
him.
16
to his home.
17
Defreitas or Steven Francis to Kareem Ibrahim's home.
18
we'll talk about that too.
19
did anything with Kareem Ibrahim but testify that he hadn't
20
spoke with him in almost 25 years until the night Steven
21
Francis and Russell Defreitas were at his home.
22
talk about him again.
23
You have everything.
But
He never spoke with
He never directed Steven Francis and Russell Defreitas

Let me repeat that.
He never directed Russell
He never spoke with him.
And
He never
But we will
That leaves Russell Defreitas and my client.
But
24
there is one person missing, and his picture should be up
25
there huge.
And that is Steven Francis because when you go

SUMMATION - NKRUMAH
4765
back to the tape, as Ms. Whalen said just a little while ago,
it is Steven Francis that is talking to Abdul Kadir for the
most part and no one else.
Not Talib Rutherford.
Not Shukrijumah.
Not Abdel Nur.
No one but Steven Francis.
They talk to you about conversations that they had
that aren't recorded, conversations that my client joined in
on this conspiracy.
his home.
We are going to talk about the significance of them calling
10
him on his cell phone in a minute, but they call him on his
11
cell phone and they say, "Can we come by?"
Abdul Kadir received a phone call from
He is at home.
12
"Yeah."
13
So they come by.
They call him on his cell phone.
They come by, and they talk.
As
14
the evidence has already pointed out, first thing they talk
15
about is business.
16
they talk about Abdul Kadir building a mosque in Guyana.
17
this isn't the first time they talk about this.
18
remember, Abdul Kadir testified when he first met with
19
Mr. Defreitas.
20
you.
21
employer.
They talk about export and import, and
If you
Mr. Defreitas told him, "I am so happy to meet
I know -- I know someone who knows you.
22
Now,
He is my
He talks so highly of you."

And they also talk about business.
No plots; no
23
JFK; no plan; importing, exporting Guyana's best; and his
24
mosque.
25
their separate ways.
Mr. Kadir gives Mr. Defreitas his car and they go

SUMMATION - NKRUMAH
4766
Then he meets Mr. Francis the next day.

That conversation is not taped.
Then they
come to his home.
Mr. Francis says he doesn't tape the conversation because he
is scared of Mr. Kadir.
going to say that he was or he wasn't.
think that you do too, but I am not going to say that he was
or he wasn't.
Okay.
And
We weren't there; so I'm not

I have my idea and I
But he doesn't record the conversation.
one of the most important conversations in this whole thing
10
when you talk about Abdul Kadir because he wasn't in any of
11
that -- all of that other stuff that happened before.
12
wasn't a part.
13
matter if they met every week or whatever.
14
of that.
15
16
17
He
No matter if they got it off of the ground, no

He wasn't a part
He didn't meet them.

So this conversation is the conversation that brings
him in.
Steven Francis says that my guy joined the plot.
18
Abdul Kadir says that he doesn't.
19
we don't know who is telling the truth.
20
But that is
There is no recording; so
Or do we?
Steven Francis was charged to report to his handler
21
anytime that he possibly could.
When he was overseas, when he
22
was home, when he was finished dealing with whoever he dealt
23
with he was supposed to report.
24
report, he was also supposed to give pertinent information.
25
Well, Detective Napoli testified that was Steven Francis'
Not only was he supposed to

SUMMATION - NKRUMAH
4767
handler, and he testified about how Steven Francis was
supposed to give the report and how he gave the report and
when he was safe and everything else.
a full report at one point, he would tell him things later on.
But you know what is missing from this conversation?
And you have the 302s, and anything that I say you
And if he couldn't give
can verify by just going back to the evidence because
everything that I talk about here --
THE COURT:
10
11
There are no 302s in evidence.
MR. NKRUMAH:
Just going back to the testimony
because everything that I say here is about the testimony.
12
Wondering if Mr. Kadir joined this plot or not, that
13
is important.
14
understand that that is an important point.
15
the transcripts, Mr. Napoli will tell you that Steven Francis
16
never told him that.
17
same day.
18
told him that afterward.
19
when he was sitting on that stand right there.
20
It doesn't take a 20-year detective to

When you check
He didn't tell him the day after or the
It was the same day that he reported, and he never

The first time you heard that is
He also told them -- and this right here, this is
21
the most important part.
He also told us -- he didn't tell
22
Napoli anything, but he also told us when he was sitting on
23
that stand that Abdul Kadir told him about downloading Google
24
earth.
25
And it is just not this conversation where that is talked
That is a huge point in all of this, a huge point.

SUMMATION - NKRUMAH
4768
about.
You can look back over of the transcripts and look at
the conversations about Google earth and see how interested or
how uninterested Mr. Kadir was in Google earth.
conversation, this unrecorded conversation, he tells us that
Mr. Kadir tells him to download Google earth.
the tapes.
But at this
It is not in
It is not in Napoli's notes.
MR. MILLER:
Objection.
MR. NKRUMAH:
THE COURT:
It is nowhere.
Sustained.
10
Napoli's notes are not in evidence.
11
MR. NKRUMAH:
Napoli never testified to it.
12
Actually, he said if he would have told me I would have wrote
13
it down because that is important.
14
Blueprints, the same thing.
If he would have told
15
me I would have wrote it down because that is important.
16
They're sitting there watching the videos.
17
showed us a multitude of videos -- still frames, videos,
18
everything.
19
Abdul Kadir didn't see that.
They don't -- they
He testified that he
20
saw one short clip, and the clip was of somebody recording
21
something, shaking up and down.
22
behind a wall.
23
could get a better look at this by going to Google Earth?"
24
25
It looked like some tanks
He asked them, "Why would you do that when you
He admitted to you on the stand that he said this.

But think about the context in which he said it in.

Think
SUMMATION - NKRUMAH
4769
about the context.
Did he know what they were doing at this
time?
mentioned Google earth to them, he did not know that their
plan was to blow up JFK.
And it is answer is clear.
He did not.
When he
My seven-year-old niece, who loves computers, comes
into a room and says, "Why are you looking at it like that,
Uncle, when you can go to Google Earth?"
we are bringing her in here and charging her for conspiracy,
especially when she doesn't know why I am looking at Google
10
I don't think that
earth.
11
It is no different for Abdul Kadir, even though he
12
found out later on -- later on what he was looking at and why
13
he was looking at it.
14
earth he didn't know what they were planning.
15
evidence.
16
take my word, but I hope that you do.
17
At the time that he mentioned Google
You can look at the transcripts.
It is in
You don't have to
After dealing with this video they still don't talk
18
about the plot.
They walk back into his living room.
19
Remember, they walk out of his living room to go do the video
20
on his little, tiny computer screen, and then they walk back
21
into the living room.
22
something about the plot.
23
was spoken about is anywhere.
24
is not recorded.
25
Francis, out of his mouth, the only place it ever came from.
And Defreitas starts telling him

Again, nothing that Francis says
It is not in any evidence.
It is nowhere.
It
It is just there, from

SUMMATION - NKRUMAH
4770
During that conversation Mr. Kadir talks about after
learning about their plan he decides to himself, you know
what?
with this, but -- but I don't want to lose this possibility
that has been offered to me about trying to finance my mosque,
a mosque that I have been trying to finance for well over
20 years.
I am not dealing with this.
8
9
I am not going to deal
And we will talk about that too.

Income from possible business expedition that is
sorely needed because my work as a consultant -- even though I
10
am an engineer, the work in Guyana is slow; so it is not
11
bringing in the money that I kind of need.
12
children at home plus my wife.
13
14
And I've got five
So he tells them, "Look, I will get back to you.

Give me some time."
15
Have you ever blown anybody off?
Have you ever told
16
anyone -- anyone who is married or used to be married or has
17
a friend who just likes to talk or acquaintance or a coworker,
18
have you ever told anyone, "Yeah, yeah, yeah."
19
something and you heard it and you knew that you weren't going
20
to do it.
21
the moment that he said it to you that you weren't with that,
22
you weren't going to do it, but you didn't tell them?
23
didn't say anything.
24
going to go on.
25
you never do anything.
They told you
Your husband told you something, and you knew from
You
You just let them think that you were
And you go on and you go on and you go on and

That is what happened here.

That is
SUMMATION - NKRUMAH
what happened.
That is exactly what happened here.
Oh, yeah.
a lot of garbage.
did anything.
4771
Abdul Kadir admitted to you he told them
He told them a lot of things, but he never
Now, I am not going to try to read it off of memory
the Judge's instructions.
My memory just isn't that good; so
I am going to read to you instructions that you are going to
hear from Judge Irizarry, if not today, tomorrow, about
conspiracy and becoming a member of the conspiracy because it
10
is not just words, as the Government wants to you believe.
It
11
is not just words that make you a member.
12
sit down and talk about a whole lot of things.
13
down and talk about committing every crime in the world.
14
is not just the words that make us guilty; we've got to do
15
something.
Me or you, we can
We can sit
It
We've got to do something.
16
MR. MILLER:
Objection.
17
THE COURT:
18
MR. NKRUMAH:
19
THE COURT:
20
The Court is going to instruct the jury as to the
Sustained.
It has to be an overt act.
Sustained.
21
law of conspiracy, and it is what I instruct you that controls
22
and not what any of the lawyers refer to in the instruction.
23
(The following was heard at sidebar:)
24
(Matter continued on next page.)
25

SUMMATION - NKRUMAH
MR. MILLER:
4772
That is a sufficiently inaccurate
description of the law.
understands that.
tomorrow, but it is going to be a long, and Mr. Nkrumah just
inaccurately stated the law.
requirement.
7
8
9
10
11
It has to fixed so the jury
I know Your Honor is going to instruct them
There is no overt act
He can't --
THE COURT:
I will add that to the curative.
is no overt act.
MR. MILLER:
THE COURT:
Okay.
I really prefer that counsel stay away
from stating what the law is.
12
MR. NKRUMAH:
13
THE COURT:
14
And these instructions are not 100 percent
15
16
There
completely final.
Can I read the law in?
No.
That is my job.
The conspiracy part is fairly set.
MR. NKRUMAH:
Your Honor, the conspiracy part is
17
set, and the Government in their opening instruction commented
18
on the law when -- she commented on the law in her opening --
19
in her closing statement -- in the opening closing statement.
20
She commented on the law.
21
that they needed to do is talk about the crime.
She told the jury that -- that all
22
MR. MILLER:
That is not what she said.
23
MR. NKRUMAH:
She commented on the law.
24
commented on the law.
25
MR. MILLER:
She
She didn't say what you said she said.

SUMMATION - NKRUMAH
MR. NKRUMAH:
Okay.
4773
All I am asking the Court to
do -- if I'm in correct, all I am asking the Court to do is to
allow me to read the Court's jury instruction that the Court
is going to read into the --
THE COURT:
No.
I am not going to allow you to read
the instructions on the law.
That is my job.
You can argue
the law as to what the elements are and what does and does not
constitute conspiracy.
as you have been saying, you know, he never met with these
You can certainly argue the evidence,
10
people.
He didn't do this or didn't do that.
11
this or he didn't say that.
12
He didn't say
But I am not going to allow you to stand there and
13
read, and then to tell and you read from my instructions?
14
Absolutely not.
15
province.
I am not going to permit that.
16
MR. NKRUMAH:
17
THE COURT:
18
That is my
Yes, Your Honor.
And I am not going to let you say that
you are reading from my instruction --
19
MR. NKRUMAH:
20
THE COURT:
Yes, Your Honor.
-- because that is going to lend
21
credence to what you are saying as to what the law is, and
22
that is inappropriate.
23
MR. NKRUMAH:
24
MR. MILLER:
25
Okay.
I will just ask for a curative
instruction.

SUMMATION - NKRUMAH
MR. NKRUMAH:
I will give it.
(End of sidebar discussion.)
(Matter continued on next page.)
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

4774
SUMMATION - NKRUMAH
THE COURT:
4775
As I mentioned, ladies and gentlemen,
I am going to be instructing you on the law as they relate not
only to the law of conspiracy and what the requirements are,
but also as to the specific charges that are contained in the
indictment and other things, including how to consider the
evidence.
parts that are contained in the indictment that alleges
conspiracy Counts 1 through 5, there is no requirement that an
overt act be committed.
In that regard, with respect to the particular
10
You may continue, Mr. Nkrumah.
11
MR. NKRUMAH:
As I said, you will hear the
12
instruction from the Judge, and when you hear the instruction
13
from the Judge listen carefully to the conspiracy instruction.
14
Listen carefully, and when you hear those instructions, think
15
about Abdul Kadir and what he didn't do.
16
One of the things that we ask you to do is when you
17
walk through those doors and you sit in that chair you use
18
common sense.
19
ask you to leave what you learned in all of your life out the
20
door.
21
You don't actually leave it outside.
We don't
We ask you to use common sense.

So I am going to ask you to use common sense right
22
now, and I am going to talk about what Mr. Kadir did.
23
am going to ask you, does it sounds like someone who really
24
wants something to happen?
25
And I
Other than one conversation, they always contacted

SUMMATION - NKRUMAH
Always.
4776
Mr. Kadir.
time the Chicken Far was brought up, except one conversation.
All Mr. Kadir ever did was say, "Uh-huh.
goods.
Uh-huh.
They had always contacted him.
Okay.
And every
That sounds
Okay."
Contacts.
He never said anything about introducing
them to contacts in Venezuela or Iran.
Steven Francis said that is not in the evidence anyplace else.
Not from Abdul Kadir, not from the testimony of Detective
Napoli.
From no one.
10
11
Who did he contact?
Do you know?
Do I know?
Do
they know?
12
13
That is something that
What are the phone records?
Where are the phone
records to the say that he had contacted anybody?
14
Investigator Addonizio testified that they had
15
cooperation from the Trinidadian government, the Guyanese
16
government.
17
No phone records to show that he contacted anybody, just him
18
saying it because he is blowing them off to that point.
19
when I say blowing them off, I am not saying that he didn't
20
want anything to do with them.
He had never said he didn't
21
want anything to do with them.
Quite to the contrary.
22
How difficult are phone records?
How difficult?
And
What he said was that part of their plan I know I
23
didn't want to have anything to do with, but I didn't want to
24
lose them.
25
kids' information.
They had my plans for the mosque.

They had my business.

They had my
They had offered me
SUMMATION - NKRUMAH
4777
business plans that I thought that I could take advantage of.
So I didn't want to cut them off totally.
them for what I could use them for.
crime?
5
6
I wanted to use
Selfish?
Maybe.
No.
Abu Bakr.
Let's talk about him for a minute.
said we'd get back to him.
Abu Bakr.
He gave, according to the Government, a
whole lot information about Abu Bakr, how you approach him,
how you should deal with him, what you should and shouldn't
10
do, who should say what and who should say anything.
11
Government says he had knew Abu Bakr.
12
Abu Bakr was supposed to be someone that he was close to.
13
The
The Government says
If he wanted this to happen -- think about it.
Just
14
think about it for one second.
15
and Abu Bakr was someone that these people wanted to see, and
16
this is someone that he is close to, why not a phone call?
17
Why not a letter?
18
indication that he sent them?
19
talk.
20
If he wanted this to happen,
Why not something to give Abu Bakr that

Nothing.
Nothing but a lot of
Nothing but a lot of talk.

Let's think about the assistance that he gave in
21
Trinidad, the so-called assistance.
22
Mr. Defreitas and Mr. Francis, and it is not at Kareem
23
Ibrahim's house.
24
know that from the testimony of Steven Francis.
25
through the tapes of Russell Defreitas.
And we know that.
He sets up boarding for
How do we know that?

We
We know that
SUMMATION - NKRUMAH
4778
He sets up boarding, and he tells you why.
as a Muslim that is part of his duties.
to go to anybody's house.
set them up somewhere.
Ibrahim.
Because
He didn't tell them
He told them to go to a mosque.
He
He never ever mentioned Kareem
And when we were talking about who Abu Bakr was
speaking to, it was his students that live in Trinidad.
wanted to help Steven Francis and Russell Defreitas, if he was
interested in Steven Francis and Russell Defreitas meeting
10
Abu Bakr, why not have the students do it?
11
the students can make this introduction?
12
According to the Government, something came up.
13
Mr. Kadir, he was never going.
14
If he
Why not make it so

He can't come.
According to
So since he is not going and he wants this to happen
15
so bad, why not set it up?
16
happen and I am supposed to do it and I can't, I am making
17
arrangements.
18
is making arrangements.
19
20
I know if I want something to
I know you are making arrangements.
You have transcripts.
You can look through each and
every page to find the arrangements he made.
21
Boarding?
He got them a place to stay.
22
talking about a mosque.
23
plan?
24
not assisting them with anything.
25
Somebody
It is not.
And he was
How is that assisting them in their
It is fluff.
Okay?
It is fluff.
He is
How is it we know that he never talked to -- despite

SUMMATION - NKRUMAH
4779
what is on, again -- a lot of talk on those recordings.
Despite what he told Steven Francis he would do, he never
spoke to his people.
you speak to your people?
How do we know that?
And I come to you.
What happens when
If I am supposed to do something
for you, I am not going to ask you when are we going to do
this?
Trinidad two days, could not find Abdul -- excuse me.
Nur for two days.
10
When are we going to go see Abu Bakr?
They were in
Abdel
Did anybody associated with Abdul Kadir come to them
11
and say, "Look.
12
Kadir said that we need to take you because he set this up"?
13
Through the evidence, this is just common sense.
14
do it, somebody else needed to do it if I wanted to work.
15
I know you can't find Abdel Nur, but Brother
If I can't
They talk about the conversation in which he says he
16
knows Abu Bakr.
He knows him well.
17
he calls him.
18
he calls upon me.
When he goes to Trinidad
When he comes back -- when he comes to Guyana

He calls.
19
Did he say a word?
20
Oh, I forgot.
He is too slick for that.
He -- he is not like Russell Defreitas.
He is too
21
slick.
He is not
22
like Steven Francis.
23
hiding by meeting Russell Defreitas and Steven Francis in
24
public places, but he is hiding.
25
Steven Francis and Russell Defreitas not a dummy cell number,
He is worldly; so he is hiding.
He is
He is hiding by giving

SUMMATION - NKRUMAH
4780
not a throwaway cell, not a phony number, a number to somebody
else -- he is hiding by giving him his cell number and his
phone number, his house number.
hiding, and he doesn't want his identity to be known.
But he is hiding.
He is
But when they had call him about this trip to
Trinidad, when they talk to him about this trip to Trinidad --
I will let you read it off the transcript.
8
9
I am reading it from Government Exhibit 219.

is on Government Exhibit 219.
10
Government Exhibit 219T.
11
evidence.
12
13
This
I am reading this off of
Government Exhibit 219 is in
MR. KADIR says:
"You haven't fixed the flight
times as yet."
14
MR. FRANCIS says:
"No.
Actually, I am
15
supposed to get a phone call from the -- from the
16
airline -- the lady that is dealing with the
17
airline.
18
information, but, um, I would like to know -- um,
19
she -- if you are going.
20
MR. Defreitas says:
21
Um, uh-huh.
She wants, uh, our
"What name?"
Why would he ask him, "What name?"
Again, we don't
22
have to be law enforcement to figure this one out.
23
him what name because he is trying to get him to use an alias.
24
He is hiding.
25
Remember?
"What name?"
MR. KADIR says:
He asks
Mr. Defreitas says.
"Under what name would you

SUMMATION - NKRUMAH
4781
like us to book the flight for -- from Guyana to
Trinidad, if you are coming?
"Abdul Kadir."
A-b-d-u-l, same name as on the calling cards.
But he is not like them because he is hiding.
He is
just a sophisticated super spy from 1982, but he is hiding; so
he is not giving up his real name.
8
9
He wasn't hiding.
He didn't have anything to hide
about because this part of their plan he didn't want nothing
10
to do with.
But did he tell him?
11
Now, He didn't use my words.
12
that.
No.
And he told you why.
He said, "I am going to sidestep
I am not going to deal with that."
13
He didn't say any of that.
What he said was, "I
14
don't want to lose the possibility," and that is not a crime.
15
Again, that trip to Trinidad, he backed out the day
16
they were supposed to go.
17
me back up.
18
Oh, wait a second.
I forgot.
Francis is at his home for ten days.

His son's home.
19
Not his home.
20
Excuse me.
21
Kadir sit and talk with Steven Francis?
22
I want this to work.
23
on my own with no one knowing to make this work.
24
to one of the two architects of this thing two times.
25
second time I talked to him, I ain't going.
He is at his home.
Ten days.
Okay.
Let
Okay.
Eleven days.
How many times does Abdul

Two.
I need this to work.

Eleven days.
I am going to Iran
But I talked
And the
I am not going.
SUMMATION - NKRUMAH
I didn't make any alternate plans.
you to see Abu Bakr.
it easy on you.
people.
4782
I am not hooking up for
I didn't clear the path.
Nothing.
Yeah, yeah, yeah.
I didn't make
I told my
I told my people nothing, but I want this to work.
Does that make sense to you?
sense.
We are talking common sense.
you?
to work, I am pushing to make it work.
We are talking people
Does that make sense to
Because it don't make sense to me.
If I want something
We can go over all of that, and then we go through
10
all of the conversation, and I am not going to go through all
11
of the conversations with you because you have them in
12
evidence.
13
word.
14
the conversations go like that.
15
they are going to do.
16
can work with that.
17
You can look at them.
You don't have to take my
But we go through all of the conversation, and all of

Steven Francis saying what
Abdul Kadir, okay.
Uh-huh.
Yeah.
Uh-huh.
Good.
Uh-huh.
Never let me tell you how to do this.
You don't
18
have to get there.
19
want this to work, and you asked me how to make this better
20
and I tell you nothing.
21
you information on your cell phone.
22
don't send nothing, but I want this to work.
23
We
Even when asked -- even when asked but I
I tell you that I am going to send

Do I send it?
No.
You call me and tell me that you got Google earth.
24
You found it.
25
That's good.
And I am, like, oh, you found Google earth?

But that is all that I say.

I don't tell you
SUMMATION - NKRUMAH
anything else.
4783
All of the conversations about Google earth go the
same way.
because they all go the same way.
information.
gets technical.
information.
plan to really kick off?
stolen satellite plans from secured JFK safes.
10
11
I don't have to go through them verbatim verbatim

They ask him to provide
Remember, he is an engineer.
He is the one who
Defreitas can't give him technical
Francis certainly can't.
And they want this
This is Google earth.
secret Government documents.
This isn't
This isn't
This is Google earth.
You mean to tell me people in Iran don't have Google
12
earth; that they needed Abdul Kadir to come from Guyana to
13
show them Google earth?
14
bogeyman comes from.
15
with America are bad.
16
Their relations are friendly.
17
This is Iran, the country that the
This is Iran, who we had know relations

But with Guyana, a different story.
Do they need Abdul Kadir to come from Guyana to show
18
him Google earth?
What is he going to tell them when he shows
19
them Google earth?
They don't need Abdul Kadir for than, and
20
Abdul Kadir wasn't going to Iran for that.
21
going to Iran for the same reasons that he went to Iran twice
22
before, for a commemoration.
23
Abdul Kadir was
And I am going to Iran, but
24
I don't tell you nothing.
We are partners, me and you,
25
because remember, I am not the brains of this.

I am not the
SUMMATION - NKRUMAH
one who can make this plan kick off.
intimate knowledge about JFK.
this intimate knowledge about JFK.
I can tell you.
4784
I don't have this
I never even -- I don't have

So there is nothing that
It is Russell Defreitas who has intimate knowledge.
But I am going to Iran, but it is not for spreading the plan.
I am going to Iran, and I don't tell you that I am going to
Iran.
going to Trinidad.
I am going to Trinidad, and don't tell you that I am

I don't tell you nothing.
10
advancing your plot?
11
the people, or anyone else?
12
How am I
He wasn't.
How am I helping you secure the moneys,

How am I helping you?
I am not.
He was going to Iran to celebrate the
13
death of one of his religious leaders.
14
testimony about Ayatollah Khomeini, who he was and what he was
15
and the fatwa against Salmon Rushdie and everything else.
16
That is another bogeyman.
17
18
Here.
Guyana, but worldwide.

Ayatollah Khomeini is a religious leader, someone
20
they celebrate yearly.
21
this.
23
That is another bogeyman.
But to cheer one group worldwide -- not just in
19
22
You heard a lot of
He has been there twice already for
He is going again.
How do we know he is going again?
Because
Government Exhibit 162 tells you that he is going again.
24
(Document put up on the screen.)
25
MR. NKRUMAH:
"Distinguished hosts and fellow

SUMMATION - NKRUMAH
4785
guests:
I thank you for inviting me to the home of
Iman Rula al Musabe, al Khomeini, as a humble guest
in the presence of the distinguished host.
paid my respect of us and the greatest Mudahjin of
our time."
Those are the notes for a speech that he was going
to give when he was in Iran.
You can read the rest.
going to read the entire note to you.
Look for Jihad, JFK, or anything else.
It is not there.
least, that is not what he was going to Iran for.
11
what he was going to Iran for.

Okay.
I am not
You can read the rest.
10
12
I first
He is going to Iran.
At
It is not
What does he have?
13
What does he have on him that he is going to Iran to show this
14
plot, to sell this plot?
15
had all done on it, but I am not telling you what I am doing.
16
I am the Lone Ranger now, and I am doing this on my own.
17
stealing this, or I am going to do this and I am going to
18
surprise you.
19
20
Mind you, this is the plot that we
I am
I don't have anything.
Investigator Addonizio testified no blueprints, no

map, no details, no nothing.
21
Okay.
Before I forget, there was something.
22
(Pictures put up on the screen.)
23
He had that and he had that and he had that and he
24
had that picture and this picture of his daughter.
25
one of his daughters.
That is his son.

This is
This is his daughter
SUMMATION - NKRUMAH
again.
These pictures.
Another daughter.
4786
Two daughters.
His daughter again.
Let me put the bogeyman picture up there.
This
picture.
This bogeyman picture is the picture that they were
taking at -- that he was taking to Iran, according to the
Government, to prove to them that he was down with their
program.
Government.
no evidence that he gave Government secrets when he was in
This is the spy.
Remember?
From '82 who got into
Curiously, when he got into Government there is
10
Government.
11
a newspaper and sending it to a religious leader of his.
12
He is spying in '82 by taking information out of
There is no Embassies in Guyana for Iran, and the
13
nearest one is in Venezuela, and he testified to you about all
14
of that, and so did Dr. Levin.
15
about Iran.
16
leaders may be religious, but that is not a requirement.
17
Iran it is different.
18
Remember what Dr. Levin said
It is not quite like America.
He said our
In
He sent in information -- and you have the letters.
19
You can read the letters.
20
poverty.
21
not eating, how the morale is low, how there is not enough
22
food, flour, rice.
23
things are bad here, but he is fine.
24
25
He is sending in information about
He is sending in information about how people are
He is telling his spiritual leader that
But none of that is fine that took place when he was

in Government.
Why not spy when I am the mayor.

I can get my
SUMMATION - NKRUMAH
1
2
3
4
hands on -- I can really Abe spy now.

Check the documents.
the documents.
Nothing.
4787
Nothing.
You would have them.
But he is spying.
(Matter continued on the next page.)
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

Check
Summation - Nkrumah
MR. NKRUMAH:
(Cont'd.)
4788
He's a confidential
informant who got nothing.
for money for a mosque.
them to pay for a computer for their intercepts, but he's
spying.
He's been begging Iran for years
He had to write them a letter for
Abdul Kadir told you about these pictures and he
told you in Iran he could never show these pictures.
never ever show these pictures.
clothed properly.
Why is that?
In Islam that's a no-no.
He could
He's not
But even more
10
importantly, ladies and gentlemen, it's not how he's dressed,
11
it's how his daughter is not dressed.
12
ladies and gentlemen, even though she's covered from head --
13
almost from head to tow, because her face is showing she's not
14
dressed.
In Iran that's blasphemy, in Iran --
15
MR. MILLER:
16
THE COURT:
17
She's not dressed,
Objection.
Sustained.
Again, it's the jury's
recollection of the evidence that controls.
18
MR. NKRUMAH:
In Iran he could never ever show those
19
pictures.
20
that respected Shia Muslim leader in Guyana.
21
He wouldn't be an Imam any longer.
He wouldn't be
Let's talk about that for just half a second.
He
22
teaches Islam in Georgetown Squares.
He's in government as a
23
Muslim.
24
that boogeyman thing out because he wasn't spying for anybody.
25
He's in government where he has the best opportunity.
We already know you're not spying.
HOLLY DRISCOLL, CSR
Let's just throw
He's in
Summation - Nkrumah
4789
Parliament for five years.
Does he spy?
He helps poor
people.
their communities, Lindendale.
years as a parliamentarian.
Trinidad or anyplace else that he's militant, that he's
teaching violence, nothing.
He sets up celebrations so people can be proud of
He serves his country for five
There are no reports from Guyana,
Don't everybody think of Iran the way that America
does and it's okay, it ain't a crime.
like them don't mean the rest of the word has to follow suit.
10
Just cause we don't
He's going to Iran while they're at Kareem Ibrahim's house.
11
Let me back up, because I'm back to I want this
12
thing to work so bad, I want to be a part of this so bad that
13
I'm going to risk everything to make this happen but you go to
14
Trinidad but I don't tell you to call me and tell me what's
15
going on.
16
matter of fact, I try to talk you out of it.
17
I don't ask you to contact me not one time.
As a
You might not remember that but Ms. Whalen just
18
played it for you just a little while ago before you all went
19
to lunch, the conversation that Steven Francis and Russell
20
Defreitas had where Russell Defreitas told him the sheikh in
21
Guyana.
22
Donald Nero been gone, boof (ph), kicked to the curb.
23
he's not talking about Neville Rutherford because he been gone
24
too.
25
Guyana.
We know he wasn't talking about Donald Nero because

We know
So, who is he talking about, who is the sheikh in

Abdul Kadir told me this was a bad idea, he tried to
HOLLY DRISCOLL, CSR
Summation - Nkrumah
4790
tell us don't go.
But I want this to work, this is my common
sense, if I tell them not to do it they'll do it and it will
work.
Yeah, okay.
That's how I get this to work.
That's my master plan.
Abdul Kadir goes to Iran, he has nothing, no
blueprints, no plans, he has nothing.
what is he showing, what does he have, what is he doing.
it make any sense to you, because it doesn't to me, unless I'm
telling them what they want to hear so I can get what I want
10
What is he selling,
Does
from them.
11
The government asked you who does that, who does
12
that, who deals with bad people.
13
bad people.
14
always bad when we got what we wanted.
15
deal with bad people every day, every single day.
16
mean they prescribe to everything that bad person does.
17
right, is it wrong, we don't know, but we do know dealing with
18
bad people is not a crime.
19
Our government deals with
Saddam Hussein wasn't always bad, Noriega wasn't

People in regular life
It doesn't
Is it
They want to talk to you about that all these
20
connections in Iran, Mohsen Rabbani, you heard that name, it
21
came up, it came up, it came up, another boogeyman, Mohsen
22
Rabbani.
23
committing a crime, not convicted, he's convicted of nothing,
24
they arrested him and let him go.
25
say for whatever reason they let him go.
Accused, let me say that again, accused of
For whatever reason, they
HOLLY DRISCOLL, CSR
Accused of a crime.
Summation - Nkrumah
4791
You'll have that evidence in the back with you.
able to read letter from letter.
it was sent because Abdul Kadir didn't even write it and that
letter was thanking Mohsen Rabbani for his work with the
students.
you to read it.
Muslims in Guyana need help, boogeyman.
8
9
You'll be
One, we don't even know if
Read it, just don't take my word for it, I'm asking
The other letter he's asking for help, us
They show you that he has Mohsen Rabbani's phone

number in a phone book that dates back to 1984.
And when he
10
was asked why he had the phone number, he says I never talked
11
to Mohsen Rabbani, I've never met Mohsen Rabbani but the
12
number that I have belongs to his office because he was the
13
one that we dealt with when my children were educated in Iran,
14
not just his children, children from England, Spain, all over
15
the world.
16
You heard Ms. Kadir, you heard Baiyna Kadir, Abdul
17
Kadir's daughter, when she took the stand, the boogeyman
18
pictures, something that the family always did, devoted loving
19
father, played with his children.
20
unless you get cable which he never bought, they entertained
21
themselves, maybe not the way you and I would but that's not a
22
crime and there's no indication that he had any intent to
23
commit a crime because he was playing with his kids.
24
25
Two channels in Guyana,
You heard Baiyna testify.

school in Iran.
She says she went to
Her sister went to school in Iran.
HOLLY DRISCOLL, CSR
Her
Summation - Nkrumah
4792
brothers went to school in Iran.
be terrorists, they didn't go there because they wanted to do
jihad on the west.
religiously as Shia Muslims and the major center, the major
center for Shia Islam, the only Shia Islamic state, Iran.
not going to send my kids if I'm Shia Muslim to the Vatican if
I want them to learn Shia Muslim, Shia Islam, I'm going to
send them to Iran.
And they didn't go there to
They went there to improve who they are
I'm
Being a Shia Muslim was part and parcel of Abdul
10
Kadir's life.
He lived his life around Islam.
That's not a
11
crime.
12
to be sympathetic to people who may not like us, it's not a
13
crime, no indication of a crime, and surely isn't any
14
indication that he wanted to commit a crime.
It's not a crime to be Muslim, not a crime to hate --
15
The other boogeyman, Hezbollah, that's the other
16
boogeyman.
17
Hezbollah, if he likes Hezbollah he got to like the whole
18
thing.
19
dislike what they do on that other table, he can't do that.
20
That's impossible, according to them.
21
like that, they don't disassociate bits and pieces, they take
22
it in the whole.
23
to disassociate bad from good.
24
25
Now, they want to tell you that he can like
He can't appreciate what Hezbollah does for people and
People just don't act
Do you take it in the whole.
Are you able
How about that friend you know that he went to

prison, how about that friend that you might know who's
HOLLY DRISCOLL, CSR
Summation - Nkrumah
4793
committing a crime, do you turn your back on your friend,
because you disagree with the fact that he's out there
crimeing (sic), do you turn your back on your relative when
you know they're out there doing wrong, or do you disassociate
yourself with the wrong that they're doing and deal with other
aspects of their lives.
can't he do that.
8
9
Isn't that how it works.
Common sense.
Forget all this boogeyman stuff.

common sense.
So, why
Let's just use
Let's just think about if I want this to work
10
what would I do, how would I act.
11
I not talk to nobody, will I not try to seek out details, will
12
I not try to find out everything I can find out or will I not
13
try to improve this plan because I'm the engine here, I'm the
14
brains.
15
off the ground.
16
Would I act like him, would
Would I not try to improve this plan so we can get it
There's places in the transcript that Steven Francis
17
and Russell Defreitas readily admit, this is before anyone
18
knew they were being recorded, that Abdul Kadir was not a part
19
of this.
20
house, they told Kareem.
21
When did they do that?
When they were at Kareem's
Now, Mr. Francis when he was on the stand he tried
22
to explain to you what Russell Defreitas meant when he said
23
that.
24
but he was going to explain to you why he said that.
25
never talked about it, never said a word but ready to explain
Mind you, he didn't even know he was going to say that
HOLLY DRISCOLL, CSR
They
Summation - Nkrumah
4794
to you why Mr. Defreitas would tell Mr. Ibrahim that my client
wasn't a part of of this.
wasn't a part of this and they knew it.
He didn't need any explanation, he
Now, did they know it?
Abdul Kadir tells them give
me two weeks.
Do they wait two weeks?
They go right back to
Wahab, can you get us in touch with Osama.
looking for the highest bidder now, they're not going to wait
two weeks for Kadir, they just automatically go back to Wahab,
give me Osama.
Now, I guess they
10
Why would you do that if you thought I was down.
11
Why would you do that if you thought I was a part of this.
12
Common sense, that's all, that's all we're asking, common
13
sense, just think this through.
14
boogeyman stuff.
15
going to Iran.
16
out what Hezbollah is about.
17
Kadir did and did not do and let's tell from there.
18
Let's put out all the
Let's put out those pictures.
Let's put out
Let's put out what Iran is about and let's put

Let's just deal with what Abdul
There's testimony in there about a bullet found
19
during the search of Abdul Kadir's home.
20
I'm running ahead to June.
21
they search his house not once like Steven -- excuse me,
22
Investigator Addonizio testified to but twice, and the first
23
time they searched his home they don't find guns.
24
MR. MILLER:
25
THE COURT:
Now, I'm going --
Kadir is locked up in Trinidad,
Objection.
Sustained.
HOLLY DRISCOLL, CSR
Summation - Nkrumah
MR. NKRUMAH:
4795
There's no mention of a bullet being
found during that search.
It's found on the second search.
And is that bullet tested.
bullet tested.
Was that bullet connected to anything here.
part of this plan; no, it wasn't.
Where is that bullet.
Is that
Was there a weapon to connect that bullet to.

Was that bullet a
Ms. Whalen talked a little about Steven Francis and
she told you a little about who he was and who she might have
thought from the testimony that he gave, she told you about
10
him crying when he talked about doing those eight years in
11
prison.
12
what happens here.
13
someplace you want to go to, not someplace you want your
14
children to go to, ugly, ugly place.
15
snitches.
Let me tell you why Steven Francis has an interest in

Prison is an ugly, ugly place.
16
MR. MILLER:
17
THE COURT:
It's not
It's really ugly for
Objection, Judge.
Sustained.
Again, it's not in evidence.
18
The jury is to disregard any statements about items that are
19
not in evidence.
20
MR. NKRUMAH:
We know what happens to people when
21
they go to prison and they've told things that they weren't
22
supposed to tell.
23
MR. MILLER:
24
THE COURT:
25
Objection, Judge.
Sustained.
That remark is stricken.
Again, there's been no evidence to that effect.
HOLLY DRISCOLL, CSR
The jury is
Summation - Nkrumah
4796
not to speculate as to any items that are not in evidence.
MR. NKRUMAH:
Prison is an ugly place.
Why else does he have interest in this.
He has a
family, a new family, a new wife, a new child.
prison or more, life, that's all gone.
Yeah, I got an interest in this because I don't want to lose
my wife, I don't want to lose my family, I don't want to lose
my home.
there and do your best, results only, the only thing that
10
25 years in
That's all gone.
Remember the plea agreement, it doesn't say go out
matters results only.
11
Steven Francis has an interest in this, Steven
12
Francis has a vested interest, despite what they tell you,
13
despite what they tell you.
14
an interest.
15
he's looking at a boatload of time and how does he get it cut,
16
he cooperates.
17
cooperate and give up people, he tells the judge I'm never
18
doing this again; judge, I've changed my ways, I'm not doing
19
it again.
20
Common sense tells us that he got
He's arrested, he's prosecuted in federal court,
Not only does he cooperate, not only does he
That lasted maybe all of nine months, maybe, because
21
we don't even know when he started.
He gets busted again, not
22
five keys of coke, 40 plus.
23
in our communities, what type of devastation does that do to
24
our communities.
25
again, he cooperates, he gives up anybody he can and then he
What type of devastation is that
He gets busted again.
HOLLY DRISCOLL, CSR
What does he do
Summation - Nkrumah
4797
signs on the dotted line and says I will do whatever I can to
help myself.
can to help myself and I don't care who has to go to prison
because I don't want to.
not romanticize him, let's not do that, let's see him for who
he really is.
looking out for self right now.
8
9
That's who Steven Francis is, I'll do whatever I
That's who Steven Francis is.
Let's
He's looking out for self back then, he's
I know I keep jumping back and forth, I'm sorry for

taking you all like that but this is common sense and
10
sometimes when you think about these things you don't think
11
about it in order, it pops -- one thought pops in your mind,
12
the next thought pops in your mind but this is common sense
13
and I want this to work so I'm going to do everything I can
14
but there's no evidence that Kadir did anything but talk a lot
15
of game.
16
I'm taking you back to May 19th when Abdul Kadir
17
told him that he wasn't going to Trinidad, you all should
18
leave Abu Bakr alone, May 19th.
19
recorded on May 19th.
20
Steven Francis showed Abdul Kadir the map.
21
that recorded.
22
at that time.
23
days now.
24
so.
25
Defreitas to get there, remember Russell Defreitas didn't stay
You got a lot of conversation
What you don't have recorded is when
Why is that not recorded?
You don't have

Was he still scared
He had been in his son's house for about ten
Was he still scared at that time.
Why it's not recorded.
I don't think
He knew -- he waited for Russell
HOLLY DRISCOLL, CSR
Summation - Nkrumah
4798
out there, Russell Defreitas was in Georgetown.
for Defreitas to get there to show the map.
was scared.
recorded.
Kadir again not recorded.
recorded.
is that not recorded; because he's scared, I don't think so.
8
9
Why is that not recorded.
So, he waited
I don't think he
Why is that not
The second most important incident concerning Abdul

Is this coincidence.
Why is it not
All the rest of the conversation is recorded so why
Common sense, what's his motive, what's his reason,

why is he doing this.
Let's take out right now that he's
10
doing it for the money.
He didn't ask for any money.
There's
11
no testimony that he asked for any money for this mosque from
12
this plan.
13
ever testified when you sell this, give me a piece; when you
14
sell this, build my mosque.
15
equation, let's just take it out.
16
So, why did he do this.
He didn't -- he never ever said to them and no one
So, let's take that out of the
According to the
17
government, because he disagreed with the ways of the west.
18
He may disagree with the ways of the west but that ain't a
19
reason.
20
his grandchildren that live here.
21
and his children reside here, his family lives here.
22
think that's it either.
23
Why that's not a reason, his children that live here,
So, why did he do this.
He disagrees with the west

I don't
Nothing in anything that
24
they introduced to you other than a couple of chants that are
25
chanting in Iran and in probably other places about not liking
HOLLY DRISCOLL, CSR
Summation - Nkrumah
4799
America but that's not evidence because if that's the case, we
got a lot of people living right here in America that write
bad things about America.
because that's not evidence, that's just boogeyman stuff, that
ain't evidence.
Why they not before you on trial,
More importantly, when speaking to Russell Defreitas
and Steven Francis and you have the -- I keep saying this but
it's so true, you got the testimony, the testimony belongs to
you, you could look at any part you want, you can read back
10
anything you want; he never, ever, never, ever talks about
11
hating America so much that he wants to harm it.
12
out.
13
Check it
You don't have to believe me but I hope that you do.

We already said he wasn't no spy.
We already went
14
through that boogeyman stuff.
15
fact that he behaved differently.
16
that, I'm not going to repeat that, just to say he didn't
17
hide, he didn't hide from anybody.
18
We already went through the

We already went through
They want to make a big deal about him telling them
19
not to carry that stuff with you because you gonna' get in
20
trouble if they find it, you'll have to explain yourself and
21
that's an ugly scene right there trying to explain why you're
22
carrying that stuff and they're going to tell you that he did
23
that because he was trying to protect himself.
24
trying to protect them because he had nothing to do with that
25
but they did.
HOLLY DRISCOLL, CSR
No, he was
Summation - Nkrumah
4800
They're going to tell you that he told Steven
Francis that he can pull it down from the Internet.
Steven Francis already knew that because he did that without
Kadir telling him to do it.
in the evidence.
Kadir about Google Earth, Abdul Kadir gave him nothing but
words and those words didn't help him produce a map or
anything else.
But
We know that's true because it's
No matter how many times he asked Abdul
They're in Trinidad and he speaks to them and --
10
excuse me, they're in Trinidad and they're talking to Kareem
11
Ibrahim and they tell Kareem Ibrahim he's not down.
12
Steven Francis had his own take but Mr. Defreitas made it
13
clear.
14
15
16
17
18
19
20
21
22
23
24
25
HOLLY DRISCOLL, CSR
Again,
4801
NKRUMAH - SUMMATION
15:24:13
MR. NKRUMAH:
I'll read to you what's been marked
into evidence as Government's Exhibit 224 and I'm reading
from Government's Exhibit 224 T, the transcript.
Mr. Defreitas says:
they?
But we realized that Guyana is 40 years behind, okay, and
nobody, not Kadir, not anybody else in Guyana could handle
this.
We took to Guyana.
They ain't -- who's
When Kareem Ibrahim -- the "they" is Kadir.
Uh-huh.
That's Russell Defreitas talking to Kareem Ibrahim
10
about Abdul Kadir and his nonparticipation, about what he
11
cannot and has not done for them.
12
take you back and forth and jump you from one spot to the
13
other.
14
thinking and I'm just putting myself in this spot and I'm
15
saying it myself if I want this to work and I'm an engineer
16
and I'm giving up good engineering tips, I don't care how
17
much training, how can I tell what the composition of tanks
18
are that I've never worked on?
19
they're made of?
20
engineering advice.
21
single tank when I've never worked on it?
22
from looking at a Google Earth map?
23
Again, I don't mean to
I really, really don't mean that, but I'm just
How can I tell you what
I'm an engineer and I'm giving you good

How can I tell if it is a double tank or
These maps aren't that detailed.
24
Take it in the back, look at it.
25
those tanks are made of.
How can I tell
You have the map.
Come back and tell me what
Take it to your friend --.

M. BRYMER, RPR, OCR
4802
NKRUMAH - SUMMATION
1
MR. MILLER:
THE COURT:
Objection.
Sustained.
The jury is to deliberate
among themselves and to consider the evidence that has been
presented.
tomorrow as to what evidence you may consider, what's not
evidence and the instruction as to the principle of the law
that you are to consider the facts as you find them.
Remember, you are the sole judges of the facts in this case.
I will be giving instructions to the jury
It is not the recollection of the evidence of the
10
attorneys or even of the Court that controls.
11
recollection and your recollection alone.
12
13
It is your
Counsel shall refrain from expressing any personal

belief here.
14
MR. NKRUMAH:
15
has been a long hour.
Yes, your Honor.
One last thing.
It
One last thing --.
16
THE COURT:
Hour and a half.
17
MR. NKRUMAH:
18
I almost forgot to talk about the bank account.
Thank you.
Thank you.
If
19
I'm dealing with someone who is dealing with people who are
20
willing to give me money to do something like that, I want to
21
make sure that if they're giving me any of that money that
22
those people who gave the money, they know what's happening
23
with that money.
24
coming into my bank account.
25
THE COURT:
I don't want them to think that it is
Counsel, are you becoming a witness

M. BRYMER, RPR, OCR
4803
NKRUMAH - SUMMATION
1
here, or are you referring to what Mr. Kadir was stating?
MR. NKRUMAH:
THE COURT:
here.
Excuse me, your Honor.
Because you cannot become a witness
The remark is stricken.
MR. NKRUMAH:
Mr. Kadir did not want to come into
his account without them knowing exactly what was going on.
And when they was asking about it he explained it to you, he
said I wanted the sponsors to know they were putting the
money in my account, that they knew where the money was going
10
and for what.
11
nothing logical about that.
12
that.
13
wasn't taking their money.
14
Francis.
15
In his mind, not to terrify his mosque and

There's nothing shady about
He wanted to make sure these people understood that he

And that's what he said to Steven
We live in a dangerous world, but convicting an
16
innocent man doesn't make this world any safer.
Abdul Kadir
17
at no time ever had the intent to join this conspiracy.
18
Abdul Kadir at no time, never assisted Steven Francis or
19
Russell Defreitas in advancing the objectives of this
20
conspiracy.
21
Abdul Kadir is not guilty.
22
Thank you.
23
THE COURT:
24
All right, ladies and gentlemen, we have one more
25
Thank you, Mr. Nkrumah.
step left for today and I would like to get through the
M. BRYMER, RPR, OCR
4804
1
summations today.
give you the instruction on the law, but I'm going to give
you all about a 15-minute break before we get started with
the rebuttal summation by the government.
So, tomorrow morning first thing I can
Remember, like I told you earlier today, you must
not form or draw any conclusions about this case, about what
you have seen or heard in the courtroom, the evidence in this
case.
about this case.
You cannot talk among yourselves or with anyone else

You may not look at, read, consider, hear
10
anything that might be connected with this case, reported
11
about this case or do any kind of investigation or research
12
connected with this case or any kind of media.
13
during this brief break you can't use your cell phones for
14
any reason.
15
16
Remember that
About 15 minutes or so by the courtroom clock, about

a quarter to five.
17
Thank you.
18
(The jury exits the courtroom.)
19
THE COURT:
Jury is no longer present.
20
take a break until a quarter to five.
21
charge.
Parties can
Marshals can take
22
(Recess taken.)
23
(Continued on the following page.)
24
25
M. BRYMER, RPR, OCR
REBUTTAL SUMMATION - MILLER
(Rebuttal Summations by Mr. Miller.)
THE COURT:
Mr. Miller, you got all of your technical stuff
Please have a seat.
ready?
5
6
MR. MILLER:
Ms. Ahmad has all of the technical
stuff.
I will try not to be talking too fast.
THE COURT:
MR. MILLER:
Yes, please.
Not too fast.
I don't know if it's going to work.)
10
THE COURT:
11
(Whereupon, the defendants enter the courtroom.)
12
THE COURT:
13
Be kind to the reporter.
Is there anything else before I send for
the jury?
14
MR. MILLER:
Nothing from the Government.
15
MR. KAMDANG:
Nothing from the defendant.
16
MR. NKRUMAH:
Nothing from the defendant, Your
17
Honor.
18
THE CLERK:
19
(Jury enters the Courtroom at 4:50 P.M.)
20
THE COURT:
21
You may all be seated, please.
22
Do all of the parties agree that the jurors are
23
4805
Please rise.
Welcome back, ladies and gentlemen.
present and properly seated?
24
MR. MILLER:
25
MR. NKRUMAH:
Yes, Your Honor.

Yes, Your Honor.

MR. KAMDANG:
THE COURT:
4806
Yes, Your Honor.
All right.
Ladies and gentlemen, at
this point you will hear a rebuttal summation on behalf of the
Government by Mr. Miller.
You may proceed, Mr. Miller.
(Rebuttal Summation - Mr. Miller.)
MR. MILLER:
Good afternoon.
THE JURY:
10
MR. MILLER:
Good afternoon.
Members of the jury, the two defendants
11
in this case were caught red handed, captured on tape
12
committing the very crimes charged in the indictment, engaging
13
in it is conspiracy, agreeing to attack JFK airport, and
14
conducting surveillance at JFK airport in person and over of
15
the Internet.
16
You heard the defendants commit the very crimes
17
charged.
18
recordings that are in evidence.
19
the defendants' guilt was established beyond a reasonable
20
doubt by the tape-recorded words that came out of their own
21
words.
22
You heard them do it in their own words on the

This is the rare case where
So What did the defendant do?
What do they do when
23
they're caught red-handed?
The same thing kids do when they
24
are caught with their hands in the cookie jar and crumbs on
25
their lips.
They can't argue their hands aren't in the cookie

4807
jar.
is left?
wild excuses that stand -- that don't stand up to common
sense.
They can't argue they didn't eat the cookies.
So what
Argument about things that are not in evidence and
Okay.
I did it, but I didn't mean to do it.
Okay.
I did it, but I was pretending to do it.
That is exactly what
we have here.
in this conspiracy, evidence coming from their own mouths on
the recordings, not to mention from the witnesses, the
Faced with overwhelming evidence of their guilt
10
documents, the photographs, the defendants have resorted to
11
wild excuses and arguments that make no common sense.
12
take a look.
13
First, Mr. Defreitas.
Let's
When you boil it down,
14
Mr. Defreitas' argument comes down to, okay.
15
a part of the conspiracy.
Okay.
16
up with the idea myself.
And yes.
17
taking surveillance footage.
18
country in pursuit of my plan.
19
Francis and Kadir and Ibrahim into the plot, and I did it on
20
tape.
21
I was never serious.
22
And yes.
I said I was
I will grant you that I came
Yes.
I drove around the airport

I traveled from country to
Yes.
I recruited Nero and
I spent over a year pursuing this plot, but
Off the bat, before we look at all of the evidence,
23
that is flat-out ridiculous.
24
idea.
25
Mr. Francis told you that.
This plot was Mr. Defreitas'
And how do you know that?
Mr. Nero told you that.
Russell Defreitas told you that

4808
again and again and again on the tapes.
told Detective Addonizio that when he confessed to the crime.
And Russell Defreitas
Now, ladies and gentlemen, in the space of over a
couple of hours Ms. Whalen and Mr. Nkrumah called their
clients' own words on tape everything under the sun other than
what they are, which are an agreement to attack JFK airport.
They called them fantasy talk; trash talk; stupid, ugly talk;
big talk -- I was writing all these down -- dirty talk;
showoff talk; kid talk; ugly imagination talk; face-saving
10
talk; sizzle; window dressing; big-mouth talk; Bruce Willis
11
talk; fluff talk; lots of talk; talking a lot of game.
12
personal favorite, it is all a character flaw.
13
This isn't junior high with trash talking and name
14
calling.
15
plotting to commit a terrorist attack at an airport, not
16
boasting about their cars or their girlfriends.
17
And my
These are grown men, and they caught on tape
The defense attorneys are just coming up with new
18
words to describe their own clients agreeing again and again
19
and again on tape to engage in the plot to attack JFK Airport.
20
And throughout this conspiracy Russell Defreitas was
21
determined to make the JFK attack happen.
22
time again Defreitas demonstrated that he was the most serious
23
and committed member of the plot.
24
25
In fact, time and
And let's look at his own statements about his

commitment.
Let's look from rhetoric to evidence.

Ms. Whalen
4809
characterized his statements, but characterizations are not
evidence.
The fantasy talk, the trash talk, that is not
evidence.
The evidence comes from the court reporters in the
form of the transcript and the evidence comes in the form of
the exhibits.
So let's look at Mr. Defreitas' statements about his
own commitment from the evidence, from the recordings.
these statements span the conspiracy from the trips to the
airport to his comments to the Kareem Ibrahim just a couple of
10
days before his arrest.
11
many, many more.
12
And
And I picked a few, but there were
Let's start at the beginning.
"I always wanted to
13
do something against those was bastards."
14
And let's look at the next one.
Ms. Whalen told
15
you, by the way, that Mr. Defreitas was in no hurry, no hurry
16
at all, to get to the airport when he got back from -- from
17
Guyana.
18
airport.
19
That is the evidence.
Well, let's look at his own words.
20
I feel like going there now.
Let's look at a few more.
"Let's go to the
I cannot wait a day."
"I need to pay them back.
21
Those bastards are going to love when I get them back.
22
got to tell the sheik to hurry up.
23
two days.
24
like a cell."
25
You've
We accomplish too much in
I don't be like -- I don't like to be sitting here
You remember, he didn't want to be a cell that

4810
waited and waited and waited because he was determined to make
the attack happen.
"I've been studying this thing a long time.
I've
spent a lot of years trying to try to figure out how I can get
to them.
trip to Trinidad.
We didn't come here for entertainment."

"We came here on a mission."
And the next two, which come after Ms. Whalen said
that he came to some sort of an epiphany.
things off the ground.
10
"We've got to get
We ain't got time to wait.
Kadir, I
know he is hungry."
11
Didn't we just hear from Mr. Nkrumah that
12
Mr. Defreitas didn't think Kadir was involved?
13
words.
14
This was a
"KADIR:
I know he is hungry.
Look at his
Our mission is
15
to see it accomplished."
16
And, finally, just a couple of more days before he
17
is arrested, "I don't have much time to waste."
18
sound like someone who is just stringing things along, or is
19
that somebody who wants to make this attack happen?
20
And look at his actions:
Does that
Surveilling the airport,
21
recruiting conspirator after conspirator, seeking and
22
approaching seasoned terrorist after seasoned terrorist.
23
Ms. Whalen told you that Russell Defreitas was just
24
responding to Steven Francis.
I think that was her idea.
25
Well, let's look at his own words.
When he tells Steven

4811
Francis, what does he say?
you," Steven Francis, "would have given up, you would have
missed this."
4
5
He says to Steven Francis, "If
He was going to do it anyway.
Steven Francis would
have been the one missing it.
Now, Ms. Whalen went on about Defreitas ultimately
choosing not to follow through with Abu Bakr after the group
got to Trinidad and Abdel Nur met with Abu Bakr about the plot
to attack JFK airport.
You remember he came back and reported
10
that he had met with Abu Bakr and that Abu Bakr had been
11
interested but wanted another meeting.
12
Now, remember the context here.
Remember what was
13
happening when Defreitas decided not to follow through with
14
Abu Bakr.
15
to result in arrest and far more likely to result in bombs
16
going off at the airport.
17
He found a better path, a path that was less likely
Remember what he learned.
He learned that Abu Bakr
18
was dangerous.
19
when he confessed that he had learned that Abu Bakr had killed
20
the nephew of a friend.
21
also learned that Abu Bakr was under surveillance, tight
22
surveillance by local and international law enforcement.
23
remember Kadir told him that.
24
Trinidad, Ibrahim confirmed it.
25
You remember what he told Detective Addonizio
But more importantly, Defreitas had
You
And when they had got to
And remember, like every person who commits crimes,

4812
Defreitas didn't want to get caught.
the rest of his life in jail or some long portion.
why he took precautions when he went to the airport to surveil
it.
is like talking in code.
phone; they didn't want to get caught.
So let's be clear.
Do you remember?
He didn't want to spend

That is
He tried to get the small camera?
That
All of them talking in code on the
Defreitas had found a better way
to make the plot happen.
Now, the tape that you heard that was played that
10
Defreitas tells Francis he doesn't want to follow through with
11
Abu Bakr.
12
terrorist plot to Kareem Ibrahim.
13
you remember what happened.
14
first and says, "Let's take it to Iran.
15
revolutionary leadership in Iran."
16
That happened after Defreitas' pitched the JFK

And it happened after --
Ibrahim dived into the plot head

Let's take it to the
And remember, Kareem Ibrahim was 100 percent on
17
board.
They talked at length about how to get the plot done.
18
They agreed to do the attack at night and in the winter.
19
agreed to take it to Iran.
20
this trial, that in Iran Defreitas had struck pay dirt because
21
Iran and Hezbollah had engaged in successful terrorist
22
attacks, widely publicized terrorist attacks against the
23
United States, and they had engaged in successful terrorist
24
attacks, widely publicized ones, in the Americas.
25
about all that from Dr. Levitt.
They
And you know from the testimony in

You heard
4813
Iran was a better partner for this plot, more likely
to get it done than was Abu Bakr.
sponsored terrorist attacks against the United States, and
Abu Bakr was under tight surveillance.
After all, Iran had
So what Ms. Whalen left out when she said he didn't
want to go through with Abu Bakr was that he found a better,
safer plan.
and under strict law enforcement scrutiny when he found a
better way?
10
Why would he approach he thought was dangerous
Here is what Defreitas, himself, had to say about
the better plan after Ibrahim joined the plot.
11
And remember who he is talking to here, Abdul Kadir,
12
using the code that Abdul Kadir gave him.
13
code that Abdul Kadir gave him.
14
We'll back to the
Everything has to start in the direction.
He
15
started the Chicken Far.
16
repeatedly the Chicken Far was the plot to attack JFK airport.
17
We have to divert into another area that can produce a better
18
project than having the chickens grow.
19
means.
20
just as committed to the mission, just as committed to making
21
it happen; he's just got a new plan.
22
23
You remember Mr. Kadir confirmed
You know what that
A better chance to blow up the airport.
So he remains
Now, Ms. Whalen also argued that -- let me go back

quickly and finish over the second part of this.
24
Can you push it up a little bit?
25
What else does he say, Mr. Ibrahim?

Again, this is
4814
the comment about Kadir, "I know he is hungry.
to see this accomplished."
Our mission is
His mission is to see the JFK plot come to fruition.
Now, you heard Ms. Whalen argue that Mr. Defreitas
came up with some strange ideas.
argument because I want you to see two things.
doesn't matter if he had strange ideas about the plot; and,
two, his ideas weren't really very strange.
Well, let's look at that
First point, it doesn't matter.
Number one, it
When Judge Irizarry
10
charges you on the law, I predict she is going to tell you
11
what the elements of the crime are, and you are going to hear,
12
I predict, that a defendant can be found guilty of conspiracy
13
even if his illegal plans were impossible, even if they
14
couldn't have succeeded.
15
couldn't have accomplished his goal of attacking the airport,
16
he is still guilty if he joined the conspiracy to attack the
17
airport on purpose.
18
So even if you think Mr. Defreitas
Let me tell you what you are not going to hear from
19
Judge Irizarry, I predict.
You are not going to hear that the
20
law requires the Government to prove the defendants to be of
21
a particular intelligence or of a particular capability or
22
that they are diabolical to be guilty.
23
be shocked to learn that many people who commit crimes aren't
24
rocket scientists.
25
about being caught.
I don't think you will
Many people who commit crimes are worried

That doesn't make them not guilty.

4815
Nobody ever stood up here and told you that Russell
Defreitas was James Bond or Al Capone or Osama bin Ladin.
Just the opposite.
We told you we would prove that he committed the
crimes with which he is charged, and you know we did because
you listened to hour after hour of Russell Defreitas engaging
in the conspiracy on tape.
8
9
And one more thing about the exaggeration that

Ms. Whalen referenced.
When do people pad their resum and
10
say they have more experience than they do?
11
they want the job?
12
for ten years instead of six years it is because they are
13
trying to get something done, not because they don't want to
14
get the job?
15
Isn't it when
When people say I have been working at it
So let's talk about these supposedly silly ideas.
16
Ms. Whalen talked a little bit about how Mr. Defreitas wasn't
17
the airport expert.
18
bear that out.
19
Members of the jury, the evidence doesn't
Remember what the first witness, Peter Carbonaro,
20
told you.
Most people don't know about that main full tank
21
farm.
22
visit.
23
fuel lines.
24
But Russell Defreitas knew.
25
he used to work at JFK, in particular not only at Evergreen,
It's not in the part of the airport that many people

Even fewer people -- very few people know about the
They are underground.
You can't even see them.
How did he know?

He knew because
4816
the cargo company, but also at Ogden, the fuel services
company.
fuel services company.
the pipelines that went under them could cause catastrophic
damage to the airport and to the surrounding community,
including, by the way, that air train that ran nearby.
He knew how the fuel ran from when he worked at the

He knew that exploding fuel tanks and
Now, you also heard Russell Defreitas tell Francis
and show him repeatedly that he knew the back road in and out
of the airport so that -- the idea being they could show
10
people how to get in and out who were going to execute the
11
attack, get them in quickly before they are detected; flee the
12
scene quickly to escape.
13
Again, you heard from Peter Carbonaro that the back
14
roads and exits generally don't have signs leading to them,
15
and they're rarely used by the general public.
16
these things Russell Defreitas was bringing knowledge to the
17
conspiracy to attack the airport.
18
So between
Now, what about the security at the airport?
A lot
19
of questions about that on cross-examination about license
20
plate reading technologies and comprehensive camera systems
21
and a lot of suggestions that Mr. Defreitas was crazy to think
22
that the airport had such things.
23
What did you hear from Peter Carbonaro and
24
Detective Addonizio?
25
security equipment.
That they do have that high-tech

There is a comprehensive camera system,

4817
and they do have license plate reading technology that they
use.
Port Authority Police Department used that every day.
You heard it from Detective Addonizio.
4
5
He told you the
So Defreitas wasn't -- wasn't stupid or crazy to be

worried about the security technology.
He was dead on.
Now, there was some questions about the tower, and
Ms. Whalen, I think, said that she asked when the current
tower was built, and there was discussion about the 1990s,
what is the implication here?
That before the mid 1990s
10
planes were just flying around willy-nilly?
11
an air traffic control system?
12
they did.
13
They didn't have
That is ridiculous.
Of course
It has got no relevance.

And there was something about no signs saying don't
14
take photographs.
15
the photographs or the video with the intent to commit a
16
terrorist attack.
17
terrorist attack here at the airport.
18
arrested"?
19
But what makes it a crime is that you take
Should there be a sign that says, "No

You will been
Come on.
Here is an important point.
Mr. Defreitas knew what
20
he could do and what he, himself, couldn't do.
21
airport.
22
fuel pipelines attached to the full tanks.
He knew about the
23
back roads, how to get in, how to get out.
But Russell
24
Defreitas also knew he couldn't achieve of the big attack he
25
wanted, the one you heard him talking about on the tapes that
He knew the security weak points.

He knew the
He knew about the
would rival 9/11 on his own.
do?
That is what a person does when they are looking -- when they
know they can't do something, when they assess themselves and
say here what is I can do.
rest.
He looked for help.
So what did he do?
4818
That is what a smart person does.
I need someone to help me with the
And what did you learn at this trial?
the right people.
try to contact?
What did he
He looked to
Who did Defreitas and his coconspirators
Well, first, they tried to find Al-Qaeda, and
10
in particular this individual, Adnan Shukrijumah, an Al-Qaeda
11
operative with ties to the Caribbean and explosive expertise,
12
just the guy to get this plot operational.
13
And as Dr. Levitt, the terrorism expert told you,
14
Defreitas wasn't crazy to think Shukrijumah was in the
15
Caribbean.
16
he was in Trinidad and other parts of the Caribbean right when
17
it mattered.
18
There were reports in the media at the time that
Who else?
Who is the next person that Defreitas and
19
his coconspirators tried to contact.
In this case, through
20
Abdel Nur actually succeeded in contacting this individual,
21
Abu Bakr.
22
because as you heard from Calvin Bennett, the expert from
23
Trinidad, Abu Bakr had engaged in a coordinated terrorist
24
attack of his own, the suicide bombing of the police station,
25
the shooting of the Prime Minister, and the takeover of the
And you know that Abu Bakr was also a smart choice

4819
parliament TV station in Trinidad.
And ultimately who did Defreitas and his
coconspirators decide to pursue and make efforts to contact?
The Iranian revolutionary leadership.
heard from Dr. Levitt it was.
of terrorism.
Hezbollah, the terrorist group it funds, are widely known to
have committed terrorist strikes against the United States and
the western hemisphere in the Americas.
Why?
A smart choice?
You
Iran is a state sponsor
You heard that from Dr. Levitt.
That Iran and
Because you heard
10
from Dr. Levitt that Iran bombed the Israeli embassy and a
11
Jewish cultural center in Buenos Aires, Argentina, again, in a
12
widely publicized terrorist attack.
13
So what does all of this tell you?
First, it tells
14
you that Russell Defreitas and the other plotters were deadly
15
serious, and they were reaching out to exactly the kind of
16
people, seasoned terrorists, they believed made this plot
17
operational.
18
is an accurate assessment for Mr. Defreitas of what he could
19
do himself and what he needed help with to make his plot
20
become the nightmare reality.
21
reaching out to the three most prominent terrorist groups with
22
links to the Caribbean.
23
That is not stupid.
That is not crackpot.
That
That is Russell Defreitas
Now Ms. Whalen argued that Defreitas' specific ideas
24
for the attack don't add up.
25
big ideas.
But remember, he came up with
He wanted an attack to rival 9/11.

You can't
4820
think small if you want to outdo 9/11.
Kareem Ibrahim and Abdul Kadir and Steven Francis and all the
rest of them -- in particular you heard it when he proposed it
to Kareem Ibrahim:
pipelines and that the plot would need a few seasoned
operators, four or five or six.
is not crazy.
8
9
10
So his proposal to
Attack JFK airport, fuel tanks and
That is ambitious, but that
The idea of engaging in coordinated terrorist

attacks on an infrastructure facility, like an airport, is far
from crazy.
That is Terrorism 101.
11
And Ms. Whalen pointed out that Defreitas suggested
12
that perhaps the people should dress in black if at night and
13
perhaps they should use camouflage.
14
to commit a terrorist attack that rivaled 9/11.
15
he said multiple times.
16
had terrorist training and could infiltrate the airport seems
17
like a reasonable suggestion.
18
he was seeking out seasoned terrorists; right?
19
Is that crazy?
He wanted
That's what
Four to six people who engaged -- who
It is realistic.
That is why
He wasn't -- he was going to find Al-Qaeda,
20
hezbollah, an individual who actually successfully engaged in
21
a coordinated terrorist attack on multiple facilities,
22
Abu Bakr.
23
But he didn't just think big; right?
He also came
24
up with smaller, simpler ideas.
Remember the idea that
25
Defreitas had about taking a suitcase into a terminal and

exploding a bomb?
4821
Let's look at that.
You remember this.
Four passengers come in.
He
said I can show an Arab how to get into the terminal where
passengers come in and then they can put down the suitcase and
go on your way and the whole area blows up.
silly or strange about that idea, about figuring out a way to
get past security into a terminal and putting down a bomb in
a briefcase or a suitcase?
Anything crazy or
Through his experience at the airport he says he
10
knows a way to get into a terminal with a bomb.
11
crazy.
That was not
That was simple, and it is doable.
12
Ms. Whalen said something about the reasons
13
Defreitas gave for his desire to attack the airport, she said
14
those don't add up.
15
when Mr. Defreitas went to Abdul Kadir's friend Kareem Ibrahim
16
and pitched the plot to him, and Kareem Ibrahim jumped in
17
wholeheartedly?
18
gave?
19
9/11 attack so that the U.S. Government can kill Muslims and
20
declare war on Islam.
Remember
Do you remember the reason Kareem Ibrahim
That Jewish people in the United States committed the
21
22
Well, first, does that matter?
That was Mr. Ibrahim's reason.
That sure isn't true.

guilty?
Does that make Ibrahim not
Of course not.
23
The reason that many, many terrorist groups and
24
individuals targets the United States are false, but that
25
doesn't make their crimes of terrorism any less serious or any

4822
less dangerous.
Also, the evidence doesn't support this claim.
What
were the defendant's motives?
He had gave three basic reasons:
the missiles he saw at the airport, his own treatment by his
airport employers, and his own treatment in the United States.
What did he say on the tapes?

U.S. support of Israel and
Now, Ms. Whalen only talked about the first, his
anger at U.S. support of Israel and the missiles.
said that wasn't true.
And she
What is the basis for that?
Peter
10
Carbonaro, a current Port Authority employee who works in the
11
land road area, was asked, "Do you know of any missiles that
12
are carried through the airport?"
13
was not aware of that.
14
Why would he?
He said he didn't know.
He
He would works in the land road area
15
of the airport, not the flight department or the side of the
16
airport that handles cargo or military shipments.
17
from his testimony that he is not aware of current flights
18
involving missiles Ms. Whalen extrapolates that Defreitas
19
didn't see missiles when he worked at JFK in the '90s.
20
that is just speculation.
21
Somehow
But
And Ms. Whalen didn't even touch the other two
22
reasons, his anger at his treatment at the airport and his
23
anger at his treatment in the United States generally.
24
you listened to the tapes.
25
palpable.
You heard his anger.
And you heard his determination.

It was
And
4823
And there was some talk about his other business
ventures.
business ventures, but let's look at them.
He is not charged with anything to do with his
He wanted to engage in importing products from
Guyana to the U.S. and exporting products from the U.S. to
Guyana.
export/import business every day.
has a wide array of products that are not available in the
United States.
What's crazy about that?
10
People make a living in the

And you heard that Guyana
There is talk about the idea that he might want to
11
make money of hydroelectric power.
12
has significant electricity problems.
13
that?
14
And you heard that Guyana

What is crazy about
Apparently he wanted to make money off of bottled
15
purified water.
16
Brooklyn.
17
So what?
You heard that the water is sold in
One thing for sure, we know that Abdul Kadir didn't
18
think these business reasons were silly or crazy.
19
interested he said he joined the terrorist plot just to be
20
part of it.
21
MR. NKRUMAH:
22
THE COURT:
23
24
25
He was so
Objection.
Overruled.
It is fair commentary by
counsel.
MR. MILLER:
Now, you remember there was some talk
about the video; that it wasn't a professional movie.

But
4824
remember what the point of the video was.
it into a film festival.
shots of the tanks and the other targets, and they were trying
to show coconspirators the location of the tanks as it related
to the roads and the water waste.
It was not to enter
They were trying to get close-up
And, of course, they were operating under difficult
circumstances, trying to film the airport without getting
caught.
airport with the intent to commit a terrorist attack.
10
After all, as you know, it is a crime to film the
And here is what Defreitas about the filming.
11
said he couldn't slice up and keep it like a movie.
12
what?
13
that you did listen to Defreitas say, "Good enough."
14
They did get what they wanted.
Good enough for what?
He
But guess
You heard in the tape
Good enough to present to
15
Rutherford and Nero and later to the other coconspirators to
16
show what -- the parts that mattered.
17
was testimony about how Defreitas told Francis how to play the
18
video, to play the relevant portions.
19
Rutherford and Nero were happy with the video because it
20
enabled them to discuss what explosives to you, dynamite --
21
remember, there was talk about the chemicals.
22
And one more thing about the video.
And you remember there
And you heard that
There was
23
discussion about the difficulty that Defreitas and Francis had
24
in using the brand-new piece of machinery.
25
Defreitas wanted a new, high-tech camera that was small and

You remember
4825
would be hard for law enforcement to see.
Rutherford had
directed that they take the video -- directed Defreitas to
take the video.
find a camera at home."
Francis said, "I think I might be able to
Defreitas said, "No.
We need a high-tech one."
When anyone gets new technological equipment it can
be hard to manage, particularly hard to manage it when you are
driving and hiding from law enforcement.
point?
They filmed the airport.
But what's the
They captured the images of
10
the tanks that they wanted to take to their coconspirators and
11
that they wanted to take to the explosive experts.
12
Take a look quickly at these slides.
Now, there was
13
some talk about these slides.
14
Mr. Francis testified on direct examination after a question
15
from Mr. Jones, would these -- "Did you make these and take
16
them down to Guyana?"
17
18
And he said, "No.
When these were introduced,
These were not made at that
point."
19
But the point is this is how they were shown.
This
20
is how they were shown.
Do you remember they showed just the
21
relevant portions of what Mr. Defreitas told Francis to do for
22
the coconspirators.
23
portions.
24
testimony about the hangars and the planes when you go back to
25
the tanks.
And here you are seeing the relevant
You see the hangars.
Do you remember there was
And the fuel tanks.

4826
The point of the video is just to make your lives
easier so you can see what the conspirators saw when they
watched the relevant portions and they pushed pause and they
talked about it.
That is the point.
There was some claim that somehow Russell Defreitas
was manipulated by Steven Francis.
listened to the tapes.
pressure Defreitas.
again, "You tell me what to do."
10
11
12
You were here.
You
I don't -- Steven Francis did not
But you remember, he would say again and
This was his directions from Detective Napoli, "Let

Mr. Defreitas and let the other conspirators take the lead."
And you heard him say that again and again.
In
13
fact, so much that sometimes Defreitas would get frustrated
14
with him and say, "I want some feedback."
15
And he would say, "I am here to serve you."
16
Take a look at some -- just a few examples.
17
here to serve you, man.
18
208 -- 211.
19
Anything that you ask."
"I am
That's
"It's more appropriate for you to tell me
20
actually what you think.
I am a follower of the
21
prophet Mohammed.
I am here to serve him.
22
you ask me to do.
You tell me what I am going to
23
do.
I am here to serve you.
24
do.
Whatever decision you make."
25
Whatever decision you make.
Whatever
You tell me what to

4827
And it's interesting that Mr. Nkrumah said that
Steven Francis somehow manipulated Abdul Kadir.
said, "Try to get Abdul Kadir to say a fake name."
Let's take a look at that.
Remember, he
Let's take a look at
that where Mr. Nkrumah said that Steven Francis was trying to
get him to say a fake name when he said, "What name?"
Wait a minute.
Who said that?
Who said, "What name?"
That is Russell
Defreitas; right?
Russell Defreitas.
So when Mr. Nkrumah is trying to say that when Russell
10
Defreitas is saying, "What name?" that somehow Steven Francis
11
is manipulating Abdul Kadir into giving a false name.
12
that make any sense?
13
Does
That is why we have evidence because it doesn't lie.
14
Defreitas is the one who says, "What name?"
So how, possibly,
15
could Steven Francis be trying to manipulate Abdul Kadir.
16
is not possible.
It
17
There was some talk about the Government wasting
18
money and time and that somehow they're on the wrong track
19
here.
20
learned that defendant wanted to blow up a huge international
21
airport and is arranging meetings or attempting to arrange
22
meetings with seasoned terrorists that the FBI takes steps to
23
protect the country?
24
25
Does it surprise you for a minute that when the FBI
That is their job.
And there was talk about the goodies that Francis

supposedly gave to Mr. Defreitas.
Let's talk -- let's take

4828
those one at a time.
There was an apartment.
And you remember,
Detective Addonizio told you why the apartment was offered.
Mr. Defreitas had been living in New York on and off between
his trips to Guyana, and there were many.
Detective Addonizio testified -- and you can look -- that
there are something over 30 stamps in Mr. Defreitas' passport;
so he wasn't having too much difficulty traveling back and
forth to Guyana and that he needed a new place to stay,
You remember that
10
Mr. Defreitas and that he told his friend that he needed a new
11
place to stay.
12
And then at the same time Neville Talib Bilai
13
Rutherford was saying, "You know what?
14
plot going.
15
16
Let's try to get this
Maybe we can even do it around Christmas time."
Do remember that discussion?
And right around the
same time Mr. Defreitas is looking for an apartment.
17
So what does the FBI do?
It has access to a free
18
apartment.
19
Defreitas was looking for.
20
for an apartment.
21
figure out where this person plotting to attack JFK Airport
22
was going to end up and how to perform surveillance.
23
enforcement.
24
did that.
25
Of course of the FBI offered the apartment that

Saved him the trouble of looking
Saved the FBI the trouble of trying to
It was simple law enforcement.
What about the plane ticket.
Law
Of course they
Again, Defreitas and

4829
his coconspirators were looking for tickets to go to Trinidad
to visit Abu Bakr, a known terrorist who engaged in attacks in
Trinidad.
Mr. Defreitas had flown back and forth.
provided the ticket so that they could set up surveillance in
the appropriate places to make sure that nothing happened;
that there was no actual attack.
8
9
We know they were able to buy tickets in the past.

Of course the FBI
There was some talk about Government's Exhibit 270.

Do you remember that?
That was the plane ticket that was
10
found when Detective Addonizio went to Guyana.
11
that plane ticket was here is a plane ticket that the FBI did
12
not know had been purchased.
13
There may well have been others that the FBI didn't know was
14
purchased.
15
The point of
There could have been others.
Now, the FBI getting reporting from Steven Francis.
16
But the FBI can't track ever foreign plane ticket.
17
purpose of introducing Government's Exhibit 270 was not to
18
suggest Abdel Nur took a trip.
19
tickets are purchased by the conspirators outside the
20
knowledge of the FBI.
21
spend a couple of hundred dollars to insure that the plot
22
doesn't get away from them, doesn't actually -- meetings don't
23
happen with Abu Bakr or with other known terrorists not under
24
the FBI's watch?
25
And the
It was to show that plane
So when the FBI has an opportunity to
Of course they too advantage of it.
Members of the jury, Russell Defreitas didn't spend

4830
over a year plotting to attack JFK airport and pursuing the
biggest terrorist in the Caribbean region to pitch the plot --
his plot to attach JFK airport for a few hundred dollars worth
of plane tickets.
5
6
It is a ridicules.
A few more quick points here and then I want to

switch to Mr. Nkrumah's argument.
First, what did the defendant Abdul Kadir tell you
about Russell Defreitas?
Well, number one, during his
testimony he testified under oath that Russell Defreitas was
10
a member of the plot to attack JFK airport.
11
was the first one to pitch him on the plot.
12
And what else did he tell you?
Russell Defreitas
That he didn't think
13
Russell Defreitas was incapable of involvement in a serious
14
endeavor.
15
business ideas and connections so much that he told him he
16
would join in the terrorist plot with him in order to go into
17
business with him.
18
In fact, he liked his business ideas.
He liked his
Second, let's suppose for one second that Russell
19
Defreitas didn't mean any of the things he said.
20
absurd, given the wealth of evidence that demonstrates beyond
21
any reasonable doubt that he meant every word.
22
just suppose for one minute.
23
It is
Well, let's
He gets arrested by the FBI and told he has been
24
arrested for plotting to attack JFK airport.
25
he does, oh, he lies.
The first thing
He says he wasn't involved at all.

Okay.
2
3
4831
But then he is told the evidence is significant.

There are tape recordings.
He is under surveillance.
If Russell Defreitas really hadn't meant it, if he
just had been doing what Ms. Whalen said, playing along to get
money or make friends, wouldn't he have told Detective
Addonizio that?
again?
I was just trying to make friends."
Wouldn't he have told him again and again and
"I didn't mean it.
I was just trying to make money.
10
He didn't.
Take a look.
11
At this point in the interview did Russell Defreitas
12
say he was part of the plot to attack JFK airport, but he
13
never really meant to do anything?
14
15
No.
He did not.
At any point in the interview did Russell Defreitas

suggest or say that the plot was not serious?
16
No.
Did he tell you that he came up with the idea of the
17
plot?
Russell Defreitas said it was idea.
18
short interview.
19
hours long.
20
Addonizio that he have wasn't a member of the plot really
21
because he was a member of the plot.
22
heard it on the tapes.
23
about Nero and about Rutherford, about the Code words, about
24
the videotape, about the travel, about the plan to seek out
25
Abu Bakr.
You heard about it.
So he didn't lack time.
This wasn't a
It was a couple of
He didn't tell Detective
He confessed it.
You
He confessed to all kind of details
He confessed, and he is on those tapes saying all

4832
of those things because he is guilty.
He told Detective Addonizio and the other agents
that he came up with the plan because he did come up with the
plan.
he was a member of the conspiracy.
about playing along, crazy talk, because it is just not true.
Now, in this case, as I said, the defendants' guilt
He told them he was a member of the conspiracy because

He didn't say one word
has been established based on the tape-recorded statements,
not to mention the documentary evidence and the confession of
10
Russell Defreitas and the admissions of Abdul Kadir during
11
cross-examination.
And we will come back to this.
12
But the testimony of the cooperating witnesses,
13
Donald Nero and Steven Francis, that is just icing on the
14
cake.
15
That is just more evidence.

Strangely, you heard a lot of Nero and Francis
16
during the defense summations.
I guess if you don't like what
17
your client says on the tape recording, it is a lot easier to
18
attack the person holding the tape recorder.
19
the recordings prove the defendants' guilt, let's take a look
20
at their testimony, Francis and Nero's testimony.
So even though
21
Keep in mind they haven't seen each other in three
22
years, and they don't know what evidence the Government has.
23
When you do the comparison you will see that of all of the
24
significant points, their testimony is corroborated by the
25
other evidence in the case.
Francis and Nero both testified

4833
that the plot was Defreitas' idea.
and guess what?
confession in the interview.
that Defreitas was angry at the U.S. based on his experiences
at JFK airport.
They confirmed each other,
Russell Defreitas confirmed during his

Francis and Nero both testified
The recordings confirm that testimony.
They testified about the same people being involved
in the plots and about plot meetings at Rutherford's office.
Again, the recordings confirm that testimony.
They both testified that Defreitas' job was to give
10
information about JFK Airport and that he recruited Francis
11
into the plot.
Again, the recordings confirm it.
12
They both testified that Defreitas traveled to the
13
U.S. to get video of JFK airport and then brought it back to
14
Guyana and then played it back for Rutherford in Europe, who
15
liked it and thought it was very helpful.
16
confirmed that.
17
The recordings
They both testified the plotters talked about using
18
dynamite to blow up the tanks and chemicals to penetrate the
19
tanks.
20
Again, they confirm each other.

The both testified the plotters planned to go to
21
Trinidad to meet Abu Bakr, find Shukrijumah, to pitch the plot
22
with the help of Abdel Nur.
23
recordings.
24
25
This is confirmed by the
They hadn't seen each other in three years.
And
while Francis reviewed the tapes, you remember, for accuracy

4834
so they could be admitted into evidence, Nero never listened
to a single recording.
other evidence in the case was.
And neither witness knew what the
And, by the way, as Ms. Ahmad told you, what Francis
testified about the meeting with Mr. Kadir, Mr. Kadir
confirmed almost every single part of that.
couple of distinctions that we will come back to.
Now, the defense argued there were some
inconsistencies, but ask yourself, were these the
There were a
10
inconsistencies about key events that you'd remember, like the
11
ones we just went over, who was involved in the plot, what was
12
the plan, where were the meetings, that kind of thing?
13
were they details, details like did Nero ask for help for his
14
wife that Francis never gave to his wife?
15
that three years later, whether you ask somebody for help for
16
someone else and you never got that help?
17
remember that?
18
wouldn't remember.
19
Or
Who would remember
Why would you
It's the kind of insignificant detail you
And there was some talk about these cooperation
20
agreements, and I think Ms. Whalen suggested that somehow Nero
21
got a great deal.
22
conspiring to attack a mass transportation facility, to commit
23
a terrorist attack.
24
time up to the rest of his life.
25
he did it to get to the United States?
Members of the jury, he pled guilty to
He faces jail time -- significant jail

And Ms. Whalen argued that
He hasn't even seen

4835
his family or even talked to his family, you heard, since he
got here.
Is that a great deal?

He took responsibility for being involved in a
conspiracy.
airport, and he pled guilty to that because he is guilty of
that.
He agreed with other people to attack JFK
And take a look at the agreements.
You'll see that
Nero and Francis face long prison terms, far longer if they
lie.
They had no idea what the other evidence is that the
10
Government has, whether the phone was tapped.
11
idea when they were under surveillance.
12
in the agreement to suggest that it matters to them whether
13
the defendants are convicted or acquitted.
14
They have no
And there is nothing
Under those circumstances, what is the only rational
15
thing for a self-interested person to do?
16
lie.
17
time, possibly for the rest of their life.
18
truth, they get a chance, a chance for a Judge to reduce an
19
otherwise lengthy prison sentence.
20
It sure isn't to
If either witness lies they go to jail for a very long
Let's talk about Abdul Kadir.
If they tell the
And Abdul Kadir
21
repeatedly indicated his involvement in the conspiracy on the
22
audio recording.
23
earth satellite images of JFK airport, saying, "We can work
24
with that."
25
that.
He was caught on tape advising on Google
Not you can work with that, but we can work with

4836
He was caught on tape agreeing to travel to Trinidad
to pitch the blot to Abu Bakr, who he had lived with in
Trinidad for three years, as he said on tape.
who Abu Bakr is.
the plotters to stay when they pitched the plot to Abu Bakr,
and he knew why they were going there.
he provided engineering advice on the composition of the fuel
tanks, how to blow them up.
And he knows
He is caught on tape setting up a place for
He admitted here that
We'll come back to that.
Conspiring on how to accomplish the plot without
10
getting caught and authorizing the use of his Mustang.
11
despite all of those statements, Kadir's argument was that,
12
yes, I did all of those things.
13
plot.
14
I didn't mean it.
And
I said I agreed to pitch the
I was just pretending.
Again, this isn't junior high.
You can't say that
15
I had my finger crossed behind my back.
16
That is the type of absurd argument you get when a defendant
17
is caught on tape.
18
19
That is my defense.
It doesn't stands up.
Now, let's just talk for a minute and go over what

knowledge and intent is and what it isn't.
20
The question is did Abdul Kadir know what the
21
conspiracy was about?
22
attack JFK airport, and did he intentionally participate in
23
it?
24
That is not an element.
25
Did he know it was about a plan to
That is the question.
It doesn't matter why he did it.
So whether you believe that Kadir entered into the

4837
conspiracy, agreed to assist in the plot to raise money or for
business connections or because of a commitment to the Iranian
worldwide revolution or to support hezbollah or because he's
following his Muslim duty in some misguided sense, he is still
guilty as long as he agreed to help knowing what the plot is
about and intentionally participated, and the evidence proves
beyond any reasonable doubt that he did.
8
9
And the same is true, by the way, of Russell

Defreitas.
Whatever his reason was for being involved in the
10
plot, whether it was the motive that he said on the tape or if
11
he really joined the plot to make friends, as long as he
12
knowingly and intentionally participated, he is guilty.
13
Now, Mr. Nkrumah argued that you should credit
14
Mr. Kadir's story, but it is packed with inconsistencies and
15
lies, and it is absolutely contradicted by the tapes.
16
Think about that first meeting.
Let's just talk
17
about that for a second.
18
journeyed an hour, an hour and a half from Georgetown to meet
19
with him to pitch him the plot.
20
while and they played him the video.
21
He said that Defreitas and Francis
He says they talked for a
You heard Russell Defreitas pitch the plot.
You
22
heard it on Government Exhibit 224.
That is where he pitches
23
the plot to Kareem Ibrahim.
24
played the video, and Mr. Defreitas talked at length about it.
25
They talked about the tower.
Remember how it went.
They
They talked about the planes,

4838
the tanks, the entries, the exits, his reasons for wanting to
do it, on and on.
3
4
What does Kadir say happened?

the video twice.
He said they played
Nobody didn't said anything.
MR. NKRUMAH:
MR. MILLER:
THE COURT:
Overruled.
I'm sorry.
The jury's recollection, of course, is
9
10
Objection.
Did that seem reasonable?
what counts.
(Matter continued on the next page.)
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

Rebuttal - Miller
MR. MILLER:
(Cont'g.)
4839
He says after the videos are
played, he says what is this, all that Defreitas and Francis
say are tanks.
Airport.
No explanation, no description, tanks at JFK
Airport.
Does that make a remote amount of sense.
travel all this way after Abdul Wahab, by the way, tells them
that this is a guy who has connections and may be interested
and they play him the video twice and say nothing.
they answer -- and then he asks what's this all about and they
He asked where and all they answer is JFK
They
And then
10
don't answer that either, they just say JFK Airport, tanks.
11
It makes no sense for the obvious reason, it's not true.
12
Now, Mr. Kadir conceded that at the end of the first
13
meeting about the JFK plot he did agree to pitch the plot to
14
his connections but here's where he claims he's pretending,
15
this is the first pretending, no matter that he has such
16
connections, no matter that he has contacts and you've seen
17
the letters to Mohsen Rabbani, no matter that he has contacts
18
to Iranian leadership, no matter that he knows Abu Bakr, he
19
claimed he was just pretending and remember all the reasons he
20
gave, the inconsistent and different reasons.
21
wanted to go into business with them, wanted to meet rich
22
Muslims through Francis and Defreitas, he wanted to stay close
23
to those terrorist plotters not cut ties with them, those were
24
his words, wanted to stay close to them, not sever ties.
25
First, he
Remember what he said before back at the time of his
HOLLY DRISCOLL, CSR
Rebuttal - Miller
4840
arrest under oath that he agreed not because he wanted to work
with these guys but out of fear and shock and confusion and to
get as far as away from them as possible and their plan as
possible.
like slinking whisperers.
it.
and utterly inconsistent.
people that you fear and think are the devil, so why change
your story.
He said Defreitas and Francis were like the devil,

It's in evidence, you can look at
That was his claim under oath three years ago.
Totally
Nobody goes into business with
Remember the phone calls, you listened to a
10
couple of them, the beginnings of them as well as the whole
11
phone calls and the parts about the plot where Kadir and
12
Francis and Defreitas greet each other like friends, close
13
friends.
14
The fear story didn't stand up to the tapes.

Then there's the third story about rehabilitation.
15
I submit this was the most absurd story of all, trying to
16
rehabilitate the plotters is what he said he was doing.
17
don't rehabilitate an alcoholic by giving him a six pack of
18
beer.
19
wrong in what they're doing and showing them what's right but
20
Mr. Nkrumah or Mr. Kadir, they didn't point to a single
21
example on the tapes where he said something that would be
22
rehabilitating, like what you're doing is wrong, no.
23
You
You rehabilitate someone by telling them that they're
Do you rehabilitate plotters attempting to blow up
24
an airport by directing them to satellite images of the
25
airport and when they find them, saying good, good, good, we
HOLLY DRISCOLL, CSR
Rebuttal - Miller
4841
can work with that.
you rehabilitate terrorist plotters by agreeing to introduce
them to your friend Abu Bakr who previously committed a
coordinated suicide bombing and violent coup, does that sound
like rehabilitation.
advice on how not to get caught and how to do a good job where
they're pitching the plot to a seasoned terrorist, is that
rehabilitation.
Does that sound like rehabilitation.
Do
How about giving terrorist plotters
And here's one of my favorites, do you rehabilitate
10
terrorist plotters by giving them your best engineering advice
11
on the composition of the fuel tanks, the number of walls it
12
has, how many explosions it's going to take to blow them up.
13
Does that sound like rehabilitation to you.
14
cross-examination Kadir admitted that he gave them his best
15
engineering advice on the composition of the tanks.
16
Because on
Let's look closely at Kadir's testimony on this
17
point.
18
Detective Addonizio that he was involved in the plot and I
19
submit, members of the jury, that Abdul Kadir confessed to you
20
that he was a member of the plot during his testimony just the
21
other day.
22
As we discussed before, Russell Defreitas confessed to
"Question:
As an engineer they asked you about the
23
composition of the tanks that you knew they wanted to blow up
24
and you answered them as best you could, correct?
25
"Answer:
Yes, sir.
HOLLY DRISCOLL, CSR
Rebuttal - Miller
"Question:
4842
You gave individuals that you knew
wanted to blow up fuel tanks at an airport your best
engineering advice on the composition of those fuel tanks; is
that correct?
"Answer:
My best advice."
Mr. Kadir -- excuse me, Mr. Nkrumah just said Kadir
didn't try to improve the plan, he didn't do anything, he said
it was all boogeyman that the government was setting up.
gave them his best engineering advice on how to blow up the
10
tanks, those are his words.
11
plan.
12
I pretended to give them advice.
13
advice but I didn't know what the plot was about at that
14
point, no.
15
on how to blow up the tanks.
16
He
How is that not assisting the
He didn't say here -- even this time he didn't even say

He didn't say I gave them
Right there he gave them the best advice I could
Let me talk about one more thing about the
17
audiotapes.
Mr. Nkrumah argued, hey, on the audiotapes they
18
don't -- my guy doesn't say that he's helping.
19
off, he says again and again that he agrees to do things for
20
the plot, Google Earth, we can work with that; Abu Bakr, I'll
21
go introduce you, but that's not all.
22
tapes because during those conversations they not only talk
23
about going forward what they're going to do next but they
24
also talk about what's happened.
25
the idea that the first conversation about the plot wasn't on
Well, first
Remember, look at the
Mr. Nkrumah made much about
HOLLY DRISCOLL, CSR
Rebuttal - Miller
4843
tape but remember they have conversations where they talk
about what happened.
So, not only does Abdul Kadir, for example, in the
conversation about going to Trinidad to introduce the plotters
to Abu Bakr, not only does he agree to help but there's more
to that conversation.
that Abdel Nur was the right guy to approach Abu Bakr and what
does Abdul Kadir say, yeah, uh-huh, yeah, and then at that
point Mr. Francis asks will you go -- we think you'd be
You remember Francis says you told us
10
better, we think you'd do a better job, but what about the
11
first part of the conversation, that's on tape, that's
12
available for you to look at, what does that tell you about
13
what happened before.
14
you was accurate.
15
remember when you told us about that Abdel Nur was the right
16
guy to introduce us to Abu Bakr and he says yes.
17
taped statement about what had happened and that's there for
18
your review.
19
It tells you that what Mr. Francis told
Mr. Kadir confirms it.
What about the bank account.
Francis says you
That's a
Let's not forget about
20
this call about the bank account.
We've now heard a couple of
21
different stories about the bank account.
22
Can you put that one up.
23
Kadir argued this related to a plane ticket, do you
24
remember that on direct examination.
25
bank account conversation.
He was asked about this
He said it had to do with the
HOLLY DRISCOLL, CSR
Rebuttal - Miller
refund of a plane ticket.
Francis:
4844
Let's look at it.
In the discussions with the Sheikh here --
you remember this is a call from Kareem Ibrahim's house, there
were multiple calls to and from Kareem Ibrahim's house.
are even calls where Ibrahim and Kadir got on the phone
together, you could only hear Ibrahim's side but you remember
Ibrahim talks to Kadir, he says uh-huh, uh-huh, uh-huh and
then he comes back and they continue with the discussion and
that's when they talk about Ibrahim who has just spoken to
They
10
Kadir on the phone, old friend, just spoken on the phone and
11
Defreitas had just spoken, you remember we looked at the
12
conversation earlier where Defreitas says we're going in a new
13
direction, we're going to a better project for the Chicken
14
Far.
15
Defreitas suggested let's put the money through Kadir's bank
16
account and here's what happens.
17
So, that's what's happened so far.
Francis says:
And Ibrahim and
In the discussions with the Sheikh,
18
Ibrahim here, it's been agreed that if some investors were to
19
come for the Chicken Far -- I want to pause, you remember
20
Mr. Kadir said over and over again, no doubt about it, Chicken
21
Far is the plot to attack JFK Airport.
22
about investors to the plot to attack JFK Airport, they're
23
concerned about the monies, the great responsibility of a
24
large amount of money.
25
of capital for the attack on JFK Airport.
So, we're talking
They're talking about a big infusion
HOLLY DRISCOLL, CSR
Sheikh Muhammed
Rebuttal - Miller
4845
suggested the use of the account for the building of the
mosque for that money.
And if you go back in 224 -- 225, you'll see that
Russell Defreitas suggested, hey, let's use Kadir's mosque
account.
permission from the persons who were to sponsor the Chicken
Far.
absolutely.
What does Kadir say?
He says, fine, with the
As long as the terrorist financiers say it's okay,
So, if the sponsor agrees are you in agreement?
10
Yes, if the sponsor agrees we can transfer it to the mosque
11
account.
12
me, terrorist investments in a plot to attack an airport in
13
his bank account.
14
He's agreeing to put terrorist proceeds -- excuse
Okay.
Where is the plane part, where is the
15
airplane part, where's the couple hundred dollars that comes
16
from a refunded plane ticket.
17
monies that the investors are going to give for the plot to
18
attack JFK Airport.
19
when Mr. Nkrumah got up here, the planes were gone, all of a
20
sudden when he was describing the bank account conversation
21
all of a sudden there was no discussion anymore about airplane
22
refunds because, again, the evidence contradicts Mr. Kadir's
23
story, it keeps changing.
24
evidence from the mouth of the defendant himself.
25
Is that the large amount of
Of course not.
That's not all.
Of course not.
And then
Again, more clear and unequivocal
Let's look at what Mr. Kadir's
HOLLY DRISCOLL, CSR
Rebuttal - Miller
4846
co-conspirators think of his involvement.
Here's what Defreitas has to say about Mr. Kadir
after a conversation when they finished.
You might remember
this conversation, this is the conversation where Francis
talks about the Google Earth openly and talks about Abu Bakr
on the conversation and you'll see they hang up with Kadir and
Russell Defreitas says:
Francis says:
Laden.
Sorry.
You can't over the phone like that.

Defreitas:
Remember he's just like Bin
That's what Mr. Defreitas thinks of Mr. Kadir.
10
Now, there was just discussion about how, oh, he
11
didn't think he was involved.
12
puts the lie to that.
13
This recording among others
Let's see another one.
Ah, this is a good one.
14
Again, remember that the tapes, they not only talk about
15
what's going on but they talk about what happened as well and
16
it's captured on recordings for you to observe.
17
have May 7, 2007 and Francis says they're talking about going
18
to Trinidad and Guyana.
19
speak about it, are we going to talk about John F. Kennedy or
20
are we going to use Chicken Far.
21
Defreitas:
22
Sheikh, Chicken Far.
23
Francis says:
So, here we
How are we going to
And look at this, Russell
We'll keep the words because we got it from the
And just in case there's any confusion as to who the
24
Sheikh is because the Sheikh gets used for Kadir and Ibrahim
25
and Rutherford:
So we go with Sheikh Kadir's idea?
HOLLY DRISCOLL, CSR
Yeah,
Rebuttal - Miller
4847
Chicken Far, yes.
He didn't say let's go with Abdul Wahab's idea,
right.
already happened but they do it on tape.
confirms that it was indeed Abdul Kadir, the chicken farmer,
who suggested the code the Chicken Far.
Again, they are referring back to things that have

Russell Defreitas
The next one, okay, this is when they go meet
Ibrahim and this is after the phone call that I mentioned
earlier where Kadir and Ibrahim speak to each other on the
10
phone, you can hear Ibrahim's side and what are Defreitas and
11
Ibrahim doing, they are scheming about how to move the plot
12
forward now that the plot is headed to revolutionary
13
leadership in Iran rather than Abu Bakr.
14
things where Kadir will come in, Defreitas says.
15
say Kadir is not involved.
16
come in, he's already got an open account.
17
conversation I was talking about a minute ago right before
18
they call Kadir and say can we use your bank account.
19
got an open account for money, I can trust Kadir.
20
This is one of the

He doesn't
He says that is where Kadir will

This is that
And then what do Ibrahim and Nur say.
He's
Let's talk
21
about how Nur doesn't know anything about Kadir.
22
Nur and Ibrahim say, they talk when we present the plan, yes.
23
Ibrahim:
24
25
What does
He'll go to Guyana to meet Kadir.

So, Ibrahim knows Kadir is involved, he just spoke
to him on the phone.
Ibrahim knows Kadir is involved,
HOLLY DRISCOLL, CSR
Rebuttal - Miller
4848
Defreitas knows Kadir is involved, Nur knows Kadir is involved
and once again just to confirm it, one of the last
conversations, Kadir:
talk about whether he's pretending if he's really hungry, he
wants to eat something.
accomplished.
the mission is to see the JFK Airport plot accomplished.
is evidence.
He's hungry.
Now, I'm sure that we can
Our mission is to see this
Our mission.
Kadir, Ibrahim, Defreitas, Nur,

This
This isn't argument, this is words, recordings.
Now, Mr. Nkrumah argued that Kadir didn't support
10
the goals of the plot but look at some of the words of his own
11
and the words of the people that he was with.
12
talked about the words of the Ayatollah Khomeini, Ms. Ahmad
13
showed them to you, about the hands of criminal America, how
14
it's the enemy of Iran.
15
Then look at the words of Latif Ali.
We already
You remember
16
who Latif Ali is, this is a close friend of Mr. Kadir's who he
17
traveled to Iran on the two times he went to Iran, what's he
18
got to say.
19
the criminal America is confronting the only Islamic state
20
with laser guided missiles and again our forces have gained
21
victory.
22
He has to say:
The forces of Kufr marshaled by
But more importantly, what does Abdul Kadir say,
23
what does he say; he says:
The day of resurrection shall not
24
approach until the Muslims engage the yahud in a war and the
25
Muslims have taken it upon themselves before as only the
HOLLY DRISCOLL, CSR
Rebuttal - Miller
yahud, the Jews, who took the initiative.
2
3
4849
What else does he say, talks about the hands of the

oppressors being cut off.
And let me show you one more thing because this is
important.
This is a description of his own mosque, the
Guyana Islamic Information Center.
primary influences of the Guyana Islamic Information Center,
Hasan Al Bannah, Seyyid Kutub.
mosque and you heard from Dr. Levitt who stated who Kutub is.
Take a look at one of the
This is his document about his
10
He testified about it.
11
Kutub advised Muslims the big advance in the jihadist movement
12
that Kutub made, Seyyid Kutub, the influence on the direction
13
of Mr. Kadir's mosque, was that Muslims should be advised to
14
fight offensive jihad against the enemies of Islam.
15
Feel free to reread that testimony.
Members of the jury, you don't have to find that.
16
That gives him plenty of motive but you don't have to find
17
that, as we talked about earlier.
18
the plot for lots of reasons, any one of those reasons, it
19
doesn't matter, the government doesn't have to prove that.
20
All we have to prove is that he knew what this conspiracy was
21
about and he agreed, he agreed to advance the conspiracy.
22
knew what the goal of the plot was, he admitted that on the
23
stand and you've seen him today through the bank account,
24
through the engineering advice, through the Google Earth
25
images, through the introductions in Trinidad advancing the
Mr. Kadir could have joined
HOLLY DRISCOLL, CSR
He
Rebuttal - Miller
1
2
4850
plot.
Let's talk about the conference quickly, then I'll
try to wind up.
There was talk about how Mr. Kadir traveled
to Iran for this annual conference and commemoration.
Remember Mr. Nkrumah spent some time on that and how it
clearly wasn't to pitch the plot, it was for this long planned
annual conference and commemoration.
need to prove that he went on this particular trip, we just
have to prove that he agreed to be part of this conspiracy.
Now, again, we don't
10
Let's take a look at the evidence.
Remember the
11
defendant hadn't been to Iran in 17 years, since 1990.
12
claims he was going to an event, it started on June 2nd, 2007,
13
an event that happens every year, a time to celebrate
14
Khomeini's death.
And he
15
What do people do when they're planning a big tip
16
halfway across the world, get your passport ready, get your
17
flight set, you get your visa, your hotel reservations, you do
18
it in advance.
19
preparation for this event.
You know he flew from Guyana to
20
Trinidad on May 31st, 2007.
Here's his ticket, Government
21
Exhibit 153.
22
Did Abdul Kadir do any of those things in
I think I'm back -- right there, 31 May 2007.
What
23
was he doing that day.
Let's take a look at his flight
24
documents, Government Exhibits 150, 154, 155 and 156 because
25
that will tell us what he was doing.
HOLLY DRISCOLL, CSR
Rebuttal - Miller
4851
That day -- well, from these, 155 -- can you zoom
out a little bit -- and 154 we know that he was paying for his
tickets.
And look here, he gets his receipt May 31st, 2007 buying his
ticket.
issued and how did he pay.
cash.
says in cash.
He paid 82,400 Guyanese dollars on May 31, 2007.
And if you look at his itinerary, May 31st, 2007 it's
He gets his receipts.
You go back, you'll see paid in

On one of the other documents it
When does a person buy plane tickets for a trip
10
halfway across the world the day he leaves in cash.
11
the answer from your common sense.
12
day he leaves when he's in a huge hurry, right, and he buys it
13
in cash when he doesn't want a credit card account of the
14
transaction.
15
MR. NKRUMAH:
16
THE COURT:
17
MR. MILLER:
You know
A person buys a ticket the
Objection.
Overruled.
But there's more, because Kadir also
18
got his passport and his visa on May 31st, 2007.
19
Take a look at page 11 of Government Exhibit 152, Kadir's
20
passport.
21
renewed May 31, 2007.
22
passport renewed, if you could skip to I think page 15.
23
is his Venezuelan visa.
24
May 31, 2007.
25
Take a look.
Take a look.
Take a look at this document, it's

Buying his ticket in cash, getting his
I wonder when he got that.
Here
Oh,
So, he's also gone to the Venezuelan embassy to get
HOLLY DRISCOLL, CSR
Rebuttal - Miller
4852
his visa that same day.
the day he's flying out when he's headed halfway across the
world to a long scheduled annual conference that happens the
same time every year that he hasn't been to in 17 years.
Are these the things a person does on
Take a look at his date book, Government
Exhibit 161.
In May he has entries for important dates.
Let's take a look.
coming in from the U.S., that's Russell Defreitas and Steven
Francis; the brothers leave for Trinidad and Tobago, that's
Among other dates you see the brothers
10
Russell Defreitas, Abdel Nur and Steven Francis heading out.
11
Pretty important dates, only put six or seven dates, put the
12
really key dates in his book.
13
what Mr. Nkrumah said, this meant a lot to him.
14
So, he cared a lot, despite
Turn to the next page.
No
15
conference.
16
information about where it's being held, nothing.
17
thought, if he's going to a conference that started on
18
June 2nd, 2007, what's he doing in Trinidad and Tobago on the
19
other side of the world, and you can look in this passport,
20
without an Iranian visa yet in the middle of the day on
21
June 1st, 2007.
22
Iranian visa and jump a flight to Iran halfway across the
23
world; add in the time difference, he's not even going to make
24
his conference.
25
Hmm.
Where is the conference?
Nothing, no hotel reservation, no

One more
He still has to fly to Venezuela, get his
MR. NKRUMAH:
Objection.
HOLLY DRISCOLL, CSR
Rebuttal - Miller
THE COURT:
MR. MILLER:
4853
Overruled.
So, what's really going on, why is
Abdul Kadir dropping everything at the very last minute,
scurrying around and heading off to Iran and why is he trying
to hide what he's doing by claiming he's going to an annual
conference that he clearly hadn't planned to attend having had
no real viable passport, no visa and no plane ticket.
what happened in the week before May 31st, 2007 that would
require a quick trip to Iran.
10
I submit you know the answer.
Well,
Remember what Kareem
11
Ibrahim told Russell Defreitas about the next step in the plan
12
just days before Kadir drops everything and scrambles to get
13
to Iran for the first time in 17 years.
14
this is on 225-T, page 20, he wanted to send somebody out to
15
Iran, a trusted brother to discover the revolutionary movement
16
there and speak to top men, the top people of the
17
revolutionary movement about the plan.
18
Ibrahim said, and
And then he says something important, he doesn't
19
have the plan but he is saying that he has access to the plan.
20
That's what Kareem Ibrahim said.
21
description, who has contacts in the revolutionary movement,
22
the top people of the revolutionary movement in Iran, Abdul
23
Kadir.
24
the documents.
25
Iranian contacts without having to bring the video or the
And who fits that
You know that from his testimony, you know that from
Who knows the plot well enough to pitch it to
HOLLY DRISCOLL, CSR
Rebuttal - Miller
4854
images with him and you know he wasn't going to take the
images, he's the one who told Steven Francis to make sure no
one carried the images on them in Trinidad.
Abdul Kadir.
Kareem Ibrahim described what Abdul Kadir was doing
to a T, heading to Iran with knowledge of the plan to attack
JFK Airport to pitch the plan to his contacts, contacts like
Mohsen Rabbani and other high ranking Iranian revolutionary
leaders but, members of the jury, as I said, you don't have to
find that Mr. Kadir was going to Iran, though I submit the
10
inference is obvious given all the evidence, the question is
11
did he agree to be a member of this plot and you have tape
12
recording after tape recording about that.
13
Now, quickly I want to touch for a moment on these
14
photographs, the boogeyman photographs I think they were
15
called by Mr. Nkrumah.
16
photographs.
17
and she said he's a good peaceful Imam with a mosque -- with a
18
dream of building a mosque.
19
photographs.
20
doesn't call the cops.
21
detective.
22
people out of his home.
23
Imam with a dream to build a mosque.
24
Obviously, to give all the advice and support and agreement to
25
the plot.
What is the point of these
Ms. Messina got up here on opening statements
What is the point of these
He is approached about a terrorist attack.
He
Remember he has a friend Tony, the
He doesn't call the cops.
He doesn't throw the
Is that the action of a good peaceful
HOLLY DRISCOLL, CSR
I submit not.
Rebuttal - Miller
4855
But also take a look at these photos, are these the
photos of a true peaceful religious leader that Ms. Messina
talked about.
religious leaders draft development plans that include
infiltration of their native country's government including
the use of forged documents and military as well as religious
training.
8
9
I submit not.
By the way, how many true
I submit to you none.

But let's look at this.
pose with high powered weaponry.
How many religious leaders

Mr. Nkrumah spent a little
10
time talking about these guns and we heard witnesses saying
11
they were fake but it doesn't matter.
12
guns and poses in militant poses and, by the way, apparently
13
one of these guns is real, this one here on the left side,
14
that's what the testimony was.
15
decide they're playing with four fake guns so you decide to go
16
get a real gun to inject a real gun into the situation.
17
that sound like it makes any sense.
18
these guns.
19
20
21
Who grabs these five
The idea is your grown kids
Does
Take a close look at
Can you show the other photo.
This one here, can
you zero in a little bit on that one.

It's got a rusty screw.
These are the plastic guns
22
that the investigator said he bought one that doesn't look
23
much like this.
24
plastic gun with a rusty screw?
25
It's got a rusty screw here.
Can you go up a little bit.
HOLLY DRISCOLL, CSR
That's a toy
Rebuttal - Miller
4856
Pulling the ejector pin and swinging out the
cylinder where the bullets go right here in her hand.
a toy plastic gun?
bullet.
And don't forget about that assault rifle
He told you that this gun -- zoom out -- this gun is
the real one.
assault rifle bullets if all these guns are fake.
8
9
That's
That's not an assault rifle.
Why would he have
So, why is he telling you something that's not true.

It's the same reason he told you things that weren't true
10
about his connections to Iran on the witness stand and then
11
when shown documents had to admit that he did have
12
relationships and was providing information to Iranian
13
officials, same reason he lied to you about Abu Bakr and his
14
relationship with Abu Bakr when he said I didn't know him, I
15
only met him once and then on tape he said he lived with him
16
for three years in Trinidad.
17
you should ignore the tapes where he agrees to be part of the
18
plot.
19
he's just pretending because he knows that if you know about
20
his connections to Iran and if you know that he's friends with
21
Abu Bakr and if you know that he's got many serious weapons
22
and if you know all these things, you won't believe him when
23
he says something else that's not true which is that when he
24
said he was a part of the conspiracy, when he helped the
25
conspiracy move forward he was just pretending.
He's trying to convince you that
He's trying to convince you to believe him when he says
HOLLY DRISCOLL, CSR
Rebuttal - Miller
4857
One last point and then I'll finish up.
Mr. Kadir
said that this is a cultural thing, that the reason he kept
working with these terrorists was because Muslims don't
confront people when they're plotting to commit terrorist
attacks, instead they welcome in terrorists if they're
travelers in your country.
Muslims don't treat terrorists any different than any other
people.
help them with their terrorist plots because they're Muslim.
It borders on the offensive.
They don't welcome terrorists into their homes and
10
People who welcome people into their homes who are terrorists
11
and knowingly and intentionally agree to help people with
12
those plots are guilty of a crime.
13
conspirators.
14
They're terrorists'
It has nothing to do with their religion.
Members of the jury, the defendants have argued that
15
the government wasted money here, that the government
16
overreacted.
17
country and to do it in a manner that's consistent with the
18
Constitution and laws of this country.
19
enforcement took in this case was focused on those goals,
20
protect the country from attack, gather evidence to present in
21
a court of law and do so in a manner that's lawful and
22
appropriate.
23
prosecuting terrorism defendants in a court of law is
24
expensive, so be it, that's the price of freedom.
25
Well, the government's job is to protect this
Every step that law
And if protecting this country and charging and
This case is an example of how law enforcement
HOLLY DRISCOLL, CSR
Rebuttal - Miller
4858
should operate from inside the United States and abroad.
Russell Defreitas and Abdul Kadir and their co-conspirators
conspired to attack this country and this city and JFK
Airport.
kill U.S. citizens.
Kadir for months to identify soft targets at the airport, find
money and explosives, take their plan to experienced
terrorists like Shukrijumah and Bakr.
They wanted to hurt the U.S. economy, they wanted to

Russell Defreitas worked for a year and
United States law enforcement used every legal and
10
appropriate tool to develop evidence to prosecute the
11
conspirators in a court of law, that's its job, and now it's
12
time for you, the jury, to assess the evidence, that's your
13
job, look through all the evidence.
14
listen to the defendants' tape recorded statements in which
15
they engaged in the conspiracy to attack JFK Airport, engaged
16
in the very crimes charged, when you look at all the other
17
evidence, the documents, the photographs, the testimony, when
18
you use your common sense I submit you'll find there's only
19
one verdict consistent with all that evidence and that's a
20
verdict of guilty, guilty for Russell Defreitas, guilty for
21
Abdul Kadir, guilty as charged.
When you do, when you
22
Thank you for your patience and for your attention.
23
THE COURT:
24
Okay, ladies and gentlemen, I know it's been a
25
Thank you, Mr. Miller.
really long day so you can go home, rest up because tomorrow
HOLLY DRISCOLL, CSR
4859
1
is going to be a pretty long day as well.
for you to come back at 9:00 tomorrow again.
sure that you're all bright-eyed and bushy-tailed so make sure
you go to bed early today and rest up, all right.
I'm going to need

I want to make
Remember what I've been telling you all day and what
I've told you every single day since the trial started, it is
very important that you keep an open mind, that you're not
drawing any opinions or conclusions about the case.
you still have not heard my instructions on the law and you
Remember
10
have not had an opportunity to actually start deliberating
11
with each other and considering the evidence.
12
You cannot talk about the case among yourselves or
13
with anyone else, whether it's at home or any other place.
14
You cannot look at, read, listen to over any kind of media
15
anything that might be reported in connection with this case
16
or do any kind of independent research or investigation in
17
connection with this case over any kind of media.
18
So, the next step tomorrow is going to be my giving
19
you the instructions on the law and then you will begin to
20
deliberate.
21
For our alternate jurors just so that you know what
22
will happen tomorrow, once you hear the -- once I give the
23
instruction on the law to all of you together, you will then
24
be segregated from our 12 jurors but we're going to keep you
25
around.
As you've already seen today near the end of the
HOLLY DRISCOLL, CSR
4860
1
case, one of the jurors was unable to finish out her service
and so the alternates play a very important role in enabling
us to keep the case going in the circumstance if it should
happen that one of the 12 jurors should not be able to finish
out their duty in this case.
happen.
yourselves, okay.
8
9
We hope it's not going to
So, you all have to take very good care of
All right, so we'll see you tomorrow at 9:00.

up.
10
(Time noted:
6:10 p.m.)
11
(Jury leaves courtroom.)
12
13
14
15
16
17
18
19
20
21
22
23
24
25
HOLLY DRISCOLL, CSR
Rest
(Time noted: 6:08 p.m.)
THE COURT:
3
4
4861
You can all have a seat.
The jury is no
longer present.
As I had indicated early this morning before we
started with the summations, the Court will incorporate into
the final charge the revised aiding and abetting charge and
the limiting instruction that was requested by counsel.
8
9
Then, as soon as that is done, the Court will post

that electronically.
If counsel likes, we can have that
10
e-mailed to you as well as if you would like to have it in
11
that format.
12
MS. WHALEN:
I would like that.
13
THE COURT:
So we will do that.
14
Is there anything else that you want to raise?
15
There was the issue about the exhibit list.
16
a chance to review that and conform it?
Have you all had
17
MR. JONES:
Yes, Your Honor.
18
I circulated a list to the parties yesterday and
19
hard copies today.
I think we are all in agreement that it
20
all looks good.
21
file a final copy because I didn't want to file a draft.
I will speak to counsel afterwards.
22
THE COURT:
Yes.
23
MR. JONES:
I will file it this evening.
I will
It is
24
complete and ready to go.
I compared it to Your Honor's list
25
and the parties list, and I think we are all in agreement.

THE COURT:
4862
That exhibit list can be given.
Just so
we're all on the same page, that exhibit list can then be
submitted to the jury so that if they want to request any
particular piece of evidence, they know what to ask for.
Is everybody in agreement with that?
MR. JONES:
MS. WHALEN:
MR. NKRUMAH:
Yes, Your Honor.
MR. KAMDANG:
Your Honor, just one more issue with
Yes, Your Honor.

Yes, Your Honor.
10
respect to whether or not the Court is going to give the
11
entrapment language and the defense theory instruction.
12
I think our position is that -- I think Ms. Whalen
13
did an admirable job of backing off since the concerns the
14
government had.
15
necessary.
16
I don't think that that language is
I think Mr. Nkrumah's, from my listening, summation
17
tends to be more about lack of evidence than pressure,
18
manipulation, in terms of the concerns that the government
19
raised.
20
So I think our first choice would be that none of
21
the language from either side included.
22
inclined to include the entrapment language, then we would ask
23
for our theory of defense in the instructions as well.
24
25
MR. JONES:
But if the Court is
Your Honor, from the government's
prospective, I think we disagree with how Ms. Whalen navigated

4863
that shift.
government had left these guys to their own devices.
She said that nothing would have happened if the
She said that the government was clearly frustrated
and that the jury would notice the government was offering all
these, and I think she called them goodies.
Mr. Francis was handing out treats to her client.
Russell Defreitas was continuing to go along with Mr. Francis'
proposals.
the surveillance video would never have been made.
10
She said that

And that
That if Francis hadn't brought them together, then
Those are entrapment arguments.
And if they are not
11
entrapment arguments, they're certainly entrapment like
12
arguments.
13
they would be making an attempt for a back door entrapment
14
defense rather than coming with the rights of an affirmative
15
defense.
16
I think it's like we feared and like we predicted,
Because they did that despite Your Honor's warnings,
17
we ask that the jury be instructed that entrapment is not a
18
defense in this matter.
19
MS. WHALEN:
Your Honor, just for my comment.
20
believe that I summed up the way that I informed everybody I
21
would be summing up.
22
that he had other reasons to accept the things that were
23
offered to him.
24
he had an intent to commit this crime.
25
I'm not going entrapment.
I'm going
Accepting those things does not indicate that
We've made our position known.

I'll defer to the
4864
Court.
summation were entrapment or entrapment like.
arguing that a person could have a reason to accept these
things and not be joining a conspiracy and not be
demonstrating a conspiracy.
But I don't think that the statements that I made in
THE COURT:
I think it was
I had mentioned on Friday one of the
reasons why I wanted to reserve decision on it and held it in
abeyance was to have the opportunity to hear the summations
from all of the parties.
10
I think that perhaps while the defense may have come
11
somewhat close to an entrapment like defense, I don't think
12
that it rises to any level where the proposed charge that the
13
government suggested should be given by the Court.
14
I think that the government, in its rebuttal, was
15
able to address all of the points that were raised by both the
16
defense counsel, again alerting the jury to the fact that that
17
it was before Mr. Francis even came.
18
the -- direct evidence that points to Defendant Defreitas
19
having hatched a plot, if you will.
20
Evidence that points to
I think that there might be some confusion.
I think
21
to give the kind of charge that's requested, I think would
22
likely create more confusion than not.
23
of the summations taken together, including the government
24
summations, I think that given the charge that the Court is
25
going to give wherein the elements of intent and knowing are
Given the tenor of all

1
2
4865
heeded.
The elements required for conspiracy and, in
particular, for these conspiracies which are a little
different from the common law conspiracy in that it doesn't
require an overt act, I think the charges themselves repeat
some of these elements over again.
I think that the parties have ably argued the
evidence from their prospective as to what proof there is that
satisfies all of those elements.
10
If the jury comes back and says what about
11
entrapment, then we'll talk about it then.
12
all of the summations together, I think that the danger that
13
the government is concerned about is minimal at best.
14
MR. JONES:
I think, taking
For purposes of the record, it sounds
15
like Mr. Kamdang was suggesting if Your Honor was inclined not
16
to give the entrapment defense instruction, that they were
17
withdrawing the request for the theory of defense instruction.
18
THE COURT:
19
defense instruction.
20
hand-in-hand.
21
Well, I'm not gonna give the theory of

It seemed to me that they went
MR. KAMDANG:
That's correct.
I think maybe the
22
record is a little muddy on what I said.
23
In light of Your Honor's ruling, if the entrapment language
24
isn't given, then we did submit a theory of defense
25
instruction.
We'll withdraw that request.

Mr. Jones is right.
But we'll reserve,
4866
obviously, in the situation that you talked about where
there's a note about entrapment in some sort of language from
the jury, we might renew that request.
we're happy to withdraw it.
But at this point,
MR. JONES:
THE COURT:
Anything else?
I'm also assuming that Defendant Kadir also has
submitted a theory of defense request.
withdrawn as well.
I'm assuming that is
10
MR. NKRUMAH:
11
THE COURT:
12
(Whereupon the matter was adjourned to July 27,
13
You are correct, Your Honor.
I'll see everybody at 9:00 tomorrow.
2010, at 9:00 a.m.)
14
15
16
17
18
19
20
21
22
23
24
25

4867
1
2
INDEX
WITNESS:
PAGE:
3
SUMMATION - MS. AHMAD
4646
SUMMATION - MS. WHALEN
4708
SUMMATION - MR. NKRUMAH
4762
REBUTTAl SUMMATION BY MR. MILLER
4805
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
$
$30 [1] - 4696:14
'
'82 [2] - 4786:7, 4786:10
'90s [1] - 4822:19
0
07-CR-543 [2] - 4633:3, 4634:25
1
1 [10] - 4637:15, 4637:19, 4637:23,
4642:4, 4642:23, 4643:13, 4643:17,
4644:5, 4644:14, 4775:8
100 [4] - 4634:4, 4666:19, 4772:14,
4812:16
10013 [1] - 4634:5
10026 [1] - 4634:2
101 [2] - 4710:20, 4820:10
10th [3] - 4754:1, 4754:3, 4755:16
11 [1] - 4851:19
111th [1] - 4634:1
11201 [3] - 4633:16, 4633:24, 4634:9
116 [1] - 4634:1
11:40 [2] - 4705:12, 4706:6
11th [1] - 4755:19
12 [2] - 4859:24, 4860:4
12:00 [3] - 4705:10, 4706:4, 4707:3
15 [5] - 4679:10, 4704:13, 4717:15,
4804:15, 4851:22
15-minute [1] - 4804:3
150 [1] - 4850:24
152 [1] - 4851:19
153 [1] - 4850:21
154 [2] - 4850:24, 4851:2
155 [2] - 4850:24, 4851:1
156 [1] - 4850:24
161 [1] - 4852:6
162 [1] - 4784:23
17 [3] - 4850:11, 4852:4, 4853:13
1982 [1] - 4781:6
1984 [1] - 4791:9
1990 [1] - 4850:11
1990s [3] - 4718:7, 4817:8, 4817:9
1991 [2] - 4717:2, 4717:17
1994 [1] - 4750:24
1995 [1] - 4717:16
1996 [1] - 4717:16
19th [3] - 4797:16, 4797:18, 4797:19
1st [1] - 4852:21
2
2 [1] - 4644:13
20 [3] - 4719:17, 4770:7, 4853:14
20-year [1] - 4767:13
2000 [1] - 4750:1
2001 [2] - 4750:1, 4750:19
2002 [1] - 4750:20
2006 [16] - 4647:9, 4648:19, 4648:25,
4661:19, 4662:1, 4663:9, 4665:6,
4666:1, 4668:6, 4668:22, 4701:17,
4710:21, 4710:23, 4713:20, 4763:4,
4763:5
2007 [28] - 4646:9, 4647:9, 4668:6,
4669:6, 4678:2, 4684:4, 4696:7,
4701:18, 4732:19, 4753:12, 4753:16,
4753:20, 4753:23, 4754:1, 4754:3,
4846:17, 4850:12, 4850:20, 4850:22,
4851:3, 4851:4, 4851:5, 4851:18,
4851:21, 4851:24, 4852:18, 4852:21,
4853:8
2010 [2] - 4633:8, 4866:13
202 [1] - 4714:22
203 [1] - 4714:23
204 [1] - 4747:15
206 [1] - 4722:9
208 [2] - 4721:12, 4826:18
211 [1] - 4826:18
212 [1] - 4669:21
214 [2] - 4731:17, 4732:6
215 [2] - 4732:12
216 [1] - 4732:19
218 [1] - 4738:5
219 [3] - 4780:8, 4780:9, 4780:10
219T [1] - 4780:10
22 [2] - 4717:23, 4724:4
221 [1] - 4738:6
223 [3] - 4683:17, 4735:12, 4736:13
224 [5] - 4739:11, 4801:2, 4801:3,
4837:22, 4845:3
225 [2] - 4634:9, 4845:3
225-T [1] - 4853:14
226 [1] - 4744:7
229 [1] - 4722:12
230 [2] - 4739:12, 4741:6
25 [2] - 4764:20, 4796:4
26 [1] - 4633:8
26th [1] - 4753:23
27 [1] - 4866:12
270 [7] - 4727:14, 4753:1, 4753:3,
4753:10, 4753:25, 4829:8, 4829:17
271 [1] - 4633:16
28 [1] - 4753:16
2:45 [1] - 4760:3
2:55 [1] - 4761:15
2nd [2] - 4850:12, 4852:18
3
30 [2] - 4730:9, 4828:7
302 [1] - 4754:20
302s [2] - 4767:6, 4767:9
31 [4] - 4850:22, 4851:3, 4851:21,
4851:24
31st [6] - 4717:17, 4850:20, 4851:4,
4851:5, 4851:18, 4853:8
34th [3] - 4721:14, 4721:16, 4722:2
3D [2] - 4732:16, 4732:18
4
40 [2] - 4796:22, 4801:6
401 [1] - 4639:10
4646 [1] - 4867:4
4708 [1] - 4867:5
4762 [1] - 4867:6
48 [1] - 4696:6
4805 [1] - 4867:7
4:50 [1] - 4805:19
5
5 [1] - 4775:8
50 [4] - 4722:13, 4748:4, 4750:25,
4757:17
502 [1] - 4634:4
51 [3] - 4700:4, 4754:24, 4754:25
52 [1] - 4754:24
59 [1] - 4754:24
5th [2] - 4678:2, 4753:20
6
60 [1] - 4754:25
61 [1] - 4754:25
63 [1] - 4669:24
6:08 [1] - 4861:1
6:10 [1] - 4860:10
7
7 [3] - 4678:24, 4732:19, 4846:17
8
8 [7] - 4637:14, 4637:19, 4637:23,
4642:6, 4643:4, 4643:12, 4644:6
82,400 [1] - 4851:3
9
9/11 [8] - 4650:22, 4664:13, 4762:13,


4818:1, 4819:25, 4820:1, 4820:14,
4821:19
9:00 [7] - 4633:8, 4635:17, 4635:21,
4859:2, 4860:8, 4866:11, 4866:13
9:18 [1] - 4634:18
9:30 [1] - 4636:15
9:50 [1] - 4643:22
A
a.m [7] - 4633:8, 4634:18, 4636:15,
4643:23, 4705:13, 4706:6, 4866:13
Abdel [60] - 4648:23, 4668:14,
4680:11, 4680:15, 4682:23, 4685:21,
4685:22, 4685:23, 4711:22, 4712:11,
4726:2, 4727:10, 4727:16, 4727:19,
4727:22, 4727:24, 4728:2, 4728:6,
4736:25, 4737:1, 4737:4, 4737:5,
4737:13, 4737:22, 4738:2, 4738:3,
4738:7, 4738:8, 4738:12, 4738:14,
4738:17, 4738:18, 4741:18, 4741:19,
4752:17, 4752:19, 4753:6, 4753:11,
4754:4, 4754:13, 4754:14, 4754:16,
4754:19, 4763:23, 4763:24, 4764:1,
4764:6, 4765:3, 4779:8, 4779:11,
4811:8, 4818:20, 4829:18, 4833:22,
4843:7, 4843:15, 4852:10
ABDUL [2] - 4633:6, 4781:4
Abdul [141] - 4634:1, 4635:11,
4647:24, 4648:23, 4652:24, 4653:17,
4654:17, 4658:5, 4658:12, 4659:13,
4659:14, 4659:15, 4660:16, 4665:17,
4665:22, 4673:14, 4673:23, 4674:14,
4676:2, 4676:25, 4678:21, 4680:18,
4691:6, 4694:4, 4698:14, 4729:4,
4729:7, 4729:8, 4729:10, 4729:22,
4729:23, 4729:25, 4730:1, 4730:2,
4730:3, 4730:4, 4730:7, 4730:22,
4730:25, 4731:3, 4731:4, 4731:10,
4731:15, 4731:17, 4731:23, 4732:20,
4733:3, 4733:5, 4735:4, 4735:6,
4735:13, 4735:21, 4736:12, 4736:22,
4737:2, 4739:18, 4739:19, 4743:1,
4743:14, 4743:20, 4744:18, 4756:17,
4762:23, 4763:5, 4763:6, 4763:12,
4763:13, 4764:9, 4765:2, 4765:7,
4765:16, 4765:18, 4766:10, 4766:18,
4767:23, 4768:19, 4769:11, 4771:2,
4775:15, 4776:8, 4779:8, 4779:10,
4781:3, 4781:20, 4782:15, 4783:12,
4783:17, 4783:19, 4783:20, 4788:6,
4789:25, 4790:5, 4791:3, 4791:16,
4792:9, 4793:18, 4794:4, 4794:16,
4794:19, 4797:16, 4797:20, 4798:4,
4800:5, 4800:6, 4801:10, 4803:16,
4803:18, 4803:21, 4813:11, 4813:12,
4813:13, 4820:2, 4821:15, 4823:17,
4827:2, 4827:3, 4827:11, 4827:15,
4830:7, 4832:10, 4835:20, 4836:20,
4839:6, 4841:19, 4843:3, 4843:8,
4847:2, 4847:5, 4848:22, 4850:18,

4853:3, 4853:22, 4854:3, 4854:4,
4858:2, 4858:21
Abe [1] - 4787:1
abetting [7] - 4638:8, 4638:15, 4639:5,
4702:9, 4703:5, 4703:10, 4861:6
abeyance [2] - 4641:22, 4864:8
ability [7] - 4650:11, 4721:2, 4728:18,
4732:5, 4741:5, 4744:25, 4756:18
able [14] - 4635:23, 4643:4, 4644:4,
4670:16, 4673:15, 4673:17, 4683:10,
4716:18, 4791:2, 4792:22, 4825:3,
4829:3, 4860:4, 4864:15
ably [1] - 4865:7
abroad [2] - 4675:6, 4858:1
absence [1] - 4715:24
absolutely [5] - 4684:2, 4725:25,
4773:14, 4837:15, 4845:8
absurd [3] - 4830:20, 4836:16,
4840:15
Abu [102] - 4658:4, 4658:18, 4668:8,
4668:15, 4671:12, 4673:4, 4680:8,
4680:23, 4681:4, 4681:9, 4681:15,
4681:18, 4682:8, 4682:14, 4682:19,
4683:11, 4683:13, 4683:22, 4684:6,
4684:18, 4684:20, 4685:1, 4685:9,
4685:14, 4685:22, 4685:24, 4686:1,
4686:4, 4688:18, 4713:6, 4713:8,
4714:16, 4726:2, 4727:10, 4733:7,
4735:14, 4735:22, 4737:24, 4738:4,
4738:7, 4738:18, 4739:5, 4739:12,
4739:13, 4739:15, 4740:8, 4740:10,
4740:11, 4742:24, 4743:23, 4757:16,
4763:19, 4763:20, 4777:5, 4777:7,
4777:8, 4777:11, 4777:12, 4777:15,
4777:17, 4778:6, 4778:10, 4779:7,
4779:16, 4782:2, 4797:18, 4811:7,
4811:8, 4811:10, 4811:14, 4811:17,
4811:19, 4811:21, 4812:11, 4813:2,
4813:4, 4813:6, 4818:21, 4818:23,
4820:22, 4829:2, 4829:23, 4831:25,
4833:21, 4836:2, 4836:4, 4836:5,
4839:18, 4841:3, 4842:20, 4843:5,
4843:7, 4843:16, 4846:5, 4847:13,
4856:13, 4856:14, 4856:21
Abul [1] - 4743:13
accept [5] - 4641:25, 4645:17,
4750:23, 4863:22, 4864:3
acceptance [3] - 4709:18, 4757:3,
4757:6
accepting [2] - 4751:25, 4863:23
accepts [2] - 4653:18, 4654:2
access [4] - 4728:13, 4728:14,
4828:17, 4853:19
accompany [1] - 4680:22
accomplish [7] - 4651:14, 4652:17,
4666:19, 4669:1, 4713:23, 4809:22,
4836:9
accomplished [6] - 4723:23, 4810:15,
4814:2, 4814:15, 4848:6, 4848:7
accomplishing [1] - 4661:5

accomplishment [4] - 4723:21,
4723:22, 4740:2, 4740:4
accomplishments [2] - 4710:1,
4739:22
according [9] - 4683:23, 4710:22,
4753:10, 4777:7, 4778:12, 4786:5,
4792:20, 4798:16
account [28] - 4635:22, 4646:9,
4658:19, 4677:6, 4689:25, 4690:2,
4690:9, 4692:25, 4743:13, 4802:18,
4802:24, 4803:6, 4803:9, 4843:19,
4843:20, 4843:21, 4843:25, 4844:16,
4845:1, 4845:5, 4845:11, 4845:13,
4845:20, 4847:16, 4847:18, 4847:19,
4849:23, 4851:13
accountable [3] - 4703:22, 4703:24,
4704:1
accuracy [2] - 4659:12, 4833:25
accurate [3] - 4645:19, 4819:18,
4843:14
accused [4] - 4667:20, 4790:22,
4790:25
achievable [1] - 4748:18
achieve [1] - 4817:24
achieved [2] - 4710:4, 4748:25
acquaintance [2] - 4664:8, 4770:17
acquitted [1] - 4835:13
act [14] - 4657:10, 4657:17, 4695:20,
4698:9, 4700:8, 4751:11, 4771:18,
4772:5, 4772:8, 4775:9, 4792:20,
4793:10, 4865:5
acting [1] - 4724:20
action [4] - 4648:20, 4660:13,
4725:25, 4854:22
actions [7] - 4647:18, 4650:13,
4652:16, 4662:19, 4689:16, 4752:1,
4810:20
active [1] - 4680:4
actively [1] - 4694:4
activity [1] - 4682:21
actual [4] - 4661:9, 4671:10, 4690:11,
4829:7
adapt [1] - 4639:14
Adbul [1] - 4676:6
add [4] - 4772:7, 4819:24, 4821:14,
4852:23
additional [5] - 4638:2, 4638:7,
4638:21, 4639:5, 4698:8
Addonizio [27] - 4635:5, 4659:18,
4660:5, 4660:12, 4662:14, 4664:1,
4666:16, 4686:4, 4697:19, 4713:19,
4713:21, 4752:21, 4753:1, 4776:14,
4785:19, 4794:22, 4808:2, 4811:18,
4816:24, 4817:2, 4828:3, 4828:6,
4829:10, 4831:7, 4831:20, 4832:2,
4841:18
address [5] - 4636:3, 4636:5, 4641:11,
4744:10, 4864:15
adds [2] - 4688:13, 4748:5


adjourned [1] - 4866:12
administrative [2] - 4635:8, 4635:12
admirable [1] - 4862:13
admissible [3] - 4639:8, 4639:18,
4639:21
admissions [1] - 4832:10
admit [5] - 4676:4, 4676:22, 4684:4,
4793:17, 4856:11
admits [1] - 4741:3
admitted [13] - 4659:15, 4659:24,
4660:19, 4746:17, 4751:2, 4751:4,
4755:17, 4768:24, 4771:2, 4834:1,
4836:6, 4841:14, 4849:22
admitting [2] - 4751:5, 4751:8
Adnan [6] - 4658:3, 4667:4, 4667:25,
4763:12, 4764:7, 4818:10
advance [4] - 4663:10, 4849:11,
4849:21, 4850:18
advancing [3] - 4784:10, 4803:19,
4849:25
advantage [9] - 4650:11, 4716:1,
4725:5, 4734:14, 4734:19, 4736:20,
4756:23, 4777:1, 4829:24
advice [30] - 4655:13, 4658:17,
4660:22, 4681:21, 4682:14, 4682:24,
4683:6, 4683:7, 4683:10, 4684:24,
4685:7, 4694:8, 4694:9, 4694:10,
4694:14, 4694:16, 4801:20, 4836:7,
4841:6, 4841:10, 4841:15, 4842:3,
4842:5, 4842:9, 4842:12, 4842:13,
4842:14, 4849:24, 4854:24
advisable [1] - 4682:2
advise [3] - 4682:19, 4694:17, 4695:1
advised [4] - 4638:25, 4640:12,
4849:11, 4849:13
advising [3] - 4658:15, 4675:4,
4835:22
aeronautical [1] - 4717:13
affected [2] - 4701:23, 4702:1
affidavit [4] - 4692:3, 4692:5, 4692:22,
4693:5
afraid [4] - 4740:21, 4741:16, 4742:22,
4742:24
afternoon [5] - 4755:10, 4762:7,
4762:8, 4806:8, 4806:9
AFTERNOON [1] - 4760:1
afterwards [2] - 4746:9, 4861:20
Agent [1] - 4669:23
agents [1] - 4832:2
aggressor [1] - 4654:12
ago [8] - 4660:8, 4678:17, 4679:8,
4717:15, 4765:1, 4789:18, 4840:6,
4847:17
agree [21] - 4637:18, 4640:18,
4641:14, 4644:16, 4654:1, 4654:3,
4658:4, 4658:9, 4691:10, 4696:19,
4708:8, 4729:14, 4743:20, 4761:18,
4762:10, 4762:17, 4805:22, 4839:13,
4843:5, 4854:11, 4857:11
agreed [31] - 4646:24, 4647:3,
4655:21, 4657:16, 4657:23, 4658:13,

4658:25, 4661:21, 4662:12, 4663:2,
4675:1, 4677:15, 4695:3, 4695:25,
4701:12, 4703:20, 4715:23, 4727:10,
4744:1, 4744:2, 4812:18, 4812:19,
4835:4, 4836:12, 4837:1, 4837:5,
4840:1, 4844:18, 4849:21, 4850:9
agreeing [11] - 4657:7, 4657:10,
4658:20, 4662:24, 4700:7, 4733:25,
4806:13, 4808:18, 4836:1, 4841:2,
4845:11
agreement [22] - 4639:17, 4641:3,
4647:5, 4647:7, 4657:8, 4657:13,
4657:20, 4661:22, 4709:23, 4715:19,
4725:3, 4744:25, 4746:5, 4748:19,
4796:8, 4808:6, 4835:12, 4845:9,
4854:24, 4861:19, 4861:25, 4862:5
agreements [2] - 4834:20, 4835:7
agrees [12] - 4637:21, 4680:22,
4689:25, 4714:17, 4737:5, 4737:24,
4740:18, 4741:24, 4842:19, 4845:9,
4845:10, 4856:17
Agriculture [1] - 4676:15
ahead [1] - 4794:20
aHMAD [1] - 4649:5
Ahmad [8] - 4635:3, 4645:25, 4646:2,
4704:5, 4705:16, 4805:5, 4834:4,
4848:12
AHMAD [20] - 4633:18, 4646:3,
4649:16, 4649:25, 4650:9, 4651:10,
4664:23, 4670:5, 4672:2, 4672:18,
4678:7, 4679:4, 4680:2, 4681:1,
4682:19, 4683:21, 4689:11, 4694:21,
4698:4, 4867:4
Ahmad's [1] - 4722:15
Aided [1] - 4634:12
aiding [7] - 4638:8, 4638:14, 4639:5,
4702:9, 4703:5, 4703:10, 4861:6
aimed [1] - 4686:20
ain't [6] - 4781:25, 4789:8, 4798:18,
4799:5, 4801:4, 4810:9
air [4] - 4717:8, 4717:11, 4816:6,
4817:11
Air [4] - 4718:2, 4724:5, 4724:8,
4724:10
aircraft [4] - 4699:7, 4699:8, 4699:10
Aires [1] - 4819:11
airline [3] - 4733:9, 4780:16, 4780:17
airplane [5] - 4697:9, 4699:12, 4700:4,
4845:15, 4845:21
airplanes [3] - 4699:12, 4699:14,
4699:20
Airport [42] - 4646:14, 4647:4, 4647:9,
4649:13, 4649:18, 4655:12, 4655:22,
4656:1, 4658:14, 4659:24, 4660:22,
4661:3, 4662:25, 4690:16, 4695:4,
4695:10, 4699:2, 4700:11, 4700:13,
4701:10, 4702:15, 4703:21, 4708:25,
4709:7, 4711:25, 4718:8, 4720:4,
4745:10, 4808:19, 4828:21, 4833:10,
4839:4, 4839:5, 4839:10, 4844:21,

4844:22, 4844:25, 4845:18, 4848:7,
4854:6, 4858:4, 4858:15
airport [106] - 4646:25, 4647:19,
4650:20, 4651:2, 4651:3, 4651:11,
4657:11, 4657:25, 4660:4, 4661:11,
4662:15, 4663:2, 4667:11, 4669:7,
4669:9, 4672:8, 4672:12, 4681:14,
4694:15, 4695:14, 4696:6, 4696:10,
4696:12, 4697:20, 4698:9, 4700:8,
4700:10, 4700:12, 4701:11, 4701:18,
4702:19, 4703:3, 4703:6, 4716:6,
4716:11, 4716:15, 4716:17, 4716:20,
4717:2, 4717:7, 4717:10, 4717:18,
4717:20, 4718:17, 4720:16, 4720:18,
4723:23, 4724:12, 4731:18, 4744:7,
4745:13, 4806:13, 4806:14, 4807:16,
4808:6, 4808:15, 4809:9, 4809:16,
4809:18, 4810:20, 4811:9, 4811:16,
4812:3, 4813:16, 4813:19, 4814:15,
4814:17, 4815:17, 4815:21, 4816:5,
4816:9, 4816:17, 4816:18, 4816:22,
4817:17, 4817:21, 4820:4, 4820:9,
4820:16, 4821:9, 4821:13, 4822:5,
4822:6, 4822:12, 4822:15, 4822:16,
4822:22, 4824:7, 4824:9, 4825:9,
4827:21, 4830:1, 4830:3, 4830:10,
4830:24, 4831:12, 4833:5, 4833:13,
4835:5, 4835:23, 4836:22, 4840:24,
4840:25, 4842:2, 4845:12, 4858:6
airports [1] - 4649:20
al [4] - 4685:12, 4785:2, 4815:2
Al [15] - 4657:4, 4667:4, 4667:6,
4667:18, 4668:4, 4673:21, 4712:15,
4712:17, 4712:18, 4746:13, 4746:18,
4818:9, 4818:10, 4820:19, 4849:8
Al-Qaeda [3] - 4818:9, 4818:10,
4820:19
alcoholic [1] - 4840:17
alert [1] - 4636:20
alerting [1] - 4864:16
alhemdulilah [1] - 4719:20
Ali [3] - 4664:8, 4848:15, 4848:16
alias [1] - 4780:23
Allah [1] - 4687:9
alleged [1] - 4745:18
alleges [1] - 4775:7
ALLEN [1] - 4633:17
allow [7] - 4641:24, 4735:23, 4735:24,
4744:1, 4773:3, 4773:5, 4773:12
allowed [1] - 4758:9
allowing [2] - 4658:19, 4736:8
alluded [1] - 4713:13
alluding [1] - 4719:5
almost [13] - 4647:7, 4669:10,
4674:15, 4703:17, 4738:12, 4742:5,
4749:15, 4756:2, 4756:7, 4764:20,
4788:13, 4802:18, 4834:6
alone [3] - 4645:22, 4797:18, 4802:11
ALTERNATE [3] - 4643:1, 4643:13,


4643:17
Alternate [6] - 4637:15, 4637:19,
4642:4, 4644:5, 4644:13, 4644:14
alternate [5] - 4637:23, 4642:23,
4643:6, 4782:1, 4859:21
alternates [7] - 4637:4, 4642:7,
4643:16, 4644:6, 4644:11, 4860:2
amazed [3] - 4652:1, 4720:3, 4720:6
amazement [1] - 4720:8
ambitious [1] - 4820:6
amended [1] - 4640:3
amends [1] - 4745:17
AMERICA [1] - 4633:3
America [19] - 4646:10, 4653:21,
4653:24, 4686:23, 4686:24, 4687:1,
4687:2, 4687:13, 4719:24, 4730:21,
4783:15, 4786:15, 4789:7, 4799:1,
4799:2, 4799:3, 4799:11, 4848:13,
4848:19
America's [2] - 4671:19, 4686:21
American [2] - 4650:5, 4697:23
Americans [1] - 4762:14
Americas [2] - 4812:24, 4819:9
amount [5] - 4651:16, 4671:6, 4839:5,
4844:24, 4845:16
amounts [1] - 4750:5
AND [1] - 4634:3
anger [9] - 4648:18, 4648:21, 4649:10,
4650:17, 4651:19, 4822:8, 4822:22,
4822:23, 4822:24
angles [1] - 4752:4
angry [5] - 4648:18, 4650:2, 4673:5,
4833:4
Annas [5] - 4721:16, 4721:18,
4730:13, 4730:16, 4746:11
annas [1] - 4721:21
annual [4] - 4850:4, 4850:7, 4852:3,
4853:5
Answer [3] - 4753:13, 4841:25, 4842:5
answer [13] - 4655:4, 4749:13,
4749:15, 4749:16, 4754:12, 4755:22,
4769:2, 4839:3, 4839:9, 4839:10,
4851:11, 4853:10
answered [3] - 4655:6, 4749:14,
4841:24
answering [1] - 4714:7
answers [2] - 4738:23, 4749:12
anticipate [1] - 4687:20
ants [1] - 4717:9
anxious [1] - 4671:11
anyplace [2] - 4776:7, 4789:5
anytime [2] - 4752:6, 4766:21
anyway [2] - 4736:2, 4811:4
apart [2] - 4672:22, 4748:3
apartment [15] - 4712:8, 4714:9,
4733:16, 4734:7, 4747:6, 4751:14,
4751:18, 4756:23, 4757:1, 4828:2,
4828:3, 4828:16, 4828:18, 4828:20
apologize [1] - 4635:15
appearance [3] - 4635:9, 4635:12,
4635:14
appearances [2] - 4635:1, 4636:4
APPEARANCES [1] - 4633:13
appeared [1] - 4727:9
applied [1] - 4676:16
appreciate [2] - 4636:3, 4792:18
approach [5] - 4654:8, 4777:8, 4813:7,
4843:7, 4848:24
approached [1] - 4854:19
approaching [1] - 4810:22
appropriate [7] - 4638:11, 4640:19,
4641:1, 4826:19, 4829:6, 4857:22,
4858:10
approves [1] - 4689:1
April [1] - 4750:1
Arab [1] - 4821:3
Arabic [1] - 4719:20
Arabs [1] - 4686:24
architects [1] - 4781:24
area [9] - 4669:9, 4670:25, 4671:3,
4671:19, 4700:18, 4813:17, 4821:5,
4822:11, 4822:14
areas [3] - 4670:20, 4672:8, 4697:5
Argentina [1] - 4819:11
argue [9] - 4695:5, 4746:14, 4749:1,
4757:2, 4773:6, 4773:8, 4806:25,
4807:1, 4814:4
argued [10] - 4813:22, 4819:23,
4834:8, 4834:24, 4837:13, 4842:17,
4843:23, 4848:9, 4857:14, 4865:7
arguing [2] - 4723:5, 4864:3
argument [8] - 4641:7, 4807:2,
4807:14, 4814:6, 4830:6, 4836:11,
4836:16, 4848:8
arguments [9] - 4639:25, 4645:2,
4645:8, 4645:15, 4645:17, 4807:11,
4863:10, 4863:11, 4863:12
armed [1] - 4673:23
armor [1] - 4671:20
arouse [1] - 4650:13
arrange [2] - 4666:2, 4827:21
arranged [3] - 4681:13, 4681:17,
4686:7
arrangement [1] - 4730:18
arrangements [4] - 4778:17, 4778:18,
4778:20
arranges [1] - 4690:10
arranging [3] - 4658:17, 4668:16,
4827:21
array [1] - 4823:8
arrest [5] - 4745:3, 4756:4, 4809:10,
4811:15, 4840:1
arrested [12] - 4659:19, 4660:9,
4689:20, 4744:24, 4745:19, 4750:21,
4790:24, 4796:14, 4810:17, 4817:18,
4830:23, 4830:24
arrests [1] - 4755:24
arts [3] - 4674:3, 4674:17, 4742:10
aspects [1] - 4793:6
assault [3] - 4856:3, 4856:6, 4856:7
assess [3] - 4664:19, 4818:4, 4858:12

assessment [1] - 4819:18
asset [1] - 4673:21
assist [2] - 4645:6, 4837:1
assistance [2] - 4777:20, 4777:21
Assistant [2] - 4633:19, 4645:9
assisted [1] - 4803:18
assisting [3] - 4778:22, 4778:24,
4842:10
associated [1] - 4779:10
associates [2] - 4664:12, 4664:14
assume [2] - 4642:6, 4643:9
assuming [2] - 4866:7, 4866:8
assumption [1] - 4675:11
attach [1] - 4830:3
attached [1] - 4817:22
attack [101] - 4647:17, 4648:22,
4650:10, 4650:22, 4655:16, 4655:22,
4657:23, 4658:9, 4658:14, 4658:20,
4659:1, 4660:4, 4660:21, 4661:20,
4661:21, 4661:22, 4662:2, 4662:12,
4662:15, 4663:14, 4664:12, 4664:25,
4666:5, 4667:11, 4667:24, 4668:1,
4670:12, 4670:16, 4672:18, 4672:24,
4673:10, 4673:17, 4673:24, 4678:12,
4680:23, 4681:5, 4682:7, 4687:6,
4688:9, 4690:8, 4690:11, 4690:16,
4690:24, 4691:10, 4692:8, 4693:15,
4695:18, 4695:24, 4697:19, 4699:7,
4700:24, 4701:25, 4703:21, 4704:1,
4806:13, 4808:6, 4808:15, 4808:19,
4808:21, 4810:2, 4810:19, 4811:9,
4812:18, 4813:16, 4814:16, 4816:11,
4816:17, 4817:16, 4817:17, 4817:24,
4818:24, 4819:12, 4819:24, 4819:25,
4820:4, 4820:14, 4820:21, 4821:13,
4821:19, 4824:9, 4828:21, 4829:7,
4830:1, 4830:10, 4830:24, 4831:12,
4832:18, 4834:22, 4834:23, 4835:4,
4836:22, 4844:21, 4844:22, 4844:25,
4845:12, 4845:18, 4854:5, 4854:19,
4857:20, 4858:3, 4858:15
attacking [4] - 4649:18, 4650:20,
4654:16, 4814:15
attacks [10] - 4650:23, 4667:20,
4682:9, 4812:22, 4812:24, 4813:3,
4820:9, 4829:2, 4857:5
attempt [2] - 4656:9, 4863:13
attempted [1] - 4657:15
attempting [2] - 4827:21, 4840:23
attend [1] - 4853:6
attention [5] - 4636:21, 4648:11,
4665:24, 4682:13, 4858:22
Attorney [2] - 4633:15, 4645:9
attorney [1] - 4749:14
attorney's [1] - 4645:19
attorneys [6] - 4636:4, 4636:6,
4636:20, 4645:16, 4802:10, 4808:17
Attorneys [1] - 4633:19
attracting [2] - 4648:11, 4682:13


audience [1] - 4719:25
Audio [2] - 4651:8, 4680:25
audio [33] - 4649:3, 4649:4, 4649:14,
4649:15, 4649:23, 4649:24, 4650:7,
4650:8, 4651:9, 4664:21, 4664:22,
4670:3, 4670:4, 4671:25, 4672:1,
4672:16, 4672:17, 4678:5, 4678:6,
4679:2, 4679:3, 4679:25, 4680:1,
4680:24, 4682:17, 4682:18, 4683:19,
4683:20, 4689:9, 4689:10, 4698:2,
4698:3, 4835:22
audiotapes [2] - 4842:17
August [1] - 4710:23
authorities [1] - 4653:5
Authority [6] - 4651:2, 4669:10,
4676:14, 4701:17, 4817:3, 4822:10
authority [1] - 4653:6
authorizing [1] - 4836:10
automatically [2] - 4641:17, 4794:8
available [3] - 4703:12, 4823:8,
4843:12
avenge [3] - 4648:3, 4687:6, 4687:17
avoid [4] - 4655:11, 4681:22, 4682:13,
4716:14
aware [3] - 4674:3, 4822:13, 4822:17
awhile [1] - 4674:19
Ayatollah [6] - 4653:12, 4653:16,
4654:1, 4784:14, 4784:19, 4848:12
B
backed [1] - 4781:15
background [1] - 4654:22
backing [3] - 4658:6, 4673:10,
4862:13
bad [22] - 4693:8, 4744:22, 4746:18,
4747:1, 4748:6, 4764:7, 4764:8,
4778:15, 4783:15, 4786:23, 4789:12,
4789:25, 4790:12, 4790:13, 4790:14,
4790:15, 4790:16, 4790:18, 4792:23,
4799:3
bag [2] - 4651:1, 4651:6
bail [1] - 4748:14
Baiyna [2] - 4791:16, 4791:24
Bakr [104] - 4658:4, 4658:18, 4668:8,
4668:15, 4671:12, 4673:4, 4680:9,
4680:23, 4681:4, 4681:9, 4681:15,
4681:18, 4682:8, 4682:14, 4682:20,
4683:11, 4683:14, 4683:22, 4684:6,
4684:19, 4684:20, 4684:22, 4685:1,
4685:9, 4685:14, 4685:22, 4685:24,
4686:1, 4686:4, 4688:18, 4713:6,
4713:8, 4714:16, 4726:2, 4727:10,
4733:7, 4735:14, 4735:22, 4737:24,
4738:4, 4738:7, 4738:18, 4739:5,
4739:12, 4739:13, 4739:15, 4740:8,
4740:10, 4740:11, 4740:12, 4742:24,
4743:23, 4757:16, 4763:19, 4763:20,
4777:5, 4777:7, 4777:8, 4777:11,
4777:12, 4777:15, 4777:17, 4778:6,

4778:10, 4779:7, 4779:16, 4782:2,
4797:18, 4811:7, 4811:8, 4811:10,
4811:14, 4811:17, 4811:19, 4811:21,
4812:11, 4813:2, 4813:4, 4813:6,
4818:21, 4818:23, 4820:22, 4829:2,
4829:23, 4831:25, 4833:21, 4836:2,
4836:4, 4836:5, 4839:18, 4841:3,
4842:20, 4843:5, 4843:7, 4843:16,
4846:5, 4847:13, 4856:13, 4856:14,
4856:21, 4858:8
Balai [2] - 4665:14, 4665:16
balancing [1] - 4641:7
band [1] - 4693:14
bank [14] - 4658:19, 4689:25, 4756:5,
4802:18, 4802:24, 4843:19, 4843:20,
4843:21, 4843:25, 4844:15, 4845:13,
4845:20, 4847:18, 4849:23
Bannah [1] - 4849:8
barber [1] - 4713:15
barely [2] - 4684:2, 4693:14
barriers [2] - 4718:12
based [5] - 4702:14, 4727:9, 4748:21,
4832:8, 4833:4
basic [2] - 4659:2, 4822:4
Basin [4] - 4669:17, 4669:18, 4670:14,
4724:5
basis [1] - 4822:9
bastards [3] - 4649:19, 4809:13,
4809:21
bat [1] - 4807:22
Bauxite [2] - 4676:14, 4678:13
Bay [1] - 4704:3
Beach [1] - 4724:6
bear [1] - 4815:18
beards [1] - 4742:10
beat [1] - 4719:3
became [3] - 4637:23, 4686:2, 4711:11
become [6] - 4644:13, 4709:21,
4709:23, 4748:15, 4803:3, 4819:20
becomes [1] - 4716:19
becoming [3] - 4642:5, 4771:9,
4802:25
bed [1] - 4859:4
beer [1] - 4840:18
BEFORE [1] - 4633:10
began [1] - 4646:7
begging [2] - 4737:6, 4788:2
begin [4] - 4645:25, 4708:16, 4762:5,
4859:19
beginning [11] - 4659:25, 4676:13,
4679:23, 4692:5, 4704:17, 4708:1,
4708:2, 4721:12, 4755:13, 4757:20,
4809:12
beginnings [1] - 4840:10
begun [1] - 4653:23
behalf [5] - 4703:15, 4749:10,
4760:17, 4761:25, 4806:3
behaved [2] - 4654:23, 4799:15
behavior [1] - 4746:25
behind [4] - 4651:7, 4768:22, 4801:6,

4836:15
belied [1] - 4677:8
belief [2] - 4653:14, 4802:13
believer [1] - 4653:13
belly [1] - 4722:8
belong [1] - 4737:21
belongs [2] - 4791:12, 4799:8
below [2] - 4690:18, 4694:25
Bennett [2] - 4685:1, 4818:22
BENTON [1] - 4633:15
Bergen [4] - 4669:17, 4669:18,
4670:14, 4724:5
BERGER [1] - 4633:18
Berger [3] - 4635:3, 4646:6, 4657:2
BERIT [1] - 4633:18
Berit [1] - 4635:2
best [29] - 4670:9, 4670:10, 4681:9,
4687:16, 4688:18, 4691:23, 4694:10,
4694:14, 4694:15, 4694:17, 4694:24,
4695:1, 4704:2, 4723:3, 4729:11,
4739:24, 4748:6, 4765:23, 4788:25,
4796:9, 4841:10, 4841:14, 4841:24,
4842:2, 4842:5, 4842:9, 4842:14,
4865:13
better [25] - 4655:6, 4658:2, 4658:15,
4665:12, 4668:25, 4674:24, 4675:4,
4688:13, 4688:15, 4693:20, 4703:8,
4707:17, 4768:23, 4782:19, 4811:14,
4812:7, 4813:1, 4813:6, 4813:9,
4813:10, 4813:17, 4813:19, 4843:10,
4844:13
between [18] - 4647:9, 4657:9, 4675:4,
4675:7, 4675:10, 4676:3, 4678:1,
4692:16, 4692:20, 4705:23, 4738:1,
4741:10, 4747:10, 4747:11, 4747:23,
4761:1, 4816:15, 4828:4
beyond [13] - 4647:23, 4661:1,
4672:13, 4692:1, 4734:20, 4734:22,
4748:7, 4748:8, 4752:9, 4757:5,
4806:19, 4830:20, 4837:7
bidder [1] - 4794:7
big [16] - 4690:22, 4708:21, 4721:17,
4736:19, 4742:18, 4750:9, 4757:19,
4799:18, 4808:8, 4808:10, 4817:24,
4819:25, 4820:23, 4844:24, 4849:11,
4850:15
big-mouth [1] - 4808:10
bigger [1] - 4667:2
biggest [1] - 4830:2
Bilai [1] - 4828:12
Bilal [1] - 4730:10
Bin [1] - 4846:8
bin [1] - 4815:2
bit [13] - 4636:23, 4640:20, 4641:20,
4655:20, 4683:2, 4691:5, 4704:13,
4749:3, 4813:24, 4815:16, 4851:2,
4855:20, 4855:25
bite [1] - 4664:6
bits [1] - 4792:21


bitter [1] - 4662:5
black [3] - 4742:9, 4820:12
Black [1] - 4730:5
blank [1] - 4651:15
blanks [2] - 4749:7, 4752:6
blasphemy [1] - 4788:14
blend [1] - 4650:11
bloody [1] - 4686:25
blot [1] - 4836:2
blow [35] - 4646:13, 4646:25, 4647:8,
4647:19, 4655:12, 4661:2, 4662:21,
4672:12, 4672:14, 4687:2, 4694:14,
4694:24, 4695:4, 4695:13, 4697:20,
4699:12, 4700:14, 4701:18, 4708:24,
4711:24, 4713:3, 4740:6, 4745:10,
4745:13, 4769:4, 4813:19, 4827:20,
4833:18, 4836:8, 4840:23, 4841:12,
4841:23, 4842:2, 4842:9, 4842:15
blowing [7] - 4652:6, 4656:1, 4660:11,
4699:13, 4763:11, 4776:18, 4776:19
blown [2] - 4677:25, 4770:15
blows [1] - 4821:5
blueprints [3] - 4768:14, 4785:19,
4790:6
board [3] - 4665:13, 4689:20, 4812:17
boarding [3] - 4777:21, 4778:1,
4778:21
boasting [2] - 4710:10, 4808:16
boatload [1] - 4796:15
bodily [3] - 4696:16, 4696:20, 4696:23
body [2] - 4670:13, 4670:17
bogeyman [6] - 4764:7, 4783:14,
4784:16, 4786:3, 4786:4
boil [1] - 4807:13
boiled [2] - 4648:19
bomb [20] - 4647:3, 4651:1, 4651:6,
4651:12, 4656:25, 4657:7, 4657:10,
4659:24, 4662:24, 4663:2, 4667:4,
4667:6, 4670:7, 4670:9, 4670:23,
4671:5, 4693:21, 4821:1, 4821:7,
4821:10
bombed [1] - 4819:10
bombing [6] - 4668:11, 4684:7,
4695:20, 4698:9, 4818:24, 4841:4
bombs [10] - 4667:9, 4671:1, 4686:25,
4699:18, 4702:15, 4702:17, 4703:14,
4719:9, 4719:10, 4811:15
bona [1] - 4687:5
Bond [1] - 4815:2
boof [1] - 4789:22
boogeyman [12] - 4788:24, 4790:21,
4791:7, 4791:17, 4792:15, 4792:16,
4793:8, 4794:14, 4799:4, 4799:14,
4842:8, 4854:14
book [5] - 4687:24, 4781:1, 4791:9,
4852:5, 4852:12
bordered [1] - 4669:16
borders [1] - 4857:6
borrow [1] - 4731:24
borrowed [2] - 4652:3, 4737:11
bottled [1] - 4823:14

bottom [4] - 4699:16, 4710:9, 4721:13,
4727:14
bought [5] - 4725:9, 4727:12, 4737:8,
4791:20, 4855:22
bound [1] - 4649:12
boy [1] - 4719:8
brains [2] - 4783:25, 4793:14
brand [1] - 4824:24
brand-new [1] - 4824:24
break [12] - 4642:17, 4697:25, 4704:6,
4704:12, 4705:4, 4705:15, 4758:3,
4758:23, 4760:19, 4804:3, 4804:13,
4804:20
breaking [1] - 4724:22
breaks [1] - 4672:22
breeze [1] - 4663:18
brief [2] - 4705:4, 4804:13
briefcase [1] - 4821:8
briefly [1] - 4642:5
bright [1] - 4859:3
bright-eyed [1] - 4859:3
bring [9] - 4636:11, 4642:4, 4643:8,
4643:20, 4663:25, 4679:5, 4708:25,
4760:10, 4853:25
bringing [4] - 4686:18, 4769:8,
4770:11, 4816:16
brings [6] - 4663:19, 4678:7, 4696:14,
4743:6, 4743:10, 4766:15
broken [1] - 4723:25
broker [1] - 4676:6
Brooklyn [5] - 4633:5, 4633:16,
4633:24, 4634:9, 4823:16
Brother [1] - 4779:11
brother [6] - 4652:3, 4652:6, 4653:4,
4688:23, 4739:4, 4853:15
brothers [6] - 4681:16, 4755:14,
4755:18, 4792:1, 4852:7, 4852:9
brought [12] - 4636:21, 4643:2,
4654:17, 4662:11, 4664:2, 4672:6,
4712:22, 4747:21, 4764:9, 4776:2,
4833:13, 4863:8
Bruce [2] - 4713:11, 4808:10
Buenos [1] - 4819:11
build [2] - 4798:14, 4854:23
building [13] - 4634:22, 4648:18,
4648:19, 4672:10, 4690:3, 4698:18,
4698:21, 4700:1, 4731:21, 4731:22,
4765:16, 4845:1, 4854:18
buildings [1] - 4698:23
built [6] - 4698:20, 4699:2, 4717:15,
4717:19, 4718:7, 4817:8
bulk [3] - 4669:13, 4669:15, 4697:6
bullet [9] - 4794:18, 4795:1, 4795:3,
4795:4, 4795:5, 4856:4
bullets [2] - 4856:2, 4856:7
burden [3] - 4645:11, 4704:8, 4734:20
buried [1] - 4749:16
bushy [1] - 4859:3
bushy-tailed [1] - 4859:3
business [36] - 4648:14, 4655:23,

4656:2, 4674:19, 4676:19, 4683:2,
4684:18, 4684:19, 4691:12, 4691:19,
4693:13, 4727:18, 4729:17, 4729:19,
4731:11, 4731:15, 4735:3, 4750:2,
4756:13, 4756:15, 4756:19, 4765:15,
4765:22, 4770:8, 4776:25, 4777:1,
4823:1, 4823:3, 4823:7, 4823:18,
4830:14, 4830:15, 4830:17, 4837:2,
4839:21, 4840:7
businessman [2] - 4665:17, 4688:2
bust [1] - 4756:6
busted [2] - 4796:21, 4796:24
busy [2] - 4657:11, 4730:19
butters [1] - 4739:22
butts [1] - 4726:7
buy [9] - 4647:22, 4723:17, 4727:10,
4733:17, 4737:16, 4737:19, 4752:19,
4829:3, 4851:9
buying [2] - 4851:4, 4851:21
buys [2] - 4851:11, 4851:12
BY [2] - 4633:17, 4867:7
C
cable [1] - 4791:20
Cadman [2] - 4633:16, 4634:9
cake [1] - 4832:14
calender [1] - 4665:7
callous [1] - 4650:11
calm [1] - 4652:10
Calvin [2] - 4684:25, 4818:22
camera [16] - 4709:14, 4721:9, 4722:2,
4722:4, 4722:7, 4722:9, 4722:20,
4723:8, 4723:10, 4723:15, 4723:17,
4812:4, 4816:20, 4816:25, 4824:25,
4825:4
cameras [2] - 4718:10, 4721:18
camouflage [1] - 4820:13
CAMPBELL [1] - 4633:15
candidate [3] - 4687:16, 4739:24
cannot [10] - 4695:3, 4704:25, 4705:3,
4705:4, 4801:11, 4803:3, 4804:8,
4809:18, 4859:12, 4859:14
capability [1] - 4814:21
capital [1] - 4844:25
capone [1] - 4815:2
captured [3] - 4806:11, 4825:9,
4846:16
car [6] - 4652:4, 4669:21, 4669:22,
4669:25, 4703:2, 4765:24
Carbonaro [18] - 4651:2, 4669:9,
4669:12, 4696:5, 4697:4, 4701:16,
4702:22, 4717:10, 4717:14, 4717:21,
4718:6, 4718:14, 4718:23, 4724:11,
4815:19, 4816:13, 4816:23, 4822:10
card [2] - 4717:17, 4851:13
cards [1] - 4781:4
care [11] - 4655:1, 4661:6, 4663:20,


4665:19, 4715:24, 4735:2, 4743:22,
4752:5, 4797:3, 4801:16, 4860:6
cared [3] - 4663:21, 4693:15, 4852:12
careful [6] - 4654:24, 4654:25,
4655:14, 4663:25, 4685:10, 4687:14
carefully [2] - 4775:13, 4775:14
cargo [9] - 4648:12, 4700:18, 4718:23,
4718:24, 4719:6, 4740:17, 4816:1,
4822:16
Caribbean [13] - 4667:5, 4667:14,
4667:19, 4668:5, 4668:9, 4685:11,
4712:20, 4746:14, 4818:11, 4818:15,
4818:16, 4819:22, 4830:2
carried [2] - 4822:12, 4854:3
carry [5] - 4653:7, 4657:15, 4690:13,
4728:18, 4799:19
carrying [2] - 4745:25, 4799:22
cars [1] - 4808:16
case [81] - 4638:6, 4640:20, 4644:8,
4644:25, 4645:23, 4656:17, 4659:7,
4661:19, 4666:24, 4677:5, 4682:2,
4690:7, 4691:22, 4692:4, 4692:5,
4701:16, 4704:19, 4704:23, 4705:1,
4705:6, 4705:7, 4708:23, 4709:1,
4709:2, 4709:4, 4709:6, 4709:20,
4713:25, 4717:11, 4720:9, 4731:1,
4744:17, 4748:6, 4749:6, 4749:21,
4750:24, 4751:2, 4751:10, 4751:12,
4752:21, 4754:22, 4755:2, 4756:6,
4757:5, 4757:11, 4757:13, 4757:22,
4758:7, 4758:8, 4758:11, 4758:13,
4758:14, 4758:16, 4758:17, 4760:14,
4799:1, 4802:8, 4804:6, 4804:8,
4804:9, 4804:10, 4804:11, 4804:12,
4806:11, 4806:18, 4818:19, 4832:7,
4832:25, 4834:3, 4846:23, 4857:19,
4857:25, 4859:8, 4859:12, 4859:15,
4859:17, 4860:1, 4860:3, 4860:5
cash [5] - 4851:7, 4851:8, 4851:10,
4851:13, 4851:21
casually [1] - 4666:3
catastrophic [1] - 4816:4
category [1] - 4660:15
caught [29] - 4647:17, 4655:11,
4655:19, 4664:18, 4670:11, 4671:2,
4671:3, 4672:9, 4681:23, 4682:5,
4682:9, 4692:23, 4740:21, 4742:22,
4751:14, 4806:11, 4806:23, 4806:24,
4808:14, 4812:1, 4812:6, 4814:25,
4824:8, 4835:22, 4836:1, 4836:4,
4836:10, 4836:17, 4841:6
caused [3] - 4649:18, 4650:23,
4696:11
causing [1] - 4646:14
caution [2] - 4655:12, 4655:17
cautious [4] - 4655:18, 4664:15,
4665:10, 4675:20
celebrate [3] - 4784:12, 4784:20,
4850:13
celebrations [1] - 4789:2
cell [13] - 4705:3, 4746:22, 4758:9,

4765:8, 4765:10, 4765:11, 4779:25,
4780:1, 4780:2, 4782:21, 4804:13,
4809:24, 4809:25
Center [4] - 4653:2, 4697:24, 4849:6,
4849:7
center [4] - 4679:6, 4792:4, 4792:5,
4819:11
certain [4] - 4645:13, 4666:9, 4763:11
certainly [5] - 4675:7, 4700:13,
4773:8, 4783:7, 4863:11
chair [1] - 4775:17
chambers [3] - 4641:10, 4641:23,
4642:1
chance [12] - 4640:22, 4664:2, 4664:7,
4681:9, 4682:15, 4691:11, 4704:22,
4756:25, 4813:19, 4835:18, 4861:16
chances [1] - 4683:8
change [5] - 4642:8, 4644:13,
4668:19, 4688:25, 4840:8
changed [9] - 4638:14, 4655:20,
4677:4, 4691:7, 4692:24, 4762:13,
4762:14, 4796:18
changes [2] - 4676:23, 4743:1
changing [3] - 4638:15, 4677:6,
4845:23
channels [1] - 4791:19
chanting [1] - 4798:25
chants [1] - 4798:24
character [5] - 4664:16, 4680:12,
4708:22, 4757:21, 4808:12
characterizations [1] - 4809:1
characterized [1] - 4809:1
charge [32] - 4637:7, 4637:8, 4638:4,
4638:5, 4638:7, 4638:8, 4638:9,
4638:11, 4638:15, 4638:16, 4638:21,
4639:5, 4639:12, 4639:13, 4639:22,
4640:1, 4640:2, 4640:13, 4640:18,
4640:25, 4646:22, 4656:12, 4662:22,
4759:2, 4804:21, 4861:6, 4864:12,
4864:21, 4864:24
charged [19] - 4641:4, 4646:20,
4657:1, 4657:3, 4657:5, 4657:7,
4658:8, 4685:1, 4695:16, 4703:5,
4709:19, 4757:21, 4766:20, 4806:12,
4806:17, 4815:5, 4823:2, 4858:16,
4858:21
charges [15] - 4639:23, 4647:2,
4657:21, 4685:13, 4695:11, 4695:23,
4698:17, 4699:6, 4700:6, 4701:4,
4702:8, 4745:2, 4775:4, 4814:10,
4865:5
charging [2] - 4769:8, 4857:22
chauffeur [1] - 4724:24
chauffeuring [1] - 4716:8
check [6] - 4758:10, 4760:25, 4767:14,
4787:2, 4799:11
checked [3] - 4640:7, 4701:16,
4744:14
cheer [1] - 4784:17
Chef [1] - 4697:6

chemicals [3] - 4666:22, 4824:21,
4833:18
chick [1] - 4719:11
Chicken [24] - 4654:17, 4655:16,
4675:22, 4676:5, 4676:10, 4678:8,
4679:5, 4680:10, 4690:4, 4690:5,
4690:6, 4732:21, 4776:2, 4813:15,
4813:16, 4844:13, 4844:19, 4844:20,
4845:6, 4846:20, 4846:22, 4847:1,
4847:6
chicken [8] - 4655:15, 4675:23,
4676:8, 4676:9, 4676:17, 4676:20,
4719:7, 4847:5
chickens [1] - 4813:18
child [1] - 4796:4
children [9] - 4661:14, 4770:12,
4791:13, 4791:14, 4791:19, 4795:14,
4798:19, 4798:21
chink [1] - 4671:19
choice [4] - 4668:3, 4818:21, 4819:4,
4862:20
chooses [1] - 4655:2
choosing [3] - 4703:23, 4704:1,
4811:7
chose [2] - 4663:16, 4668:14
Christmas [1] - 4828:14
circle [1] - 4664:3
circulated [1] - 4861:18
circumstance [1] - 4860:3
circumstances [2] - 4824:7, 4835:14
citizen [5] - 4648:10, 4650:12,
4652:25, 4700:23, 4701:1
citizens [2] - 4698:14, 4858:5
City [16] - 4710:15, 4714:3, 4714:5,
4714:12, 4714:15, 4714:18, 4714:21,
4715:5, 4715:12, 4715:19, 4715:25,
4716:9, 4725:12, 4733:19, 4747:17,
4756:24
city [2] - 4648:11, 4858:3
claim [7] - 4709:17, 4719:11, 4723:23,
4724:16, 4822:2, 4826:5, 4840:6
claimed [5] - 4676:6, 4677:19,
4693:14, 4723:12, 4839:19
claiming [4] - 4641:3, 4678:3, 4679:8,
4853:5
claims [9] - 4652:1, 4678:17, 4710:5,
4720:8, 4739:23, 4746:19, 4747:13,
4839:14, 4850:12
clarified [2] - 4737:9, 4737:10
clarify [3] - 4640:4, 4640:5, 4655:6
clarity [1] - 4639:10
classic [2] - 4648:8, 4677:4
clear [29] - 4640:5, 4648:25, 4649:9,
4649:20, 4652:19, 4656:9, 4656:10,
4659:11, 4675:10, 4679:20, 4680:14,
4688:8, 4690:19, 4695:9, 4713:11,
4716:19, 4716:25, 4729:23, 4742:12,
4743:21, 4756:16, 4763:4, 4763:6,
4763:8, 4769:2, 4782:2, 4800:13,


4812:7, 4845:23
clearly [10] - 4730:22, 4731:11,
4733:4, 4736:14, 4737:23, 4744:10,
4744:13, 4850:6, 4853:6, 4863:3
CLERK [5] - 4634:16, 4634:21,
4634:24, 4761:13, 4805:18
clerk [1] - 4761:8
client [10] - 4763:7, 4763:8, 4763:9,
4764:5, 4764:23, 4765:6, 4794:1,
4832:17, 4863:6
clients [3] - 4636:7, 4637:12, 4808:18
clients' [2] - 4636:4, 4808:5
clip [3] - 4747:14, 4768:20
clips [1] - 4741:7
clock [2] - 4705:10, 4804:15
close [19] - 4657:6, 4657:13, 4669:4,
4669:11, 4670:22, 4671:2, 4671:9,
4689:1, 4699:23, 4717:24, 4777:12,
4777:16, 4824:2, 4839:22, 4839:24,
4840:12, 4848:16, 4855:17, 4864:11
close-up [1] - 4824:2
closed [2] - 4645:1, 4716:23
closely [1] - 4841:16
closer [2] - 4640:20, 4694:20
closing [4] - 4645:2, 4645:8, 4772:19
clothed [1] - 4788:9
co [2] - 4846:1, 4858:2
co-conspirators [2] - 4846:1, 4858:2
cocaine [2] - 4750:5, 4750:25
coconspirator [1] - 4668:14
coconspirators [13] - 4658:1, 4670:23,
4692:7, 4697:22, 4698:14, 4818:8,
4818:19, 4819:3, 4824:4, 4824:15,
4825:10, 4825:22, 4829:1
code [15] - 4666:15, 4675:17, 4675:19,
4675:22, 4675:23, 4676:4, 4676:7,
4676:10, 4676:22, 4677:3, 4812:5,
4813:12, 4813:13, 4847:6
Code [1] - 4831:23
codes [1] - 4741:23
coincidence [1] - 4798:5
coke [1] - 4796:22
collateral [2] - 4661:7, 4661:16
collected [2] - 4652:11, 4751:19
comb [1] - 4752:6
coming [18] - 4691:17, 4692:10,
4704:15, 4707:14, 4714:2, 4714:4,
4715:2, 4724:5, 4724:6, 4724:7,
4741:2, 4747:6, 4781:2, 4802:24,
4807:8, 4808:17, 4852:8, 4863:14
commemoration [3] - 4783:22,
4850:4, 4850:7
comment [2] - 4814:1, 4863:19
commentary [1] - 4823:22
commented [5] - 4772:17, 4772:18,
4772:20, 4772:23, 4772:24
comments [1] - 4809:9
commerce [3] - 4698:22, 4698:23,
4701:24
commit [24] - 4656:15, 4695:20,
4702:2, 4703:15, 4703:20, 4709:19,

4709:22, 4716:5, 4734:15, 4734:17,
4742:19, 4757:4, 4791:23, 4792:14,
4806:16, 4808:15, 4814:23, 4814:24,
4817:15, 4820:14, 4824:9, 4834:22,
4857:4, 4863:24
commitment [9] - 4664:17, 4664:19,
4686:12, 4687:4, 4690:18, 4742:19,
4808:25, 4809:7, 4837:2
commits [2] - 4748:15, 4811:25
committed [15] - 4655:25, 4665:13,
4684:6, 4687:10, 4688:2, 4689:14,
4691:18, 4775:9, 4808:23, 4813:20,
4815:4, 4819:8, 4821:18, 4841:3
committing [8] - 4661:20, 4663:23,
4738:6, 4749:2, 4771:13, 4790:23,
4793:1, 4806:12
common [23] - 4647:1, 4664:4, 4688:4,
4695:21, 4775:18, 4775:20, 4775:21,
4779:13, 4782:6, 4790:1, 4793:7,
4793:9, 4794:12, 4796:13, 4797:9,
4797:12, 4798:8, 4807:3, 4807:11,
4851:11, 4858:18, 4865:4
communicate [2] - 4675:25, 4676:23
communication [2] - 4676:25, 4743:4
communications [3] - 4641:25,
4676:1, 4743:7
communities [3] - 4789:3, 4796:23,
4796:24
community [1] - 4816:5
company [4] - 4697:7, 4816:1, 4816:2,
4816:3
compare [2] - 4724:3, 4749:13
compared [1] - 4861:24
comparison [1] - 4832:23
compiled [1] - 4669:21
complaint [1] - 4732:15
complaints [1] - 4732:14
complete [2] - 4741:18, 4861:24
completed [2] - 4689:12, 4701:23
completely [3] - 4664:19, 4692:21,
4772:15
completion [1] - 4689:15
composition [11] - 4658:2, 4669:8,
4671:9, 4694:13, 4694:16, 4801:17,
4836:7, 4841:11, 4841:15, 4841:23,
4842:3
compound [1] - 4685:13
comprehensive [2] - 4816:20, 4816:25
Compton [3] - 4753:4, 4753:5,
4753:10
computer [10] - 4672:25, 4674:22,
4705:22, 4722:22, 4728:12, 4732:2,
4761:2, 4761:6, 4769:20, 4788:4
Computer [1] - 4634:12
computers [2] - 4712:4, 4769:5
conceded [1] - 4839:12
concerned [3] - 4685:17, 4844:23,
4865:13
concerning [3] - 4639:7, 4731:3,
4798:4
concerns [2] - 4862:13, 4862:18
conciliate [1] - 4747:22
conclusion [1] - 4644:9
conclusions [6] - 4645:14, 4645:20,
4704:19, 4758:6, 4804:6, 4859:8
concrete [4] - 4648:20, 4652:16,
4685:4, 4694:8
conduct [6] - 4657:16, 4662:16,
4670:16, 4681:21, 4724:12, 4724:19
conducting [4] - 4682:9, 4702:8,
4756:1, 4806:14
confer [1] - 4637:12
conference [9] - 4850:2, 4850:4,
4850:7, 4852:3, 4852:14, 4852:15,
4852:17, 4852:24, 4853:6
confess [2] - 4745:22, 4745:25
confessed [9] - 4666:15, 4697:18,
4808:2, 4811:19, 4831:21, 4831:22,
4831:25, 4841:17, 4841:19
confession [7] - 4647:14, 4659:18,
4662:14, 4677:11, 4686:3, 4832:9,
4833:3
confidential [1] - 4788:1
confirm [5] - 4833:5, 4833:8, 4833:11,
4833:19, 4848:2
confirmed [7] - 4811:24, 4813:15,
4833:1, 4833:2, 4833:16, 4833:22,
4834:6
confirms [2] - 4843:14, 4847:5
conform [1] - 4861:16
confront [1] - 4857:4
confronted [2] - 4692:2, 4692:13
confronting [1] - 4848:19
confronts [1] - 4738:17
confusion [7] - 4641:20, 4643:15,
4692:14, 4840:2, 4846:23, 4864:20,
4864:22
connect [1] - 4795:4
connected [7] - 4672:4, 4705:1,
4705:7, 4758:14, 4795:5, 4804:10,
4804:12
connection [5] - 4639:23, 4692:4,
4745:14, 4859:15, 4859:17
connections [13] - 4667:15, 4673:21,
4686:9, 4688:20, 4689:23, 4790:20,
4830:15, 4837:2, 4839:7, 4839:14,
4839:16, 4856:10, 4856:20
consider [9] - 4639:22, 4656:17,
4731:7, 4731:8, 4775:5, 4802:3,
4802:5, 4802:7, 4804:9
considered [2] - 4638:23, 4654:16
considering [1] - 4859:11
consistent [5] - 4638:11, 4638:12,
4679:14, 4857:17, 4858:19
conspiracies [2] - 4641:4, 4865:3
conspiracy [99] - 4646:21, 4647:1,
4657:1, 4657:8, 4658:9, 4659:2,
4660:3, 4661:22, 4662:18, 4663:24,
4673:14, 4685:2, 4695:13, 4695:15,


4695:18, 4698:12, 4700:21, 4701:22,
4702:7, 4709:10, 4709:22, 4715:20,
4716:1, 4716:5, 4720:18, 4723:6,
4725:4, 4725:8, 4726:1, 4726:7,
4727:22, 4728:23, 4729:3, 4732:1,
4732:23, 4733:20, 4734:1, 4734:12,
4734:24, 4736:10, 4736:15, 4736:24,
4737:21, 4739:9, 4743:10, 4745:7,
4745:15, 4745:18, 4750:6, 4750:20,
4756:12, 4756:21, 4757:4, 4757:18,
4762:24, 4763:4, 4763:5, 4763:10,
4763:13, 4763:14, 4763:17, 4765:7,
4769:8, 4771:9, 4771:21, 4772:15,
4772:16, 4773:8, 4775:3, 4775:8,
4775:13, 4803:17, 4803:20, 4806:13,
4807:8, 4807:15, 4808:20, 4809:8,
4814:12, 4814:16, 4815:7, 4816:17,
4832:4, 4832:5, 4835:4, 4835:21,
4836:21, 4837:1, 4849:20, 4849:21,
4850:9, 4856:24, 4856:25, 4858:15,
4864:4, 4864:5, 4865:2, 4865:4
conspirator [2] - 4810:21
conspirators [10] - 4665:10, 4685:15,
4725:20, 4826:2, 4826:11, 4829:19,
4846:1, 4857:13, 4858:2, 4858:11
conspired [1] - 4858:3
conspiring [9] - 4661:2, 4662:24,
4695:23, 4698:18, 4699:6, 4700:7,
4701:4, 4834:22, 4836:9
constitute [1] - 4773:8
Constitution [1] - 4857:18
consultant [1] - 4770:9
Cont'd [1] - 4788:1
Cont'g [1] - 4839:1
contact [8] - 4726:1, 4726:2, 4733:2,
4776:10, 4789:15, 4818:9, 4818:19,
4819:3
contacted [5] - 4683:24, 4775:25,
4776:1, 4776:13, 4776:17
contacting [2] - 4683:15, 4818:20
contacts [27] - 4654:13, 4654:15,
4658:16, 4675:1, 4675:6, 4677:15,
4677:20, 4678:4, 4678:15, 4678:18,
4678:25, 4679:12, 4680:21, 4684:22,
4731:11, 4732:21, 4739:1, 4739:6,
4741:4, 4776:5, 4776:6, 4839:16,
4839:17, 4853:21, 4853:25, 4854:6
contacts' [1] - 4679:21
contained [2] - 4775:4, 4775:7
context [5] - 4651:25, 4656:17,
4768:25, 4769:1, 4811:12
continue [6] - 4644:8, 4653:22,
4725:11, 4729:12, 4775:10, 4844:8
continued [7] - 4726:11, 4760:14,
4771:24, 4774:3, 4787:4, 4800:14,
4838:10
Continued [2] - 4804:23, 4860:12
continues [1] - 4741:22
continuing [3] - 4734:10, 4761:23,
4863:7
contradicted [2] - 4694:2, 4837:15

contradictory [1] - 4660:18
contradicts [1] - 4845:22
contrary [2] - 4659:3, 4776:21
contributions [1] - 4648:4
control [5] - 4684:10, 4717:8, 4717:12,
4761:8, 4817:11
controls [6] - 4717:8, 4717:12, 4723:3,
4771:21, 4788:17, 4802:10
conversation [51] - 4678:20, 4679:5,
4679:10, 4679:21, 4680:13, 4680:18,
4682:16, 4684:18, 4689:12, 4700:3,
4710:25, 4711:2, 4711:4, 4715:1,
4719:12, 4731:20, 4732:20, 4735:12,
4735:19, 4738:20, 4741:19, 4766:2,
4766:3, 4766:8, 4766:15, 4767:5,
4767:25, 4768:4, 4770:1, 4775:25,
4776:2, 4779:15, 4782:10, 4782:13,
4789:19, 4797:18, 4798:6, 4842:25,
4843:4, 4843:6, 4843:11, 4843:25,
4844:12, 4845:20, 4846:3, 4846:4,
4846:6, 4847:17
conversations [24] - 4659:10,
4660:20, 4675:10, 4675:14, 4678:22,
4712:18, 4714:20, 4714:24, 4716:3,
4720:12, 4738:11, 4742:16, 4756:3,
4765:5, 4765:6, 4766:9, 4768:2,
4782:11, 4782:14, 4783:2, 4842:22,
4843:1, 4848:3
conversing [1] - 4704:23
convicted [3] - 4790:23, 4835:13
convicting [2] - 4762:20, 4803:15
convince [2] - 4856:16, 4856:18
convinced [2] - 4640:25, 4752:18
convincing [1] - 4681:10
cookie [2] - 4806:24, 4806:25
cookies [1] - 4807:1
cool [1] - 4652:10
cooperate [3] - 4708:15, 4796:16,
4796:17
cooperates [2] - 4796:16, 4796:25
cooperating [2] - 4751:8, 4832:12
cooperation [8] - 4744:25, 4746:5,
4748:19, 4748:22, 4748:23, 4749:5,
4776:15, 4834:19
coordinated [4] - 4818:23, 4820:8,
4820:21, 4841:4
copies [2] - 4681:25, 4861:19
cops [2] - 4854:20, 4854:21
copy [3] - 4638:17, 4722:22, 4861:21
core [1] - 4646:23
corner [1] - 4741:18
correct [8] - 4641:19, 4694:17,
4754:10, 4773:2, 4841:24, 4842:4,
4865:21, 4866:10
corroborated [2] - 4674:15, 4832:24
counsel [21] - 4635:4, 4636:7,
4637:12, 4638:13, 4638:19, 4639:15,
4641:7, 4645:3, 4645:8, 4645:12,
4645:24, 4704:7, 4704:21, 4772:10,
4802:12, 4802:25, 4823:23, 4861:7,

4861:9, 4861:20, 4864:16
counsel's [1] - 4639:10
Count [6] - 4662:23, 4698:7, 4698:17,
4700:6, 4700:20, 4702:6
count [14] - 4695:21, 4695:23,
4696:15, 4698:17, 4699:5, 4699:6,
4700:6, 4701:4, 4701:22, 4702:6,
4702:7, 4702:16
countless [1] - 4646:5
countries [1] - 4762:15
country [22] - 4646:18, 4648:17,
4650:9, 4650:14, 4653:22, 4668:4,
4683:25, 4703:25, 4730:10, 4762:17,
4783:13, 4789:3, 4807:17, 4807:18,
4827:23, 4857:6, 4857:17, 4857:18,
4857:20, 4857:22, 4858:3
country's [1] - 4855:5
Counts [1] - 4775:8
counts [5] - 4657:1, 4695:16, 4695:17,
4700:13, 4838:9
county [1] - 4665:22
coup [1] - 4841:4
couple [15] - 4636:22, 4637:24,
4673:6, 4673:13, 4761:3, 4798:24,
4808:4, 4809:9, 4810:16, 4829:21,
4831:18, 4834:7, 4840:10, 4843:20,
4845:15
course [16] - 4658:5, 4675:7, 4678:19,
4704:8, 4715:24, 4755:2, 4817:11,
4821:22, 4824:6, 4828:18, 4828:23,
4829:4, 4829:24, 4838:8, 4845:18
COURT [96] - 4633:1, 4634:17,
4634:20, 4634:23, 4635:13, 4635:16,
4635:19, 4636:11, 4636:16, 4636:20,
4637:16, 4637:20, 4637:22, 4638:23,
4639:6, 4641:16, 4641:25, 4642:3,
4642:13, 4642:22, 4642:24, 4643:2,
4643:14, 4643:19, 4643:21, 4643:24,
4644:2, 4644:21, 4694:18, 4704:5,
4705:14, 4706:2, 4707:4, 4707:9,
4707:11, 4707:14, 4707:17, 4707:21,
4708:2, 4708:4, 4708:6, 4708:13,
4757:25, 4758:21, 4759:1, 4760:2,
4760:8, 4760:10, 4760:14, 4760:24,
4761:5, 4761:7, 4761:11, 4761:16,
4761:23, 4762:6, 4767:9, 4768:9,
4771:17, 4771:19, 4772:7, 4772:10,
4772:13, 4773:5, 4773:17, 4773:20,
4775:1, 4788:16, 4794:25, 4795:17,
4795:24, 4802:2, 4802:16, 4802:25,
4803:3, 4803:23, 4804:19, 4805:2,
4805:8, 4805:10, 4805:12, 4805:20,
4806:2, 4823:22, 4838:7, 4851:16,
4853:1, 4858:23, 4861:2, 4861:13,
4861:22, 4862:1, 4864:6, 4865:18,
4866:6, 4866:11
court [9] - 4771:20, 4773:1, 4773:2,
4773:3, 4796:14, 4809:3, 4857:21,
4857:23, 4858:11


Court [20] - 4634:8, 4634:8, 4637:24,
4638:4, 4638:9, 4638:13, 4638:15,
4638:16, 4639:3, 4641:23, 4641:24,
4802:10, 4861:5, 4861:8, 4862:10,
4862:21, 4864:1, 4864:13, 4864:24
Court's [4] - 4636:21, 4641:13,
4641:14, 4705:10
court's [1] - 4773:3
Courthouse [1] - 4633:4
Courtroom [2] - 4761:14, 4805:19
courtroom [15] - 4636:13, 4636:14,
4642:23, 4643:18, 4643:22, 4692:6,
4705:12, 4708:5, 4758:20, 4760:13,
4804:7, 4804:15, 4804:18, 4805:11,
4860:11
covered [2] - 4635:23, 4788:12
coworker [1] - 4770:17
crack [1] - 4750:25
crackpot [1] - 4819:17
crashed [1] - 4652:4
crazy [12] - 4816:21, 4817:4, 4818:14,
4820:7, 4820:10, 4820:13, 4821:5,
4821:11, 4823:6, 4823:12, 4823:18,
4832:6
create [2] - 4690:25, 4864:22
credence [1] - 4773:21
credentials [1] - 4691:4
credit [2] - 4837:13, 4851:13
crew [2] - 4711:20, 4712:10
cried [2] - 4727:3, 4749:23
crime [42] - 4646:24, 4657:13,
4657:14, 4658:8, 4662:23, 4663:23,
4703:11, 4703:14, 4709:22, 4716:5,
4734:15, 4734:18, 4742:20, 4745:25,
4746:4, 4748:15, 4750:13, 4757:4,
4771:13, 4772:21, 4777:4, 4781:14,
4789:8, 4790:18, 4790:23, 4790:25,
4791:22, 4791:23, 4792:11, 4792:13,
4792:14, 4793:1, 4808:2, 4814:11,
4817:14, 4824:8, 4857:12, 4863:24
crimeing [1] - 4793:3
crimes [21] - 4646:20, 4656:16,
4664:1, 4708:22, 4709:19, 4748:17,
4750:22, 4751:2, 4751:5, 4751:8,
4757:20, 4757:21, 4806:12, 4806:16,
4811:25, 4814:23, 4814:24, 4815:5,
4821:25, 4858:16
Criminal [1] - 4634:24
criminal [6] - 4646:9, 4663:24,
4682:21, 4688:4, 4848:13, 4848:19
critical [1] - 4711:8
cross [14] - 4674:4, 4676:3, 4676:21,
4692:3, 4692:22, 4693:2, 4693:23,
4716:7, 4750:25, 4752:24, 4755:17,
4816:19, 4832:11, 4841:14
cross-examination [13] - 4676:3,
4676:21, 4692:3, 4692:22, 4693:2,
4693:23, 4716:7, 4750:25, 4752:24,
4755:17, 4816:19, 4832:11, 4841:14
crossed [1] - 4836:15
crumbs [1] - 4806:24

crying [2] - 4698:1, 4795:10
crystal [2] - 4649:8, 4690:19
cuff [1] - 4652:15
cultural [2] - 4819:11, 4857:2
curative [2] - 4772:7, 4773:24
curb [1] - 4789:22
cures [1] - 4720:23
curiously [1] - 4786:8
current [3] - 4817:7, 4822:10, 4822:17
custody [1] - 4746:16
cut [6] - 4672:24, 4693:6, 4777:2,
4796:15, 4839:23, 4849:3
cutting [1] - 4750:4
cylinder [1] - 4856:2
D
damage [10] - 4650:24, 4661:7,
4661:10, 4661:16, 4671:6, 4696:12,
4697:17, 4700:7, 4701:14, 4816:5
damaged [1] - 4722:23
damages [1] - 4756:14
danger [4] - 4711:3, 4729:10, 4741:15,
4865:12
dangerous [7] - 4739:14, 4762:9,
4762:22, 4803:15, 4811:18, 4813:7,
4822:1
darken [1] - 4742:9
date [6] - 4640:3, 4744:9, 4753:19,
4753:21, 4754:3, 4852:5
dates [6] - 4791:9, 4852:6, 4852:7,
4852:11, 4852:12
daughter [6] - 4785:24, 4785:25,
4786:1, 4788:11, 4791:17
daughters [2] - 4785:25, 4786:1
Dawood [17] - 4710:7, 4711:15,
4712:11, 4712:21, 4712:22, 4712:24,
4714:12, 4714:14, 4715:4, 4715:6,
4715:13, 4727:20, 4728:14, 4755:10,
4755:20, 4755:21
days [19] - 4637:3, 4678:24, 4723:23,
4738:14, 4739:25, 4740:19, 4741:1,
4754:16, 4779:8, 4779:9, 4781:18,
4781:19, 4781:21, 4797:23, 4809:10,
4809:23, 4810:16, 4853:12
dead [1] - 4817:5
deadly [3] - 4652:11, 4667:24, 4819:14
deal [15] - 4663:21, 4665:5, 4667:11,
4702:13, 4741:5, 4746:9, 4770:3,
4777:9, 4781:12, 4790:15, 4793:5,
4794:16, 4799:18, 4834:21, 4835:2
dealing [12] - 4652:8, 4682:22,
4683:11, 4686:2, 4750:17, 4766:22,
4769:17, 4770:3, 4780:16, 4790:17,
4802:19
deals [6] - 4638:8, 4684:13, 4684:14,
4731:20, 4790:12
dealt [2] - 4766:22, 4791:13
10
dear [1] - 4650:6

death [7] - 4687:17, 4696:2, 4704:3,
4719:8, 4740:17, 4784:13, 4850:14
debate [2] - 4666:21, 4666:23
decades [2] - 4649:1, 4762:16
December [3] - 4714:25, 4715:2,
4717:17
decent [1] - 4648:12
decide [14] - 4641:24, 4664:10,
4682:2, 4688:17, 4689:17, 4691:18,
4731:1, 4736:4, 4736:5, 4755:22,
4764:3, 4819:3, 4855:15
decided [14] - 4665:4, 4668:7,
4668:13, 4669:2, 4673:2, 4678:25,
4708:25, 4713:2, 4713:4, 4713:5,
4713:23, 4739:14, 4740:13, 4811:13
decides [6] - 4666:4, 4715:2, 4728:3,
4740:1, 4745:10, 4770:2
deciding [1] - 4703:24
decision [11] - 4636:8, 4640:14,
4667:10, 4667:22, 4667:25, 4668:19,
4668:20, 4674:5, 4826:24, 4826:25,
4864:7
declare [1] - 4821:20
Defendant [7] - 4633:22, 4634:1,
4639:6, 4639:8, 4660:16, 4864:18,
4866:7
defendant [14] - 4647:4, 4647:16,
4652:23, 4695:23, 4708:16, 4805:15,
4805:16, 4806:22, 4814:12, 4827:20,
4830:7, 4836:16, 4845:24, 4850:11
defendant's [2] - 4638:3, 4822:3
Defendants [1] - 4633:7
defendants [48] - 4634:20, 4636:1,
4636:12, 4636:14, 4639:19, 4639:21,
4641:1, 4641:2, 4646:13, 4646:20,
4646:24, 4647:2, 4648:6, 4656:13,
4656:25, 4657:3, 4657:14, 4661:2,
4690:24, 4695:13, 4695:17, 4695:25,
4696:9, 4698:18, 4699:4, 4699:6,
4699:19, 4700:7, 4700:12, 4701:4,
4701:12, 4702:3, 4702:8, 4702:14,
4702:19, 4703:20, 4704:10, 4760:7,
4760:10, 4760:13, 4805:11, 4806:10,
4806:16, 4807:10, 4814:20, 4835:13,
4857:14, 4857:23
defendants' [9] - 4647:23, 4659:5,
4660:15, 4690:16, 4696:15, 4806:19,
4832:7, 4832:19, 4858:14
Defenders [2] - 4633:23, 4635:7
Defense [1] - 4714:22
defense [34] - 4638:4, 4638:6, 4639:9,
4639:15, 4640:13, 4640:16, 4640:17,
4640:25, 4641:7, 4645:8, 4651:22,
4660:8, 4704:6, 4704:7, 4707:11,
4707:15, 4749:14, 4808:17, 4832:16,
4834:8, 4836:15, 4862:11, 4862:23,
4863:14, 4863:15, 4863:18, 4864:10,
4864:11, 4864:16, 4865:16, 4865:17,
4865:19, 4865:24, 4866:8


defer [1] - 4863:25
definitely [2] - 4678:18, 4679:13
definitively [1] - 4678:4
Defreitas [495] - 4633:22, 4634:25,
4635:8, 4636:16, 4637:14, 4638:14,
4641:8, 4647:14, 4647:24, 4648:6,
4648:8, 4648:16, 4648:21, 4648:25,
4649:7, 4649:10, 4649:17, 4650:11,
4650:25, 4651:4, 4651:21, 4651:25,
4652:10, 4652:21, 4653:5, 4653:8,
4654:17, 4654:24, 4654:25, 4655:7,
4655:13, 4655:22, 4657:22, 4658:13,
4658:18, 4658:25, 4659:13, 4659:14,
4659:19, 4659:24, 4660:6, 4660:8,
4660:21, 4661:20, 4662:1, 4662:3,
4662:5, 4662:8, 4662:10, 4662:11,
4662:13, 4663:1, 4663:8, 4663:12,
4663:14, 4663:17, 4664:5, 4664:6,
4664:10, 4665:9, 4666:1, 4666:15,
4667:12, 4669:3, 4669:6, 4669:17,
4669:25, 4670:5, 4670:15, 4670:19,
4670:21, 4670:23, 4671:11, 4671:21,
4672:3, 4672:6, 4672:22, 4672:25,
4673:4, 4673:9, 4673:14, 4673:20,
4675:10, 4675:25, 4677:10, 4677:11,
4678:2, 4678:8, 4680:8, 4680:15,
4680:20, 4680:22, 4683:3, 4685:16,
4685:21, 4685:24, 4685:25, 4686:5,
4686:10, 4686:15, 4686:20, 4687:3,
4687:5, 4687:7, 4687:19, 4687:20,
4688:10, 4688:14, 4689:4, 4689:7,
4689:11, 4689:14, 4689:17, 4690:10,
4690:22, 4691:3, 4691:12, 4691:15,
4693:11, 4693:12, 4694:4, 4695:4,
4696:24, 4697:18, 4697:23, 4699:22,
4700:14, 4701:1, 4702:24, 4703:7,
4708:17, 4708:20, 4708:24, 4709:3,
4709:6, 4709:11, 4709:13, 4709:16,
4710:6, 4710:10, 4710:11, 4710:13,
4710:14, 4710:19, 4710:23, 4711:3,
4711:11, 4711:13, 4711:14, 4711:16,
4712:11, 4712:24, 4714:1, 4714:4,
4714:10, 4714:11, 4714:15, 4714:18,
4714:24, 4715:1, 4715:5, 4715:21,
4716:4, 4716:9, 4716:10, 4716:11,
4716:13, 4716:18, 4716:19, 4716:24,
4717:1, 4717:6, 4717:7, 4717:20,
4718:4, 4718:7, 4718:10, 4718:11,
4718:14, 4718:18, 4718:19, 4718:21,
4718:25, 4719:4, 4719:24, 4720:2,
4720:10, 4720:11, 4720:13, 4720:17,
4720:21, 4720:25, 4721:7, 4721:20,
4721:22, 4721:25, 4722:2, 4722:4,
4722:5, 4722:7, 4722:8, 4723:5,
4723:7, 4723:12, 4723:15, 4723:16,
4723:17, 4723:20, 4724:17, 4724:20,
4725:2, 4725:6, 4725:9, 4725:10,
4725:12, 4725:19, 4725:24, 4727:6,
4727:20, 4728:10, 4728:15, 4728:19,
4729:2, 4729:4, 4729:13, 4729:14,
4729:16, 4729:18, 4729:21, 4729:23,
4730:1, 4730:3, 4730:4, 4730:9,

4730:14, 4730:17, 4730:22, 4731:5,
4731:9, 4731:12, 4731:14, 4731:17,
4731:19, 4731:20, 4731:24, 4732:5,
4732:7, 4732:8, 4732:10, 4732:14,
4732:17, 4732:22, 4732:24, 4733:1,
4733:2, 4733:10, 4733:11, 4733:12,
4733:14, 4733:16, 4733:18, 4733:19,
4733:23, 4733:24, 4734:1, 4734:5,
4734:6, 4734:7, 4734:9, 4734:13,
4734:20, 4734:25, 4735:1, 4735:2,
4735:5, 4735:8, 4735:18, 4735:20,
4736:5, 4736:6, 4736:11, 4736:16,
4736:21, 4737:1, 4737:2, 4737:5,
4737:8, 4737:9, 4737:10, 4737:13,
4737:14, 4737:16, 4737:17, 4737:18,
4738:16, 4739:8, 4739:12, 4739:13,
4739:14, 4739:16, 4739:21, 4739:25,
4740:1, 4740:12, 4740:18, 4740:20,
4740:22, 4740:24, 4740:25, 4741:13,
4741:16, 4741:17, 4741:21, 4742:1,
4742:6, 4742:14, 4742:17, 4742:22,
4742:24, 4743:3, 4743:6, 4743:9,
4743:12, 4743:17, 4743:19, 4743:21,
4743:23, 4744:12, 4744:13, 4744:18,
4744:24, 4745:19, 4747:13, 4747:17,
4747:20, 4752:12, 4752:19, 4752:22,
4755:4, 4755:24, 4755:25, 4756:2,
4756:9, 4756:11, 4756:17, 4757:1,
4757:10, 4757:13, 4757:14, 4757:23,
4763:8, 4764:15, 4764:17, 4764:21,
4764:23, 4765:19, 4765:24, 4769:21,
4777:22, 4777:25, 4778:8, 4778:9,
4779:21, 4779:23, 4779:25, 4780:20,
4780:24, 4783:6, 4784:5, 4789:20,
4793:17, 4793:22, 4794:1, 4797:25,
4798:1, 4798:2, 4799:6, 4800:12,
4801:4, 4801:9, 4803:19, 4807:13,
4807:25, 4808:1, 4808:20, 4808:22,
4809:15, 4810:12, 4810:23, 4811:6,
4811:13, 4811:20, 4812:1, 4812:7,
4812:10, 4812:20, 4813:9, 4814:4,
4814:14, 4815:2, 4815:6, 4815:16,
4815:24, 4816:7, 4816:16, 4816:21,
4817:4, 4817:19, 4817:24, 4818:8,
4818:14, 4818:18, 4819:2, 4819:14,
4819:18, 4819:20, 4820:11, 4820:25,
4821:13, 4821:15, 4822:18, 4824:10,
4824:13, 4824:17, 4824:23, 4824:25,
4825:2, 4825:5, 4825:21, 4826:5,
4826:8, 4826:11, 4826:13, 4827:8,
4827:10, 4827:14, 4827:25, 4828:4,
4828:10, 4828:16, 4828:19, 4828:25,
4829:4, 4829:25, 4830:8, 4830:9,
4830:10, 4830:13, 4830:19, 4831:4,
4831:11, 4831:14, 4831:17, 4832:10,
4833:2, 4833:4, 4833:12, 4837:9,
4837:17, 4837:21, 4837:24, 4839:2,
4839:22, 4840:4, 4840:12, 4841:17,
4844:11, 4844:12, 4844:15, 4845:4,
4846:2, 4846:7, 4846:8, 4846:9,
4846:21, 4847:4, 4847:10, 4847:14,

4848:1, 4848:6, 4852:8, 4852:10,
4853:11, 4858:2, 4858:5, 4858:20,
4863:7, 4864:18
DEFREITAS [2] - 4633:6, 4636:18
Defreitas' [38] - 4639:6, 4652:9,
4659:18, 4662:13, 4664:3, 4671:1,
4686:3, 4691:10, 4694:12, 4700:3,
4709:24, 4715:19, 4717:16, 4720:3,
4724:24, 4725:7, 4727:25, 4734:23,
4735:3, 4736:10, 4736:11, 4736:15,
4736:24, 4737:21, 4742:20, 4742:21,
4743:11, 4744:16, 4756:20, 4757:6,
4807:14, 4807:23, 4809:6, 4812:11,
4819:23, 4828:7, 4833:1, 4833:9
DeFreitas'own [1] - 4730:6
delay [3] - 4634:21, 4635:25, 4708:13
delays [1] - 4635:22
deleting [1] - 4672:25
deliberate [3] - 4704:24, 4802:2,
4859:20
deliberating [2] - 4741:12, 4859:10
deliberations [2] - 4645:6, 4714:19
delivered [2] - 4651:1, 4751:19
delta [1] - 4718:12
demeanor [1] - 4749:11
demonstrate [1] - 4725:22
demonstrated [1] - 4808:22
demonstrates [2] - 4678:20, 4830:20
demonstrating [2] - 4726:6, 4864:5
deny [2] - 4660:20, 4660:24
department [2] - 4817:3, 4822:15
deposit [1] - 4743:12
deprived [1] - 4653:21
deputy [1] - 4637:1
describe [2] - 4688:11, 4808:18
described [2] - 4663:11, 4854:4
describing [2] - 4661:25, 4845:20
description [5] - 4727:5, 4772:2,
4839:4, 4849:5, 4853:21
designation [1] - 4689:21
desire [3] - 4648:3, 4697:23, 4821:13
desperate [3] - 4649:17, 4743:14,
4752:17
desperately [1] - 4745:5
despite [12] - 4659:17, 4676:18,
4689:13, 4729:22, 4763:8, 4778:25,
4779:2, 4796:12, 4796:13, 4836:11,
4852:12, 4863:16
destroy [11] - 4646:10, 4646:21,
4647:25, 4653:23, 4661:4, 4687:13,
4693:24, 4698:18, 4700:7, 4700:13,
4703:25
destroying [1] - 4650:4
destruction [7] - 4650:24, 4661:11,
4696:11, 4696:17, 4696:21, 4719:8,
4740:17
destructive [4] - 4699:8, 4699:9,
4701:5, 4702:10
detail [2] - 4710:1, 4834:17

11

detailed [2] - 4736:13, 4801:23
details [7] - 4646:12, 4711:19,
4785:20, 4793:11, 4831:22, 4834:13
detected [1] - 4816:11
Detective [20] - 4635:4, 4659:18,
4660:5, 4660:12, 4662:14, 4664:1,
4666:16, 4674:7, 4674:8, 4686:4,
4697:19, 4713:19, 4719:10, 4752:15,
4776:8, 4817:2, 4828:3, 4831:6,
4832:2, 4841:18
detective [10] - 4766:25, 4767:13,
4808:2, 4811:18, 4816:24, 4826:10,
4828:6, 4829:10, 4831:19, 4854:21
determination [5] - 4650:17, 4651:20,
4668:24, 4690:18, 4822:25
determine [3] - 4669:7, 4670:8,
4686:12
determined [13] - 4649:17, 4650:2,
4650:4, 4651:17, 4652:14, 4653:23,
4668:1, 4671:15, 4686:5, 4686:15,
4689:14, 4808:21, 4810:1
determines [1] - 4748:21
detonate [2] - 4696:1, 4696:9
devastating [8] - 4651:21, 4670:11,
4672:14, 4682:7, 4682:9, 4690:17,
4697:15, 4704:2
devastatingly [1] - 4666:11
devastation [5] - 4649:21, 4690:25,
4698:5, 4796:22, 4796:23
develop [1] - 4858:10
developed [1] - 4654:13
development [1] - 4855:4
device [1] - 4736:1
devices [2] - 4715:16, 4863:2
devil [3] - 4692:12, 4840:4, 4840:8
devilish [2] - 4693:4, 4693:24
devils [2] - 4693:3, 4693:11
devise [5] - 4699:8, 4699:9, 4701:5,
4701:13, 4702:10
devising [2] - 4648:22, 4650:10
devoted [2] - 4653:12, 4791:18
devouring [1] - 4653:21
diabolical [1] - 4814:22
diagonally [2] - 4643:4, 4643:10
die [6] - 4664:20, 4665:2, 4694:6,
4755:11, 4755:21
differ [1] - 4723:2
difference [3] - 4693:19, 4852:23
different [14] - 4652:24, 4659:20,
4660:18, 4702:3, 4702:6, 4716:14,
4722:21, 4769:11, 4783:15, 4786:17,
4839:20, 4843:21, 4857:7, 4865:4
differently [3] - 4653:8, 4654:23,
4799:15
difficult [5] - 4653:24, 4723:11,
4776:16, 4824:6
difficulty [2] - 4824:23, 4828:8
digging [1] - 4718:5
diplomatic [3] - 4677:24, 4679:14,
4684:15
direct [13] - 4675:22, 4676:13,

4676:24, 4677:12, 4691:9, 4693:9,
4693:10, 4716:18, 4716:24, 4752:21,
4825:14, 4843:24, 4864:18
directed [8] - 4732:17, 4751:23,
4752:11, 4753:2, 4764:15, 4764:16,
4825:2
directing [5] - 4665:25, 4716:21,
4732:11, 4752:13, 4840:24
direction [7] - 4689:3, 4689:5,
4689:18, 4746:15, 4813:14, 4844:13,
4849:12
directions [2] - 4721:24, 4826:10
directly [5] - 4655:4, 4675:25, 4677:1,
4729:24, 4730:2
dirt [1] - 4812:20
dirty [1] - 4808:8
disable [2] - 4701:8, 4702:11
disagree [5] - 4654:1, 4675:3, 4793:2,
4798:18, 4862:25
disagreed [1] - 4798:17
disagrees [2] - 4653:10, 4798:20
disappears [1] - 4738:14
disassociate [3] - 4792:21, 4792:23,
4793:4
disaster [1] - 4705:22
discouragement [1] - 4695:1
discover [1] - 4853:15
discovered [2] - 4638:2, 4685:3
discuss [7] - 4637:6, 4637:10,
4637:18, 4689:5, 4705:1, 4743:4,
4824:20
discussed [8] - 4637:13, 4637:25,
4661:14, 4685:18, 4691:17, 4711:25,
4731:12, 4841:17
discusses [2] - 4680:7, 4711:18
discussing [3] - 4686:13, 4688:17,
4764:6
discussion [14] - 4663:22, 4666:5,
4680:19, 4712:6, 4735:10, 4739:19,
4742:18, 4774:2, 4817:8, 4824:23,
4828:15, 4844:8, 4845:21, 4846:10
discussions [6] - 4697:2, 4712:2,
4713:15, 4735:15, 4844:2, 4844:17
disease [1] - 4720:23
disguise [1] - 4651:14
disinformation [1] - 4695:1
dislike [1] - 4792:19
display [1] - 4688:13
dispute [11] - 4647:7, 4659:11, 4681:1,
4696:4, 4696:8, 4698:15, 4698:24,
4699:1, 4701:2, 4747:10, 4747:11
disputed [1] - 4659:12
disputes [1] - 4702:4
disregard [1] - 4795:18
disruption [1] - 4696:3
dissuade [1] - 4693:4
distance [3] - 4676:2, 4692:16,
4692:20
distinctions [1] - 4834:7
12
distinguished [2] - 4784:25, 4785:3

distract [1] - 4694:4
distributed [1] - 4750:5
distributing [1] - 4651:4
DISTRICT [2] - 4633:1, 4633:1
District [1] - 4633:11
dived [1] - 4812:13
divert [1] - 4813:17
DLI [1] - 4633:3
doable [1] - 4821:11
docket [1] - 4639:11
Docket [1] - 4634:24
doctor [1] - 4637:2
Document [1] - 4784:24
document [6] - 4639:10, 4654:5,
4728:6, 4753:24, 4849:8, 4851:20
documentary [1] - 4832:9
documents [25] - 4639:7, 4639:9,
4639:17, 4639:21, 4647:13, 4676:8,
4726:4, 4727:17, 4727:19, 4727:23,
4728:2, 4731:3, 4752:16, 4754:15,
4761:2, 4783:10, 4787:2, 4787:3,
4807:10, 4850:24, 4851:7, 4853:24,
4855:6, 4856:11, 4858:17
dollars [4] - 4829:21, 4830:3, 4845:15,
4851:3
Donald [39] - 4648:23, 4657:23,
4661:8, 4661:17, 4661:22, 4662:9,
4663:2, 4663:8, 4664:18, 4699:11,
4710:6, 4710:8, 4711:15, 4711:21,
4712:2, 4712:7, 4727:2, 4727:20,
4728:21, 4744:21, 4744:22, 4745:3,
4745:6, 4745:17, 4745:20, 4746:10,
4746:22, 4746:25, 4747:2, 4747:10,
4747:20, 4748:5, 4756:17, 4763:17,
4789:21, 4789:22, 4832:13
done [15] - 4640:23, 4645:10, 4662:22,
4671:11, 4692:24, 4701:14, 4703:11,
4703:16, 4703:17, 4785:15, 4801:11,
4812:17, 4813:2, 4815:13, 4861:8
door [3] - 4673:23, 4775:20, 4863:13
doors [1] - 4775:17
DORA [1] - 4633:10
dotted [1] - 4797:1
double [2] - 4640:7, 4801:20
doubt [16] - 4647:24, 4658:10, 4661:1,
4692:1, 4696:23, 4709:23, 4734:21,
4734:23, 4748:7, 4748:9, 4752:9,
4757:6, 4806:20, 4830:21, 4837:7,
4844:20
doubtless [1] - 4697:10
down [25] - 4642:8, 4644:12, 4665:9,
4700:15, 4714:2, 4724:7, 4725:15,
4725:22, 4731:22, 4753:7, 4768:13,
4768:15, 4768:21, 4771:12, 4771:13,
4786:6, 4794:10, 4800:2, 4800:11,
4807:13, 4807:14, 4808:8, 4821:4,
4821:7, 4825:16
download [2] - 4703:8, 4768:5
downloading [2] - 4693:18, 4767:23


downplay [1] - 4752:2
Dr [10] - 4664:8, 4667:17, 4786:14,
4812:25, 4818:13, 4819:5, 4819:6,
4819:10, 4849:9
draft [3] - 4640:7, 4855:4, 4861:21
draw [6] - 4645:13, 4645:20, 4665:23,
4704:19, 4758:6, 4804:6
drawing [1] - 4859:8
dream [2] - 4854:18, 4854:23
dress [2] - 4742:9, 4820:12
dressed [4] - 4788:10, 4788:11,
4788:14
dressing [2] - 4757:12, 4808:10
drew [1] - 4750:7
drive [6] - 4699:18, 4703:4, 4711:12,
4716:23, 4718:13, 4723:22
driven [1] - 4716:12
driver [7] - 4730:7, 4730:17, 4730:18,
4730:19, 4730:20, 4757:2
drives [5] - 4716:4, 4716:7, 4717:5,
4718:20, 4720:21
driving [10] - 4669:25, 4670:13,
4671:3, 4703:2, 4721:24, 4723:23,
4724:24, 4734:8, 4756:24, 4825:8
dropping [1] - 4853:3
drops [1] - 4853:12
drove [6] - 4649:7, 4669:8, 4669:17,
4670:20, 4670:24, 4807:16
drown [1] - 4704:3
drug [5] - 4749:2, 4750:2, 4750:6,
4750:20, 4756:6
drugs [9] - 4750:10, 4750:18, 4751:12,
4751:13, 4751:17, 4751:18, 4751:19,
4751:22, 4752:2
due [1] - 4636:1
dumb [1] - 4696:25
dummy [1] - 4779:25
duration [1] - 4643:7
during [18] - 4644:24, 4645:5, 4656:5,
4686:3, 4693:10, 4704:8, 4705:3,
4758:8, 4770:1, 4794:19, 4795:2,
4804:13, 4830:8, 4832:10, 4832:16,
4833:2, 4841:20, 4842:22
duties [1] - 4778:2
duty [3] - 4762:19, 4837:4, 4860:5
dwarf [1] - 4650:22
dying [3] - 4664:23, 4664:24, 4664:25
dynamite [5] - 4666:22, 4666:24,
4824:20, 4833:18
E
e-mailed [1] - 4861:10
e-mails [1] - 4714:8
eager [1] - 4648:1
early [6] - 4678:15, 4697:2, 4741:19,
4753:12, 4859:4, 4861:4
earning [1] - 4750:17
earth [19] - 4653:21, 4732:8, 4767:24,
4768:2, 4768:3, 4768:5, 4769:3,

4769:10, 4769:14, 4782:23, 4782:24,
4783:2, 4783:8, 4783:10, 4783:12,
4783:13, 4783:18, 4783:19, 4835:23
Earth [14] - 4658:15, 4674:24, 4682:1,
4688:12, 4693:18, 4703:8, 4732:3,
4768:23, 4769:7, 4800:6, 4801:22,
4842:20, 4846:5, 4849:24
easier [2] - 4826:2, 4832:17
easily [1] - 4757:7
East [4] - 4633:16, 4634:9, 4686:22,
4686:24
EASTERN [1] - 4633:1
easy [2] - 4651:5, 4782:3
eat [2] - 4807:1, 4848:5
eating [1] - 4786:21
ECF [1] - 4639:16
economic [8] - 4661:10, 4696:3,
4696:12, 4696:18, 4697:16, 4698:6,
4745:8, 4756:14
economy [9] - 4646:10, 4661:4,
4687:13, 4693:25, 4697:21, 4697:23,
4697:25, 4703:25, 4858:4
ecstatic [2] - 4727:2, 4727:7
edict [1] - 4653:25
edited [1] - 4727:6
educated [1] - 4791:13
effect [1] - 4795:25
effort [1] - 4709:17
efforts [2] - 4686:12, 4819:3
egg [1] - 4655:15
eight [2] - 4636:24, 4795:10
either [15] - 4645:18, 4696:1, 4696:20,
4700:21, 4701:22, 4709:8, 4713:17,
4744:16, 4744:22, 4747:6, 4758:15,
4798:22, 4835:16, 4839:10, 4862:21
ejector [1] - 4856:1
electricity [1] - 4823:12
electronic [1] - 4703:6
electronically [2] - 4641:17, 4861:9
element [10] - 4656:12, 4695:15,
4695:20, 4698:8, 4698:16, 4700:21,
4701:2, 4701:21, 4702:4, 4836:24
elements [9] - 4646:22, 4647:1,
4695:22, 4773:7, 4814:11, 4864:25,
4865:2, 4865:6, 4865:9
eleven [2] - 4781:19, 4781:21
Elmo [3] - 4705:23, 4707:25, 4724:2
Embassies [1] - 4786:12
embassy [2] - 4819:10, 4851:25
employee [1] - 4822:10
employer [1] - 4765:21
employers [1] - 4822:6
employs [1] - 4696:13
empty [5] - 4651:23, 4660:7, 4663:20,
4663:22, 4673:12
enabled [1] - 4824:20
enabling [1] - 4860:2
encouragement [1] - 4694:9
end [10] - 4660:19, 4677:21, 4710:9,
13
4715:2, 4732:6, 4742:21, 4742:25,

4828:22, 4839:12, 4859:25
End [1] - 4774:2
endanger [1] - 4699:10
endangered [1] - 4700:9
endangering [1] - 4700:14
endeavor [1] - 4830:14
ended [2] - 4725:16, 4747:12
endlessly [1] - 4674:5
enemies [1] - 4849:14
enemy [2] - 4653:21, 4848:14
enforcement [13] - 4660:13, 4682:20,
4685:12, 4780:22, 4811:22, 4813:8,
4825:1, 4825:8, 4828:23, 4857:19,
4857:25, 4858:9
engage [6] - 4641:4, 4654:8, 4660:3,
4808:19, 4823:4, 4848:24
engaged [11] - 4673:12, 4695:18,
4701:24, 4812:21, 4812:23, 4818:23,
4820:15, 4820:20, 4829:2, 4858:15
engaging [3] - 4806:12, 4815:6,
4820:8
engine [1] - 4793:13
engineer [6] - 4694:22, 4770:10,
4783:5, 4801:15, 4801:19, 4841:22
engineering [10] - 4658:17, 4694:15,
4801:16, 4801:20, 4836:7, 4841:10,
4841:15, 4842:3, 4842:9, 4849:24
England [1] - 4791:14
English [1] - 4749:18
enjoy [1] - 4758:19
enjoyed [1] - 4644:3
enjoying [1] - 4716:12
enter [5] - 4636:12, 4636:14, 4760:13,
4805:11, 4824:1
entered [1] - 4836:25
entering [2] - 4643:21, 4708:4
enterprise [2] - 4688:7, 4690:23
enters [5] - 4642:23, 4643:22, 4708:5,
4761:14, 4805:19
entertained [1] - 4791:20
entertainment [1] - 4810:5
entire [4] - 4653:11, 4690:23, 4741:11,
4785:8
entrapment [18] - 4638:6, 4640:13,
4640:17, 4862:11, 4862:22, 4863:10,
4863:11, 4863:13, 4863:17, 4863:21,
4864:2, 4864:11, 4865:11, 4865:16,
4865:23, 4866:2
entrepreneurial [1] - 4648:14
entries [2] - 4838:1, 4852:6
envoy [2] - 4668:13, 4680:8
epiphany [1] - 4810:8
equation [1] - 4798:15
equipment [2] - 4816:25, 4825:6
erase [1] - 4690:20
errands [4] - 4711:14, 4716:9,
4716:12, 4724:25
errors [1] - 4640:8
escape [4] - 4647:18, 4695:3, 4695:5,


4816:12
especially [6] - 4684:3, 4734:3,
4741:2, 4746:23, 4757:8, 4769:9
ESQUIRE [1] - 4633:15
essentially [1] - 4732:8
establish [1] - 4658:23
established [2] - 4806:19, 4832:8
estate [1] - 4676:6
Europe [2] - 4667:21, 4833:14
evening [2] - 4638:20, 4861:23
event [4] - 4679:20, 4850:12, 4850:13,
4850:19
events [4] - 4676:9, 4755:15, 4755:19,
4834:10
eventually [8] - 4659:23, 4665:4,
4668:23, 4672:22, 4688:8, 4711:22,
4725:6, 4737:5
Evergreen [2] - 4719:2, 4815:25
Eversley [3] - 4753:4, 4753:5, 4753:11
everywhere [1] - 4734:8
evidence [192] - 4638:11, 4639:23,
4639:25, 4640:11, 4645:13, 4645:14,
4645:16, 4645:19, 4646:5, 4647:10,
4647:12, 4647:14, 4647:22, 4648:7,
4649:8, 4650:18, 4651:18, 4652:16,
4655:18, 4656:9, 4656:10, 4657:19,
4658:10, 4659:6, 4659:10, 4659:21,
4659:23, 4661:1, 4675:9, 4677:6,
4677:7, 4677:8, 4677:12, 4680:6,
4689:19, 4690:16, 4691:22, 4691:24,
4691:25, 4692:19, 4692:25, 4694:3,
4695:6, 4695:8, 4695:12, 4695:19,
4696:22, 4698:5, 4699:3, 4702:2,
4703:1, 4703:19, 4709:1, 4709:4,
4709:7, 4709:9, 4709:11, 4709:12,
4709:15, 4709:18, 4711:10, 4715:19,
4717:22, 4718:18, 4718:21, 4720:8,
4720:18, 4723:2, 4723:6, 4723:10,
4724:15, 4725:3, 4725:4, 4725:8,
4725:11, 4725:21, 4728:21, 4729:11,
4729:17, 4729:19, 4729:22, 4731:5,
4732:22, 4732:24, 4732:25, 4733:2,
4733:16, 4733:21, 4733:25, 4734:1,
4734:8, 4734:11, 4734:14, 4736:9,
4736:14, 4736:15, 4736:23, 4737:20,
4744:15, 4744:17, 4744:20, 4746:12,
4746:15, 4748:20, 4751:3, 4751:9,
4752:20, 4754:23, 4756:10, 4756:19,
4756:22, 4757:5, 4757:10, 4757:11,
4757:13, 4757:22, 4765:14, 4767:7,
4767:9, 4768:10, 4769:15, 4769:23,
4773:8, 4775:6, 4776:7, 4779:13,
4780:11, 4782:12, 4786:9, 4788:17,
4791:1, 4795:17, 4795:19, 4795:25,
4796:1, 4797:14, 4799:1, 4799:4,
4799:5, 4800:5, 4801:2, 4802:3,
4802:5, 4802:6, 4802:9, 4804:7,
4806:18, 4807:2, 4807:7, 4807:8,
4807:22, 4808:25, 4809:2, 4809:3,
4809:4, 4809:7, 4809:19, 4815:17,
4822:2, 4827:13, 4830:20, 4831:2,

4832:9, 4832:14, 4832:22, 4832:25,
4834:1, 4834:3, 4835:9, 4837:6,
4840:5, 4845:22, 4845:24, 4848:8,
4850:10, 4854:10, 4857:20, 4858:10,
4858:12, 4858:13, 4858:17, 4858:19,
4859:11, 4862:4, 4862:17, 4864:17,
4864:18, 4865:8
ex [1] - 4641:25
ex-parte [1] - 4641:25
exact [3] - 4649:17, 4667:1, 4668:1
exactly [12] - 4646:6, 4651:12,
4651:14, 4658:11, 4673:11, 4738:22,
4756:8, 4756:9, 4771:1, 4803:6,
4807:6, 4819:15
exaggerated [1] - 4691:4
exaggeration [1] - 4815:8
examination [18] - 4675:22, 4676:3,
4676:21, 4691:9, 4692:3, 4692:22,
4693:2, 4693:10, 4693:23, 4716:7,
4750:25, 4752:24, 4755:17, 4816:19,
4825:14, 4832:11, 4841:14, 4843:24
examine [1] - 4752:4
examined [1] - 4674:4
example [9] - 4650:25, 4677:5, 4680:7,
4694:3, 4694:8, 4840:21, 4843:3,
4857:25
examples [4] - 4649:2, 4649:5,
4743:25, 4826:16
excellent [1] - 4691:19
except [2] - 4719:20, 4776:2
excited [2] - 4689:2, 4699:21
excitement [1] - 4692:10
exclusive [1] - 4645:23
excuse [8] - 4690:21, 4779:8, 4781:20,
4794:21, 4800:10, 4803:2, 4842:6,
4845:11
excuses [3] - 4662:16, 4807:3,
4807:11
execute [1] - 4816:10
executing [1] - 4657:5
exercise [1] - 4704:10
exhibit [5] - 4780:10, 4829:17,
4861:15, 4862:1, 4862:2
Exhibit [44] - 4662:8, 4669:21,
4669:24, 4683:17, 4700:4, 4710:20,
4714:22, 4714:23, 4717:23, 4721:12,
4722:9, 4722:12, 4722:13, 4724:4,
4727:14, 4731:17, 4732:6, 4732:12,
4732:19, 4735:12, 4738:5, 4738:6,
4739:11, 4741:6, 4744:7, 4747:15,
4748:4, 4753:1, 4753:3, 4753:10,
4753:25, 4757:17, 4780:8, 4780:9,
4780:10, 4784:23, 4801:2, 4801:3,
4829:8, 4837:22, 4850:21, 4851:19,
4852:6
Exhibits [3] - 4754:24, 4754:25,
4850:24
exhibits [6] - 4669:20, 4722:20,
4722:22, 4723:1, 4735:10, 4809:5
14
existed [3] - 4662:1, 4718:14, 4720:5

existence [1] - 4647:9
exists [1] - 4653:22
exits [4] - 4758:20, 4804:18, 4816:14,
4838:1
exonerate [1] - 4691:24
expect [3] - 4650:14, 4673:11, 4705:9
expected [4] - 4639:2, 4642:15,
4644:23, 4646:15
expedition [1] - 4770:8
expensive [1] - 4857:24
experience [6] - 4648:17, 4667:14,
4682:8, 4762:15, 4815:10, 4821:9
experienced [1] - 4858:7
experiences [1] - 4833:4
experiencing [1] - 4762:16
expert [9] - 4667:4, 4672:11, 4684:25,
4694:23, 4712:19, 4746:19, 4815:17,
4818:13, 4818:22
expertise [3] - 4667:6, 4667:19,
4818:11
experts [2] - 4757:12, 4825:11
expires [1] - 4717:17
explain [10] - 4642:5, 4716:15,
4722:20, 4735:8, 4749:7, 4793:22,
4793:24, 4793:25, 4799:20, 4799:21
explained [1] - 4803:7
explains [1] - 4752:6
explanation [5] - 4728:12, 4745:14,
4752:8, 4794:2, 4839:4
explode [4] - 4650:19, 4651:7, 4666:7,
4695:9
exploding [2] - 4816:3, 4821:1
explosion [7] - 4646:14, 4666:9,
4666:10, 4666:18, 4690:25, 4697:11,
4699:3
explosions [1] - 4841:12
explosive [11] - 4666:20, 4667:14,
4667:18, 4668:24, 4672:11, 4694:25,
4696:1, 4698:19, 4701:13, 4818:11,
4825:11
explosives [7] - 4666:7, 4667:3,
4696:9, 4728:13, 4745:24, 4824:20,
4858:7
export [5] - 4712:1, 4731:14, 4731:19,
4756:13, 4765:15
export/import [1] - 4823:7
exporting [3] - 4648:14, 4765:23,
4823:5
exposure [1] - 4688:6
expressed [2] - 4660:12, 4674:6
expressing [2] - 4692:10, 4802:12
Expressway [1] - 4724:7
extensive [7] - 4654:13, 4682:8,
4696:11, 4696:17, 4696:21, 4697:11,
4698:5
extent [1] - 4639:20
extra [1] - 4675:20
extraordinary [1] - 4709:7
extrapolates [1] - 4822:18


extreme [1] - 4649:8
extremely [1] - 4685:10
extremist [2] - 4648:9, 4654:15
eye [1] - 4713:23
eyebrows [1] - 4685:12
eyed [1] - 4859:3
eyes [2] - 4650:15, 4656:5
F
face [14] - 4647:2, 4655:24, 4659:23,
4683:13, 4691:18, 4741:21, 4750:15,
4750:19, 4788:13, 4808:9, 4835:8
face-saving [1] - 4808:9
face-to-face [2] - 4655:24, 4691:18
faced [3] - 4647:16, 4651:18, 4807:7
faces [2] - 4748:16, 4834:23
facilities [2] - 4700:8, 4820:21
facility [5] - 4695:24, 4700:12, 4702:9,
4820:9, 4834:22
facing [2] - 4751:6, 4751:10
fact [33] - 4640:10, 4656:9, 4659:15,
4670:25, 4675:23, 4676:17, 4676:18,
4685:4, 4685:18, 4690:19, 4691:3,
4693:13, 4695:5, 4695:7, 4697:12,
4710:7, 4717:13, 4717:22, 4731:21,
4732:15, 4733:19, 4746:18, 4751:1,
4757:15, 4758:14, 4762:21, 4789:16,
4793:2, 4799:15, 4808:21, 4826:13,
4830:14, 4864:16
facts [4] - 4645:23, 4749:21, 4802:7,
4802:8
fail [1] - 4685:8
failed [3] - 4691:24, 4691:25, 4692:2
fair [2] - 4754:8, 4823:22
fairly [1] - 4772:15
faith [2] - 4665:2, 4673:9
fake [5] - 4827:3, 4827:6, 4855:11,
4855:15, 4856:7
fall [3] - 4665:6, 4668:22, 4728:15
fallen [1] - 4748:3
false [6] - 4656:4, 4660:1, 4718:23,
4718:25, 4821:24, 4827:11
falsehood [1] - 4654:6
family [9] - 4676:19, 4731:4, 4791:18,
4796:4, 4796:7, 4798:21, 4835:1
fantasies [2] - 4740:16, 4742:12
fantasy [5] - 4741:14, 4742:18,
4744:17, 4808:7, 4809:2
far [10] - 4650:13, 4658:21, 4666:11,
4741:14, 4811:15, 4820:9, 4835:8,
4840:3, 4844:14
Far [13] - 4686:23, 4732:21, 4776:2,
4813:15, 4813:16, 4844:14, 4844:19,
4844:21, 4845:7, 4846:20, 4846:22,
4847:1, 4847:6
farm [14] - 4669:13, 4669:14, 4669:15,
4669:16, 4669:18, 4675:23, 4676:8,
4680:3, 4697:6, 4697:8, 4699:17,
4699:19, 4700:5, 4815:21

Farm [11] - 4654:17, 4655:16, 4675:22,
4676:5, 4676:10, 4678:8, 4679:5,
4680:10, 4690:4, 4690:5, 4690:6
farmer [1] - 4847:5
farms [2] - 4669:12, 4718:7
fast [2] - 4805:7, 4805:8
faster [1] - 4739:6
father [1] - 4791:19
fatwa [2] - 4735:16, 4784:15
favorable [1] - 4749:8
favorite [1] - 4808:12
favorites [1] - 4841:9
favors [1] - 4747:5
faxed [1] - 4641:10
FBI [22] - 4659:21, 4669:23, 4703:3,
4733:15, 4745:20, 4746:21, 4754:8,
4756:5, 4756:8, 4827:19, 4827:22,
4828:17, 4828:18, 4828:20, 4829:4,
4829:11, 4829:13, 4829:15, 4829:16,
4829:20, 4830:23
FBI's [2] - 4667:19, 4829:24
fear [4] - 4692:13, 4840:2, 4840:8,
4840:13
feared [1] - 4863:12
February [4] - 4710:21, 4750:1,
4753:12, 4753:20
federal [2] - 4646:21, 4796:14
Federal [2] - 4633:23, 4635:7
feed [2] - 4719:7, 4740:17
feedback [1] - 4826:14
fellow [1] - 4784:25
felt [1] - 4673:20
fence [2] - 4671:5, 4718:13
festival [1] - 4824:2
fever [1] - 4637:2
few [17] - 4637:9, 4649:2, 4659:20,
4660:18, 4664:7, 4671:22, 4671:24,
4678:22, 4692:18, 4707:4, 4809:10,
4809:20, 4815:22, 4820:5, 4826:16,
4830:3, 4830:5
fewer [1] - 4815:22
fide [1] - 4687:5
fields [1] - 4718:11
fight [4] - 4654:11, 4728:20, 4747:20,
4849:14
fighting [2] - 4664:25, 4684:16
fights [1] - 4686:25
figure [11] - 4653:1, 4658:2, 4665:18,
4666:20, 4670:10, 4671:9, 4683:14,
4687:23, 4780:22, 4810:4, 4828:21
figuring [3] - 4686:21, 4687:15, 4821:6
file [3] - 4861:21, 4861:23
filed [1] - 4641:16
filing [3] - 4639:2, 4639:10, 4641:23
fill [1] - 4749:7
fills [1] - 4752:6
film [3] - 4824:2, 4824:7, 4824:8
filmed [1] - 4825:9
15
filming [2] - 4723:9, 4824:10

final [5] - 4645:6, 4689:21, 4772:15,
4861:6, 4861:21
finally [5] - 4698:7, 4739:8, 4741:2,
4755:23, 4810:16
finance [3] - 4690:1, 4770:5, 4770:6
finances [2] - 4715:8, 4715:12
financial [3] - 4663:13, 4682:6, 4683:8
financiers [1] - 4845:7
fine [5] - 4637:14, 4752:5, 4786:23,
4786:24, 4845:5
finger [1] - 4836:15
finish [6] - 4643:5, 4707:5, 4813:23,
4857:1, 4860:1, 4860:4
finished [2] - 4766:22, 4846:3
fire [2] - 4696:11, 4698:19
FIRM [1] - 4634:1
firmly [2] - 4687:20, 4688:2
first [68] - 4636:22, 4643:6, 4645:8,
4646:6, 4647:2, 4647:6, 4648:6,
4652:12, 4654:10, 4654:19, 4659:9,
4659:19, 4661:18, 4666:20, 4674:2,
4674:16, 4678:7, 4678:8, 4679:4,
4681:13, 4687:19, 4688:21, 4693:1,
4695:16, 4696:1, 4696:23, 4697:10,
4702:13, 4702:18, 4711:5, 4714:24,
4715:5, 4717:10, 4724:23, 4733:24,
4737:8, 4744:21, 4747:16, 4753:24,
4763:10, 4765:14, 4765:17, 4765:18,
4767:18, 4785:3, 4794:22, 4804:1,
4807:13, 4812:14, 4814:9, 4815:19,
4818:9, 4819:13, 4821:14, 4822:7,
4830:7, 4830:11, 4830:24, 4837:16,
4839:12, 4839:15, 4839:20, 4842:18,
4842:25, 4843:11, 4853:13, 4862:20
firsthand [1] - 4739:13
fit [6] - 4639:24, 4659:22, 4677:6,
4677:9, 4691:24, 4749:21
fits [1] - 4853:20
Five [1] - 4701:4
five [16] - 4676:13, 4695:16, 4705:10,
4706:4, 4720:23, 4721:13, 4751:13,
4755:15, 4770:11, 4789:1, 4789:3,
4796:22, 4804:16, 4804:20, 4820:6,
4855:11
five-page [1] - 4676:13
fix [1] - 4640:9
fixed [2] - 4772:2, 4780:12
flat [1] - 4807:23
flat-out [1] - 4807:23
flatly [1] - 4694:2
flaw [1] - 4808:12
flaws [2] - 4708:22, 4757:21
flee [2] - 4752:19, 4816:11
flew [4] - 4696:6, 4754:13, 4754:19,
4850:19
flight [12] - 4689:20, 4717:12, 4753:3,
4753:9, 4753:11, 4753:17, 4780:12,
4781:1, 4822:15, 4850:17, 4850:23,
4852:22


flights [2] - 4753:14, 4822:17
floor [1] - 4685:4
flour [1] - 4786:22
flown [1] - 4829:4
flu [1] - 4637:2
fluff [3] - 4778:23, 4808:11
fly [2] - 4719:18, 4852:21
flying [2] - 4817:10, 4852:2
focus [2] - 4646:23, 4671:22
focused [1] - 4857:19
follow [6] - 4653:12, 4659:4, 4789:9,
4811:7, 4811:13, 4812:10
follower [1] - 4826:20
following [5] - 4645:4, 4707:1,
4771:23, 4804:23, 4837:4
food [1] - 4786:22
fool [2] - 4724:21, 4724:22
foolish [2] - 4736:19, 4740:16
footage [3] - 4669:14, 4703:3, 4807:17
force [4] - 4684:10, 4746:2, 4746:3,
4746:4
forced [2] - 4676:4, 4676:21
forces [3] - 4713:13, 4848:18, 4848:20
foreign [3] - 4698:22, 4754:8, 4829:16
foreigner [1] - 4650:12
foreigners [1] - 4650:16
forged [1] - 4855:6
forget [4] - 4785:21, 4793:8, 4843:19,
4856:3
forgot [4] - 4707:6, 4779:20, 4781:16,
4802:18
form [9] - 4651:18, 4656:15, 4666:22,
4675:9, 4704:18, 4758:6, 4804:6,
4809:4
format [1] - 4861:11
former [1] - 4665:18
formulate [1] - 4657:23
forth [6] - 4705:23, 4761:1, 4797:8,
4801:12, 4828:9, 4829:4
forward [4] - 4644:9, 4842:23,
4847:12, 4856:25
founding [1] - 4668:15
Four [3] - 4700:6, 4700:20
four [12] - 4657:25, 4669:6, 4671:7,
4679:10, 4739:25, 4740:19, 4741:1,
4754:2, 4820:6, 4820:15, 4821:2,
4855:15
frame [1] - 4686:17
frames [1] - 4768:17
France [1] - 4664:4
FRANCIS [1] - 4780:14
Francis [365] - 4654:18, 4655:13,
4655:22, 4657:24, 4658:18, 4658:25,
4660:21, 4661:25, 4662:3, 4663:7,
4663:15, 4663:16, 4664:4, 4664:7,
4664:9, 4664:10, 4664:13, 4664:15,
4664:18, 4664:24, 4665:4, 4665:8,
4665:9, 4665:11, 4666:2, 4666:4,
4666:23, 4669:3, 4669:6, 4670:20,
4670:22, 4671:16, 4673:19, 4673:20,
4673:25, 4674:4, 4674:9, 4674:11,

4674:15, 4674:16, 4674:18, 4674:19,
4674:21, 4674:23, 4674:25, 4675:3,
4675:10, 4675:16, 4675:21, 4675:25,
4676:24, 4676:25, 4677:16, 4677:20,
4678:2, 4678:4, 4678:17, 4678:24,
4679:12, 4680:2, 4680:8, 4680:9,
4680:14, 4680:15, 4680:16, 4680:20,
4680:23, 4681:16, 4682:24, 4683:10,
4683:23, 4684:21, 4685:16, 4685:18,
4685:21, 4685:24, 4686:11, 4687:25,
4688:2, 4688:10, 4690:2, 4692:15,
4693:11, 4693:12, 4694:5, 4694:12,
4696:25, 4697:24, 4699:11, 4703:7,
4703:15, 4710:6, 4710:17, 4710:23,
4711:2, 4711:6, 4711:10, 4711:12,
4711:14, 4711:16, 4711:20, 4711:24,
4712:3, 4712:7, 4712:12, 4712:21,
4713:2, 4713:4, 4713:5, 4714:6,
4714:10, 4714:12, 4714:13, 4714:21,
4715:3, 4715:6, 4715:7, 4715:10,
4715:12, 4715:15, 4715:16, 4715:23,
4716:7, 4716:8, 4716:18, 4716:22,
4716:24, 4717:6, 4718:9, 4719:22,
4720:1, 4720:6, 4720:10, 4720:12,
4720:16, 4720:21, 4720:24, 4721:2,
4721:7, 4721:13, 4722:1, 4722:4,
4723:12, 4723:14, 4723:16, 4724:24,
4725:1, 4725:3, 4725:6, 4725:15,
4725:16, 4725:17, 4725:24, 4727:2,
4727:18, 4727:24, 4727:25, 4728:1,
4728:5, 4728:7, 4728:10, 4728:11,
4728:15, 4728:16, 4728:17, 4728:20,
4729:1, 4729:3, 4729:6, 4729:9,
4729:17, 4729:20, 4729:21, 4730:6,
4732:2, 4732:3, 4732:4, 4732:9,
4732:17, 4732:20, 4733:11, 4733:13,
4734:2, 4734:8, 4734:10, 4734:25,
4735:4, 4735:5, 4735:9, 4735:13,
4735:22, 4735:23, 4735:24, 4736:7,
4736:9, 4736:21, 4737:4, 4737:8,
4737:14, 4737:15, 4737:18, 4738:1,
4738:2, 4738:7, 4738:15, 4738:17,
4738:21, 4739:16, 4740:20, 4740:23,
4741:3, 4741:15, 4742:2, 4742:4,
4742:6, 4742:8, 4742:10, 4742:11,
4742:12, 4742:13, 4742:14, 4743:1,
4743:2, 4743:8, 4743:10, 4743:14,
4743:15, 4743:17, 4743:25, 4744:3,
4744:8, 4744:9, 4744:10, 4746:17,
4747:1, 4747:5, 4747:9, 4747:11,
4747:12, 4747:18, 4747:21, 4747:22,
4747:23, 4748:2, 4748:10, 4748:11,
4748:13, 4749:20, 4750:2, 4752:3,
4752:10, 4752:14, 4752:17, 4752:18,
4754:15, 4754:21, 4755:3, 4755:11,
4755:13, 4755:16, 4756:18, 4764:15,
4764:17, 4764:21, 4764:25, 4765:2,
4765:4, 4766:1, 4766:3, 4766:17,
4766:20, 4767:1, 4767:15, 4769:22,
4769:25, 4776:7, 4777:22, 4777:24,
16
4778:8, 4778:9, 4779:2, 4779:22,

4779:23, 4779:25, 4781:18, 4781:21,
4782:14, 4783:7, 4789:19, 4793:16,
4793:21, 4795:7, 4795:11, 4796:11,
4796:12, 4797:2, 4797:4, 4797:20,
4799:7, 4800:2, 4800:3, 4800:12,
4803:14, 4803:18, 4807:19, 4807:25,
4810:24, 4811:1, 4811:2, 4811:4,
4812:10, 4816:7, 4820:2, 4824:17,
4824:23, 4825:3, 4825:14, 4825:21,
4826:6, 4826:7, 4827:2, 4827:5,
4827:10, 4827:15, 4827:24, 4829:15,
4832:13, 4832:15, 4832:20, 4832:25,
4833:3, 4833:10, 4833:25, 4834:4,
4834:14, 4835:8, 4837:17, 4839:2,
4839:22, 4840:4, 4840:12, 4843:6,
4843:9, 4843:13, 4843:14, 4844:2,
4844:17, 4846:4, 4846:8, 4846:17,
4846:18, 4852:9, 4852:10, 4854:2,
4863:6, 4863:8, 4864:17
Francis' [7] - 4676:9, 4677:18, 4711:5,
4719:11, 4748:19, 4766:25, 4863:7
Francis'number [1] - 4738:15
Francis'offers [1] - 4734:6
Francis's [1] - 4743:11
Francis'testimony [1] - 4729:6
free [17] - 4639:24, 4715:21, 4715:22,
4716:2, 4733:9, 4733:16, 4733:23,
4733:25, 4734:2, 4734:6, 4736:17,
4756:23, 4757:1, 4828:17, 4849:10
freedom [1] - 4857:24
freely [2] - 4734:13, 4746:14
Friday [6] - 4638:1, 4639:18, 4640:5,
4640:6, 4640:7, 4864:6
friend [14] - 4730:4, 4746:20, 4770:17,
4792:24, 4792:25, 4793:1, 4801:25,
4811:20, 4821:15, 4828:10, 4841:3,
4844:10, 4848:16, 4854:20
friendly [1] - 4783:16
friends [11] - 4677:17, 4711:11,
4719:21, 4723:19, 4756:25, 4831:6,
4831:9, 4837:11, 4840:12, 4840:13,
4856:20
front [3] - 4643:11, 4643:14, 4679:5
fruition [2] - 4708:25, 4814:3
frustrated [3] - 4733:5, 4826:13,
4863:3
fuel [52] - 4646:13, 4647:3, 4650:19,
4650:22, 4657:7, 4661:2, 4666:8,
4666:21, 4669:8, 4669:12, 4669:13,
4669:14, 4669:15, 4669:16, 4669:18,
4670:7, 4670:8, 4671:9, 4671:23,
4680:3, 4694:13, 4694:15, 4694:16,
4695:10, 4695:13, 4696:9, 4696:11,
4697:6, 4697:8, 4697:20, 4699:2,
4699:17, 4699:19, 4700:5, 4701:9,
4702:15, 4717:25, 4718:6, 4718:11,
4815:23, 4816:1, 4816:2, 4816:3,
4817:22, 4820:4, 4825:25, 4836:7,
4841:11, 4842:2, 4842:3


full [11] - 4642:20, 4647:8, 4677:25,
4696:16, 4697:5, 4716:21, 4718:18,
4720:15, 4767:4, 4815:20, 4817:22
fun [1] - 4719:6
funds [3] - 4658:19, 4739:2, 4819:7
G
gained [1] - 4848:20
game [6] - 4690:22, 4762:13, 4762:14,
4797:15, 4808:11
games [2] - 4719:9, 4754:23
garbage [1] - 4771:3
gas [1] - 4700:17
gather [1] - 4857:20
gathering [1] - 4655:8
gears [1] - 4692:23
gel [1] - 4666:22
general [2] - 4685:23, 4816:15
generally [3] - 4695:18, 4816:14,
4822:23
generators [1] - 4700:16
gentleman [2] - 4681:3, 4681:4
gentlemen [53] - 4643:25, 4644:22,
4644:25, 4651:24, 4685:6, 4705:11,
4708:7, 4708:14, 4708:20, 4709:20,
4713:10, 4719:16, 4720:6, 4721:11,
4723:1, 4723:4, 4723:14, 4724:1,
4724:3, 4727:4, 4730:25, 4731:23,
4733:4, 4734:16, 4735:18, 4737:12,
4737:22, 4740:3, 4740:22, 4741:10,
4747:25, 4748:11, 4749:1, 4749:22,
4751:15, 4751:17, 4754:11, 4754:24,
4756:10, 4757:4, 4758:5, 4758:21,
4761:17, 4761:23, 4762:7, 4775:1,
4788:10, 4788:12, 4803:24, 4805:20,
4806:2, 4808:3, 4858:24
Georgetown [10] - 4677:17, 4735:2,
4737:14, 4737:16, 4737:18, 4754:1,
4754:5, 4788:22, 4798:1, 4837:18
girlfriends [1] - 4808:16
given [14] - 4683:22, 4685:13,
4703:25, 4705:24, 4751:2, 4755:18,
4811:2, 4830:20, 4854:10, 4862:1,
4864:13, 4864:22, 4864:24, 4865:24
globe [1] - 4654:14
goal [13] - 4652:17, 4661:4, 4661:5,
4663:9, 4683:7, 4690:23, 4697:18,
4697:19, 4702:20, 4748:18, 4749:1,
4814:15, 4849:22
goals [7] - 4648:4, 4663:11, 4683:1,
4683:2, 4683:5, 4848:10, 4857:19
God [4] - 4664:25, 4665:3, 4671:17,
4703:25
gonna [4] - 4699:24, 4700:17, 4739:5,
4865:18
gonna' [1] - 4799:19
goodies [5] - 4709:16, 4709:18,
4714:1, 4827:24, 4863:5
goods [2] - 4648:14, 4776:4

Google [34] - 4658:15, 4674:24,
4682:1, 4688:12, 4688:14, 4693:18,
4703:8, 4732:3, 4732:8, 4735:6,
4767:23, 4768:2, 4768:3, 4768:5,
4768:23, 4769:3, 4769:7, 4769:9,
4769:13, 4782:23, 4782:24, 4783:2,
4783:8, 4783:10, 4783:11, 4783:13,
4783:18, 4783:19, 4800:6, 4801:22,
4835:22, 4842:20, 4846:5, 4849:24
government [85] - 4635:3, 4637:20,
4637:21, 4638:2, 4638:5, 4638:7,
4640:17, 4640:18, 4641:11, 4642:18,
4645:7, 4645:25, 4655:9, 4656:20,
4684:10, 4704:9, 4708:23, 4709:2,
4709:5, 4709:15, 4710:5, 4710:17,
4711:5, 4713:16, 4713:18, 4713:20,
4713:21, 4714:1, 4714:9, 4715:18,
4716:3, 4718:17, 4718:19, 4723:5,
4723:7, 4724:13, 4724:16, 4725:17,
4728:2, 4728:16, 4728:17, 4733:4,
4733:8, 4734:22, 4735:11, 4736:23,
4737:23, 4744:23, 4745:3, 4748:14,
4748:15, 4748:24, 4749:8, 4749:9,
4749:12, 4752:16, 4754:13, 4754:17,
4756:1, 4756:6, 4757:1, 4757:14,
4762:17, 4776:15, 4776:16, 4788:22,
4788:25, 4790:11, 4790:12, 4798:17,
4804:4, 4842:8, 4849:19, 4855:5,
4857:15, 4862:14, 4862:18, 4863:2,
4863:3, 4863:4, 4864:13, 4864:14,
4864:23, 4865:13
Government [39] - 4633:15, 4710:20,
4714:22, 4714:23, 4721:12, 4722:9,
4732:19, 4744:11, 4762:25, 4771:10,
4772:17, 4777:7, 4777:11, 4778:12,
4780:8, 4780:9, 4780:10, 4783:10,
4784:23, 4786:6, 4786:8, 4786:9,
4786:10, 4786:25, 4805:14, 4806:4,
4814:20, 4821:19, 4827:17, 4832:22,
4835:10, 4837:22, 4850:20, 4850:24,
4851:19, 4852:5
Government's [24] - 4640:21, 4717:23,
4722:12, 4722:13, 4724:4, 4727:14,
4731:16, 4732:12, 4735:12, 4738:5,
4741:6, 4747:15, 4748:4, 4753:1,
4753:3, 4753:10, 4753:24, 4754:25,
4757:17, 4801:2, 4801:3, 4829:8,
4829:17
government's [9] - 4638:12, 4638:20,
4639:5, 4640:13, 4746:19, 4749:19,
4760:19, 4857:16, 4862:24
grabs [1] - 4855:11
gracing [1] - 4635:13
grain [2] - 4727:5, 4732:16
gram [1] - 4750:3
grams [1] - 4750:25
grand [2] - 4748:25, 4749:4
grandchildren [1] - 4798:20
grant [1] - 4807:15
17
grappling [1] - 4666:6

great [7] - 4656:1, 4663:21, 4673:21,
4693:13, 4834:21, 4835:2, 4844:23
greatest [1] - 4785:4
greet [1] - 4840:12
greeting [1] - 4692:9
grenades [1] - 4719:13
grievances [1] - 4653:9
grip [1] - 4674:17
ground [8] - 4657:6, 4660:23, 4683:6,
4717:13, 4731:15, 4766:12, 4793:15,
4810:9
group [8] - 4657:4, 4713:2, 4713:4,
4713:5, 4713:22, 4784:17, 4811:7,
4819:7
groupings [2] - 4639:9, 4639:20
groups [2] - 4819:21, 4821:23
grow [1] - 4813:18
grown [3] - 4662:18, 4808:14, 4855:14
gruesome [1] - 4691:2
guaranteed [1] - 4699:14
guard [2] - 4664:19, 4697:7
guards [2] - 4719:5, 4742:8
guess [4] - 4794:6, 4824:11, 4832:16,
4833:2
guest [2] - 4743:17, 4785:2
guests [1] - 4785:1
guide [1] - 4645:5
guided [1] - 4848:20
guilt [14] - 4656:11, 4658:7, 4658:23,
4659:6, 4659:7, 4663:5, 4677:7,
4677:13, 4692:25, 4745:21, 4806:19,
4807:7, 4832:7, 4832:19
guilty [40] - 4657:14, 4657:15,
4657:22, 4658:8, 4658:12, 4658:24,
4661:2, 4661:22, 4662:18, 4662:20,
4662:22, 4663:1, 4691:25, 4695:6,
4695:25, 4699:5, 4703:15, 4704:4,
4734:20, 4745:25, 4746:4, 4757:23,
4771:14, 4803:21, 4814:12, 4814:16,
4814:22, 4814:25, 4821:22, 4832:1,
4834:21, 4835:5, 4837:5, 4837:12,
4857:12, 4858:20, 4858:21
gun [6] - 4855:16, 4855:24, 4856:3,
4856:5
gunpoint [1] - 4684:9
guns [9] - 4667:8, 4794:23, 4855:10,
4855:12, 4855:13, 4855:15, 4855:18,
4855:21, 4856:7
guppy [1] - 4757:14
guy [25] - 4656:2, 4686:20, 4687:3,
4717:1, 4717:3, 4728:13, 4728:14,
4740:10, 4741:1, 4742:1, 4742:25,
4745:22, 4746:19, 4746:21, 4751:20,
4756:7, 4756:24, 4764:7, 4764:8,
4766:17, 4818:12, 4839:7, 4842:18,
4843:7, 4843:16
Guyana [69] - 4648:15, 4652:25,
4653:2, 4663:8, 4664:12, 4665:9,
4665:17, 4665:22, 4668:4, 4676:14,


4676:19, 4680:20, 4684:8, 4692:11,
4710:21, 4711:16, 4711:20, 4712:10,
4714:2, 4714:4, 4714:22, 4715:13,
4719:25, 4720:15, 4725:7, 4725:11,
4725:23, 4725:25, 4726:6, 4726:8,
4731:12, 4733:24, 4735:1, 4747:6,
4752:18, 4754:1, 4765:16, 4770:10,
4779:17, 4781:1, 4783:12, 4783:15,
4783:17, 4784:18, 4786:12, 4788:20,
4789:4, 4789:21, 4789:25, 4791:7,
4791:19, 4801:4, 4801:6, 4801:7,
4809:17, 4823:5, 4823:6, 4823:7,
4823:11, 4825:16, 4828:5, 4828:9,
4829:10, 4833:14, 4846:18, 4847:23,
4849:6, 4849:7, 4850:19
Guyana's [1] - 4765:23
Guyanese [6] - 4688:1, 4698:14,
4712:1, 4728:1, 4776:15, 4851:3
guys [11] - 4693:3, 4693:13, 4713:11,
4713:13, 4713:18, 4713:20, 4715:16,
4728:18, 4737:24, 4840:2, 4863:2
H
hair [2] - 4742:9, 4750:3
half [11] - 4646:15, 4693:1, 4693:22,
4702:13, 4702:18, 4705:21, 4706:1,
4750:3, 4788:21, 4802:16, 4837:18
half-way [2] - 4693:1, 4693:22
halfway [4] - 4850:16, 4851:10,
4852:2, 4852:22
hammer [1] - 4678:22
hand [5] - 4651:16, 4751:14, 4856:2,
4865:20
hand-in-hand [1] - 4865:20
handed [4] - 4647:17, 4655:19,
4806:11, 4806:23
handing [2] - 4714:1, 4863:6
handle [1] - 4801:7
handler [2] - 4766:20, 4767:1
handles [1] - 4822:16
hands [9] - 4666:8, 4667:2, 4703:24,
4717:24, 4787:1, 4806:24, 4806:25,
4848:13, 4849:2
hang [1] - 4846:6
hangars [6] - 4697:9, 4699:13,
4701:10, 4716:24, 4825:23, 4825:24
hanging [1] - 4719:22
happily [1] - 4692:9
happy [9] - 4671:18, 4672:14, 4672:21,
4689:7, 4746:20, 4765:19, 4824:19,
4866:4
hard [9] - 4664:2, 4694:19, 4720:8,
4727:8, 4752:7, 4825:1, 4825:7,
4861:19
harm [3] - 4651:21, 4762:11, 4799:11
Hasan [1] - 4849:8
hatched [1] - 4864:19
Hatchers [1] - 4676:5
hatchery [2] - 4676:9, 4676:17

hate [2] - 4694:18, 4792:11
hated [1] - 4704:1
hating [1] - 4799:11
hats [1] - 4742:9
head [5] - 4668:12, 4722:10, 4788:12,
4788:13, 4812:13
headed [2] - 4847:12, 4852:2
heading [3] - 4852:10, 4853:4, 4854:5
headlock [2] - 4674:3, 4729:8
headquarters [2] - 4668:11, 4684:8
heads [1] - 4653:2
hear [42] - 4645:2, 4652:14, 4652:19,
4693:9, 4694:19, 4704:6, 4709:25,
4712:14, 4713:15, 4714:24, 4722:6,
4730:10, 4732:7, 4732:14, 4738:12,
4741:11, 4742:16, 4743:5, 4744:3,
4745:4, 4747:19, 4752:12, 4755:13,
4760:9, 4764:5, 4771:8, 4775:11,
4775:12, 4775:14, 4790:9, 4804:9,
4806:3, 4810:11, 4814:11, 4814:18,
4814:19, 4816:23, 4844:6, 4847:10,
4859:22, 4864:8
heard [81] - 4638:19, 4649:16,
4649:19, 4651:2, 4656:14, 4657:18,
4659:8, 4659:9, 4659:11, 4659:17,
4660:16, 4665:7, 4670:19, 4672:22,
4673:2, 4675:15, 4679:15, 4686:2,
4686:3, 4690:21, 4696:5, 4696:13,
4697:17, 4698:4, 4704:20, 4704:21,
4716:6, 4717:10, 4717:21, 4727:1,
4731:4, 4744:21, 4745:2, 4752:14,
4760:3, 4762:24, 4762:25, 4763:23,
4763:24, 4767:18, 4770:19, 4771:23,
4784:13, 4790:20, 4791:16, 4791:24,
4804:7, 4806:16, 4806:17, 4812:9,
4812:24, 4814:4, 4816:7, 4816:13,
4817:2, 4817:25, 4818:22, 4819:5,
4819:6, 4819:9, 4820:3, 4822:24,
4822:25, 4823:7, 4823:11, 4823:15,
4824:12, 4824:18, 4826:12, 4831:18,
4831:22, 4832:15, 4835:1, 4837:21,
4837:22, 4843:20, 4849:9, 4855:10,
4859:9
hearing [1] - 4678:15
heart [1] - 4719:2
heartedly [1] - 4689:1
heat [3] - 4652:2, 4652:6, 4652:10
heavy [3] - 4655:15, 4684:20, 4686:25
heeded [1] - 4865:1
held [3] - 4684:9, 4852:16, 4864:7
helicopters [1] - 4718:22
help [35] - 4651:11, 4655:21, 4658:9,
4658:13, 4658:25, 4663:9, 4670:11,
4671:9, 4681:11, 4681:13, 4705:23,
4711:13, 4712:8, 4712:12, 4731:22,
4732:7, 4747:5, 4747:7, 4778:8,
4791:6, 4791:7, 4797:2, 4797:3,
4800:7, 4818:2, 4818:5, 4819:19,
4833:22, 4834:13, 4834:15, 4834:16,
18
4837:5, 4843:5, 4857:9, 4857:11

helped [1] - 4856:24
helpful [2] - 4663:5, 4833:15
helping [4] - 4716:9, 4784:10,
4784:11, 4842:18
helps [1] - 4789:1
hemisphere [1] - 4819:9
heroin [1] - 4751:1
hezbollah [2] - 4820:20, 4837:3
Hezbollah [10] - 4655:5, 4657:5,
4735:16, 4792:15, 4792:17, 4792:18,
4794:16, 4812:21, 4819:7
hidden [1] - 4685:3
hide [5] - 4690:1, 4781:8, 4799:17,
4853:5
hiding [14] - 4668:5, 4724:21, 4779:22,
4779:23, 4779:24, 4780:2, 4780:3,
4780:4, 4780:24, 4781:5, 4781:6,
4781:8, 4825:8
high [15] - 4637:1, 4666:11, 4672:12,
4722:4, 4722:5, 4722:7, 4722:10,
4723:10, 4808:13, 4816:24, 4824:25,
4825:5, 4836:14, 4854:7, 4855:9
high-tech [3] - 4816:24, 4824:25,
4825:5
higher [1] - 4688:5
highest [1] - 4794:7
highlighted [1] - 4699:16
highly [1] - 4765:21
hilt [1] - 4720:2
himself [23] - 4647:4, 4648:12, 4653:7,
4655:23, 4676:3, 4680:22, 4686:1,
4692:7, 4692:9, 4703:16, 4719:17,
4719:21, 4727:11, 4746:6, 4747:7,
4747:10, 4747:11, 4770:2, 4799:23,
4813:9, 4817:20, 4819:19, 4845:24
history [1] - 4654:10
hit [1] - 4699:14
hmm [1] - 4852:15
hog [1] - 4656:7
hold [8] - 4641:22, 4650:6, 4656:17,
4679:1, 4703:22, 4703:24, 4704:1,
4717:24
holding [4] - 4646:16, 4651:15,
4712:25, 4832:18
home [25] - 4668:4, 4678:23, 4733:25,
4734:2, 4758:10, 4764:16, 4764:17,
4764:21, 4765:8, 4766:2, 4766:22,
4770:12, 4781:18, 4781:19, 4781:20,
4785:1, 4794:19, 4794:23, 4796:8,
4825:4, 4854:22, 4858:25, 4859:13
homegrown [2] - 4648:8, 4668:9
homes [2] - 4857:8, 4857:10
honestly [1] - 4723:7
Honor [55] - 4635:6, 4635:10, 4637:17,
4638:22, 4639:4, 4641:14, 4641:19,
4642:2, 4642:10, 4642:11, 4642:12,
4642:19, 4644:18, 4644:19, 4644:20,
4646:3, 4705:20, 4707:6, 4707:16,
4707:20, 4708:10, 4708:11, 4708:12,


4758:24, 4758:25, 4760:5, 4760:6,
4760:12, 4760:22, 4761:20, 4761:21,
4761:22, 4762:3, 4762:5, 4772:3,
4772:16, 4773:16, 4773:19, 4802:14,
4803:2, 4805:17, 4805:24, 4805:25,
4806:1, 4806:7, 4861:17, 4862:6,
4862:7, 4862:8, 4862:9, 4862:24,
4863:19, 4865:15, 4866:5, 4866:10
Honor's [3] - 4861:24, 4863:16,
4865:23
HONORABLE [1] - 4633:10
hook [2] - 4681:18, 4707:7
hooked [2] - 4707:8, 4710:16
hooking [1] - 4782:1
hope [6] - 4642:16, 4644:2, 4704:2,
4769:16, 4799:12, 4860:5
hoped [1] - 4696:10
hopeful [1] - 4729:16
hopes [1] - 4677:9
hoping [1] - 4685:7
horrible [1] - 4750:9
horrific [3] - 4657:10, 4663:23,
4693:16
horse's [1] - 4660:25
host [1] - 4785:3
hosts [1] - 4784:25
hot [1] - 4684:22
hotel [2] - 4850:17, 4852:15
hour [11] - 4635:14, 4705:21, 4705:25,
4758:9, 4760:23, 4802:15, 4802:16,
4815:6, 4837:18
hours [10] - 4642:16, 4646:4, 4692:6,
4703:18, 4705:16, 4737:15, 4763:1,
4808:4, 4831:19
house [14] - 4653:17, 4654:5, 4676:8,
4677:14, 4747:3, 4777:23, 4778:3,
4780:3, 4789:10, 4793:20, 4794:21,
4797:22, 4844:3, 4844:4
Howard [1] - 4724:6
huge [6] - 4685:3, 4764:25, 4767:24,
4827:20, 4851:12
human [1] - 4663:13
humble [1] - 4785:2
humiliation [1] - 4741:19
hundred [5] - 4671:24, 4762:25,
4829:21, 4830:3, 4845:15
hundreds [1] - 4646:4
hungry [7] - 4689:11, 4758:1, 4810:10,
4810:14, 4814:1, 4848:3, 4848:4
hurry [5] - 4716:11, 4809:15, 4809:22,
4851:12
hurt [4] - 4697:21, 4697:23, 4699:25,
4858:4
husband [1] - 4770:20
Hussein [1] - 4790:13
hydroelectric [1] - 4823:11
I
Ibrahim [78] - 4658:5, 4681:15,
4685:25, 4686:7, 4686:10, 4686:19,
4686:21, 4686:24, 4687:4, 4687:20,
4688:8, 4688:17, 4688:20, 4688:21,
4689:3, 4690:10, 4690:12, 4699:22,
4735:8, 4738:16, 4739:11, 4739:17,
4739:20, 4739:21, 4739:22, 4740:4,
4740:6, 4740:19, 4741:1, 4741:3,
4743:5, 4743:8, 4743:12, 4764:12,
4764:19, 4778:5, 4794:1, 4800:11,
4801:5, 4801:9, 4807:19, 4809:9,
4811:24, 4812:12, 4812:13, 4812:16,
4813:10, 4813:25, 4820:2, 4820:4,
4821:15, 4821:16, 4821:17, 4821:21,
4837:23, 4844:5, 4844:7, 4844:9,
4844:14, 4844:18, 4846:24, 4847:8,
4847:9, 4847:11, 4847:20, 4847:22,
4847:23, 4847:24, 4847:25, 4848:6,
4853:11, 4853:13, 4853:20, 4854:4
Ibrahim's [10] - 4686:12, 4739:23,
4764:17, 4777:23, 4789:10, 4821:20,
4844:3, 4844:4, 4844:6, 4847:10
icing [1] - 4832:13
idea [49] - 4636:2, 4648:7, 4650:18,
4656:1, 4656:3, 4658:16, 4659:25,
4661:9, 4661:20, 4662:7, 4662:12,
4662:15, 4662:17, 4672:23, 4688:21,
4691:17, 4691:19, 4693:2, 4693:8,
4694:6, 4703:8, 4705:9, 4705:17,
4705:19, 4706:2, 4712:25, 4729:11,
4736:1, 4749:17, 4760:18, 4766:5,
4789:25, 4807:16, 4807:24, 4810:24,
4816:9, 4820:8, 4820:24, 4821:6,
4823:10, 4831:16, 4831:17, 4833:1,
4835:9, 4835:11, 4842:25, 4846:25,
4847:2, 4855:14
ideas [12] - 4650:20, 4650:21, 4654:3,
4814:5, 4814:7, 4814:8, 4815:15,
4819:23, 4819:25, 4820:24, 4830:14,
4830:15
identification [1] - 4717:17
identify [1] - 4858:6
identities [1] - 4665:19
identity [2] - 4665:13, 4780:4
idiot [1] - 4723:13
ignore [2] - 4659:4, 4856:17
illegal [3] - 4670:24, 4670:25, 4814:13
illegally [2] - 4745:9, 4747:8
images [17] - 4674:25, 4675:5, 4680:3,
4682:1, 4688:12, 4688:13, 4688:14,
4693:20, 4703:12, 4703:13, 4825:9,
4835:23, 4840:24, 4849:25, 4854:1,
4854:2, 4854:3
imagination [3] - 4708:22, 4757:19,
4808:9
imagine [1] - 4693:16
imam [1] - 4686:8
19
Imam [4] - 4719:18, 4788:19, 4854:17,

4854:23
Iman [1] - 4785:2
immediately [5] - 4665:23, 4671:14,
4678:11, 4686:6, 4743:16
immigration [2] - 4712:8, 4747:7
implicate [1] - 4681:25
implication [2] - 4674:11, 4817:9
implications [1] - 4682:4
imply [1] - 4748:24
import [5] - 4711:25, 4731:14,
4731:19, 4756:13, 4765:15
import/export [2] - 4656:2, 4729:17
importance [3] - 4644:6, 4710:4,
4739:24
important [27] - 4643:15, 4644:7,
4656:13, 4678:12, 4682:13, 4704:16,
4715:22, 4719:17, 4719:21, 4723:16,
4734:4, 4736:18, 4750:12, 4766:9,
4767:13, 4767:14, 4767:21, 4768:13,
4768:15, 4798:4, 4817:19, 4849:5,
4852:6, 4852:11, 4853:18, 4859:7,
4860:2
importantly [5] - 4665:12, 4788:10,
4799:6, 4811:20, 4848:22
importation [1] - 4678:14
importing [2] - 4765:23, 4823:4
impossible [2] - 4792:20, 4814:13
impress [1] - 4756:25
impressed [2] - 4720:3, 4723:20
impressive [1] - 4723:18
improve [4] - 4792:3, 4793:13,
4793:14, 4842:7
improvised [1] - 4752:14
in-between [2] - 4675:4, 4675:7
inaccurate [1] - 4772:1
inaccurately [1] - 4772:5
inappropriate [2] - 4642:1, 4773:22
Inc [1] - 4633:23
incapable [1] - 4830:13
incentive [2] - 4749:6, 4749:7
incentives [1] - 4734:9
incident [1] - 4798:4
inclined [2] - 4862:22, 4865:15
include [6] - 4638:4, 4640:3, 4640:12,
4640:15, 4855:4, 4862:22
included [2] - 4687:20, 4862:21
includes [1] - 4668:11
including [6] - 4667:21, 4698:14,
4775:5, 4816:6, 4855:5, 4864:23
inclusive [1] - 4640:1
income [1] - 4770:8
inconsistencies [3] - 4834:9, 4834:10,
4837:14
inconsistent [2] - 4839:20, 4840:7
incorporate [1] - 4861:5
increasing [2] - 4683:7, 4741:23
indeed [2] - 4647:8, 4847:5
independent [1] - 4859:16


INDEX [1] - 4867:1
indicate [2] - 4720:17, 4863:23
indicated [2] - 4835:21, 4861:4
indicates [2] - 4747:1, 4756:20
indication [5] - 4641:9, 4777:18,
4791:22, 4792:13, 4792:14
indictment [6] - 4662:23, 4750:24,
4751:7, 4775:5, 4775:7, 4806:12
indisputable [1] - 4647:10
individual [3] - 4818:10, 4818:20,
4820:20
individuals [3] - 4694:14, 4821:24,
4842:1
industry [1] - 4676:15
infer [1] - 4727:24
inference [1] - 4854:10
inferences [2] - 4645:14, 4645:20
infiltrate [1] - 4820:16
infiltration [1] - 4855:5
influence [2] - 4685:18, 4849:12
influences [1] - 4849:7
informant [3] - 4746:22, 4748:16,
4788:2
informants [1] - 4757:11
Information [3] - 4653:2, 4849:6,
4849:7
information [15] - 4671:8, 4766:24,
4776:25, 4777:8, 4780:18, 4782:21,
4783:5, 4783:7, 4786:10, 4786:18,
4786:19, 4786:20, 4833:10, 4852:16,
4856:12
informed [1] - 4863:20
infrastructure [1] - 4820:9
infusion [1] - 4844:24
initial [3] - 4711:9, 4711:18, 4729:22
initiative [1] - 4849:1
inject [1] - 4855:16
injury [4] - 4696:2, 4696:17, 4696:20,
4696:23
inner [1] - 4664:3
innocent [5] - 4646:11, 4661:6,
4703:23, 4762:20, 4803:16
insha'allah [1] - 4727:3
inside [5] - 4669:21, 4669:25, 4700:24,
4722:19, 4858:1
insignificant [1] - 4834:17
inspire [1] - 4736:3
instance [1] - 4730:10
instead [4] - 4658:5, 4740:14,
4815:12, 4857:5
instruct [8] - 4645:4, 4698:15,
4698:24, 4702:4, 4731:7, 4771:20,
4771:21, 4772:3
instructed [4] - 4721:8, 4731:6,
4744:5, 4863:17
instructing [4] - 4722:1, 4732:11,
4736:6, 4775:2
instruction [21] - 4639:7, 4640:2,
4640:3, 4722:3, 4771:22, 4772:17,
4773:3, 4773:18, 4773:25, 4775:12,
4775:13, 4802:6, 4804:2, 4859:23,

4861:7, 4862:11, 4865:16, 4865:17,
4865:19, 4865:25
instructions [13] - 4639:15, 4704:21,
4736:12, 4771:6, 4771:7, 4772:14,
4773:6, 4773:13, 4775:14, 4802:4,
4859:9, 4859:19, 4862:23
instruments [1] - 4708:14
insure [1] - 4829:21
intelligence [3] - 4655:7, 4655:8,
4814:21
intend [1] - 4728:6
intended [12] - 4641:5, 4676:23,
4695:9, 4696:16, 4696:20, 4696:21,
4697:14, 4698:11, 4699:4, 4700:8,
4702:15, 4733:21
intending [1] - 4723:6
intent [53] - 4663:5, 4667:12, 4668:21,
4689:13, 4690:16, 4696:2, 4696:15,
4697:16, 4698:5, 4702:10, 4703:13,
4709:18, 4709:21, 4715:20, 4715:25,
4716:5, 4720:17, 4725:4, 4725:8,
4725:21, 4725:22, 4726:6, 4727:21,
4727:24, 4729:19, 4729:20, 4733:25,
4734:11, 4734:17, 4734:23, 4736:11,
4736:15, 4736:24, 4737:21, 4737:23,
4739:9, 4739:10, 4742:19, 4743:11,
4744:16, 4756:11, 4756:14, 4756:20,
4757:3, 4757:18, 4791:22, 4803:17,
4817:15, 4824:9, 4836:19, 4863:24,
4864:25
intentionally [4] - 4836:22, 4837:6,
4837:12, 4857:11
intentions [1] - 4652:15
intercepts [1] - 4788:4
interest [8] - 4654:20, 4679:22,
4795:11, 4796:3, 4796:6, 4796:11,
4796:12, 4796:14
interested [33] - 4675:8, 4675:12,
4677:20, 4677:22, 4678:4, 4678:18,
4678:19, 4679:13, 4679:16, 4679:17,
4679:22, 4680:21, 4681:3, 4681:4,
4688:9, 4691:14, 4692:15, 4713:3,
4716:14, 4728:22, 4732:21, 4732:23,
4738:4, 4738:8, 4768:2, 4778:9,
4811:11, 4823:19, 4835:15, 4839:7
interesting [1] - 4827:1
interests [2] - 4653:20, 4653:23
International [1] - 4700:11
international [6] - 4655:7, 4657:11,
4700:8, 4700:12, 4811:22, 4827:20
Internet [4] - 4682:4, 4721:15, 4800:2,
4806:15
interrupt [4] - 4694:18, 4704:14,
4705:18, 4706:3
interruption [1] - 4644:9
interstate [3] - 4698:22, 4698:23,
4701:24
interview [4] - 4831:11, 4831:14,
4831:18, 4833:3
20
intimate [3] - 4784:2, 4784:3, 4784:5

introduce [6] - 4655:15, 4713:8,
4841:2, 4842:21, 4843:4, 4843:16
introduced [5] - 4648:24, 4664:11,
4664:13, 4798:24, 4825:13
introduces [1] - 4711:14
introducing [3] - 4687:24, 4776:5,
4829:17
introduction [2] - 4640:10, 4778:11
introductions [1] - 4849:25
invest [3] - 4721:3, 4740:7, 4740:9
investigate [1] - 4758:17
investigation [6] - 4705:7, 4711:5,
4756:5, 4758:13, 4804:11, 4859:16
investigations [1] - 4711:7
Investigator [2] - 4635:5, 4794:22
investigator [3] - 4776:14, 4785:19,
4855:22
investment [1] - 4720:22
investments [1] - 4845:12
investors [3] - 4844:18, 4844:22,
4845:17
invites [1] - 4711:16
inviting [1] - 4785:1
involved [23] - 4665:16, 4673:3,
4682:21, 4683:2, 4688:2, 4750:2,
4750:4, 4750:6, 4750:13, 4750:20,
4810:12, 4830:25, 4833:6, 4834:11,
4835:3, 4837:9, 4841:18, 4846:11,
4847:15, 4847:24, 4847:25, 4848:1
involvement [10] - 4656:10, 4666:2,
4687:21, 4688:1, 4688:10, 4745:18,
4752:2, 4830:13, 4835:21, 4846:1
involving [1] - 4822:18
Iran [82] - 4658:6, 4658:17, 4658:21,
4677:16, 4686:9, 4688:19, 4688:22,
4689:2, 4689:18, 4689:19, 4689:22,
4731:3, 4735:17, 4741:4, 4744:19,
4776:6, 4781:22, 4783:11, 4783:13,
4783:14, 4783:20, 4783:21, 4783:23,
4784:6, 4784:7, 4784:8, 4784:12,
4785:7, 4785:10, 4785:11, 4785:12,
4785:13, 4786:5, 4786:12, 4786:15,
4786:17, 4788:2, 4788:7, 4788:14,
4788:18, 4789:7, 4789:10, 4790:5,
4790:20, 4791:13, 4791:25, 4792:1,
4792:5, 4792:8, 4794:15, 4798:25,
4812:14, 4812:15, 4812:19, 4812:20,
4812:21, 4813:1, 4813:2, 4819:5,
4819:6, 4819:10, 4847:13, 4848:14,
4848:17, 4850:4, 4850:11, 4852:22,
4853:4, 4853:9, 4853:13, 4853:15,
4853:22, 4854:5, 4854:9, 4856:10,
4856:20
Iranian [10] - 4653:13, 4655:9, 4819:4,
4837:2, 4839:18, 4852:20, 4852:22,
4853:25, 4854:7, 4856:12
IRIZARRY [1] - 4633:10
Irizarry [4] - 4659:3, 4771:8, 4814:9,
4814:19


irony [1] - 4674:13
irrefutable [1] - 4703:19
irrelevant [1] - 4755:8
Islam [7] - 4788:9, 4788:22, 4792:5,
4792:7, 4792:10, 4821:20, 4849:14
Islamic [8] - 4653:2, 4665:7, 4668:9,
4689:21, 4792:5, 4848:19, 4849:6,
4849:7
Island [1] - 4720:7
Israel [3] - 4649:12, 4822:4, 4822:8
Israeli [2] - 4719:5, 4819:10
issue [7] - 4637:13, 4647:6, 4667:2,
4698:21, 4709:20, 4861:15, 4862:9
issued [3] - 4753:21, 4753:22, 4851:6
issues [2] - 4637:24, 4685:19
it,he'll [1] - 4738:23
items [3] - 4731:8, 4795:18, 4796:1
itinerary [4] - 4753:3, 4753:9, 4753:21,
4851:5
itself [4] - 4657:11, 4695:6, 4699:13,
4701:11
J
jail [8] - 4634:21, 4746:3, 4746:22,
4749:25, 4812:2, 4834:23, 4835:16
JAM [2] - 4668:15, 4668:16
Jamaat [1] - 4685:12
Jamaica [1] - 4704:3
James [1] - 4815:2
January [7] - 4669:6, 4742:2, 4750:1,
4753:11, 4753:16, 4753:23, 4754:4
jar [2] - 4806:24, 4807:1
Jason [1] - 4635:2
JASON [1] - 4633:17
jeopardy [1] - 4697:1
Jewish [2] - 4819:11, 4821:18
Jews [2] - 4654:9, 4849:1
JFK [125] - 4646:14, 4646:21, 4647:3,
4647:8, 4647:12, 4647:25, 4648:13,
4648:22, 4649:13, 4649:18, 4650:19,
4654:16, 4655:12, 4655:17, 4655:22,
4656:1, 4656:25, 4657:8, 4657:17,
4657:23, 4657:25, 4658:14, 4659:24,
4660:4, 4660:11, 4660:21, 4661:3,
4661:21, 4662:3, 4662:12, 4662:21,
4662:24, 4667:11, 4671:19, 4672:5,
4672:19, 4678:13, 4681:5, 4690:9,
4690:16, 4691:11, 4692:8, 4693:15,
4695:4, 4695:10, 4695:18, 4695:20,
4696:13, 4696:25, 4698:11, 4698:23,
4699:2, 4700:11, 4700:13, 4701:10,
4702:1, 4702:15, 4703:21, 4708:24,
4709:6, 4709:12, 4711:24, 4713:3,
4716:4, 4717:4, 4717:22, 4718:4,
4718:8, 4718:24, 4719:2, 4719:17,
4720:4, 4723:18, 4724:10, 4724:13,
4727:3, 4732:4, 4740:6, 4740:16,
4745:10, 4745:14, 4752:22, 4763:12,
4765:23, 4769:4, 4783:9, 4784:2,

4784:3, 4785:9, 4806:13, 4806:14,
4808:6, 4808:19, 4808:21, 4811:9,
4812:11, 4813:16, 4814:3, 4815:25,
4820:4, 4822:19, 4828:21, 4830:1,
4830:3, 4830:10, 4830:24, 4831:12,
4833:5, 4833:10, 4833:13, 4835:4,
4835:23, 4836:22, 4839:3, 4839:4,
4839:10, 4839:13, 4844:21, 4844:22,
4844:25, 4845:18, 4848:7, 4854:6,
4858:3, 4858:15
JFK's [1] - 4696:4
jihad [2] - 4792:3, 4849:14
Jihad [4] - 4664:20, 4664:24, 4687:5,
4785:9
Jihadist [1] - 4686:13
jihadist [1] - 4849:11
job [12] - 4772:13, 4773:6, 4815:11,
4815:14, 4827:23, 4833:9, 4841:6,
4843:10, 4857:16, 4858:11, 4858:13,
4862:13
jobs [2] - 4676:16, 4710:2
John [1] - 4846:19
join [26] - 4648:24, 4662:12, 4687:17,
4695:9, 4709:22, 4715:20, 4715:25,
4716:5, 4720:17, 4723:6, 4725:4,
4725:8, 4726:6, 4733:21, 4734:1,
4734:12, 4734:23, 4736:24, 4739:9,
4745:10, 4756:11, 4756:20, 4757:3,
4757:18, 4803:17, 4830:16
joined [13] - 4635:4, 4641:3, 4745:6,
4745:15, 4747:4, 4765:6, 4766:17,
4767:12, 4813:10, 4814:16, 4823:19,
4837:11, 4849:17
joining [1] - 4864:4
joints [3] - 4673:7, 4747:14, 4748:1
joke [1] - 4741:20
JONES [13] - 4633:17, 4635:2,
4637:21, 4642:10, 4642:19, 4644:18,
4758:24, 4861:17, 4861:23, 4862:6,
4862:24, 4865:14, 4866:5
Jones [3] - 4635:2, 4825:15, 4865:22
journeyed [1] - 4837:18
JTTF [1] - 4711:7
judge [12] - 4698:15, 4698:24, 4701:1,
4702:3, 4723:10, 4775:12, 4775:13,
4796:17, 4796:18, 4814:9, 4814:19,
4835:18
Judge [7] - 4633:11, 4659:3, 4694:21,
4731:6, 4771:8, 4795:16, 4795:23
Judge's [1] - 4771:6
judges [2] - 4645:23, 4802:8
July [2] - 4633:8, 4866:12
jump [2] - 4801:12, 4852:22
jumped [1] - 4821:16
jumping [1] - 4797:8
jumps [1] - 4693:14
juncture [1] - 4637:4
June [6] - 4754:1, 4754:3, 4794:20,
4850:12, 4852:18, 4852:21
21
junior [2] - 4808:13, 4836:14

jurisdictional [5] - 4698:8, 4698:16,
4700:20, 4701:2, 4701:21
juror [3] - 4636:24, 4643:18
Juror [7] - 4637:14, 4637:19, 4637:23,
4642:5, 4643:3, 4643:12, 4644:5
jurors [13] - 4636:22, 4642:3, 4643:3,
4644:16, 4645:22, 4705:12, 4708:8,
4761:18, 4805:22, 4859:21, 4859:24,
4860:1, 4860:4
jury [67] - 4633:11, 4639:22, 4642:15,
4643:5, 4643:21, 4643:22, 4644:4,
4644:16, 4644:25, 4649:3, 4649:14,
4649:23, 4650:7, 4651:8, 4664:21,
4670:3, 4671:25, 4672:16, 4678:5,
4679:2, 4679:25, 4680:24, 4682:17,
4683:19, 4689:9, 4698:2, 4707:2,
4708:4, 4708:5, 4741:12, 4748:25,
4749:4, 4758:1, 4758:20, 4760:15,
4760:19, 4761:12, 4761:14, 4771:20,
4772:2, 4772:20, 4773:3, 4795:18,
4795:25, 4802:2, 4802:4, 4804:18,
4804:19, 4805:13, 4805:19, 4806:10,
4815:17, 4829:25, 4834:21, 4841:19,
4849:15, 4854:8, 4857:14, 4858:12,
4860:11, 4861:2, 4862:3, 4863:4,
4863:17, 4864:16, 4865:10, 4866:3
JURY [3] - 4644:1, 4762:8, 4806:9
jury's [3] - 4705:17, 4788:16, 4838:8
justice [1] - 4764:9
K
Kabir [1] - 4763:6
Kadir [286] - 4634:1, 4634:25, 4635:12,
4636:17, 4637:16, 4637:18, 4638:19,
4639:8, 4647:24, 4648:23, 4652:24,
4653:5, 4653:8, 4653:25, 4654:13,
4654:17, 4654:19, 4654:23, 4655:6,
4655:18, 4656:7, 4658:5, 4658:12,
4659:13, 4659:14, 4659:15, 4660:17,
4660:19, 4665:18, 4665:22, 4673:23,
4674:2, 4674:14, 4674:16, 4674:17,
4674:22, 4674:23, 4674:25, 4675:1,
4675:2, 4675:3, 4675:7, 4675:10,
4675:11, 4675:16, 4675:18, 4675:21,
4675:23, 4676:4, 4676:10, 4676:12,
4676:21, 4677:5, 4677:12, 4677:14,
4677:16, 4677:19, 4678:2, 4678:3,
4678:10, 4678:14, 4678:21, 4678:24,
4679:4, 4679:20, 4680:15, 4680:18,
4680:22, 4681:2, 4681:7, 4682:11,
4682:13, 4682:24, 4683:10, 4683:13,
4683:17, 4683:21, 4684:13, 4684:18,
4685:10, 4685:16, 4685:19, 4686:7,
4688:12, 4688:15, 4688:20, 4688:25,
4689:4, 4689:11, 4689:14, 4689:17,
4689:18, 4689:20, 4689:25, 4690:4,
4690:7, 4691:6, 4691:9, 4691:20,
4692:2, 4692:23, 4693:2, 4693:14,


4694:1, 4694:4, 4694:8, 4694:22,
4695:3, 4698:14, 4703:5, 4703:14,
4729:5, 4729:7, 4729:22, 4729:23,
4730:1, 4730:3, 4730:4, 4730:7,
4730:10, 4730:23, 4731:3, 4731:11,
4731:15, 4731:18, 4731:24, 4732:20,
4735:4, 4735:6, 4735:13, 4735:21,
4736:12, 4737:2, 4739:19, 4743:1,
4743:14, 4743:20, 4744:18, 4756:17,
4760:17, 4761:25, 4762:23, 4763:5,
4763:12, 4763:13, 4764:10, 4765:2,
4765:7, 4765:16, 4765:18, 4765:24,
4766:4, 4766:10, 4766:18, 4767:12,
4767:23, 4768:3, 4768:5, 4768:19,
4769:11, 4770:1, 4771:2, 4775:15,
4775:22, 4776:1, 4776:3, 4776:8,
4779:10, 4779:12, 4781:3, 4781:21,
4782:15, 4783:12, 4783:17, 4783:19,
4783:20, 4788:6, 4789:25, 4790:5,
4791:3, 4791:16, 4793:18, 4794:4,
4794:8, 4794:17, 4794:20, 4797:14,
4797:16, 4797:20, 4798:5, 4800:4,
4800:6, 4801:5, 4801:7, 4801:10,
4803:1, 4803:5, 4803:16, 4803:18,
4803:21, 4807:19, 4810:9, 4810:12,
4811:23, 4813:11, 4813:12, 4813:13,
4813:15, 4814:1, 4820:2, 4823:17,
4827:2, 4827:3, 4827:11, 4827:15,
4830:7, 4832:10, 4834:5, 4835:20,
4836:20, 4836:25, 4838:3, 4839:12,
4840:11, 4840:20, 4841:14, 4841:19,
4842:6, 4843:3, 4843:8, 4843:14,
4843:23, 4844:5, 4844:7, 4844:10,
4844:20, 4845:5, 4846:2, 4846:6,
4846:9, 4846:24, 4847:5, 4847:9,
4847:14, 4847:15, 4847:18, 4847:19,
4847:21, 4847:23, 4847:24, 4847:25,
4848:1, 4848:3, 4848:6, 4848:9,
4848:22, 4849:17, 4850:3, 4850:18,
4851:17, 4853:3, 4853:12, 4853:23,
4854:3, 4854:4, 4854:9, 4857:1,
4858:2, 4858:6, 4858:21, 4866:7
kadir [1] - 4778:13
KADIR [5] - 4633:6, 4636:19, 4780:12,
4780:25, 4810:14
Kadir's [31] - 4641:15, 4653:17,
4654:4, 4658:23, 4674:18, 4676:8,
4676:11, 4680:6, 4687:21, 4687:22,
4688:10, 4689:7, 4731:1, 4731:4,
4739:18, 4743:13, 4791:17, 4792:10,
4794:19, 4821:15, 4836:11, 4837:14,
4841:16, 4844:15, 4845:4, 4845:22,
4845:25, 4846:25, 4848:16, 4849:13,
4851:19
Kafahni [1] - 4635:11
KAFAHNI [1] - 4634:2
Kamdang [3] - 4635:7, 4662:5,
4865:15
KAMDANG [13] - 4633:22, 4635:6,
4637:13, 4642:11, 4644:19, 4707:16,
4707:20, 4760:9, 4761:22, 4805:15,

4806:1, 4862:9, 4865:21
Kareem [48] - 4658:4, 4681:14,
4686:7, 4688:8, 4689:3, 4735:8,
4738:16, 4739:11, 4739:17, 4739:20,
4739:21, 4739:22, 4739:23, 4740:3,
4740:4, 4740:6, 4740:19, 4741:1,
4741:2, 4743:5, 4743:8, 4743:12,
4764:12, 4764:17, 4764:19, 4777:22,
4778:4, 4789:10, 4793:20, 4800:10,
4800:11, 4801:5, 4801:9, 4809:9,
4812:12, 4812:16, 4820:2, 4820:4,
4821:15, 4821:16, 4821:17, 4837:23,
4844:3, 4844:4, 4853:10, 4853:20,
4854:4
Kareem's [1] - 4793:19
keep [18] - 4665:19, 4679:17, 4704:18,
4704:25, 4713:23, 4739:1, 4750:10,
4751:16, 4751:20, 4758:6, 4797:8,
4799:7, 4824:11, 4832:21, 4846:21,
4859:7, 4859:24, 4860:3
keeps [3] - 4720:24, 4720:25, 4845:23
Kennedy [1] - 4846:19
kept [3] - 4674:6, 4751:19, 4857:2
key [2] - 4834:10, 4852:12
keys [1] - 4796:22
Khomeini [7] - 4653:12, 4653:16,
4654:1, 4784:14, 4784:19, 4785:2,
4848:12
Khomeini's [1] - 4850:14
kick [2] - 4783:8, 4784:1
kicked [2] - 4728:25, 4789:22
kid [2] - 4652:3, 4808:9
kids [4] - 4791:23, 4792:6, 4806:23,
4855:14
kids' [1] - 4776:25
kill [5] - 4652:4, 4652:5, 4693:25,
4821:19, 4858:5
killed [3] - 4661:14, 4697:3, 4811:19
kilo [2] - 4750:5, 4751:1
kilos [1] - 4751:13
kind [38] - 4644:22, 4655:24, 4666:9,
4666:18, 4666:20, 4668:24, 4674:6,
4677:23, 4684:19, 4685:7, 4686:1,
4692:12, 4695:2, 4705:6, 4705:8,
4709:24, 4710:10, 4713:14, 4743:7,
4745:24, 4747:9, 4748:1, 4758:13,
4758:16, 4758:17, 4770:11, 4804:11,
4804:12, 4805:10, 4819:15, 4831:22,
4834:12, 4834:17, 4859:14, 4859:16,
4859:17, 4864:21
knock [2] - 4699:25, 4700:15
knowing [11] - 4683:22, 4685:17,
4701:7, 4710:24, 4716:13, 4740:19,
4746:17, 4781:23, 4803:6, 4837:5,
4864:25
knowingly [2] - 4837:12, 4857:11
knowledge [18] - 4651:11, 4672:7,
4672:8, 4672:9, 4717:1, 4717:3,
4718:16, 4720:4, 4723:18, 4739:23,
22
4784:2, 4784:3, 4784:5, 4816:16,

4829:20, 4836:19, 4854:5
known [17] - 4643:12, 4658:3,
4665:16, 4667:8, 4668:10, 4672:4,
4676:19, 4676:20, 4683:23, 4688:1,
4739:25, 4741:1, 4780:4, 4819:7,
4829:2, 4829:23, 4863:25
knows [32] - 4650:5, 4651:12,
4651:14, 4678:10, 4678:13, 4682:11,
4682:23, 4683:11, 4686:8, 4687:3,
4716:15, 4718:17, 4728:16, 4728:17,
4735:25, 4738:10, 4748:15, 4749:9,
4752:3, 4755:24, 4765:20, 4779:16,
4821:10, 4836:3, 4839:18, 4847:24,
4847:25, 4848:1, 4853:24, 4856:19
Kosovo [2] - 4745:12, 4745:13
Kufr [1] - 4848:18
Kutub [5] - 4849:8, 4849:9, 4849:11,
4849:12
L
lack [2] - 4831:19, 4862:17
Laden [1] - 4846:9
ladies [53] - 4643:25, 4644:21,
4644:25, 4651:24, 4685:6, 4705:11,
4708:7, 4708:13, 4708:20, 4709:20,
4713:10, 4719:16, 4720:5, 4721:11,
4723:1, 4723:3, 4723:14, 4724:1,
4724:3, 4727:4, 4730:25, 4731:23,
4733:4, 4734:16, 4735:18, 4737:12,
4737:22, 4740:2, 4740:22, 4741:10,
4747:25, 4748:10, 4749:1, 4749:22,
4751:15, 4751:17, 4754:11, 4754:24,
4756:10, 4757:4, 4758:5, 4758:21,
4761:17, 4761:23, 4762:7, 4775:1,
4788:10, 4788:12, 4803:24, 4805:20,
4806:2, 4808:3, 4858:24
Ladin [1] - 4815:2
lady [2] - 4643:4, 4780:16
Lafayette [1] - 4634:4
LaGuardia [1] - 4697:6
laid [2] - 4639:9, 4670:8
land [6] - 4673:22, 4698:20, 4698:23,
4699:2, 4822:11, 4822:14
language [7] - 4641:6, 4862:11,
4862:14, 4862:21, 4862:22, 4865:23,
4866:2
laptop [4] - 4705:24, 4707:12,
4707:15, 4760:25
large [5] - 4691:1, 4718:12, 4750:5,
4844:24, 4845:16
largely [1] - 4671:23
laser [1] - 4848:20
last [11] - 4637:24, 4639:16, 4656:8,
4660:15, 4681:6, 4702:6, 4802:14,
4802:15, 4848:2, 4853:3, 4857:1
lasted [1] - 4796:20
late [5] - 4636:23, 4662:1, 4665:6,


4753:11, 4754:4
Latif [2] - 4848:15, 4848:16
laughable [4] - 4656:3, 4656:4,
4691:19
laughing [2] - 4727:7, 4741:18
launder [1] - 4658:19
LAW [1] - 4634:1
law [50] - 4640:20, 4645:5, 4645:7,
4653:19, 4654:2, 4657:9, 4657:11,
4659:2, 4660:13, 4682:20, 4685:12,
4704:22, 4724:22, 4761:8, 4771:21,
4772:2, 4772:5, 4772:11, 4772:12,
4772:18, 4772:20, 4772:23, 4772:24,
4773:6, 4773:7, 4773:21, 4775:2,
4775:3, 4780:22, 4802:6, 4804:2,
4811:22, 4813:8, 4814:10, 4814:20,
4825:1, 4825:8, 4828:22, 4828:23,
4857:18, 4857:21, 4857:23, 4857:25,
4858:9, 4858:11, 4859:9, 4859:19,
4859:23, 4865:4
lawful [1] - 4857:21
laws [3] - 4646:22, 4701:19, 4857:18
lawsuit [3] - 4714:5, 4715:24, 4725:11
lawyers [1] - 4771:22
layout [3] - 4658:16, 4669:7, 4703:9
lead [2] - 4747:3, 4826:11
leader [6] - 4665:14, 4784:19,
4786:11, 4786:22, 4788:20, 4855:2
leader's [1] - 4653:18
leaders [5] - 4784:13, 4786:16,
4854:8, 4855:4, 4855:8
leadership [9] - 4658:6, 4658:21,
4688:19, 4689:23, 4689:24, 4812:15,
4819:4, 4839:18, 4847:13
leading [1] - 4816:14
learn [5] - 4676:7, 4699:15, 4792:7,
4814:23, 4818:7
learned [9] - 4684:25, 4739:12,
4739:13, 4775:19, 4811:17, 4811:19,
4811:21, 4827:20
learning [1] - 4770:2
learns [2] - 4685:25, 4728:11
least [6] - 4638:11, 4638:24, 4639:2,
4679:10, 4757:12, 4785:10
leave [8] - 4705:12, 4740:18, 4740:22,
4740:25, 4775:18, 4775:19, 4797:18,
4852:9
leaves [6] - 4643:18, 4735:9, 4764:23,
4851:10, 4851:12, 4860:11
led [1] - 4672:24
left [15] - 4648:18, 4662:21, 4663:8,
4669:13, 4676:16, 4680:19, 4697:6,
4715:15, 4751:14, 4755:23, 4803:25,
4807:2, 4813:5, 4855:13, 4863:2
legal [2] - 4640:9, 4858:9
LEN [1] - 4633:22
Len [1] - 4635:7
lend [1] - 4773:20
length [2] - 4812:17, 4837:24
lengths [1] - 4684:1
lengthy [2] - 4749:16, 4835:19

lent [1] - 4653:6
less [11] - 4642:17, 4649:20, 4650:13,
4679:18, 4710:24, 4760:19, 4760:21,
4760:22, 4811:14, 4821:25, 4822:1
lessen [1] - 4748:16
lesson [2] - 4646:10, 4646:12
letter [7] - 4749:10, 4777:17, 4788:3,
4791:2, 4791:4, 4791:6
letters [3] - 4786:18, 4786:19, 4839:17
letting [2] - 4652:20, 4736:8
level [2] - 4679:21, 4864:12
Levin [2] - 4786:14
Levitt [10] - 4667:5, 4667:17, 4712:19,
4746:19, 4812:25, 4818:13, 4819:5,
4819:6, 4819:10, 4849:9
liar [4] - 4718:21, 4744:22, 4747:1,
4748:7
Libya [1] - 4668:17
license [2] - 4816:19, 4817:1
lie [16] - 4659:19, 4677:25, 4683:21,
4692:23, 4695:8, 4695:9, 4745:16,
4745:19, 4746:12, 4749:7, 4750:18,
4750:21, 4827:13, 4835:9, 4835:16,
4846:12
lied [4] - 4678:21, 4695:7, 4752:16,
4856:13
lies [4] - 4728:1, 4830:25, 4835:16,
4837:15
Lieutenant [1] - 4719:10
life [14] - 4648:12, 4653:11, 4661:13,
4710:1, 4741:15, 4746:1, 4775:19,
4790:14, 4792:10, 4796:5, 4812:2,
4834:24, 4835:17
lifetime [3] - 4748:17, 4748:22, 4749:4
light [1] - 4865:23
Light [4] - 4666:13, 4666:15, 4666:17,
4675:19
likely [13] - 4668:7, 4682:21, 4682:22,
4699:9, 4700:9, 4702:11, 4702:17,
4724:9, 4728:21, 4811:14, 4811:15,
4813:1, 4864:22
limiting [5] - 4639:7, 4639:14, 4640:2,
4640:3, 4861:7
Linden [7] - 4730:4, 4735:1, 4735:4,
4735:6, 4735:10, 4736:12, 4737:15
Lindendale [1] - 4789:3
line [5] - 4650:22, 4710:9, 4730:9,
4731:18, 4797:1
lines [3] - 4656:19, 4702:1, 4815:23
links [1] - 4819:22
lipped [1] - 4654:25
lips [1] - 4806:25
list [7] - 4667:20, 4861:15, 4861:18,
4861:24, 4861:25, 4862:1, 4862:2
listen [42] - 4649:2, 4649:25, 4651:10,
4683:16, 4683:17, 4705:5, 4714:19,
4716:10, 4716:20, 4717:5, 4719:19,
4719:25, 4721:5, 4723:19, 4731:16,
4732:6, 4735:19, 4735:21, 4738:1,
23
4738:5, 4738:11, 4740:14, 4741:7,

4741:11, 4742:16, 4742:25, 4743:5,
4743:24, 4744:3, 4747:15, 4747:18,
4752:11, 4755:9, 4755:12, 4758:12,
4758:15, 4764:1, 4775:13, 4775:14,
4824:13, 4858:14, 4859:14
listened [7] - 4692:6, 4692:9, 4815:6,
4822:24, 4826:7, 4834:1, 4840:9
listening [7] - 4652:13, 4683:18,
4684:5, 4736:17, 4741:13, 4744:7,
4862:16
live [5] - 4714:4, 4778:7, 4798:19,
4798:20, 4803:15
lived [7] - 4648:10, 4683:14, 4683:24,
4717:2, 4792:10, 4836:2, 4856:15
lives [11] - 4646:11, 4661:6, 4661:7,
4696:24, 4697:1, 4697:14, 4703:23,
4746:14, 4793:6, 4798:21, 4826:1
living [13] - 4658:24, 4674:18,
4733:15, 4734:7, 4762:9, 4762:10,
4762:11, 4769:18, 4769:19, 4769:21,
4799:2, 4823:6, 4828:4
load [1] - 4649:12
loading [1] - 4718:22
local [1] - 4811:22
location [2] - 4654:20, 4824:4
locked [1] - 4794:20
logical [2] - 4645:21, 4803:11
logistical [1] - 4713:22
Lone [1] - 4785:16
long-term [1] - 4708:24
look [96] - 4640:20, 4640:22, 4653:16,
4655:12, 4669:11, 4669:18, 4677:4,
4677:23, 4679:9, 4681:12, 4699:15,
4705:4, 4715:18, 4717:16, 4717:24,
4722:12, 4722:21, 4731:16, 4735:10,
4735:19, 4735:20, 4735:23, 4736:24,
4736:25, 4737:25, 4738:16, 4744:20,
4746:22, 4748:10, 4752:20, 4754:12,
4758:11, 4758:15, 4760:5, 4768:1,
4768:23, 4769:15, 4770:13, 4778:19,
4779:11, 4782:12, 4785:9, 4799:9,
4801:24, 4804:9, 4807:12, 4807:22,
4808:24, 4808:25, 4809:6, 4809:14,
4809:17, 4809:20, 4810:12, 4810:20,
4810:25, 4814:5, 4821:1, 4823:3,
4825:12, 4826:16, 4827:4, 4828:6,
4831:10, 4832:19, 4835:7, 4840:5,
4841:16, 4842:21, 4843:12, 4844:1,
4845:25, 4846:20, 4848:10, 4848:15,
4849:6, 4850:10, 4850:23, 4851:4,
4851:5, 4851:18, 4851:19, 4851:20,
4852:5, 4852:7, 4852:19, 4855:1,
4855:8, 4855:17, 4855:22, 4858:13,
4858:16, 4859:14
Look [1] - 4696:25
looked [7] - 4661:24, 4732:24,
4751:18, 4768:21, 4818:2, 4818:7,
4844:11
looking [25] - 4640:24, 4667:13,


4672:4, 4673:15, 4687:16, 4700:2,
4721:14, 4732:7, 4732:13, 4757:21,
4757:22, 4769:6, 4769:9, 4769:12,
4769:13, 4794:7, 4796:15, 4797:6,
4797:7, 4801:22, 4818:3, 4828:16,
4828:19, 4829:1
looks [6] - 4651:4, 4715:14, 4732:15,
4746:9, 4754:11, 4861:20
loose [1] - 4654:25
loose-lipped [1] - 4654:25
lose [10] - 4691:11, 4698:6, 4734:6,
4734:7, 4770:4, 4776:24, 4781:14,
4796:6, 4796:7
losing [1] - 4673:13
loss [3] - 4661:13, 4696:3, 4696:18
lost [2] - 4651:13, 4661:7
Louis [2] - 4719:14, 4754:20
lousy [1] - 4757:17
love [1] - 4809:21
loves [1] - 4769:5
loving [1] - 4791:18
low [3] - 4715:9, 4746:7, 4786:21
lower [1] - 4751:6
lucky [1] - 4668:18
lunch [7] - 4704:13, 4705:17, 4741:10,
4758:3, 4758:9, 4758:19, 4789:19
Lunch [1] - 4759:3
lunches [1] - 4758:2
lying [2] - 4746:11, 4750:15
M
machine [4] - 4720:22, 4720:23,
4740:5, 4742:24
machinery [1] - 4824:24
mail [4] - 4651:1, 4651:3, 4651:5,
4651:6
mailed [1] - 4861:10
mails [1] - 4714:8
main [4] - 4666:6, 4675:3, 4690:21,
4815:20
major [10] - 4696:3, 4696:12, 4696:18,
4697:16, 4698:6, 4705:22, 4722:22,
4756:14, 4792:4
maker [2] - 4667:4, 4667:6
mall [1] - 4677:17
man [31] - 4648:7, 4652:24, 4653:7,
4655:1, 4662:6, 4662:18, 4667:17,
4668:10, 4682:8, 4683:23, 4684:11,
4685:18, 4686:2, 4686:7, 4708:21,
4708:24, 4709:3, 4709:6, 4710:10,
4715:22, 4719:22, 4723:25, 4730:11,
4736:19, 4740:14, 4757:7, 4757:18,
4762:20, 4763:14, 4803:16, 4826:17
man's [1] - 4731:1
manage [4] - 4709:17, 4713:25,
4825:7
managed [1] - 4648:12
Manhattan [2] - 4721:15, 4721:17
manifests [2] - 4718:23, 4719:1

manipulate [1] - 4827:15
manipulated [2] - 4826:6, 4827:2
manipulating [1] - 4827:11
manipulation [1] - 4862:18
manner [2] - 4857:17, 4857:21
map [16] - 4669:16, 4699:15, 4732:4,
4732:14, 4732:15, 4732:18, 4735:6,
4735:9, 4740:18, 4785:20, 4797:20,
4798:2, 4800:7, 4801:22, 4801:23
maps [3] - 4717:21, 4717:22, 4801:23
March [3] - 4678:2, 4678:24, 4732:19
MARIE [1] - 4634:3
marked [3] - 4718:1, 4727:13, 4801:1
married [3] - 4747:8, 4770:16
MARSHAL [2] - 4636:10, 4760:12
marshaled [1] - 4848:18
MARSHALL [1] - 4633:17
Marshall [1] - 4635:2
marshals [2] - 4759:1, 4804:20
Marshals [1] - 4760:6
martial [3] - 4674:2, 4674:17, 4742:10
martyr [5] - 4664:20, 4664:23, 4665:1,
4755:11, 4755:21
Masood [2] - 4711:21, 4712:11
mass [11] - 4701:5, 4701:6, 4701:8,
4701:10, 4701:11, 4701:23, 4702:9,
4702:11, 4702:16, 4703:13, 4834:22
massacres [1] - 4687:17
massive [1] - 4666:10
master [1] - 4790:3
mastermind [1] - 4709:13
materials [1] - 4699:7
Matt [1] - 4746:19
matt [1] - 4667:5
matter [26] - 4636:21, 4637:11,
4637:18, 4641:22, 4657:12, 4733:20,
4737:22, 4762:21, 4766:12, 4766:13,
4787:4, 4789:16, 4800:5, 4814:7,
4814:9, 4821:14, 4836:23, 4838:10,
4839:15, 4839:16, 4839:17, 4839:18,
4849:19, 4855:11, 4863:18, 4866:12
Matter [2] - 4771:24, 4774:3
mattered [2] - 4818:17, 4824:16
matters [7] - 4635:8, 4635:12, 4636:3,
4636:5, 4682:23, 4796:10, 4835:12
Matthew [1] - 4712:19
maximize [1] - 4682:15
mayor [5] - 4653:1, 4665:18, 4730:3,
4730:12, 4786:25
MDC [1] - 4636:2
mean [17] - 4651:23, 4660:2, 4660:7,
4673:16, 4701:9, 4724:21, 4738:21,
4739:7, 4783:11, 4789:9, 4790:16,
4801:11, 4801:13, 4807:5, 4830:19,
4831:8, 4836:13
means [12] - 4643:6, 4644:11, 4654:9,
4664:23, 4664:24, 4665:1, 4698:19,
4703:10, 4724:22, 4748:8, 4757:6,
4813:19
24
meant [9] - 4660:10, 4682:1, 4749:8,

4752:7, 4793:22, 4830:21, 4831:4,
4831:13, 4852:13
media [7] - 4705:6, 4705:8, 4758:17,
4804:12, 4818:15, 4859:14, 4859:17
meet [26] - 4658:18, 4664:7, 4665:5,
4668:13, 4681:9, 4681:15, 4681:18,
4710:18, 4711:17, 4713:8, 4713:14,
4714:16, 4729:21, 4730:7, 4730:18,
4730:23, 4735:14, 4735:22, 4739:17,
4765:19, 4766:14, 4833:21, 4837:18,
4839:21, 4847:7, 4847:23
meeting [24] - 4646:16, 4646:17,
4673:4, 4673:25, 4674:12, 4674:16,
4677:14, 4677:16, 4677:19, 4685:24,
4713:20, 4729:7, 4729:8, 4729:22,
4731:23, 4732:13, 4735:7, 4750:14,
4778:9, 4779:23, 4811:11, 4834:5,
4837:16, 4839:13
meetings [10] - 4660:20, 4668:22,
4711:9, 4711:18, 4747:3, 4827:21,
4827:22, 4829:22, 4833:7, 4834:12
meets [7] - 4685:22, 4710:10, 4711:20,
4711:21, 4711:22, 4766:1
meltdown [1] - 4722:22
member [17] - 4647:4, 4653:1, 4655:5,
4680:4, 4698:12, 4700:23, 4763:5,
4771:9, 4771:11, 4808:23, 4830:10,
4831:20, 4831:21, 4832:4, 4832:5,
4841:20, 4854:11
members [17] - 4644:4, 4647:25,
4648:1, 4657:4, 4668:15, 4668:16,
4673:13, 4684:9, 4695:13, 4806:10,
4815:17, 4829:25, 4834:21, 4841:19,
4849:15, 4854:8, 4857:14
membership [1] - 4695:15
memory [6] - 4744:22, 4747:1, 4748:6,
4750:9, 4771:5, 4771:6
men [12] - 4646:8, 4656:20, 4688:24,
4709:25, 4710:1, 4710:2, 4710:3,
4732:13, 4741:24, 4742:13, 4808:14,
4853:16
mention [5] - 4641:2, 4675:23, 4795:1,
4807:9, 4832:9
mentioned [8] - 4639:16, 4753:7,
4769:3, 4769:13, 4775:1, 4778:4,
4847:8, 4864:6
mere [3] - 4648:1, 4661:7, 4661:16
message [3] - 4749:19, 4749:21
MESSINA [3] - 4634:3, 4635:15,
4635:18
Messina [4] - 4635:11, 4635:14,
4854:16, 4855:2
met [15] - 4674:2, 4683:14, 4710:6,
4724:23, 4730:11, 4730:17, 4763:16,
4763:18, 4765:18, 4766:13, 4773:9,
4791:11, 4811:8, 4811:10, 4856:15
metal [1] - 4719:13
microphone [1] - 4642:14
mid [1] - 4817:9


middle [2] - 4707:18, 4852:20
might [17] - 4692:15, 4705:5, 4727:4,
4746:20, 4746:22, 4748:3, 4758:12,
4789:17, 4792:25, 4795:8, 4804:10,
4823:10, 4825:3, 4846:3, 4859:15,
4864:20, 4866:3
mike [2] - 4694:19, 4694:20
MILDRED [1] - 4633:22
Mildred [1] - 4635:7
militant [2] - 4789:5, 4855:12
military [3] - 4718:24, 4822:16, 4855:6
miller [1] - 4858:23
MILLER [27] - 4633:17, 4708:10,
4761:20, 4768:7, 4771:16, 4772:1,
4772:9, 4772:22, 4772:25, 4773:24,
4788:15, 4794:24, 4795:16, 4795:23,
4802:1, 4805:5, 4805:9, 4805:14,
4805:24, 4806:7, 4806:10, 4823:24,
4838:6, 4839:1, 4851:17, 4853:2,
4867:7
Miller [6] - 4635:2, 4805:1, 4805:3,
4806:4, 4806:5, 4806:6
million [2] - 4696:6, 4696:14
millions [1] - 4740:15
mind [15] - 4679:6, 4679:17, 4686:17,
4704:18, 4708:21, 4753:5, 4757:19,
4758:6, 4785:14, 4793:23, 4797:11,
4797:12, 4803:10, 4832:21, 4859:7
minded [4] - 4654:14, 4673:15,
4673:16, 4736:19
minds [1] - 4704:25
minimal [1] - 4865:13
minister [1] - 4684:9
Minister [1] - 4818:25
Ministry [1] - 4676:15
minute [15] - 4648:5, 4651:25,
4652:23, 4656:8, 4661:17, 4681:6,
4705:15, 4765:10, 4777:5, 4827:7,
4827:19, 4830:22, 4836:18, 4847:17,
4853:3
Minutes [1] - 4634:12
minutes [6] - 4637:10, 4640:7,
4704:13, 4707:4, 4755:22, 4804:15
misguided [2] - 4692:17, 4837:4
misled [1] - 4683:12
missed [1] - 4811:3
missile [1] - 4649:12
missiles [8] - 4718:22, 4719:1, 4822:5,
4822:8, 4822:11, 4822:18, 4822:19,
4848:20
missing [3] - 4764:24, 4767:5, 4811:5
mission [9] - 4710:24, 4810:6,
4810:14, 4813:20, 4814:1, 4814:3,
4848:5, 4848:6, 4848:7
mistake [1] - 4673:16
mock [1] - 4658:19
modest [1] - 4690:23
modifying [1] - 4638:16
Mohammad [1] - 4733:10
Mohammed [10] - 4733:22, 4735:24,
4736:2, 4737:3, 4744:1, 4744:2,

4744:5, 4752:10, 4826:21
Mohsen [8] - 4790:20, 4790:21,
4791:4, 4791:8, 4791:11, 4839:17,
4854:7
mold [1] - 4652:24
moment [12] - 4638:22, 4652:2,
4652:7, 4652:10, 4657:16, 4657:22,
4658:13, 4658:24, 4663:1, 4691:6,
4770:21, 4854:13
Monday [1] - 4678:15
money [55] - 4683:3, 4690:1, 4690:3,
4715:6, 4715:7, 4715:14, 4719:7,
4720:24, 4721:2, 4725:21, 4728:8,
4728:13, 4731:24, 4733:17, 4737:11,
4737:12, 4737:25, 4738:3, 4738:6,
4738:10, 4738:13, 4739:12, 4741:24,
4743:13, 4750:17, 4751:16, 4751:19,
4751:21, 4756:12, 4757:16, 4764:3,
4770:11, 4788:3, 4798:10, 4798:11,
4802:20, 4802:21, 4802:22, 4802:23,
4803:9, 4803:13, 4823:11, 4823:14,
4827:18, 4831:6, 4831:8, 4837:1,
4844:15, 4844:24, 4845:2, 4847:19,
4857:15, 4858:7
moneys [1] - 4784:10
monies [2] - 4844:23, 4845:17
monitors [2] - 4642:20, 4644:22
month [5] - 4646:4, 4665:6, 4710:24,
4750:15, 4750:16
months [9] - 4638:9, 4646:16, 4742:4,
4750:6, 4750:10, 4754:2, 4796:20,
4858:6
morale [1] - 4786:21
morning [14] - 4635:6, 4635:10,
4636:16, 4636:18, 4636:19, 4636:25,
4641:13, 4642:25, 4643:1, 4643:25,
4644:1, 4646:4, 4804:1, 4861:4
mosque [30] - 4666:3, 4673:7, 4683:3,
4685:4, 4689:25, 4690:3, 4731:11,
4731:21, 4742:7, 4742:9, 4765:16,
4765:24, 4770:5, 4770:6, 4776:24,
4778:3, 4778:22, 4788:3, 4798:11,
4798:14, 4803:10, 4845:2, 4845:4,
4845:10, 4849:5, 4849:9, 4849:13,
4854:17, 4854:18, 4854:23
most [21] - 4659:6, 4660:24, 4665:12,
4667:19, 4668:8, 4672:7, 4678:12,
4688:6, 4691:2, 4718:21, 4739:6,
4749:8, 4751:20, 4765:3, 4766:9,
4767:21, 4798:4, 4808:22, 4815:20,
4819:21, 4840:15
mother [1] - 4636:25
Mother [1] - 4667:23
motivated [2] - 4648:2, 4697:22
motivation [1] - 4656:15
motive [4] - 4674:6, 4798:8, 4837:10,
4849:16
motives [1] - 4822:3
mountain [2] - 4651:18, 4691:22
mounts [1] - 4651:21

mourning [1] - 4650:10
mouth [7] - 4660:25, 4708:21,
4736:19, 4757:19, 4769:25, 4808:10,
4845:24
mouths [2] - 4659:7, 4807:8
move [11] - 4642:7, 4644:8, 4644:12,
4656:12, 4659:5, 4694:19, 4695:11,
4697:16, 4698:17, 4847:11, 4856:25
movement [7] - 4688:23, 4688:24,
4849:11, 4853:15, 4853:17, 4853:21,
4853:22
movie [2] - 4823:25, 4824:11
movies [2] - 4713:11, 4722:11
moving [2] - 4681:12, 4700:6
MR [110] - 4635:2, 4635:6, 4635:10,
4636:18, 4636:19, 4637:13, 4637:17,
4637:21, 4638:22, 4639:4, 4641:13,
4641:19, 4642:2, 4642:10, 4642:11,
4642:12, 4642:19, 4644:18, 4644:19,
4644:20, 4707:16, 4707:20, 4708:10,
4708:12, 4758:24, 4758:25, 4760:9,
4760:22, 4761:3, 4761:6, 4761:10,
4761:20, 4761:21, 4761:22, 4762:3,
4762:4, 4762:5, 4762:7, 4762:9,
4767:10, 4768:7, 4768:8, 4768:11,
4771:16, 4771:18, 4772:1, 4772:9,
4772:12, 4772:16, 4772:22, 4772:23,
4772:25, 4773:1, 4773:16, 4773:19,
4773:23, 4773:24, 4774:1, 4775:11,
4780:12, 4780:14, 4780:20, 4780:25,
4784:25, 4788:1, 4788:15, 4788:18,
4794:24, 4795:1, 4795:16, 4795:20,
4795:23, 4796:2, 4801:1, 4802:1,
4802:14, 4802:17, 4803:2, 4803:5,
4805:5, 4805:9, 4805:14, 4805:15,
4805:16, 4805:24, 4805:25, 4806:1,
4806:7, 4806:10, 4823:21, 4823:24,
4838:5, 4838:6, 4839:1, 4851:15,
4851:17, 4852:25, 4853:2, 4861:17,
4861:23, 4862:6, 4862:8, 4862:9,
4862:24, 4865:14, 4865:21, 4866:5,
4866:10, 4867:6, 4867:7
MS [38] - 4635:15, 4635:18, 4646:3,
4649:5, 4649:16, 4649:25, 4650:9,
4651:10, 4664:23, 4670:5, 4672:2,
4672:18, 4678:7, 4679:4, 4680:2,
4681:1, 4682:19, 4683:21, 4689:11,
4694:21, 4698:4, 4705:20, 4707:6,
4707:13, 4707:24, 4708:3, 4708:11,
4708:20, 4722:18, 4723:1, 4727:1,
4741:9, 4760:5, 4861:12, 4862:7,
4863:19, 4867:4, 4867:5
Mudahjin [1] - 4785:4
muddy [1] - 4865:22
mugging [1] - 4677:18
Muhammed [3] - 4688:14, 4721:8,
4844:25
multi [1] - 4750:4
multiple [3] - 4820:15, 4820:21,

25

4844:4
multitude [1] - 4768:17
murder [2] - 4685:2, 4687:10
murders [1] - 4687:10
Murkler [1] - 4669:23
Musabe [1] - 4785:2
Muslim [9] - 4778:2, 4788:20, 4788:23,
4792:6, 4792:7, 4792:9, 4792:11,
4837:4, 4857:9
Muslimeen [1] - 4685:13
Muslims [29] - 4648:3, 4649:11,
4650:3, 4653:14, 4654:8, 4654:11,
4656:14, 4656:21, 4683:4, 4684:11,
4686:22, 4687:1, 4687:7, 4687:8,
4687:11, 4709:3, 4710:15, 4745:11,
4745:13, 4791:7, 4792:4, 4821:19,
4839:22, 4848:24, 4848:25, 4849:11,
4849:13, 4857:3, 4857:7
must [6] - 4700:9, 4712:1, 4712:6,
4730:11, 4758:1, 4804:5
Mustang [1] - 4836:10
muster [1] - 4666:4
mutual [1] - 4664:8
N
Nada [1] - 4763:21
name [21] - 4666:15, 4675:17,
4675:19, 4675:22, 4687:9, 4780:20,
4780:21, 4780:23, 4780:24, 4780:25,
4781:4, 4781:7, 4790:20, 4808:13,
4827:3, 4827:6, 4827:8, 4827:10,
4827:11, 4827:14
names [2] - 4665:22, 4673:6
Napoli [12] - 4674:7, 4674:8, 4719:10,
4719:14, 4752:15, 4754:20, 4766:25,
4767:15, 4767:22, 4768:11, 4776:9,
4826:10
Napoli's [2] - 4768:6, 4768:10
national [1] - 4698:12
native [1] - 4855:5
naturalized [2] - 4648:10, 4701:1
nature [1] - 4663:24
navigated [1] - 4862:25
near [12] - 4696:9, 4697:5, 4699:8,
4699:18, 4699:20, 4701:5, 4701:13,
4702:11, 4702:15, 4716:24, 4716:25,
4859:25
nearby [1] - 4816:6
nearest [1] - 4786:13
necessary [8] - 4639:22, 4657:20,
4658:7, 4658:22, 4661:15, 4663:4,
4671:4, 4862:15
need [40] - 4636:3, 4637:5, 4640:1,
4642:21, 4644:24, 4666:7, 4666:25,
4667:12, 4668:20, 4681:19, 4682:3,
4682:5, 4688:15, 4693:11, 4696:19,
4697:13, 4702:25, 4704:25, 4705:23,
4707:4, 4724:18, 4731:10, 4743:16,
4752:5, 4752:7, 4761:9, 4770:11,

4779:12, 4781:22, 4783:17, 4783:19,
4791:7, 4794:2, 4809:20, 4818:5,
4820:5, 4825:5, 4850:8, 4859:1
needed [12] - 4666:20, 4668:6,
4668:24, 4671:8, 4677:3, 4770:9,
4772:21, 4779:14, 4783:12, 4819:19,
4828:9, 4828:10
needs [1] - 4683:9
neighborhood [1] - 4717:2
nephew [1] - 4811:20
Nero [72] - 4648:23, 4657:23, 4661:8,
4661:17, 4661:22, 4661:24, 4661:25,
4662:2, 4662:9, 4663:2, 4663:8,
4663:11, 4664:14, 4664:18, 4665:1,
4665:7, 4666:1, 4666:14, 4667:1,
4667:6, 4667:13, 4669:2, 4671:16,
4672:2, 4673:2, 4673:5, 4675:18,
4697:1, 4699:11, 4710:7, 4710:8,
4710:22, 4711:15, 4711:21, 4712:2,
4712:7, 4727:2, 4727:21, 4728:21,
4744:21, 4744:22, 4745:3, 4745:17,
4745:20, 4745:21, 4746:10, 4746:12,
4746:16, 4746:22, 4747:2, 4747:10,
4747:13, 4747:21, 4756:17, 4763:17,
4789:21, 4789:22, 4807:18, 4807:24,
4824:15, 4824:19, 4831:23, 4832:13,
4832:15, 4832:25, 4833:3, 4834:1,
4834:13, 4834:20, 4835:8
Nero's [6] - 4662:16, 4673:9, 4745:6,
4746:25, 4748:5, 4832:20
nero's [1] - 4662:18
nervous [2] - 4673:3, 4674:1
never [73] - 4641:3, 4641:4, 4660:6,
4660:10, 4660:12, 4668:18, 4669:10,
4673:6, 4676:16, 4677:22, 4678:18,
4679:13, 4683:14, 4710:2, 4710:3,
4710:4, 4711:2, 4719:14, 4720:4,
4725:15, 4733:21, 4754:19, 4762:23,
4763:15, 4763:16, 4763:17, 4763:18,
4763:19, 4763:20, 4763:21, 4764:14,
4764:15, 4764:16, 4764:18, 4767:16,
4767:17, 4768:11, 4770:25, 4771:3,
4773:9, 4776:5, 4776:20, 4778:4,
4778:13, 4778:25, 4779:2, 4782:17,
4784:2, 4788:7, 4788:8, 4788:18,
4791:10, 4791:11, 4791:20, 4793:25,
4796:17, 4798:12, 4799:10, 4801:18,
4801:21, 4803:18, 4807:21, 4831:13,
4834:1, 4834:14, 4834:16, 4863:9
Neville [2] - 4789:23, 4828:12
NEW [1] - 4633:1
new [20] - 4675:16, 4677:8, 4689:4,
4689:18, 4693:14, 4729:2, 4741:23,
4742:12, 4750:13, 4796:4, 4808:17,
4813:21, 4824:24, 4824:25, 4825:6,
4828:9, 4828:10, 4844:12
New [31] - 4633:5, 4633:16, 4633:23,
4633:24, 4634:2, 4634:5, 4634:9,
4646:11, 4650:5, 4680:14, 4710:15,
26
4714:3, 4714:5, 4714:12, 4714:15,

4714:18, 4714:21, 4715:5, 4715:12,
4715:19, 4715:25, 4716:9, 4725:2,
4725:10, 4725:12, 4733:18, 4747:17,
4756:24, 4828:4
news [1] - 4679:7
newspaper [1] - 4786:11
next [32] - 4643:10, 4678:9, 4678:15,
4678:22, 4688:18, 4692:10, 4697:5,
4697:8, 4699:17, 4700:4, 4703:14,
4704:14, 4726:11, 4727:18, 4732:13,
4741:22, 4766:1, 4771:24, 4774:3,
4787:4, 4797:12, 4800:14, 4809:14,
4810:7, 4818:18, 4838:10, 4842:23,
4847:7, 4852:14, 4853:11, 4859:18,
4860:12
nice [1] - 4644:3
niece [1] - 4769:5
night [7] - 4637:25, 4639:16, 4732:9,
4755:24, 4764:20, 4812:18, 4820:12
nightmare [5] - 4646:19, 4652:22,
4663:3, 4667:15, 4819:20
nilly [1] - 4817:10
nine [3] - 4750:6, 4750:10, 4796:20
Ninjas [3] - 4741:25, 4742:3, 4742:11
Nkrumah [23] - 4635:11, 4641:9,
4760:18, 4761:25, 4772:4, 4775:10,
4803:23, 4808:4, 4810:11, 4827:1,
4827:5, 4827:9, 4837:13, 4840:20,
4842:6, 4842:17, 4842:24, 4845:19,
4848:9, 4850:5, 4852:13, 4854:15,
4855:9
NKRUMAH [55] - 4634:2, 4635:10,
4637:17, 4638:22, 4639:4, 4641:13,
4641:19, 4642:2, 4642:12, 4644:20,
4708:12, 4758:25, 4760:22, 4761:3,
4761:6, 4761:10, 4761:21, 4762:3,
4762:4, 4762:5, 4762:7, 4762:9,
4767:10, 4768:8, 4768:11, 4771:18,
4772:12, 4772:16, 4772:23, 4773:1,
4773:16, 4773:19, 4773:23, 4774:1,
4775:11, 4784:25, 4788:1, 4788:18,
4795:1, 4795:20, 4796:2, 4801:1,
4802:14, 4802:17, 4803:2, 4803:5,
4805:16, 4805:25, 4823:21, 4838:5,
4851:15, 4852:25, 4862:8, 4866:10,
4867:6
Nkrumah's [2] - 4830:6, 4862:16
NO [2] - 4643:13, 4643:17
NO.1 [1] - 4643:1
nobody [9] - 4650:14, 4714:7, 4726:1,
4793:11, 4801:7, 4815:1, 4838:4,
4840:7
non [1] - 4648:13
none [7] - 4658:22, 4662:16, 4675:13,
4683:5, 4786:24, 4855:7, 4862:20
nonendorseable [1] - 4727:15
nonetheless [1] - 4650:23
nonparticipation [1] - 4801:10
nonprofit [1] - 4741:23


nonrefundable [1] - 4727:16
nonsense [2] - 4736:18, 4742:21
Noriega [1] - 4790:13
note [4] - 4678:7, 4699:23, 4785:8,
4866:2
noted [5] - 4634:18, 4638:10, 4707:3,
4860:10, 4861:1
notes [3] - 4768:6, 4768:10, 4785:6
nothing [51] - 4643:19, 4649:20,
4655:19, 4677:25, 4690:19, 4697:24,
4702:25, 4715:15, 4719:16, 4723:25,
4732:1, 4738:19, 4748:5, 4763:15,
4763:16, 4763:18, 4769:22, 4777:18,
4777:19, 4781:9, 4782:3, 4782:4,
4782:20, 4782:22, 4783:24, 4784:3,
4784:9, 4785:20, 4787:1, 4787:3,
4788:2, 4789:6, 4790:5, 4790:6,
4790:23, 4798:23, 4799:24, 4800:6,
4803:11, 4805:14, 4805:15, 4805:16,
4829:6, 4835:11, 4839:8, 4852:15,
4852:16, 4857:13, 4863:1
notice [3] - 4724:18, 4735:11, 4863:4
November [1] - 4750:20
nowhere [3] - 4733:20, 4768:8,
4769:24
Number [1] - 4717:23
number [16] - 4636:3, 4636:24,
4711:7, 4717:6, 4779:25, 4780:1,
4780:2, 4780:3, 4791:9, 4791:10,
4791:12, 4814:6, 4830:8, 4841:11
numbers [1] - 4644:12
Nur [65] - 4648:23, 4668:14, 4680:11,
4680:16, 4682:23, 4685:21, 4685:22,
4685:23, 4685:25, 4711:22, 4712:11,
4726:2, 4727:10, 4727:16, 4727:19,
4727:22, 4727:24, 4728:2, 4728:6,
4736:22, 4737:1, 4737:4, 4737:5,
4737:13, 4737:22, 4738:2, 4738:3,
4738:7, 4738:8, 4738:12, 4738:14,
4738:17, 4738:22, 4741:18, 4741:20,
4752:17, 4752:19, 4753:6, 4753:11,
4754:4, 4754:13, 4754:14, 4754:16,
4754:19, 4763:23, 4764:1, 4764:6,
4765:3, 4779:9, 4779:11, 4811:8,
4818:20, 4829:18, 4833:22, 4843:7,
4843:15, 4847:20, 4847:21, 4847:22,
4848:1, 4848:6, 4852:10
Nur's [2] - 4736:25, 4738:18
O
oath [4] - 4692:3, 4830:9, 4840:1,
4840:6
objection [13] - 4641:15, 4642:9,
4768:7, 4771:16, 4788:15, 4794:24,
4795:16, 4795:23, 4802:1, 4823:21,
4838:5, 4851:15, 4852:25
objectives [2] - 4763:11, 4803:19
obligation [1] - 4704:7
observe [1] - 4846:16

obtain [1] - 4753:11
obtained [1] - 4701:6
obvious [2] - 4839:11, 4854:10
obviously [6] - 4637:3, 4698:22,
4711:25, 4721:1, 4854:24, 4866:1
occupy [1] - 4713:12
October [1] - 4713:20
OF [2] - 4633:1, 4633:3
offense [2] - 4702:2, 4749:2
offensive [2] - 4849:14, 4857:6
offer [8] - 4714:10, 4716:2, 4725:5,
4733:9, 4734:14, 4734:19, 4757:8
offered [10] - 4733:22, 4736:17,
4756:23, 4757:1, 4757:8, 4770:5,
4776:25, 4828:3, 4828:18, 4863:23
offering [2] - 4711:12, 4863:4
offers [2] - 4732:10, 4733:11
offhand [1] - 4652:15
office [10] - 4651:1, 4715:14, 4726:8,
4727:19, 4728:1, 4728:5, 4728:10,
4728:25, 4791:12, 4833:7
Officer [4] - 4750:14, 4750:16,
4750:18
official [2] - 4728:2, 4752:16
Official [1] - 4634:8
officials [1] - 4856:13
Ogden [1] - 4816:1
old [6] - 4662:6, 4675:19, 4719:8,
4740:14, 4769:5, 4844:10
Omar [1] - 4730:5
on/off [1] - 4709:14
once [37] - 4642:7, 4659:20, 4664:10,
4666:3, 4675:23, 4676:21, 4677:7,
4683:14, 4685:25, 4687:4, 4689:3,
4689:17, 4690:3, 4692:22, 4693:5,
4693:10, 4693:12, 4694:5, 4702:20,
4702:22, 4704:23, 4714:4, 4714:6,
4729:25, 4731:25, 4733:22, 4735:6,
4738:13, 4739:3, 4739:20, 4750:15,
4758:5, 4794:21, 4848:2, 4856:15,
4859:22
One [4] - 4633:23, 4662:23, 4695:23,
4698:7
one [156] - 4636:24, 4637:4, 4638:22,
4642:8, 4643:10, 4644:4, 4644:12,
4646:4, 4647:20, 4651:15, 4655:17,
4655:20, 4656:13, 4659:11, 4659:12,
4660:1, 4660:2, 4661:18, 4662:6,
4662:17, 4663:6, 4666:8, 4668:7,
4668:15, 4669:13, 4669:21, 4669:24,
4674:13, 4675:11, 4676:23, 4679:20,
4680:18, 4688:21, 4690:7, 4691:5,
4692:24, 4693:9, 4694:3, 4696:19,
4697:7, 4699:25, 4702:6, 4716:22,
4717:22, 4718:1, 4722:9, 4724:11,
4724:13, 4724:14, 4726:2, 4727:22,
4728:22, 4729:15, 4730:7, 4731:10,
4732:2, 4732:3, 4732:4, 4732:8,
4732:10, 4736:2, 4736:9, 4737:4,
27
4738:21, 4742:17, 4743:13, 4743:15,

4744:8, 4744:9, 4744:10, 4745:22,
4746:2, 4746:3, 4746:10, 4746:13,
4751:6, 4752:18, 4757:23, 4761:9,
4764:4, 4764:24, 4765:3, 4765:4,
4766:9, 4767:4, 4768:20, 4775:16,
4775:25, 4776:2, 4776:9, 4777:14,
4780:22, 4781:23, 4781:24, 4783:5,
4784:1, 4784:13, 4784:17, 4785:25,
4786:13, 4789:15, 4791:2, 4791:13,
4797:11, 4798:12, 4801:12, 4802:14,
4802:15, 4803:24, 4809:14, 4811:5,
4814:6, 4815:8, 4817:25, 4823:17,
4824:22, 4825:5, 4827:14, 4828:1,
4830:8, 4830:11, 4830:18, 4830:22,
4832:5, 4841:9, 4842:16, 4843:22,
4846:13, 4847:7, 4847:13, 4848:2,
4849:4, 4849:6, 4849:18, 4851:7,
4852:16, 4854:2, 4854:3, 4855:13,
4855:19, 4855:20, 4855:22, 4856:6,
4857:1, 4858:19, 4860:1, 4860:4,
4862:9, 4864:6
ones [5] - 4650:21, 4690:24, 4722:24,
4812:24, 4834:11
open [7] - 4704:18, 4704:25, 4716:19,
4758:6, 4847:16, 4847:19, 4859:7
opened [3] - 4708:23, 4709:2, 4709:5
opening [6] - 4657:3, 4662:4, 4772:17,
4772:18, 4772:19, 4854:16
openly [1] - 4846:5
operate [2] - 4667:8, 4858:1
operating [2] - 4675:11, 4824:6
operational [4] - 4682:6, 4683:8,
4818:12, 4819:17
operative [5] - 4667:18, 4712:16,
4712:17, 4712:19, 4818:11
operatives [5] - 4658:3, 4670:15,
4690:11, 4690:14, 4746:14
operator [1] - 4752:3
operators [1] - 4820:6
opinion [1] - 4694:23
opinions [1] - 4859:8
opportune [1] - 4679:18
opportunities [3] - 4674:19, 4745:8,
4756:15
opportunity [9] - 4637:17, 4641:24,
4645:10, 4655:23, 4757:9, 4788:25,
4829:20, 4859:10, 4864:8
oppose [2] - 4638:14, 4639:4
opposed [1] - 4640:2
opposite [4] - 4668:1, 4675:12,
4694:7, 4815:3
oppression [3] - 4648:3, 4654:7,
4687:6
oppressors [2] - 4653:15, 4849:3
options [1] - 4686:6
order [16] - 4639:16, 4641:13,
4641:14, 4642:8, 4645:10, 4662:17,
4669:1, 4669:7, 4669:14, 4686:19,
4695:24, 4702:2, 4703:8, 4745:4,


4797:11, 4830:16
organization [1] - 4750:5
organizations [2] - 4654:16, 4688:5
organized [1] - 4684:7
original [2] - 4677:7, 4751:7
originally [1] - 4737:11
Osama [3] - 4794:6, 4794:9, 4815:2
otherwise [1] - 4835:19
ourselves [1] - 4762:18
outdo [1] - 4820:1
outlandish [1] - 4692:17
outline [1] - 4659:2
outside [4] - 4686:25, 4700:25,
4775:18, 4829:19
overhead [2] - 4669:22, 4703:4
overreacted [1] - 4857:16
overruled [4] - 4823:22, 4838:7,
4851:16, 4853:1
overseas [1] - 4766:21
overt [5] - 4771:18, 4772:5, 4772:8,
4775:9, 4865:5
overview [1] - 4685:23
overwhelming [2] - 4647:15, 4807:7
own [44] - 4647:18, 4647:23, 4649:9,
4649:22, 4651:19, 4651:20, 4653:1,
4654:4, 4659:7, 4660:15, 4662:19,
4679:22, 4683:17, 4691:4, 4703:23,
4715:16, 4725:16, 4733:15, 4733:17,
4735:2, 4737:12, 4739:14, 4748:14,
4748:16, 4781:23, 4785:16, 4800:12,
4806:17, 4806:20, 4807:8, 4808:5,
4808:18, 4808:24, 4809:7, 4809:17,
4810:25, 4818:1, 4818:24, 4822:5,
4822:6, 4848:10, 4849:5, 4863:2
P
p.m [5] - 4707:3, 4760:4, 4761:15,
4860:10, 4861:1
P.M [1] - 4805:19
pack [1] - 4840:17
packed [1] - 4837:14
pad [1] - 4815:9
page [16] - 4676:13, 4721:12, 4726:11,
4771:24, 4774:3, 4778:20, 4787:4,
4800:14, 4804:23, 4838:10, 4851:19,
4851:22, 4852:14, 4853:14, 4860:12,
4862:2
PAGE [1] - 4867:2
paid [8] - 4723:14, 4733:14, 4736:21,
4737:9, 4737:10, 4785:4, 4851:3,
4851:6
pain [1] - 4649:19
palpable [1] - 4822:25
panel [2] - 4642:20, 4643:20
papers [3] - 4641:8, 4641:9, 4641:11
paralysis [1] - 4692:12
parcel [1] - 4792:9
Parliament [4] - 4684:8, 4684:9,
4730:15, 4789:1
parliament [2] - 4653:1, 4819:1
parliamentarian [1] - 4789:4
part [49] - 4641:15, 4641:20, 4641:21,
4645:18, 4656:15, 4688:9, 4699:12,
4727:25, 4740:13, 4742:20, 4744:16,
4747:19, 4755:5, 4757:3, 4757:6,
4762:23, 4763:12, 4763:13, 4763:14,
4763:17, 4765:3, 4766:12, 4766:13,
4767:21, 4772:15, 4772:16, 4776:22,
4778:2, 4781:9, 4789:12, 4792:9,
4793:18, 4794:2, 4794:3, 4794:11,
4795:6, 4799:9, 4807:15, 4813:23,
4815:21, 4823:20, 4831:12, 4834:6,
4843:11, 4845:14, 4845:15, 4850:9,
4856:17, 4856:24
parte [1] - 4641:25
participants [1] - 4648:2
participate [6] - 4646:24, 4691:10,
4709:4, 4710:15, 4732:25, 4836:22
participated [2] - 4837:6, 4837:12
participation [4] - 4656:25, 4680:7,
4736:25, 4756:20
particular [14] - 4639:25, 4645:19,
4657:4, 4667:6, 4699:23, 4775:6,
4814:21, 4815:25, 4818:10, 4820:3,
4850:8, 4862:4, 4865:3
particularly [3] - 4650:5, 4751:10,
4825:7
parties [20] - 4637:5, 4638:17,
4638:24, 4638:25, 4639:2, 4639:17,
4639:24, 4640:12, 4644:15, 4705:14,
4708:8, 4760:15, 4761:18, 4761:24,
4804:19, 4805:22, 4861:18, 4861:25,
4864:9, 4865:7
partner [1] - 4813:1
partners [2] - 4691:19, 4783:24
parts [5] - 4725:23, 4775:7, 4818:16,
4824:16, 4840:11
party's [1] - 4640:16
pass [1] - 4757:15
passenger [3] - 4651:12, 4651:13,
4671:22
passengers [2] - 4821:2, 4821:4
passes [2] - 4666:4, 4743:2
passport [7] - 4828:7, 4850:16,
4851:18, 4851:20, 4851:22, 4852:19,
4853:7
past [3] - 4703:18, 4821:7, 4829:3
patently [1] - 4656:4
path [3] - 4782:2, 4811:14
pathetic [1] - 4723:20
patience [1] - 4858:22
Pause [1] - 4707:19
pause [6] - 4634:19, 4707:10, 4707:15,
4721:10, 4826:3, 4844:19
pay [11] - 4684:12, 4714:17, 4725:14,
4725:16, 4725:18, 4728:3, 4750:3,
4788:4, 4809:20, 4812:20, 4851:6
paying [4] - 4715:8, 4737:13, 4737:17,
4851:2
peace [1] - 4747:23
peaceful [3] - 4854:17, 4854:22,
4855:2
peas [1] - 4719:11
pending [2] - 4685:13, 4714:6
penetrate [2] - 4666:21, 4833:18
people [101] - 4647:3, 4647:11,
4647:19, 4648:22, 4654:14, 4654:20,
4657:9, 4661:12, 4661:14, 4663:9,
4663:19, 4663:25, 4664:4, 4671:22,
4673:15, 4673:17, 4673:19, 4676:20,
4677:23, 4681:15, 4684:13, 4684:14,
4684:15, 4685:7, 4690:8, 4693:25,
4694:6, 4694:22, 4696:6, 4696:13,
4697:3, 4697:4, 4697:10, 4703:23,
4711:17, 4719:6, 4724:14, 4724:15,
4724:18, 4725:23, 4727:21, 4736:17,
4749:7, 4751:24, 4762:11, 4773:10,
4777:15, 4779:3, 4779:4, 4782:4,
4782:5, 4783:11, 4784:11, 4786:20,
4789:2, 4790:12, 4790:13, 4790:14,
4790:15, 4790:18, 4792:12, 4792:18,
4792:20, 4795:20, 4796:17, 4799:2,
4802:19, 4802:22, 4803:12, 4814:23,
4814:24, 4815:9, 4815:11, 4815:20,
4815:21, 4815:22, 4816:10, 4818:8,
4819:16, 4820:12, 4820:15, 4821:18,
4823:6, 4833:6, 4835:4, 4840:8,
4848:11, 4850:15, 4853:16, 4853:22,
4854:22, 4857:4, 4857:8, 4857:10,
4857:11
people's [1] - 4697:1
percent [3] - 4666:19, 4772:14,
4812:16
perfectly [1] - 4684:3
perform [1] - 4828:22
perhaps [7] - 4637:9, 4641:2, 4641:5,
4694:19, 4820:12, 4820:13, 4864:10
perimeter [1] - 4718:10
period [1] - 4642:1
permission [11] - 4674:7, 4690:5,
4701:6, 4701:15, 4701:18, 4702:21,
4702:23, 4724:12, 4724:17, 4724:18,
4845:6
permit [2] - 4644:8, 4773:14
person [28] - 4651:13, 4655:24,
4665:5, 4668:7, 4679:4, 4680:11,
4680:17, 4685:11, 4688:23, 4702:25,
4710:16, 4710:17, 4711:20, 4743:6,
4764:24, 4790:16, 4806:14, 4811:25,
4818:2, 4818:3, 4818:18, 4828:21,
4832:18, 4835:15, 4851:9, 4851:11,
4852:1, 4864:3
personal [7] - 4653:10, 4724:24,
4734:9, 4747:9, 4747:11, 4802:12,
4808:12
personally [2] - 4679:22, 4729:23
persons [2] - 4692:15, 4845:6
persuaded [1] - 4641:7

28

pertinent [1] - 4766:24
Peter [10] - 4651:2, 4669:9, 4696:5,
4697:4, 4701:16, 4702:22, 4815:19,
4816:13, 4816:23, 4822:9
ph [3] - 4730:5, 4737:12, 4789:22
philosophical [1] - 4653:10
phone [38] - 4646:17, 4664:14, 4678:1,
4680:13, 4692:10, 4711:15, 4722:10,
4743:2, 4744:5, 4744:15, 4765:7,
4765:8, 4765:10, 4765:11, 4776:12,
4776:16, 4776:17, 4777:16, 4780:3,
4780:15, 4782:21, 4791:8, 4791:9,
4791:10, 4812:6, 4835:10, 4840:9,
4840:11, 4844:5, 4844:10, 4846:7,
4847:8, 4847:10, 4847:25
phones [5] - 4705:3, 4712:4, 4758:9,
4758:11, 4804:13
phony [1] - 4780:1
photo [1] - 4855:19
photograph [1] - 4724:15
photographs [8] - 4807:10, 4817:14,
4817:15, 4854:14, 4854:16, 4854:19,
4858:17
photos [4] - 4647:13, 4731:4, 4855:1,
4855:2
physical [1] - 4696:2
pick [4] - 4670:9, 4681:17, 4682:15,
4751:24
picked [3] - 4681:14, 4751:18, 4809:10
picks [1] - 4742:17
picture [8] - 4743:23, 4764:24,
4785:24, 4786:3, 4786:4
pictures [13] - 4658:15, 4669:4,
4671:4, 4688:16, 4785:22, 4786:2,
4788:6, 4788:7, 4788:8, 4788:19,
4791:18, 4794:14
piece [5] - 4677:8, 4722:10, 4798:13,
4824:24, 4862:4
pieces [1] - 4792:21
Pierrepont [1] - 4633:23
pin [1] - 4856:1
pipeline [4] - 4646:14, 4650:22,
4696:11, 4718:6
pipelines [11] - 4647:3, 4650:19,
4657:8, 4661:3, 4695:10, 4695:14,
4697:20, 4701:9, 4816:4, 4817:22,
4820:5
pissed [1] - 4728:24
pitch [11] - 4830:2, 4830:11, 4833:21,
4836:2, 4836:12, 4837:19, 4837:21,
4839:13, 4850:6, 4853:24, 4854:6
pitched [3] - 4812:11, 4821:16, 4836:5
pitches [2] - 4686:10, 4837:22
pitching [1] - 4841:7
place [39] - 4647:20, 4649:18, 4671:1,
4671:5, 4674:12, 4695:25, 4698:9,
4700:22, 4701:5, 4701:12, 4702:10,
4702:15, 4703:14, 4707:1, 4714:3,
4714:20, 4715:21, 4716:8, 4718:5,
4720:11, 4721:14, 4721:16, 4721:17,
4721:21, 4721:22, 4721:23, 4733:11,

4746:23, 4769:25, 4778:21, 4786:24,
4795:12, 4795:14, 4796:2, 4828:9,
4828:11, 4836:4, 4859:13
places [5] - 4709:25, 4779:24,
4793:16, 4798:25, 4829:6
placing [5] - 4650:25, 4699:7, 4699:9,
4699:18, 4699:19
plan [90] - 4646:9, 4646:10, 4646:11,
4646:12, 4657:6, 4657:12, 4657:15,
4657:19, 4657:23, 4658:4, 4658:9,
4658:13, 4662:2, 4664:11, 4664:12,
4667:10, 4667:23, 4670:11, 4671:1,
4673:24, 4675:8, 4678:25, 4679:17,
4680:23, 4681:10, 4682:14, 4687:6,
4687:11, 4687:13, 4687:17, 4688:24,
4689:5, 4691:10, 4691:14, 4692:17,
4693:4, 4693:24, 4694:5, 4696:9,
4696:24, 4697:19, 4699:12, 4700:12,
4704:1, 4708:24, 4709:4, 4713:3,
4738:4, 4738:18, 4740:1, 4741:17,
4741:22, 4743:7, 4744:8, 4748:14,
4765:23, 4769:4, 4770:2, 4776:22,
4778:23, 4781:9, 4783:8, 4784:1,
4784:6, 4790:3, 4793:13, 4793:14,
4795:6, 4798:12, 4807:18, 4813:7,
4813:10, 4813:21, 4831:24, 4832:3,
4832:4, 4834:12, 4836:21, 4840:3,
4842:7, 4842:11, 4847:22, 4853:11,
4853:17, 4853:19, 4854:5, 4854:6,
4858:7
plane [29] - 4658:22, 4689:19,
4700:18, 4703:3, 4710:12, 4714:17,
4715:22, 4719:18, 4722:8, 4733:14,
4733:17, 4733:23, 4752:25, 4754:4,
4756:23, 4757:2, 4828:25, 4829:9,
4829:11, 4829:16, 4829:18, 4830:4,
4843:23, 4844:1, 4845:14, 4845:16,
4851:9, 4853:7
planes [8] - 4699:17, 4699:23,
4699:24, 4718:23, 4817:10, 4825:24,
4837:25, 4845:19
planned [9] - 4659:1, 4670:7, 4670:23,
4671:1, 4700:24, 4740:8, 4833:20,
4850:6, 4853:6
planning [8] - 4648:25, 4672:20,
4675:24, 4690:24, 4746:21, 4747:4,
4769:14, 4850:15
plans [11] - 4688:25, 4713:16, 4733:1,
4743:11, 4776:24, 4777:1, 4782:1,
4783:9, 4790:6, 4814:13, 4855:4
plant [1] - 4700:16
plastic [3] - 4855:21, 4855:24, 4856:3
plate [2] - 4816:20, 4817:1
plausible [2] - 4675:8, 4676:11
play [10] - 4687:24, 4707:11, 4722:14,
4747:14, 4752:4, 4754:22, 4824:17,
4824:18, 4839:8, 4860:2
played [34] - 4649:3, 4649:14,
4649:23, 4650:7, 4651:8, 4664:21,
29
4668:16, 4670:3, 4671:25, 4672:16,

4674:21, 4678:5, 4679:2, 4679:25,
4680:24, 4682:17, 4683:19, 4689:9,
4698:2, 4719:9, 4722:17, 4722:25,
4723:4, 4740:11, 4741:8, 4755:10,
4789:18, 4791:19, 4812:9, 4833:14,
4837:20, 4837:24, 4838:3, 4839:2
players [1] - 4763:11
playing [4] - 4791:23, 4831:5, 4832:6,
4855:15
Plaza [3] - 4633:16, 4633:23, 4634:9
plea [1] - 4796:8
plead [2] - 4745:25, 4746:4
pleading [2] - 4662:20, 4662:22
pleased [3] - 4671:16, 4671:18, 4689:5
pled [3] - 4661:22, 4834:21, 4835:5
plenty [1] - 4849:16
plot [156] - 4646:25, 4647:8, 4647:25,
4648:7, 4648:22, 4653:6, 4654:19,
4654:24, 4655:16, 4656:10, 4656:22,
4656:24, 4656:25, 4657:25, 4658:20,
4659:9, 4660:21, 4661:9, 4661:25,
4662:11, 4662:21, 4663:7, 4663:10,
4663:19, 4665:24, 4666:1, 4666:12,
4675:1, 4675:6, 4675:18, 4677:15,
4678:12, 4679:23, 4680:5, 4680:7,
4680:9, 4681:5, 4681:12, 4682:25,
4683:6, 4683:8, 4685:23, 4686:10,
4686:14, 4686:15, 4686:20, 4687:19,
4687:25, 4688:3, 4688:11, 4688:17,
4689:3, 4689:15, 4689:18, 4689:23,
4690:1, 4690:2, 4692:7, 4693:15,
4695:9, 4697:2, 4710:5, 4710:13,
4710:16, 4711:19, 4711:24, 4713:23,
4728:18, 4735:3, 4740:6, 4740:9,
4745:10, 4757:7, 4763:22, 4766:17,
4767:12, 4769:18, 4769:22, 4784:10,
4785:14, 4807:19, 4807:20, 4807:23,
4808:19, 4808:23, 4811:8, 4812:8,
4812:12, 4812:13, 4812:17, 4813:1,
4813:10, 4813:16, 4814:3, 4814:7,
4818:12, 4819:16, 4819:19, 4820:5,
4821:16, 4823:19, 4828:14, 4829:21,
4830:2, 4830:3, 4830:10, 4830:11,
4830:16, 4831:12, 4831:15, 4831:17,
4831:20, 4831:21, 4833:1, 4833:7,
4833:11, 4833:21, 4834:11, 4836:5,
4836:9, 4836:13, 4837:1, 4837:5,
4837:10, 4837:11, 4837:19, 4837:21,
4837:23, 4839:13, 4840:11, 4841:7,
4841:18, 4841:20, 4842:13, 4842:20,
4842:25, 4844:21, 4844:22, 4845:12,
4845:17, 4847:11, 4847:12, 4848:7,
4848:10, 4849:18, 4849:22, 4850:1,
4850:6, 4853:24, 4854:11, 4854:25,
4856:18, 4864:19
plot's [1] - 4648:4
plots [5] - 4665:14, 4765:22, 4833:7,
4857:9, 4857:12
plotted [1] - 4659:24


plotter's [2] - 4667:10, 4667:22
plotters [19] - 4665:19, 4666:6,
4668:18, 4671:7, 4672:21, 4681:9,
4696:24, 4697:12, 4819:14, 4833:17,
4833:20, 4836:5, 4839:23, 4840:16,
4840:23, 4841:2, 4841:5, 4841:10,
4843:4
plotting [7] - 4647:17, 4667:20,
4808:15, 4828:21, 4830:1, 4830:24,
4857:4
plumber [1] - 4731:22
plus [3] - 4652:16, 4770:12, 4796:22
podium [3] - 4642:14, 4694:20,
4760:25
point [40] - 4637:7, 4638:17, 4645:1,
4663:12, 4666:7, 4670:6, 4675:3,
4678:23, 4680:14, 4684:17, 4705:25,
4713:10, 4717:3, 4722:9, 4730:7,
4767:4, 4767:14, 4767:24, 4776:18,
4806:3, 4814:9, 4817:19, 4824:1,
4825:9, 4825:18, 4825:19, 4826:1,
4826:4, 4829:10, 4831:11, 4831:14,
4840:20, 4841:17, 4842:14, 4843:9,
4854:15, 4854:18, 4857:1, 4866:3
pointed [3] - 4711:6, 4765:14, 4820:11
points [7] - 4746:15, 4817:21, 4830:5,
4832:24, 4864:15, 4864:17, 4864:18
police [7] - 4668:11, 4684:7, 4697:9,
4713:13, 4719:6, 4817:3, 4818:24
political [1] - 4687:22
politician [1] - 4652:25
pony [1] - 4725:20
Ponytail [10] - 4664:14, 4710:11,
4710:12, 4710:18, 4711:15, 4711:21,
4715:11, 4720:14, 4727:21
poor [1] - 4789:1
pop [1] - 4718:13
pops [4] - 4764:13, 4797:11, 4797:12
Port [6] - 4651:2, 4669:9, 4701:17,
4754:5, 4817:3, 4822:10
portion [1] - 4812:2
portions [6] - 4722:14, 4755:8,
4824:18, 4825:21, 4825:23, 4826:3
pose [1] - 4855:9
poses [2] - 4855:12
position [4] - 4653:7, 4654:23,
4862:12, 4863:25
possibility [4] - 4691:15, 4734:24,
4770:4, 4781:14
possible [11] - 4665:20, 4669:11,
4669:19, 4670:9, 4671:13, 4671:14,
4681:9, 4770:8, 4827:16, 4840:3,
4840:4
possibly [4] - 4662:6, 4766:21,
4827:14, 4835:17
post [2] - 4651:1, 4861:8
posted [3] - 4637:25, 4638:2, 4697:7
poster [1] - 4712:25
posting [2] - 4638:1, 4638:24
potatoes [1] - 4719:11
poverty [1] - 4786:20

power [1] - 4823:11
powered [1] - 4855:9
powerful [2] - 4659:6, 4666:25
Praise [1] - 4671:17
praises [1] - 4720:1
praying [1] - 4755:14
precautions [2] - 4687:15, 4812:3
precisely [1] - 4664:4
predict [3] - 4814:10, 4814:12,
4814:19
predicted [1] - 4863:12
prefer [3] - 4679:14, 4684:15, 4772:10
pregnant [1] - 4661:14
preparation [1] - 4850:19
prerogative [1] - 4704:11
prescribe [1] - 4790:16
presence [3] - 4644:7, 4707:1, 4785:3
present [30] - 4642:4, 4644:17, 4645:7,
4658:4, 4658:20, 4667:10, 4667:23,
4667:25, 4673:24, 4675:1, 4675:6,
4677:15, 4680:9, 4680:23, 4682:14,
4688:19, 4689:22, 4708:9, 4735:19,
4739:21, 4755:5, 4760:15, 4761:19,
4804:19, 4805:23, 4824:14, 4847:22,
4857:20, 4861:3
presented [14] - 4654:19, 4682:4,
4688:11, 4711:17, 4716:3, 4724:15,
4735:11, 4744:21, 4746:13, 4751:3,
4752:21, 4755:1, 4757:22, 4802:4
presenting [1] - 4687:19
presents [2] - 4687:5, 4743:25
pressure [2] - 4826:8, 4862:17
pretend [2] - 4684:1, 4751:21
pretended [3] - 4680:19, 4691:10,
4842:12
pretending [10] - 4651:13, 4660:3,
4807:6, 4836:13, 4839:14, 4839:15,
4839:19, 4848:4, 4856:19, 4856:25
pretends [1] - 4683:1
pretty [10] - 4647:10, 4713:10,
4743:21, 4746:6, 4746:23, 4751:9,
4752:15, 4755:12, 4852:11, 4859:1
prevent [1] - 4722:8
previous [1] - 4639:14
previously [2] - 4692:4, 4841:3
price [1] - 4857:24
primary [2] - 4697:18, 4849:7
prime [2] - 4684:9, 4818:25
principle [1] - 4802:6
principles [1] - 4645:5
prints [1] - 4732:10
prison [13] - 4746:1, 4749:24, 4749:25,
4750:7, 4792:25, 4795:11, 4795:12,
4795:21, 4796:2, 4796:5, 4797:3,
4835:8, 4835:19
Probation [4] - 4750:14, 4750:15,
4750:18
probation [3] - 4748:17, 4748:22,
4749:5
30
problem [1] - 4713:25

problems [3] - 4677:24, 4684:15,
4823:12
procedure [2] - 4642:9, 4756:5
proceed [7] - 4642:18, 4644:4, 4644:9,
4645:24, 4646:1, 4708:18, 4806:5
proceeding [1] - 4634:19
proceedings [1] - 4640:9
proceeds [1] - 4845:11
process [2] - 4638:1, 4638:15
produce [2] - 4800:7, 4813:17
Produced [1] - 4634:12
production [1] - 4636:1
products [4] - 4712:1, 4823:4, 4823:5,
4823:8
professional [1] - 4823:25
profit [1] - 4648:13
program [2] - 4690:13, 4786:7
project [2] - 4813:18, 4844:13
prominence [2] - 4654:23, 4687:22
prominent [5] - 4652:25, 4665:16,
4665:18, 4685:11, 4819:21
promise [1] - 4746:8
promised [1] - 4744:24
promises [2] - 4738:2, 4746:5
proof [7] - 4645:11, 4681:23, 4704:9,
4734:20, 4748:7, 4748:8, 4865:8
proper [1] - 4664:16
properly [6] - 4644:17, 4673:6, 4708:9,
4761:19, 4788:9, 4805:23
property [3] - 4698:19, 4698:21
prophet [1] - 4826:21
proposal [1] - 4820:1
proposals [2] - 4734:11, 4863:8
proposed [6] - 4639:12, 4661:20,
4691:12, 4729:13, 4820:3, 4864:12
proposes [1] - 4734:10
prosecute [1] - 4858:10
prosecuted [1] - 4796:14
prosecuting [1] - 4857:23
prosecution [1] - 4645:11
prosecutor [2] - 4748:21, 4748:23
prospective [2] - 4862:25, 4865:8
protect [8] - 4688:5, 4762:18, 4762:19,
4799:23, 4799:24, 4827:23, 4857:16,
4857:20
protecting [3] - 4688:6, 4696:25,
4857:22
protects [1] - 4688:6
proud [1] - 4789:2
prove [16] - 4657:21, 4658:7, 4701:22,
4702:21, 4716:4, 4720:19, 4734:22,
4757:5, 4786:6, 4814:20, 4815:4,
4832:19, 4849:19, 4849:20, 4850:8,
4850:9
proved [1] - 4701:20
proven [3] - 4647:23, 4661:1, 4691:25
proves [1] - 4837:6
provide [5] - 4638:5, 4638:16,


4728:24, 4749:5, 4783:4
provided [4] - 4638:9, 4709:16,
4829:5, 4836:7
provider [3] - 4701:7, 4701:12,
4701:24
providing [3] - 4655:8, 4658:17,
4856:12
province [1] - 4773:15
PTA [1] - 4676:15
public [11] - 4661:23, 4669:10,
4683:14, 4685:17, 4695:24, 4696:5,
4707:20, 4716:19, 4723:22, 4779:24,
4816:15
publicized [3] - 4812:22, 4812:24,
4819:12
publicly [1] - 4703:12
pull [2] - 4694:20, 4800:2
pulling [1] - 4856:1
purchased [5] - 4737:7, 4754:18,
4829:12, 4829:14, 4829:19
purification [3] - 4720:22, 4740:5,
4742:23
purified [1] - 4823:15
purifier [3] - 4740:7, 4740:10, 4756:13
purify [1] - 4720:23
purpose [3] - 4645:15, 4814:17,
4829:17
purposes [1] - 4865:14
pursue [1] - 4819:3
pursuing [2] - 4807:20, 4830:1
pursuit [1] - 4807:18
push [1] - 4813:24
pushed [1] - 4826:3
pushing [1] - 4782:8
put [28] - 4650:12, 4651:16, 4651:24,
4653:5, 4655:10, 4662:6, 4674:2,
4674:17, 4676:2, 4679:1, 4692:16,
4692:20, 4717:18, 4761:6, 4784:24,
4785:22, 4786:3, 4794:13, 4794:14,
4794:15, 4821:4, 4843:22, 4844:15,
4845:11, 4852:11
puts [1] - 4846:12
putting [6] - 4697:1, 4702:17, 4724:18,
4801:14, 4803:8, 4821:7
Q
Qaeda [14] - 4657:4, 4667:4, 4667:6,
4667:18, 4668:4, 4673:21, 4712:15,
4712:17, 4712:19, 4746:13, 4746:18,
4818:9, 4818:10, 4820:19
quality [1] - 4748:22
quarter [5] - 4758:3, 4758:18, 4759:2,
4804:16, 4804:20
Queens [3] - 4646:15, 4697:13,
4698:11
questioned [2] - 4673:9, 4756:4
questions [11] - 4670:19, 4674:9,
4686:20, 4694:12, 4749:12, 4749:13,
4749:14, 4753:2, 4755:25, 4816:19,

4817:6
quick [4] - 4705:14, 4711:11, 4830:5,
4853:9
quickly [8] - 4696:22, 4735:25,
4813:23, 4816:11, 4816:12, 4825:12,
4850:2, 4854:13
quiet [1] - 4648:17
quietly [1] - 4648:10
quite [4] - 4639:13, 4675:12, 4776:21,
4786:15
R
Rabbani [7] - 4790:20, 4790:22,
4791:4, 4791:11, 4839:17, 4854:7
Rabbani's [1] - 4791:8
races [1] - 4710:14
radical [3] - 4668:9, 4675:1, 4675:6
radicalized [1] - 4662:9
rage [3] - 4648:17, 4649:12, 4673:1
Rail [1] - 4720:7
raise [5] - 4640:16, 4685:12, 4758:22,
4837:1, 4861:14
raised [3] - 4641:8, 4862:19, 4864:15
raising [2] - 4658:16, 4683:3
Ramadan [4] - 4665:7, 4711:16,
4714:2, 4731:22
ran [3] - 4676:8, 4816:2, 4816:6
range [1] - 4673:4
Ranger [1] - 4785:16
ranking [1] - 4854:7
rapt [1] - 4745:21
rare [1] - 4806:18
rarely [2] - 4749:15, 4816:15
rather [3] - 4676:10, 4847:13, 4863:14
rational [1] - 4835:14
RD [1] - 4714:23
RD-A [1] - 4714:23
re [1] - 4647:17
re-handed [1] - 4647:17
reach [3] - 4654:21, 4670:10, 4675:6
reached [1] - 4645:1
reaching [2] - 4819:15, 4819:21
reaction [1] - 4689:5
read [24] - 4641:13, 4705:4, 4758:12,
4758:15, 4771:5, 4771:7, 4772:12,
4773:3, 4773:4, 4773:5, 4773:13,
4780:7, 4785:7, 4785:8, 4786:19,
4791:2, 4791:5, 4791:6, 4799:9,
4801:1, 4804:9, 4859:14
readily [1] - 4793:17
reading [6] - 4773:18, 4780:8, 4780:9,
4801:2, 4816:20, 4817:1
ready [9] - 4643:8, 4673:24, 4708:18,
4761:11, 4762:2, 4793:25, 4805:4,
4850:16, 4861:24
real [15] - 4676:6, 4698:18, 4698:19,
4713:15, 4713:16, 4718:8, 4740:11,
31
4740:12, 4742:22, 4781:7, 4853:7,

4855:13, 4855:16, 4856:6
realistic [1] - 4820:17
reality [7] - 4646:19, 4652:22, 4657:19,
4663:4, 4667:16, 4713:17, 4819:20
realize [3] - 4635:18, 4635:19, 4635:20
realized [8] - 4659:21, 4668:23,
4692:2, 4692:23, 4707:6, 4728:22,
4728:23, 4801:6
realizes [4] - 4652:5, 4741:13,
4741:15, 4741:17
really [36] - 4637:1, 4640:22, 4665:2,
4673:5, 4696:4, 4696:8, 4710:2,
4710:3, 4710:4, 4716:20, 4718:25,
4733:8, 4738:6, 4741:5, 4746:7,
4750:12, 4751:15, 4751:16, 4764:2,
4772:10, 4775:23, 4783:8, 4787:1,
4795:14, 4797:6, 4801:13, 4814:8,
4831:4, 4831:13, 4831:20, 4837:11,
4848:4, 4852:12, 4853:2, 4858:25
reason [28] - 4655:21, 4656:23,
4669:10, 4682:22, 4684:2, 4684:19,
4685:11, 4693:6, 4694:1, 4707:14,
4723:4, 4727:7, 4762:12, 4790:24,
4790:25, 4798:8, 4798:19, 4804:14,
4821:17, 4821:20, 4821:23, 4837:9,
4839:11, 4856:9, 4856:13, 4857:2,
4864:3
reasonable [15] - 4647:24, 4658:10,
4661:1, 4692:1, 4734:21, 4734:23,
4748:7, 4748:9, 4752:9, 4757:5,
4806:19, 4820:17, 4830:21, 4837:7,
4838:6
reasons [12] - 4783:21, 4821:12,
4822:4, 4822:22, 4823:18, 4838:1,
4839:19, 4839:20, 4849:18, 4863:22,
4864:7
rebut [1] - 4645:10
Rebuttal [2] - 4805:1, 4867:7
rebuttal [5] - 4760:20, 4804:4, 4806:3,
4806:6, 4864:14
receipt [1] - 4851:4
receipts [1] - 4851:7
receive [1] - 4668:17
received [6] - 4638:13, 4641:12,
4645:13, 4674:7, 4690:1, 4765:7
recess [2] - 4706:6, 4759:3
Recess [1] - 4804:22
recognizable [1] - 4665:23
recognized [1] - 4653:3
recollection [6] - 4746:25, 4788:17,
4802:9, 4802:11, 4838:8
recommending [1] - 4731:21
record [9] - 4635:1, 4639:11, 4668:10,
4673:25, 4723:18, 4735:19, 4766:8,
4865:14, 4865:22
recorded [22] - 4651:19, 4651:20,
4659:10, 4705:5, 4739:11, 4765:6,
4769:24, 4793:18, 4797:19, 4797:21,
4797:24, 4798:3, 4798:4, 4798:5,


4798:6, 4798:7, 4806:20, 4832:8,
4858:14
recorder [1] - 4832:18
recording [27] - 4710:25, 4711:1,
4711:4, 4711:17, 4712:16, 4724:9,
4729:8, 4729:10, 4732:6, 4735:7,
4735:20, 4736:1, 4736:13, 4739:20,
4747:16, 4747:18, 4756:2, 4756:7,
4766:18, 4768:20, 4832:17, 4834:2,
4835:22, 4846:11, 4854:12
Recording [1] - 4741:8
recordings [45] - 4646:5, 4649:8,
4655:2, 4659:12, 4659:17, 4711:8,
4711:23, 4712:14, 4716:21, 4721:5,
4722:5, 4729:5, 4729:7, 4729:14,
4729:15, 4729:18, 4735:15, 4738:1,
4740:15, 4742:25, 4743:15, 4743:21,
4743:24, 4744:3, 4748:12, 4752:12,
4755:7, 4755:8, 4756:16, 4763:1,
4779:1, 4806:18, 4807:9, 4809:7,
4831:3, 4832:19, 4833:5, 4833:8,
4833:11, 4833:15, 4833:23, 4846:16,
4848:8
records [5] - 4701:17, 4776:12,
4776:13, 4776:16, 4776:17
recovers [1] - 4735:25
recruit [5] - 4657:24, 4663:13, 4709:3,
4710:15
recruited [3] - 4662:3, 4807:18,
4833:10
recruiting [4] - 4648:22, 4663:7,
4690:11, 4810:21
recruits [1] - 4690:12
recycling [1] - 4700:16
red [4] - 4655:19, 4718:2, 4806:11,
4806:23
red-handed [2] - 4655:19, 4806:23
reduce [2] - 4647:12, 4835:18
reduced [1] - 4672:19
refer [1] - 4771:22
referenced [1] - 4815:9
referring [2] - 4803:1, 4847:3
reflected [1] - 4654:3
refrain [1] - 4802:12
refund [1] - 4844:1
refunded [1] - 4845:16
refunds [1] - 4845:22
regard [1] - 4775:6
regarding [1] - 4735:21
region [2] - 4687:23, 4830:2
regular [2] - 4666:24, 4790:14
rehabilitate [6] - 4840:16, 4840:17,
4840:18, 4840:23, 4841:2, 4841:9
rehabilitated [1] - 4693:8
rehabilitating [2] - 4683:4, 4840:22
rehabilitation [7] - 4693:11, 4695:2,
4840:14, 4841:1, 4841:5, 4841:8,
4841:13
reject [1] - 4645:17
relate [1] - 4775:2
related [2] - 4824:4, 4843:23

relates [1] - 4696:15
relation [1] - 4691:13
relations [3] - 4692:21, 4783:14,
4783:16
relationship [4] - 4693:6, 4731:3,
4747:12, 4856:14
relationships [1] - 4856:12
relative [1] - 4793:3
relatively [1] - 4719:22
release [3] - 4637:14, 4637:19,
4746:24
released [2] - 4750:7, 4750:11
relevance [3] - 4656:16, 4670:21,
4817:12
relevant [4] - 4824:18, 4825:21,
4825:22, 4826:3
religion [4] - 4656:15, 4656:16,
4656:23, 4857:13
religious [14] - 4652:25, 4653:19,
4653:25, 4654:2, 4665:18, 4687:22,
4784:13, 4784:19, 4786:11, 4786:16,
4855:2, 4855:4, 4855:6, 4855:8
religiously [1] - 4792:4
reluctant [1] - 4687:21
remains [1] - 4813:19
remark [2] - 4795:24, 4803:4
remarks [1] - 4652:15
remember [110] - 4654:18, 4655:4,
4660:5, 4661:8, 4661:18, 4662:1,
4662:4, 4664:18, 4665:6, 4670:14,
4674:4, 4684:21, 4684:25, 4694:11,
4699:21, 4704:16, 4704:20, 4705:4,
4720:20, 4733:22, 4734:5, 4738:20,
4747:2, 4747:3, 4747:4, 4747:7,
4747:9, 4747:10, 4749:11, 4749:22,
4749:25, 4750:12, 4751:4, 4751:23,
4755:10, 4758:7, 4758:10, 4765:18,
4769:19, 4780:24, 4783:5, 4783:25,
4786:7, 4786:14, 4789:17, 4796:8,
4797:25, 4802:8, 4804:5, 4804:12,
4809:25, 4811:9, 4811:12, 4811:17,
4811:18, 4811:23, 4811:25, 4812:4,
4812:13, 4812:16, 4813:11, 4813:15,
4815:19, 4819:24, 4820:24, 4821:2,
4821:14, 4821:17, 4823:24, 4824:1,
4824:16, 4824:21, 4824:24, 4825:20,
4825:23, 4826:8, 4827:2, 4828:2,
4828:5, 4828:15, 4829:9, 4833:25,
4834:10, 4834:14, 4834:17, 4834:18,
4837:23, 4839:19, 4839:25, 4840:9,
4842:21, 4843:1, 4843:6, 4843:15,
4843:24, 4844:3, 4844:6, 4844:11,
4844:19, 4846:3, 4846:8, 4846:14,
4848:15, 4850:5, 4850:10, 4853:10,
4854:20, 4859:5, 4859:8
remembers [1] - 4693:23
remind [6] - 4645:22, 4657:2, 4704:7,
4705:3, 4753:8, 4758:5
remorse [1] - 4750:23
32
remote [1] - 4839:5

remotely [1] - 4679:14
remove [1] - 4644:22
rendering [1] - 4645:6
renew [1] - 4866:3
renewed [2] - 4851:21, 4851:22
rent [1] - 4750:3
repeat [3] - 4764:16, 4799:16, 4865:5
repeatedly [4] - 4721:7, 4813:16,
4816:8, 4835:21
repeating [2] - 4679:7, 4715:11
replacing [1] - 4643:7
reply [3] - 4638:13, 4638:20, 4638:21
report [8] - 4677:18, 4754:20, 4766:20,
4766:23, 4766:24, 4767:2, 4767:4
reported [5] - 4758:13, 4767:17,
4804:10, 4811:9, 4859:15
Reporter [2] - 4634:8, 4634:8
reporter [1] - 4805:10
reporters [1] - 4809:3
reporting [2] - 4750:13, 4829:15
reports [2] - 4789:4, 4818:15
Republic [1] - 4689:21
request [9] - 4638:3, 4638:21, 4639:7,
4862:3, 4865:17, 4865:25, 4866:3,
4866:8
requested [10] - 4638:5, 4638:7,
4638:10, 4638:20, 4639:15, 4640:13,
4640:18, 4640:25, 4861:7, 4864:21
require [3] - 4695:17, 4853:9, 4865:5
required [1] - 4865:2
requirement [3] - 4772:6, 4775:8,
4786:16
requirements [1] - 4775:3
requires [3] - 4700:21, 4702:21,
4814:20
reread [1] - 4849:10
research [6] - 4640:23, 4705:6,
4758:14, 4758:16, 4804:11, 4859:16
reseated [1] - 4644:16
resentful [1] - 4648:18
resentment [1] - 4649:11
reservation [1] - 4852:15
reservations [1] - 4850:17
reserve [3] - 4640:14, 4864:7, 4865:25
reside [1] - 4798:21
resorted [1] - 4807:10
resources [1] - 4663:14
respect [10] - 4637:10, 4639:6, 4640:4,
4647:13, 4698:7, 4732:1, 4757:13,
4775:6, 4785:4, 4862:10
respected [1] - 4788:20
responded [2] - 4693:17, 4694:12
responding [1] - 4810:24
responds [1] - 4686:24
response [5] - 4638:3, 4640:21,
4673:11, 4687:3, 4738:18
responsibilities [1] - 4752:1
responsibility [6] - 4647:18, 4662:20,


4662:21, 4750:23, 4835:3, 4844:23
responsible [4] - 4662:18, 4751:11,
4751:13, 4751:21
rest [14] - 4643:20, 4662:7, 4785:7,
4785:8, 4789:9, 4798:6, 4812:2,
4818:6, 4820:3, 4834:24, 4835:17,
4858:25, 4859:4, 4860:8
restricted [3] - 4670:20, 4670:25,
4671:3
result [6] - 4644:5, 4696:3, 4696:18,
4698:6, 4811:15
results [2] - 4796:9, 4796:10
resume [3] - 4676:13, 4759:2, 4760:16
resum [1] - 4815:9
resurrection [2] - 4654:8, 4848:23
return [4] - 4725:9, 4725:13, 4753:17,
4754:2
returning [2] - 4753:12, 4754:5
reveal [1] - 4665:11
revealed [1] - 4719:12
revenge [2] - 4649:18, 4650:4
revenue [1] - 4696:14
review [6] - 4645:12, 4696:22, 4705:5,
4758:12, 4843:18, 4861:16
reviewed [1] - 4833:25
revised [2] - 4638:17, 4861:6
revisions [1] - 4637:25
revolution [3] - 4653:13, 4654:6,
4837:3
revolutionary [16] - 4658:6, 4658:21,
4687:2, 4688:19, 4688:22, 4688:24,
4689:23, 4689:24, 4812:15, 4819:4,
4847:12, 4853:15, 4853:17, 4853:21,
4853:22, 4854:7
rhetoric [1] - 4808:25
rice [1] - 4786:22
rich [1] - 4839:21
ride [2] - 4716:25, 4718:17
rides [1] - 4742:5
ridicules [2] - 4651:24, 4830:4
ridiculous [3] - 4691:21, 4807:23,
4817:11
rifle [3] - 4856:3, 4856:6, 4856:7
rights [1] - 4863:14
rise [5] - 4634:16, 4643:21, 4653:14,
4761:13, 4805:18
rises [1] - 4864:12
risk [5] - 4671:3, 4686:18, 4709:17,
4713:25, 4789:13
rival [3] - 4664:13, 4818:1, 4819:25
rivaled [1] - 4820:14
RMR [1] - 4634:8
road [6] - 4669:17, 4699:16, 4716:23,
4816:8, 4822:11, 4822:14
Road [1] - 4720:7
roads [9] - 4716:15, 4716:18, 4718:1,
4720:4, 4723:22, 4723:24, 4816:14,
4817:23, 4824:5
robbery [1] - 4756:6
Robert [4] - 4635:5, 4713:21, 4752:21,
4753:1
rocket [1] - 4814:24
role [3] - 4651:4, 4668:16, 4860:2
roll [1] - 4741:25
rolling [1] - 4742:3
rolls [1] - 4666:1
romanticize [1] - 4797:5
RONALD [1] - 4634:8
room [7] - 4658:24, 4674:18, 4741:12,
4769:6, 4769:18, 4769:19, 4769:21
rough [1] - 4640:7
route [1] - 4718:2
routes [2] - 4672:9, 4716:14
rubble [2] - 4647:12, 4672:19
Rula [1] - 4785:2
ruled [2] - 4639:18, 4640:6
ruling [2] - 4641:21, 4865:23
rumblings [1] - 4760:3
rumored [2] - 4668:5, 4712:20
run [6] - 4666:3, 4676:17, 4684:10,
4711:13, 4716:9, 4727:22
running [7] - 4636:22, 4637:1,
4716:12, 4724:25, 4736:6, 4736:9,
4794:20
runway [1] - 4699:18
runways [1] - 4717:13
Rushdie [2] - 4735:16, 4784:15
RUSSELL [1] - 4633:6
Russell [332] - 4633:22, 4647:14,
4647:24, 4648:6, 4648:8, 4648:16,
4648:21, 4649:7, 4649:17, 4650:10,
4651:21, 4652:9, 4652:10, 4652:21,
4653:4, 4654:17, 4654:25, 4655:21,
4657:22, 4658:13, 4658:25, 4659:13,
4659:14, 4659:18, 4660:5, 4660:8,
4660:20, 4661:19, 4662:5, 4662:8,
4662:10, 4662:11, 4663:1, 4663:17,
4664:3, 4669:24, 4670:5, 4670:15,
4683:3, 4689:4, 4690:21, 4691:3,
4694:4, 4695:4, 4700:25, 4702:24,
4703:7, 4708:20, 4708:23, 4709:3,
4709:6, 4709:11, 4709:13, 4709:16,
4710:6, 4710:9, 4710:11, 4710:12,
4710:14, 4710:19, 4710:23, 4711:3,
4711:11, 4711:12, 4711:14, 4711:15,
4712:10, 4712:24, 4714:1, 4714:4,
4714:10, 4714:11, 4714:14, 4714:18,
4714:24, 4715:1, 4715:5, 4715:18,
4715:20, 4716:4, 4716:8, 4716:10,
4716:11, 4716:13, 4716:17, 4716:19,
4716:24, 4716:25, 4717:6, 4717:7,
4717:20, 4718:7, 4718:9, 4718:11,
4718:18, 4718:19, 4718:21, 4718:25,
4719:4, 4719:24, 4720:2, 4720:3,
4720:10, 4720:11, 4720:13, 4720:17,
4720:21, 4720:25, 4721:7, 4721:25,
4722:2, 4722:5, 4722:6, 4722:8,
4723:5, 4723:7, 4723:12, 4723:15,
4723:16, 4723:17, 4723:19, 4724:17,
4724:20, 4724:24, 4725:2, 4725:6,
4725:7, 4725:9, 4725:10, 4725:12,

4725:19, 4725:24, 4727:5, 4727:20,
4727:25, 4728:10, 4728:15, 4728:19,
4729:1, 4729:3, 4729:13, 4729:16,
4729:18, 4729:21, 4729:23, 4730:1,
4730:3, 4730:4, 4730:5, 4730:22,
4731:5, 4731:12, 4731:14, 4731:17,
4731:19, 4731:20, 4731:24, 4732:4,
4732:7, 4732:8, 4732:10, 4732:14,
4732:17, 4732:22, 4732:24, 4732:25,
4733:2, 4733:10, 4733:11, 4733:12,
4733:14, 4733:16, 4733:18, 4733:19,
4733:23, 4733:24, 4734:1, 4734:5,
4734:6, 4734:7, 4734:9, 4734:13,
4734:19, 4734:25, 4735:1, 4735:2,
4735:3, 4735:5, 4735:8, 4735:18,
4736:5, 4736:6, 4736:10, 4736:11,
4736:14, 4736:16, 4736:21, 4736:23,
4737:1, 4737:2, 4737:5, 4737:8,
4737:9, 4737:10, 4737:13, 4737:14,
4737:16, 4737:17, 4737:18, 4737:20,
4739:8, 4739:12, 4739:13, 4739:14,
4739:16, 4739:21, 4739:25, 4740:1,
4740:12, 4740:18, 4740:20, 4740:22,
4740:23, 4740:25, 4741:13, 4741:16,
4741:17, 4741:21, 4742:1, 4742:6,
4742:14, 4742:16, 4742:20, 4742:21,
4742:22, 4742:24, 4743:3, 4743:5,
4743:8, 4743:11, 4743:12, 4743:17,
4743:18, 4743:19, 4743:21, 4743:22,
4744:12, 4744:13, 4744:16, 4744:18,
4744:24, 4747:13, 4747:17, 4747:19,
4752:12, 4752:19, 4752:22, 4755:4,
4755:23, 4755:25, 4756:11, 4756:16,
4756:19, 4757:1, 4757:6, 4757:10,
4757:14, 4764:15, 4764:16, 4764:21,
4764:23, 4777:25, 4778:8, 4778:9,
4779:21, 4779:23, 4779:25, 4784:5,
4789:19, 4789:20, 4793:17, 4793:22,
4797:24, 4797:25, 4798:1, 4799:6,
4801:9, 4803:19, 4807:25, 4808:1,
4808:20, 4810:23, 4815:1, 4815:6,
4815:24, 4816:7, 4816:16, 4817:23,
4819:14, 4819:20, 4826:5, 4827:7,
4827:8, 4827:9, 4829:25, 4830:8,
4830:9, 4830:10, 4830:13, 4830:18,
4831:4, 4831:11, 4831:14, 4831:17,
4832:10, 4833:2, 4837:8, 4837:21,
4841:17, 4845:4, 4846:7, 4846:20,
4847:4, 4852:8, 4852:10, 4853:11,
4858:2, 4858:5, 4858:20, 4863:7
rusty [3] - 4855:21, 4855:23, 4855:24
rutherford [2] - 4825:1, 4831:23
Rutherford [65] - 4648:23, 4662:2,
4665:14, 4665:17, 4665:22, 4665:25,
4666:3, 4666:4, 4666:12, 4666:14,
4666:16, 4667:13, 4669:1, 4669:2,
4671:16, 4671:17, 4672:23, 4673:1,
4675:18, 4688:1, 4711:22, 4712:2,
4712:11, 4712:22, 4712:23, 4714:11,
4714:13, 4714:14, 4714:17, 4715:2,

33

4715:4, 4715:11, 4715:13, 4715:23,
4720:11, 4720:25, 4725:9, 4725:14,
4725:18, 4727:3, 4727:9, 4727:11,
4727:20, 4728:3, 4728:4, 4728:5,
4728:8, 4728:9, 4728:12, 4728:20,
4728:22, 4728:23, 4740:23, 4747:4,
4756:17, 4763:14, 4763:15, 4765:4,
4789:23, 4824:15, 4824:19, 4828:13,
4833:14, 4846:25
Rutherford's [3] - 4672:25, 4726:8,
4833:7
S
sacrifice [1] - 4661:16
Saddam [1] - 4790:13
safe [2] - 4746:23, 4767:3
safer [3] - 4762:21, 4803:16, 4813:7
safes [1] - 4783:9
safety [4] - 4674:1, 4699:10, 4700:9,
4700:14
sake [1] - 4665:3
salemoalicum [1] - 4719:20
sales [2] - 4750:3, 4751:17
Salman [1] - 4735:16
Salmon [1] - 4784:15
salt [2] - 4727:5, 4732:16
sANKOFA [1] - 4634:1
sat [5] - 4658:24, 4662:10, 4674:18,
4692:6, 4745:23
satellite [16] - 4658:15, 4669:14,
4674:24, 4675:5, 4680:3, 4688:16,
4693:20, 4697:8, 4699:17, 4699:19,
4700:5, 4703:12, 4703:13, 4783:9,
4835:23, 4840:24
satisfied [5] - 4687:4, 4698:16,
4701:3, 4702:5, 4702:19
satisfies [1] - 4865:9
satisfy [1] - 4649:21
Saturday [1] - 4639:1
save [2] - 4715:6, 4741:21
Saved [2] - 4828:19, 4828:20
saving [2] - 4715:14, 4808:9
saw [11] - 4655:23, 4659:21, 4670:13,
4671:17, 4677:10, 4686:11, 4692:19,
4719:10, 4768:20, 4822:5, 4826:2
scared [6] - 4686:4, 4766:4, 4797:21,
4797:23, 4798:3, 4798:7
scary [1] - 4743:23
scene [2] - 4799:21, 4816:12
scheduled [1] - 4852:3
scheme [4] - 4648:24, 4650:18,
4694:9, 4743:13
scheming [5] - 4647:12, 4653:9,
4655:11, 4690:17, 4847:11
scholarly [1] - 4741:4
school [3] - 4791:25, 4792:1
scientists [1] - 4814:24
scouting [1] - 4717:3
scrambles [1] - 4853:12

screen [6] - 4699:16, 4761:4, 4761:8,
4769:20, 4784:24, 4785:22
screw [3] - 4855:21, 4855:23, 4855:24
screwed [1] - 4754:14
scrutiny [1] - 4813:8
scurrying [1] - 4853:4
search [5] - 4682:2, 4794:19, 4794:21,
4795:2
searched [1] - 4794:23
searches [1] - 4729:2
seasoned [8] - 4667:13, 4810:22,
4819:16, 4820:5, 4820:18, 4827:22,
4841:7
seat [8] - 4636:24, 4642:6, 4642:8,
4643:9, 4724:21, 4758:22, 4805:2,
4861:2
seated [11] - 4634:17, 4642:20,
4642:24, 4643:24, 4644:17, 4708:6,
4708:9, 4761:16, 4761:19, 4805:21,
4805:23
second [19] - 4647:4, 4677:16,
4685:23, 4696:2, 4696:8, 4702:13,
4723:3, 4749:2, 4749:3, 4777:14,
4781:16, 4781:25, 4788:21, 4795:2,
4798:4, 4813:23, 4830:18, 4837:17
seconds [1] - 4679:11
secret [5] - 4665:19, 4718:1, 4718:23,
4718:25, 4783:10
secretly [1] - 4685:7
secrets [2] - 4719:5, 4786:9
secure [1] - 4784:10
secured [1] - 4783:9
security [14] - 4671:22, 4681:19,
4697:7, 4717:9, 4717:12, 4718:8,
4719:5, 4742:7, 4742:8, 4816:18,
4816:25, 4817:5, 4817:21, 4821:7
sedition [1] - 4685:2
see [61] - 4639:24, 4640:1, 4640:15,
4642:13, 4644:4, 4644:6, 4651:17,
4652:18, 4655:1, 4666:11, 4669:15,
4669:22, 4670:7, 4676:24, 4680:9,
4680:11, 4681:15, 4681:17, 4686:15,
4689:11, 4689:19, 4710:19, 4717:25,
4723:9, 4724:3, 4724:4, 4725:20,
4727:10, 4727:14, 4730:1, 4733:6,
4733:7, 4743:25, 4746:21, 4753:24,
4768:2, 4768:19, 4777:15, 4779:7,
4782:2, 4797:5, 4810:15, 4814:2,
4814:3, 4814:6, 4815:23, 4822:19,
4825:1, 4825:23, 4826:2, 4832:23,
4835:7, 4845:3, 4846:6, 4846:13,
4848:5, 4848:7, 4851:6, 4852:7,
4860:8, 4866:11
seeing [7] - 4654:24, 4663:18,
4679:23, 4689:14, 4718:5, 4727:9,
4825:22
seek [7] - 4650:4, 4658:2, 4658:5,
4682:6, 4764:11, 4793:11, 4831:24
seeking [4] - 4682:7, 4692:16,
34
4810:21, 4820:18
seem [3] - 4641:12, 4719:21, 4838:6
seething [2] - 4648:17, 4653:9
segregated [1] - 4859:24
seized [2] - 4676:8, 4684:10
selected [1] - 4664:3
self [4] - 4676:11, 4797:6, 4797:7,
4835:15
self-interested [1] - 4835:15
self-serving [1] - 4676:11
selfish [1] - 4777:3
sell [11] - 4738:24, 4739:1, 4739:2,
4739:3, 4739:4, 4740:4, 4740:6,
4742:23, 4785:14, 4798:13, 4798:14
selling [1] - 4790:6
send [16] - 4668:13, 4680:8, 4688:22,
4715:3, 4728:4, 4728:5, 4728:7,
4738:2, 4761:11, 4782:20, 4782:21,
4782:22, 4792:6, 4792:8, 4805:12,
4853:14
sending [11] - 4680:15, 4712:3,
4714:11, 4714:13, 4714:14, 4715:5,
4725:22, 4738:6, 4786:11, 4786:19,
4786:20
senior [2] - 4667:18, 4668:4
sense [40] - 4655:6, 4668:25, 4671:14,
4675:15, 4678:16, 4679:6, 4686:19,
4688:4, 4689:2, 4728:12, 4745:7,
4745:15, 4775:18, 4775:20, 4775:21,
4779:13, 4782:5, 4782:6, 4782:7,
4790:2, 4790:8, 4793:7, 4793:9,
4794:12, 4794:13, 4796:13, 4797:9,
4797:12, 4798:8, 4807:4, 4807:11,
4827:12, 4837:4, 4839:5, 4839:11,
4851:11, 4855:17, 4858:18
senses [1] - 4741:2
sensitive [2] - 4678:25, 4679:18
sent [7] - 4672:25, 4673:4, 4710:17,
4754:16, 4777:18, 4786:18, 4791:3
sentence [7] - 4746:1, 4746:7,
4748:16, 4750:1, 4750:7, 4751:6,
4835:19
sentences [1] - 4748:20
sentencing [1] - 4749:10
separate [3] - 4643:2, 4695:21,
4765:25
separately [1] - 4731:2
September [2] - 4755:16, 4755:19
Serbia [1] - 4745:14
serious [24] - 4652:11, 4660:7,
4660:14, 4661:10, 4663:17, 4663:22,
4681:12, 4682:10, 4684:23, 4685:5,
4686:14, 4696:16, 4696:20, 4749:2,
4751:2, 4751:4, 4751:8, 4807:21,
4808:22, 4819:15, 4821:25, 4830:13,
4831:15, 4856:21
seriously [4] - 4652:1, 4660:13,
4662:6, 4662:9
seriousness [1] - 4662:24
sermons [1] - 4653:16


serve [5] - 4682:25, 4826:15, 4826:17,
4826:21, 4826:23
served [5] - 4641:10, 4641:18, 4683:5,
4746:7, 4746:8
serves [2] - 4683:7, 4789:3
service [2] - 4643:5, 4860:1
services [2] - 4816:1, 4816:3
serving [1] - 4676:11
SESSION [1] - 4760:1
set [14] - 4642:14, 4655:5, 4673:13,
4696:10, 4707:22, 4744:9, 4772:15,
4772:17, 4778:4, 4778:15, 4779:12,
4829:5, 4850:17
set's [1] - 4681:20
sets [5] - 4685:23, 4731:18, 4777:21,
4778:1, 4789:2
setting [3] - 4707:5, 4836:4, 4842:8
settled [1] - 4663:14
settles [1] - 4686:6
seven [2] - 4769:5, 4852:11
seven-year-old [1] - 4769:5
sever [3] - 4691:13, 4692:21, 4839:24
several [4] - 4646:21, 4648:13, 4657:1,
4698:13
Seyyid [2] - 4849:8, 4849:12
shady [1] - 4803:11
Shafek [1] - 4737:12
Shafik [2] - 4673:19, 4673:20
shaking [1] - 4768:21
shall [3] - 4654:8, 4802:12, 4848:23
sharing [1] - 4715:14
shark [1] - 4757:15
sheet [1] - 4639:11
sheik [1] - 4809:22
Sheikh [13] - 4721:8, 4736:2, 4744:1,
4744:2, 4744:5, 4752:10, 4844:2,
4844:17, 4844:25, 4846:22, 4846:24,
4846:25
sheikh [2] - 4789:20, 4789:24
Sheikhs [2] - 4720:13, 4720:14
Shi'a [1] - 4686:8
Shia [8] - 4788:20, 4792:4, 4792:5,
4792:6, 4792:7, 4792:9
shift [1] - 4863:1
shifted [1] - 4692:23
Shiite [3] - 4653:4, 4653:13, 4653:14
Shiites [1] - 4739:6
Shining [4] - 4666:13, 4666:15,
4666:17, 4675:19
shining [1] - 4738:8
shipments [1] - 4822:16
shipped [1] - 4719:1
shock [2] - 4692:13, 4840:2
shocked [1] - 4814:23
shocking [2] - 4755:12, 4755:21
shoot [3] - 4673:10, 4747:14, 4748:1
shooting [3] - 4663:18, 4668:12,
4818:25
shops [1] - 4713:15
short [2] - 4768:20, 4831:18

shorter [1] - 4705:25
shortly [1] - 4760:16
shot [4] - 4671:10, 4673:7, 4684:8,
4700:3
shots [7] - 4671:2, 4671:9, 4755:1,
4755:4, 4755:5, 4824:3
show [34] - 4670:2, 4715:25, 4721:11,
4722:13, 4723:19, 4727:13, 4735:6,
4736:10, 4740:1, 4742:19, 4750:23,
4755:6, 4756:19, 4757:3, 4757:7,
4757:17, 4761:4, 4776:17, 4783:13,
4783:17, 4785:13, 4788:7, 4788:8,
4788:18, 4791:8, 4798:2, 4816:8,
4816:9, 4821:3, 4824:4, 4824:16,
4829:18, 4849:4, 4855:19
showed [6] - 4688:14, 4756:22,
4768:17, 4797:20, 4825:20, 4848:13
showing [6] - 4691:2, 4699:22,
4719:1, 4788:13, 4790:7, 4840:19
shown [18] - 4646:6, 4647:11, 4648:8,
4692:22, 4693:5, 4709:1, 4709:5,
4709:8, 4709:9, 4709:11, 4709:12,
4709:15, 4724:13, 4740:3, 4753:1,
4825:19, 4825:20, 4856:11
showoff [1] - 4808:9
shows [25] - 4651:16, 4655:18,
4681:11, 4691:5, 4695:19, 4699:5,
4700:4, 4716:1, 4718:18, 4729:18,
4729:19, 4730:2, 4734:9, 4734:14,
4734:17, 4734:18, 4736:14, 4736:16,
4740:3, 4756:10, 4756:12, 4757:10,
4757:13, 4757:18, 4783:18
shrapnel [1] - 4719:13
Shukrijumah [28] - 4667:11, 4712:16,
4712:17, 4712:18, 4712:22, 4713:1,
4713:3, 4713:4, 4713:6, 4713:9,
4713:12, 4714:16, 4726:1, 4728:14,
4728:16, 4733:6, 4733:7, 4746:12,
4746:13, 4746:17, 4757:16, 4763:12,
4764:7, 4765:3, 4818:10, 4818:14,
4833:21, 4858:8
Shukrijumiah [7] - 4658:3, 4667:4,
4667:7, 4667:25, 4668:3, 4668:19,
4671:13
Shukrijumiah's [2] - 4667:5, 4668:8
Shurkijumah [2] - 4746:18, 4746:20
shut [1] - 4719:3
sic [1] - 4793:3
sick [1] - 4637:1
side [9] - 4642:16, 4671:5, 4676:18,
4822:15, 4844:6, 4847:10, 4852:19,
4855:13, 4862:21
sidebar [2] - 4771:23, 4774:2
sidestep [1] - 4781:11
sign [4] - 4686:14, 4724:13, 4724:14,
4817:16
significance [1] - 4765:9
significant [6] - 4650:24, 4668:9,
4823:12, 4831:2, 4832:24, 4834:23
35
signs [4] - 4724:18, 4797:1, 4816:14,

4817:13
silly [3] - 4815:15, 4821:6, 4823:18
similar [1] - 4639:12
simple [3] - 4684:19, 4821:11, 4828:23
simpler [2] - 4650:21, 4820:24
simply [6] - 4677:12, 4684:16, 4685:6,
4723:11, 4724:10, 4748:24
single [11] - 4700:15, 4701:17,
4704:17, 4718:1, 4757:23, 4790:15,
4801:21, 4834:2, 4834:6, 4840:20,
4859:6
singling [1] - 4656:20
sister [1] - 4791:25
sit [10] - 4637:15, 4649:6, 4705:14,
4710:1, 4710:2, 4710:3, 4771:12,
4775:17, 4781:21
sits [2] - 4636:24, 4643:4
sitting [5] - 4726:7, 4767:19, 4767:22,
4768:16, 4809:23
situation [2] - 4855:16, 4866:1
Six [3] - 4702:6, 4702:8
six [9] - 4695:16, 4741:24, 4742:4,
4742:12, 4815:12, 4820:6, 4820:15,
4840:17, 4852:11
size [2] - 4659:20, 4677:9
sizzle [2] - 4757:10, 4808:10
skepticism [1] - 4674:5
sketch [1] - 4718:5
skills [1] - 4667:8
skip [1] - 4851:22
sky [1] - 4669:22
Sky [1] - 4697:6
slice [1] - 4824:11
slick [2] - 4779:20, 4779:21
slides [3] - 4661:24, 4825:12, 4825:13
slightly [1] - 4722:21
slinking [3] - 4692:12, 4693:3, 4840:5
slip [1] - 4670:16
slow [1] - 4770:10
small [10] - 4642:13, 4665:21,
4669:16, 4708:21, 4722:10, 4723:11,
4757:19, 4812:4, 4820:1, 4824:25
smaller [2] - 4669:24, 4820:24
smart [3] - 4818:2, 4818:21, 4819:4
smiling [1] - 4672:20
smooth [1] - 4752:3
smuggling [1] - 4710:11
sneak [2] - 4651:11, 4672:8
snitches [1] - 4795:15
so-called [2] - 4710:13, 4777:21
soft [2] - 4672:7, 4858:6
sold [1] - 4823:15
sole [2] - 4645:22, 4802:8
solutions [2] - 4679:14, 4684:15
solving [1] - 4677:24
someone [31] - 4651:11, 4652:20,
4657:16, 4664:2, 4665:15, 4667:14,
4672:24, 4673:11, 4682:19, 4686:17,


4686:18, 4700:23, 4703:10, 4710:10,
4719:15, 4723:16, 4729:2, 4740:24,
4752:7, 4764:9, 4765:20, 4775:23,
4777:12, 4777:15, 4777:16, 4784:19,
4802:19, 4810:18, 4818:5, 4834:16,
4840:18
someplace [2] - 4795:13
sometime [2] - 4666:1, 4687:13
sometimes [3] - 4708:15, 4797:10,
4826:13
somewhat [2] - 4641:6, 4864:11
somewhere [3] - 4675:4, 4764:13,
4778:4
son [1] - 4785:25
son's [2] - 4781:19, 4797:22
soon [6] - 4671:11, 4671:13, 4671:14,
4714:3, 4714:5, 4861:8
sophisticated [1] - 4781:6
sorely [1] - 4770:9
sorry [6] - 4669:2, 4707:16, 4708:13,
4797:8, 4838:8, 4846:8
sort [4] - 4751:3, 4751:12, 4810:8,
4866:2
sorts [1] - 4736:17
sought [2] - 4667:18, 4744:23
soul [1] - 4701:17
sound [11] - 4720:13, 4721:25, 4727:6,
4751:25, 4760:24, 4764:2, 4810:18,
4841:1, 4841:4, 4841:13, 4855:17
sounds [4] - 4752:1, 4775:23, 4776:3,
4865:14
source [2] - 4692:14
space [2] - 4679:10, 4808:3
Spain [2] - 4754:5, 4791:14
span [1] - 4809:8
speaking [8] - 4659:9, 4659:14,
4719:4, 4746:16, 4749:9, 4778:7,
4799:6
speaks [2] - 4715:4, 4800:9
special [4] - 4648:11, 4666:22,
4718:16, 4748:21
specific [2] - 4775:4, 4819:23
specifically [1] - 4661:13
spectacle [1] - 4690:25
speculate [2] - 4649:7, 4796:1
speculation [1] - 4822:20
speech [1] - 4785:6
spend [3] - 4812:1, 4829:21, 4829:25
spent [8] - 4646:16, 4648:16, 4703:18,
4757:15, 4807:20, 4810:4, 4850:5,
4855:9
spin [1] - 4660:17
spiritual [1] - 4786:22
spoken [4] - 4769:23, 4844:9,
4844:10, 4844:11
sponsor [4] - 4819:5, 4845:6, 4845:9,
4845:10
sponsored [1] - 4813:3
sponsoring [1] - 4690:8
sponsors [3] - 4690:4, 4690:5, 4803:8
spot [2] - 4801:12, 4801:14

spots [1] - 4672:7
spread [1] - 4697:12
spreading [1] - 4784:6
spy [6] - 4781:6, 4786:7, 4786:25,
4787:1, 4789:1, 4799:13
spying [5] - 4786:10, 4787:3, 4788:5,
4788:23, 4788:24
Squares [1] - 4788:22
stage [1] - 4665:10
stake [1] - 4748:13
stamps [1] - 4828:7
stand [29] - 4653:3, 4653:18, 4655:20,
4656:8, 4656:23, 4659:16, 4662:10,
4674:8, 4674:14, 4678:21, 4679:11,
4681:2, 4683:12, 4683:22, 4691:7,
4695:7, 4703:20, 4749:23, 4767:19,
4767:23, 4768:24, 4773:12, 4791:17,
4793:21, 4807:3, 4840:13, 4849:23,
4856:10
standing [3] - 4653:4, 4686:8, 4741:9
stands [1] - 4836:17
start [14] - 4636:6, 4644:10, 4669:20,
4673:15, 4678:1, 4690:11, 4704:22,
4704:24, 4705:10, 4721:23, 4762:2,
4809:12, 4813:14, 4859:10
started [16] - 4642:20, 4648:13,
4662:2, 4707:23, 4710:5, 4713:7,
4714:1, 4763:4, 4763:10, 4796:21,
4804:3, 4813:15, 4850:12, 4852:17,
4859:6, 4861:5
starting [1] - 4730:9
starts [4] - 4686:6, 4714:11, 4733:8,
4769:21
stash [1] - 4685:3
state [8] - 4635:1, 4668:12, 4692:13,
4698:13, 4702:1, 4792:5, 4819:5,
4848:19
statement [5] - 4657:3, 4662:4,
4772:19, 4843:17
statements [15] - 4645:15, 4651:25,
4730:6, 4755:23, 4756:1, 4795:18,
4808:24, 4809:1, 4809:6, 4809:8,
4832:8, 4836:11, 4854:16, 4858:14,
4864:1
STATES [2] - 4633:1, 4633:3
states [2] - 4652:14, 4712:5
States [44] - 4633:11, 4633:15,
4634:25, 4645:9, 4649:13, 4650:3,
4651:20, 4661:5, 4663:13, 4664:13,
4667:21, 4668:2, 4669:3, 4673:18,
4693:25, 4697:21, 4698:10, 4700:25,
4710:20, 4711:1, 4712:9, 4712:13,
4714:7, 4731:13, 4731:14, 4731:25,
4745:1, 4745:4, 4745:8, 4746:2,
4746:8, 4747:8, 4812:23, 4813:3,
4819:8, 4821:18, 4821:24, 4822:6,
4822:23, 4823:9, 4834:25, 4858:1,
4858:9
States' [1] - 4650:3
36
stating [2] - 4772:11, 4803:1

station [6] - 4684:10, 4697:9, 4700:17,
4720:7, 4818:24, 4819:1
statute [1] - 4702:20
stay [15] - 4681:14, 4686:7, 4715:21,
4730:25, 4733:11, 4735:1, 4744:25,
4772:10, 4778:21, 4797:25, 4828:9,
4828:11, 4836:5, 4839:22, 4839:24
staying [1] - 4739:18
stays [1] - 4735:1
stealing [2] - 4719:6, 4785:17
steam [2] - 4652:6, 4652:20
steel [1] - 4718:12
Stenographically [1] - 4634:12
step [8] - 4652:19, 4688:18, 4691:8,
4803:25, 4853:11, 4857:18, 4859:18
steps [6] - 4652:16, 4657:18, 4663:3,
4663:4, 4663:6, 4827:22
steven [1] - 4673:20
Steven [262] - 4654:18, 4655:22,
4657:24, 4658:25, 4660:21, 4661:25,
4662:3, 4663:7, 4663:14, 4664:3,
4664:24, 4671:16, 4673:19, 4673:25,
4676:25, 4678:3, 4679:12, 4680:9,
4682:24, 4683:23, 4684:21, 4690:2,
4692:14, 4694:5, 4699:11, 4703:7,
4710:6, 4710:17, 4710:23, 4711:2,
4711:5, 4711:6, 4711:10, 4711:11,
4711:14, 4711:16, 4711:20, 4711:23,
4712:3, 4712:7, 4712:12, 4712:21,
4713:2, 4713:4, 4713:5, 4714:6,
4714:9, 4714:10, 4714:12, 4714:13,
4714:21, 4715:3, 4715:6, 4715:7,
4715:10, 4715:12, 4715:15, 4715:16,
4715:23, 4716:7, 4716:8, 4716:18,
4716:21, 4716:24, 4717:6, 4718:9,
4719:11, 4719:22, 4720:1, 4720:6,
4720:10, 4720:12, 4720:16, 4720:21,
4720:24, 4721:2, 4721:7, 4721:13,
4722:1, 4722:3, 4723:12, 4723:14,
4723:15, 4724:23, 4725:1, 4725:3,
4725:6, 4725:15, 4725:16, 4725:17,
4725:24, 4727:2, 4727:17, 4727:23,
4727:25, 4728:1, 4728:5, 4728:7,
4728:9, 4728:11, 4728:14, 4728:16,
4728:17, 4728:20, 4729:1, 4729:3,
4729:5, 4729:6, 4729:9, 4729:16,
4729:20, 4729:21, 4730:6, 4732:2,
4732:3, 4732:9, 4732:17, 4732:19,
4733:10, 4733:13, 4734:2, 4734:6,
4734:8, 4734:10, 4734:25, 4735:4,
4735:5, 4735:9, 4735:13, 4735:21,
4735:23, 4735:24, 4736:7, 4736:9,
4736:21, 4737:4, 4737:7, 4737:14,
4737:15, 4737:18, 4738:1, 4738:2,
4738:7, 4738:14, 4738:15, 4738:17,
4738:21, 4739:16, 4740:20, 4740:23,
4741:3, 4741:15, 4742:2, 4742:4,
4742:6, 4742:8, 4742:10, 4742:11,
4742:13, 4742:14, 4743:1, 4743:2,


4743:8, 4743:10, 4743:11, 4743:14,
4743:15, 4743:17, 4743:25, 4744:3,
4744:8, 4744:9, 4746:17, 4747:1,
4747:5, 4747:9, 4747:11, 4747:12,
4747:17, 4747:21, 4747:22, 4747:23,
4748:1, 4748:10, 4748:11, 4748:13,
4748:19, 4749:20, 4750:2, 4752:3,
4752:10, 4752:14, 4752:17, 4752:18,
4754:15, 4754:21, 4755:2, 4755:11,
4755:13, 4755:16, 4756:18, 4764:15,
4764:17, 4764:20, 4764:25, 4765:2,
4765:4, 4766:17, 4766:20, 4766:25,
4767:1, 4767:15, 4776:7, 4777:24,
4778:8, 4778:9, 4779:2, 4779:22,
4779:23, 4779:25, 4781:21, 4782:14,
4789:19, 4793:16, 4794:21, 4795:7,
4795:11, 4796:11, 4797:2, 4797:4,
4797:20, 4799:7, 4800:1, 4800:3,
4800:12, 4803:13, 4803:18, 4810:24,
4810:25, 4811:1, 4811:2, 4811:4,
4820:2, 4826:6, 4826:7, 4827:2,
4827:5, 4827:10, 4827:15, 4829:15,
4832:13, 4852:8, 4852:10, 4854:2
stick [4] - 4651:5, 4728:15, 4728:19,
4729:20
still [18] - 4693:7, 4700:3, 4704:16,
4704:20, 4711:8, 4726:3, 4726:7,
4729:16, 4730:2, 4751:5, 4768:17,
4769:17, 4797:21, 4797:23, 4814:16,
4837:4, 4852:21, 4859:9
sting [1] - 4757:11
stipulation [1] - 4689:19
stolen [1] - 4783:9
stood [1] - 4815:1
stop [2] - 4663:2, 4681:8
stopped [17] - 4649:4, 4649:15,
4649:24, 4650:8, 4651:9, 4664:22,
4670:4, 4672:1, 4672:17, 4678:6,
4679:3, 4680:1, 4680:25, 4682:18,
4683:20, 4689:10, 4698:3
store [2] - 4721:9, 4722:2
stories [3] - 4659:20, 4660:18,
4843:21
story [21] - 4660:1, 4660:17, 4675:24,
4676:22, 4677:4, 4677:6, 4691:7,
4691:23, 4692:24, 4694:2, 4728:9,
4742:18, 4743:22, 4745:6, 4783:15,
4837:14, 4840:9, 4840:13, 4840:14,
4840:15, 4845:23
straight [5] - 4659:7, 4660:25,
4683:13, 4733:23, 4750:19
strange [5] - 4676:12, 4814:5, 4814:7,
4814:8, 4821:6
strangely [1] - 4832:15
stranger [1] - 4682:21
streamlined [1] - 4641:5
Street [3] - 4634:1, 4634:4, 4721:16
strength [1] - 4673:9
stricken [2] - 4795:24, 4803:4
strict [1] - 4813:8
strike [1] - 4672:14

strikes [1] - 4819:8
striking [1] - 4690:17
stringing [1] - 4810:18
strong [3] - 4665:2, 4703:19, 4754:22
struck [1] - 4812:20
struggle [2] - 4653:22, 4653:24
student [1] - 4739:18
students [4] - 4778:7, 4778:10,
4778:11, 4791:5
studying [1] - 4810:3
stuff [12] - 4672:12, 4713:17, 4721:18,
4766:11, 4793:8, 4794:14, 4799:4,
4799:14, 4799:19, 4799:22, 4805:3,
4805:6
stupid [9] - 4692:17, 4709:10,
4709:21, 4709:22, 4709:24, 4709:25,
4808:7, 4817:4, 4819:17
subjugation [1] - 4654:7
submissions [1] - 4640:24
submit [11] - 4650:1, 4689:22,
4840:15, 4841:19, 4853:10, 4854:9,
4854:23, 4855:3, 4855:7, 4858:18,
4865:24
submitted [4] - 4639:1, 4692:4,
4862:3, 4866:8
substance [1] - 4699:8
substantial [2] - 4746:6, 4749:5
substitute [4] - 4637:4, 4637:19,
4720:8, 4722:23
succeed [4] - 4682:12, 4682:25,
4683:9, 4686:15
succeeded [2] - 4814:14, 4818:20
succeeding [1] - 4657:13
succeeds [1] - 4657:12
success [2] - 4682:15, 4719:24
successful [3] - 4665:17, 4812:21,
4812:23
successfully [1] - 4820:20
sudden [3] - 4693:22, 4845:20,
4845:21
suddenly [2] - 4692:13, 4708:25
suffice [1] - 4656:7
sufficiently [1] - 4772:1
suggest [6] - 4645:13, 4693:10,
4693:12, 4829:18, 4831:15, 4835:12
suggested [9] - 4666:12, 4674:24,
4820:11, 4834:20, 4844:15, 4845:1,
4845:4, 4847:6, 4864:13
suggesting [1] - 4865:15
suggestion [1] - 4820:17
suggestions [1] - 4816:21
suggests [1] - 4679:7
suicide [5] - 4664:25, 4668:11, 4684:7,
4818:24, 4841:4
suit [1] - 4789:9
suitcase [3] - 4820:25, 4821:4, 4821:8
Suite [1] - 4634:4
sum [2] - 4645:8, 4704:11
summary [1] - 4645:19

SUMMATION [5] - 4762:4, 4867:4,
4867:5, 4867:6, 4867:7
Summation [3] - 4646:2, 4708:19,
4806:6
summation [10] - 4704:15, 4705:18,
4708:16, 4710:9, 4722:16, 4761:24,
4804:4, 4806:3, 4862:16, 4864:2
summations [23] - 4637:7, 4637:8,
4640:15, 4640:16, 4642:15, 4642:21,
4644:24, 4645:2, 4645:4, 4645:12,
4645:15, 4645:24, 4704:6, 4704:20,
4760:16, 4760:17, 4804:1, 4832:16,
4861:5, 4864:8, 4864:23, 4864:24,
4865:12
Summations [1] - 4805:1
summed [1] - 4863:20
summer [1] - 4661:19
summing [2] - 4761:25, 4863:21
sums [1] - 4642:18
sun [1] - 4808:5
super [1] - 4781:6
supervisor [1] - 4648:13
support [11] - 4681:10, 4682:7,
4682:8, 4683:9, 4713:22, 4822:2,
4822:4, 4822:8, 4837:3, 4848:9,
4854:24
suppose [2] - 4830:18, 4830:22
supposed [16] - 4635:16, 4635:20,
4678:10, 4710:14, 4714:25, 4726:3,
4766:23, 4766:24, 4767:2, 4777:12,
4778:16, 4779:5, 4780:15, 4781:16,
4795:22
supposedly [5] - 4710:21, 4714:16,
4727:21, 4815:15, 4827:25
suppressed [1] - 4687:10
supreme [1] - 4653:18
surely [1] - 4792:13
surprise [5] - 4660:13, 4691:4,
4691:21, 4785:18, 4827:19
surrounding [1] - 4816:5
surveil [1] - 4812:3
surveillance [33] - 4647:13, 4657:25,
4658:1, 4669:23, 4671:7, 4673:23,
4674:21, 4682:20, 4684:20, 4684:23,
4685:5, 4685:9, 4686:1, 4702:8,
4702:10, 4702:24, 4702:25, 4703:3,
4703:6, 4716:6, 4724:12, 4724:19,
4756:1, 4806:14, 4807:17, 4811:21,
4811:22, 4813:4, 4828:22, 4829:5,
4831:3, 4835:11, 4863:9
surveilled [1] - 4702:19
surveilling [1] - 4810:20
survivors [1] - 4704:2
suspicion [1] - 4650:13
suspicious [1] - 4672:23
sustained [7] - 4768:9, 4771:17,
4771:19, 4788:16, 4794:25, 4795:17,
4795:24
Sustained [1] - 4802:2

37

swinging [1] - 4856:1
switch [7] - 4658:5, 4705:23, 4707:25,
4708:14, 4709:14, 4724:1, 4830:6
sworn [1] - 4692:3
sympathetic [1] - 4792:12
sync [1] - 4639:14
system [7] - 4661:23, 4670:7, 4696:1,
4696:5, 4707:7, 4816:25, 4817:11
systems [1] - 4816:20
T
table [4] - 4635:4, 4646:8, 4672:6,
4792:19
tail [1] - 4732:6
tailed [1] - 4859:3
takeover [1] - 4818:25
Talib [8] - 4648:23, 4665:14, 4665:16,
4665:22, 4763:14, 4763:15, 4765:4,
4828:12
talkers [1] - 4713:19
talks [28] - 4649:10, 4650:25, 4654:6,
4714:12, 4714:13, 4716:13, 4718:22,
4719:4, 4719:7, 4719:9, 4720:21,
4723:20, 4723:21, 4731:12, 4731:17,
4731:21, 4737:2, 4740:15, 4741:19,
4741:23, 4750:22, 4765:21, 4770:1,
4799:10, 4844:7, 4846:5, 4849:2
tank [6] - 4658:16, 4671:9, 4694:13,
4801:20, 4801:21, 4815:20
tanks [71] - 4646:14, 4647:3, 4647:8,
4650:19, 4657:7, 4658:2, 4661:2,
4666:8, 4666:21, 4666:24, 4668:25,
4669:4, 4669:8, 4670:8, 4670:10,
4670:22, 4671:23, 4672:2, 4674:25,
4693:20, 4694:15, 4694:16, 4694:23,
4695:10, 4695:14, 4696:9, 4696:25,
4697:5, 4697:20, 4699:2, 4699:13,
4699:23, 4700:16, 4701:9, 4701:13,
4701:14, 4702:15, 4702:17, 4702:25,
4703:9, 4716:25, 4717:25, 4718:11,
4718:22, 4719:1, 4720:5, 4768:21,
4801:17, 4801:25, 4816:3, 4817:22,
4820:4, 4824:3, 4824:4, 4825:10,
4825:25, 4833:18, 4833:19, 4836:8,
4838:1, 4839:3, 4839:4, 4839:10,
4841:11, 4841:15, 4841:23, 4842:2,
4842:3, 4842:10, 4842:15
tape [41] - 4647:17, 4651:19, 4651:20,
4655:19, 4659:10, 4660:24, 4674:13,
4675:5, 4675:14, 4741:11, 4743:5,
4764:5, 4765:1, 4766:3, 4806:11,
4806:20, 4807:20, 4808:5, 4808:14,
4808:19, 4812:9, 4815:7, 4824:12,
4831:3, 4832:8, 4832:17, 4832:18,
4835:22, 4836:1, 4836:3, 4836:4,
4836:17, 4837:10, 4843:1, 4843:11,
4847:4, 4854:11, 4854:12, 4856:15,
4858:14
tape-recorded [2] - 4806:20, 4832:8

taped [2] - 4766:2, 4843:17
tapes [36] - 4649:25, 4652:9, 4652:20,
4656:14, 4670:14, 4671:7, 4686:3,
4694:3, 4697:17, 4716:10, 4717:5,
4719:19, 4720:2, 4723:19, 4741:11,
4749:8, 4763:1, 4763:25, 4764:1,
4764:14, 4768:6, 4777:25, 4808:1,
4817:25, 4822:3, 4822:24, 4826:7,
4831:22, 4831:25, 4833:25, 4837:15,
4840:13, 4840:21, 4842:22, 4846:14,
4856:17
tapped [1] - 4835:10
target [2] - 4672:3, 4698:11
targets [4] - 4671:8, 4821:24, 4824:3,
4858:6
tarj [2] - 4681:23, 4681:24
taxi [1] - 4699:18
taxiway [1] - 4699:17
teach [1] - 4646:10
teaches [1] - 4788:22
teaching [1] - 4789:6
tears [1] - 4750:8
tech [9] - 4672:12, 4722:4, 4722:5,
4722:7, 4722:10, 4723:11, 4816:24,
4824:25, 4825:5
technical [8] - 4646:22, 4695:22,
4708:14, 4713:22, 4783:6, 4805:3,
4805:5
technological [1] - 4825:6
technologies [1] - 4816:20
technology [2] - 4817:1, 4817:5
ten [7] - 4719:8, 4750:8, 4755:22,
4781:18, 4781:19, 4797:22, 4815:12
ten-year [1] - 4719:8
tends [1] - 4862:17
tenor [1] - 4864:22
term [1] - 4708:24
terminal [6] - 4651:12, 4671:22,
4820:25, 4821:3, 4821:7, 4821:10
terminals [1] - 4724:8
terms [3] - 4681:19, 4835:8, 4862:18
terrible [4] - 4646:9, 4710:22, 4749:24,
4749:25
terrify [1] - 4803:10
terror [2] - 4655:25, 4762:15
terrorism [7] - 4690:23, 4749:5,
4818:13, 4819:6, 4820:10, 4821:25,
4857:23
terrorist [59] - 4650:23, 4653:6,
4656:22, 4656:24, 4657:4, 4657:17,
4658:3, 4661:20, 4664:12, 4667:13,
4667:24, 4668:9, 4670:12, 4682:7,
4682:9, 4683:6, 4684:7, 4690:24,
4691:14, 4703:20, 4740:12, 4742:23,
4808:15, 4810:22, 4812:12, 4812:21,
4812:22, 4812:23, 4813:3, 4817:16,
4817:17, 4818:23, 4819:7, 4819:8,
4819:12, 4819:21, 4820:8, 4820:14,
4820:16, 4820:21, 4821:23, 4823:19,
38
4824:9, 4829:2, 4830:2, 4830:16,

4834:23, 4839:23, 4841:2, 4841:5,
4841:7, 4841:10, 4845:7, 4845:11,
4845:12, 4854:19, 4857:4, 4857:9
terrorists [14] - 4691:18, 4694:23,
4755:18, 4792:2, 4819:16, 4820:18,
4827:22, 4829:23, 4857:3, 4857:5,
4857:7, 4857:8, 4857:10, 4858:8
terrorists' [1] - 4857:12
test [1] - 4707:7
tested [2] - 4795:3, 4795:4
testified [58] - 4660:25, 4661:9,
4683:13, 4711:3, 4711:12, 4712:19,
4712:21, 4712:24, 4713:19, 4713:21,
4715:10, 4717:14, 4718:6, 4718:14,
4718:24, 4721:7, 4722:4, 4724:11,
4725:1, 4728:7, 4729:1, 4733:13,
4735:5, 4736:7, 4736:21, 4737:8,
4740:20, 4740:23, 4742:7, 4742:8,
4746:10, 4747:12, 4748:25, 4750:8,
4752:10, 4755:3, 4765:18, 4766:25,
4767:1, 4768:11, 4768:19, 4776:14,
4785:19, 4786:13, 4794:22, 4798:13,
4825:14, 4828:6, 4830:9, 4832:25,
4833:3, 4833:6, 4833:9, 4833:12,
4833:17, 4833:20, 4834:5, 4849:10
testifies [2] - 4729:3, 4745:7
testify [5] - 4660:17, 4665:8, 4749:20,
4764:19, 4791:24
testifying [1] - 4749:4
testimony [49] - 4647:13, 4655:3,
4656:5, 4680:19, 4712:15, 4727:1,
4729:9, 4731:5, 4733:13, 4745:22,
4748:5, 4748:6, 4748:8, 4752:4,
4752:25, 4762:24, 4762:25, 4763:1,
4763:2, 4763:3, 4763:6, 4763:23,
4767:10, 4767:11, 4776:8, 4777:24,
4784:14, 4794:18, 4795:9, 4798:11,
4799:8, 4812:19, 4822:17, 4824:17,
4825:24, 4830:9, 4832:12, 4832:20,
4832:24, 4833:5, 4833:8, 4841:16,
4841:20, 4849:10, 4853:23, 4855:14,
4858:17
thanking [1] - 4791:4
THE [104] - 4634:16, 4634:17, 4634:20,
4634:21, 4634:23, 4634:24, 4635:13,
4635:16, 4635:19, 4636:10, 4636:11,
4636:16, 4636:20, 4637:16, 4637:20,
4637:22, 4638:23, 4639:6, 4641:16,
4641:25, 4642:3, 4642:13, 4642:22,
4642:24, 4643:2, 4643:14, 4643:19,
4643:21, 4643:24, 4644:1, 4644:2,
4644:21, 4694:18, 4704:5, 4705:14,
4706:2, 4707:4, 4707:9, 4707:11,
4707:14, 4707:17, 4707:21, 4708:2,
4708:4, 4708:6, 4708:13, 4757:25,
4758:21, 4759:1, 4760:2, 4760:8,
4760:10, 4760:14, 4760:24, 4761:5,
4761:7, 4761:11, 4761:13, 4761:16,
4761:23, 4762:6, 4762:8, 4767:9,


4768:9, 4771:17, 4771:19, 4772:7,
4772:10, 4772:13, 4773:5, 4773:17,
4773:20, 4775:1, 4788:16, 4794:25,
4795:17, 4795:24, 4802:2, 4802:16,
4802:25, 4803:3, 4803:23, 4804:19,
4805:2, 4805:8, 4805:10, 4805:12,
4805:18, 4805:20, 4806:2, 4806:9,
4823:22, 4838:7, 4851:16, 4853:1,
4858:23, 4861:2, 4861:13, 4861:22,
4862:1, 4864:6, 4865:18, 4866:6,
4866:11
theft [1] - 4722:8
themselves [8] - 4654:11, 4681:22,
4689:6, 4791:21, 4802:3, 4818:4,
4848:25, 4865:5
theoretically [1] - 4728:17
theory [8] - 4638:4, 4638:12, 4862:11,
4862:23, 4865:17, 4865:18, 4865:24,
4866:8
therefore [1] - 4703:15
Theresa [1] - 4667:23
they've [3] - 4671:19, 4726:4, 4795:21
think's [1] - 4705:20
thinking [8] - 4636:6, 4672:18,
4672:19, 4686:6, 4705:25, 4738:12,
4741:20, 4801:14
thinks [11] - 4637:2, 4712:11, 4716:23,
4721:2, 4722:7, 4737:20, 4738:3,
4738:7, 4740:15, 4748:23, 4846:9
third [2] - 4737:3, 4840:14
thousands [1] - 4696:13
threat [1] - 4748:1
threatened [2] - 4673:10, 4747:13
threatens [2] - 4684:11, 4684:12
threats [1] - 4652:9
three [17] - 4637:3, 4639:9, 4660:8,
4669:20, 4709:12, 4714:19, 4758:4,
4758:19, 4759:2, 4819:21, 4822:4,
4832:21, 4833:24, 4834:15, 4836:3,
4840:6, 4856:16
Three [1] - 4699:6
throughout [7] - 4644:7, 4675:20,
4677:5, 4690:7, 4692:24, 4746:14,
4808:20
throw [3] - 4653:15, 4788:23, 4854:21
throwaway [1] - 4780:1
throwing [1] - 4728:9
ticket [47] - 4651:15, 4714:17,
4715:22, 4725:9, 4725:13, 4725:14,
4725:16, 4725:18, 4725:21, 4727:11,
4727:15, 4727:16, 4727:23, 4736:22,
4736:25, 4737:3, 4737:7, 4737:8,
4737:9, 4737:11, 4737:13, 4737:16,
4737:19, 4738:7, 4738:10, 4738:13,
4752:19, 4752:25, 4753:11, 4753:21,
4754:4, 4754:17, 4757:2, 4828:25,
4829:5, 4829:9, 4829:11, 4829:16,
4843:23, 4844:1, 4845:16, 4850:20,
4851:5, 4851:11, 4851:21, 4853:7
tickets [15] - 4727:10, 4728:3,
4728:24, 4733:9, 4733:14, 4733:17,

4733:23, 4754:18, 4756:24, 4829:1,
4829:3, 4829:19, 4830:4, 4851:3,
4851:9
ties [8] - 4667:4, 4667:19, 4668:4,
4668:15, 4689:1, 4818:11, 4839:23,
4839:24
tight [2] - 4811:21, 4813:4
timber [1] - 4678:13
time-to-time [1] - 4691:7
tiny [1] - 4769:20
tip [2] - 4710:18, 4850:15
tips [2] - 4682:12, 4801:16
titanium [1] - 4666:24
Tobago [2] - 4852:9, 4852:18
today [11] - 4637:8, 4638:18, 4762:10,
4771:8, 4803:25, 4804:1, 4804:5,
4849:23, 4859:4, 4859:25, 4861:19
together [8] - 4727:11, 4747:21,
4747:23, 4844:6, 4859:23, 4863:8,
4864:23, 4865:12
TOLKIN [1] - 4634:8
tomorrow [11] - 4637:9, 4771:8,
4772:4, 4802:5, 4804:1, 4858:25,
4859:2, 4859:18, 4859:22, 4860:8,
4866:11
ton [1] - 4763:1
tone [2] - 4652:14, 4679:7
TONI [1] - 4634:3
Toni [1] - 4635:11
Tony [1] - 4854:20
took [29] - 4650:11, 4652:1, 4652:17,
4657:19, 4662:20, 4662:21, 4663:3,
4669:6, 4669:25, 4674:8, 4674:12,
4678:21, 4684:8, 4687:15, 4700:21,
4700:22, 4702:3, 4714:20, 4716:8,
4723:8, 4755:21, 4786:24, 4791:17,
4801:4, 4812:3, 4829:18, 4835:3,
4849:1, 4857:19
tool [1] - 4858:10
tooth [1] - 4752:5
top [7] - 4688:24, 4710:11, 4746:13,
4751:20, 4853:16, 4853:22
total [1] - 4649:21
totally [2] - 4777:2, 4840:6
touch [5] - 4684:3, 4687:12, 4794:6,
4822:21, 4854:13
tow [1] - 4788:13
towards [2] - 4651:19, 4724:7
tower [9] - 4700:15, 4717:8, 4717:11,
4717:14, 4717:18, 4740:17, 4817:6,
4817:8, 4837:25
towers [1] - 4687:12
town [2] - 4653:1, 4672:20
toy [2] - 4855:23, 4856:3
track [4] - 4668:10, 4754:8, 4827:18,
4829:16
Trade [1] - 4697:24
trade [1] - 4691:14
traffic [6] - 4716:14, 4717:8, 4717:11,
39
4717:12, 4717:13, 4817:11

tragedies [1] - 4687:18
Train [4] - 4718:3, 4724:5, 4724:8,
4724:10
train [3] - 4635:22, 4690:12, 4816:6
trainer [1] - 4741:24
training [8] - 4668:17, 4690:13,
4690:14, 4742:11, 4742:12, 4801:17,
4820:16, 4855:7
transaction [1] - 4851:14
transcribed [1] - 4747:19
Transcript [1] - 4634:12
transcript [6] - 4659:13, 4721:12,
4780:7, 4793:16, 4801:3, 4809:4
Transcription [1] - 4634:12
transcripts [6] - 4721:6, 4761:3,
4767:15, 4768:1, 4769:15, 4778:19
transfer [2] - 4719:2, 4845:10
transit [1] - 4701:10
transportation [13] - 4661:23,
4695:24, 4696:5, 4701:5, 4701:7,
4701:8, 4701:11, 4701:23, 4702:9,
4702:11, 4702:16, 4703:13, 4834:22
trash [8] - 4713:15, 4726:8, 4741:14,
4743:9, 4756:25, 4808:7, 4808:13,
4809:2
travel [16] - 4681:7, 4725:7, 4726:4,
4727:17, 4727:18, 4727:19, 4727:23,
4728:2, 4728:5, 4728:6, 4752:16,
4754:9, 4754:15, 4831:24, 4836:1,
4839:6
traveled [5] - 4702:1, 4807:17,
4833:12, 4848:17, 4850:3
travelers [1] - 4857:6
traveling [3] - 4685:19, 4744:18,
4828:8
travelling [3] - 4646:17, 4655:13,
4681:24
treat [1] - 4857:7
treated [4] - 4649:13, 4715:22,
4745:12, 4745:13
treating [3] - 4723:16, 4734:4, 4736:18
treatment [8] - 4649:10, 4650:2,
4650:3, 4686:21, 4822:5, 4822:6,
4822:22, 4822:23
treats [1] - 4863:6
trial [17] - 4634:24, 4643:7, 4644:5,
4644:7, 4645:13, 4646:5, 4647:7,
4647:11, 4660:2, 4660:16, 4704:8,
4704:18, 4760:14, 4799:3, 4812:20,
4818:7, 4859:6
tribute [1] - 4684:12
tried [16] - 4659:19, 4659:20, 4660:17,
4664:1, 4664:19, 4692:19, 4692:25,
4695:5, 4730:6, 4730:14, 4739:21,
4789:25, 4793:21, 4812:4, 4818:9,
4818:19
tries [4] - 4652:18, 4718:13, 4732:4,
4740:4
Trinidad [75] - 4655:14, 4658:18,


4668:5, 4671:12, 4680:16, 4680:23,
4681:7, 4681:14, 4681:16, 4681:22,
4682:11, 4683:15, 4683:24, 4684:11,
4684:22, 4685:19, 4685:22, 4686:9,
4713:5, 4713:6, 4713:7, 4714:16,
4715:3, 4726:3, 4727:10, 4728:7,
4733:1, 4733:11, 4733:15, 4733:18,
4733:24, 4734:3, 4736:22, 4737:2,
4737:25, 4738:10, 4738:14, 4739:10,
4742:21, 4744:8, 4777:21, 4778:7,
4779:8, 4779:16, 4780:6, 4781:2,
4781:15, 4784:8, 4784:9, 4789:5,
4789:14, 4794:20, 4797:17, 4800:9,
4800:10, 4810:6, 4811:8, 4811:24,
4818:16, 4818:23, 4819:1, 4829:1,
4829:3, 4833:21, 4836:1, 4836:3,
4843:4, 4846:18, 4849:25, 4850:20,
4852:9, 4852:18, 4854:3, 4856:16
Trinidadian [1] - 4776:15
trip [14] - 4710:21, 4711:23, 4733:18,
4733:25, 4734:2, 4734:3, 4780:5,
4780:6, 4781:15, 4810:6, 4829:18,
4850:8, 4851:9, 4853:9
trips [5] - 4657:25, 4669:7, 4702:3,
4809:8, 4828:5
trouble [4] - 4682:10, 4799:20,
4828:19, 4828:20
truck [3] - 4722:19, 4741:25, 4742:3
true [24] - 4658:12, 4660:10, 4683:16,
4684:16, 4698:10, 4698:13, 4701:25,
4717:7, 4719:13, 4729:15, 4746:18,
4764:8, 4799:8, 4800:4, 4821:21,
4822:9, 4832:6, 4837:8, 4839:11,
4855:2, 4855:3, 4856:8, 4856:9,
4856:23
trust [10] - 4663:25, 4664:10, 4664:15,
4682:22, 4744:23, 4747:2, 4748:11,
4752:8, 4847:19
trusted [2] - 4688:23, 4853:15
trustworthiness [2] - 4686:13, 4751:4
trustworthy [1] - 4751:10
truth [4] - 4665:4, 4695:3, 4766:19,
4835:18
try [23] - 4660:1, 4663:13, 4677:6,
4677:8, 4686:12, 4688:22, 4707:22,
4730:19, 4740:24, 4745:9, 4764:11,
4771:5, 4789:16, 4793:11, 4793:12,
4793:13, 4793:14, 4805:7, 4810:4,
4818:9, 4828:13, 4842:7, 4850:3
Try [1] - 4827:3
trying [36] - 4647:18, 4692:20, 4693:4,
4693:24, 4694:4, 4705:17, 4709:17,
4730:23, 4731:15, 4740:6, 4740:7,
4751:11, 4752:2, 4757:14, 4764:3,
4770:5, 4770:6, 4780:23, 4799:21,
4799:23, 4799:24, 4810:4, 4815:13,
4824:2, 4824:3, 4824:7, 4827:5,
4827:9, 4827:15, 4828:20, 4831:8,
4831:9, 4840:15, 4853:4, 4856:16,
4856:18
turn [9] - 4644:23, 4667:3, 4686:18,

4716:22, 4723:8, 4740:9, 4793:1,
4793:3, 4852:14
turns [4] - 4663:7, 4727:16, 4740:14,
4746:21
TV [2] - 4684:10, 4819:1
twenty [1] - 4709:12
twice [5] - 4783:21, 4784:20, 4794:22,
4838:4, 4839:8
twin [1] - 4687:12
two [38] - 4638:9, 4642:16, 4646:8,
4647:1, 4647:2, 4650:1, 4657:9,
4657:14, 4669:12, 4678:24, 4679:8,
4694:14, 4703:18, 4703:19, 4705:16,
4723:23, 4732:13, 4737:15, 4738:14,
4754:16, 4758:15, 4779:8, 4779:9,
4781:21, 4781:24, 4786:1, 4791:19,
4794:5, 4794:8, 4806:10, 4809:23,
4810:7, 4814:6, 4814:8, 4822:21,
4848:17
Two [2] - 4698:17
type [7] - 4666:7, 4684:15, 4687:5,
4743:4, 4796:22, 4796:23, 4836:16
types [1] - 4654:15
tyranny [1] - 4654:7
U
U.S [29] - 4633:4, 4633:19, 4648:10,
4650:10, 4661:10, 4663:9, 4672:14,
4688:10, 4690:18, 4700:22, 4700:23,
4701:1, 4709:3, 4744:11, 4746:22,
4746:23, 4760:12, 4821:19, 4822:4,
4822:8, 4823:5, 4833:4, 4833:13,
4852:8, 4858:4, 4858:5
ugly [17] - 4708:21, 4709:10, 4709:21,
4709:22, 4709:24, 4709:25, 4718:20,
4757:19, 4795:12, 4795:14, 4796:2,
4799:21, 4808:7, 4808:9
ultimately [2] - 4811:6, 4819:2
unable [1] - 4860:1
unanimously [1] - 4696:19
uncle [1] - 4769:7
undeniable [1] - 4650:1
under [23] - 4675:11, 4682:20,
4684:20, 4684:23, 4685:5, 4685:9,
4686:1, 4692:3, 4705:16, 4780:25,
4808:5, 4811:21, 4813:4, 4813:8,
4816:4, 4824:6, 4829:23, 4830:9,
4831:3, 4835:11, 4835:14, 4840:1,
4840:6
undercover [3] - 4733:10, 4733:22,
4737:3
underground [2] - 4697:13, 4815:23
underlying [1] - 4696:10
underneath [1] - 4685:3
understood [2] - 4685:14, 4803:12
undertake [2] - 4690:11, 4700:9
unequivocal [1] - 4845:23
unequivocally [1] - 4678:20

unfortunately [2] - 4643:3, 4644:3
unguarded [1] - 4671:23
unhappy [2] - 4745:11, 4745:12
uninterested [1] - 4768:3
unique [1] - 4718:16
UNITED [2] - 4633:1, 4633:3
united [1] - 4633:11
United [43] - 4633:15, 4634:25,
4645:9, 4649:13, 4650:3, 4651:20,
4661:4, 4663:13, 4664:12, 4667:21,
4668:2, 4669:3, 4673:17, 4693:25,
4697:21, 4698:10, 4700:25, 4710:20,
4711:1, 4712:9, 4712:13, 4714:6,
4731:13, 4731:25, 4744:25, 4745:4,
4745:8, 4746:2, 4746:8, 4747:8,
4812:23, 4813:3, 4819:8, 4821:18,
4821:24, 4822:6, 4822:23, 4823:9,
4834:25, 4858:1, 4858:9
unknown [1] - 4672:3
unlawful [3] - 4695:20, 4698:9,
4752:15
unless [6] - 4715:2, 4727:6, 4741:1,
4748:12, 4790:8, 4791:20
unluckiest [1] - 4663:6
unnecessary [1] - 4665:24
unraveled [1] - 4656:5
unrecorded [1] - 4768:4
up [173] - 4634:22, 4642:14, 4642:18,
4642:20, 4643:14, 4645:9, 4646:13,
4646:25, 4647:8, 4647:19, 4648:7,
4653:14, 4655:12, 4656:1, 4656:19,
4660:2, 4660:11, 4660:17, 4661:2,
4662:17, 4662:21, 4666:14, 4666:16,
4669:4, 4670:22, 4671:2, 4671:9,
4672:12, 4672:13, 4674:12, 4675:16,
4675:21, 4676:4, 4676:7, 4676:10,
4676:22, 4678:7, 4679:5, 4679:11,
4681:6, 4681:14, 4681:17, 4681:18,
4682:16, 4685:23, 4687:2, 4688:5,
4688:21, 4688:22, 4691:21, 4691:23,
4693:2, 4694:1, 4694:14, 4694:24,
4694:25, 4695:4, 4695:13, 4697:20,
4699:12, 4699:13, 4700:14, 4701:18,
4704:11, 4704:15, 4705:10, 4707:5,
4707:8, 4708:24, 4710:16, 4711:24,
4712:17, 4712:22, 4712:25, 4713:3,
4713:14, 4717:24, 4718:5, 4718:13,
4719:3, 4720:1, 4725:16, 4725:21,
4732:9, 4739:22, 4740:6, 4741:22,
4742:17, 4744:9, 4745:10, 4745:13,
4748:13, 4751:18, 4751:24, 4754:14,
4754:20, 4760:6, 4762:1, 4763:11,
4764:13, 4764:24, 4768:21, 4769:4,
4776:2, 4777:21, 4778:1, 4778:4,
4778:12, 4778:15, 4779:12, 4781:7,
4781:17, 4782:1, 4784:24, 4785:22,
4786:3, 4789:2, 4789:11, 4790:21,
4794:20, 4796:17, 4796:25, 4801:16,
4807:3, 4807:16, 4808:17, 4809:22,

40

4811:2, 4813:19, 4813:24, 4814:5,
4815:1, 4819:24, 4820:24, 4821:5,
4821:14, 4824:2, 4824:11, 4827:20,
4828:22, 4829:5, 4831:16, 4832:3,
4833:18, 4834:24, 4836:4, 4836:8,
4836:17, 4840:13, 4840:23, 4841:12,
4841:23, 4842:2, 4842:8, 4842:9,
4842:15, 4843:22, 4845:19, 4846:6,
4850:3, 4854:16, 4855:25, 4857:1,
4858:25, 4859:4, 4860:9, 4863:20,
4863:21
upset [1] - 4673:5
urgency [1] - 4671:14
useless [1] - 4727:12
usual [1] - 4756:5
utterly [1] - 4840:7
V
Van [1] - 4724:7
varying [1] - 4748:20
Vatican [1] - 4792:6
vehicle [5] - 4701:5, 4701:8, 4702:11,
4702:16, 4718:13
vehicles [1] - 4701:10
Venezuela [6] - 4658:17, 4677:15,
4689:21, 4776:6, 4786:13, 4852:21
Venezuelan [2] - 4851:23, 4851:25
venture [1] - 4691:16
ventures [5] - 4648:14, 4691:12,
4756:13, 4823:2, 4823:3
verbatim [2] - 4783:3
verbiage [1] - 4749:17
verdict [3] - 4645:6, 4858:19, 4858:20
verify [2] - 4748:12, 4767:7
version [3] - 4676:9, 4676:11, 4677:7
versus [1] - 4634:25
vested [1] - 4796:12
vets [1] - 4686:11
viable [2] - 4691:16, 4853:7
victory [1] - 4848:21
video [63] - 4658:1, 4669:21, 4669:22,
4669:23, 4669:24, 4670:6, 4670:21,
4671:10, 4671:17, 4672:21, 4673:23,
4674:21, 4674:23, 4688:15, 4699:22,
4700:4, 4703:1, 4709:14, 4719:9,
4722:18, 4722:19, 4723:5, 4723:8,
4723:17, 4723:18, 4723:20, 4724:4,
4724:9, 4727:3, 4727:4, 4727:6,
4727:9, 4728:11, 4732:13, 4740:3,
4740:15, 4740:18, 4740:23, 4740:25,
4745:23, 4748:4, 4755:3, 4755:6,
4757:17, 4769:17, 4769:19, 4817:15,
4823:25, 4824:1, 4824:18, 4824:19,
4824:22, 4825:2, 4825:3, 4826:1,
4833:13, 4837:20, 4837:24, 4838:4,
4839:8, 4853:25, 4863:9
videos [5] - 4703:2, 4768:16, 4768:17,
4839:1
videotape [6] - 4722:17, 4722:25,

4724:14, 4724:16, 4724:21, 4831:24
videotapes [1] - 4721:4
view [2] - 4656:14, 4661:6
views [2] - 4654:15, 4670:22
violate [2] - 4646:21, 4657:9
violates [1] - 4657:11
violence [3] - 4668:10, 4684:12,
4789:6
violent [3] - 4649:8, 4691:18, 4841:4
visa [9] - 4746:9, 4746:23, 4850:17,
4851:18, 4851:23, 4852:1, 4852:20,
4852:22, 4853:7
visible [1] - 4718:2
visit [2] - 4815:22, 4829:2
visits [1] - 4685:12
vital [2] - 4648:4, 4687:8
voice [3] - 4648:21, 4653:5, 4653:6
voluntarily [1] - 4734:13
volunteers [1] - 4690:12
vouch [1] - 4664:8
vulnerable [2] - 4671:19, 4672:7
W
wagon [1] - 4693:14
Wahab [8] - 4673:14, 4676:2, 4676:6,
4676:10, 4676:25, 4794:6, 4794:8,
4839:6
Wahab's [1] - 4847:2
Wahib [7] - 4729:4, 4729:8, 4729:10,
4729:25, 4730:2, 4733:3, 4733:5
Wahid [1] - 4729:25
wait [10] - 4636:12, 4725:18, 4725:20,
4744:12, 4781:16, 4794:5, 4794:7,
4809:18, 4810:9, 4827:7
waited [6] - 4664:6, 4797:24, 4798:1,
4810:1
waive [2] - 4635:9, 4635:12
waiving [1] - 4636:4
walk [9] - 4651:6, 4672:20, 4681:24,
4682:2, 4682:3, 4769:18, 4769:19,
4769:20, 4775:17
wall [1] - 4768:22
walls [1] - 4841:11
wants [33] - 4650:9, 4651:10, 4682:12,
4682:25, 4689:11, 4715:18, 4719:25,
4722:9, 4724:25, 4728:16, 4728:17,
4732:9, 4734:18, 4736:23, 4737:4,
4737:24, 4737:25, 4742:25, 4743:4,
4744:8, 4744:9, 4744:10, 4744:11,
4748:17, 4756:15, 4757:2, 4771:10,
4775:24, 4778:14, 4780:17, 4799:11,
4810:19, 4848:5
war [3] - 4654:9, 4821:20, 4848:24
warnings [1] - 4863:16
warranted [1] - 4645:21
wary [2] - 4685:10, 4686:2
waste [3] - 4686:16, 4810:17, 4824:5
41
wasted [1] - 4857:15

wasting [1] - 4827:17
watch [3] - 4655:12, 4655:17, 4829:24
watched [2] - 4745:23, 4826:3
watches [1] - 4717:9
watching [4] - 4655:10, 4674:23,
4703:4, 4768:16
Water [1] - 4676:14
water [14] - 4670:13, 4670:17,
4720:22, 4720:23, 4740:5, 4740:7,
4740:10, 4742:23, 4756:13, 4823:15,
4824:5
ways [7] - 4677:24, 4744:20, 4752:15,
4765:25, 4796:18, 4798:17, 4798:18
wayward [1] - 4683:4
weak [2] - 4736:19, 4817:21
weak-minded [1] - 4736:19
wealth [1] - 4830:20
weapon [1] - 4795:4
weaponry [1] - 4855:9
weapons [3] - 4668:17, 4685:3,
4856:21
wear [4] - 4674:7, 4674:10, 4681:23,
4681:24
wearing [1] - 4735:25
week [7] - 4674:13, 4678:3, 4678:15,
4678:17, 4754:5, 4766:13, 4853:8
weekend [3] - 4638:24, 4644:3,
4705:22
weeks [8] - 4678:22, 4679:8, 4679:12,
4692:18, 4726:5, 4794:5, 4794:8
welcome [7] - 4644:2, 4708:7,
4761:16, 4805:20, 4857:5, 4857:8,
4857:10
well-known [4] - 4658:3, 4665:16,
4676:19, 4688:1
west [4] - 4792:3, 4798:17, 4798:18,
4798:20
West [3] - 4634:1, 4653:10, 4667:21
western [1] - 4819:9
Western [1] - 4653:15
whalen [3] - 4809:14, 4815:9, 4821:12
WHALEN [17] - 4633:22, 4705:20,
4707:6, 4707:13, 4707:24, 4708:3,
4708:11, 4708:20, 4722:18, 4723:1,
4727:1, 4741:9, 4760:5, 4861:12,
4862:7, 4863:19, 4867:5
Whalen [31] - 4635:7, 4705:18, 4707:4,
4708:17, 4708:18, 4708:19, 4757:25,
4764:2, 4765:1, 4789:17, 4795:7,
4808:4, 4808:25, 4810:7, 4810:23,
4811:6, 4813:5, 4813:22, 4814:4,
4815:16, 4817:7, 4819:23, 4820:11,
4822:7, 4822:18, 4822:21, 4831:5,
4834:20, 4834:24, 4862:12, 4862:25
whereabouts [1] - 4668:8
wherein [1] - 4864:25
whisperer [1] - 4692:12
whisperers [2] - 4693:3, 4840:5
who'd [2] - 4654:16, 4664:2


whole [19] - 4645:18, 4650:9, 4651:6,
4656:7, 4688:7, 4689:1, 4700:18,
4722:13, 4731:18, 4744:14, 4748:3,
4766:9, 4771:12, 4777:8, 4792:17,
4792:22, 4821:5, 4840:10
whole-heartedly [1] - 4689:1
wholeheartedly [1] - 4821:17
wide [1] - 4823:8
widely [4] - 4812:22, 4812:24, 4819:7,
4819:12
wife [7] - 4712:8, 4747:5, 4770:12,
4796:4, 4796:7, 4834:14
wild [2] - 4807:3, 4807:11
willing [9] - 4648:2, 4665:11, 4665:12,
4673:17, 4684:4, 4690:13, 4725:20,
4745:9, 4802:20
Willis [2] - 4713:11, 4808:10
willy [1] - 4817:10
willy-nilly [1] - 4817:10
wind [1] - 4850:3
window [2] - 4757:12, 4808:10
WINGE [1] - 4633:18
winter [1] - 4812:18
wire [2] - 4674:8, 4674:10
wish [1] - 4704:10
withdraw [2] - 4865:25, 4866:4
withdrawing [1] - 4865:17
withdrawn [1] - 4866:9
witness [21] - 4651:3, 4653:18,
4655:20, 4659:15, 4662:10, 4674:14,
4678:21, 4683:22, 4684:25, 4691:7,
4695:7, 4710:7, 4710:8, 4717:11,
4747:2, 4802:25, 4803:3, 4815:19,
4834:2, 4835:16, 4856:10
WITNESS [1] - 4867:2
witnesses [4] - 4661:18, 4807:9,
4832:12, 4855:10
woman [2] - 4636:25, 4661:15
women [1] - 4661:14
wonder [1] - 4851:23
wonderful [1] - 4745:8
wondering [1] - 4767:12
word [12] - 4655:2, 4655:12, 4693:9,
4719:23, 4769:16, 4779:19, 4782:13,
4789:9, 4791:5, 4793:25, 4830:21,
4832:5
words [38] - 4647:23, 4649:9, 4649:22,
4650:21, 4651:19, 4651:20, 4652:9,
4652:20, 4653:18, 4654:1, 4655:17,
4660:15, 4683:17, 4689:15, 4771:10,
4771:11, 4771:14, 4781:11, 4800:7,
4806:17, 4806:20, 4806:21, 4808:5,
4808:18, 4809:17, 4810:13, 4810:25,
4831:23, 4839:24, 4842:10, 4846:21,
4848:8, 4848:10, 4848:11, 4848:12,
4848:15
wordy [1] - 4749:12
works [5] - 4655:8, 4754:19, 4793:6,
4822:10, 4822:14
world [22] - 4648:4, 4649:11, 4650:4,
4653:14, 4653:22, 4655:7, 4687:7,

4691:1, 4713:13, 4762:9, 4762:11,
4762:20, 4771:13, 4791:15, 4803:15,
4803:16, 4850:16, 4851:10, 4852:3,
4852:19, 4852:23
World [1] - 4697:24
worldly [1] - 4779:22
worldwide [5] - 4653:13, 4654:6,
4784:17, 4784:18, 4837:3
worried [5] - 4675:18, 4684:18,
4740:24, 4814:24, 4817:5
worry [1] - 4682:5
worst [1] - 4748:7
worth [2] - 4740:15, 4830:3
Wow [1] - 4730:13
wreck [1] - 4702:17
write [4] - 4701:19, 4788:3, 4791:3,
4799:2
writing [3] - 4654:4, 4749:9, 4808:8
wrote [6] - 4692:4, 4692:11, 4754:20,
4763:21, 4768:12, 4768:15
Wyck [1] - 4724:7
42
Yorkers [1] - 4650:6

young [1] - 4719:22
yourself [8] - 4655:24, 4683:21,
4703:11, 4719:15, 4723:10, 4793:5,
4799:20, 4834:9
yourselves [5] - 4705:2, 4758:8,
4804:8, 4859:12, 4860:7
Y
Yahud [4] - 4654:9, 4654:11, 4654:12
yahud [2] - 4848:24, 4849:1
yards [1] - 4671:24
Yasin [3] - 4658:4, 4668:8, 4682:8
year [13] - 4696:14, 4719:8, 4744:23,
4745:20, 4750:19, 4756:2, 4756:7,
4769:5, 4807:20, 4830:1, 4850:13,
4852:4, 4858:5
yearly [1] - 4784:20
years [36] - 4648:11, 4648:16,
4648:17, 4648:25, 4653:9, 4654:13,
4655:9, 4660:8, 4672:10, 4683:24,
4709:12, 4717:15, 4719:17, 4723:24,
4750:8, 4755:15, 4764:20, 4770:7,
4788:2, 4789:1, 4789:4, 4795:10,
4796:4, 4801:6, 4810:4, 4815:12,
4832:22, 4833:24, 4834:15, 4836:3,
4840:6, 4850:11, 4852:4, 4853:13,
4856:16
yell [1] - 4652:4
yellow [1] - 4699:16
yesterday [5] - 4638:20, 4638:25,
4639:1, 4640:22, 4861:18
Yiddish [1] - 4719:4
yoke [1] - 4653:15
YORK [1] - 4633:1
York [30] - 4633:5, 4633:16, 4633:23,
4633:24, 4634:2, 4634:5, 4634:9,
4646:11, 4680:14, 4710:15, 4714:3,
4714:5, 4714:12, 4714:15, 4714:18,
4714:21, 4715:5, 4715:12, 4715:19,
4715:25, 4716:9, 4725:2, 4725:10,
4725:12, 4733:18, 4747:17, 4756:24,
4828:4

Z
ZAINAB [1] - 4633:18
Zainab [1] - 4635:3
zero [1] - 4855:20
zoom [2] - 4851:1, 4856:5

(English) Transcript of Trial - United States of America V Russell Defreitas, Abdul Kadir - 7-26-2010

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(English) Transcript of Trial - United States of America V Russell Defreitas, Abdul Kadir - 7-26-2010

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4633

UNITED STATES DISTRICT COURT

July 26, 2010

HONORABLE DORA L. IRIZARRY

For the Government:

For the Defendant:

RONALD E. TOLKIN, RMR, CRR

U.S.A. v. DEFREITAS and KADIR

For the Defendant:

SANKOFA LAW FIRM

RONALD E. TOLKIN, RMR, CRR

Minutes Taken Stenographically.

(Time noted 9:18 a.m.)

Do we know where the defendants are?

There was a delay at the jail.

Criminal cause on trial, Docket

07-CR-543, United States versus Defreitas and Kadir.

RONALD E. TOLKIN, RMR, CRR

U.S.A. v. DEFREITAS AND KADIR

Please state your appearances for the record.

Berger and Zainab Ahmad for the government.

Jason Jones, Marshall Miller, Berit

We are joined at the counsel table by Detective

Good morning, Your Honor.

Federal Defenders by Len Kamdang and Mildred Whalen.

Mr. Defreitas is not here yet.

will waive his appearance.

For administrative matters, we

Kafahni Nkrumah and Toni Messina for Mr. Abdul

We waive his appearance for administrative matters.

Thank you for gracing us with your

appearance at this hour, Ms. Messina.

Good morning, Your Honor.

Everyone was supposed to be here at

You realize that.

You always realize that.

everything else was covered, everyone else was able to be

Everyone was supposed to be here at

Whatever you had to do to make sure you were here on

I understand that there has been some delay in the

RONALD E. TOLKIN, RMR, CRR

U.S.A. v. DEFREITAS AND KADIR

production of the defendants due to something that happened at

number of matters that we do need to address.

the attorneys waiving their clients' appearances so that we

can address these matters.

I have no idea what that is.

Just so that the attorneys can start thinking about

what they want to counsel their clients, I understand this is

Are they here?

We would wait for the defendants to enter the

(Whereupon the defendants enter the courtroom at

You can bring them out.

Good morning, Mr. Defreitas and

I was about to alert your attorneys as

to a matter that has been brought to the Court's attention.

First of all, we've got a couple of jurors who are running a

bit late but they would be here.

We have one juror, juror sits in seat number eight,

RONALD E. TOLKIN, RMR, CRR

U.S.A. v. DEFREITAS AND KADIR

She is very sick.