IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION 

UNITED STATES OF AMERICA ( NUMBER 3: 04-240-G 

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VERSUS ( 

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HOLY LAND FOUNDATION, ET AL. ( September 17, 2007

__________________________________________________________

VOLUME 30

TRANSCRIPT OF THE TRIAL

BEFORE THE HONORABLE A. JOE FISH

__________________________________________________________

A P P E A R A N C E S:

For the Government: MR. JIM JACKS

MR. BARRY JONAS

MS. ELIZABETH SHAPIRO

MR. NATHAN GARRETT

Assistant United States Attorney

UNITED STATES DEPARTMENT OF JUSTICE

NORTHERN DISTRICT OF TEXAS

U.S. Courthouse 

1100 Commerce Street

Dallas, Texas 75242

214/659-8600

For the Defendant Shukri Baker:

MS. NANCY HOLLANDER 

MS. TERESA DUNCAN

FREEDMAN BOYD DANIELS 

HOLLANDER 

20 First Plaza, Suite 700 

Albuquerque, NM 87102

505/842-9960 

CASSIDI L. CASEY, CSR, 214-354-3139

UNITED STATES DISTRICT COURT

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For the Defendant El-Mezain:

MR. JOSHUA DRATEL

MR. AARON J. MYSLIWIEC

LAW OFFICE OF JOSHUA L. DRATEL

14 Wall Street, 28th Floor

New York, NY 10005

212/732-0707 

For the Defendant Mufid Abdulqader:

MS. MARLO CADEDDU

LAW OFFICE OF MARLO P. CADEDDU

3232 McKinney Avenue, Suite 700

Dallas, Texas 75204

214/744-3015 

For the Defendant Elashi:

MS. LINDA MORENO

LAW OFFICE OF LINDA MORENO

PO BOX 10985 

Tampa, Florida 33679

813-247-4500 

MR. JOHN D. CLINE 

Jones Day 

555 California St 

26th Floor 

San Francisco, CA 94104-1500 

415/875-5812 

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For the Defendant Odeh:

MR. GREG WESTFALL

WESTFALL PLATT CUTRER

Mallick Tower

One Summit Avenue, Suite 910

Fort Worth, Texas 76102

817/877-1700

Court Reporter: Cassidi L. Casey, CSR No. 1703

1100 Commerce Street, Rm 15D6L

Dallas, Texas 75242

214-254-3139

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P R O C E E D I N G S:

THE COURT: Good morning, Ladies and Gentlemen. 

I hope all of you had a pleasant and restful weekend. We 

are now moving into a new phase of the trial, and I want 

to give you an overview of what to expect over the next 

few days. 

As I told you when we were last together last 

week, Counsel will now be given an opportunity to argue to 

you what they believe the evidence in this case has shown 

or not shown. And I have allotted a maximum of six hours 

per side for that closing argument. Now, under the 

schedule that we have been using for trial, we are 

normally in the courtroom about five to five and a half 

hours per trial day. So if all parties use the full 

amount of time that I have allocated to them, that means 

that we probably will not hear the last of the closing 

arguments until sometime Wednesday. 

And at the conclusion of the closing arguments, 

I will then give you my instructions on the law which I 

have reduced to writing and which have been provided to 

counsel. In fact, they may refer to those instructions in 

their closing argument and if they do, it's not because 

they are clairvoyant. They have actually seen a copy of 

the instructions which you will also be given when I read 

them to you at the conclusion of the argument. But I 

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anticipate that will be Wednesday before that happens. 

Then you will retire to the juryroom to begin 

your deliberations. However, I wanted to let you know for 

the purposes of planning your schedules, that due to 

commitments that I have made, we will not be in session on 

Friday of this week. So I don't mean to suggest 

necessarily that you should reach a verdict on Thursday. 

I think that's probably unlikely and unrealistic. But I 

just wanted to let you know what our schedule for this 

week will likely be. Now, keep in mind during closing 

arguments, what counsel say -- indeed what they have said 

at any time during the trial -- is not evidence. Rather, 

this is their interpretation or analysis of the evidence 

which you are free to accept or reject depending upon how 

closely it coincides with your own memory of the evidence 

and also depending on how persuasive you think the 

argument is. As has been true throughout the case, the 

government as the prosecution and as the party with the 

burden of proof will have the right to begin the argument, 

but in recognition of that burden of proof, the government 

will also have the right to finish the argument. So some 

of the government's six hours will be devoted to the 

beginning phase of the argument, and then we will hear 

from all defense counsel in turn, and then we will hear 

from counsel for the government again, and then I will 

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give you my instructions on the law. 

Who will be arguing the case initially for the 

government? 

MR. JONAS: Your Honor, I will. 

THE COURT: Mr. Jonas, do you have any idea how 

much time you want to use at this point? 

MR. JONAS: Your Honor, I think I will be using 

four hours today. 

THE COURT: Ladies and Gentlemen, I will try as 

much as possible not to interrupt counsel to take our 

recesses, but with a four-hour block I think we will need 

to take our mid-morning recess and our luncheon recess. 

Mr. Jonas, do you want me to give you any 

warnings about how much time you have used at any point? 

MR. JONAS: Not this morning, your Honor. Maybe 

after lunch, I'll let you know if I need a warning. 

THE COURT: Thank you. We'll hear now from 

counsel for the government. 

MR. JONAS: Please the Court. 

THE COURT: Yes, sir. 

MR. JONAS: Defense counsel, fellow prosecutors. 

Ladies and Gentlemen of the Jury. Home stretch, we're 

almost done. Good morning. I want to start off by 

thanking you not just for the government but the defense 

as well for your patience and attention. We really do 

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appreciate the jury service that you guys have done in 

this courtroom. As his Honor has said, this is our 

opportunity to talk to you about the evidence that you 

have heard over the past several months. But before I do 

that, I want to talk to you about a few points to keep in 

mind. 

Now, the first point is you have heard a lot of 

foreign-sounding names. It's understandable that you are 

not going to remember all of those names. You are not 

going to remember who those people were and what they were 

associated with in this trial. And I want you to know 

that you don't have to worry about that. Don't get hung 

up on remembering every single name that you have heard. 

For example, you have heard some of the leaders of the 

Jenin Zakat Committee and their names. Don't bother about 

the names. What I want you to remember is the leaders of 

the Jenin Zakat Committee were HAMAS. You have heard the 

names of some of the speakers that the HLF brought into 

the United States to raise funds on behalf of the HLF. 

Again, don't worry about remembering every single 

speaker's name. Just remember those speakers were members 

and leaders of HAMAS. There were five names I do want you 

to remember, and those are the defendants: Shukri Abu 

Baker, Abdulraham Odeh, Mohamed El-Mezain, Ghassan Elashi 

and Mufid Abdulqader. Those are the names that you need 

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to remember. 

The second thing I want you to keep in mind as I 

go through my argument to you and as you go through the 

records, the exhibits, during your deliberations is that 

is this what a real charity would do? Think about what 

you guys think of as a regular moral charity -- the 

American Red Cross, the United Way. Think about those 

charities and how they operate. As you go through the 

exhibits, think about is this what a real charity would 

do? Would a real charity have a security document to tell 

it how to act? Would a real charity bring in a foreign 

terrorist organization to raise funds on its behalf? 

The answer is no. But an organization that's 

part of a terrorist organization would. 

The third thing I want to mention is that you 

have heard testimony brought out by the defense during 

their witnesses and on cross examination the government's 

witnesses about the Government of Israel and things the 

Government of Israel has done in regard to the Palestinian 

people. That's not why you are here. You are not here to 

decide who's right and who is wrong in the Israel 

Palestinian conflict. I'm sure defense counsel when they 

get up and argue before you, they will talk about a lot 

about what the Government of Israel has done. They are 

doing that to distract you from the main issue in this 

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case. As Mr. Jacks told you two months ago when he 

appeared before you, the issue is whether these defendants 

knowingly and willfully gave money to HAMAS -- pure and 

simple -- not whether Israel is right or wrong. It's 

about HAMAS. HAMAS is a terrorist organization and no 

U.S. person or anyone in the United States is allowed to 

give money to HAMAS. 

Now, I want to talk for a few moments about 

HAMAS itself. If you remember the government's first 

witness, Dr. Levitt, he was the government's expert on 

HAMAS. He educated us on what HAMAS is and how HAMAS was 

created. In 1928, a group was formed in Egypt call the 

Muslim Brotherhood. And the goals of the Muslim 

Brotherhood is basically to turn the world into a world 

run by Islamic law. So instead of having laws that we do 

where they are passed by Congress and not religious laws, 

the world would operate under Muslim law. And the Muslim 

Brotherhood over the years grew and formed chapters in 

different parts of the world, including a chapter in the 

Gaza Strip. 

If I can, I will show you the map, 24-2, that we 

showed you early on. What we have on the right is Israel 

as we know it. This strip over here is the Gaza Strip. 

This portion over here, the West Bank. They make up the 

Palestinian Territories. Israel is surrounded by Egypt in 

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the south, Jordan to the east and Syria and Lebanon to the 

north. 

So the Muslim Brotherhood formed a chapter in 

Gaza as early as 1948 when Israel was first formed as a 

country. And through time that chapter grew until the 

1980's when it was taken over and run by a man name Sheikh 

Ahmad Yassin. You have heard that name several times. 

Ahmad Yassin was based in Gaza, and he ran, not just the 

Muslim Brotherhood, but there were certain institutions 

that he set up -- and I'll talk about those in a few 

moments -- which were Muslim Brotherhood institutions. 

Now, in December of 1987 something happened. 

Israel had been subjected to several terrorist attacks. 

And around the same time those attacks were happening, an 

Israel citizen who was driving a truck ran into a crowd of 

Palestinians. Some people believed that was on purpose in 

retaliation for the attacks, and some people believe that 

was an accident. For whatever reason, it happened, and it 

caused an uprising among the Palestinian people, a grass 

roots uprising, one that was not directed by any 

organization or any particular leader, and that uprising 

became known as the Intifada. Today we call it the First 

Intifada because a year later there was a Second Intifada. 

Back then we called it the Intifada. 

Well, the Palestinian branch of the Muslim 

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Brotherhood led by Sheikh Yassin decided to do something 

and get involved. There were concern if they didn't get 

involved in this Intifada that they would lose ground to 

other Palestinian groups such as the PLO and other groups. 

So they decided to reform themselves and they did in the 

form of HAMAS, also known as Islamic Resistance Movement 

and sometimes referred to as just the Movement. 

Palestinians who were Muslim Brotherhood back 

then became HAMAS members. These institutions formed by 

Sheikh Yassin that were Muslim Brotherhood institutions 

became HAMAS institutions. Back then, HAMAS was not just 

throwing rocks at the Intifada, as they told you during 

their opening statement, but they were committing more 

violent acts, as Dr. Levitt told you, including kidnapping 

of Israeli soldiers. 

Now shortly after being formed in 1988, hAMAS 

came out with a charter, its Constitution in effect. And 

that Constitution has not changed to this day. If you 

remember, I went through it fairly extensively with 

Dr. Levitt, and I'm not going into detail like I did then, 

but you can look at it when you are deliberating. It's 

21-61. I want to point out a couple of things about the 

charter. The charter calls for the destruction of Israel. 

HAMAS does not want a two-state solution; a two-state 

solution being that the West Bank and Gaza form one 

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country, the country of Palestine, and Israel remains as 

the Country of Israel with the two living side by side. 

That's not what HAMAS wants. HAMAS wants all of that area 

to be Palestine and the State of Israel to be completely 

eliminated. 

Now, in the charter it states Israel will exist 

and continue to exist until Islam obliterates it. The 

charter calls for the destruction of Israel through Jihad. 

Now, we heard Dr. Levitt say that Jihad can be 

two things: One of them being violence, and you have to 

look at the context of the word to determine if the 

meaning is violent. As Dr. Levitt told you, when you go 

through the charter the meaning of the word "destruction" 

is violence. So they are calling for the destruction of 

Israel through violence. 

The charter states initiatives and so called 

peaceful solutions and international conferences are in 

contradiction to the opinions and principals of HAMAS. 

Back in 1988 what they are saying is no peace, no peace 

talks, no peace conferences, period. Their goal is one 

goal only: Destroy Israel through violence. The charter 

states there is no solution for the Palestinian question, 

except through Jihad. Initiatives, proposals, conference 

are a waste of time. This is five years before the Oslo 

Accords which was an attempt at a peace process between 

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the Palestinian people and Israel. And I will talk more 

about those in a few minutes. 

The charter also calls for Muslims everywhere, 

not just Palestinians living in the West Bank and Gaza to 

commit to Jihad. It calls for economic jihad, a term 

defined by Dr. Levitt. What that basically means is if 

you can't commit your body to support HAMAS, then use your 

money to support those that are using their body. 

Now, Dr. Levitt also taught us about the 

structure of HAMAS, that it has three sections -- a 

military wing, social wing and political wing. And if we 

can pull up Government's Exhibit 23-3, this was the 

triangle that Dr. Levitt talked about that shows the 

structure. If you see, the social wing sits on the 

bottom. That's the foundation that the other two wings 

are built on. You have the political wing in the middle 

and then the military wing on the top of that. 

I want to talk about each wing separately for a 

moment. I want to talk about the order that Dr. Levitt 

talked about. The military wing is currently call the Izz 

Al Din Qassam Brigades. That name came out in early 1993, 

around that time. Before that, it was known as the 

Palestinian Mujihadeen. Military wing is what the name 

suggestions. Either commits soldiers, shootings, 

bombings. What HAMAS is most famous for? Suicide 

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bombings. 

Now, the military wing in committing its acts 

doesn't just focus on the Israel military, doesn't 

distinguish between civilians and military or young or old 

or men or women or even Israelis or foreigners. You heard 

Dr. Levitt talk about an attack on Mike's Place, a western 

style bar located right next to the American embassy. 

Now, the attacks that military wing commits are terror in 

every sense of the word, not just in the destruction and 

carnage, but also in the fact that Israelis on an everyday 

basis have to worry when they get on a bus if they are 

ever getting off the bus, if they go in a restaurant if 

that's the last meal they will have. That's where the 

attacks occur -- in public places -- in order to terrorize 

the population. As Dr. Levitt described, sometimes HAMAS 

will do two attacks at once. There will be a bomb go off, 

and as rescuers are running to help the victims, there 

would be a second bomb. 

The military wing doesn't just use men. They 

use women and children to help. For example, you have a 

woman accompanying a suicide bomber because a couple is 

less suspicious. You will have a child carry notes among 

members because the child is less likely to be searched. 

HAMAS will take credit for the attacks they commit. And 

the reason they take the credit is several ways. One is 

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through an issue of a communique which is like a press 

release. They will have a TV station announce some of 

these attacks and that they take credit for them. On the 

internet or in the newspapers. They will make posters 

praising the suicide bomber or showing a living will of 

the suicide bomber talking about the killing he plans on 

doing. HAMAS takes credit for these acts for two reasons. 

One is part of the terror so the Israeli public and the 

rest of the world knows that suicide bombing was committed 

by us and you need to be scared of us and watch out for 

us. They take credit so that the Palestinian people will 

know who to support. HAMAS committed this act, not some 

other group, my money is with HAMAS. 

The social wing of HAMAS is designed to win the 

hearts and minds of people. The social wing does things 

that we think of as humanitarian purposes. Schools, food, 

hospitals, libraries, mosques, things that on their face 

sound fairly benign or benevolent to the Palestinian 

people. But we know the reason HAMAS does this is to win 

those people over, to get those people to support HAMAS, 

and the reason why they want to support the Palestinian 

people is several fold. One is because if they get the 

support of the people when they need their help, they will 

have their help. For example, HAMAS needs someone to give 

their house up as a safehouse for a bomber. Well, I fed 

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your family, I now need you to hide this person, and the 

Palestinian people will do that. I need you to drive 

somebody to a location. Military wing needs someone 

driven to a location. People do that because HAMAS has 

won their hearts and minds through the social help that 

they have given. The social help also helps to get people 

to join HAMAS, become -- join the military wing. 

We talked about education in this trial. HAMAS 

is big on education. It's in their charter. The social 

wing teaches children in the ways of HAMAS. It 

brainwashes little five year old kids in kindergarten to 

praise suicide bombers so that when these children grow up 

they will become members of HAMAS. Remember the HAMAS's 

charter's purpose. It's to destroy Israel, not help the 

Palestinian people. Helping the Palestinian people is a 

means to an end. It's a means of achieving HAMAS's goal 

of destroying Israel through violent Jihad. 

The social wing also helps the military wing in 

other ways. For example, Dr. Levitt told us this one 

incident where arms, guns, munitions were found buried 

under a playground at a kindergarten because it was less 

likely to be searched. Chemicals in the hospital are used 

to make bombs in the HAMAS hospitals. HAMAS-run mosques 

are used as dead drops. In other words, they are passing 

messages in the mosque, and someone else will come in and 

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take it because it's less likely to be searched. 

The social wing supports the military wing also 

by giving the members cover. You will see that several 

members of the military wing will be employed by the Zakat 

Committees that are ministered for social support, and 

that gives those military members cover and protection. 

All of this gathers the support and loyalty of the 

Palestinian people, and it's what makes HAMAS one of the 

strongest and most successful terrorist groups in the 

Middle East. 

The third wing is the political wing. The 

political wing sits atop the military wing and social 

wing. The political wing runs the big picture of HAMAS. 

You heard Dr. Levitt say there is the inside leadership 

and the outside leadership, the inside leadership being 

the people on the ground in the West Bank and Gaza like 

Sheikh Yassin and others. The outside are people who 

aren't even living in Gaza and West Bank. Initially, they 

were living in Jordan and got kicked out to Lebanon. Two 

of those were Khalil Mishal and then Mousa Abu Marzook. 

Marzook was Number 1, and Khalil Mishal was Number 2, and 

when Mousa Abu Marzook was arrested in New York, they 

flipped places, and now Marzook is Number 2 and Khalil 

Mishal is 1. They make the big picture decisions. 

We heard testimony that HAMAS has 

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representatives in Iran, in Yemen, the Sudan and other 

countries. So they deal on the big level picture. 

We have heard several people talk about Mousa 

Abu Marzook being the leader of HAMAS. You don't have to 

take their word for it if you look at Government's Exhibit 

21-58, which is the letter from HAMAS to Senator Orin 

Hatch that identifies Mousa Abu Marzook. Mousa Abu 

Marzook was arrested in New York in 1995, and HAMAS was 

protesting the arrest and sent a letter to the Senator. 

They identify Mousa Abu Marzook as the leader of HAMAS 

back then. 

I want to turn your attention now back to the 

United States. I want to go back to the time that HAMAS 

was first formed in 1987, 1988. Around that time, 

initially Shukri Abu Baker, the defendant, was leaving in 

Indiana. Ghassan Elashi was living in Los Angeles. 

Shukri Abu Baker decides to start the Holy Land 

Foundation. Back then it was called the Occupied Land 

Fund. He moves to Los Angeles, and he starts it with 

himself, the Defendant Ghassan Elashi and the Defendant 

Mohamed El-Mezain. And just by way of an example so that 

you can see their titles, if you look at Government's 

Exhibit 11-20, that's just one of the tax returns. It 

says their position. Mohamed El-Mezain was Chairman of 

the Board, Ghassan Elashi was Treasurer and Shukri Abu 

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Baker was the Chief Executive Officer. 

Ghassan Elashi, if you look at 11-28, was also 

the treasurer. These guys were Holy Land Foundation at 

the beginning, its inception. They formed it and ran it. 

We know that as early as 1990 the Defendant Mufid 

Abdulqader was raising funds for HLF and a few years later 

the Defendant Abdulraham Odeh opened a New Jersey office 

and ran it until 2001. 

Ms. Hollander told you in her opening statement 

that the Holy Land Foundation was created because of a 

sick child that the Defendant Shukri Abu Baker had. We 

know that's not true. I'm not saying he didn't have a 

sick child. I'm saying that's not why the Holy Land 

Foundation was created. 

As I told you earlier, the Muslim Brotherhood 

had chapters throughout the world, not just in Gaza. 

There was a Muslim Brotherhood chapter here in the United 

States as early as the 1980's. The Muslim Brotherhood 

Worldwide, and the United States is not just made up of 

Palestinians. It's also made up of other nationalities -- 

Pakistanis, Egyptians and others. 

By 1987, 1988 when the Intifada was started and 

the HAMAS was created, the International Moslem 

Brotherhood -- the worldwide leadership -- decided to form 

Palestine committees in every country. And these 

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Palestine committees were created to support HAMAS, the 

HAMAS cause. And there was a Palestine Committee formed 

here in the United States. That Palestine Committee was 

directed again to support HAMAS in the United States. And 

that committee oversaw three organizations. It oversaw 

the Islamic Association of Palestine, IAP, which was 

already in existence prior to the formation of the 

Palestine Committee. We will see that the IAP existed as 

part of the Muslim Brotherhood in the United States from 

at least the early 1980's, and the IAP's role was to be 

sort of the media outlet for HAMAS; that is, to issue the 

communiques. The IAP published the HAMAS charter in the 

United States. The Palestine Committee also oversaw the 

United Association for Studies and Research, UASR. Their 

role was to be a think tank. They produced research on 

HAMAS, books on HAMAS. That was their role. The third 

was the Holy Land Foundation, and its role was to raise 

funds for HAMAS. 

Now, how do we know this? We know this in 

several ways. The first set of documents I want to talk 

about were documents taken from the home of Ismail El 

Barasse, a member of this Palestine Committee. El Barasse 

lived in Northern Virginia right outside of Washington, 

D.C., and he was sort of an archivist of the Muslim 

Brotherhood. He kept the history of the Brotherhood in 

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his home. 

Before I go to the first exhibit, I want to 

point out to you -- and I'm only going to give you a 

sampling of the El Barasse documents, not all of them, but 

you will have them all in your deliberations. And you are 

free to go through this. Before I go there, I want to say 

something about our exhibit system. We tried to number 

these as to where they came from. The El Barasse 

documents start with a 3. Of the Holy Land Foundation, 

all start with a 1. Documents seized from Infocom which 

was the company run by Defendant Ghassan Elashi and his 

brothers that was located across the street from Holy Land 

Foundation. A lot of Holy Land Foundation documents were 

found at Infocom. Those documents start with 2. As we go 

along I'll give you that key system. 

I want to start off with Government's Exhibit 

3-15, Page 10. What the second paragraph of this document 

states: "These two characteristics make the cause of 

Palestine a unique cause which requires a unique method 

and means to manage the struggle as well. This is what 

the Islamic movement, the Muslim Brotherhood, has 

realized. Therefore, it pays special attention to the 

cause of Palestine and established a special apparatus for 

it which requires support and assistance from all the 

Brotherhood's movements."

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Bottom half of the page it talks about the 

Palestine section or committee. "This is a special 

apparatus that the Muslim Brotherhood formed in order to 

support HAMAS." And what that says is "At the end of the 

Seventies the Shamm Countries" -- I believe Dr. Brown, the 

defense witness, identified the Shamm Countries as those 

countries surrounding Israel like Lebanon and Syria. "The 

Shamm Countries Movement opened a new section which was 

called the Palestine Section to oversee the affairs of the 

Ikhwan inside the Occupied Territories. It was considered 

the liaison between the followers of the Movement on the 

inside and outside. 

"In the beginning of the eighties, the Islamic 

action for Palestine experienced distinguished leaps. At 

the inside level groups and apparatuses were formed to 

confront the Zionist enemy, and they carried different 

names then such as the Palestinian Mujihadeen and other 

names." You recall again, Dr. Levitt said the military 

wing of HAMAS was known as the Palestinian Mujihadeen. 

Page 11, bottom half goes on to state "The 

Islamic Resistance Movement." We know that's HAMAS. 

"With the increase of the Intifada and the advance of the 

Islamic action inside and outside of Palestine, the 

Islamic Resistance Movement, HAMAS, provided through its 

activities in resisting the Zionist occupation a lot of 

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sacrifices from martyrs, detainees, wounded, injured 

fugitives, deportees, and it was able to prove that it is 

an original and effective movement in leading the 

Palestinian people. This Movement which was bred in the 

bosom of the mother movement, 'The Moslem Brotherhood' 

restored hope and life to the Muslim nation and the notion 

that the flare of jihad has not died out and that the 

banner of Islamic jihad is still raised." There again you 

see the connection between HAMAS and the Muslim 

Brotherhood. Again, Jihad, violence. 

If we turn to Page 14 of this document, the top 

part talks specifically about action in the United States. 

In fact, if you go up a little higher than that, it talks 

about some of the resolutions that were reached. Number 

17, the last resolution talks about asking country to 

increase financial and moral support for HAMAS. Number 5 

talks about Islamic action for the Palestinian cause in 

North America. I'm not going to read every exhibit. 

Don't worry. But this exhibit is a pretty good one that 

talks about the formation of the Palestine Committee. It 

says "Like other Western, Arab and Islamic arenas, the 

American arena has seen a move for action for the 

Palestinian cause by the grace of God and due to the 

presence of the Islamic Movement and its pioneer the 

Muslim Brotherhood. The first organizational frame for 

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Islamic Action for Palestine came in the beginning of the 

eighties when the leadership of the Movement decided to 

establish the Islamic Association for Palestine in North 

America." IAP, the media outlet. It publishes the 

communiques, etcetera. "When work developed, the Intifada 

was started and the Islamic Resistance Movement, HAMAS, 

was formed and the general apparatus for Palestine 

developed, and in light of the resolutions of the Guidance 

Office and the Shura Council of the International Movement 

to form Palestine Committees in all the countries, the 

General Director came and met with the leadership of the 

Movement in America in 1988."

So here we see the International Muslim 

Brotherhood coming to the United States to talk to the 

U.S. members of the Muslim Brotherhood about what they are 

going to do to support HAMAS. "After the discussion and 

agreement, a Palestine Committee was formed under the 

supervision of the executive office. The Committee was 

then tasked with supervising all the organizations which 

serve the plan of the Movement domestically and 

internationally in addition to the Palestinian cause. 

Among these organizations were The Islamic Association, 

the Occupied Land Fund and the United Association."

The Occupied Land Fund is the Holy Land 

Foundation. It's the name they originally used before 

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they changed the name to Holy Land Foundation a few years 

later. So what this document is saying is that the 

International Muslim Brotherhood decided that a Palestine 

Committee would be formed in the United States, that 

committee would be to support HAMAS and that committee 

would oversee the IAP, the HLF and UASR. 

If we go to -- I'm sorry. Page 15, the last 

page of this document. This document is in Arabic. We're 

reading the English translation. The last page, "The 

Palestinian cause -- or say the Islam's cause in Palestine 

-- needs today an effective and a distinguished role for 

the grand Islamic Movement as one fortified wall behind 

its leadership represented by the Shura Council and a 

strong support for their tool and striking wing, the 

Islamic Resistance Movement, HAMAS."

HAMAS was the striking wing for the Palestinian 

cause. Those strikes came in the form of violence. 

Government's Exhibit 3-17 is another document 

that talks about amending the bylaws of the Palestinian 

Committee, and that document specifically says that the 

Palestinian Committee will be called the Central 

Committee. They use both names, the Palestinian Committee 

and the Central Committee. That's on Page 8. 

Page 9 talks about issues related to the 

Occupied Land Fund. So it's about drawing a general 

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strategy for the Fund -- its budget, its employees, board 

of directors. So what we start to see is the Palestinian 

Committee exercising control over the HLF by determining 

its board of directors and budget, etcetera. In fact, in 

this document if we can turn to Page 12 it says "Remarks." 

Number 3, collection of donations for the Islamic 

Resistance Movement. So again, we see the role of the 

Palestine Committee, collecting money for HAMAS. And how 

do they do it? Through the HAMAS. 

Government's Exhibit 3-1. I would like to put 

this on the screen, Page 1. This is a chart for the 

Central Committee, an organizational chart for the 

Palestine Committee. It's using both names. We didn't 

create this. This was taken from the home of Ismail El 

Barasse. You see, you have a president, a Central 

Committee, IAP, UASR, Occupied Land Fund. You recall the 

accountant that testified for HLF. He said it was an 

independent organization that didn't answer to anybody but 

its board of directors. Does this show that? Absolutely 

not. It shows it answered to the Central Committee whose 

goal was to support HAMAS. 

Turn to Page 4, this lists out the members of 

the Palestine Committee. Look at the top. The first 

thing it says is Administrative Aspect, Chairman Mousa. 

Who do we know as Mousa? Mousa Abu Marzook, the leader of 

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HAMAS. He's also doubling up as the leader of the 

Palestine Committee. Look on the left where it says 

Committee Chairman Palestinian Action Aspects, we see 

members of the Central Committee, Mousa, Mousa Abu 

Marzook; Number 4, El Barasse, Ismail El Barasse, the 

person whose house this came from. 

Again, don't get hung up on the names. I know 

I'm throwing a lot of names at you, but don't worry about 

every single one. Number 5, there is a name I want you to 

remember, Mohamed El-Mezain. Number 9, Shukri, the 

Defendant Shukri Abu Baker. Under the Executive 

Committee, we see Omar Yehya, who's also known as Omar 

Ahmad. We will see his name later and other names that 

we're coming across as we talk this morning. 

Looking again on this organizational chart, 

Number 4, Charitable and Humanitarian Aspect, who names do 

we see? El-Mezain. What organization do we see listed as 

Number 1? Occupied Land Fund, the Holy Land Foundation. 

And again, when you look through this document 

on the right, you will see names and members of the 

committee on the right-hand side. You will see the same 

names that we went through with you. Some of the 

defendants and some of their co-conspirators. 

Now, we don't only see their names in this 

document, the names of the members of the Palestine 

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Committee. We also see their names in Marzook's phone 

book, Government's Exhibit 5-79. Why would the leader of 

a terrorist organization have these people's names in his 

phone book unless he was connected to them. 

In 4-1, there is a series of documents and 

photographs taken from the home of a man named Ashqar. In 

his home. And Ashqar had a phone list, and this document 

was in Arabic and here we have it in English. This page 

is entitled "Important Phone and Fax Numbers, Palestinian 

Section, America." And it's seen from another source. 

There is a Palestine Committee and these are the members. 

1, Mousa Abu Marzook; 5, Mohamed El-Mezain, Shukri Abu 

Baker. So we're seeing who the members are. 

There is other El Barasse exhibits. 3-3 is 

another one of them that shows the creation of the 

Palestine Committee. What we have seen is the Muslim 

Brotherhood decides to form a Palestine Committee. The 

Palestine Committee is to support HAMAS. In supporting 

HAMAS, the Palestine Committee overseas the IAP which is 

the media, the UASR which is the think tank and Holy Land 

Foundation which is the fundraising arm. 

Now, even in the early years, even though HAMAS 

wasn't designated as a terrorist organization and it 

wasn't illegal to deal with HAMAS back in the early 90's, 

it was still a terrorist organization. There was still a 

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09:46

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committee and violent acts. Dr. Levitt told you that the 

fact the State Department recognized HAMAS in a document 

they published every year called "Global Patterns of 

Terrorists." So because of that it's not good to align 

yourself with HAMAS. So the Palestine Committee felt it 

needed to disassociate with HAMAS before the public. 

While they can claim they are HAMAS in the Muslim 

Brotherhood community, when it came to facing the American 

public they had to conceal that. And you will see this 

concealment -- this deceit of the American public 

throughout the evidence. 

One of the places we see it is Government's 

Exhibit 7-1. This is a deposition in a civil lawsuit when 

Holy Land was sued. It's the deposition of Mohamed 

El-Mezain, the defendant, and in that deposition Mohamed 

El-Mezain was asked about IAP, and he said the HLF had no 

relationship with the IAP. Well, we have just seen from 

the El Barasse documents that the HLF did have a 

relationship. It was almost like a brother. 

In another deposition for the same lawsuit, 

Shukri Abu Baker said the HLF only had a business 

relationship with the IAP. You can see the relationship 

with the IAP was a lot more than business. Those are two 

of the statements they made to conceal the nature and 

purpose of the Palestine Committee from the American 

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public. 

We have seen certain documents, Government's 

Exhibits 3-5, 3-8, 3-23, the Palestine Committee at work. 

We see where the HLF is filing reports with the Palestine 

Committee, where they are committing budgets with 

Palestine Committee salaries. They talk about -- In 3-8 

HLF talks about opening an office in Jerusalem. They talk 

about changing the name from the Occupied Land Fund to the 

Holy Land Foundation. Are these things an independent 

charity would do? No. Are these the things that a normal 

charity would do? Answer to an organization that's is set 

up to help an support HAMAS? No. 

Now, we see the Palestine Committee in action 

not just through the El Barasse documents but we have 

heard them in action. We have seen them act and get 

together through several of these phone calls and meetings 

that they had that the FBI taped. The first on -- And I 

want to talk about some of them. The first one took place 

in October of 1993, a Marriott hotel in Philadelphia. We 

call this the Philadelphia conference. That's how I will 

refer to it. We know that the Philadelphia conference was 

set up by the Defendant Shukri Abu Baker along with Omar 

Ahmad, who was part of the Palestine Committee, and 

Ashqar, another member of the Palestine Committee. 

We have seen 16-25 and 15. They talk about the 

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agenda, who's going to attend, the location and other 

issues. All to set up this Philadelphia conference. And 

the attendees were many members of the Palestine 

Committee. We see American Express records where HLF paid 

for these people to come. Why would a charity use its 

money to pay for people who are not part of the charity to 

attend a conference of the Palestine Committee. They 

shouldn't, but they did because that's HLF's purpose. We 

know that Mohamed El-Mezain -- Why would his signature be 

on the hotel record? And you can see that on 21-60. The 

defendant in that same lawsuit I talked about a moment 

ago. And one of the papers filed in that lawsuit, 

Government's Exhibit 77-6, said the Defendant Ghassan 

Elashi wasn't there, but he was. We showed you a picture 

of Ghassan Elashi walking with Shukri Abu Baker outside 

the hotel during this Philadelphia conference. So we have 

Mufid Abdulqader in attendance, the Defendant Shukri Abu 

Baker. All there. And Mohamed El-Mezain was supposed to 

be there, but he was sick. He was in the hospital and 

couldn't attend. The transcript for this conference which 

took place over two days in October 1993 are 16-47 and 

16-41, and I invite you to read them. I'll hit only 

highlights, but you will see the highlights I hit are 

throughout the transcripts. 

Now, in a different lawsuit, a separate one, the 

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Defendant Shukri Abu Baker filed a declaration with the 

court. A declaration is open to the public. And in the 

declaration, Shukri Abu Baker says the meeting, the 

Philadelphia conference, was just a meeting of Islamic 

intellectuals, community leaders and representatives. It 

was not a meeting of any particular organization. But we 

know that's not true. That's being deceptive, and we know 

that because Omar Ahmad in the beginning of the meeting, 

16-47 states "This is a meeting of Palestine Committee." 

Sets it right out there. That's an organization. So 

Shukri Abu Baker says in a sworn -- under oath -- 

declaration that was not a meeting of an organization. He 

wasn't telling the truth. He was being deceptive. 

During the conference, the Defendant Shukri Abu 

Baker tries to give a cover. Tries to tell the attendees 

there that we can't let anyone else know why we're 

meeting, and he says in 16-49 "Please don't mention the 

name HAMAS in an explicit manner. We insist on saying 

SAMAH. We will talk about her honor in this session." 

The session here is a joint workshop between the Holy Land 

Foundation and the Islamic Association of Palestine. 

"This is the official form, I mean, please, in case some 

inquire."

Why would Shukri Abu Baker be concerned about 

people inquiring about this Philadelphia conference unless 

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the true purpose of the conference is to talk about their 

plans for HAMAS in America? 

Now, we know that they try to conceal the 

purpose because Shukri Abu Baker was admonishing people 

for using the term "HAMAS." When one person says "Is this 

against HAMAS," Shukri Abu Baker said "Didn't we say not 

to mention that term?" And the person says "Is this 

against the Movement," the Movement being another name for 

HAMAS. Another person says "HAMAS, I mean SAMAH." 

Obviously that person caught themselves. Shukri Abu Baker 

said the term SAMAH was a whimsical play on words in that 

declaration. SAMAH means forgiveness in Arabic. If you 

read the transcript for the Philadelphia conference, you 

will see they are not whimsically playing with words but 

referring to HAMAS. They use HAMAS, SAMAH, Movement 

throughout all of those transcripts. No question the 

purpose of this meeting was to discuss HAMAS and their 

support of HAMAS. 

One of the main agendas was the Oslo Accords. 

The month prior to this meeting in September of 1993 the 

Oslo Accords were signed on the White House lawn here in 

the United States. Again, the purpose of the Oslo Accords 

was to be a peace treaty between the Israelis and the 

Palestinians. In this case, the Palestinians were 

represented by the PLO, Yasser Arafat. The PLO was a 

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secular group, not religious based. And HAMAS as we know 

was against all peace conferences. Five years before the 

Oslo Accords happened, they are saying no peace 

conference, waste of time. So off the bat they are 

against the Oslo Accords. 

In fact, they took several steps to try to 

derail the Oslo Accords through suicide attacks. 

Dr. Levitt told you that certain attacks after the Accords 

were designed to interrupt the peace process. Like when 

Secretary of State Albright traveled to Israel there were 

promises then to interrupt the process, and it worked. 

The peace process never happened and from a large part due 

to the bombings by HAMAS. 

Now, the Palestine Committee during this meeting 

also expressed a concern about the Oslo Accords. They 

discussed the affects of the Accord on HAMAS. They 

expressed the concern that if peace breaks out no one 

would support HAMAS. God forbid peace should break out. 

They are afraid of the Authority that may take over the 

Zakat Committees. HAMAS controls the Zakat Committees. 

They talk specifically about measures they have to take in 

order to derail the agreements that support HAMAS. One of 

defendants, Shukri Abu Baker, talks about derailing the 

agreement, not -- All the participants collectively are 

talking about that. 

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Government's Exhibit 16-63, "The most important 

thing we can provide in this stage is to support Jihad in 

Palestine. I believe it's the only way to bring the goals 

of Accord to fail."

16-67, "I'm working on Jihad." Support the 

Jihad, support the Jihad. Who's doing Jihad? HAMAS. It 

says so in their charter. 

16-85, after discussion of the Oslo Accords, the 

Defendant Shukri Abu Baker says "Your mother SAMAH is the 

mother of democracy." Would you expect a regular charity 

who says its purpose is to help people be against a peace 

process? Absolutely not. 

By the way, Philadelphia was not the only time 

they used the term "SAMAH." We see it in a phone call 

between Shukri Abu Baker and Ashqar when they talk about 

someone approaching Baker who claimed to be part of HAMAS, 

and in that phone call Shukri Abu Baker used the term 

"SAMAH." 

They talk about ways they are going to present 

themselves to the American public. Again, they can't say 

they are HAMAS because that wouldn't look good because 

HAMAS is against the peace process and committing 

terroristic acts. The United States was supporting the 

peace process. The American public was supporting it. 

And if the Palestine Committee came out against it, it 

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would not look good. They decided to publically make it 

appear as if they were distancing themselves from HAMAS 

and at the same time supporting HAMAS. Shukri Abu Baker 

talks about that point, after the peace accords they were 

going against the current. How initially they were with 

everybody, everybody was with them supporting the 

violence, supporting HAMAS, and now there is peace accords 

and everyone is supporting the peace. So they were going 

against the tide of the people. And what he says in 

regard to what he can say to the American public is 

specifically at 16-87, "I cannot say to him that I'm 

HAMAS." Shukri Abu Baker is acknowledging that he cannot 

say to the American public -- he cannot say to you -- that 

he is HAMAS. 

To help keep their cover, they discuss creating 

an untainted organization because all of those 

organizations -- IAP, HLF, UASR -- are tainted as being 

HAMAS. In 16-69, one of the participants is 

saying "Representing the Islamic community in general 

terms, you see. This way we can visit Palestine not as 

the Holy Land Foundation because the Holy Land Foundation 

is stamped already as whatever."

16-67, someone else says "In my opinion we must 

form a new organization for activism which will remain 

neutral because we are placed in a corner. It is known 

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who we are. We are marked." Marked as what? Marked as 

HAMAS. 

Someone says "Brother had a suggestion to form 

an organization, one whose Islamic hue is not very 

conspicuous." One of the participants, Omar Ahmad, a name 

you heard me mention, talks further about the 

organization. They talk about it throughout the 

Philadelphia conference. And what do they do? They 

create the organization. The organization is called the 

Council of American Islamic Rights, CAIR, C-A-I-R, and 

CAIR joins its brothers, the IAP, the HLF and UASR as part 

of the Palestine Committee in supporting HAMAS, and we see 

this in 3-78, Page 6. You see Number 3. The top says 

"Meeting Agenda for the Palestine Committee, July 30, 

1994." This is about eight months after that meeting in 

Philadelphia. "Number 3, Reviewing reports of the working 

organizations. Future suggestions to develop work for the 

following organizations: IAP, HLF, UASR, CAIR." CAIR has 

now joined the other three. 

After the Philadelphia conference, we again see 

the Palestine Committee in action in 1994 when a dispute 

arose between several members of the committee, between 

the HLF and Ashqar whose name I mentioned a few moments 

ago. Ashqar had an organization called the Al-Aqsa 

Education Fund. What Ashqar did is he brought in a 

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speaker named Jamil Hammami, one of the leaders and 

founders in the West Bank. He brought Hammimi to the 

United States to raise funds on behalf of Al-Aqsa 

Education Fund. And that was a problem because the 

Committee and the HLF had an arrangement with Ashqar that 

Ashqar would not bring in speakers at certain times of the 

year and without clearing it with HLF because there might 

be conflicts. Why should an independent charitable 

organization be worried about another organization? It's 

not an independent charitable organization. We see it 

here. It's in control of the Palestine Committee. 

So what happened? Mousa Abu Marzook, the leader 

of HAMAS intercedes, and we see in Government's Exhibit 

16-3, a phone call between Ashqar and someone else. 

Ashqar talks about a letter that Marzook wrote them, and 

in that letter Marzook says stop the fighting. We must be 

united. Ashqar backed down and let go of Hammami. Why 

would the leader of HAMAS have to intercede unless the HLF 

was part of HAMAS and an important part of HAMAS? Ashqar 

didn't listen. 

So the Palestine Committee got together, and 

they had a conference call, and Government's Exhibit 17-1, 

they talk about what they are going to do and how they are 

going to handle the situation. And what they decide is 

they decided that the HLF would get the money that Hammami 

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raised and the HLF would send it back to Hammami and his 

organization in the West Bank. All the Committee members 

voted. If we could play 17-1. If we could play an 

excerpt of that meeting of the Palestine Committee. 

(Tape played).

MR. JONAS: So the Palestine Committee came 

together and decided that HLF would take over the money 

that Hammimi raised. By the way, I had the acronym right, 

CAIR, but it's Council of American Islamic Relations. 

Ashqar is still not happy, and he's visited by 

Hammimi and Syam back at his home in Oxford, Mississippi. 

In 16-67, we see them talking about the Marzook letter, 

the decision of the Committee and what's going to happen 

to the money, and so we see the Palestine Committee in 

action in interceding and Marzook as well in interceding 

on behalf of HLF in the dispute. 

The function of the Palestine Committee 

continued up through at least 1999. If you recall when 

Mr. Yaish was on the stand -- and he's the accountant -- I 

played a phone call between Shukri Abu Baker and Omar 

Ahmad where they discuss they are going to pay Mohamed 

El-Mezain for some of the fundraising he did on behalf of 

HLF. And in that phone call -- In that phone call Omar 

Ahmed says "we" consider this and "we" pay him that and 

"we" look through the books of the HLF. We, we, we. Omar 

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Ahmad has nothing to do with the HLF. At least clearly 

not on the face. But by saying we, we, we and he and 

Shukri Abu Baker decide how much to pay Mohamed El-Mezain, 

Omar Ahmad is exercising control over the HLF. Again, 

it's another example of the Palestine Committee directing 

the HLF in its support for HAMAS. 

What it shows from these documents coming from 

multiple sources -- Philadelphia, Ashqar, Philadelphia 

conference, Marzook's phone book -- is that there is a 

Palestine Committee in the United States that's part of 

the U.S. Muslim Brotherhood. The Palestine Committee was 

set up to support HAMAS. The Palestine Committee controls 

four organizations, each with a separate purpose: IAP as 

the media outlet, UASR as HAMAS think tank, CAIR as 

HAMAS's lobbying arm and HLF as HAMAS's fundraiser in the 

United States. Again, is this how a regular charity would 

act? 

This covers the creation and purpose of the HLF. 

Let's look at what they did in those early years. The HLF 

did not waste much time in supporting HAMAS. First, if we 

could put up Government's Exhibit 20-33 we see payments 

between Marzook and the HLF. This is one of those 

schedules -- This is a schedule that basically summarizes 

the payments. And very briefly, you have the date, who's 

making the payment. You have whether it's a check or a 

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wire, the amount, who it's going to, and then you have on 

the far right the exhibits that support that particular 

payment on the schedule. We see it going back and forth. 

We see as early as 1988, the HLF giving $10,000 to Marzook 

both in April and May of that year. And we see Marzook 

putting money back in the HLF, and back and forth it goes. 

Marzook ended up giving over several hundred thousand 

dollars to the HLF, and HLF gave $10,000 back to Marzook. 

We're talking about the leader of a terrorist organization 

here. Government's Exhibit 7-1, this is the deposition 

that Shukri Abu Baker gave in a civil lawsuit so the only 

connection between Marzook and HLF was a one time $200,000 

contribution that Marzook made. What he failed to say is 

that HLF gave tens of thousands of dollars back to 

Marzook. Concealment. Shukri Abu Baker was concealing 

the relationship between HAMAS and HLF. 

That's not the only money that HLF gave directly 

back to HAMAS. In a three-month period, 20-16, from 

September 1988 until the end of October of 1988, actually 

a two-month period. Holy Land Foundation gives $250,000 

to K & A trading. Now, the money was wired from the K & A 

Trading account in Switzerland. I know it says the Banque 

du Paris, but the account was actually in Switzerland, and 

we have seen the records of this account. 

19-14 are bank records and that tells you that K 

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& A Trading was run by Khairy Al Agha, and we know from 

Dr. Levitt that Al Agha is a well known HAMAS financeer. 

Go back to Marzook's phone book, 4-1, Page 5. It says 

more than phone and fax numbers. Palestine Section 

Outside of America, the very first name, Khairy Al Agha. 

Why would a charity be wiring $250,000 to a trading 

company based in Switzerland. It shouldn't, unless that 

trading company is also a HAMAS front. We know that K & A 

is connected to Marzook. That's further evidence of 

HAMAS. We see K & A wiring $100,000 back to Marzook. 

It's all very incestuous. 

At the same time HLF is wiring a $125,000 to an 

organization run by Sheikh Yassin in the seventies. 

Remember I told you that Yassin when he was running the 

Muslim Brotherhood set up certain organizations. Islamic 

Center was one of them. Once HAMAS was formed, it became 

a HAMAS institution. For five years, I believe starting 

in 1998, HLF sent over $125,000 to the Islamic Center, 

Sheikh Yassin's institution. 

There is also direct contact between HLF and 

leaders of HAMAS. We see phone calls. Khalil Mishal, the 

current number one of the political bureau, back then 

Number 2, called up Mohamed El-Mezain. 

(Tape played) 

MR. JONAS: Abu Ibrahim is the Defendant Mohamed 

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El-Mezain's "Abu" name and Abu Omar is Khalil Mishal's 

"Abu" name. 

(Tape played).

MR. JONAS: So we see one of the top two people 

in HAMAS inviting Mohamed El-Mezain to Turkey. We need 

you there. Who is we? HAMAS. HAMAS needs Mohamed 

El-Mezain to go to Turkey. We see from the phone records 

that HLF called Imad Alami. Who is he? The HAMAS 

representative in Iran. Why would a charity call the 

HAMAS representative in Iran? 

Now, the defendants expressed their support and 

association with HAMAS in several different ways. The 

IAP, the media outlet for HAMAS, published a magazine in 

Arabic. The magazine was called Ila Filistine. 

Government's Exhibit 21-3, one of those Ila Filistine 

issues. We turn to Page 60 of that magazine. This is an 

ode, a poem, an essay, whatever you want, to HAMAS written 

by the Defendant Shukri Abu Baker. It's entitled "Hayzum 

HAMAS Has Arrived," and at the bottom at the end of the 

poem, Shukri Abu Baker writes "We will not accept other 

than HAMAS." Keep in mind what I talked about, deception. 

8-1 is that sworn declaration that Shukri Abu Baker filed. 

On Page 2 of 8-1 Shukri Abu Baker says that he rejects and 

abhors HAMAS and all its ways. Does this poem or ode to 

HAMAS sound like it's coming from a man who rejects and 

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abhors HAMAS? No, this poem is written in Arabic in a 

magazine that's designed to go to the supporters of HAMAS. 

That declaration was filed publically which the American 

public can see. One face to the supporters of HAMAS. 

Another face to the American public. 

Abdulraham Odeh had a picture in his New Jersey 

office that looked like it was cut out from a newspaper of 

three major terrorist leaders, Khalil Mishal and two 

others. He had several HAMAS books in his office, 

published by the IAP and UASR. It's not illegal to 

possess this material. But two questions. One is why 

would a charity have this? And the second thing, while 

it's not illegal to possess it's something you can 

consider in determining whether Odeh was a supporter of 

HAMAS and whether or not he was part of the conspiracy 

that he's charged with in this case. 

Mohamed El-Mezain, the defendant, had a 

particular interest in suicide bombings. Again, having an 

interest in suicide bombings is not against the law. It's 

something you can consider in determining whether he 

supported HAMAS as charged in this case. He regularly 

received HAMAS communiques from the IAP which reported on 

the activities of HAMAS. For example, Government's 

Exhibit 15-52 is a report on a suicide bombing in 

Jerusalem. The report is entitled "A Special Report about 

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the Jihadist Heroic Operation in the Midst of the City of 

Jerusalem." Jihadist heroic operation. That doesn't 

sound like reporting an event that went on in the Middle 

East. It sounds like someone who's supporting the action. 

That's what Mohamed El-Mezain was receiving. And another 

report on a kidnapping in another IAP communique reports a 

kidnapping of an Israeli soldier who happened to be an 

American citizen. Dr. Levitt told you that soldier was 

killed, and that led to the suspension of peace talks, one 

of the goals of HAMAS. That happened in 1994, about a 

year after the Oslo Accords. 

15-27 is a report in January of 1995. An adult 

suicide bomber, indicating facts to El-Mezain that killed 

eight people and injured sixty-two. According to a report 

that El-Mezain received, a car was boobytrapped and a bomb 

went off at the restaurant. What Dr. Levitt told you was 

a small bomb went off first, and then when the people were 

running to help, a larger bomb went off. The Defendant 

El-Mezain got a call about this attack from the Defendant 

Abdulraham Odeh. 15-1 is a very short call, but in it 

Odeh said it was reported on the radio, and Odeh called it 

"a beautiful operation." The Defendant El-Mezain ends the 

conversation by saying "It will be good, God willing." 

The defendant El-Mezain didn't just -- Your Honor, I'm 

about to play a video if you want to take the mid-morning 

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recess at this time. 

THE COURT: All right. Ladies and Gentlemen, 

we'll take our break now, we'll be in recess until 10:35. 

 (Recess)

THE COURT: Go ahead, Mr. Jonas. 

MR. JONAS: Before the break, I was talking 

about some of the communiques that the Defendant Mohamed 

El-Mezain received that the IAP reported on in the HAMAS 

suicide bombings, and one thing I forgot to mention 

earlier when I pointed out the numbering system. I 

mentioned the 15 system. The 13 series through the 18 

series are the wire taps for the phone calls and faxes the 

government intercepted. Each number being a separate 

subject or phone line. 

To get back to the Defendant Mohamed El-Mezain, 

he didn't just read about these suicide bombings. He 

didn't just talk about Jihad on the phone. He also 

preached it. I want to play seconds of a video tape that 

you have seen which comes from the home of Fawaz Mushtaha. 

Fawaz Mushtaha was one of the names of the members of the 

Palestine Committee, and these video tapes -- If you 

remember the government's second or third witness was an 

individual who told you that he lives right outside of 

Washington, D.C., and he was levelling his backyard one 

day, and he uncovered these spools of tape, and these are 

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tapes that were buried and tried to be destroyed by Fawaz 

Mushtaha. Fawaz Mushtaha was the prior homeowner before 

this guy. So these tapes were buried, and Fawaz Mushtaha 

not only buried tapes but tried to burn other items. 

There were other items found in his fireplace and barbecue 

pit, and the FBI put together what they could of these 

video tapes. Some of them were unsalvageable. And these 

are some of these video tapes he tried to destroy. And 

ask yourself why he would try to destroy them unless there 

was incriminating evidence on them. 

First, we're going to see an individual who's 

going to talk about a conference that El-Mezain is talking 

at, and then we will see El-Mezain talking and a few other 

clips and this is Government's Exhibit 22-12. 

(Tape played).

MR. JONAS: Now, we see this is an IAP festival 

talking about HAMAS, and it's taking place right here in 

the United States in Arizona. 

(Tape played)

MR. JONAS: Here we see the Defendant Mohamed 

El-Mezain come out. Obviously a much younger El-Mezain 

than we see today. This next segment is a clip of what he 

says. 

(Tape played).

MR. JONAS: They will not leave except by the 

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sword, and they will not leave except by force. Again, 

talking about the HAMAS charter, the only way they will 

get rid of Israel is through force. 

(Tape played).

MR. JONAS: From the river to the sea. From the 

river to the sea, all of Israel will become Palestine. 

Now, this last clip is something that happened 

after Defendant Mohamed El-Mezain gave his lecture. 

(Tape played).

MR. JONAS: Notice the babies crying. 

(Tape played).

MR. JONAS: All about HAMAS. Well, we have seen 

Shukri Abu Baker and his poem to HAMAS. We have seen Odeh 

and his material found in the office. We have seen 

El-Mezain talking about suicide operations and giving a 

lecture on Jihad at the IAP festival in the United States. 

We know that Mufid Abdulqader was a member of a band, and 

we saw some video of the band singing songs. I want to 

play a couple of short clips of the songs the Defendant 

Mufid Abdulqader sang. 14-1 A and C. 

(Tape played).

MR. JONAS: On the right, you see the Defendant 

Mufid Abdulqader. 

Here he is again. 

(Tape played).

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MR. JONAS: HAMAS is my role model. The martyrs 

are my role model. This was what the defendant was 

singing about. This wasn't just him on his own. This was 

a group. This video tape was seized at the Holy Land 

Foundation. And while it may have been old, it was seized 

in 2001. So they held onto it for many years. Why would 

the HLF hold onto such a tape? Why would the HLF hire 

this band to sing at their functions unless Holy Land 

Foundation supported what this group was saying? 

Mufid did more than just sing. We see him 

sending greetings to Sheikh Yassin and Mousa Abu Marzook. 

If we could play 1-315. Again, this is a tape seized from 

the Holy Land Foundation. 3-15 B. I'm sorry. I jumped 

ahead. We will play the rest of the excerpt of 3-14. 

(Tape played).

MR. JONAS: This is the Defendant Mufid 

Abdulqader second from the left. 

(Tape played).

MR. JONAS: There is the Mufid Abdulqader 

singing about fighting on the land of HAMAS. You see they 

start to do more than sing. They send greetings to Sheikh 

Yassin and Mousa Abu Marzook, 3-15, another video seized 

from the HLF. 1-315, Clip B. 

(Tape played).

MR. JONAS: This tape must have been around 1995 

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because he was talking about Mousa Abu Marzook being 

arrested in New York, and that's when he was. The 

Defendant Mufid Abdulqader would sing and send out 

greetings and put on skits. I want to put on one of those 

skits. This is 3-74 that was seized from the home of 

Ismail El Barasse. 

(Tape played).

MR. JONAS: There is the Defendant Mufid 

Abdulqader. That was played just to show you this tape is 

from an IAP festival. 

The next clip. 

(Tape played).

MR. JONAS: This is something that went on 

there. 

(Tape played).

MR. JONAS: Sheikh Yassin, spiritual leader and 

founder of HAMAS. There is a picture of him. 

(Tape played).

MR. JONAS: Wearing green head bands the way 

HAMAS members wear. 

(Tape played).

MR. JONAS: Peaceful solution is not acceptable; 

that's what HAMAS says. 

(Tape played).

MR. JONAS: You can see children on the stage 

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wearing ski masks. 

(Tape played).

MR. JONAS: You see men come out with a gun and 

pretend to shoot them. 

(Tape played).

MR. JONAS: I am from HAMAS. The next clip of 

what went on at that conference. This is here in the 

United States. You see the individual on the left is 

pretending to be from Israel. 

(Tape played).

MR. JONAS: Here comes the Defendant Mufid 

Abdulqader. There are cheers for him. He says "I am 

HAMAS."

(Tape played).

MR. JONAS: And then they go back and forth in 

the skit and it ends with --

(Tape played).

MR. JONAS: There are cheers in the crowd when 

he kills the person pretending to be an Israeli. And they 

chant for HAMAS. 

Now, these took place in the United States, but 

everything is in Arabic. It's not something that's 

available for the American public to come in and see and 

participate in. 

During their opening statements, the defendants'

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counsel all talked to you about freedom of speech. 

Freedom of speech is a wonderful and incredible right in 

the United States, and except in certain circumstances, 

you cannot be prosecuted for saying what's on your mind, 

and these defendants here are not on trial for saying 

what's on their mind, where the Defendant Mufid Abdulqader 

is enacting a skit where he's killing somebody. 

But you as a juror are certainly allowed to 

consider that speech in determining whether or not they 

committed the acts that they are charged with. They are 

charged with providing money to HAMAS, and by looking at 

what they had to say and expressing their thoughts and 

opinions and feelings, you are allowed to consider that 

speech in determining whether or not they are guilty of 

the crimes they are charged with. So again, while they 

are not on trial for exercising their speech, you can 

consider that speech in determining what's going on in 

their head. 

Now, I talked about the Palestine Committee and 

the HLF's role in it. I talked about the defendants 

individually, how they talked about their support for 

HAMAS. I want to talk about the HLF now as a whole, as an 

organization. We saw in the Philadelphia conference the 

Defendant Shukri Abu Baker tried to be security conscious, 

talking about SAMAH, using the code word SAMAH, telling 

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the other members to pretend that this is just supposed to 

be a meeting between the HLF and IAP in case anyone asks. 

Well, why were they security conscious? Government's 

Exhibit 2-101 is a security document found at Infocom 

among other HLF documents, and this document lays out ways 

for the Holy Land Foundation to act in a secretive manner, 

in a covert manner. And ask yourself this question, as I 

said at the beginning. Would a regular charity have such 

a document? This document is not unique to the HLF. This 

is part of the mantra of the Muslim Brotherhood in the 

United States to operate in this secretive manner. 

Government's Exhibit 3-92, Page 20, is a document -- a 

Muslim Brotherhood United States document. This is one of 

the ones seized from El Barasse. Page 25 of that 

document, if we can pull that up. 3-92, Page 25. This 

document is entitled "Implementation Manual for the 

Group's Plan for the Year of 1991 to 1992."

Okay, it's not coming up. Let me tell you what 

it says. You will have all of these exhibits back in the 

juryroom when you deliberate so you can look at these for 

yourself. This lists out the departments and committees 

for the group, this being the Muslim Brotherhood in the 

United States. And it's now on the screen. Page 20, the 

bottom half of these departments and committees, we see 

Number 13, Security. And it says one of the things the 

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security group is to do is to publish a security bulletin. 

Well, we have seen that security bulletin, 2-101, found at 

Infocom. And just to show you this is not just some 

random document that's not connected to these defendants, 

if you go to the next page, Number 14 of the committees is 

the Palestine Committee. And if you go to the last page, 

it talks about work to be implemented by the Palestine 

Committee. It talks about the Fund, and we know the Fund 

is Occupied Land Fund or the HLF. Government's Exhibit 

3-85 is another manual that talks about security for the 

group. It talks about a center which is concerned with 

the security issues, and again that document lists the 

Occupied Land Fund as one of its organizations. 

So the Muslim Brotherhood is concerned about 

security, and they created this document, this 2-101, 

which was found at Infocom, and we see in going through 

the document certain examples where the HLF followed 

through on the security measures set forth in this 

document, and you heard Agent Miranda go through some of 

the examples, and I will briefly mention some. In the 

1990's, Shukri Abu Baker applied for a visa to travel to 

Saudi Arabia under the guise of being an Infocom employee. 

The Defendant Shukri Abu Baker never worked at Infocom. 

But the security manual says to get covered while 

travelling, and that's what he did. That's Government's 

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Exhibit 1-8. 

Government's Exhibit 1-195, we see an invoice 

from a security company that was hired by the HLF to sweep 

the building for bugs, for electronic listening devices. 

Why would a charity sweep its offices for electronic 

listening devices? Why would the leader of a charity 

travel under false cover unless he's operating under the 

security document which was implemented by the Muslim 

Brotherhood and HAMAS. They use code words, "SAMAH," not 

once in a whimsical fashion but throughout the 

Philadelphia conference and in at least one phone call 

that we have seen. All of this is an attempt to conceal 

the true nature to the American public. 

And they were not the only ones who were trying 

to conceal the HLF's true purpose. If you remember Steve 

McGonigle, he's the reporter from the Dallas Morning News. 

He testified in 1989 he went over to Gaza to research a 

story on the Holy Land Foundation. He testified he met 

with Mahmud Zahar, one of the leaders of HAMAS. Mahmud 

Zahar told Steve McGonigle that Holy Land Foundation is 

not part of HAMAS, and yes, he once met Shukri Abu Baker 

in the early 90's, late 80's and they talked about medical 

issues. Mr. Zahar is a medical doctor. What he didn't 

tell Mr. McGonigle is the Holy Land Foundation brought 

Zahar over to the United States on the Fund's fundraising 

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behalf. You'll see Shukri Abu Baker sitting in the 

audience with Zahar. Zahar knew if Holy Land Foundation 

was outed as HAMAS they would get in trouble. 

Steve McGonigle then went to visit Sheikh 

Yassin, the spiritual leader and founder of HAMAS, and we 

know the phone call between the HLF representative in Gaza 

and the Defendants Shukri Abu Baker and Ghassan Elashi, 

who were very worried about McGonigle's trip to the Gaza, 

that Sheikh Yassin played dumb when it came to the HLF. 

Sheikh Yassin told McGonigle that what is this HLF. We're 

building a school, maybe they can help us. As the HLF 

representative said, he played dumb. Why would the leader 

of HAMAS have to play dumb when it came to the HLF unless 

he knew he had to cover up for them? 

Now, I have talked about the creation of HLF, 

the Palestine Committee and the defendants' support and 

their words, the security measures, the covering up. 

Let's now talk about how the HLF went about their mission. 

How did they raise funds for HAMAS. Well, they did so 

through several ways. One of those ways was conferences 

where they would get up there themselves and speak and 

raise funds. I want to play segments of a video of one of 

these conference so that you can get a flavoring of what 

went on. This is a video, 1-122, that was seized from 

Fawaz Mushtaha's home, the backyard where the tape was 

CASSIDI L. CASEY, CSR, 214-354-3139

UNITED STATES DISTRICT COURT

GOVERNMENT'S CLOSING ARGUMENT 56

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taken out of one of the spools. There is several segments 

of this one. 

(Tape played).

MR. JONAS: There is the Defendant Mohamed 

El-Mezains in the middle. To our right, looking at him on 

the right is Mahmud Zahar, the individual that McGonigle 

interviewed that said HLF not HAMAS. On the Defendant 

El-Mezain's left is Sheikh Jamil Hammimi, one of the 

founders of HAMAS from the West Bank. This took place in 

Los Angeles. This is not on the West Bank and Gaza. This 

is happening right here in the United States. There is 

El-Mezain, and there is shake Jamil Hammimi. 

(Tape played).

MR. JONAS: All right. The second tape, the 

second segment. 

There we see the Defendant Mufid Abdulqader's 

band, and Mufid Abdulqader is second from the left. Here 

we see the Defendant Shukri Abu Baker encouraging people 

to dance and sing, a song about blood. You see children 

dancing to this song. 

(Tape played).

MR. JONAS: The Defendant Shukri Abu Baker 

introducing Mohamed El-Mezain to come up and raise funds. 

(Tape played).

MR. JONAS: Talks about honored guests, members 

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of the Palestine Committee, member of the military wing 

initially. 

(Tape played).

MR. JONAS: This is before the HLF changed their 

name obviously and moved out here to Richardson. 

(Tape played).

MR. JONAS: The next segment, more of what's 

going on at this conference, this fundraiser. You see the 

man who's singing is Fawaz Mushtaha. That's the guy who 

buried the tapes in the backyard, right next to the 

Defendant Mufid Abdulqader, one of the members of the 

Palestine Committee. 

Songs about HAMAS with the children on the stage 

dancing. 

(Tape played).

MR. JONAS: Defendant Shukri Abu Baker standing 

in front of the stage. 

(Tape played).

MR. JONAS: Next clip. 

(Tape played).

MR. JONAS: Shukri Abu Baker announcing how much 

they raised. 

(Tape played).

MR. JONAS: Next clip. This is another skit 

with the Defendant Mufid Abdulqader on the right. Someone 

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who's supposed to be Israel. Chanting I am HAMAS. You 

can't get more clear than that. Next clip. 

(Tape played).

MR. JONAS: Later on in this skit he pretends to 

kill the person. Why would a charity put on a skit like 

this to raise funds? 

(Tape played).

MR. JONAS: Again, children on stage dancing 

with Shukri Abu Baker in front of them. 

(Tape played).

MR. JONAS: There is the Defendant Mufid 

Abdulqader, clear shot. 

(Tape played).

MR. JONAS: Shukri Abu Baker acknowledging and 

thanking Mahmud Zahar and something sitting next to 

El-Mezain. This is an example of what goes on at an HLF 

fundraiser. 

Now, besides themselves getting up on stage to 

raise funds, the HLF also brought in speakers and 

fundraisers. They have had other people that they use. 

We know that the Defendant Mufid Abdulqader obviously was 

a fundraiser for them as early as the early 90's up 

through 2001. We saw on one phone, 18-5, where he was 

bragging to someone else how much money he was raising at 

fundraising. We saw a list of domestic speakers; that is, 

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speakers who live in the United States and travel around 

the United States on behalf of Holy Land Foundation 

raising funds. We also saw that they brought in speakers 

from overseas and Agent Miranda went through with you a 

list that was taken from a Holy Land computer that was 

dated 1999 that lists out the speakers. And what I would 

like to do is put up and enlarge comments of this list. 

The government has it marked as 24-62 for the record. But 

Government's Exhibit 1-6 is the original exhibit. And if 

you see we have names, phone numbers, home, work and fax 

numbers, and you see all of these dots next to the 

speakers, and I'm not going through each speaker and what 

each dot represents. Agent Miranda went through that with 

you. Each dot represents how these individuals are 

connected, either to HAMAS or something called the Islamic 

Action Front which was the Muslim Brotherhood organization 

in Jordan. Basically, HAMAS's sister organization there. 

Islamic Action Front were the HAMAS leaders when they were 

in Jordan. That's where it operated out of. 

Basically the ways that the government connected 

each individual with a dot to HAMAS are several. One is 

they are identified as such by either Dr. Levitt or Mr. 

Avi. Another way is a lot of these people, their name and 

number are in the phone book of Mousa Abu Marzook, the 

leader of HAMAS. Another way is the senate letter, 21-58. 

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This is the letter sent from HAMAS to Senator Orin Hatch 

protesting Marzook being detained. If you look at the 

bottom of the letter underneath the name of the HAMAS 

spokesman, Ibrahim Ghousbeh, we see the telephone number 

and fax number for the HAMAS. That same phone and fax 

number are contained next to the names of several of these 

speakers. 

We also know that some of these speakers of 

HAMAS were Islamic Action Front because of a pamphlet that 

was found at HLF listing them out as such, Islamic Action 

Front members. So we see there are multiple ways that 

these individuals -- many, many of these individuals that 

Holy Land Foundation brought into the United States to 

raise funds on its behalf are connected to HAMAS. 

And I want to give you now a flavoring of the 

philosophy of some of these speakers and what some of 

these speakers had to say. Government's Exhibit 1-343 was 

a tape of a man named Abu Zant who's on here, Number 7, 

Abu Zant. In that tape, he said -- this is a tape that 

was seized from the Holy Land Foundation, not just some 

random tape that the government found. On that tape, he 

talks about praying to bring failure to the 

reconciliation, plot with the Jews, Oslo Accords. He goes 

on to discuss the bodies of American soldiers being 

dragged through the streets of Somalia, and then he goes 

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on to discuss HAMAS, praising HAMAS. This is the type of 

speaker that HLF is bringing in to raise funds on its 

behalf. Is this what a charity would do? Mohammed Syam, 

a well known HAMAS leader. He's the one that met with 

Ashqar on that dispute between Ashqar and the HLF 

fundraising. Let's play a little clip of what Mohammed 

has to say. This is one of the video tapes found in the 

home of Fawaz Mushtaha.

(Tape played).

MR. JONAS: He's talking about children 

committing terrorist acts against Israeli soldiers. 

Giving them a jar of what appears to be water, and it's 

nitric acid and lighting a match and running away. Giving 

them a fig that has poison. This is what Shukri Abu Baker 

denied one face to the public and one face to HAMAS. 

There was a phone call between Shukri Abu Baker and 

Reporter Gail Reeves. 1-68. We'll play that. 

(Tape played).

MR. JONAS: We have just seen the video tape of 

the band of the Defendant Mufid Abdulqader brought in by 

the Holy Land to raise funds at a Holy Land conference 

singing songs about HAMAS at a conference in the United 

States that was geared towards HAMAS supporters in the 

United States. Now we see him on the phone with an 

American reporter who's writing a story where he says, "Oh 

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no, we never talked about HAMAS. We never had anything to 

do with HAMAS." That's not true. Next clip, please. 

(Tape played).

MR. JONAS: We're not sponsoring speakers from 

HAMAS. Look at this list. This is a list that came from 

the Holy Land Foundation. Look how many people they 

sponsored from HAMAS. Again, he's deceiving the reporter. 

Last clip, please. 

(Tape played).

MR. JONAS: Not true, not true. This was a call 

in 1996 after HAMAS was designated as a terrorist 

organization. Now, some of the speakers that the HLF used 

to raise funds didn't come to the United States. Some of 

them -- Some of them don't always appear in person. One 

of the tools the HLF used was that they would have these 

conference calls set up where people could call a number, 

like an eight hundred number or something, and listen in 

to a speaker. One such call, Government's Exhibit 13-170, 

is a speaker who appears to be from Pakistan who gives a 

political speech on behalf of HAMAS, and the moderator 

thanks him on behalf of Holy Land Foundation. Why would a 

charity have a speaker come in to raise funds for HAMAS? 

Something involving one of these conference calls in 1997 

involving Mohammed Syam. We saw him on the video clip 

talking about the girl with the gasoline and Hamed 

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Beitawi, one of the speakers that HLF supported. One of 

the calls involving these gentlemen says -- Yaish, Yassin, 

Mousa Abu Marzook, that's the trifecta of HAMAS members. 

Yaish, also known as the engineer, who's one of the 

leading figures of the military wing of HAMAS. Sheikh 

Yassin, we know is a spiritual leader. Mousa Abu Marzook, 

the leader of the political wing. So this speaker goes on 

in this conference call and talks about HAMAS and the 

leaders of HAMAS and then what happened? At the end of 

the call the moderator says, "Give your donations to the 

Holy Land Foundation." The HLF is using these types of 

speakers to raise funds on its behalf. They could have 

brought in other prominent Palestinians, other prominent 

Muslims from other countries who are not part of a 

terrorist organization. They chose to bring in these 

people because that's part of their philosophy and what 

their job is, to raise funds for HAMAS. 

Another way that they raise funds, they took 

other speeches -- speeches of people who may not have been 

at the conference and put their stamp on it. Give to OLF 

and that's being Occupied Land Fund. An example of that 

is a man named Abdallah Azzam who Dr. Levitt talked about 

being a well known HAMAS figure until he was killed a 

couple of years ago. Now, let's look at 2-22 B a video of 

the fundraising that took place in Los Angeles. 

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(Tape played).

MR. JONAS: Talks about Abdallah Azzam, who 

visited them two years ago. Let's play the speech of 

Abdallah Azzam and see what he says. 13-22, I believe. 

(Tape played).

MR. JONAS: He talks about buying weapons, 

bombs, and he talks about Jihad that runs on life and 

money. Economic Jihad. Let's see what happens later on 

in that speech. 

(Tape played).

MR. JONAS: Send your donations to the Occupied 

Land Fund. By putting this on the tape after the speech, 

they are endorsing what he has to say. They are saying 

"Listen to this man. Listen to this man talk about buying 

weapons. Listen to this man talk about committing Jihad 

with the money and send us your money, give your donations 

to us." Is this what a regular charity would do? 

Another way they raise funds is through Ila 

Filistine, the magazine that the IAP published. I want to 

turn your attention to Government's Exhibit 21-8. This is 

a different issue of Ila Filistine than the one we saw 

earlier where Shukri Abu Baker had the ode to HAMAS. On 

the cover of this one, we see Abdel Azzam coincidentally. 

Turn to Page 8. The title of this article is "An Intifada 

of Our People Knocks on the Door of Its Third Year With 

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More Determination, Persistence and Heroism." The middle 

of the article talks about HAMAS, the leadership of HAMAS, 

"giving it their confidence, moves along with it and by it 

in the most wonderful Jihad march which brings anxiety to 

the enemy and shakes the ground from under its feet." It 

talks about liberating Palestine through Jihad and talks 

about HAMAS. And then on the next page in the middle it 

says "The Islamic Association in North Americas calls upon 

all of you to do the following in support of the people of 

the Intifada and your homeland and to make the cause of 

Palestine victorious. First: we call on all of you to 

perform jihad with your money for the sake of God by 

donating the maximum amount you can to support the 

Intifada of your people in Palestine. You may send your 

donations in the name of the Occupied Land Fund."

So they are asking people to support HAMAS by 

sending their money to Occupied Land Fund, the Holy Land 

Foundation. So we see the image of HAMAS throughout all 

of Holy Land Foundation's ways of raising funds -- at the 

conference, through the speakers they bring in, through 

the speakers they have at the conference calls, by placing 

their ad or their name on tapes of Abdallah Azzam, by 

putting this in Ila Filistine magazine. 

By the way, in discussing this Ila Filistine, 

Ms. Hollander questioned Agent Burns about ads placed by 

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other companies. And what you don't see is the other 

companies that people are directed to send their donation 

to. Only Occupied Land Fund. So what sort of a message 

did HLF send to the Muslim community, supporters of Muslim 

Brotherhood and HAMAS? They send the message that we are 

HAMAS. We saw letters written by the HLF to the HAMAS, 

2-77, 2-11, where someone writes about publications that 

Shukri Abu Baker used to send to this woman about HAMAS. 

2-77 is someone sending money saying "God bless you and 

all the honorable brothers who perform the best of 

charitable deeds which support the Mujihadeen in the 

Occupied Land." 2-8, all of these are letters. 

Government's Exhibit 5-24 which is the bank records. 

Someone writes Mujihadeen in the memo section of a check 

to the HLF. Why would people write these types of letters 

to the HLF unless they knew that the HLF was supportive of 

HAMAS? Another letter we saw, 1-56, Page 2. This was a 

letter found in the HLF office of New Jersey, the office 

run by the Defendant Abdulraham Odeh. This letter says 

Salaam Alikum. Enclosed is a modest contribution for our 

people suffering from Jewish/Christian Western crimes. 

Insallah, both will be defeated/slaughtered and kicked out 

of Islamic Lands. This is for relief supplies and weapons 

to crush the hated enemy. Thank you, Sultan Mahmoud. And 

it goes on. Why would this person write this letter to 

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the HLF unless he knew the HLF was all about? We see 

similar language in the HAMAS charter. More importantly, 

why are would the HLF hold onto this letter that's dated 

in 1996 for five years until they were shut down? Why 

would the Defendant Abdulraham Odeh notify the main office 

in Richardson that this man sent us a contribution and 

that his name ends up on their mailing list and they send 

him -- granted it's a boilerplate letter but a letter 

soliciting more funds. And even though Mr. Westfall 

pointed out the address in the letter was wrong, that they 

sent it back to New Jersey, that's not the point. The 

point is they kept the letter, the donation and put him on 

the mailing list. Again, why would this person write to 

the HLF with this language? 

Well, we see -- we see why. Government's 

Exhibit 3-85. This was one of the El Barasse documents, 

it talks about the creation of the Palestine Committee, 

the HLF, their support for HAMAS. And 3-85, Page 21, 

"Number 4. Understanding the role of the Muslim 

Brotherhood in North America. The process of settlement 

is a civilization jihadist process with all the word 

means. The Ikhwan must understand their work in America 

is a kind of grand Jihad in eliminating and destroying the 

western civilization from within and sabotaging its 

miserable house by their hands and the hands of believers 

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so that it is eliminated and God's religion is made 

victorious over all other religions."

That's very similar to the language in the 

letter we saw written by that guy to the HLF. Again, that 

is the message that they are sending to their supporters. 

Okay. I have talked about the creation of HLF, 

the Palestinian Committee, the defendants' own expressions 

and beliefs in support of HAMAS. I talked about how they 

raised funds for HAMAS. We know they raised millions of 

dollars over the years. 

Now let's turn our attention to what they did 

with that money. I talked about economic Jihad. We have 

seen that in Ila Filistine magazine. We have seen 

Abdallah Azzam preach where he talks about giving your 

money to Jihad. We have heard Khalil Mishal the leader of 

political bureau talk about Jihad. If we could play 3-77. 

This is an interview of Khalil Mishal that was seized from 

the home of El Barasse. 

(Tape played).

MR. JONAS: He talks about doing Jihad with your 

souls and your money. And that is the function that the 

HLF played in the United States. They were the ones to 

help people do Jihad with their money and who better to do 

that than someone you trust? Next clip, 3-77 B. Also 

part of that same interview. 

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(Tape played).

MR. JONAS: Americans ears are listening. Get 

your money to someone you trust, and they will get the 

money to HAMAS. Who better to trust than family? The 

Defendant Mufid Abdulqader is the brother of that man we 

just heard, Khalil Mishal. We know that the Defendant 

Ghassan Elashi is related by marriage to Mousa Abu 

Marzook. We know that these defendants were very close to 

the leaders of HAMAS. Who better to trust? 

We have heard a lot of testimony from Mr. Avi 

and Dr. Levitt and some of the defense witnesses about the 

Zakat Committees that the HLF supported. Before we talk 

about the Zakat Committees, I want to talk about someplace 

else that HLF sent its money to. Over the years they set 

up offices in the West Bank and Gaza, and they set up bank 

accounts, and they sent millions of dollars over there and 

some of that money was directed to Zakat Committees and 

some wasn't. What they did with some of the money is they 

supported families. And they specifically targeted 

families of martyrs and prisoners. They went beyond that 

as well. I'm not saying they only supported martyrs' 

families and prisoners. But that was something they 

focused on. The HLF was helping HAMAS take care of its 

own. And when HAMAS knew their families were cared for, 

they could continue the fighting. We played a second of 

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the Khalil Mishal interview where he talks about focusing 

on the martyrs and prisoners. We know the Philadelphia 

conference, 16-63, they said you have the issue of 

sponsoring the families of martyrs. You have the 

prisoners, but those people have a direct relationship 

with Jihad, and they must get more money and more thought. 

In our letters we sent to people we ought to place 

emphasis on the family of martyrs, the prisoners and the 

orphans and the families of the wounded. And we see 

letters to the HLF where they talk specifically about 

supporting the families of martyrs and prisoners. We know 

that the Defendant Odeh supported the family of Yaish the 

engineer, one of the leading figures of the military wing 

of HAMAS. Why would a charity specifically identify -- 

this special segment of the Palestinian society -- special 

segment is a term Mr. Avi used -- to support above others. 

Why would a regular charity do that. It wouldn't. We 

also know that the HLF sent money to its offices over in 

the West Bank and Gaza. They have directed a large amount 

of that money to be furthered to HAMAS money changers. 

Ms. Hollander showed you that some of that money may have 

been used to purchase food and produce and other supplies. 

Why pick a HAMAS money changer to send money through? Why 

not a bank or regular money changer? Because again, they 

are supporting HAMAS. 

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UNITED STATES DISTRICT COURT

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I want to turn my attention now to the Zakat 

Committees. That's what this case is about, supporting 

those Zakat Committees. Mr. Avi from the ISA talked about 

outside organizations, organizations not located in the 

West Bank or Gaza, very similar to the HLF. There were 

charities set up in other countries whose main goal is to 

support HAMAS. He talked about -- He identified these 

organizations by certain criteria that he had, including 

the way they raise their funds, using the same type of 

speakers, the relationship between the leaders of the 

organizations and the leaders of HAMAS and where these 

organizations sent their money. He identified a few of 

the organizations, including InterPal in London, CVSP in 

France and Al-Aqsa in Germany as well as the HLF. Those 

organizations operated in the same manner with the same 

goals and purpose as the HLF, and they are all part of one 

network. And what we know is that the HLF helped set up 

this network. Government's Exhibit 3-15, one of the El 

Barasse documents again, talked about Palestine committees 

being set up in other countries. Well, 3-8, Page 6. This 

is a document entitled "The OLF report." This is the 

Occupied Land Fund reporting on its activities to the 

Palestine Committee. At the bottom of this page where it 

says "The Central Committee for Charity Work," it says 

"Brother Ghassan" -- that's the Defendant Ghassan 

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Elashi -- "is currently on a visit to Britain representing 

the Fund" -- Occupied Land Fund and the Holy Land 

Foundation -- "in order to study the possibility of 

forming a substantial committee for charity work 

affiliated with the apparatus in all the countries with 

the goals of coordination, exchange of experiences and 

finding the best ways to increase donations and quickly 

respond to the request of the people on the inside." The 

inside being HAMAS. 

Here we see this outside network of charities in 

other countries that were helped to be formed by the Holy 

Land Foundation, and what those organizations did -- what 

the HLF did -- is send a large amount of money to these 

Zakat Committees located in the West Bank and Gaza. 

Now, we heard testimony from Dr. Levitt that the 

Zakat Committees are the ways that the social wing of 

HAMAS implemented its aid to the Palestinian people. They 

are the ones who ran the schools, who ran the hospitals. 

They set up mosques, and they did other things, and we 

heard from Mr. Avi that there are hundreds of Zakat 

Committees throughout the West Bank and Gaza. And HAMAS 

does not control all of them. HAMAS controls only a small 

percentage, and if someone wanted to really help the 

Palestinian people, help them without going through a 

terrorist organization, there are certainly ways and 

CASSIDI L. CASEY, CSR, 214-354-3139

UNITED STATES DISTRICT COURT

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avenues that they could do so, but these defendants 

because they are part of HAMAS chose particular Zakat 

Committees that were run and controlled and operated by 

HAMAS in order to send their money. They sent it to the 

committees in Jenin, Ramallah, Qalqilla, Islamic 

Charitable Society of Hebron, Islamic Society in Gaza. 

These are some of the names we heard. 

One of the committees they sent money to, 

Islamic Relief Committee. Islamic Relief Committee, as 

Mr. Avi said, was set up by HAMAS in the early 90's to 

sort of be a funnel of money to the Zakat Committees. And 

while the HLF sent money directly to the Zakat Committees, 

at the same time they were sending money to the Islamic 

Relief Committee. They sort of did both. Mr. Avi 

identified Islamic Relief as HAMAS. Mr. Abington, the 

defenses' own witness, identified the Islamic Relief 

Committee as being HAMAS. And if we could pull up 20-12, 

this is a schedule of payments between the Holy Land 

Foundation and the Islamic Relief Committee. Last page. 

We see that between 1991 and 1996 after HAMAS is initially 

designated as a terrorist organization, the Holy Land 

Foundation gave almost 1.5 million dollars to the Islamic 

Relief Committee. And if you look at Government's Exhibit 

3-65 of the El Barasse documents, this is a document that 

came from the Islamic Relief Committee, and you'll see 

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what they are about. They talk about violence and getting 

weapons to carry out Jihad operations. So this particular 

Zakat Committee is not about helping people. It's all 

about helping HAMAS, the social wing and the military 

wing. 

Now, Mr. Avi in identifying particular Zakat 

Committees being controlled by HAMAS talked to you about 

the criteria it had in determining whether one Zakat 

Committee is HAMAS and one Zakat Committee is not. And it 

wasn't just posters found there. As Mr. Abington said and 

Dr. Brown said, just because you have posters there 

doesn't mean it's HAMAS. Mr. Avi didn't look at just 

posters. He looked at a whole range of materials, 

including who ran the committees. What else was there 

besides HAMAS internal documents? He looked at videos 

that were seized in the committees, and we have also seen 

documents that the defendants had access to that were 

created here in the United States identifying the Zakat 

Committees as HAMAS. I want to talk about these 

committees. 

Your Honor, this may be a good time for a break. 

I know we're a few minutes early. 

THE COURT: Ladies and Gentlemen, we'll be in 

recess for lunch until 1:20. 

(Jury out).

CASSIDI L. CASEY, CSR, 214-354-3139

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THE COURT: Mr. Jonas, you have used almost two 

hours and nineteen minutes of your time. You had said 

earlier that you might want during the noon recess to ask 

me for warnings about your time, and I wanted to ask if 

you had made any decision about that or if you wanted to 

think about it. 

MR. JONAS: No, your Honor, I'm going a little 

faster than I expected. So I think I am going to come 

well within my four hours. Thank you. Thank you for the 

early break. 

THE COURT: Yes, sir. And I wanted to ask a 

procedural question for the defendants' counsel, and that 

is whether we will be going in the order of the indictment 

or if there is some other order that's been agreed upon. 

MS. HOLLANDER: There is another order. I'm not 

actually sure what it is, except that I know that I'm 

first. That's as far as we'll get today I'm sure. 

THE COURT: What about the allocation of time? 

Is there going to be an equal division of time? 

MS. HOLLANDER: No, it's not. 

THE COURT: Okay, I will want to know that ahead 

of time because I don't want one of the later counsel who 

runs out of time to tell me, well, I had such and such, 

and I wasn't told that ahead of time. 

MS. HOLLANDER: I can tell you that I am first, 

CASSIDI L. CASEY, CSR, 214-354-3139

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and that my allocation of time is approximately an hour 

and a half. 

THE COURT: Why don't you work out all the 

details between now and the time that defense closing 

arguments begin, and let me know what that division is. 

MR. GARRETT: Your Honor, I wanted to bring one 

thing to your attention. The defense in regard to the 

jury instructions -- the defense had objected to one 

particular issue, the lack of an element in the 2239(B) 

charge connecting the knowledge that the committees were 

operating for or on behalf of HAMAS, and we have looked at 

that closely on the government's side, and we agree there 

is something to that, and what I'm suggesting is we may 

work on some suggested language just for that one element 

that we would propose to your Honor. We don't have that 

now, and I don't think it has to be right now, but we have 

talked to defense counsel about it, and I wanted to put 

you on notice that we may offer something to your Honor 

for your consideration on that issue. 

THE COURT: All right. Sooner would be better 

than later. We'll be in recess for lunch until 1:20. 

 (Recess) 

THE COURT: Good afternoon, Ladies and 

Gentlemen. Go ahead, Mr. Jonas. 

MR. JONAS: Thank you, your Honor. Before we 

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broke for lunch, I was talking about what the HLF did with 

their money, how they themselves focused on a special 

segment of society, being children and families of 

prisoners and martyrs and how they committed economic 

Jihad on behalf of HAMAS. I want to talk about the Zakat 

Committees that we have heard a lot of testimony about and 

how this money went to the Zakat Committees as part of 

their mission, in fact a completion of their duties. They 

raised money in the United States and sent it to the 

social wing of Zakat Committees and that completes their 

role. I want to start off going committee by committee. 

I want to start with the Nablus Zakat Committee. First, 

20-6. 

This is a schedule of the payments between the 

Holy Land Foundation and the Nablus Zakat Committee. And 

again, I just want to point out the column that says 

direct versus indirect. Just to remind you what that 

means is if it's direct it's a payment that went straight 

from HLF here in Dallas to the Zakat Committee's bank 

account wherever that may be. If it's indirect, the money 

went from HLF's account to an account in Gaza and from 

there it was forwarded onto the Zakat Committee. We see 

starting in 1991 when the HLF starts to make payments to 

this committee, and it ends in 2001. The HLF paid almost 

half a million dollars to the Nablus Zakat Committee. 

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The HLF, besides just making payments to the 

committee, they had several other connections to the 

Nablus Zakat Committee. This is part of the Power Point 

presentation that Agent Burns went through with you when 

Mr. Garrett was questioning her, and I'm not going to pull 

up all the exhibits. I just want to show you this 

represents the letters and the correspondence going back 

and forth between the Nablus Zakat Committee and the HLF. 

So it goes to show the HLF wasn't just blindly sending 

money to this committee. They actually had a more 

substantial relationship with the organization. 

Now, the Nablus Zakat we know was controlled by 

HAMAS for a few reasons. One of those reasons is several 

of the leaders and members at random were HAMAS members 

themselves, and this was identified by Mr. Avi. But it 

wasn't just Mr. Avi saying this. One of those 

individuals's names was Hamed Beitawi. I mentioned his 

name before. If you recall the dispute between HLF and 

Ashqar when Ashqar brought Hammimi into the United States 

to raise funds, it was Hamed Beitawi that went to see 

Ashqar to help resolve the dispute. We know that Beitawi 

was HAMAS, and we know the defendants knew from a video 

tape that was seized from the HLF. This is a video that 

is made of HAMAS deportees in Lebanon in the early 90's, 

and we see them sitting around identifying themselves. 

CASSIDI L. CASEY, CSR, 214-354-3139

UNITED STATES DISTRICT COURT

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1-318. 

(Tape played).

MR. JONAS: You see the symbol for HAMAS appear 

on the screen? This isn't something that the government 

prepared. This is as found at the offices of the HLF. 

(Tape played).

MR. JONAS: There are several other individuals 

here who are part of the committees that are 

HAMAS-supported. I wanted to point out this individual, 

Mohammed Abu Zeid, is one of them. 

(Tape played).

MR. JONAS: The last person we saw Hamed Beitawi 

of the Nablus Zakat Committee was one of the members of 

HAMAS. I misspoke when I said Beitawi was one of the 

individuals that went down to settle a dispute between 

Ashqar and HLF. That was Mohammed Syam. I promised you 

don't have to worry about the names, and I'm not reading 

off the name, but remember that there are three other 

members identified by Mr. Avi who were running the Nablus 

Zakat Committee and also members of HAMAS. Besides the 

leadership of the committee being HAMAS, there was also -- 

And we have seen a series of exhibits of things found at 

the Nablus Zakat Committee, posters. 6-61, a poster of an 

individual who was part of the military wing of HAMAS. 

There was 6-76, post cards of two HAMAS military members. 

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UNITED STATES DISTRICT COURT

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6-77, a key chain of Sheikh Yassin. 6-79, a key chain of 

the famous engineer, Yaish, a military member. 6-75, this 

was a video tape that was found at the Zakat Committee. 

And we'll play a short segment of this video. 

(Tape played).

MR. JONAS: What he is talking about is military 

operations committed by the HAMAS military wing. As you 

can see, he's standing there holding the gun, and this 

tape was found at the Nablus Zakat Committee. Now, if 

these Zakat Committees are independent organizations, why 

would they have a video like this in its possession? We 

have also seen exhibits here in the United States showing 

the Nablus Zakat as HAMAS, including some of the El 

Barasse documents, Government's Exhibit 3-7. On that 

document it identifies Sheikh Hamed Beitawi, the man in 

the video tape, as being part of HAMAS. 4-21 also talks 

about the Nablus Zakat Committee having Islamists on its 

board. The Ramallah Zakat Committee, 20-8. This is a 

scheduled payment between the Holy Land Foundation and the 

Ramallah Zakat Committee. 

You see this shows when HAMAS was designated as 

a terrorist organization in 1995, the payments started way 

before then, and they continued on until way after then. 

All of these payments to a HAMAS-controlled 

Ramallah Zakat Committee. 

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You see that over the years HLF paid Ramallah 

over half a million dollars. 

Again, this is a listing -- besides money, a 

listing of the correspondence and relationship between 

Holy Land Foundation and the Ramallah Zakat Committee. 

Now, Mr. Avi talked about several members of that 

committee who are part of HAMAS, some of whom are part of 

the military wing. Dr. Levitt talked about an individual 

named Abdel Hamdam who was connected to planning suicide 

attacks. Remember I told you earlier one thing the social 

wing does is give cover to the members of the military 

wing, and we see that right here with a member of this 

Zakat Committee who was involved in committing military 

attacks, terrorist attacks. 

Government's Exhibit 3-7, Page 4. I'm only 

going to pull this document up once, but this document 

refers to most of the Zakat Committees I will be talking 

about. As you can see, on the left they mention all of 

them. Ramallah Zakat Committee, all of it is ours. Now, 

this document was found along with the other El Barasse 

documents about the Palestine Committee and the purpose of 

Palestine Committee and the goals and all of that. So 

when it says all of it is ours, what do you think they are 

talking about? Clearly, they are talking about HAMAS, 

that the Zakat Committee is ours. It's HAMAS. When you 

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take this in conjunction with the leaders of the Ramallah 

Zakat Committee being HAMAS members, it's clear that this 

committee is part of the HAMAS social infrastructure. The 

Tulkarem Zakat Committee, 20-9. HLF started supporting 

the Tulkarem Zakat Committee as early as 1991. We see 

payments going all through the years -- Last page, 

please -- up through 2001 when they sent a total of over 

$315,000 to the Tulkarem Zakat Committee. Once again, we 

have letters, correspondence, going back and forth between 

the Holy Land Foundation and the Tulkarem Zakat Committee. 

We heard from Mr. Avi that there are six or seven 

individuals of the Tulkarem Zakat Committee who are 

connected with HAMAS. And Mr. Avi is not just coming up 

with that. He's relying upon multiple sources to make 

that identification, including interviews of Khalil 

Mishal -- the leader of HAMAS -- statements made by HAMAS 

members to the Israel police as well as other public 

identification of these individuals. 

In the Tulkarem Zakat, there were posters of 

HAMAS members found, posters of HAMAS military members, 

posters of HAMAS leaders, Government's Exhibit 6-35 and 

the 6 series of documents are all of these documents that 

the Israelis found at these Zakat Committees. 6-57 was a 

poster of Yaish the engineer holding a gun in one hand. 

This is a picture in a frame. He's holding a gun in one 

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hand and his child in the other. We have several other 

posters found of HAMAS leaders at this committee. I'm not 

going through all of them, but you will have them back in 

the juryroom, and you can look at them when you 

deliberate. We also know that in the Philadelphia 

conference they talked about the Zakat Committees. 

Government's Exhibit 16-59, they talk about the Tulkarem 

Zakat Committee, the fact that it's building a hospital. 

3-7, the document I pulled up before talks about Tulkarem 

and the members and supporters. 

So again, the evidence shows these committees 

are HAMAS. Divers, not one source. Coming from multiple 

sources. Some of the sources are only available to the 

defendants. Some of those sources were not available to 

the defense Wednesday, Mr. Abington or Mr. Brown. 

Bethlehem Orphans Care Society, 20-10. Now, the Bethlehem 

Orphans Care Society started out in 1997 when Ghassan 

Harmas left a different society that the HLF was 

supporting which was the Bethlehem Charity. In 1997, he 

leaves the Bethlehem Charity and starts the Bethlehem 

Orphans Care Society and HLF support goes with him. If we 

continue on through this document, you will see that it 

changes from Bethlehem Charity to Bethlehem Orphans Care 

Society. 

Now, Ghassan harms, as I said, he was the one 

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that left the Bethlehem Charity and formed the Bethlehem 

Orphans Care Society. Remember when you think of orphans, 

their definition as used by the defendants is not the same 

as what most people think of. It's not both parents being 

deceased. It's only the father that is deceased. And we 

know Ghassan Harmas was a member of HAMAS identified by 

Mr. Avi as well as other members of the Bethlehem Orphans 

Care Society. Government's Exhibit 3-7 says "We have 

seven out of eleven including Ghassan Harmas, an honorable 

man." I'm not going to pull these up every single time. 

But this exhibit shows again there is other correspondence 

between the HLF and Bethlehem Orphans Care Society showing 

the connection between the two.

The Islamic Science and Culture committee. This 

is a committee run by Jamil Hammimi. You have heard about 

it several times. Jamil Hammimi is the one at the center 

of the dispute between HLF and Ashqar. Hammimi is the one 

who had a falling out with HAMAS back in 1997 or 

thereabouts until years later when they made up. 

Government's Exhibit 20-4, this is a scheduled payment 

between the HLF and the Islamic Science and Culture 

Committee, Jamil Hammimi's committee. The last page, you 

see that the payments ended in 1996 which was when Jamil 

Hammimi -- around the time that Hammimi has a falling out 

with HAMAS. We know that Jamil Hammimi was an overseas 

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speaker for the HLF. We know he was one of the founders 

of HAMAS in the West Bank. We know there were several 

other people connected to the Zakat Committee that were 

identified as being members of HAMAS. 

In the Philadelphia conference, they talked 

specifically about Jamil Hammimi and the Islamic Science 

and Culture Committee. They said in Jerusalem there 

remains some organizations, particularly the Islamic 

Science and Culture Society, which is directly counted 

with us. Who do they mean when they talk about us? 

HAMAS. 

Government's Exhibit 3-7 talks about Islamic 

Science and Culture. We have three of our people on it. 

So again, you have a lot of different evidence pointing to 

the fact that that committee is controlled by HAMAS. 

Qalqilla Zakat Committee, 20-7, another 

committee supported by the HLF through the years starting 

in 1992 going up to 2001 when they gave the Qalqilla Zakat 

Committee over $284,000. There was at least three known 

HAMAS members running this organization. And 3-7, an El 

Barasse document, when they refer to the Qalqilla Zakat 

Committee they said "All of it is ours, and it is 

guaranteed." They also talked about the Qalqilla Zakat 

Committee in the Philadelphia conference. 

The Islamic Society, 20-14. Payments went to 

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the Islamic Society from 1992 until 2001. $300,000 and 

the ILS is Israeli shekels. That's not included in the 

computation of $300,000. 

This was a society that was founded by Sheikh 

Yassin in the seventies as a Muslim Brotherhood 

organization and became a HAMAS organization once HAMAS 

was formed. And it has several significant members that 

are HAMAS, some of whom we saw in the video tape of the 

deportees sitting around in the tent, and you know there 

was a second part of that video tape that I forgot to 

play. We can play it now. 318 B. 

(Tape played).

MR. JONAS: The Defendant Mohamed El-Mezain, the 

Defendant Shukri Abu Baker. 

So we see this gentlemen sitting around the tent 

with the deportees who are identifying themselves as 

HAMAS. Some of whom are identifying themselves as being 

part of the same Zakat Committees HLF supported, and this 

individual is talking about coming to the United States at 

the invitation of the Holy Land Foundation and two of 

these defendants. 

We have Government's Exhibit 4-21 that talks 

about the Islamic Society being part of HAMAS. 3-65, 

another El Barasse document, talks about it. Another 

Zakat Committee, Islamic Charitable Society of Hebron. If 

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we could pull up 20-3. I'm sorry. Before we do that, 

before we leave Islamic Society, there is another short 

clip I want to play of a video tape. This video tape was 

played for Dr. Levitt and Mr. Avi, and it was played for 

you to evaluate their testimony when talking about the 

Zakat Committees and HAMAS. Mr. Avi told you this was not 

found at the Islamic Society but downloaded off the TV of 

a kindergarten ceremony of the Islamic Society, and he 

discussed it when he was explaining to you how Islamic 

Society is part of HAMAS. 

(Tape played).

MR. JONAS: There is the suicide belt on the 

child. A child dressed as Sheikh Yassin, the one in the 

white. I don't know if you remember this, but that song 

was playing in the background and was one of the songs 

that the Defendant Mufid Abdulqader was singing in the 

tapes I played this morning. 

(Tape played).

MR. JONAS: When Dr. Levitt and Mr. Avi were 

talking about the Zakat Committees and their support for 

HAMAS, part -- one of the things they were relying upon is 

videos like this. The Islamic Charitable Society of 

Hebron. 20-3. This society was a very large one that has 

several branches, at least five branches identified by Mr. 

Avi. And we see payments going not just to the Islamic 

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society in Hebron but also payments to some of the 

branches of its organizations, and we see payments as 

early as 1991 going up through 2001, almost 1.8 million 

dollars going to the Islamic Charitable Society in Hebron. 

Mr. Avi identified about six or seven individuals that are 

part of this organization that are HAMAS members one of 

whom, Nabil Natsheh, his name is in Marzook's phone book. 

But there is another individual whose last name is also 

Natsheh that we see in a video that was seized from this 

organization. I want to play 6-58. 

While that's being worked on, let me talk to you 

about some of the other documents found at this zakat 

committee. Posters, political statements, 6-22. This is 

not a poster being shown to people walking in. This is an 

internal HAMAS document. Government's Exhibit 6-66, what 

was an internal document that talked about HAMAS 

elections, and that document is written in very tiny 

writing like it was supposed to be hidden or concealed 

away. All of that was found -- That last document was 

found in the office of Natsheh, the individual who's named 

as part of this committee and is a well known HAMAS member 

in Hebron. There is pictures of suicide bombers in a 

child's frame and so forth. Government's Exhibit 3-7, the 

El Barasse document with regard to the Islamic Charitable 

Society of Hebron, it says "All of it is ours." In the 

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Philadelphia conference, they said "In Hebron, Hebron as a 

city, is a place where we consider that we have a good 

presence and weight as Islamic organizations such as the 

Islamic Charitable Society which was founded in 1962 and 

has over a thousand employees." From Philadelphia, they 

are acknowledging that the Islamic Charitable Society of 

Hebron is theirs. Some of the workers from the Islamic 

Charitable Society went on to become part of the military 

wing of HAMAS according to Mr. Avi. All right. Let's see 

if we can play the video now. 

(Tape played).

MR. JONAS: This is another one of those 

kindergarten school ceremonies. 

(Tape played).

MR. JONAS: What we see here is the children 

holding rocket RPG launchers. And what we're going to see 

in a minute if we can get up to that point --

(Tape played).

MR. JONAS: What she just did is identify the 

man Abdel Natsheh as one of the leaders of HAMAS in Hebron 

who's also part of this society in Hebron. So between the 

items found there and between the leader being HAMAS, as 

this woman told us, between the Palestine Committee 

identifying all of it is ours, there is no question that 

the Islamic Charitable Society of Hebron is HAMAS. 

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The last one, Jenin Zakat Committee, 20-5. 

20-5 is the schedule of payments between the HLF 

and the Jenin Zakat Committee, and those show to be from 

the early eighties right up to 2001. Over the years the 

HLF provided over $600,000 to the Jenin Zakat Committee. 

Now, we know that the Jenin Zakat Committee is a member of 

HAMAS. One of the leaders of the Jenin Zakat Committee, a 

man named Mohammed Fouad Abu Zeid, a man we saw on the 

video a few minutes ago. Number 3-7 identifies Jenin as 

theirs specifically because of Mohammed Abu Zeid. They 

have at least six other members that have been identified 

as being HAMAS members through different sources. Mr. Avi 

said that Khalil Mishal identified some of these people. 

Part of these people are from the military wing of HAMAS. 

They have been involved in military attacks as identified 

by Dr. Levitt. So you have at least six members of the 

leaders running the committee for HAMAS. We have 

postcards of Sheikh Yassin that were found there. 

Government's Exhibits 6-71, 72, postcards of Rantisi, 

another HAMAS leader. We showed you one of those 

postcards. Mr. Avi told you that there are boxes of them. 

And when someone walks into the Jenin Zakat Committee and 

there boxes of postcards, what do you think they are doing 

with those postcards? They are handing them out to 

people. Hey, we're Jenin Zakat Committee, and we're 

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affiliated and part of HAMAS, and this is part of building 

the loyalty and getting the hearts and minds, winning the 

hearts and minds of the Palestinian population, letting 

people know who that committee is with. Otherwise, if the 

committee cannot take credit, HAMAS cannot take credit. 

Then people aren't going to know who to support. 

16-59, the Philadelphia conference, they talked 

about the Jenin Zakat Committee. They say when -- "We 

then come to the main activities which is the Zakat 

Committees," and they talk about Jenin and having the 

Jenin Zakat Committee running the largest Islamic school. 

2-22, talks about the Jenin hospital, a hospital 

run by the Jenin Zakat Committee, and that was the 

document I went through with Mr. Abington where it talks 

about ours, brother, semi-brother, distinctions between 

Fatah which is the PLO organization that was running the 

Palestinian Authority and Islamists which is what HAMAS 

is. 

So we see a lot of different sources of evidence 

showing the Jenin Zakat Committee is HAMAS. The same time 

a lot of these sources of evidence tell us -- show us that 

the defendants knew the Jenin Zakat Committee and all of 

these Zakat Committees are HAMAS. They talked about it in 

Philadelphia. I encourage you to read Government's 

Exhibit 16-59. You have 3-7, El Barasse document. You 

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have that video tape taken from the HLF of the deportees. 

You have so many overseas speakers they brought in. Some 

of the HAMAS overseas speakers are affiliated with these 

Zakat Committees. And finally, you have your common 

sense. If the Holy Land is part of the Palestine 

Committee and if its role was to raise funds for HAMAS and 

they bring in speakers and have conferences where HAMAS is 

the theme of the day and they send their money to 

HAMAS-controlled organizations, common sense tells you 

that they know that they are sending their money to HAMAS. 

Only that makes sense. When you deliberate you are 

allowed to use your common sense. 

I want to show you one more video that's taken 

from the Jenin Zakat Committee. Government's Exhibit 

6-82. This is of a summer camp. 

(Tape played).

MR. JONAS: The Jenin Zakat Committee and these 

other Zakat Committees run schools and camps to put guns 

in children's hands. They dress them as suicide bombers 

and re-enact terrorist acts all to brainwash these 

children, and they did so with the money raised by these 

defendants sitting behind me, and it wasn't just in the 

West Bank and Gaza where they were brainwashing children. 

They were doing it right here in the United States. I 

want to show you some video tape seized from the HLF. If 

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we can show 1-314. 

(Tape played).

MR. JONAS: Little children singing about HAMAS. 

In the same tape -- 

(Tape played).

MR. JONAS: -- singing out Jihad with a child 

pointing a gun. These children are very impressionable, 

and this is what they are trying to do to them, to 

brainwash them to become members of HAMAS. 

(Tape played).

MR. JONAS: The cheers are for him saying HAMAS 

is calling me. 

(Tape played).

MR. JONAS: 1-325. 

(Tape played).

MR. JONAS: Also on the tape. 

(Tape played).

MR. JONAS: A ladder to glory out of our skulls 

the children are singing. You see one child in the back 

with a gun. 

(Tape played).

MR. JONAS: 1997 -- 1995 to 1997 HAMAS was 

designated a terrorist organization by the United States 

Government. In 1995 forward, once it was designated, it 

became illegal to provide money, support, to HAMAS. You 

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have heard a lot of talk about the designations. I just 

want to briefly explain what that means. There is two 

types of designations, specially designated terrorists or 

specially designated global terrorists and foreign 

terrorist organizations, SDFO's. SFDO's can only be 

organizations that are foreign-based. The SDT designation 

began in 1995 based upon a presidential executive order, 

and the FTO designation was based upon a law passed by 

Congress in 1997. HAMAS was a charter member of both. 

HAMAS was one of the original members to be designated as 

a specially designated terrorist and one of the first 

groups to be designated as a foreign terrorist 

organization. Look at 11-9 and 11-1 and will you'll see 

those designations. The implication for being designated 

on either list is the same. No U.S. person, citizen, 

anybody living in the United States or organization can 

give money to HAMAS. Simple as that. To do so is a 

crime. And that's what these defendants are charged with. 

They are charged with giving money to HAMAS. 

Now, the defendants knew about these 

designations, and they knew about the consequences. 

Government's Exhibit 2-179 is a copy of that executive 

order designating HAMAS as a specially designated 

terrorist. That executive order was found in the office 

of Ghassan Elashi, the defendant, over at Infocom. Ask 

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yourself this. How many people have a copy of a 

presidential executive order lying around their office or 

home, especially one of which they are accused of 

violating. 

Government's Exhibit 15-94 is a phone call 

between the Defendant Mohammed El Mezain and another 

individual where they talk about HAMAS being designated 

and its assets frozen. We will see several phone calls 

between the defendants where they talk about the 

consequences -- the designation and the consequences. I 

want to play 13-121, one such phone call between the 

Defendants Ghassan Elashi and Shukri Abu Baker. 

(Tape played).

MR. JONAS: They are talking about themselves 

being identified as a HAMAS cell in North Texas. 

Government's Exhibit 13-3. 

(Tape played).

MR. JONAS: This is the Defendant Shukri Abu 

Baker and Ghassan Elashi. 

(Tape played).

MR. JONAS: Same conversation. 

(Tape played).

MR. JONAS: The Defendant Shukri Abu Baker was 

absolutely right. It doesn't matter whether it's a 

charitable wing of the terrorist organization as long as 

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it's a part of the terrorist organization. It becomes 

illegal to give money to that organization. You have 

heard a lot of questions by Mr. Cline of some of the 

government's witnesses regarding whether or not the social 

wing of HAMAS, its Zakat Committees, was designated 

itself, whether the Zakat Committees were designated, and 

I guess the point he was trying to make is if those Zakat 

Committees were designated or if those Zakat Committees 

were part of HAMAS, they would have been designated, just 

like you have some of the leaders of HAMAS designated 

themselves. That's not the case. It doesn't have to be 

each component and each individual of a terrorist 

organization designated if those committees are part of 

the organization which they are. Dr. Levitt told you 

there are many reasons why every single person and every 

single component of a terrorist organization is not 

designated. 

Let me put it this way. Let's say the Dallas 

Cowboys are designated as a specially designated terrorist 

organization and Jerry Jones and Wade Phillips are 

designated themselves as well for their affiliation with 

the Cowboys. Do you think that means that someone can 

give money to the offensive line to go out and buy 

equipment because the offensive line is not designated? 

Of course, the offensive line is part of the team, and 

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they don't have to be separately designated in order for 

it to be illegal to give to them, especially when these 

defendants knew they were part of HAMAS. And the 

defendants knew the law, and the defendants knew that they 

were breaking that law. The indictment charges them with 

providing money to a foreign terrorist organization. 

There is a bunch of charges in that, both conspiracy, 

which means they got together and agreed they were going 

to provide money to HAMAS. That agreement doesn't have to 

be in writing or spoken as long as it's understood, as 

long as one person takes a step to further that agreement 

such as sending one payment to HAMAS. That's good enough 

to take that step to reach the goals of that conspiracy. 

They are charged with specific counts of sending 

money to HAMAS, both as a specially designated terrorist 

and as a terrorist organization. The charge of money 

laundering, of sending the money out of the United States 

to HAMAS, that is a separate crime in and of itself. And 

just to let you know, we put together a schedule, 

Government's Exhibit 20-54, that lists out all the 

transactions in the indictment. That's pulled from those 

schedules of the payments to the Zakat Committees. It 

also charges Shukri Abu Baker and Ghassan Elashi with tax 

evasion. By sending money to HAMAS and reporting those 

payments on the tax return of HLF as legitimate program 

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services, that was making those returns false, and that's 

a violation in itself. 

In their opening statement to you, Ms. Hollander 

kept saying need not creed. But whose need did the HLF 

fulfill? The HLF aided HAMAS's need by taking advantage 

of the economic situation in the West Bank and Gaza and 

the suffering of the children of both locations in order 

to achieve the goal of HAMAS to destroy Israel through 

violent Jihad. They said so in the Philadelphia 

conference, Government's Exhibit 16-51. Quote, "The first 

step should be taken by the brothers in how to make the 

agreement fail, the national rights, the human rights, 

stuff which will be exploited in order to make you look 

legitimate while you call on the annulment of the 

agreement," the agreement being the Oslo Accords. "The 

human rights stuff which will be exploited in order to 

make you look legitimate." That's exactly what the HLF 

was doing. That's exactly what HAMAS was doing. Even the 

Defendant Abdulraham Odeh, sitting behind me, the New 

Jersey rep, in discussing with the Defendant Mohamed 

El-Mezain the HLF help during the Oklahoma City bombing, 

Government's Exhibit 15-16, said "It is a good opportunity 

for us to be highlighted from something good in America." 

And Abdulraham Odeh said, "Yes, if we can benefit in 

America." They weren't there to help but to put on a face 

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for their own gain. They were trying to show one face to 

America and conceal their true selves. 

16-69, Page 13, bottom half. The Defendant 

Shukri Abu Baker says "I swear by your God that war is 

deception. War is deception. We're fighting our enemy 

with a kind heart. We never thought of deceiving it. War 

is deception. Deceive, camouflage, pretending you are 

leaving when you are walking that way. You have to 

deceive your enemy." And Omar Ahmad says "This is like 

one who plays basketball. He makes a player believe that 

he is doing this while he does something else. I agree 

with you. Like they say, politics is a completion of 

war." Page 21, again, "War is deception." Omar Ahmad 

said "Learn from your masters in the Fund." The Holy Land 

Fund, the Holy Land Foundation. "War is deception." We 

have seen several times where they tried to deceive the 

American public. We have seen Sheikh Yassin playing dumb 

to Steve McGonigle, the reporter. We have seen the 

Government's Exhibit 16-61, minutes of the meeting of the 

Holy Land Foundation back in 1991 of just those three 

defendants, minutes if the IRS came in and audited the 

Holy Land Foundation they would be able to review. Those 

minutes in English are fairly benign. But in Government's 

Exhibit 3-19, taken from El Barasse, we see minutes in the 

same meeting in Arabic which talk about the Palestine 

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Committee, which talks about the true purpose of HLF and 

what they were really doing, and those minutes in 3-19 are 

very different from the minutes in the meeting which is 

3-32 which could be exposed to the public. We see Shukri 

Abu Baker's statement to Gail Reeves about "We never 

supported HAMAS or brought in HAMAS speakers." We know 

that's not true. We see Shukri Abu Baker's ode to HAMAS, 

poem to HAMAS in the Ila Filistine magazine plus his sworn 

declaration filed in a lawsuit which is public for 

everyone to see which says "I hate and abhor HAMAS." We 

see deceit all over the Philadelphia conference, and I 

encourage you to read the transcripts where they talk 

about showing one face to America and another face to the 

Muslim community that supports HAMAS and the Muslim 

Brotherhood. War is deception. For over thirteen years 

the defendants deceived the American public into believing 

they were a legitimate charity with good intentions who 

only wanted to help the poor and the needy, and in reality 

they were part of a larger plan, in cahoots with a 

terrorist organization, HAMAS, to try to destroy the State 

of Israel through violent Jihad. Don't let the defendants 

deceive you into believing what they did they did to 

support widows and orphans. The reality is by supporting 

HAMAS they were helping to create widows and orphans. Do 

not let them deceive you. Find them guilty. Thank you. 

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THE COURT: Ladies and Gentlemen, as I told you 

earlier, I am going to try to insofar as possible arrange 

our recesses so that we don't interrupt the argument of 

counsel. So even though this is a bit earlier than we 

normally take our mid-afternoon recess, I think this would 

be a good time to take it. We'll be in recess until 3:45. 

I'm sorry. 2:45. 

(Jury out)

THE COURT: Ms. Hollander, has it been worked 

out among defense counsel what order you will be going in 

and how much time will be allocated to each? 

MS. HOLLANDER: I think so. Pretty much. I'm 

going first, and I'm taking approximately an hour and a 

half, although my cocounsel gave me some leeway, if 

necessary, and next is Mr. Dratel. 

MR. DRATEL: Yes, sir, an hour and a half at the 

outside. 

MS. HOLLANDER: And next is Ms. Cadeddu. 

MS. CADEDDU: Forty-five minutes. 

MS. HOLLANDER: Next is Mr. Westfall for 

approximately forty-five minutes. 

MR. WESTFALL: Approximately forty-five minutes, 

yes. 

MS. HOLLANDER: And last is Ms. Moreno for an 

hour and a half. 

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THE COURT: Thank you. We'll hear from Ms. 

Hollander then when we come back. 

MR. DRATEL: Your Honor, may I ask also since 

Ms. Hollander is going to finish around 4:15 or so if we 

can recess and I could do mine in one piece tomorrow. I 

don't think it would make any difference because we have 

three tomorrow and two on Wednesday. 

THE COURT: That sounds fine. 

 (Recess)

THE COURT: Ladies and Gentlemen, now that 

counsel for the government has finished its opening 

portion of the government's closing argument, we are at 

the point where we will begin hearing from counsel for the 

defendants. Of course, each of the defendants is 

represented separately by counsel, and so as I told you 

this morning, I have collectively allocated six hours for 

the defense, and they apparently have agreed among 

themselves as to how that time is to be divided. We will 

begin by hearing from Ms. Hollander. 

Ms. Hollander, would you like any warnings from 

me about your time? 

MS. HOLLANDER: No, thank you. I have a watch 

with me, your Honor. Thank you very much.

THE COURT: Yes, ma'am. 

MS. HOLLANDER: Good afternoon Ladies and 

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Gentlemen. This case is about charity. That's what I 

said when we began in July, and it's still true. The 

government charges Shukri Abu Baker with providing money 

to charitable organizations that minister to the poor, the 

desperately poor in Palestine and other places in the 

world. That's what this case is about. Every witness 

talked about the desperate need of the Palestinian people. 

A real charity would do exactly what Holy Land did, 

minister to the poor and the needy, keep perfect, 

detailed, completely open records for anyone to see, file 

all tax documents, insure that the recipients of its aid 

are licensed, require the recipients of its aid to 

document how the money was spent. Holy Land is a real 

charity -- was a real charity that provided real aid to 

desperately needy people around the world. 

I want to stop there for a minute and look at 

Defendant's Exhibit 1079, and I hope that you will take 

notes of any of the exhibits that you are going to want 

that we discussed. You are going to want to look at them 

when you get back in the juryroom because, of course, you 

will have hundreds of exhibits, and you might take note of 

the ones you want to look at more closely. 

This is a report, a report called a Food 

Security Assessment. It's a joint project for the United 

States Agency for International Development and other 

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international organizations. According to this survey, 

Holy Land was one of four Islamic organizations providing 

essential food for a 145,000 Palestinian families. Mr. 

Edward Abington, if you recall -- and we'll talk about him 

some more -- represented the United States in Jerusalem 

for five years. He told you that meant approximately 

twenty to twenty-five percent of Palestinian families in 

need of food were being fed by these four organizations, 

and Holy Land was one of them. So what happened when the 

government closed Holy Land in 2001? According to this 

document, this international document, what happened was 

that the food supplies went down. Now, that doesn't mean 

there was no fancy lettuce in the produce department. 

That meant that people went hungry. That's the reality of 

this case. And that's what Shukri tried so desperately to 

avoid. He wanted these children who had nothing at all to 

have a little food. He wanted these children to have 

shoes to walk to school, a library to study in, supplies 

they needed to learn. He wanted people to survive and 

some day to thrive, and that's what Holy Land did. It 

helped people to survive and to prepare for a better 

tomorrow. 

What this case is not about is the terrible acts 

of HAMAS. Yet, Mr. Jonas spent the entire morning of his 

closing -- two and a half hours -- talking about violence. 

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He's really trying to scare you, Ladies and Gentlemen, by 

saying people were actually speaking in America. There is 

no evidence of violence in America. And one thing is very 

clear. Shukri Abu Baker is not charged with any violence 

whatsoever. It's the same way actually the government 

tried this case. They spent most of the six weeks they 

put on evidence just trying to scare you with disturbing 

videos of children, and you saw them again and again and 

again and with photos and testimonies of bombings and 

violence, none of which had anything to do with Shukri or 

the Holy Land. The last video you saw was in 2004, and 

Holy Land closed down in 2001. Don't be misled by that. 

No one here disputes that HAMAS engages in acts of 

terrorism, nor does anyone condone it. But no one here is 

charged with engaging in acts of terrorism. This case is 

about providing charity. 

In addition to being how Shukri Abu Baker and 

Holy Land responded to the needs of the Palestinian 

people, this case is also about something else: It's 

about how Shukri sought to make certain that Holy Land 

would never, ever give a single dime to an organization or 

charity that the United States Government told him not to. 

It's also about how Shukri did everything he knew how to 

do to follow the law so that the people who needed his 

help could always count on him. He took steps -- and 

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we're going to talk about them -- to distance the 

Foundation from politics to be sure that the orphans get 

fifty dollars a month, none of which is contested, that 

the children would get their food supplies and backpacks 

and the mothers would get milk to feed their babies or a 

refrigerator to store it if their houses had been 

demolished, refrigerators and all. 

To do this, Shukri actually hired a former 

United States Congressman, John Bryant, to help Holy Land 

comply with the law and satisfy the government that it was 

doing so. John Bryant also wanted to find out why the 

newspapers were printing stories saying that Holy Land was 

linked to HAMAS, printing stories like the one we just 

heard about that there were people in North Texas who were 

terrorists. John Bryant told you that he thought this was 

coming from Israel, and he tried to get someone in the 

Israeli Embassy or in the United States Government to tell 

him why, and no one would talk to him. 

Let me add here something that I am going to 

have to move pretty fast. I only have an hour and a half, 

and the Government has six hours. So there will be some 

subjects that other defense counsel will cover since we 

have to divide the time. So if I miss something, it's 

probably because someone else is going to cover it, but 

please consider what the other defense counsel say for 

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Shukri also as though I had made those arguments. 

For example, Ms. Moreno will be talking to you 

more about the steps that Congressman Bryant took to find 

out what Shukri and what Ghassan Elashi could do to avoid 

breaking the law. As you have also learned, Shukri is a 

religious Muslim man. His faith requires him to give 

zakat. We have learned a lot about zakat. It's an Arabic 

word that means to give alms, something of what you have 

to someone less fortunate. 

We have heard about the special place of orphans 

in the Muslim religion. To a Muslim, a child is an orphan 

if his father cannot provide for him -- if he is deceased 

or gone or in prison. The Prophet Mohammad himself was an 

orphan. So orphans have a special places in Islam. It's 

a different definition than perhaps you and I have, but 

it's a definition that's consistent with their faith. 

The government has claimed here today that 

Shukri really wanted to provide this much needed 

charity -- And there is no contest that he provided the 

charity, and Holy Land did -- but that he did it for the 

purpose of supporting HAMAS and that he actually provided 

material support to HAMAS. But they have never proven 

that. The prosecution has failed to prove that Shukri 

told anyone to support HAMAS through the distribution of 

Holy Land's charity. They failed to prove that Shukri 

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intended to or conspired or attempted or did provide 

material support to HAMAS. They failed to prove that 

these Zakat Committees and charities that Holy Land gave 

money to were operated on behalf of and controlled by 

HAMAS. They failed to prove those things because those 

things are not true. 

What the government's own evidence shows is 

Shukri's concern for the welfare of Palestinian people and 

for other people facing hardships caused by war and 

natural disasters. The government's own evidence shows 

that Shukri's commitment to providing aid to his people 

and his commitment to avoid politics to insure that aid 

would continue. 

Shukri is now an American citizen, but like many 

of us he feels a kinship to his heritage, which happened 

to be from his father's side Palestinian. With the start 

of the first intifada in 1987, he saw the suffering of the 

Palestinian people, his people. That's indeed where the 

background of this case begins, although it's important to 

remember that Shukri's on trial here only for acts after 

1995, even though Mr. Jonas spent the entire morning 

talking about events before then and this afternoon spent 

a total of forty minutes of his three hours talking about 

what he said was the relevant facts in the case about the 

Zakat Committees. 

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Now, Mr. Jonas has told you you shouldn't 

believe Shukri because he's been secretive and deceptive 

in the past. I want to look a little more closely at 

that. Shukri did give a deposition in 2003 as a 

representative of Holy Land where Holy Land was being 

sued, not Shukri. He explained the relationship between 

IAP and HLF correctly as a business relationship. What 

Mr. Jonas didn't tell you is that Shukri went into detail 

about that, and I showed you -- and you may have forgotten 

this -- checks for the fundraising that Holy Land did 

through IAP. What he also didn't tell you is that Shukri 

said in that deposition that he personally was on the 

advisory board of IAP. He said that at that time. He 

didn't hide it. But Mr. Jonas's omission points out the 

real problem throughout this entire case. Mr. Jonas, once 

again, didn't tell you the whole story. They don't want 

you to look at the evidence, Ladies and Gentlemen. What 

did he say? Don't worry about the actual names and 

details. Just remember everyone we said was HAMAS was 

HAMAS. Trust the government, trust the Government of 

Israel, because what this really comes down to is what Avi 

said. Miranda and Burns, they didn't know anything 

really, except what the experts told them, which was Avi, 

and Dr. Levitt got his information from the Israelis. So 

that's really where it comes from. And the government 

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says just trust them. He says they are HAMAS, they are 

HAMAS. 

I want to ask you on Shukri's behalf not to do 

as Mr. Jonas says. It's your duty -- it's your duty as 

Americans citizens on this jury to carefully consider all 

the evidence in this case, not just what the prosecution 

showed you. For example, Mr. Jonas also talked about a 

declaration that Shukri wrote, and he said that Shukri 

lied in that one, too. But he didn't tell you about the 

part that we had to ask the Court to add where Shukri said 

that he's speaking from memory about events that occurred 

twelve years earlier because at the time he gave his 

declaration the government had taken all of Holy Land's 

records, and he was just trying to accurately remember 

everything he could. 

But was Shukri afraid in 2002, 2003 of saying he 

attended conferences where people sang songs about HAMAS 

and in support of HAMAS in 1990 and 1991 before it was 

designated, before the suicide bombings, when the 

political situation was vastly different? Was he afraid 

of saying that people sang about HAMAS at the same 

conference where Holy Land raised money for the poor and 

needy of Palestine or that he wrote about HAMAS in the 

same news letters in which Holy Land advertised or even 

that he said and wrote things in the early 90's and late 

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80's that would be considered in support of HAMAS? Of 

course he was. Because by the time he gave that 

deposition and wrote that declaration, Holy Land had been 

closed and designated, and he had been threatened, hounded 

by the press since 1993. His phones had been tapped, and 

he was fearful. He was afraid of being prosecuted on the 

basis of things he had said over ten years earlier. 

Exactly what's happening in this courtroom.

The government wants you to consider the things 

Shukri said in 1990, 1991 and 1992 and even consider the 

things that other people said during that time as though 

Shukri said them and as though he was saying them now. 

The government wants you to believe that people never 

change, that the world in 1991 is the same as the world in 

1997 or 2001, as though HAMAS was the same, but that is 

wrong. As you go through the evidence in this case, pay 

close attention to the speakers and the dates. This is 

particularly important because Mr. Jonas spent most of the 

morning talking about what other people said and in a time 

period different than this indictment. When you look at 

the Philadelphia meeting -- and I am going to talk about 

it in a minute -- pay attention to who's talking. Shukri 

can never ever be prosecuted for expressing a political 

viewpoint. That tramples the First Amendment that we all 

care about into the dust. 

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And even if you do think he lied, if you think 

he lied in that declaration or that deposition, he's not 

on trial here for what he said but for providing material 

support to HAMAS. That's what you have to focus on, and 

that's what the government has not proven. 

Mr. Jonas mentioned that Shukri traveled to 

Saudi Arabia and claimed that he followed certain security 

measures by saying that he worked for Infocom. He failed 

to mention again that Shukri traveled under his own name, 

used his own American passport, paid for the visa with a 

check and wrote his correct home address on the 

application. This isn't really consistent with traveling 

undercover, but it is consistent with what the government 

has done throughout the case which is to give you only a 

few things and try to link them up without telling you all 

the relevant facts. 

As Judge Fish has told you, he's going to 

instruct you at the end of this case, and one of the 

instructions he would give you is this one. A defendant 

is not on trial -- I'm sorry. This is the wrong one. 

I'll just read it to you. "A defendant is not on trial 

for any act, conduct or offense not alleged in the 

indictment." Nothing in this indictment charges Shukri 

with lying. 

What the prosecution has done throughout this 

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case is so selectively stringing documents together. They 

have done it while failing to show the relevant documents 

that they have and they have had all along. But if they 

are inconsistent with the false impression, you don't get 

to hear about them, and I want to give you several 

examples. One of them actually happened right here. 

Right here during his closing argument Mr. Jonas showed 

you 20-33, and he said it was a summary of transactions 

between Marzook and Holy Land, to lead you to believe that 

money was going back and forth between Holy Land and 

Marzook. But Agent Burns admitted during her cross 

examination that this summary was wrong. Those two 

transactions I have highlighted in 1988, they actually 

went to another organization called the Holy Land fund. 

Let's look at that. We have the checks, and of course, 

the government has the checks because these were in the 

Holy Land documents. I'll show you one. Holy Land Fund. 

The Holy Land Foundation didn't even exist in 1988. This 

summary was wrong, and she had to admit it was wrong. 

Yet Mr. Jonas is still today telling you 

connections that don't exist, telling you facts that 

simply aren't true. He also claimed that Mahmud Zahar was 

deceitful in Holy Land's behalf in the 1999 interview with 

Steve McGonigle. If you recall, Steve McGonigle, the 

Dallas Morning News reporter, testified that he didn't 

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think Mr. Zahar was in any kind of cahoots with HLF. Now, 

Mr. Jonas said Mr. Zahar said he only met Shukri once. 

Well, that's very consistent. What Zahar told McGonigle 

was that he met Shukri at a fundraising conference in 

California, and that's exactly what Mr. Jonas pointed to, 

a fundraising conference in California. And you will 

notice that Mr. Zahar never spoke at that conference. 

I only have time for a few more examples. So I 

am going to have to ask you to rely on your memory for 

others, but let me give you some. I want to start with 

Shukri's trip to Palestine in 1991. The prosecution 

showed you a handwritten, unsigned, undated document that 

claimed to be a report about the Occupied Land Fund, that 

Shukri is currently making a trip to Palestine to discuss 

OLF's projects with people there. You kind of have to 

watch these things, and I'm not blaming this on anyone, 

but in their translations -- they are all typed up real 

nice, but you got to look at the original document to see 

what was it originally. For example, this one. It's just 

a handwritten document. It was found at Mr. El Barasse's 

house, not HLF. There is no evidence that Shukri ever 

knew about this document. Then Agent Burns showed you 

another one. She showed you a document found -- 

photographed in Mr. Ashqar's house. You remember they all 

have this front on them that says camera roll. And this 

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one, too, handwritten, by whom we don't know, photographed 

at Mr. Ashqar's house dated June 10th, 1991. It discusses 

a visit to Palestine from May 17th, 1991 to June 4th, and 

it specifically mentions HAMAS which is, of course, why 

they wanted you to see it. So they wanted to suggest that 

was about Shukri's report, and to bolster this false 

suggestion, the prosecution then showed you a customs 

form. They showed you this page, and they were hoping to 

link this visit. You see where it has coming through 

Charlotte Airport, and that was linked to these other 

reports. 

Now, here is what you have to keep in mind. 

Agent Burns. Agent Burns is sitting here because she's 

very interested in this case. It's the only case she has 

had in the FBI. She's been combing through the HLF 

records in the FBI for five years, since April of 2002. 

She knows what's there. She has combed through the 

subpoenas and bank records. So ask yourself why didn't 

she show you what she had, the receipt that showed you 

that Shukri was in England and not in Palestine in June of 

1991. 

There it is. Why didn't she show you that? Why 

didn't she show you Shukri's actual report of his 

Palestine visit one month later, July to August. That's 

the report that was in the Holy Land records. That's the 

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report that we had to find and show you. That's the 

report that in Arabic is all neatly typed up and has 

Shukri's name at the bottom of it. And that's the report 

that is consistent with the next trip coming back through 

New York, and that's the report that's consistent with 

staying at the Seven Arches Hotel in Jerusalem. She 

didn't show you any of that. She knew about it. But that 

report by Shukri talks about developing programs to 

provide charity for needy Palestinians. That doesn't say 

anything about HAMAS. So she and the prosecutors 

conveniently ignored it because it didn't support the 

theory that HAMAS was providing material support to 

HAMAS -- that Holy Land was providing material support to 

HAMAS. They hoped we wouldn't find it, and they hoped you 

wouldn't see it. That's just one instance of providing 

selected documents to leave a false and misleading 

impression, and it was during the period of time that's 

not even relevant to this indictment. Remember again, 

Shukri is only charged with the events that took place 

after HAMAS was designated as a terrorist organization, 

January 23rd, 1995. 

Now, let's talk about Philadelphia. Another 

significant example of a misleading rendition of the facts 

started with the translation that was wrong, that quoted 

Shukri as saying something he never said. You remember we 

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made this demonstrative. Agent Burns told you the 

government had lots of translators, and they worked very 

hard to make sure that everything was correct, but even 

though the FBI had a real time tape going in Philadelphia 

in 1993, they were listening while it was happening. By 

2007 in this courtroom they still had the Philadelphia 

meeting wrong until we pointed it out to the translator 

during the trial, and he had to change it. We had to 

point out that Shukri didn't say "We give the Islamists a 

hundred thousand, and we give others five thousand." What 

he said was "In the past, we gave the Islamists a hundred 

thousand, and we gave the others five thousand." And you 

know that the government thought the original false 

translation was important. Mr. Jacks said it in his 

opening statement. It was even in the indictment, and 

Burns testified about it and said it was a link to the 

five thousand dollars she claimed was what they gave in 

Oklahoma City after the bombing there in 1995. But once I 

pointed out the translation was wrong, they never 

mentioned it again. You never heard it again. The 

correct translation, however, is consistent with the rest 

of the Philadelphia conference in which Shukri talked the 

need to work with people and caring for the Palestinian 

people. We'll talk about that more. Agent Burns also 

said that two years after the meeting in Philadelphia Holy 

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Land sent five thousand dollars to the victims of Oklahoma 

City, and she drew this link. They said a hundred 

thousand and five thousand, and look, they gave five 

thousand dollars to Oklahoma, and she showed you

a five thousand dollar check to Oklahoma. But of course 

what she didn't show you that she had all along was a 

twenty-five hundred dollar check to the Red Cross for 

Oklahoma, April 19th, 1995. That's the day of the tragic 

bombing, and she didn't show you -- even though she knew 

and had it -- that Holy Land was thanked by the Feed the 

Children Program because they sent fifty volunteers to go 

and help people after the bombing. And she didn't tell 

you -- but she knew it -- that Holy Land paid for all of 

those people to go to Oklahoma. So they didn't spend five 

thousand dollars in Oklahoma. They spent over ten 

thousand dollars to go to Oklahoma, but that wasn't 

consistent with their theory. So they didn't tell you 

about that. We had to find those. 

Let me ask you who is it that's being deceptive 

here? Do you really trust the government? The 

translation was also wrong in another important respect. 

In two places on that page, one it said that Shukri said 

"Islamists" when he really said "Muslim." And in another 

place, it said Ghassan Elashi said "Islamists," and he 

really said "Muslim." We had to point that out to the 

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translator and get him to change that, too. Now, they did 

talk about Islamists at the Philadelphia meeting. No 

doubt about that. But doesn't the mistranslation show you 

something about the government's bias? Especially when 

the government's witnesses keep telling you over and over 

again that "Islamists" is the same as HAMAS. HAMAS, 

Islamists, Islamists, HAMAS, they say it's the same, 

except that it's just not true. Mr. Abington and 

Professor Brown both talked to you and Professor Brown is 

studying Islamism, and Mr. Abington was the senior 

representative of this government in Jerusalem and in 

other countries in the Middle East for thirty years. He 

knows a lot about Muslim countries. Mr. Abington defined 

an Islamist as a pious Muslim, and Professor Brown as a 

professor made a longer definition. He said an Islamist 

is a person who's dedicated to increasing the role of 

Islamic life in public or private life. 

When you review the transcripts of the 

Philadelphia meeting -- and I hope you will review them 

carefully -- you will see the majority of the speakers, 

including Shukri, are talking about Islamists in the sense 

that Dr. Brown and Mr. Abington did as Muslims seeking to 

increase the role of Islam in public life. That's the 

goal of Palestinians, people adhering to the Muslim faith 

will be permitted to -- not be permitted to live there and 

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practice their religion there and that it will be taken 

over by the secular PA, and that's a concern to them. But 

the government tries to convince you that all Islamists 

are HAMAS. Let me ask you this. Would Laura Bush, the 

President's wife -- do you think she would have met with a 

member of HAMAS and put that on the White House web site? 

Mr. Abington told you that this man who she met with is a 

leading Islamist in Palestine. And she went there, and 

she covered her head out of respect for where she was. 

This is someone the U.S. contacts regularly. The U.S. 

contacts Islamists because not all Islamists are HAMAS. 

Mr. Dratel will be talking more about Islamists 

and about how the government has also tried to merge the 

Muslim Brotherhood into HAMAS. But we know they are not 

the same because Mr. Abington and Professor Brown said the 

Muslim Brotherhood still exists in Palestine independently 

from HAMAS, and in fact, PA Chairman Yasser Arafat, who 

was the political rival of HAMAS and the leader of a 

secular, nonreligious party, was himself a member of the 

Muslim Brotherhood. No government witnesses contradicted 

any of this evidence. 

And there are a few other points about 

Philadelphia that are very important. This is a 

conference of people trying to find a way forward. It was 

a public place, a Marriott Hotel. They checked in using 

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their own names and credit cards. There was nothing about 

the meeting that was secret. It was clearly a turning 

point for HLF and Shukri, and that's something the 

government really doesn't want you to notice. The Oslo 

Accords had just been signed. No one knew what was going 

to happen next. The prosecution made a big point to 

Shukri's opposition to Oslo. 

Perhaps we should divert and talk about Oslo a 

little bit. But again the government presents selective 

information. The government's premise was HAMAS opposed 

Oslo. The men at the meeting opposed Oslo and Shukri 

opposed Oslo, and therefore, he must be HAMAS. Well, 

until we cross examined their witnesses and then 

Dr. Levitt had to admit that there are many Palestinians, 

including prominent Christian professors, who also oppose 

HAMAS, not just HAMAS, not just terrorist organizations, 

and we finally learned why they oppose Oslo. All Agent 

Burns wanted you to know is HAMAS opposed Oslo because 

HAMAS opposes Israel. Because HAMAS wants everything from 

the Jordan River to the Sea. And they do, but they didn't 

want you to know that Israel opposes Oslo because they 

want everything from the Sea to the River. And they 

didn't want you to know that other Palestinians opposed 

the Oslo Accords because they thought too much was given 

up. Remember Oslo carried out way to the end did not 

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permit for a Palestinian state. These people want a 

homeland. They wanted a homeland, and they didn't get it. 

All they got in Oslo -- All they got were the little bits 

on this map that are in dark. The little bits -- Jenin, 

Tulkarem, Nablus, the little tiny bits that are called 

Area A. That's all they got. So it's understandable that 

they would be disappointed. 

Benjamin Netanyahu, an Israeli who ran for prime 

minister and actually won, campaigned on a promise to get 

rid of Oslo. It had to be changed later, but that was his 

campaign compromise, and the settlers in the West Bank 

didn't like Oslo because they were afraid that Israel 

would give up the West Bank. Clearly opposition to Oslo 

does not make someone HAMAS. Lots of people opposed 

HAMAS, and support in the United States -- Although Mr. 

Jonas said there was support in the United States. Well, 

there may have been some, but there was a lot that wasn't. 

Edward Zeid was in the United States, and he didn't 

support Oslo, and he was a Christian professor at Colombia 

University. These are selective facts that create a false 

impression. They only want you to connect the feelings at 

Philadelphia to HAMAS. They don't want you to understand 

the reason for those feelings or why Palestinians felt the 

way they did. Once again, right here today Mr. Jonas 

again made some selective facts. I want you to look, and 

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perhaps you will have to look back in the room, but I will 

show you quickly 16-67. 

This is one part of the Philadelphia meeting, 

and I can put it on the Elmo here so that you can see it. 

But let me just tell you why it's significant. It's 

significant because an unknown person says -- You remember 

Mr. Jonas said they were talking about how they had a new 

organization. He says "In my opinion, we must form an 

organization for activism which will be neutral before we 

are placed in a corner." That's what he read. But he 

didn't read "This suggestion ought to be discussed. Of 

course, I do have some radical ideas. So that we have the 

opportunity to discuss them. Some of our approach to the 

policies in the area, nonopposition to peace is a 

statement. I mean, someone will ask you, tell him no. We 

are not opposed to peace for peace, but we are opposed to 

hypocrisy because this peace is not justice, that there is 

no justice without peace. No peace without justice. It 

is always a principal of peace with justice."

It's exactly on the same page where Mr. Jonas 

read to you, but he only read you a little part of it, not 

the rest of what this person said, and this wasn't even 

Shukri, but it's someone saying I threw out an idea here. 

This was a political meeting. And what did Shukri say? 

"There is all of this talk about SAMAH. My brother say 

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what you want to say. The door to politics is big. Did 

God tell you you must stand in front of the university and 

tell them we have to claim the 1948 land? It is just 

talk. This is an impossible address, my Brothers. It is 

not our goal to demand the '48 land. Even if we demanded, 

no one would return it to us." And he goes on, and what 

does he say after that? "SAMAH is classified as a 

terrorist by Constitution, by law. If I wanted to adopt 

its work, they would kick me out, take my citizenship. 

They tell me go away." He knows what the law is, and he's 

trying to follow the law. That's what this was about.

 There is another extremely important point, and maybe 

it's the point that's brought up there, and that's the 

First Amendment to the Constitution. Mr. Jonas said that 

no one can be convicted on the basis of what they say, but 

then he spent most of his time talking to you about what 

people say. This is what the Court will instruct you. 

The Amendment guarantees all persons in the United States 

the right to freedom of speech, freedom of religion, 

freedom of associations. Because of these Constitutional 

guarantees, no one can be convicted of a crime simply on 

the basis of his beliefs, his expression of those beliefs 

or his associations. Please remember that when you think 

about the meeting in Philadelphia. This involved 

Palestinian-Americans expressing opposition to a political 

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agreement they thought was unfair and trying to figure out 

how to move forward, and that's protected by the First 

Amendment. It's true that Shukri said "War is deception." 

He's not the first person to say that. It's come down to 

us through history. He's not the first person to say that 

politics is deception. You probably could find that in 

most newspapers every day. And he says, "This is 

political talk. Political talk. You have to separate 

from those actions." 

Additionally, one other instruction that's very 

important about Philadelphia. The mere fact that certain 

persons may have associated with each other and may have 

assembled together and discussed common aims and interests 

does not necessarily establish proof of the existence of a 

conspiracy. Please keep that in mind also when you think 

about the Philadelphia meeting. That happened, of course, 

two years before HAMAS was designated as a terrorist 

organization. Shukri made it very clear that Holy Land 

could not get caught up in the politics of the coming 

time, and if you look at 16-57 which is another part of 

the Philadelphia meeting, you will hear him say and read 

that he says that "I believe as a charity organization I 

should not give an opinion or a political judgment as all. 

I have no relationship with that. I'm not a political 

institution. I'm dealing now with a new reality. It is 

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not my job to attack the self-rule. Amicable relationship 

must be maintained with all parties. This goes without 

saying, my Brothers. We must not put any factual or 

partisan influence on the Foundation in America, and it 

cannot be the charitable arm of this or that. This is 

wrong. It can't cater to the interest of a specific 

party."

That's what he said, and that's what he did. He 

led Holy Land away from the politics that he worried would 

harm its ability to provide the food and school supplies 

and stoves and refrigerators to desperate people living 

under a harsh occupation, to refugees who have been in 

refugee camps for fifty years. You have heard about the 

harshness of this occupation and the government said well 

we just told you about Israel to distract you. Ladies and 

Gentlemen, we told you about Israel because that's the 

context that these people were living in and why they had 

to provide this charity. That was not a distraction. Not 

one witness, not one government witness, denied that the 

Palestinian people continued to live in dire poverty 

because Israel has not provided for them as it is supposed 

to provide for people it occupies. 

One month after the meeting in Philadelphia, 

there is a very important conversation that you have and 

it's at 16-57, the conversation where Mr. Ashqar, who you 

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have heard about, says "The problem is with the Fund," and 

he's talking about Holy Land. "They act on their own. 

They appoint and discharge by themselves and no one else." 

That's exactly what Shukri did. That's what he wanted. 

He took Holy Land out of politics. He said "We're an 

American charity. We're going to act in accordance with 

American law, and we're not going to break the law and 

we're not going to break the law because we want to 

provide this charity." And no one denies that they 

provided the charity. He did use the word "SAMAH." If 

you go through the Philadelphia meeting you will probably 

find they used HAMAS about the same number of times they 

used SAMAH. But there is another thing to remember. 

Shukri was born in Brazil which in those days was a 

military dictatorship, and he lived in Kuwait, not exactly 

a speech friendly place, and they were afraid of Israel. 

The intifada had been going on for five years by that 

time. Holy Land was working in the West Bank and Gaza, 

and you heard Mr. Abington say the Israelis would lock 

people up for flying a Palestinian flag. Ten thousand 

people are in jail, according to Mr. Abington, in 

administrative detention in Israel having never been 

charged with a crime. They were afraid of Israel. They 

were afraid. And yet it appears that we have become like 

those countries because now these words have come back to 

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haunt them, words they had a right to say, political 

expression that they had a right to give. Also, after 

HAMAS was designated a terrorist organization in 1995, 

there are another two calls that the government produced 

for you where Shukri used SAMAH, and in neither of them 

did he express any support for it. In the 1999 telephone 

call, the government introduced between Shukri and 

Abdulraham Odeh, Shukri told Odeh not to take money from 

someone named Deeb Anees because he raised money for 

SAMAH. Mr. Westfall will talk about this in more detail, 

but I want to point out that again the government tried to 

produce a false impression. They introduced documents 

through Miranda that show that Deeb Anees raised money for 

Holy Land after the designation. There was a list of 

names. And Agent Miranda said you see, He raised another 

seventy thousand dollars after that phone call where 

Shukri said don't take any of his money. But it wasn't 

true, and on cross Mr. Westfall and Mr. Dratel pointed out 

the list most likely reflected that he raised money for 

Holy Land only in 1996 and 1997 before that call. The 

payments were simply payments that came in after he 

called, things that were originally pledged during the 

fundraising event before that phone call. They introduced 

another version of the same document that made that clear, 

which Miranda said he had that call but they hadn't 

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offered that in evidence. 

There is another example, and Mr. Jonas brought 

it up briefly today. You remember that Avi said that Mr. 

Abu Aker was a money changer and then Agent Burns showed 

you some testimony, a summary she created. This summary. 

And they got so far as to tell you this money goes to this 

money changer, and gee, we can't address the funds once it 

gets there. That was not only selective but not truth, 

and the documents proving it was not truth have been in 

the FBI office for the last five years. So Agent Burns 

and these prosecutors knew that she could complete that 

summary all the way to the food for Palestinians, but they 

chose not to and left it to us to try to find the 

documents if we could, and fortunately we could. I know 

it was painstakingly tedious for you when I went through 

all the documents showing where all the money matched up, 

and I apologize for how tedious that was, but I needed to 

show you the information the prosecution had all along 

that Mr. Abu Aker was actually a vendor from whom Holy 

Land in Gaza bought food for Ramadan so that people who 

had no food would have something to break the fast during 

the Ramadan holiday, a holiday the Muslims are supporting 

this month, as we speak now. She could have showed the 

bid that Mr. Abu Aker provided Holy Land. She said she 

knew about those transfers. She didn't say she didn't. 

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Instead, she found a few select facts and presented them 

to you. And we had to present to you the bid. This was 

it in the Arabic. The report from the Holy Land Gaza 

Office. This was it in English, and in fact, the Holy 

Land files have a picture of that very project from 1999 

to 2000. That's a photo that they had in their possession 

for five years. They knew and Agent Burns had to admit 

after we introduced these documents that the payments to 

Abu Aker were consistent with the Ramadan food project and 

that she was aware of that project. 

Now, Mr. Abu Aker, there was also a check to him 

for $6,220. She didn't bother to address that one either. 

She just put it on her summary. But that one went 

directly to the Customs Office in Israel. There is the 

document. What was it for? Seven hundred twenty wheel 

chairs. Wheelchairs. These wheelchairs. That money 

didn't disappear. Wheelchairs, all with the Holy Land 

logo on them. Wheelchairs. 

And she identified this woman, Dalell Mohammed. 

This is the face of Holy Land Foundation, putting a child 

in a wheelchair. An uncovered woman in the West Bank 

putting a child in a wheelchair. The Holy Land manager in 

Gaza who distributed this food, Mohammed Abu Muharam, and 

this man was identified as the Minister of Health for the 

PA. They didn't want you to see that. They didn't want 

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you to see the work that Holy Land did. We had to find 

those documents for you. There was a second money 

changer -- they are really money exchangers -- Mr. 

Herzallah, and he owned a money-changing business, and in 

that part of the world people have to change money from 

dollars to shekels, and the government admitted that 

people had to change money and admitted that the Holy Land 

Office in Gaza could only get money in dollars and 

admitted reluctantly because it didn't help their case 

that they had seen records of orphans receiving the money 

in shekels. And when we walked through those financial 

documents, Agent Burns had to admit that the money trail 

from Texas to Gaza to Mr. Herzallah changed to shekels for 

the orphans was consistent with the documents. What 

reason is there to not show you these documents except to 

create a false impression and distract you from the fact 

that Holy Land provided food and charity and to lead you 

to believe that the money somehow disappeared. 

They also showed you a wire transfer to a Kamal 

Al Tamimi. In fact, they showed it to you twice. And 

they showed it to you so that Mr. Avi could say, oh, yeah, 

in my opinion he's HAMAS. See what it says: "For the 

families of Demolished Homes Projects." But they didn't 

show you anything about the demolished homes. In fact, 

you remember I asked Agent Burns, why does Israel demolish 

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homes? She said, "Well, they demolish the homes of 

terrorists. That's all I know." That's all she ever 

learned. It's convenient that she hasn't learned anything 

about the history of Israel or the conditions of 

Palestine. 

The former Consul General, Mr. Abington, knew 

about the demolishing of homes. He represented the 

government. He's retired, but he represented the 

government for thirty years. He doesn't have a dog in 

this fight. He came from Europe to testify without any 

fees because he wanted to make sure you got the full 

picture. He told you that only a small fraction of the 

houses that Israel demolishes are because they belong to 

terrorists. Most of them are because people don't have 

proper permits, but Israel won't give them proper permits, 

and people that have homes for generations are demolished, 

and sometimes they are on bypass roads that Israel wants 

to build to settlements. So they are just demolished. He 

even talked about where this sixteen thousand dollars 

went, that in Rafah which is at the border with Egypt that 

Israel decided it wanted to have a security corridor. So 

it went in and mowed down the houses. Nobody was 

compensated. Just left people destitute. The point is 

they only provided selective bits of information to give a 

false impression that only terrorists would have homes 

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demolished. They didn't want you to see the people whose 

houses and furniture and mementos and family photos were 

just turned into dust. All of these attempts by the 

government to present false evidence, misleading facts, 

incomplete situations should leave you with doubt about 

what happened, and any doubt you have a reason for is a 

reasonable doubt. We're going to talk more about that. 

But first I want to show you some of these 

pictures. Just a few. You have these if you look at the 

Power Point presentation. It's Defendant's Exhibit 1202. 

You will see all the pictures. Let me show you a few. 

This is a family living in a tent receiving food from Holy 

Land. This is the Holy Land delivering blankets, bedding. 

This is where people live. Who do you think lives here, 

has their laundry out here, an open sewer? This is where 

Holy Land was working. This is the reality of Gaza. And 

here is a family receiving just the things to survive, 

nothing more, just to survive. All of these selective 

facts, all of these things the government didn't want you 

to know. Think about that when you think about this 

instruction that the Judge will give you. "Reasonable 

doubt is a doubt based upon reason and common sense after 

careful and impartial consideration of all the evidence in 

the case. Proof beyond a reasonable doubt, therefore, is 

proof of such a convincing character that you would be 

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willing to rely on it and act upon it in the most 

important of your affairs."

Based upon the evidence that the government has 

put on, would you be willing to rely on it? Would you be 

willing to rely on that kind of evidence to have surgery 

or buy a house? I don't think so. Because if you 

hesitate at all, then you have a reasonable doubt, and 

Judge Fish will also instruct you that unless you are 

satisfied beyond a reasonable doubt that Shukri is guilty, 

the presumption of innocence alone is sufficient to find 

him not guilty. That's the presumption of innocence he 

came with, and he still has. 

We have more examples of misleading testimony. 

I'm kind of watching my time here. Several government 

witnesses discussed a man named Jamil Hammimi. They 

agreed he was one of the founders of HAMAS on the West 

Bank. Then things diverged. Levitt and Avi testified 

that he left HAMAS in 1996, but then Agent Miranda tried 

to get him designated as a terrorist in 2002 for the very 

purpose of assisting in this prosecution, and it appears 

the prosecution didn't include Avi in on the testimony 

because he said that Jamil Hammimi never left HAMAS. 

Today, Mr. Jonas said he left and then he came back, but 

there was no evidence of that. And none of them told you 

that the United States Government brought Mr. Hammimi 

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here, Sheikh Hammimi, in 1999 as a distinguished 

gentlemen. Do you remember this? It was early in the 

case. I'll just show you one document. The United States 

Information Service, that's Defendant's Exhibit 87, and 

you can see the ones behind it. We had to tell you that. 

We had to tell you that the United States State Department 

brought him here, and he toured all around the country as 

a distinguished gentlemen, and after I finally got this 

introduced, Agent Burns admitted, well, she had known 

about it for two years. They didn't tell you that. Who's 

being deceptive here? Who can you trust? There are a lot 

more examples, and I have to leave them to your memories 

because I need to turn to another subject. 

You have heard a lot of evidence about the 

United States Treasury's list of specially designated 

terrorists, and Mr. Jonas talked about specially 

designated terrorists. Two versions of that list are now 

in evidence, the list as it existed June 29, 2001 which is 

about two weeks after the last transaction charged in the 

indictment. That's this one, Defendant's Exhibit 963. 

And then there is the current list. That's even bigger, 

Defendant's Exhibit 1111. You have heard from several 

witnesses. To this day, the United States Government has 

never designated a single one of the Zakat Committees or 

charitable societies as a terrorist organization. So why 

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are these lists such crucial pieces of evidence? Because 

they are how the United States tells its citizens and the 

world who it considers to support terrorism. That's how 

the United States Government tells businesses and 

charities and everyone else who you can no longer deal 

with. You remember during the cross examination of Avi 

during, the cross examination of Miranda, the United 

States Treasury Department -- you remember hearing that 

the United States Treasury Department recently designated 

a charitable organization in Gaza call Al Saleh, and at 

the same time they designated its director, a man named 

Ahmed Al Kurd, and there is a press release. This is the 

press release, and it's very tiny writing. You can look 

at it. It's Defendant's Exhibit 1052, and it says "Today 

the U.S. Treasury Department designated the Al Saleh 

Society. HAMAS has used Al Saleh Society, as it has other 

charities, to finance its terrorist agenda. Today's 

action alerts the world to the true nature of Al Saleh and 

cuts it off from the U.S. financial system." That's what 

the Treasury Department does when it doesn't want you to 

work with something anymore. Think about it. OFAC, the 

Office of Foreign Assets Control, that's the office in the 

Treasury that does those things, alerts the world and 

tells them someone is a terrorist. That's how the 

government can cut off the finances from it. 

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So back to what I said a minute ago, not a 

single one of the Zakat Committees and charitable 

societies named in this indictment has ever been 

designated a terrorist organization. In fact, none of the 

ones discussed in this case with the exception of Al 

Saleh, which was designated last month, has ever been put 

on that list. That means the Treasury Department never 

told the world that it considered these Zakat Committees 

and charitable societies to be part of HAMAS, and you'll 

have these lists, and you can look at them. All the 

government had to do was to cut them off -- to tell Holy 

Land they couldn't do business with them -- was to put 

them on the list, but it never did, even though it 

designated Al Saleh, InterPal in England, CVSP, Sanabil, 

Al-Aqsa and even HLF, and the government can't say, Well, 

we didn't know, We didn't know that HLF was giving to 

these charities, because they knew back in 1993. Remember 

they were listening to the Philadelphia conference, and 

Mr. Jonas just reminded you that they talked about the 

Zakat Committees. They mentioned the Tulkarem Zakat 

Committee was going to get a hospital in 1993. So they 

knew about it then. And that's just the beginning. The 

FBI had wire taps on HLF's phones 24/7. They had wire 

taps on Shukri's home phone. They had wire taps on 

El-Mezain's home phone. They even bugged the Holy Land 

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office so that they could hear people chatter inside. So 

they were able also -- Because the phones were tapped they 

could read the faxes because the faxes come through the 

phone line. I have never understood quite how but somehow 

the papers go through and come out on the other end. And 

they come out at the FBI office, and they could read this 

and the e-mail. Among the calls were calls from Haitham 

Maghawri requesting transfer of monies to the Zakat 

Committees, and some of the requests were faxes, and they 

went to the very same Zakat Committees we talked about. 

So they knew where the money was going and knew it all 

along, and that was ten years before these people were 

charged in this case. 

There is a good reason they never put them on 

the list, and that's because they are not part of HAMAS 

and not controlled by HAMAS. So how do we know that? 

Think back to the testimony of Edward Abington. He was 

the United States Consul General in Jerusalem from 1993 to 

1997. He received briefings from the CIA every morning. 

The CIA is our spy agency. That's what they do. They spy 

for us, and they collect intelligence, and he had access 

through the CIA to all the intelligence the United States 

collects. And he also had access to what we call open 

source information -- newspapers, internet, television, 

which we can all look at, but the CIA studies, too, and he 

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had access to what the Israeli intelligence told the CIA 

which means whatever information Avi and his government 

had, but that's not all. He dealt regularly with the 

Palestinian Authority -- that was his job -- with Chairman 

Yasser Arafat, and he speaks Arabic, unlike Dr. Levitt. 

So Mr. Abington traveled around the West Bank and Gaza and 

talked to Palestinians, and that was part of his job. 

America wants to know what's going in the country where it 

sends its representatives. He visited the Zakat 

Committees. He visited Hebron, Bethlehem, Ramallah, 

Nablus, Tulkarem, Qalqilla, Gaza, and the hospital in 

Jenin. With all of those resources available to him, no 

one told him that the Zakat Committees and charitable 

societies that we're talking about here were part of 

HAMAS. It was important for him to know because he was 

forbidden from dealing with HAMAS because America and the 

State Department said you can't deal with HAMAS. So you 

need to know. After he left the State Department, he 

worked for the Palestinian Authority which opposes HAMAS 

and opposed it when it was controlled by FATAH, and it was 

FATAH he worked for, and those officials had every reason 

and incentive to tell him anything bad about HAMAS because 

they were fighting with HAMAS. But no one ever told him 

that the Zakat Committees and charitable societies that 

Holy Land worked with were controlled by HAMAS. Nobody. 

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Ever. 

You heard from Dr. Brown last week. You heard 

from him that the Palestinian Authority just last week 

which is now FATAH again on the West Bank closed a hundred 

three charities in the West Bank. Not one of the 

charities that they closed was one of the ones on this 

list. Mr. Abington was about as credible a witness as you 

will ever get. He was a senior representative of the 

United States Government, but unlike these prosecutors and 

these FBI agents, he has no dog in this fight. He hates 

HAMAS. He has no reason to favor of the defense. He 

wasn't even getting paid. He didn't have to come here and 

represent these Muslim men on trial for terrorism, but he 

came here, and he came here to tell you that he didn't 

consider the Zakat Committees to be part of HAMAS or 

controlled by HAMAS because he wanted to make sure you got 

the whole true story. Unlike Levitt and Burns and Miranda 

and Avi, Ed Abington has actually spoken to many 

Palestinians, and he has never heard anyone give HAMAS 

credit for the services they received from the Zakat 

Committees. The government didn't even challenge his 

testimony because it could not. 

Keep in mind also that Levitt has visited one 

Zakat Committee but not one in this indictment. Burns, 

Miranda and Avi have never set foot inside a single Zakat 

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Committee. Not one of them told you that they had spoken 

to a single Palestinian about the reputation of these 

committees or charities. But Mr. Abington wasn't the only 

one in the United States Government who doesn't consider 

Zakat Committees to be part of HAMAS. 

Remember the documents from the U.S. Agency for 

International Development. That agency, USAID, actually 

give material support to Al Razi Hospital which the Jenin 

Zakat Committee ran, and did so ten years after Avi claims 

it was already HAMAS. And they have a press release. 

They were proud of it. August 26, 2002. USAID provided 

supplies to Al Razi Hospital, the United States 

Government, 2002, and they also -- And you have these 

documents. Defendant's Exhibits 1010 and 1076. They 

actually vetted these committees, cleared them, checked 

them, said it's okay to work with Tulkarem and Qalqilla, 

and in fact, charities worked with USAID including CAIR, 

C-A-I-R, sent money to the Nablus Zakat Committee. The 

government has never contradicted that evidence because 

they can't. 

And think about Dr. Brown, who's a professor for 

George Washington University. He has devoted his entire 

professional life to studying Palestinian civil society 

and Islam. He visited to two Zakat Committees. Talked to 

their directors, talked to Palestinian scholars. And he, 

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too, speaks and reads and writes Arabic, and he, like Mr. 

Abington, doesn't have an axe to grind. No dog in this 

fight. He didn't allow us to pay him because he wanted to 

make sure he was impartial. He put his reputation on the 

line to come in and testify on behalf of these men who 

were charged with terrorism. But he told you clearly the 

Zakat Committees and charitable societies are not part of 

HAMAS, are not controlled by HAMAS, and no Palestinian he 

talked to ever told him otherwise. He even discussed the 

conversation he had with the Director of the Ramallah 

Zakat Committee, and you remember he said the guy had a 

moustache and no beard and he had never seen anyone in 

HAMAS look like that, and the director told Professor 

Brown, "Whatever politics you have outside this committee, 

you leave at the door." The government didn't challenge 

that evidence either because it can't. So it's no 

surprise that the Zakat Committees and the charitable 

societies in the indictment aren't on the specially 

designated terrorist list. They are not there because 

they are not part of HAMAS, not controlled by HAMAS and 

they don't act on behalf of HAMAS. 

So how does the government explain why they are 

not on the list? Well, you heard Dr. Levitt give some 

reasons, and you heard Mr. Jonas talk about it. But none 

of them make sense. The first reason Dr. Levitt gave you: 

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DEFENDANT ABU BAKER CLOSING ARGUMENT 143

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There is not enough time in the day to designate as a 

terrorist everyone that needs to be designated. Take a 

look at Defendant's Exhibit 1111. This is the current 

list. It contains thousands of names. It's little tiny 

print. I'll just put one page up here. Look at all of 

those names on one page. When you can go through -- And 

you'll have it at your leisure to look at. Don't you 

think if these Zakat Committees were controlled by HAMAS 

or controlled by the HAMAS wing, as the government claims, 

that they could have found time to designate at least one 

of them? There is another problem with Dr. Levitt's 

not-enough-time-in-the-day argument. Why couldn't the 

State Department at least have told John Bryant, the 

former congressman that represented Holy Land, that it 

considered the Zakat Committees to be part of HAMAS. It 

might not have been as official as a formal designation, 

but it would have had the same affect. 

You heard the phone call, and you will have it 

with you where Shukri said he wanted to see the list. 

This is 13-83. It was right when the list came out in 

1997. He said "I need to see the list so I know who we 

can't give money to." That call is very important, and I 

hope you will look at it when you get back in the 

juryroom. It's dated April 23rd, 1996. So the FBI knew 

about that call in 1996 because, of course, they taped it. 

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DEFENDANT ABU BAKER CLOSING ARGUMENT 144

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Shukri was talking to Ghassan Elashi, and he said "You 

have to abide by the law." Why did they have this? Why 

did they know about it? Because they were worried about 

it. They wanted to make sure. They knew about what was 

going on in Israel and Palestinian and they wanted to make 

sure that they stayed on the right side of the law. 

Judge Fish will also instruct you another very 

important instruction. Keep in mind when you are thinking 

about this, and that's the definition of the word 

"willfully." The government has to convince you beyond a 

reasonable doubt that Shukri acted willfully. "Willfully 

means to act voluntarily and purposefully with a specific 

intent to do something the law forbids with a bad purpose 

to disobey or disregard the law."

When you go back to the juryroom and try to 

figure out whether the government has proven beyond a 

reasonable doubt that Shukri acted willfully, read the 

transcript of this telephone call, 13-83, because it shows 

Shukri had no intention to disregard the law. He wanted 

and intended to obey it. That's why they hired a former 

congressman to go to the government and say just tell us 

what to do, tell us what to do differently. We hear these 

reports in the press. What is it? Was it Israel? We 

don't know. Mr. Abington got in trouble for saying that 

Israel was building settlements that they didn't need 

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DEFENDANT ABU BAKER CLOSING ARGUMENT 145

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because he thought they were trying to just take over 

ideologically the West Bank. He didn't get in trouble 

because it wasn't true. He got in trouble because it 

interfered with the U.S. relationship with Israel for 

people to know that. 

Shukri was waiting to see this list so that he 

would know which organizations he could and which 

organizations he could not transfer money to so that he 

could continue to assist the people of Palestinian. And 

since the FBI was tapping his calls if the U.S. Government 

wanted to stop Holy Land, all it had to do was put the 

Zakat Committees on the list, but it never did that. It 

never told Congressman Bryant or Shukri to stop working. 

Dr. Levitt had a second explanation for why the Zakat 

Committees aren't on the list, but that's as weak as the 

first. He says sometimes the government doesn't designate 

a person to avoid interfering with an investigation. What 

that means is the government, at least the FBI, sometimes 

tries to manipulate the designation process to help 

prosecute someone, and in fact, Agent Miranda attempted to 

do just that in this case. He admitted that in March of 

2002, he asked his fellow agent in Washington, D.C., to 

try to get Khalil Mishal, Jamil Hammimi and some other 

people designated as terrorists to assist in this pending 

investigation. The Treasury Department did designate Mr. 

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DEFENDANT ABU BAKER CLOSING ARGUMENT 146

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Mishal, and in the trial in this case, the government used 

that because every time they refer to Khalil Mishal, they 

didn't say Khalil Mishal; they said Specially Designated 

Terrorist Khalil Mishal over and over. So we know the FBI 

tries to manipulate the terrorist designation process to 

help prosecute people, but does that explain why the 

committees aren't on the list? It really doesn't. It 

might explain why they left them off the list before they 

closed Holy Land. Although that seems unfair, the FBI may 

have wanted to lull Holy Land into doing business so that 

it could prosecute its officers later as it's doing now, 

but that doesn't explain why it didn't put the Zakat 

Committees on the list after they closed Holy Land. 

Remember, Holy Land was closed in 2001. It's now 2007. 

Imagine how much stronger the government's case would be 

if they could refer to the Ramallah Zakat Committee as 

Specially Designated Terrorist Ramallah Zakat Committee. 

Don't you think if it really thought the Ramallah Zakat 

Committee was HAMAS that it would want to notify other 

American charities not to deal with it? But it hasn't 

done that. 

Dr. Levitt's third reason was another one that 

Mr. Jonas raised. He said well there is no need to 

designate them separately because they are already 

included in the designation of HAMAS. That argument has 

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DEFENDANT ABU BAKER CLOSING ARGUMENT 147

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two big holes. The first one is the Treasury Department 

has designated a whole bunch of organizations that Mr. Avi 

claims are part of HAMAS -- INTERPAL, CVSP, Sanabil, 

Al-Aqsa and Holy Land Foundation. And now it just 

designated Al Saleh, even though it says they are all 

controlled by HAMAS. So if they are all part of HAMAS, as 

he told you they were, there is no need for the Treasury 

Department to designate them separately, but they did. 

The Director of OFAC explained why they designated 

separately. To use their own words, "Because it alerts 

the world to the organization's true nature and cuts them 

off from the financial system." That's how it tells 

people not to do business with them. 

There is another big hole in everything included 

in this HAMAS argument, and that's Executive Order 12947, 

and that's really important. And you'll have this, also. 

It looks like this so that you can find it. And on the 

second page, it says -- It authorizes the Secretary of 

Treasury and the Attorney General and the Secretary of 

State to designate any person or organization it 

determines is owned or controlled by or acts for or on 

behalf of a designated organization like HAMAS. So once 

HAMAS was designated, the Treasury Department is supposed 

to use this part of the President's Executive Order to 

designate all the organizations that are controlled by 

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HAMAS or act on behalf of HAMAS. That's how it alerts the 

world to their true nature. That's how it keeps people 

from funding them, and that's what the Treasury Department 

does. That's what it just did with Al Saleh. That's what 

it did with Al-Aqsa and etcetera. So Dr. Levitt is 

frankly wrong when he told you that designating HAMAS is 

the same thing as designating the Zakat Committees. 

And you know something interesting? Dr. Levitt 

knows the importance of the designation process. You 

remember when I questioned him about why he was willing to 

appear on Arab television station Al Jazeera and my 

question was like, Well, Al Jazeera is an Arabic language 

station, and it has programs and been known to report some 

things from terrorists, and I asked him, I said, "Well, 

why are you willing to appear on Al Jazeera, even though 

the Israeli government has accused of it of fomenting 

terrorism?" What was his answer? "It's not designated." 

He was quick to justify appearing on Al Jazeera, and he 

said "I don't agree with anything they say, of course, but 

I get on there to debate with them, and it's not 

designated so it's okay."

Now, the same thing when Congress asked the 

Director of USAID why USAID continues to work with the 

Islamic University of Gaza. Look at 1008. This is what 

it looks like. It's a transcript of a Congressional 

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DEFENDANT ABU BAKER CLOSING ARGUMENT 149

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hearing. They said, Well, how come you are continuing, 

USAID, to work with these organizations? And Congress is 

worried about that. And they said they are not 

designated, and if they are not designated according to 

OFAC's -- We assume we can continue to work with them. 

Same answer Dr. Levitt gave when I asked him why he would 

appear on Al Jazeera: Because it's not designated. To 

this very day the Treasury Department has never alerted 

the world that it considers the Zakat Committees to be 

controlled by HAMAS and not charitable organizations. 

But these prosecutors want you to act as if they 

had been designated. They want you to ignore reality. 

They want you to rely on Avi instead of the designation 

list. Avi testified as a representative of Israel, the 

very government that occupies Palestine. The very 

government that deports people without charges, demolishes 

homes, etcetera. That's who they want you to rely on. It 

seems the ISA, the organization that Avi works for, the 

organization that inters people without charges for years. 

And the Government of Israel makes little distinction 

between who's a terrorist and who's just a Palestinian 

seeking to return to his homeland or seeking to help his 

people survive. Avi did the same thing that the 

government did here. He brought a handful of items from 

the tens of thousands that Israelis collected during 

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Operation Defensive Shield and the later military 

operations. All way after Holy Land closed, by the way. 

He like, Agent Burns, only showed you that which supported 

the conclusion that they were HAMAS. He didn't bring you 

the FATAH posters that Mr. Abington said he saw on the 

walls of Zakat Committees when he visited or the pictures 

of Yasser Arafat who opposed HAMAS and Mr. Abington said 

he saw on the walls of Zakat Committee when he visited. 

We were able to find documents from the Holy Land files 

that the government didn't want you to see. We don't have 

any way to bring you the documents, posters, pictures from 

the Zakat Committee that the Government of Israel didn't 

want you to see. And you recall the U.S. -- what the U.S. 

government thinks about Israel intelligence, that's it's 

not reliable. Ed Abington testified that Israelis have an 

agenda in terms of trying to influence the thinking of 

U.S. policy makers. They apply intelligence in a 

selective fashion. He also said the U.S. government does 

not accept Israeli intelligence at face value. The 

government never challenged this. 

Judge Fish will give you another instruction on 

how to determine the credibility or honesty of the 

witness. Did the witness have a particular reason not to 

tell the truth or a personal interest in the outcome or a 

relationship with a government? How can you rely on 

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anything Avi said here knowing that the branch of the 

United States Government in charge of intelligence does 

not -- is not willing to accept Israeli intelligence at 

face value. How can you find Shukri Abu Baker guilty 

beyond a reasonable doubt based on that kind of evidence? 

Avi claims that he knew the Zakat Committees were 

HAMAS-controlled as early as 1991, the whole time that the 

FBI was wiretapping Holy Land. Don't you know -- Don't 

you know if the FBI thought there was a serious threat to 

national security that this money from Holy Land was going 

to support terrorism, it would have done something about 

it? It was listening from 1993. 

The government made a big point of showing you 

that HAMAS started suicide bombings in 1994 and even told 

you some American citizens who happened to be in Israel 

were killed. Don't you know that the FBI -- if the FBI 

thought Holy Land money was going to the same terrorist 

organization that was killing innocent civilians, they 

would have done something about it? Why didn't they? 

Because the Holy Land money was going to legitimate 

charities and desperately poor people, not to HAMAS. They 

didn't designate these committees because they didn't have 

the evidence to designate them, even though the standard 

for designating someone a terrorist is simply reasonable 

cause, reasonable cause, a very low standard of proof. 

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They don't have to go in front of a judge or court to 

designate, and they couldn't even do that. 

You may remember the end of the government's 

case, one of the prosecutors stood up and read the 

designation of Holy Land as a specially designated 

terrorist, and I doubt that it came as a surprise to you 

that the Holy Land was designated, but there a couple of 

points about that that I want to point out to you. If you 

will take a close look at that -- I don't seem to have 

that one here. But it's Government's Exhibit 11-5. You 

will notice the Treasury Department designated Holy Land 

because it found reasonable cause to believe that Holy 

Land had been determined to meet the criteria of the 

Executive Order. Now for you to find Shukri guilty of 

crimes charged, you have to find that the government 

proved its case beyond a reasonable doubt. The difference 

between reasonable cause and proof beyond a reasonable 

doubt is huge. Proof beyond a reasonable doubt, as we 

have talked about, "is proof so convincing that you would 

rely on it and act without hesitation in the most 

important of your own affairs." Without hesitation. 

Think about that. It's the highest standard we have in 

the law. Reasonable cause, on the other hand, as I say, 

doesn't require a trial or even a judge. 

I want to make another point. There is also a 

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stipulation in this case. It's Court Exhibit 9. That's 

an agreement between the prosecution and the defendant. 

And this is an agreement which says that none of the 

individual defendants on trial here has ever been 

designated. To this very day, not a single one of these 

men -- not Shukri or any of the others -- has ever been 

designated and put on the Treasury Department's list. 

None of them appear on this list, with thousands and 

thousands of people on it. To this very day the Treasury 

Department has not even found the very low standard of 

reasonable cause to determine that Shukri meets the 

requirements to be designated as a terrorist. 

Now, I expect that Mr. Garrett will get up 

tomorrow or perhaps Wednesday and say, Well, the failure 

to designate them doesn't mean anything because the 

designation of Holy Land made it unnecessary to designate 

them individually. But that's not true. The Treasury 

Department designated HAMAS, and then it designated key 

HAMAS officials -- Sheikh Yassin, Khalil Mishal, Mousa Abu 

Marzook and several others. The Treasury Department 

designated the Al Saleh Society and then designated its 

director at the same time. If you flip through this 

document, Defendant's Exhibit 1111, you will see the 

Treasury Department has designated hundreds and hundreds 

of individuals. That means the Treasury Department when 

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it has reasonable cause to designate both an organization 

and its director and officers, that's what it does. It 

doesn't just designate the organization and then give the 

officers a pass. The fact that it didn't designate Shukri 

and these other gentlemen means only one thing. It didn't 

have the evidence to designate, and if the Treasury 

Department couldn't find enough evidence to meet the very 

low standard of reasonable cause for Shukri, you can be 

sure there is not enough evidence to get you to the very 

high standard of proof beyond a reasonable doubt. 

One more point and this is important. If you 

find Shukri not guilty of providing material support to 

HAMAS, you must find him not guilty on the tax and money 

laundering counts because those charges all rely on the 

same theory. 

Ladies and Gentlemen, you have been very patient 

with me, and I thank you. After all the defense lawyers 

speak to you, the prosecutors will get to argue one more 

time, and that's because this very high burden remains on 

them, remains right here on this table. That's where it 

is now, and that's where it was, and that's where it 

remains. And it remains with them to prove each and every 

element of every crime. You know where the doubts are. I 

have tried to show you some, and you have heard the 

others. You have heard that not even the United States 

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Government will accept Israeli intelligence at face value 

and that all of this really comes back to Avi. Miranda 

and Burns relied on Avi, and Levitt relied on Israeli 

sources. So that's really where this all comes from. You 

have heard the prosecution agree that Shukri has never 

been designated and stipulated to that. I'm asking you to 

focus on the proof and the doubt that you know exists. 

Don't permit Mr. Garrett when he stands up to wrap himself 

up in the American flag and appeal to your emotions. You 

have to wrap yourselves in the American flag. You have to 

make certain that this trial is decided fairly and on all 

the facts, not just selective facts. This case has to be 

decided on what you know is certain now about what they 

tried to prove. If anything, one thing, makes you 

hesitate about the prosecution's evidence, that's all the 

doubt you need to find Shukri not guilty. Make sure, 

please, that in the private place you go, when you make 

the most important decisions in your life, make sure that 

the prosecution has removed every single reasonable doubt 

you have. You don't have to explain or justify your 

doubt, and no one should try to talk you out of it. If 

you have a doubt, even if you can't put it into words, if 

you have a doubt -- it only takes one -- then the law 

requires you to hold onto it and let that be your verdict. 

The American justice system is what sets us 

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apart from other countries. It's the foundation on which 

this country was created and what we all hold so dear. 

Your part, holding the prosecution to that high burden is 

the most important part in the entire criminal justice 

system because it gives all of us the assurance that no 

one will be convicted of a crime just because the 

government wants to see that happen. 

I know, Ladies and Gentlemen, that you have all 

listened carefully, and again, I thank you for that and 

Shukri Abu Baker thanks you for that. I know you will 

weigh the evidence carefully, and I know that after you do 

that you will come to the only conclusion that is just and 

the only conclusion that is fair and the only conclusion 

that upholds the American justice system, and that is that 

you will find Shukri Abu Baker not guilty. Thank you. 

Thank you, your Honor. 

THE COURT: Ladies and Gentlemen, I have told 

you earlier that I wanted insofar as possible not to 

interrupt the presentation of any of these counsel during 

the closing argument. So I think this would be a good 

time to take our overnight recess so that we don't go into 

the presentation of the next counsel who will argue. 

While we're apart this evening please continue 

to observe the instructions I have given you regarding 

your conduct as jurors. We'll be in recess until nine 

CASSIDI L. CASEY, CSR, 214-354-3139

UNITED STATES DISTRICT COURT

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o'clock tomorrow morning. 

(Jury out)

THE COURT: Ladies and Gentlemen, Ms. Hollander 

stayed within her allocated one and a half hours. So I 

think we're on schedule for the time limits agreed upon by 

the defense. 

One other housekeeping matter I wanted to check 

about is what progress has been made in ascertaining what 

documents or other tangible things were admitted into the 

record during the trial. I understood when we were 

together last week that was an ongoing process, but I 

haven't heard any updates. 

MS. DUNCAN: Your Honor, I met with Mr. Jacks, 

and we went through the exhibit list, and we have agreed 

on almost all the exhibits, and my understanding Mr. Jacks 

sent an e-mail to Ms. Casey to look at the record to see 

if those exhibits were admitted. 

THE COURT: Ms. Casey says according to her 

there is no dispute. She apparently sent an e-mail. 

Counsel for the government have anything? 

MR. GARRETT: The only thing I would bring to 

your attention on this jury instruction, Mr. Cline and I 

are going to meet after court today to see if we can come 

to an agreement about that and have it to you no later 

than first thing in the morning. 

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UNITED STATES DISTRICT COURT

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THE COURT: Okay. Anything from the defense? 

MS. MORENO: No thank you, your Honor. 

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I N D E X

Arguments Page

Government..........................................6

Defendant Abu Baker...............................104

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UNITED STATES DISTRICT COURT

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C E R T I F I C A T I O N

I, Cassidi L. Casey, certify that during the 

proceedings of the foregoing-styled and -numbered cause, I 

was the official reporter and took in stenotypy such 

proceedings and have transcribed the same as shown by the 

above and foregoing Pages 1 through 161 and that said 

transcript is true and correct.

I further certify that the transcript fees and format 

comply with those prescribed by the court and the Judicial 

Conference of the United States.

s/Cassidi L. Casey

________________________________

CASSIDI L. CASEY

UNITED STATES DISTRICT REPORTER

NORTHERN DISTRICT OF TEXAS

DALLAS DIVSION

LICENSE NUMBER 1703

CASSIDI L. CASEY, CSR, 214-354-3139

UNITED STATES DISTRICT COURT

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< A >

AARON 2:4

Abdallah 64:22, 65:2, 65:4, 

66:22, 69:14

Abdel 65:23, 82:9, 90:20

Abdulqader 2:11, 7:25, 19:6, 

31:17, 48:17, 48:20, 48:23, 

49:17, 49:19, 50:3, 50:9, 

51:12, 52:6, 57:16, 57:17, 

58:11, 58:25, 59:12, 59:21, 

62:20, 70:5, 88:16

Abdulraham 7:24, 19:7, 

44:6, 45:20, 67:19, 68:5, 

99:19, 99:24, 129:8

abhor 101:10

abhors 43:24, 44:1

abide 145:2

ability 127:10

Abington 74:15, 75:10, 

84:15, 92:14, 105:4, 120:8, 

120:10, 120:13, 120:22, 

121:7, 121:15, 128:19, 

128:21, 133:6, 139:17, 140:6, 

141:7, 141:18, 142:3, 143:2, 

145:24, 151:5, 151:7, 151:15

able 23:2, 100:22, 139:2, 

151:9

above 71:16, 161:7

Absolutely 26:19, 35:12, 

96:24

accept 5:14, 43:20, 151:19, 

152:3, 156:1

acceptable 50:22

access 75:17, 139:21, 

139:23, 140:1

accident 10:18

accompanying 14:21

Accord 34:16, 35:4

accordance 128:6

According 45:14, 90:9, 

105:1, 105:10, 128:21, 150:4, 

158:18

Accords 12:25, 33:19, 33:21, 

33:22, 34:3, 34:5, 34:7, 34:8, 

34:15, 35:8, 36:4, 36:7, 

45:11, 61:23, 99:15, 122:5, 

122:24

account 41:22, 41:23, 41:24, 

78:20, 78:21, 78:21

accountant 26:17, 39:19

accounts 70:16

accurately 111:14

accused 96:3, 149:16

achieve 99:8

achieving 16:16

acid 62:13

acknowledging 36:12, 

59:14, 90:6

acronym 39:8

across 21:12, 27:14

act 8:11, 15:12, 30:15, 40:17, 

53:6, 113:22, 128:2, 128:6, 

135:1, 143:21, 145:12, 149:1, 

150:11, 153:20

acted 145:11, 145:17

Action 22:14, 22:23, 23:12, 

23:17, 23:22, 24:1, 27:3, 

30:13, 30:15, 37:21, 39:15, 

45:4, 60:16, 60:18, 61:9, 

61:10, 137:18

actions. 126:9

activism 36:24, 124:9

activities 22:25, 44:23, 

72:22, 92:9

acts 11:14, 14:2, 15:7, 29:1, 

35:23, 52:10, 62:11, 93:20, 

105:23, 106:13, 106:15, 

109:20, 148:21

actual 110:18, 116:23

actually 4:23, 41:19, 41:23, 

76:16, 79:10, 106:2, 106:5, 

107:8, 108:21, 114:6, 114:13, 

123:9, 130:19, 141:18, 142:7, 

142:15

ad 66:22

add 107:19, 111:10

addition 24:21, 106:17

Additionally 126:10

address 68:10, 113:11, 

125:4, 130:7, 131:12

adhering 120:24

Administrative 26:24, 

128:22

admit 114:19, 122:14, 131:7, 

132:12

admitted 114:11, 132:6, 

132:7, 132:9, 136:9, 146:21, 

158:9, 158:17

admonishing 33:4

adopt 125:8

ads 66:25

adult 45:12

advance 22:22

advantage 99:5

advertised 111:24

advisory 110:13

affairs 22:9

affairs. 135:2, 153:21

affect 144:17

affects 34:16

affiliated 73:5, 92:1, 93:3

affiliation 97:21

afraid 34:19, 111:16, 111:20, 

112:6, 123:12, 128:16, 

128:23, 128:24

After 6:16, 11:16, 24:16, 

34:8, 35:8, 36:4, 37:15, 

37:20, 45:11, 48:8, 63:11, 

65:12, 74:20, 81:23, 109:20, 

117:20, 118:18, 118:25, 

119:12, 125:7, 127:23, 129:2, 

129:14, 129:16, 129:21, 

131:8, 134:22, 136:8, 136:19, 

140:18, 142:9, 147:13, 151:2, 

155:17, 157:11, 158:23

afternoon 77:23, 103:25, 

109:22

against 33:6, 33:8, 34:2, 

34:5, 35:11, 35:22, 35:25, 

36:5, 36:9, 44:19, 62:11

Agency 104:25, 139:20, 

142:6, 142:7

Agenda 31:1, 37:14, 137:17, 

151:16

agendas 33:19

Agent 54:19, 60:4, 60:13, 

66:25, 79:4, 114:11, 115:22, 

116:13, 116:13, 118:1, 

118:24, 122:17, 129:15, 

130:4, 130:10, 131:7, 132:12, 

132:25, 135:18, 136:9, 

146:20, 146:22, 151:3

agents 141:10

Agha 42:1, 42:2, 42:5

ago 9:1, 31:12, 37:24, 64:24, 

65:3, 91:9, 138:1

agree 77:12, 100:11, 149:19, 

156:5

agreed 76:14, 98:8, 103:17, 

135:16, 158:5, 158:14

CASSIDI L. CASEY, CSR, 214-354-3139

UNITED STATES DISTRICT COURT

162
agreement 24:17, 34:24, 

98:9, 98:11, 99:12, 99:15, 

99:15, 126:1, 154:2, 154:3, 

158:24

agreements 34:22

ahead 46:5, 49:14, 76:21, 

76:24, 77:24

Ahmad 10:7, 10:8, 27:13, 

30:23, 32:8, 37:5, 39:21, 

40:1, 40:4, 100:9, 100:13

Ahmed 39:24, 137:12

aid 73:17, 104:11, 104:12, 

104:14, 109:11, 109:12

aided 99:5

aims 126:13

Airport 116:10

Aker 130:4, 130:19, 130:24, 

131:9, 131:11

Al 1:11, 13:21, 42:1, 42:2, 

42:5, 132:20, 137:10, 137:12, 

137:15, 137:16, 137:18, 

138:5, 138:14, 142:8, 142:12, 

148:5, 149:4, 149:11, 149:12, 

149:15, 149:18, 150:7, 

154:21

Al-aqsa 37:24, 38:3, 72:14, 

138:15, 148:4, 149:5

Alami 43:8

Albright 34:10

Albuquerque 1:46

alerted 150:8

alerts 137:18, 137:23, 

148:10, 149:1

align 29:4

Alikum 67:20

alleged 113:22

allocated 4:15, 102:11, 

103:16, 158:4

allocation 76:18, 77:1

allotted 4:10

allow 143:3

allowed 9:6, 52:8, 52:13, 

93:12

almost 6:23, 29:19, 74:22, 

76:1, 78:24, 89:3, 158:15

alms 108:8

alone 135:10

along 21:15, 30:22, 66:3, 

82:20, 114:3, 119:6, 130:18, 

139:12

already 20:7, 36:22, 142:10, 

147:24

Although 102:14, 109:19, 

123:15, 147:9

always 63:14, 106:25, 

124:19

am 51:6, 51:12, 59:1, 76:8, 

76:25, 102:2, 107:19, 112:21, 

115:9

amending 25:19

Amendment 112:24, 125:14, 

125:18, 126:3

America 1:5, 23:18, 24:12, 

33:2, 42:5, 68:20, 68:22, 

100:2, 101:13, 106:2, 106:3, 

127:4, 140:8, 140:16

America. 24:4, 28:10, 99:23, 

99:25

American 8:7, 14:7, 23:22, 

29:8, 29:10, 29:25, 31:4, 

35:20, 35:24, 36:10, 36:13, 

37:10, 39:9, 44:3, 44:5, 45:8, 

51:23, 55:13, 61:24, 62:25, 

100:17, 101:16, 109:14, 

113:10, 128:6, 128:7, 147:20, 

152:15, 156:9, 156:10, 

156:25, 157:14

Americans 70:2, 111:5

Americas 66:8

Amicable 127:1

Among 10:19, 14:22, 24:22, 

53:5, 102:10, 103:17, 139:7

amount 4:15, 41:1, 66:13, 

71:19, 73:13

analysis 5:13

Anees 129:9, 129:13

Angeles 18:16, 18:19, 57:10, 

64:25

announce 15:2

announcing 58:21

annulment 99:14

Answer 8:13, 26:18, 30:11, 

149:17, 150:6

answered 26:20

anticipate 5:1

anxiety 66:4

any 5:12, 6:5, 6:13, 6:14, 

10:20, 10:21, 32:6, 76:5, 

103:6, 103:20, 104:18, 106:4, 

113:22, 115:1, 117:7, 121:21, 

127:3, 129:6, 129:17, 133:10, 

134:6, 148:20, 151:11, 154:6, 

157:19, 158:12

anybody 26:18, 95:16

anymore 137:21

anyone 9:6, 32:16, 53:2, 

104:10, 106:14, 108:24, 

115:16, 141:19, 143:12

Anything 63:1, 106:10, 

110:22, 117:10, 132:24, 

133:3, 140:22, 149:19, 152:1, 

154:15, 156:14, 158:20, 

159:1

apart 157:1, 157:23

apologize 130:17

apparatus 21:23, 22:3, 24:7, 

73:5

apparatuses 22:15

apparently 103:17, 158:19

appeal 156:9

appear 36:2, 63:14, 80:3, 

149:11, 149:15, 150:7, 154:8

appeared 9:2

appearing 149:18

appears 62:12, 63:19, 

128:24, 135:20

application 113:12

applied 54:21

apply 151:17

appoint 128:3

appreciate 7:1

approach 124:13

approaching 35:16

Approximately 77:1, 102:13, 

102:21, 102:22, 105:6

April 41:5, 116:16, 119:8, 

144:24

Arab 23:21, 149:11

Arabia 54:22, 113:7

Arabic 25:8, 28:8, 33:12, 

43:14, 44:1, 51:22, 100:25, 

108:7, 117:2, 131:3, 140:5, 

143:1, 149:12

Arafat 33:25, 121:17, 140:5, 

151:7

Arches 117:6

archivist 20:24

Area 12:3, 123:6, 124:14

aren't 17:18, 92:6, 114:22, 

143:18, 146:15, 147:7

CASSIDI L. CASEY, CSR, 214-354-3139

UNITED STATES DISTRICT COURT

163
arena 23:22

arenas 23:21

argue 4:8, 8:23, 155:18, 

157:22

arguing 6:2

argument 4:11, 4:22, 4:25, 

5:17, 5:19, 5:21, 5:23, 8:3, 

102:3, 103:12, 114:7, 144:12, 

147:25, 148:15, 157:20

Arguments 4:17, 4:18, 5:11, 

77:5, 108:1, 160:2

Arizona 47:18

arm 28:21, 40:15, 127:5

arms 16:20

arose 37:22

Around 10:14, 13:22, 18:14, 

49:25, 60:1, 79:25, 85:24, 

87:9, 87:15, 96:2, 103:4, 

104:15, 136:7, 140:6

arrange 102:2

arrangement 38:5

arrest 18:9

arrested 17:22, 18:8, 50:2

Arrived 43:19

article 65:24, 66:2

ascertaining 158:8

Ashqar 28:6, 28:7, 30:24, 

35:15, 37:23, 37:24, 37:25, 

38:5, 38:6, 38:14, 38:15, 

38:17, 38:19, 39:10, 40:8, 

62:5, 62:5, 79:19, 79:19, 

79:21, 80:16, 85:17, 115:24, 

116:2, 127:25

Ask 47:9, 53:7, 76:3, 76:4, 

76:11, 95:25, 103:3, 111:3, 

111:10, 115:9, 116:18, 

119:19, 121:4, 124:15

asked 29:16, 132:25, 146:22, 

149:14, 149:22, 150:6

asking 23:15, 66:16, 156:6

asks 53:2

Aspect 26:24, 27:16

Aspects 27:3

assembled 126:13

Assessment 104:24

Assets 96:8, 137:22

assist 146:9, 146:24

assistance 21:24

Assistant 1:29

assisting 135:20

associated 7:11, 126:12

Association 20:6, 20:14, 

24:3, 24:22, 32:21, 43:12, 

66:8

Association. 24:23

associations 125:20, 125:23

assume 150:5

assurance 157:5

atop 17:12

attack 14:6, 45:19, 127:1

attacks 10:13, 10:14, 10:17, 

14:8, 14:14, 14:16, 14:24, 

15:3, 34:7, 34:8, 82:10, 

82:14, 82:14, 91:15

attempt 12:25, 55:12

attempted 109:1, 146:20

attempts 134:3

attend 31:1, 31:7, 31:20

attendance 31:17

attended 111:17

attendees 31:3, 32:15

attention 6:25, 18:12, 21:22, 

65:20, 69:11, 72:1, 77:7, 

112:17, 112:22, 158:22

Attorney 1:29, 148:19

audience 56:2

audited 100:21

August 116:24

Authority 34:19, 92:17, 

140:4, 140:19, 141:3

authorizes 148:18

available 51:23, 84:13, 

84:14, 140:12

Avenue 2:16, 3:7

avenues 74:1

avoid 105:16, 108:4, 109:12, 

146:17

aware 131:10

away 62:13, 89:19, 127:9

away. 125:10

axe 143:2

Azzam 64:22, 65:2, 65:4, 

65:23, 66:22, 69:14

< B >

B. 49:13, 49:23, 69:24, 87:11

babies 48:10, 107:5

backed 38:17

background 88:15, 109:19

backpacks 107:4

backyard 46:24, 56:25, 

58:10

bad 140:22, 145:13

Baker...............................104

160:4

band 48:17, 48:18, 49:8, 

57:17, 62:20

bands 50:19

Bank 9:24, 11:25, 13:4, 

17:16, 17:18, 38:2, 39:2, 

41:25, 57:9, 57:10, 67:13, 

70:15, 70:15, 71:19, 71:24, 

72:5, 73:14, 73:21, 78:19, 

86:2, 93:23, 99:6, 116:18, 

123:11, 123:13, 128:18, 

131:21, 135:17, 140:6, 141:4, 

141:5, 146:2

banner 23:8

Banque 41:22

bar 14:7

Barasse 20:22, 20:22, 21:4, 

21:8, 26:15, 27:5, 27:5, 

28:14, 29:18, 30:14, 50:6, 

53:14, 68:16, 69:18, 72:19, 

74:24, 81:14, 82:20, 86:21, 

87:24, 89:24, 92:25, 100:24, 

115:20

barbecue 47:5

BARRY 1:26

Based 10:8, 34:1, 42:7, 95:7, 

95:8, 134:22, 135:3, 152:5

Basically 9:14, 13:6, 40:23, 

60:17, 60:20

basis 14:11, 112:7, 125:15, 

125:22

basketball 100:10

bat 34:4

beard 143:12

beautiful 45:22

became 10:22, 11:9, 11:11, 

42:16, 87:6, 94:25

become 16:7, 16:13, 48:6, 

90:8, 94:9, 128:24

becomes 97:1

bedding 134:13

began 95:7, 104:2

begin 5:2, 5:19, 77:5, 

103:13, 103:19

beginning 5:23, 19:4, 22:13, 

CASSIDI L. CASEY, CSR, 214-354-3139

UNITED STATES DISTRICT COURT

164
24:1, 32:8, 53:8, 138:22

begins 109:19

behalf 7:19, 8:12, 38:3, 

39:16, 39:22, 56:1, 60:2, 

61:14, 62:3, 63:20, 63:21, 

64:12, 77:11, 78:5, 109:4, 

111:3, 114:23, 143:5, 143:21, 

148:22, 149:1

behind 25:12, 93:22, 99:19, 

136:5

Beitawi 64:1, 79:17, 79:20, 

79:21, 80:12, 80:14, 81:15

beliefs 69:8, 125:22, 125:22

believe 4:9, 10:17, 22:5, 

35:3, 42:17, 65:4, 100:10, 

110:2, 112:13, 114:9, 126:22, 

132:18, 153:12

believed 10:16

believers 68:25

believing 101:16, 101:22

belong 133:13

belt 88:12

benefit 99:24

benevolent 15:18

benign 15:18, 100:23

Benjamin 123:8

Besides 59:18, 75:15, 79:1, 

80:20, 82:3

best 67:10, 73:7

Bethlehem 84:16, 84:16, 

84:19, 84:20, 84:20, 84:23, 

84:23, 85:1, 85:1, 85:7, 

85:12, 140:10

better 69:23, 70:4, 70:9, 

77:20, 105:21

beyond 70:20, 134:24, 

135:9, 145:10, 145:16, 152:5, 

153:16, 153:17, 153:18, 

155:10

bias 120:4

bid 130:24, 131:2

big 16:9, 17:13, 17:24, 18:2, 

122:6, 125:1, 148:1, 148:14, 

152:13

bigger 136:21

bit 102:4, 122:9

bits 123:3, 123:4, 123:5, 

133:24

blaming 115:16

blankets 134:13

bless 67:9

blindly 79:9

block 6:11

blood 57:19

Board 18:25, 26:1, 26:4, 

26:19, 81:18, 110:13

bodies 61:24

body 13:7, 13:8

boilerplate 68:8

bolster 116:6

bomb 14:16, 14:18, 45:15, 

45:17, 45:18

bomber 14:21, 15:5, 15:6, 

15:25, 45:13

bombers 16:12, 89:22, 93:19

bombing 15:9, 44:24, 99:21, 

118:18, 119:9, 119:12

bombings 13:25, 14:1, 

34:13, 44:18, 44:19, 46:9, 

46:16, 106:9, 111:19, 152:14

bombs 16:23, 65:7

boobytrapped 45:15

book 28:2, 28:4, 40:9, 42:3, 

60:24, 89:7

books 20:16, 39:25, 44:9

border 133:20

born 128:14

bosom 23:5

bother 7:15, 131:12

Bottom 13:15, 22:1, 22:20, 

43:19, 53:24, 61:3, 72:23, 

100:3, 117:3

bought 130:20

BOX 2:25

boxes 91:21, 91:23

BOYD 1:43

bragging 59:24

brainwash 93:20, 94:9

brainwashes 16:11

brainwashing 93:23

branch 10:25, 152:1

branches 88:24, 88:24, 89:2

Brazil 128:14

break 34:18, 46:3, 46:6, 

75:21, 76:10, 128:7, 128:8, 

130:21

breaking 98:5, 108:5

breaks 34:17

bred 23:4

briefings 139:19

briefly 40:24, 54:20, 95:2, 

130:3

Brigades 13:21

bring 8:11, 35:3, 38:6, 61:22, 

64:15, 66:20, 77:6, 93:7, 

151:4, 151:11, 158:21

bringing 62:2

brings 66:4

Britain 73:1

broke 78:1

Brother 29:19, 37:3, 70:5, 

72:25, 92:15, 124:25

Brothers 21:12, 37:11, 

67:10, 99:11, 125:4, 127:3

brought 7:18, 8:16, 37:25, 

38:2, 55:24, 59:19, 60:3, 

61:13, 62:20, 64:13, 79:19, 

93:2, 101:6, 125:13, 130:2, 

135:25, 136:7, 150:24

Brown 22:5, 75:11, 84:15, 

120:9, 120:9, 120:14, 120:22, 

121:15, 141:2, 142:21, 

143:14

Bryant 107:9, 107:11, 

107:15, 108:3, 144:13, 

146:13

budget 26:1, 26:4

budgets 30:5

bugged 138:25

bugs 55:4

build 133:18

building 55:4, 56:11, 84:8, 

92:1, 145:25

built 13:16

bulletin 54:1, 54:2

bunch 98:7, 148:2

burden 5:19, 5:20, 155:19, 

157:3

bureau 42:22, 69:16

buried 16:20, 47:1, 47:3, 

47:4, 58:10

burn 47:4

Burns 66:25, 79:4, 110:22, 

114:11, 115:22, 116:13, 

116:13, 118:1, 118:16, 

118:24, 122:18, 130:4, 

130:10, 131:7, 132:12, 

132:25, 136:9, 141:17, 

141:24, 151:3, 156:3

bus 14:11, 14:12

CASSIDI L. CASEY, CSR, 214-354-3139

UNITED STATES DISTRICT COURT

165
Bush 121:4

business 29:21, 29:23, 

110:7, 132:4, 138:12, 147:10, 

148:13

businesses 137:4

buy 97:23, 135:6

buying 65:6, 65:14

bylaws 25:19

bypass 133:17

< C >

C-A-I-R 37:10, 142:18

C. 48:20

CA 2:33

Cadeddu 2:14, 2:15, 102:18

cahoots 101:19, 115:1

CAIR 37:10, 37:11, 37:18, 

39:9, 40:14, 142:17

CAIR. 37:18

California 2:31, 115:5, 115:6

call 9:12, 10:22, 13:20, 

30:20, 35:14, 35:17, 38:14, 

38:22, 39:20, 39:23, 39:23, 

43:9, 45:19, 45:20, 55:11, 

56:6, 62:16, 63:10, 63:16, 

63:18, 64:8, 64:10, 66:11, 

96:5, 96:11, 99:14, 129:7, 

129:16, 129:20, 129:23, 

129:25, 137:10, 139:23, 

144:18, 144:22, 144:25, 

145:18

called 10:24, 12:16, 18:18, 

22:9, 25:21, 29:3, 37:9, 

37:24, 42:23, 43:8, 43:14, 

45:21, 60:15, 104:23, 114:14, 

123:5, 129:22

calling 12:14, 94:12

calls 11:23, 12:8, 13:3, 13:5, 

30:16, 42:21, 46:12, 63:16, 

63:23, 64:2, 66:8, 66:21, 

96:8, 129:4, 139:7, 139:7, 

146:10

camera 115:25

camouflage 100:7

camp 93:15

campaign 123:11

campaigned 123:9

camps 93:18, 127:13

car 45:15

cards 80:25, 122:1

Care 70:23, 84:16, 84:17, 

84:21, 84:23, 85:2, 85:8, 

85:12, 112:25

cared 70:24

careful 134:23

carefully 111:5, 120:20, 

157:9, 157:11

caring 118:23

carnage 14:10

carried 22:16, 122:25

carry 14:22, 75:2

case 4:9, 5:17, 6:2, 9:1, 

32:22, 33:24, 44:16, 44:21, 

53:2, 72:2, 97:11, 104:1, 

104:6, 105:15, 105:23, 106:6, 

106:15, 106:19, 109:19, 

109:24, 110:15, 111:6, 

112:16, 113:14, 113:18, 

114:1, 116:14, 116:14, 132:9, 

134:24, 136:3, 138:5, 139:13, 

146:21, 147:1, 147:15, 153:4, 

153:16, 154:1, 156:12

CASEY 3:13, 158:16, 158:18, 

161:3, 161:18

CASSIDI 3:13, 161:3, 161:18

cater 127:6

caught 33:10, 126:19

cause 20:2, 21:18, 21:19, 

21:23, 23:17, 23:23, 24:21, 

25:10, 25:10, 25:17, 66:10, 

152:25, 152:25, 153:12, 

153:17, 153:23, 154:11, 

155:1, 155:8, 161:4

caused 10:19, 109:9

cell 96:15

Center 42:16, 42:18, 54:11, 

85:16

Central 25:21, 25:23, 26:12, 

26:15, 26:20, 27:4, 72:24

ceremonies 90:13

ceremony 88:8

certain 10:9, 30:2, 34:8, 

38:6, 42:15, 52:3, 54:17, 

72:8, 106:20, 113:7, 126:11, 

156:11, 156:13

certainly 52:8, 73:25

certify 161:3, 161:10

chain 81:1, 81:1

Chairman 18:24, 26:24, 

27:3, 121:17, 140:4

chairs 131:16

challenge 141:21, 143:15

challenged 151:20

change 112:14, 118:8, 

120:1, 132:5, 132:7

changed 11:18, 25:1, 58:4, 

123:10, 132:13

changer 71:23, 71:24, 130:4, 

130:7, 132:3

changers 71:20

changes 84:23

changing 30:8

chant 51:20

Chanting 59:1

chapter 9:19, 10:3, 10:5, 

19:17

chapters 9:18, 19:16

character 134:25

characteristics 21:18

charge 77:10, 98:16, 152:2

charged 44:16, 44:21, 52:10, 

52:11, 52:15, 95:18, 95:19, 

98:14, 106:4, 106:15, 117:19, 

128:23, 136:19, 139:13, 

143:6, 153:15

charges 98:5, 98:7, 98:23, 

104:3, 113:23, 150:16, 

150:19, 155:14

Charitable 27:16, 38:8, 

38:10, 67:11, 74:6, 87:25, 

88:22, 89:4, 89:24, 90:4, 

90:6, 90:8, 90:25, 96:25, 

104:4, 127:5, 136:25, 137:10, 

138:2, 138:9, 140:13, 140:24, 

143:7, 143:17, 150:10

charities 8:8, 72:6, 73:10, 

109:3, 137:5, 137:17, 138:17, 

141:5, 141:6, 142:3, 142:17, 

147:20, 152:21

charity. 128:9

Charlotte 116:10

chart 26:11, 26:12, 27:15

charter 11:17, 11:23, 11:23, 

12:6, 12:8, 12:13, 12:16, 

12:21, 13:3, 16:9, 16:14, 

20:12, 35:7, 48:2, 68:2, 95:9

chatter 139:1

check 40:25, 67:14, 113:11, 

119:5, 119:7, 131:11, 158:7

CASSIDI L. CASEY, CSR, 214-354-3139

UNITED STATES DISTRICT COURT

166
checked 121:25, 142:15

checks 110:10, 114:15, 

114:16

cheers 51:12, 51:18, 94:11

Chemicals 16:22

Chief 19:1

child 14:22, 14:23, 19:11, 

19:13, 84:1, 88:13, 88:13, 

89:23, 94:6, 94:19, 108:11, 

131:20, 131:22

Children 14:20, 16:10, 

16:12, 50:25, 57:19, 58:13, 

59:8, 62:10, 78:3, 90:15, 

93:19, 93:21, 93:23, 94:3, 

94:7, 94:19, 99:7, 105:16, 

105:17, 106:8, 107:4, 119:11

chose 64:15, 74:2, 130:13

Christian 122:15, 123:19

CIA 139:19, 139:20, 139:22, 

139:25, 140:1

circumstances 52:3

citizen 10:15, 45:8, 95:15, 

109:14

citizens 111:5, 137:2, 152:15

citizenship 125:9

City 45:1, 90:2, 99:21, 

118:18, 119:2

civil 29:13, 41:11, 142:23

civilians 14:4, 152:18

civilization 68:21, 68:24

claim 29:7, 125:3

claimed 35:16, 108:17, 

113:7, 114:22, 115:13, 

118:17

claims 142:9, 144:9, 148:3, 

152:6

clairvoyant 4:23

classified 125:7

clear 59:2, 59:12, 83:2, 

106:4, 126:18, 129:24

cleared 142:15

clearing 38:7

Clearly 40:1, 82:24, 122:2, 

123:13, 143:6

Cline 2:29, 97:3, 158:22

Clip 47:22, 48:7, 49:23, 

50:11, 51:6, 58:19, 58:24, 

59:2, 62:6, 63:2, 63:8, 63:24, 

69:24, 88:3

clips 47:14, 48:19

close 70:8, 112:17, 153:9

closed 105:10, 106:12, 

112:4, 141:4, 141:6, 147:9, 

147:13, 147:14, 151:2

closely 5:15, 77:12, 104:22, 

110:3

closing 4:11, 4:16, 4:18, 

4:22, 5:10, 77:4, 103:12, 

105:25, 114:7, 157:20

co-conspirators 27:23

cocounsel 102:14

code 52:25, 55:9

coincidentally 65:23

coincides 5:15

collect 139:21

collected 150:25

collecting 26:8

collection 26:6

collectively 34:24, 103:16

collects 139:23

Colombia 123:19

column 78:16

combed 116:17

combing 116:15

comes 46:19, 51:11, 110:21, 

110:25, 156:2, 156:4

Coming 24:14, 27:14, 40:7, 

43:25, 53:18, 83:13, 84:12, 

87:19, 107:16, 116:9, 117:4, 

126:19

comments 60:7

Commerce 1:33, 3:14

commit 13:5, 13:7, 14:24

commitment 109:11, 109:12

commitments 5:5

commits 13:24, 14:8

committed 15:9, 15:12, 

52:10, 78:4, 81:7

Committee. 32:9

committing 11:13, 14:2, 

30:5, 35:22, 62:11, 65:15, 

82:13

common 93:4, 93:9, 93:12, 

126:13, 134:22

communique 15:1, 45:6

communiques 20:12, 24:5, 

44:22, 46:7

community 29:8, 32:5, 

36:19, 67:4, 101:14

companies 67:1, 67:2

company 21:11, 42:7, 42:8, 

55:3

compensated 133:23

complete 130:11

completely 12:4, 104:10

completes 78:10

completion 78:8, 100:12

comply 107:10, 161:11

component 97:12, 97:16

compromise 123:11

computation 87:3

computer 60:5

conceal 29:9, 29:24, 33:3, 

55:12, 55:15, 100:2

concealed 89:18

concealing 41:15

Concealment 29:10, 41:15

concern 11:2, 34:15, 34:17, 

109:8, 121:2

concerned 32:24, 54:11, 

54:14

conclusion 4:18, 4:25, 

151:4, 157:12, 157:13, 

157:13

conditions 133:4

condone 106:14

conduct 113:22, 157:25

conferences 12:17, 12:20, 

34:2, 56:20, 93:7, 111:17

confidence 66:3

conflict 8:22

conflicts 38:8

confront 22:16

Congress 9:16, 95:9, 

149:22, 150:2

Congressional 149:25

Congressman 107:9, 108:3, 

144:14, 145:21, 146:13

conjunction 83:1

connect 123:21

connected 28:4, 42:9, 54:4, 

60:15, 60:20, 61:14, 82:9, 

83:13, 86:3

connecting 77:10

connection 23:9, 41:12, 

85:13

connections 79:2, 114:21

conscious 52:24, 53:3

consequences 95:21, 96:10, 

96:10

CASSIDI L. CASEY, CSR, 214-354-3139

UNITED STATES DISTRICT COURT

167
consider 39:24, 44:14, 

44:20, 52:9, 52:13, 52:17, 

90:2, 107:25, 111:5, 112:9, 

112:10, 141:15, 142:4

consideration 77:19, 134:23

considered 22:10, 112:1, 

138:8, 144:15

considers 137:3, 150:9

consistent 108:16, 113:12, 

113:13, 115:3, 117:4, 117:5, 

118:21, 119:17, 131:9, 

132:14

conspicuous. 37:5

conspiracy 44:15, 98:7, 

98:13, 126:15

conspired 109:1

Constitution 11:17, 11:18, 

125:8, 125:14

Constitutional 125:20

Consul 133:6, 139:18

contact 42:20

contacts 121:10, 121:11

contained 61:6

contains 144:4

contest 108:19

contested 107:3

context 12:11, 127:17

continue 12:7, 70:25, 84:22, 

109:13, 146:9, 150:5, 157:23

continued 39:18, 81:23, 

127:20

continues 149:23

continuing 150:1

contradicted 121:20, 142:19

contradiction 12:18

contribution 41:13, 67:20, 

68:6

Control 26:3, 38:11, 40:4, 

73:22, 137:22

controlled 74:3, 75:7, 79:12, 

86:15, 109:4, 139:16, 140:20, 

140:25, 141:16, 143:8, 

143:20, 144:8, 144:9, 148:6, 

148:21, 148:25, 150:10

controls 34:20, 40:12, 73:22

convenient 133:3

conveniently 117:11

conversation 45:23, 96:21, 

127:24, 127:25, 143:10

convicted 125:15, 125:21, 

157:6

convince 121:3, 145:10

convincing 134:25, 153:19

coordination 73:6

copy 4:23, 95:22, 96:1

corner 36:25

corner. 124:10

correct 113:11, 118:3, 

118:21, 161:8

correctly 110:7

correspondence 79:7, 82:4, 

83:9, 85:11

corridor 133:21

Council 24:9, 25:13, 37:10, 

39:9

Counsel 4:8, 4:21, 5:11, 

5:24, 5:25, 6:10, 6:18, 6:21, 

8:22, 52:1, 76:12, 76:22, 

77:17, 102:4, 102:10, 103:11, 

103:13, 103:15, 107:22, 

107:25, 157:19, 157:22, 

158:20

count 106:25

counted 86:9

Countries 18:2, 22:5, 22:6, 

22:7, 22:8, 24:10, 64:14, 

72:6, 72:20, 73:5, 73:11, 

120:12, 120:13, 128:25, 

157:1

Country 10:5, 12:1, 12:1, 

12:2, 19:25, 23:15, 136:7, 

140:8, 157:2

counts 98:14, 155:14

couple 11:22, 14:21, 48:19, 

64:24, 153:7

course 97:25, 103:14, 

104:20, 112:2, 114:15, 116:4, 

119:5, 124:12, 126:16, 

144:25, 149:19

COURT 1:1, 3:13, 4:2, 6:5, 

6:9, 6:17, 6:19, 6:20, 32:2, 

46:2, 46:5, 75:23, 76:1, 

76:11, 76:18, 76:21, 77:3, 

77:20, 77:23, 102:1, 102:9, 

103:1, 103:8, 103:10, 103:24, 

111:10, 125:17, 153:1, 154:1, 

157:17, 158:3, 158:18, 

158:23, 159:1, 161:11

Courthouse 1:32

courtroom 4:13, 7:2, 112:8, 

118:6

cover 17:3, 17:6, 32:15, 

36:15, 55:7, 56:14, 65:23, 

82:11, 107:22, 107:24

covered 54:24, 121:9

covering 56:17

covers 40:18

covert 53:7

Cowboys 97:19, 97:22

create 26:14, 37:9, 101:24, 

123:20, 132:16

created 9:12, 19:10, 19:14, 

19:23, 20:1, 54:15, 75:18, 

130:5, 157:2

creating 36:15

creation 28:15, 40:18, 56:15, 

68:17, 69:6

credibility 151:22

credible 141:7

credit 14:24, 14:25, 15:3, 

15:7, 15:11, 92:5, 92:5, 

122:1, 141:20

creed 99:4

crime 95:18, 98:18, 125:21, 

128:23, 155:23, 157:6

crimes 52:15, 67:21, 153:15

criminal 157:4

criteria 72:8, 75:8, 153:13

Cross 8:7, 8:17, 114:11, 

119:7, 122:13, 129:18, 137:6, 

137:7

crowd 10:15, 51:18

crucial 137:1

crush 67:24

crying 48:10

CSR 3:13

Culture 85:14, 85:21, 86:7, 

86:9, 86:13

current 36:5, 42:22, 136:21, 

144:3

currently 13:20, 73:1, 115:14

Customs 116:7, 131:14

cut 44:7, 137:25, 138:11

CUTRER 3:5

cuts 137:19, 148:11

CVSP 72:13, 138:14, 148:3

< D >

D. 2:29

CASSIDI L. CASEY, CSR, 214-354-3139

UNITED STATES DISTRICT COURT

168
Dalell 131:19

DALLAS 1:3, 1:34, 2:17, 

3:15, 55:16, 78:19, 97:18, 

114:25, 161:21

dance 57:19

dancing 57:20, 58:14, 59:8

DANIELS 1:43

dark 123:4

date 40:24

dated 60:6, 68:3, 116:2, 

144:24

dates 112:17

Day 2:30, 4:14, 11:18, 46:25, 

93:8, 105:20, 119:8, 126:7, 

136:23, 144:1, 150:8, 154:5, 

154:9

days 4:6, 31:21, 128:14

dead 16:24

deal 18:2, 28:24, 137:5, 

140:17, 147:20

dealing 126:25, 140:16

dealt 140:3

dear 157:2

debate 149:20

deceased 85:5, 85:5, 108:12

deceit 29:10, 101:11

deceitful 114:23

Deceive 100:7, 100:9, 

100:16, 101:22, 101:25

deceived 101:16

deceiving 63:7, 100:6

December 10:12

deception 43:21, 100:5, 

100:5, 100:7, 101:15, 126:6

deception. 100:13, 100:15, 

126:3

deceptive 32:7, 32:13, 

110:2, 119:19, 136:11

decide 8:21, 38:24, 40:3

decided 11:1, 11:5, 19:24, 

24:2, 25:3, 36:1, 38:25, 39:7, 

133:21, 156:11, 156:13

decides 18:17, 28:17

decision 39:13, 76:5

decisions 17:24, 156:18

declaration 32:1, 32:2, 32:3, 

32:12, 33:12, 43:22, 44:3, 

101:9, 111:8, 111:13, 112:3, 

113:2

dedicated 120:16

Deeb 129:9, 129:13

deeds 67:11

defeated/slaughtered 67:22

Defendants 7:23, 9:2, 27:23, 

34:23, 43:11, 51:25, 52:5, 

52:20, 54:4, 56:7, 56:16, 

69:7, 70:8, 74:1, 75:17, 

76:12, 79:22, 84:14, 85:3, 

87:21, 92:22, 93:22, 95:18, 

95:20, 96:9, 96:12, 98:3, 

98:4, 98:4, 100:21, 101:16, 

101:21, 103:14, 103:14, 

154:4

Defense 5:24, 6:21, 6:24, 

8:16, 8:22, 22:6, 70:11, 77:4, 

77:7, 77:8, 77:17, 84:15, 

102:10, 103:17, 107:22, 

107:25, 141:11, 155:17, 

158:6, 159:1

defenses 74:16

Defensive 151:1

defined 13:6, 120:13

definition 85:3, 108:15, 

108:16, 120:15, 145:9

deliberate 53:20, 84:5, 93:11

deliberating 11:21

deliberations 5:3, 8:4, 21:5

delivering 134:13

demand 125:5

demanded 125:5

democracy. 35:10

demolish 132:25, 133:1

Demolished 107:7, 132:23, 

132:24, 133:16, 133:18, 

134:1

demolishes 133:13, 150:16

demolishing 133:7

demonstrative 118:1

denied 62:15, 127:19

denies 128:9

Department 1:30, 29:2, 

105:13, 136:6, 137:8, 137:9, 

137:15, 137:20, 138:7, 

140:17, 140:18, 144:13, 

146:25, 148:1, 148:8, 148:23, 

149:3, 150:8, 153:11, 154:7, 

154:10, 154:18, 154:20, 

154:24, 154:25, 155:7

departments 53:21, 53:24

depending 5:14, 5:16

deportees 23:2, 79:24, 87:9, 

87:16, 93:1

deports 150:16

deposition 29:13, 29:14, 

29:15, 29:20, 41:10, 110:4, 

110:12, 112:3, 113:2

derail 34:7, 34:22

derailing 34:23

described 14:15

designate 144:1, 144:10, 

146:16, 146:25, 147:24, 

148:8, 148:20, 148:25, 

152:22, 152:23, 153:2, 

154:15, 154:16, 155:1, 155:3, 

155:4, 155:6

designated. 149:17

designating 95:23, 149:6, 

149:7, 152:24

designation 95:6, 95:8, 

96:10, 129:14, 144:16, 

146:19, 147:5, 147:25, 149:9, 

150:13, 153:5, 154:16

designations 95:1, 95:3, 

95:14, 95:21

designed 15:14, 34:9, 44:2

desperate 104:7, 127:11

desperately 104:5, 104:15, 

105:15, 152:21

destitute 133:23

Destroy 12:21, 16:14, 47:8, 

47:9, 99:8, 101:20

destroyed 47:1

destroying 16:17, 68:23

destruction 11:23, 12:8, 

12:13, 12:14, 14:9

detail 11:20, 110:8, 129:10

detailed 104:10

details 77:4, 110:19

detained 61:2

detainees 23:1

detention 128:22

Determination 66:1

determine 12:11, 151:22, 

154:11

determined 153:13

determines 148:21

determining 26:3, 44:14, 

44:20, 52:9, 52:14, 52:17, 

75:8

develop 37:17

CASSIDI L. CASEY, CSR, 214-354-3139

UNITED STATES DISTRICT COURT

169
developed 24:5, 24:8

developing 117:8

Development 104:25, 142:7

devices 55:4, 55:6

devoted 5:22, 142:22

dictatorship 128:15

died 23:7

difference 103:6, 153:16

different 9:19, 22:16, 31:25, 

43:12, 65:21, 84:18, 86:14, 

91:12, 92:19, 101:3, 108:15, 

111:20, 112:20

differently 145:22

dime 106:21

Din 13:21

dire 127:20

direct 42:20, 71:5, 78:17, 

78:18

directed 10:20, 20:4, 67:2, 

70:17, 71:19

directing 40:5

directly 41:17, 74:12, 86:9, 

131:14

Director 24:11, 137:11, 

143:10, 143:13, 148:9, 

149:23, 154:22, 155:2

directors 26:2, 26:4, 26:19, 

142:25

disappear 131:17

disappeared 132:18

disappointed 123:7

disassociate 29:6

disasters 109:10

discharge 128:3

discuss 33:17, 36:15, 39:21, 

61:24, 62:1, 115:14, 124:13

discussed 34:16, 88:9, 

104:19, 124:11, 126:13, 

135:15, 138:5, 143:9

discusses 116:2

discussing 66:24, 99:20

discussion 24:16, 35:8

disobey 145:14

dispute 37:21, 39:16, 62:5, 

79:18, 79:21, 80:15, 85:17, 

158:19

disputes 106:13

disregard 145:14, 145:19

distance 107:1

distancing 36:2

distinction 150:20

distinctions 92:15

distinguish 14:4

distinguished 22:14, 25:11, 

136:1, 136:8

distract 8:25, 127:15, 132:16

distraction 127:18

distributed 131:23

distribution 108:24

DISTRICT 1:1, 1:2, 1:31, 

161:19, 161:20

disturbing 106:7

diverged 135:17

Divers 84:12

divert 122:8

divide 107:23

divided 103:18

DIVISION 1:3, 76:19, 77:5

DIVSION 161:21

doctor 55:23

dog 133:9, 141:10, 143:2

doing 8:25, 15:7, 35:6, 

69:20, 91:23, 93:24, 99:18, 

99:18, 100:11, 101:2, 107:11, 

147:10, 147:11

dollar 119:5, 119:7

dollars 41:8, 41:14, 69:10, 

70:16, 74:22, 78:25, 82:2, 

89:4, 107:3, 118:17, 119:1, 

119:4, 119:15, 119:16, 

129:16, 132:6, 132:8, 133:19

domestic 59:25

domestically 24:20

donating 66:13

donation 67:2, 68:12

donations 26:6, 64:10, 

65:11, 65:16, 66:15, 73:7

done 6:23, 7:1, 8:19, 8:24, 

113:14, 113:25, 114:2, 

147:21, 152:11, 152:19

Door 65:25, 125:1

door. 143:15

dot 60:13, 60:14, 60:21

dots 60:11

doubling 27:1

doubt 120:3, 134:5, 134:6, 

134:7, 134:22, 134:22, 

134:24, 135:7, 135:9, 145:11, 

145:17, 152:5, 153:6, 153:16, 

153:18, 153:18, 155:10, 

156:7, 156:16, 156:19, 

156:21, 156:22, 156:23

doubts 155:23

down 38:17, 68:4, 80:15, 

105:12, 106:12, 110:21, 

126:4, 133:22

downloaded 88:7

dragged 61:25

Dratel 2:3, 2:5, 102:15, 

121:12, 129:18

drawing 25:25

dress 93:19

dressed 88:13

drew 119:2

drive 16:2

driven 16:4

driving 10:15

drops 16:24

du 41:23

due 5:4, 23:23, 34:12

dumb 56:9, 56:12, 56:13, 

100:17

DUNCAN 1:42, 158:13

During 5:10, 5:12, 8:4, 8:16, 

11:12, 31:16, 32:14, 34:14, 

51:25, 76:3, 99:21, 112:11, 

114:7, 114:11, 117:17, 118:8, 

129:22, 130:21, 137:6, 137:7, 

150:25, 157:19, 158:10, 

161:3

dust 112:25, 134:3

duties 78:8

duty 111:4, 111:4

< E >

e-mail 139:7, 158:16, 158:19

earlier 19:15, 46:10, 65:22, 

76:3, 82:10, 102:2, 102:4, 

111:12, 112:7, 157:18

early 9:22, 10:4, 13:21, 19:5, 

19:18, 20:10, 28:22, 28:24, 

40:19, 41:4, 55:22, 59:22, 

59:22, 74:10, 75:22, 76:10, 

79:24, 83:5, 89:3, 91:4, 

111:25, 136:2, 152:7

ears 70:2

East 10:1, 17:10, 45:4, 

120:12

Economic 13:5, 65:8, 69:12, 

CASSIDI L. CASEY, CSR, 214-354-3139

UNITED STATES DISTRICT COURT

170
78:4, 99:6

Ed 141:18, 151:15

educated 9:11

Education 16:8, 16:9, 37:25, 

38:4

Edward 105:4, 123:18, 

139:17

effect 11:17

effective 23:3, 25:11

Egypt 9:12, 9:25, 133:20

Egyptians 19:21

eight 37:15, 45:14, 63:17

eighties 22:13, 24:2, 91:4

Either 13:24, 60:15, 60:22, 

95:15, 131:12, 143:16

El 20:21, 20:22, 21:4, 21:8, 

26:14, 27:5, 27:5, 28:14, 

29:18, 30:14, 50:6, 53:14, 

68:16, 69:18, 72:18, 74:24, 

81:13, 82:20, 86:20, 87:24, 

89:24, 92:25, 96:6, 100:24, 

115:20

El-mezain 2:1, 7:24, 18:21, 

18:24, 27:10, 27:17, 28:12, 

29:15, 29:16, 31:9, 31:18, 

39:22, 40:3, 42:23, 43:1, 

43:5, 43:7, 44:17, 45:5, 

45:13, 45:15, 45:19, 45:22, 

45:24, 46:8, 46:15, 47:12, 

47:13, 47:21, 47:21, 48:8, 

48:15, 57:8, 57:12, 57:23, 

59:16, 87:13, 99:21, 138:25

El-mezains 57:5

Elashi 2:20, 7:24, 18:16, 

18:20, 18:25, 19:2, 21:11, 

31:14, 31:15, 56:7, 70:7, 

73:1, 95:25, 96:12, 96:19, 

98:23, 108:4, 119:24, 145:1

elections 89:17

electronic 55:4, 55:5

element 77:9, 77:14, 155:23

eleven 85:9

eliminated 12:5, 69:1

eliminating 68:23

ELIZABETH 1:27

Elmo 124:4

else. 128:3

Embassy 14:7, 107:17

emotions 156:9

emphasis 71:8

employed 17:4

employee 54:22

employees 26:1

employees. 90:5

enacting 52:7

Enclosed 67:20

encourage 92:24, 101:12

encouraging 57:18

end 16:16, 22:4, 41:19, 

43:19, 64:9, 113:18, 122:25, 

139:5, 153:3

ended 41:7, 85:23

endorsing 65:13

ends 45:22, 51:16, 68:7, 

78:24

enemy 22:16, 66:5, 67:24, 

100:5

enemy. 100:9

engages 106:13

engaging 106:15

engineer 64:4, 71:13, 81:2, 

83:24

England 116:20, 138:14

English 25:9, 28:8, 100:23, 

131:4

enlarge 60:7

enough 98:12, 144:1, 155:7, 

155:9

entire 105:24, 109:21, 

110:15, 142:22, 157:4

entitled 28:9, 43:18, 44:25, 

53:16, 72:21

equal 76:19

equipment 97:24

Especially 96:3, 98:2, 120:4

essay 43:17

essential 105:3

establish 24:3, 126:14

established 21:23

ET 1:11

etcetera 24:5, 26:4, 149:5, 

150:17

Europe 133:10

evaluate 88:5

evasion 98:24

evening 157:23

event 45:3, 129:23

events 109:22, 111:11, 

117:19

everybody 36:6, 36:6

everyday 14:10

everyone 36:8, 101:10, 

110:19, 137:5, 144:2

everything 51:22, 106:23, 

111:15, 118:3, 122:19, 

122:22, 148:14

everywhere 13:3

evidence 4:9, 5:12, 5:13, 

5:15, 7:3, 29:11, 42:9, 47:10, 

84:11, 86:14, 92:19, 92:21, 

106:3, 106:7, 109:7, 109:10, 

110:17, 111:6, 112:16, 

115:21, 121:21, 130:1, 134:4, 

134:23, 135:3, 135:5, 135:24, 

136:14, 136:18, 137:1, 

142:19, 143:16, 152:5, 

152:23, 155:6, 155:7, 155:9, 

156:15, 157:11

Exactly 99:17, 99:18, 104:8, 

112:8, 115:5, 124:20, 128:4, 

128:15

examination 8:17, 114:12, 

137:6, 137:7

examined 122:13

example 7:14, 14:20, 15:24, 

16:19, 18:21, 40:5, 44:23, 

59:16, 64:21, 108:2, 111:7, 

115:19, 117:23, 130:2

examples 54:17, 54:20, 

114:6, 115:8, 135:13, 136:12

except 12:23, 47:25, 48:1, 

52:3, 76:16, 110:23, 120:8, 

132:15

exception 138:5

excerpt 39:4, 49:14

exchange 73:6

exchangers 132:3

Executive 19:1, 24:18, 

27:11, 95:7, 95:22, 95:24, 

96:2, 148:15, 148:24, 153:14

exercising 26:3, 40:4, 52:16

Exhibits 8:4, 8:9, 28:14, 

30:3, 41:2, 53:19, 79:6, 

80:22, 81:12, 91:19, 104:18, 

104:21, 142:14, 158:15, 

158:17

exist 12:6, 12:7, 114:18, 

114:21

existed 20:8, 136:18

existence 20:7, 126:14

CASSIDI L. CASEY, CSR, 214-354-3139

UNITED STATES DISTRICT COURT

171
exists 121:16, 156:7

expect 4:5, 35:10, 154:13

expected 76:8

experienced 22:14

experiences 73:6

expert 9:10

experts 110:23

explain 95:2, 143:22, 147:6, 

147:8, 147:12, 156:20

explained 110:6, 148:9

explaining 88:9

explanation 146:14

explicit 32:18

exploited 99:13, 99:16

exposed 101:4

Express 31:4, 129:6

expressed 34:15, 34:17, 

43:11

expressing 52:12, 112:23, 

125:25

expression 125:22, 129:2

expressions 69:7

extensively 11:19

extremely 125:12

< F >

face 15:17, 40:2, 44:4, 44:5, 

62:15, 62:15, 99:25, 100:1, 

101:13, 101:13, 131:20, 

151:19, 152:4, 156:1

facing 29:8, 109:9

fact 4:21, 14:10, 23:13, 26:4, 

29:2, 34:6, 78:8, 84:8, 86:15, 

121:17, 126:11, 131:4, 

132:16, 132:20, 132:24, 

138:4, 142:17, 146:20, 155:4

facts 45:13, 109:24, 113:16, 

114:21, 117:23, 123:20, 

123:25, 131:1, 134:4, 134:19, 

156:12, 156:12

factual 127:3

fail 99:12

fail. 35:4

failed 41:13, 108:23, 108:25, 

109:2, 109:5, 113:8

failing 114:2

failure 61:22, 154:14

fair 157:13

fairly 11:19, 15:18, 100:23, 

156:11

faith 108:6, 108:16, 120:24

falling 85:18, 85:24

false 55:7, 99:1, 114:4, 

116:6, 117:16, 118:13, 

123:20, 129:12, 132:16, 

133:25, 134:4

families 70:19, 70:20, 70:22, 

70:24, 71:4, 71:9, 71:11, 

78:3, 105:3, 105:7, 132:23

family 16:1, 70:4, 71:8, 

71:12, 134:2, 134:12, 134:17

famous 13:25, 81:2

fancy 105:13

far 41:2, 76:17, 130:6

fashion 55:10, 151:18

fast 107:20, 130:21

faster 76:8

FATAH 92:16, 140:20, 

140:21, 141:4, 151:5

father 85:5, 108:12, 109:16

favor 141:11

Fawaz 46:19, 46:20, 47:1, 

47:2, 47:3, 56:25, 58:9, 62:8

Fax 28:9, 42:4, 60:10, 61:5, 

61:5

faxes 46:12, 139:3, 139:3, 

139:9

FBI 30:17, 47:6, 116:15, 

116:16, 118:4, 130:10, 

138:23, 139:6, 141:10, 

144:24, 146:10, 146:18, 

147:4, 147:9, 152:8, 152:9, 

152:16, 152:16

fearful 112:6

fed 15:25, 105:8

Feed 107:5, 119:10

feelings 52:13, 123:21, 

123:23

feels 109:15

fees 133:11, 161:10

feet. 66:5

fellow 6:21, 146:22

felt 29:5, 123:23

festival 47:16, 48:16, 50:10

few 4:6, 7:5, 9:8, 10:10, 13:2, 

19:6, 25:1, 37:23, 47:13, 

72:12, 75:22, 79:13, 91:9, 

113:15, 115:8, 121:22, 131:1, 

134:9, 134:11

fifty 107:3, 119:11, 127:13

fig 62:14

fight 133:10, 141:10, 143:3

fighting 38:16, 49:20, 70:25, 

100:5, 140:23

figure 64:23, 126:1, 145:16

figures 64:5, 71:13

file 104:10

filed 31:12, 32:1, 43:22, 

44:3, 101:9

files 131:5, 151:9

filing 30:4

Filistine 43:14, 43:15, 65:19, 

65:21, 66:23, 66:24, 69:13, 

101:8

finally 93:4, 122:17, 136:8

finance 137:17

financeer 42:2

finances 137:25

financial 23:16, 132:11, 

137:19, 148:12

Find 101:25, 107:11, 108:3, 

117:1, 117:14, 119:18, 

121:24, 126:6, 128:12, 

130:13, 132:1, 135:10, 

148:17, 151:9, 152:4, 153:14, 

153:15, 155:7, 155:12, 

155:13, 156:16, 157:15

finding 73:7

fine 103:8

finish 5:21, 103:4

finished 103:11

fireplace 47:5

firs 40:20, 45:17, 47:11, 

76:25, 78:12, 102:13

First 1:45, 7:7, 9:9, 10:4, 

10:22, 18:14, 20:20, 21:2, 

23:25, 26:23, 30:17, 30:18, 

42:5, 66:11, 76:17, 95:11, 

99:10, 109:17, 112:24, 

125:14, 126:2, 126:4, 126:5, 

134:8, 143:25, 146:16, 148:1, 

158:25

Fish 1:18, 113:17, 135:8, 

145:7, 151:21

Five 4:13, 4:13, 7:22, 12:24, 

16:11, 34:2, 42:17, 68:4, 

88:24, 105:6, 116:16, 118:10, 

118:12, 118:17, 119:1, 119:3, 

119:3, 119:5, 119:14, 128:17, 

CASSIDI L. CASEY, CSR, 214-354-3139

UNITED STATES DISTRICT COURT

172
130:10, 131:7

flag 128:20, 156:9, 156:10

flare 23:7

flavoring 56:23, 61:15

flip 154:22

flipped 17:23

Floor 2:6, 2:32

Florida 2:26

flying 128:20

focus 14:3, 113:4, 156:7

focused 70:23, 78:2

focusing 71:1

fold 15:22

follow 106:24, 125:11

followed 54:17, 113:7

followers 22:11

following 37:18, 66:9

fomenting 149:16

Food 15:16, 71:22, 104:23, 

105:3, 105:8, 105:12, 105:17, 

107:4, 127:10, 130:12, 

130:20, 130:21, 131:9, 

131:23, 132:17, 134:12

foot 141:25

forbid 34:18

forbidden 140:16

forbids 145:13

force 48:1, 48:3

foregoing 161:7

foregoing-styled 161:4

Foreign 8:11, 95:4, 95:12, 

98:6, 137:22

foreign-based 95:6

foreign-sounding 7:8

foreigners 14:5

forgiveness 33:12

forgot 46:9, 87:10

forgotten 110:9

form 11:6, 11:25, 19:24, 

24:10, 25:17, 28:17, 32:22, 

36:24, 37:3, 116:8, 124:8

formal 144:16

format 161:10

formation 20:7, 23:20

formed 9:12, 9:18, 10:3, 

10:4, 11:9, 11:16, 18:14, 

19:4, 20:2, 22:3, 22:15, 24:7, 

24:17, 25:4, 42:16, 73:11, 

85:1, 87:7

former 107:8, 133:6, 144:14, 

145:20

forming 73:4

Fort 3:8

forth 41:3, 41:6, 51:15, 

54:18, 79:8, 83:9, 89:23, 

114:10

fortified 25:12

fortunate 108:9

fortunately 130:14

forty 109:23

Forty-five 102:19, 102:21, 

102:22

forward 94:24, 121:24, 126:2

forwarded 78:22

Fouad 91:8

found 16:20, 21:14, 47:5, 

48:14, 53:4, 54:2, 54:16, 

61:10, 61:21, 62:7, 67:18, 

75:10, 80:5, 80:22, 81:3, 

81:9, 82:20, 83:20, 83:23, 

84:2, 88:7, 89:12, 89:19, 

89:20, 90:22, 91:18, 95:24, 

115:20, 115:23, 131:1, 

144:10, 153:12, 154:10

Foundation. 64:11

founded 87:4, 90:4

founder 50:17, 56:5

founders 38:2, 57:9, 86:1, 

135:16

four 6:8, 40:13, 76:9, 105:2, 

105:8

four-hour 6:11

fraction 133:12

frame 23:25, 83:25, 89:23

France 72:14

Francisco 2:33

frankly 149:6

free 5:14, 21:6

FREEDMAN 1:43

Freedom 52:1, 52:2, 125:19, 

125:19, 125:20

Friday 5:6

friendly 128:16

Front 42:8, 58:17, 59:9, 

60:16, 60:18, 61:9, 61:11, 

115:25, 125:2, 153:1

frozen 96:8

FTO 95:8

fugitives 23:2

fulfill 99:5

full 4:14, 133:11

function 39:17, 69:21

functions 49:8

Fund 18:19, 24:23, 24:24, 

25:25, 26:1, 26:16, 27:18, 

30:8, 37:25, 38:4, 54:8, 54:8, 

54:9, 54:13, 55:25, 64:21, 

65:12, 66:17, 67:3, 72:22, 

73:2, 73:2, 100:15, 114:14, 

114:17, 115:13, 128:1

Fund. 66:15, 100:14

funding 149:3

fundraiser 40:15, 58:8, 

59:17, 59:22

fundraisers 59:20

fundraising 28:21, 39:22, 

55:25, 59:25, 62:6, 64:25, 

110:10, 115:4, 115:6, 129:23

funds 7:19, 8:12, 19:6, 

20:18, 38:3, 56:19, 56:22, 

57:23, 59:6, 59:19, 60:3, 

61:14, 62:2, 62:21, 63:13, 

63:22, 64:12, 64:17, 64:18, 

65:18, 66:19, 68:9, 69:9, 

72:9, 79:20, 93:6, 130:7

funnel 74:11

furniture 134:2

furthered 71:20

Future 37:17

< G >

Gail 62:17, 101:5

gain 100:1

Garrett 1:28, 79:5, 154:13, 

156:8

gasoline 63:25

gathers 17:7

gave 9:3, 41:8, 41:11, 41:14, 

41:17, 48:8, 74:22, 86:18, 

102:14, 109:3, 111:12, 112:2, 

118:11, 118:12, 118:17, 

119:3, 143:25, 150:6

Gaza 9:20, 9:23, 10:4, 10:8, 

11:25, 13:4, 17:16, 17:18, 

19:16, 55:17, 56:6, 56:8, 

57:10, 70:15, 71:19, 72:5, 

73:14, 73:21, 74:6, 78:21, 

93:23, 99:6, 128:18, 130:20, 

131:3, 131:23, 132:8, 132:13, 

CASSIDI L. CASEY, CSR, 214-354-3139

UNITED STATES DISTRICT COURT

173
134:16, 137:10, 140:6, 

140:11, 149:24

geared 62:23

gee 130:7

General 24:7, 24:11, 25:25, 

36:19, 133:6, 139:18, 148:19

generations 133:16

Gentlemen 4:2, 6:9, 6:22, 

46:2, 64:2, 75:23, 77:24, 

87:15, 102:1, 103:10, 104:1, 

106:1, 110:17, 127:16, 136:2, 

136:8, 155:5, 155:16, 157:8, 

157:17, 158:3

George 142:22

Germany 72:14

gets 130:8

getting 14:12, 59:18, 75:1, 

92:2, 141:12

Ghassan 7:24, 18:16, 18:20, 

18:25, 19:2, 21:11, 31:13, 

31:15, 56:7, 70:7, 72:25, 

72:25, 84:17, 84:25, 85:6, 

85:9, 95:25, 96:12, 96:19, 

98:23, 108:4, 119:24, 145:1

Ghousbeh 61:4

girl 63:25

Give 4:5, 4:19, 6:1, 6:13, 9:7, 

15:24, 21:3, 21:15, 32:15, 

61:15, 64:10, 64:20, 65:16, 

82:11, 95:17, 97:2, 97:23, 

98:2, 106:21, 108:6, 108:8, 

110:4, 113:14, 113:19, 114:5, 

115:10, 118:9, 118:10, 

123:13, 126:23, 129:2, 

133:15, 133:24, 134:21, 

141:19, 142:8, 143:23, 

144:22, 151:21, 155:3

given 4:8, 4:24, 16:6, 

122:24, 157:24

gives 17:6, 41:20, 63:19, 

157:5

Giving 17:3, 41:4, 41:7, 

48:15, 62:12, 62:13, 66:3, 

69:14, 95:19, 138:16

Global 29:3, 95:4

glory 94:18

goal 12:20, 12:21, 16:16, 

26:21, 72:6, 99:8, 120:24, 

125:5

goals 9:13, 35:3, 45:10, 

72:16, 73:6, 82:22, 98:13

God 23:23, 34:18, 45:23, 

66:12, 67:9, 69:1, 100:4, 

125:2

Government..........................

................6 160:3

grace 23:23

grand 25:12, 68:23

granted 68:8

grass 10:19

green 50:19

greetings 49:11, 49:21, 50:4

GREG 3:4

grew 9:18, 10:5

grind 143:2

ground 11:3, 17:16, 66:5

Group 9:12, 15:13, 34:1, 

49:4, 49:9, 53:17, 53:22, 

54:1, 54:11

groups 11:4, 11:4, 17:9, 

22:15, 95:12

grow 16:12

guaranteed. 86:23

guarantees 125:18, 125:21

guess 97:7

guests 57:25

Guidance 24:8

guilty 52:14, 101:25, 135:9, 

135:11, 152:4, 153:14, 

155:12, 155:13, 156:16, 

157:15

guise 54:22

gun 51:3, 81:8, 83:24, 83:25, 

94:7, 94:20

guns 16:20, 93:18

guy 47:3, 58:9, 69:4, 143:11

guys 7:1, 8:6, 19:3

< H >

Haitham 139:7

half 4:13, 22:1, 22:20, 53:24, 

77:2, 78:25, 82:2, 100:3, 

102:14, 102:16, 102:25, 

105:25, 107:20, 158:4

Hamas-controlled 81:24, 

93:9, 152:7

Hamas-run 16:23

Hamas-supported 80:9

HAMAS. 22:4, 25:15, 33:5, 

36:12, 43:21, 51:13, 63:2, 

101:10

Hamdam 82:9

Hamed 63:25, 79:17, 79:20, 

80:12, 81:15

Hammami 38:1, 38:17, 

38:25, 39:1

Hammimi 38:2, 39:8, 39:11, 

57:8, 57:12, 79:19, 85:15, 

85:16, 85:17, 85:22, 85:24, 

85:24, 85:25, 86:6, 135:15, 

135:22, 135:25, 136:1, 

146:23

hand 83:24, 84:1, 153:23

handful 150:24

handing 91:24

handle 38:24

hands 68:25, 68:25, 93:19

handwritten 115:12, 115:20, 

116:1

happen 39:13, 122:6, 157:7

happened 10:12, 10:18, 

34:3, 34:12, 38:12, 45:7, 

45:10, 48:7, 64:9, 105:9, 

105:11, 109:15, 114:6, 

126:16, 134:6, 152:15

happening 10:14, 57:11, 

112:8, 118:5

happens 5:1, 65:8

happy 39:10

hard 118:3

hardships 109:9

harm 127:10

Harmas 84:18, 85:6, 85:9

harms 84:25

harsh 127:12

harshness 127:14

Hatch 18:7, 61:1

hate 101:10

hated 67:24

hates 141:10

haunt 129:1

Hayzum 43:18

head 50:19, 52:18, 121:9

Health 131:24

hear 4:16, 5:23, 5:24, 6:17, 

103:1, 114:5, 126:21, 139:1, 

145:22

hearing 103:13, 103:19, 

137:8, 150:1

CASSIDI L. CASEY, CSR, 214-354-3139

UNITED STATES DISTRICT COURT

174
heart 100:6

hearts 15:15, 16:5, 92:2, 

92:3

Hebron 74:6, 87:25, 88:23, 

89:1, 89:4, 89:22, 89:25, 

90:1, 90:1, 90:7, 90:20, 

90:21, 90:25, 140:10

held 49:6

help 14:17, 14:20, 15:23, 

15:24, 16:5, 16:6, 16:14, 

30:12, 35:11, 36:15, 45:18, 

56:11, 69:23, 73:23, 73:24, 

79:21, 99:21, 99:25, 101:18, 

106:25, 107:9, 119:12, 132:9, 

146:19, 147:6, 150:22

helped 72:17, 73:11, 105:21

Helping 16:15, 70:23, 75:3, 

75:4, 101:24

helps 16:6, 16:18

heritage 109:15

Heroic 45:1, 45:2

Heroism. 66:1

Herzallah 132:4, 132:13

hesitate 135:7, 156:15

hesitation 153:20, 153:21

hidden 89:18

hide 16:1, 110:14

high 155:10, 155:19, 157:3

higher 23:13

highest 153:22

highlighted 99:23, 114:13

highlights 31:23, 31:23

hire 49:7

hired 55:3, 107:8, 145:20

history 20:25, 126:5, 133:4

hit 31:22, 31:23

hold 49:7, 68:3, 156:24, 

157:2

holding 81:8, 83:24, 83:25, 

90:16, 157:3

hole 148:14

holes 148:1

holiday 130:22, 130:22

Hollander 1:41, 1:44, 19:9, 

66:25, 71:21, 99:3, 102:9, 

103:2, 103:4, 103:19, 103:20, 

158:3

Home 6:22, 20:21, 21:1, 

26:14, 28:6, 28:7, 39:11, 

46:19, 50:5, 56:25, 60:10, 

62:8, 69:18, 96:3, 113:11, 

138:24, 138:25

homeland 66:10, 123:2, 

123:2, 150:22

homeowner 47:2

Homes 132:23, 132:24, 

133:1, 133:1, 133:7, 133:16, 

133:25, 150:17

honesty 151:22

Honor 6:4, 6:7, 6:15, 7:2, 

32:19, 45:24, 75:21, 76:7, 

77:6, 77:15, 77:18, 77:25, 

103:3, 103:23, 157:16, 

158:13, 159:2

HONORABLE 1:18, 67:10, 

85:9

honored 57:25

hope 4:3, 23:6, 104:17, 

120:19, 144:23

hoped 117:14, 117:14

hoping 116:8

Hospital 16:22, 31:19, 84:8, 

92:12, 92:12, 138:21, 140:11, 

142:8, 142:12

hospitals 15:17, 16:23, 

73:18

Hotel 30:19, 31:10, 31:16, 

117:6, 121:25

hounded 112:4

hour 77:1, 102:13, 102:16, 

102:25, 107:20

hours 4:10, 4:14, 5:22, 6:8, 

76:2, 76:9, 103:16, 105:25, 

107:21, 109:23, 158:4

House 15:25, 27:6, 33:21, 

68:25, 115:21, 115:24, 116:2, 

121:6, 135:6

housekeeping 158:7

houses 107:6, 133:13, 

133:22, 134:2

hue 37:4

huge 153:18

human 99:12, 99:16

Humanitarian 15:16, 27:16

hundred 41:7, 63:17, 

118:10, 118:11, 119:2, 119:7, 

131:15, 141:4

hundreds 73:20, 104:21, 

154:24, 154:24

hung 7:12, 27:7

hungry 105:14

hypocrisy 124:17

< I >

IAP 20:6, 20:8, 20:10, 20:12, 

24:4, 25:6, 26:16, 28:19, 

29:16, 29:17, 29:22, 29:23, 

36:17, 37:11, 37:18, 40:13, 

43:13, 44:10, 44:22, 45:6, 

46:8, 47:16, 48:16, 50:10, 

53:2, 65:19, 110:7, 110:11, 

110:13

Ibrahim 42:25, 61:4

idea 6:5, 124:23

ideas 124:12

identification 83:15, 83:18

identified 22:6, 60:22, 72:7, 

72:12, 74:15, 74:16, 79:15, 

80:19, 85:6, 86:4, 88:24, 

89:5, 91:11, 91:13, 91:15, 

96:15, 131:19, 131:24

identifies 18:7, 81:15, 91:9

identify 18:10, 71:14, 90:19

identifying 75:6, 75:18, 

79:25, 87:16, 87:17, 90:24

ideologically 146:2

ignore 150:12

ignored 117:11

Ikhwan 22:10, 68:22

Ila 43:14, 43:15, 65:18, 

65:21, 66:23, 66:24, 69:13, 

101:8

illegal 28:24, 44:10, 44:13, 

94:25, 97:2, 98:2

ILS 87:2

Imad 43:8

image 66:18

Imagine 147:15

impartial 134:23, 143:4

Implementation 53:16

implemented 54:7, 55:8, 

73:17

implication 95:14

importance 149:9

Important 28:9, 35:1, 38:19, 

109:19, 112:18, 118:14, 

119:21, 121:23, 125:12, 

126:11, 127:24, 135:2, 

140:15, 144:22, 145:8, 

CASSIDI L. CASEY, CSR, 214-354-3139

UNITED STATES DISTRICT COURT

175
148:16, 153:21, 155:11, 

156:18, 157:4

importantly 68:2

impossible 125:4

impression 114:4, 117:17, 

123:21, 129:12, 132:16, 

133:25

impressionable 94:7

in. 51:24, 89:14, 93:2

incentive 140:22

inception 19:4

incestuous 42:11

incident 16:20

include 135:21

included 87:2, 147:25, 

148:14

including 9:19, 11:14, 72:8, 

72:13, 75:14, 81:13, 83:15, 

85:9, 120:21, 122:15, 142:17

incomplete 134:5

inconsistent 114:4

increase 22:22, 23:16, 73:7, 

120:23

increasing 120:16

incredible 52:2

incriminating 47:10

independent 26:18, 30:9, 

38:8, 38:10, 81:10

independently 121:16

Indiana 18:16

indicating 45:13

indictment 76:13, 98:5, 

98:21, 112:20, 113:23, 

117:18, 118:15, 136:20, 

138:3, 141:24, 143:18

indictment. 113:23

indirect 78:17, 78:20

individual 46:23, 47:11, 

51:8, 57:6, 60:21, 80:9, 

80:24, 82:8, 87:19, 89:8, 

89:20, 96:7, 97:12, 154:4

individually 52:21, 154:17

individuals 60:14, 61:12, 

61:12, 79:17, 80:7, 80:15, 

83:12, 83:18, 89:5, 154:25

influence 127:4, 151:16

Infocom 21:10, 21:14, 53:4, 

54:3, 54:16, 54:22, 54:23, 

95:25, 113:8

Information 110:24, 122:10, 

130:18, 133:24, 136:4, 

139:24, 140:2

infrastructure 83:3

Initially 6:2, 17:18, 18:15, 

36:5, 58:2, 74:20

Initiatives 12:16, 12:23

injured 23:1, 45:14

innocence 135:10, 135:11

innocent 152:18

inquire. 32:23

inquiring 32:25

Insallah 67:22

inside 17:14, 17:15, 22:10, 

22:12, 22:15, 22:23, 73:9, 

139:1, 141:25

inside. 73:8

insist 32:18

insofar 102:2, 157:18

instance 117:15

Instead 9:15, 131:1, 150:13

institution 42:17, 42:19, 

126:25

institutions 10:9, 10:11, 

11:9, 11:10, 11:11

instruct 113:18, 125:17, 

135:8, 145:7

instruction 126:10, 134:21, 

145:8, 151:21, 158:22

instructions 4:19, 4:21, 

4:24, 6:1, 77:8, 113:19, 

157:24

insure 104:11, 109:12

intellectuals 32:5

intelligence 139:21, 139:22, 

140:1, 151:14, 151:17, 

151:19, 152:2, 152:3, 156:1

intended 109:1, 145:20

intent 145:13

intention 145:19

intentions 101:17

intercede 38:18

intercedes 38:13

interceding 39:15, 39:15

intercepted 46:13

interest 44:18, 44:19, 127:6, 

151:24

interested 116:14

interesting 149:8

interests 126:13

interfered 146:4

interfering 146:17

internal 75:15, 89:15, 89:16

International 12:17, 19:23, 

24:9, 24:13, 25:3, 104:25, 

105:1, 105:11, 142:7

internationally 24:21

internet 15:4, 139:24

INTERPAL 72:13, 138:14, 

148:3

interpretation 5:13

interrupt 6:10, 34:9, 34:11, 

102:3, 157:19

inters 150:19

interview 69:17, 69:25, 71:1, 

114:23

interviewed 57:7

interviews 83:15

Intifada 10:22, 10:23, 10:23, 

10:24, 11:3, 11:12, 19:22, 

22:22, 24:5, 65:24, 66:10, 

66:14, 109:17, 128:17

introduced 129:7, 129:12, 

129:23, 131:8, 136:9

introducing 57:23

investigation 146:17, 146:25

invitation 87:20

invite 31:22

inviting 43:5

invoice 55:2

involved 11:2, 11:3, 82:13, 

91:15, 125:24

involving 63:23, 63:24, 64:2

Iran 18:1, 43:9, 43:10

IRS 100:21

ISA 72:3, 150:18

Islam 12:7, 25:10, 108:14, 

120:23, 142:24

Islamism 120:10

Islamist 120:14, 120:15, 

121:8

Islamists 81:17, 92:17, 

118:9, 118:11, 119:23, 

119:24, 120:2, 120:6, 120:7, 

120:7, 120:21, 121:3, 121:11, 

121:11, 121:12

Ismail 20:21, 26:14, 27:5, 

50:6

Israeli 11:15, 15:8, 45:7, 

51:19, 62:11, 87:2, 107:17, 

123:8, 140:1, 149:16, 151:19, 

CASSIDI L. CASEY, CSR, 214-354-3139

UNITED STATES DISTRICT COURT

176
152:3, 156:1, 156:3

Israelis 14:5, 14:10, 33:23, 

83:23, 110:24, 128:19, 

150:25, 151:15

issue 8:25, 9:2, 15:1, 20:11, 

65:21, 71:3, 77:9, 77:19

issues 25:24, 31:2, 43:16, 

54:12, 55:23

items 47:4, 47:5, 90:22, 

150:24

itself 9:9, 97:6, 98:18, 99:2

Izz 13:20

< J >

J. 2:4

Jacks 1:25, 9:1, 118:14, 

158:13, 158:15

jail 128:21

Jamil 38:1, 57:8, 57:12, 

85:15, 85:16, 85:22, 85:23, 

85:25, 86:6, 135:15, 135:22, 

146:23

January 45:12, 117:21

jar 62:12

Jazeera 149:11, 149:12, 

149:15, 149:18, 150:7

Jenin 7:15, 7:17, 74:5, 91:1, 

91:3, 91:5, 91:6, 91:7, 91:9, 

91:22, 91:25, 92:8, 92:10, 

92:11, 92:12, 92:13, 92:20, 

92:22, 93:14, 93:17, 123:4, 

140:12, 142:8

Jerry 97:20

Jersey 19:7, 44:6, 67:18, 

68:11, 99:20

Jerusalem 30:7, 44:25, 86:7, 

105:5, 117:6, 120:11, 139:18

Jerusalem. 45:2

Jewish/christian 67:21

Jews 61:23

Jihad 12:8, 12:9, 12:23, 

13:5, 13:5, 16:17, 23:7, 23:8, 

23:10, 35:2, 35:6, 35:6, 35:6, 

46:17, 48:16, 65:7, 65:8, 

65:15, 66:4, 66:6, 66:12, 

68:23, 69:12, 69:15, 69:16, 

69:20, 69:23, 71:6, 75:2, 

78:5, 94:6, 99:9, 101:21

Jihad. 35:5

Jihadist 45:1, 45:2, 68:21

JIM 1:25

job 64:17, 127:1, 140:4, 

140:7

JOE 1:18

John 2:29, 107:9, 107:11, 

107:15, 144:13

join 16:7, 16:7

joined 37:19

joins 37:11

joint 32:20, 104:24

Jonas 1:26, 6:5, 6:13, 39:6, 

42:25, 46:5, 51:18, 76:1, 

77:24, 105:24, 109:21, 110:1, 

110:8, 110:14, 110:15, 111:4, 

111:7, 112:18, 113:6, 114:7, 

114:20, 115:2, 115:5, 123:16, 

123:24, 124:7, 124:20, 

125:14, 130:2, 135:23, 

136:16, 138:19, 143:24, 

147:23

Jones 2:30, 97:20

Jordan 10:1, 17:19, 60:17, 

60:19, 122:20

JOSHUA 2:3, 2:5

Judge 113:17, 134:21, 

135:8, 145:7, 151:21, 153:1, 

153:24

judgment 126:23

Judicial 161:11

July 104:2, 116:24

jumped 49:13

June 116:2, 116:3, 116:20

juror 52:8

jurors 157:25

Jury 6:22, 7:1, 75:25, 77:8, 

102:8, 111:5, 158:2, 158:22

juryroom 5:2, 53:20, 84:4, 

104:20, 144:24, 145:15

JUSTICE 1:30, 124:17, 

124:18, 124:18, 156:25, 

157:4, 157:14

justice. 124:19

justify 149:18, 156:20

< K >

Kamal 132:19

Keep 5:10, 7:5, 8:2, 36:15, 

43:21, 104:9, 116:12, 120:5, 

126:15, 141:23, 145:8

keeps 149:2

kept 20:25, 68:12, 99:4

key 21:15, 81:1, 81:1, 154:18

Khairy 42:1, 42:5

Khalil 17:20, 17:21, 17:23, 

42:21, 43:1, 44:8, 69:15, 

69:17, 70:6, 71:1, 83:15, 

91:13, 146:23, 147:2, 147:3, 

147:4, 154:19

kick 125:9

kicked 17:19, 67:22

kidnapping 11:14, 45:6, 45:7

kids 16:11

kill 59:5

killed 45:9, 45:13, 64:23, 

152:16

killing 15:6, 52:7, 152:18

kills 51:19

kind 68:23, 100:6, 115:1, 

115:15, 135:5, 135:14, 152:5

kindergarten 16:11, 16:21, 

88:8, 90:13

kinship 109:15

Knocks 65:25

know. 133:2

knowing 152:1

knowingly 9:3

knowledge 77:10

known 10:22, 11:6, 13:22, 

22:19, 27:12, 36:25, 42:2, 

62:4, 64:4, 64:23, 86:19, 

89:21, 136:9, 149:13

knows 15:9, 116:17, 120:13, 

125:10, 149:9

Kurd 137:12

Kuwait 128:15

< L >

L. 2:5, 3:13, 161:3, 161:18

lack 77:9

ladder 94:18

Ladies 4:2, 6:9, 6:22, 46:2, 

75:23, 77:23, 102:1, 103:10, 

103:25, 106:1, 110:17, 

127:15, 155:16, 157:8, 

157:17, 158:3

Land. 67:12

Lands 67:23

CASSIDI L. CASEY, CSR, 214-354-3139

UNITED STATES DISTRICT COURT

177
language 68:2, 68:14, 69:3, 

77:14, 149:12

large 34:12, 71:19, 73:13, 

88:23

larger 45:18, 101:19

largest 92:11

Last 4:7, 4:7, 4:16, 14:13, 

23:15, 25:7, 25:9, 48:7, 54:6, 

63:8, 74:19, 80:12, 83:6, 

85:22, 89:8, 89:19, 91:1, 

102:24, 106:11, 130:10, 

136:19, 138:6, 141:2, 141:3, 

158:11

late 55:22, 111:25

Later 10:23, 19:6, 25:2, 

27:13, 59:4, 65:8, 76:22, 

77:21, 85:19, 116:24, 123:10, 

147:11, 151:1, 158:24

launchers 90:16

laundering 98:17, 155:14

laundry 134:15

Laura 121:4

LAW 2:5, 2:15, 2:24, 4:19, 

6:1, 9:15, 9:17, 44:19, 95:8, 

98:4, 98:5, 106:24, 107:10, 

108:5, 125:8, 125:10, 125:11, 

128:7, 128:7, 128:8, 145:6, 

145:13, 145:19, 153:23, 

156:23

law. 145:2, 145:14

lawn 33:21

laws 9:15, 9:16

lawsuit 29:13, 29:20, 31:11, 

31:12, 31:25, 41:11, 101:9

lawyers 155:17

lays 53:5

lead 114:9, 132:17

leader 10:21, 18:4, 18:10, 

26:25, 27:1, 28:2, 38:12, 

38:18, 41:9, 50:16, 55:6, 

56:5, 56:12, 60:25, 62:4, 

64:6, 64:7, 69:15, 83:16, 

90:22, 91:20, 121:18

leaders 7:14, 7:16, 7:22, 

32:5, 38:1, 42:21, 44:8, 

55:19, 60:18, 64:9, 70:9, 

72:10, 72:11, 79:14, 83:1, 

83:21, 84:2, 90:20, 91:7, 

91:17, 97:10

leadership 17:14, 17:15, 

17:15, 19:24, 24:2, 24:11, 

25:13, 66:2, 80:21

leading 23:3, 64:5, 71:13, 

121:8

leaps 22:14

Learn 100:14, 105:19

learned 108:5, 108:7, 

122:17, 133:3, 133:3

least 20:10, 39:18, 40:1, 

55:11, 86:19, 88:24, 91:11, 

91:16, 144:10, 144:13, 

146:18

leave 47:25, 48:1, 88:2, 

117:16, 134:5, 136:12, 

143:15

leaves 84:20

leaving 18:15, 100:8

Lebanon 10:1, 17:19, 22:7, 

79:24

lecture 48:8, 48:16

led 11:1, 45:9, 127:9

leeway 102:14

left 27:2, 49:17, 51:8, 57:8, 

57:17, 82:18, 84:18, 85:1, 

130:13, 133:23, 135:18, 

135:22, 135:23, 140:18, 

147:8

legitimate 98:25, 99:14, 

101:17, 152:20

legitimate. 99:17

leisure 144:7

less 14:22, 14:23, 16:21, 

17:1, 108:9

letter 18:6, 18:9, 38:15, 

38:16, 39:12, 60:25, 61:1, 

61:3, 67:17, 67:18, 67:19, 

67:25, 68:3, 68:8, 68:8, 

68:10, 68:12, 69:4

letters 67:6, 67:12, 67:15, 

71:7, 71:10, 79:7, 83:9, 

111:24

letting 92:3

lettuce 105:13

level 18:2, 22:15

levelling 46:24

liaison 22:11

liberating 66:6

libraries 15:17

library 105:18

LICENSE 161:22

licensed 104:12

lied 111:9, 113:1, 113:2

life 23:6, 65:7, 120:17, 

120:17, 120:23, 142:23, 

156:18

light 24:8

lighting 62:13

likely 5:10, 14:23, 16:22, 

17:1, 129:19

limits 158:5

LINDA 2:23, 2:24

line 46:14, 97:23, 97:24, 

97:25, 139:4, 143:5

link 113:15, 116:9, 118:16, 

119:2

linked 107:13, 116:10

list 28:7, 59:25, 60:5, 60:7, 

63:5, 63:5, 68:7, 68:13, 

95:15, 129:14, 129:19, 

136:15, 136:17, 136:18, 

136:21, 138:7, 138:13, 

139:15, 141:7, 143:19, 

143:23, 144:4, 144:19, 

144:20, 144:21, 146:6, 

146:12, 146:15, 147:7, 147:8, 

147:13, 150:14, 154:7, 154:8, 

158:14

listed 27:17

Listen 38:20, 63:17, 65:14, 

65:14, 65:15

listened 157:9

listening 55:4, 55:6, 70:2, 

118:5, 138:18, 152:12

listing 61:10, 82:3, 82:4

lists 26:22, 53:21, 54:12, 

60:6, 98:20, 137:1, 138:10

Little 16:11, 23:13, 62:6, 

76:7, 94:3, 105:17, 110:3, 

122:9, 123:3, 123:4, 123:5, 

124:21, 144:4, 150:20

live 60:1, 120:25, 127:20, 

134:14

lived 20:23, 128:15

lives 46:23, 134:14

living 12:2, 13:4, 15:5, 

17:18, 17:19, 18:16, 95:16, 

127:11, 127:17, 134:12

lobbying 40:15

located 14:7, 21:12, 72:4, 

73:14

CASSIDI L. CASEY, CSR, 214-354-3139

UNITED STATES DISTRICT COURT

178
location 16:3, 16:4, 31:1

locations 99:7

lock 128:19

logo 131:18

London 72:13

long 96:25, 98:10, 98:11

longer 120:15, 137:5

looked 44:7, 75:13, 75:15, 

77:11

Looking 27:15, 52:11, 57:5

looks 148:17, 149:25

Los 18:16, 18:19, 57:10, 

64:25

lose 11:3

lot 7:7, 8:23, 21:13, 22:25, 

27:8, 29:23, 60:23, 70:10, 

78:6, 86:14, 92:19, 92:21, 

95:1, 97:3, 108:7, 120:13, 

123:17, 136:11, 136:14

Lots 118:2, 123:14

low 152:25, 154:10, 155:8

loyalty 17:7, 92:2

lull 147:10

lunch 6:16, 75:24, 77:21, 

78:1

luncheon 6:12

lying 96:2, 113:24

< M >

ma'am 103:24

magazine 43:13, 43:14, 

43:16, 44:2, 65:19, 66:23, 

69:13, 101:8

Maghawri 139:8

Mahmoud 67:24

Mahmud 55:19, 55:19, 57:6, 

59:15, 114:22

mailing 68:7, 68:13

main 8:25, 33:19, 68:5, 72:6, 

92:9

maintained 127:2

major 44:8

majority 120:20

makers 151:17

Mallick 3:6

man 10:6, 28:6, 43:25, 58:9, 

61:18, 64:22, 65:14, 65:14, 

65:15, 68:6, 70:5, 81:15, 

90:20, 91:8, 91:8, 108:6, 

121:7, 131:24, 135:15, 

137:11

man. 85:10

manage 21:20

manager 131:22

manipulate 146:19, 147:5

manner 32:18, 53:6, 53:7, 

53:11, 72:15

mantra 53:10

Manual 53:16, 54:10, 54:24

map 9:21, 123:4

March 66:4, 146:21

Marked 37:1, 37:1, 60:8

marked. 37:1

MARLO 2:14, 2:15

marriage 70:7

Marriott 30:19, 121:25

martyrs 23:1, 49:1, 70:20, 

70:21, 71:2, 71:4, 71:8, 

71:11, 78:4

masks 51:1

masters 100:14

match 62:13

matched 130:16

material 44:11, 48:14, 

108:22, 109:2, 113:3, 117:12, 

117:13, 142:8, 155:12

materials 75:13

matter 96:24, 158:7

maximum 4:10, 66:13

Mcgonigle 55:16, 55:20, 

55:24, 56:4, 56:8, 56:10, 

57:6, 100:18, 114:24, 114:24, 

115:3

Mckinney 2:16

meal 14:13

mean 5:6, 32:22, 33:9, 

75:12, 86:10, 105:12, 124:15, 

154:15

meaning 12:12, 12:13

means 4:15, 13:6, 16:16, 

16:16, 21:20, 33:12, 68:22, 

78:18, 95:2, 97:22, 98:8, 

108:8, 138:7, 140:2, 145:12, 

146:18, 154:25, 155:5

meant 105:6, 105:14

measures 34:21, 54:18, 

56:17, 113:8

media 20:11, 24:4, 28:20, 

40:14, 43:13

medical 55:22, 55:23

meet 153:13, 155:7, 158:23

Meeting 32:3, 32:4, 32:6, 

32:8, 32:9, 32:12, 32:17, 

33:17, 33:20, 34:14, 37:14, 

37:15, 39:4, 53:2, 100:19, 

100:25, 101:3, 112:21, 118:7, 

118:25, 120:2, 120:19, 122:2, 

122:11, 124:3, 124:24, 

125:24, 126:16, 126:21, 

127:23, 128:11

meetings 30:16

meets 154:11

member 20:22, 30:24, 48:17, 

58:1, 81:2, 82:12, 85:6, 

89:21, 91:6, 95:9, 121:6, 

121:19

mementos 134:2

memo 67:14

memories 136:12

memory 5:15, 111:11, 115:9

men 14:5, 14:19, 51:3, 

122:11, 141:13, 143:5, 154:6

mention 8:15, 32:17, 33:7, 

37:6, 46:9, 54:20, 82:18, 

113:9

mentioned 37:23, 46:11, 

79:17, 113:6, 118:20, 138:20

mentions 116:4

mere 126:11

merge 121:13

message 67:3, 67:5, 69:5

messages 16:25

met 24:11, 55:18, 55:21, 

62:4, 115:2, 115:4, 121:5, 

121:7, 158:13

method 21:19

Mezain 96:6

mid-afternoon 102:5

mid-morning 6:12, 45:25

Middle 13:16, 17:10, 45:3, 

57:5, 66:1, 66:7, 120:12

Midst 45:1

Mike 14:6

Military 13:11, 13:17, 13:20, 

13:23, 14:2, 14:3, 14:4, 14:8, 

14:19, 16:3, 16:7, 16:18, 

17:2, 17:4, 17:6, 17:12, 

22:18, 58:1, 64:5, 71:13, 

75:4, 80:24, 80:25, 81:2, 

CASSIDI L. CASEY, CSR, 214-354-3139

UNITED STATES DISTRICT COURT

179
81:6, 81:7, 82:8, 82:11, 

82:13, 83:20, 90:8, 91:14, 

91:15, 128:15, 151:1

milk 107:5

million 74:22, 78:25, 82:2, 

89:3

millions 69:9, 70:16

mind 5:10, 7:6, 8:2, 43:21, 

52:4, 52:6, 116:12, 126:15, 

141:23, 145:8

minds 15:15, 16:5, 92:2, 

92:3

mine 103:5

Minister 104:4, 104:9, 123:9, 

131:24

ministered 17:5

minute 90:17, 104:16, 

112:22, 138:1

minutes 13:2, 75:22, 76:2, 

91:9, 100:19, 100:21, 100:23, 

100:24, 101:2, 101:3, 102:19, 

102:21, 102:22, 109:23

Miranda 54:19, 60:4, 60:13, 

110:22, 129:13, 129:15, 

129:25, 135:18, 137:7, 

141:17, 141:25, 146:20, 

156:2

miserable 68:25

Mishal 17:20, 17:21, 17:24, 

42:21, 43:1, 44:8, 69:15, 

69:17, 70:6, 71:1, 83:16, 

91:13, 146:23, 147:1, 147:2, 

147:3, 147:4, 154:19

misleading 117:16, 117:23, 

134:4, 135:13

misled 106:12

mission 56:18, 78:8

Mississippi 39:11

misspoke 80:14

mistranslation 120:3

model 49:1, 49:2

moderator 63:20, 64:10

modest 67:20

Mohamed 7:24, 18:21, 

18:24, 27:10, 28:12, 29:14, 

29:15, 31:9, 31:18, 39:21, 

40:3, 42:23, 42:25, 43:5, 

43:6, 44:17, 45:5, 46:7, 

46:15, 47:20, 48:8, 57:4, 

57:23, 87:13, 99:20

Mohammad 108:13

Mohammed 62:3, 62:6, 

63:24, 80:10, 80:16, 91:8, 

91:10, 96:6, 131:19, 131:23

moment 13:19, 31:11

moments 9:8, 10:11, 37:23

money-changing 132:4

monies 139:8

month 33:20, 107:3, 116:24, 

127:23, 130:23, 138:6

months 7:4, 9:1, 37:15

moral 8:6, 23:16

Moreno 2:23, 2:24, 102:24, 

108:2

Morning 4:2, 6:15, 6:23, 

27:14, 55:16, 88:17, 103:16, 

105:24, 109:21, 112:19, 

114:25, 139:19, 158:1, 

158:25

Moslem 19:23, 23:5

mosque 16:25

mosques 15:17, 16:23, 

73:19

mother 23:5, 35:9, 35:10

mothers 107:5

Mousa 17:20, 17:22, 18:3, 

18:7, 18:7, 18:10, 26:24, 

26:25, 26:25, 27:4, 27:4, 

28:12, 38:12, 49:11, 49:22, 

50:1, 60:24, 64:3, 64:6, 70:7, 

154:19

moustache 143:12

move 23:22, 107:20, 126:2

moved 58:5

Movement 11:6, 11:7, 21:21, 

22:8, 22:11, 22:24, 23:3, 

23:4, 23:5, 23:24, 24:2, 24:6, 

24:9, 24:12, 24:20, 25:12, 

25:15, 26:7, 33:8, 33:8, 33:15

Movement. 22:21

movements. 21:25

moves 18:19, 66:3

moving 4:4

mowed 133:22

Ms. 1:27, 1:41, 1:42, 2:14, 

2:23, 19:9, 66:25, 71:21, 

99:3, 102:9, 102:18, 102:24, 

103:1, 103:4, 103:19, 103:20, 

108:2, 158:3, 158:13, 158:16, 

158:18

Mufid 2:11, 7:25, 19:5, 

31:17, 48:17, 48:20, 48:23, 

49:10, 49:16, 49:19, 50:3, 

50:8, 51:11, 52:6, 57:16, 

57:17, 58:11, 58:25, 59:11, 

59:21, 62:20, 70:5, 88:16

Muharam 131:23

Mujihadeen 13:23, 22:17, 

22:19, 67:11, 67:14

multiple 40:8, 61:11, 83:14, 

84:12

munitions 16:20

Mushtaha 46:19, 46:20, 

47:2, 47:2, 47:3, 56:25, 58:9, 

62:8

Muslim. 119:23, 119:25

Muslims 13:3, 64:14, 

120:22, 130:22

MYSLIWIEC 2:4

< N >

Nabil 89:7

Nablus 78:12, 78:15, 78:25, 

79:3, 79:8, 79:12, 80:13, 

80:19, 80:23, 81:9, 81:13, 

81:17, 123:5, 140:11, 142:18

name 7:13, 7:21, 10:6, 10:7, 

13:21, 13:23, 24:25, 25:1, 

27:9, 27:13, 30:8, 32:18, 

33:8, 37:5, 37:23, 42:5, 43:1, 

43:2, 58:5, 60:23, 61:3, 

66:15, 66:22, 68:7, 79:18, 

80:18, 89:7, 89:8, 113:9, 

117:3

named 28:6, 38:1, 61:18, 

64:22, 82:9, 89:20, 91:8, 

129:9, 135:15, 137:11, 138:3

names 7:8, 7:9, 7:15, 7:16, 

7:18, 7:22, 7:25, 22:17, 

25:22, 26:13, 27:7, 27:8, 

27:13, 27:16, 27:20, 27:22, 

27:24, 27:25, 28:1, 28:3, 

46:20, 60:10, 61:6, 74:7, 

79:17, 80:17, 110:18, 122:1, 

129:15, 144:4, 144:6

names. 22:18

NANCY 1:41

NATHAN 1:28

nation 23:6

CASSIDI L. CASEY, CSR, 214-354-3139

UNITED STATES DISTRICT COURT

180
national 99:12, 152:10

nationalities 19:20

Natsheh 89:7, 89:9, 89:20, 

90:20

natural 109:10

nature 29:24, 55:13, 137:18, 

148:11, 149:2

neatly 117:2

necessarily 5:7, 126:14

necessary 102:15

need 6:11, 6:16, 7:25, 15:10, 

15:23, 16:1, 16:2, 43:5, 99:4, 

99:4, 99:5, 104:7, 105:8, 

118:23, 136:13, 140:18, 

144:21, 145:25, 147:23, 

148:7, 156:16

needed 29:6, 105:19, 

106:24, 108:18, 130:17

needs 15:24, 16:3, 25:11, 

43:6, 106:18, 144:2

needy 101:18, 104:9, 104:15, 

111:23, 117:9

neither 129:5

Netanyahu 123:8

network 72:17, 72:18, 73:10

neutral 36:25, 124:9

New 2:7, 4:4, 17:22, 18:8, 

19:7, 22:8, 36:24, 44:6, 50:2, 

67:18, 68:11, 99:19, 117:5, 

124:7, 126:25

News 55:16, 111:24, 114:25

newspaper 44:7

newspapers 15:4, 107:12, 

126:7, 139:24

Next 4:5, 14:7, 47:22, 50:11, 

51:6, 54:5, 58:7, 58:10, 

58:19, 58:24, 59:2, 59:15, 

60:11, 61:6, 63:2, 66:7, 

69:24, 102:15, 102:18, 

102:20, 117:4, 122:6, 157:22

nice 115:18

nine 157:25

nineteen 76:2

nitric 62:13

NM 1:46

Nobody 133:22, 140:25

None 106:10, 107:3, 135:24, 

138:4, 143:24, 154:3, 154:8

nonopposition 124:14

nonreligious 121:19

noon 76:3

nor 106:14

normal 30:10

normally 4:13, 102:5

North 10:2, 23:18, 24:3, 

66:8, 68:20, 96:15, 107:14

NORTHERN 1:2, 1:31, 20:23, 

161:20

not-enough-time-in-the-day

144:12

note 104:21

notes 14:22, 104:18

Nothing 40:1, 105:16, 

113:23, 122:1, 134:18

Notice 48:10, 77:18, 115:7, 

122:4, 153:11

notify 68:5, 147:19

notion 23:6

NUMBER 1:5, 17:21, 17:21, 

17:23, 21:7, 23:14, 23:16, 

26:6, 27:5, 27:9, 27:10, 

27:16, 27:18, 37:13, 37:16, 

42:22, 42:23, 46:13, 53:25, 

54:5, 60:24, 61:4, 61:5, 61:6, 

61:18, 63:16, 63:17, 68:19, 

91:9, 128:12, 161:22

numbering 46:10

Numbers 28:9, 42:4, 60:10, 

60:11

NY 2:7

< O >

o'clock 158:1

oath 32:11

obey 145:20

objected 77:8

obliterates 12:7

observe 157:24

Obviously 33:10, 47:21, 

58:5, 59:21

occupation 22:25, 127:12, 

127:14

Occupied 18:18, 22:10, 

24:23, 24:24, 25:25, 26:16, 

27:18, 30:8, 54:9, 54:13, 

64:21, 65:11, 66:15, 66:17, 

67:3, 67:12, 72:22, 73:2, 

115:13

occupies 127:22, 150:15

occur 14:14

occurred 111:11

October 30:19, 41:19

ode 43:17, 43:24, 65:22, 

101:7

Odeh 3:1, 7:24, 19:7, 44:6, 

44:14, 45:20, 45:21, 45:21, 

48:13, 67:19, 68:5, 71:12, 

99:19, 99:24, 129:8, 129:8

OFAC 137:21, 148:9, 150:5

offense 113:22

offensive 97:23, 97:24, 

97:25

offer 77:18

offered 130:1

Office 2:5, 2:15, 2:24, 19:7, 

24:9, 24:18, 30:7, 44:7, 44:9, 

48:14, 67:18, 67:18, 68:5, 

89:20, 95:24, 96:2, 130:10, 

131:4, 131:14, 132:8, 137:22, 

137:22, 139:1, 139:6

Officer 19:1

officers 147:11, 155:2, 155:4

offices 55:5, 70:15, 71:18, 

80:5

official 32:22, 144:16, 161:5

officials 140:21, 154:19

Okay 53:18, 69:6, 76:21, 

142:16, 159:1

okay. 149:21

Oklahoma 99:21, 118:18, 

119:1, 119:4, 119:5, 119:8, 

119:14, 119:15, 119:16

old 14:4, 16:11, 49:5

OLF 64:20, 72:21, 115:15

Omar 27:12, 27:12, 30:22, 

32:8, 37:5, 39:20, 39:23, 

39:25, 40:4, 43:1, 100:9, 

100:13

omission 110:14

Once 14:16, 42:16, 55:10, 

55:21, 82:16, 83:8, 87:6, 

94:24, 110:15, 115:2, 118:18, 

123:24, 130:7, 148:22

ones 53:14, 55:14, 69:22, 

73:18, 104:22, 136:5, 138:5, 

141:6

ongoing 158:11

open 32:2, 104:10, 134:15, 

139:23

CASSIDI L. CASEY, CSR, 214-354-3139

UNITED STATES DISTRICT COURT

181
opened 19:7, 22:8

opening 11:13, 19:9, 30:7, 

51:25, 99:3, 103:11, 118:15

operate 8:8, 9:17, 53:11

operated 60:19, 72:15, 74:3, 

109:4

operating 55:7, 77:11

Operation 45:1, 45:2, 151:1

operation. 45:22

operations 48:15, 75:2, 

81:7, 151:2

opinion 36:23, 124:8, 

126:23, 132:22

opinions 12:18, 52:13

opportunity 4:8, 7:3, 99:22, 

124:13

oppose 122:15, 122:17

opposed 122:10, 122:11, 

122:12, 122:18, 122:23, 

123:14, 124:16, 124:16, 

140:20, 151:7

opposes 122:19, 122:21, 

140:19

opposition 122:7, 123:13, 

125:25

Order 13:19, 14:14, 22:3, 

34:22, 73:3, 74:4, 76:13, 

76:14, 76:15, 95:7, 95:23, 

95:24, 96:2, 98:1, 99:7, 

99:13, 99:16, 102:10, 148:15, 

148:24, 153:14

organizational 23:25, 26:12, 

27:15

organizations 20:5, 24:19, 

24:22, 36:17, 37:17, 37:18, 

40:13, 42:15, 54:13, 72:4, 

72:4, 72:8, 72:11, 72:12, 

72:13, 72:15, 73:12, 81:10, 

86:8, 89:2, 90:3, 93:9, 95:5, 

95:6, 104:4, 105:1, 105:2, 

105:8, 122:16, 146:7, 146:8, 

148:2, 148:25, 150:2, 150:10

original 23:3, 60:9, 95:10, 

115:18, 118:13

originally 24:25, 115:19, 

129:22

Orin 18:6, 61:1

orphan 108:11, 108:14

Orphans 71:9, 84:16, 84:17, 

84:21, 84:23, 85:2, 85:2, 

85:7, 85:12, 101:23, 101:24, 

107:2, 108:10, 108:14, 

132:10, 132:14

Oslo 12:24, 33:19, 33:21, 

33:22, 34:3, 34:5, 34:7, 

34:15, 35:8, 45:11, 61:23, 

99:15, 122:4, 122:7, 122:8, 

122:11, 122:11, 122:12, 

122:17, 122:18, 122:21, 

122:24, 122:25, 123:3, 

123:10, 123:12, 123:13, 

123:19

others 17:17, 19:21, 44:9, 

71:16, 115:10, 118:10, 

118:12, 154:6, 154:20, 

155:25

Otherwise 92:4, 143:9

ought 71:7, 124:11

ours. 89:25

outcome 151:24

outed 56:3

outlet 20:11, 24:4, 40:14, 

43:13

Outside 17:15, 17:17, 20:23, 

22:12, 22:23, 31:15, 42:5, 

46:23, 72:4, 73:10, 102:17, 

143:14

overnight 157:21

oversaw 20:5, 20:5, 20:13

overseas 28:19, 60:4, 85:25, 

93:2, 93:3

oversee 22:9, 25:6

overview 4:5

own 5:15, 49:3, 69:7, 70:24, 

74:16, 100:1, 109:7, 109:10, 

113:9, 113:10, 122:1, 128:2, 

148:10, 153:21

owned 132:4, 148:21

Oxford 39:11

< P >

P. 2:15

PA 121:2, 121:17, 131:25

Pages 161:7

paid 31:4, 78:24, 82:1, 

113:10, 119:13, 141:12

painstakingly 130:15

Pakistan 63:19

Pakistanis 19:21

Palestinian-americans

125:25

Palestinians 10:16, 11:8, 

13:4, 19:20, 33:24, 33:24, 

64:13, 117:9, 120:24, 122:14, 

122:23, 123:23, 130:12, 

140:7, 141:19

pamphlet 61:9

papers 31:12, 139:5

paragraph 21:17

parents 85:4

Paris 41:23

participants 34:24, 36:18, 

37:5

participate 51:24

particular 10:21, 32:6, 41:2, 

44:18, 74:2, 75:2, 75:6, 77:9, 

151:23

particularly 86:8, 112:18

parties 4:14, 127:2

partisan 127:4

parts 9:19

party 5:18, 121:19

party. 127:7

pass 155:4

passed 9:16, 95:8

passing 16:24

passport 113:10

past 7:4, 110:3, 118:11

patience 6:25

patient 155:16

Patterns 29:3

pay 31:6, 39:21, 39:24, 40:3, 

112:16, 112:22, 143:3

payment 40:25, 41:3, 78:18, 

81:19, 85:20, 98:12

Payments 40:21, 40:24, 

74:18, 78:14, 78:23, 79:1, 

81:22, 81:24, 83:6, 85:23, 

86:25, 88:25, 89:1, 89:2, 

91:2, 98:22, 98:25, 129:21, 

129:21, 131:8

pays 21:22

peace 12:19, 12:19, 12:20, 

12:25, 33:23, 34:2, 34:3, 

34:9, 34:12, 34:17, 34:18, 

35:11, 35:22, 35:24, 36:4, 

36:7, 36:8, 45:9, 124:14, 

124:16, 124:16, 124:17, 

124:18, 124:18, 124:19

CASSIDI L. CASEY, CSR, 214-354-3139

UNITED STATES DISTRICT COURT

182
Peaceful 12:17, 50:22

pending 146:24

per 4:11, 4:14

percent 105:7

percentage 73:23

perfect 104:9

perform 66:12, 67:10

Perhaps 108:15, 122:8, 

124:1, 154:14

period 12:20, 41:18, 41:20, 

112:20, 117:17

permit 123:1, 156:8

permits 133:15, 133:15

permitted 120:25, 120:25

Persistence 66:1

person 9:6, 16:1, 27:6, 33:5, 

33:7, 33:9, 33:10, 51:19, 

59:5, 63:14, 67:25, 68:13, 

80:12, 95:15, 97:15, 98:11, 

120:16, 124:6, 124:22, 126:4, 

126:5, 146:17, 148:20

personal 151:24

personally 110:12

persons 125:18, 126:12

persuasive 5:16

phase 4:4, 5:23

Phillips 97:20

philosophy 61:16, 64:16

Phone 28:1, 28:4, 28:7, 28:9, 

30:16, 35:14, 35:17, 38:14, 

39:20, 39:23, 39:23, 40:9, 

42:3, 42:4, 42:21, 43:7, 

46:12, 46:14, 46:17, 55:11, 

56:6, 59:23, 60:10, 60:24, 

61:5, 62:16, 62:24, 89:7, 

96:5, 96:8, 96:11, 129:16, 

129:23, 138:24, 138:25, 

139:4, 144:18

phones 112:5, 138:23, 139:2

photo 131:6

photographed 115:24, 116:1

photographs 28:6

photos 106:9, 134:2

pick 71:23

picture 17:13, 17:24, 18:2, 

31:14, 44:6, 50:17, 83:25, 

131:5, 133:12

pictures 89:22, 134:9, 

134:11, 151:6, 151:11

piece 103:5

pieces 137:1

pioneer 23:24

pious 120:14

pit 47:6

Place 14:6, 30:18, 31:21, 

47:17, 51:21, 57:9, 64:25, 

71:7, 90:2, 108:10, 117:19, 

119:24, 121:25, 128:16, 

156:17

placed 36:25, 66:25, 124:10

places 14:14, 17:23, 29:12, 

104:5, 108:14, 119:22

placing 66:21

Plan 24:20, 53:17, 101:19

planning 5:4, 82:9

plans 15:6, 33:2

PLATT 3:5

play 33:11, 39:3, 39:3, 45:25, 

46:18, 48:19, 49:12, 49:14, 

56:13, 56:22, 62:6, 62:17, 

65:3, 69:16, 81:4, 87:11, 

87:11, 88:3, 89:10, 90:10, 

96:11

player 100:10

playground 16:21

playing 33:14, 88:15, 100:17

plays 100:10

Plaza 1:45

pleasant 4:3

Please 6:19, 32:17, 32:22, 

63:2, 63:8, 83:7, 107:25, 

125:23, 126:15, 156:17, 

157:23

pledged 129:22

PLO 11:4, 33:25, 33:25, 

92:16

plot 61:23

plus 101:8

PO 2:25

poem 43:17, 43:20, 43:24, 

44:1, 48:13, 101:8

poin 36:4, 125:12

Point 6:6, 6:14, 7:7, 11:22, 

21:3, 68:11, 68:12, 78:16, 

79:3, 80:9, 90:17, 97:7, 

103:13, 118:9, 119:25, 122:3, 

122:6, 125:13, 129:11, 

133:23, 134:10, 152:13, 

153:8, 153:25, 155:11

pointed 46:10, 68:10, 115:5, 

118:7, 118:19, 129:18

pointing 86:14, 94:7

points 7:5, 110:14, 121:22, 

153:8

poison 62:14

police 83:17

policies 124:14

policy 151:17

Political 13:11, 13:16, 17:11, 

17:12, 17:13, 42:22, 63:20, 

64:7, 69:16, 89:13, 111:20, 

112:23, 121:18, 124:24, 

125:25, 126:8, 126:8, 126:23, 

126:24, 129:1

politics 100:12, 107:2, 

109:12, 125:1, 126:6, 126:19, 

127:9, 128:5, 143:14

poor 101:18, 104:4, 104:5, 

104:9, 111:22, 152:21

population 14:15, 92:3

portion 9:24, 103:12

position 18:24

possess 44:11, 44:13

possession 81:11, 131:6

possibility 73:3

possible 6:10, 102:2, 157:18

post 80:25

postcards 91:18, 91:19, 

91:21, 91:23, 91:24

poster 80:23, 83:24, 89:14

Posters 15:4, 75:10, 75:11, 

75:13, 80:23, 83:19, 83:20, 

83:21, 84:2, 89:13, 151:5, 

151:11

poverty 127:20

Power 79:3, 134:10

practice 121:1

praise 16:12

praising 15:5, 62:1

praying 61:22

preach 69:14

preached 46:18

premise 122:10

prepare 105:21

prepared 80:5

prescribed 161:11

presence 23:24, 90:3

present 35:19, 131:2, 134:4

presentation 79:4, 134:10, 

157:19, 157:22

CASSIDI L. CASEY, CSR, 214-354-3139

UNITED STATES DISTRICT COURT

183
presented 131:1

presents 122:9

President 26:15, 121:5, 

148:24

presidential 95:7, 96:2

press 15:1, 112:5, 137:12, 

137:13, 142:10, 145:23

presumption 135:10, 135:11

pretend 51:4, 53:1

pretending 51:9, 51:19, 

100:7

pretends 59:4

Pretty 23:19, 102:12, 107:20

prime 123:8

principal 124:19

principals 12:18

print 144:5

printing 107:12, 107:13

prior 20:7, 33:20, 47:2

prison 108:13

prisoners 70:20, 70:22, 

71:2, 71:5, 71:8, 71:11, 78:4

private 120:17, 156:17

probably 4:16, 5:8, 107:24, 

126:6, 128:11

problem 38:4, 110:15, 128:1, 

144:11

procedural 76:12

proceedings 161:4, 161:6

process 12:25, 34:9, 34:11, 

34:12, 35:12, 35:22, 35:24, 

68:20, 68:21, 146:19, 147:5, 

149:9, 158:11

produce 71:22, 105:13, 

129:12

produced 20:15, 129:4

professional 142:23

Professor 120:9, 120:9, 

120:14, 120:15, 121:15, 

123:19, 142:21, 143:13

professors 122:15

Program 98:25, 119:11

programs 117:8, 149:13

progress 158:8

project 104:24, 131:5, 131:9, 

131:10

projects 115:15

Projects. 132:23

prominent 64:13, 64:13, 

122:15

promise 123:9

promised 80:16

promises 34:11

Proof 5:19, 5:20, 126:14, 

134:24, 134:25, 152:25, 

153:17, 153:18, 153:19, 

155:10, 156:7

proper 133:15, 133:15

Prophet 108:13

proposals 12:23

propose 77:15

prosecute 146:20, 147:6, 

147:11

prosecuted 52:4, 112:6, 

112:23

prosecution 5:18, 108:23, 

111:6, 113:25, 115:11, 116:7, 

122:6, 130:18, 135:20, 

135:21, 154:2, 156:5, 156:15, 

156:19, 157:3

prosecutors 6:21, 117:10, 

130:11, 141:9, 150:11, 153:4, 

155:18

protected 126:2

protection 17:6

protesting 18:9, 61:2

proud 142:11

prove 23:2, 108:23, 108:25, 

109:2, 109:5, 155:22, 156:14

proved 153:16

proven 108:22, 113:5, 

145:16

provide 35:2, 94:25, 98:9, 

108:12, 108:18, 109:1, 117:9, 

127:10, 127:18, 127:22, 

128:9

provided 4:20, 22:24, 91:5, 

104:14, 108:19, 108:21, 

127:21, 128:10, 130:24, 

132:17, 133:24, 142:11

providing 52:11, 98:6, 104:3, 

105:2, 106:16, 109:11, 113:3, 

117:12, 117:13, 117:15, 

155:12

proving 130:9

public 14:14, 15:8, 29:6, 

29:9, 29:10, 30:1, 32:2, 

35:20, 35:24, 36:10, 36:13, 

44:4, 44:5, 51:23, 55:13, 

62:15, 83:17, 100:17, 101:4, 

101:9, 101:16, 120:17, 

120:23, 121:25

publically 36:1, 44:3

publications 67:7

publish 54:1

published 20:12, 29:3, 

43:13, 44:10, 65:19

publishes 24:4

pull 13:12, 53:15, 74:17, 

79:5, 82:16, 85:10, 88:1

pulled 84:9, 98:21

purchase 71:22

pure 9:3

purpose 10:16, 16:14, 29:25, 

31:8, 33:1, 33:4, 33:17, 

33:22, 35:11, 40:13, 40:18, 

55:15, 72:16, 82:21, 101:1, 

108:21, 135:20, 145:13

purposefully 145:12

purposes 5:4, 15:16

put 26:10, 40:21, 47:6, 50:4, 

50:4, 59:5, 60:7, 64:20, 

68:12, 77:17, 93:18, 97:18, 

98:19, 99:25, 106:7, 121:6, 

124:4, 127:3, 131:13, 135:4, 

138:6, 138:12, 139:14, 143:4, 

144:5, 146:11, 147:12, 154:7, 

156:22

putting 41:6, 65:12, 66:23, 

131:20, 131:22

< Q >

Qalqilla 74:5, 86:16, 86:18, 

86:21, 86:23, 140:11, 142:16

Qassam 13:21

question 12:22, 33:16, 53:7, 

76:12, 90:24, 149:12

questioned 66:25, 149:10

questioning 79:5

questions 44:11, 97:3

quick 149:18

quickly 73:7, 124:2

quite 139:4

Quote 99:10

quoted 117:24

< R >

radical 124:12

CASSIDI L. CASEY, CSR, 214-354-3139

UNITED STATES DISTRICT COURT

184
radio 45:21

Rafah 133:20

raise 7:19, 8:12, 20:17, 38:3, 

56:19, 56:22, 57:23, 59:6, 

59:19, 61:14, 62:2, 62:21, 

63:13, 63:22, 64:12, 64:17, 

64:18, 65:18, 72:9, 79:20, 

93:6

raised 39:1, 39:8, 58:22, 

69:9, 69:9, 78:9, 93:21, 

111:22, 129:9, 129:13, 

129:15, 129:19, 147:23

raised. 23:8

raising 19:6, 59:24, 60:3, 

66:19

Ramadan 130:20, 130:22, 

131:9

Ramallah 74:5, 81:18, 81:20, 

81:25, 82:1, 82:5, 82:19, 

83:1, 140:10, 143:10, 147:16, 

147:17, 147:18

ran 10:8, 10:15, 19:4, 19:8, 

73:18, 73:18, 75:14, 123:8, 

142:9

random 54:4, 61:21, 79:14

range 75:13

Rantisi 91:19

Rather 5:12

Razi 142:8, 142:12

re-enact 93:20

reach 5:7, 98:13

reached 23:14

read 4:24, 23:18, 31:22, 

33:13, 46:16, 92:24, 101:12, 

113:21, 124:10, 124:11, 

124:21, 124:21, 126:21, 

139:3, 139:6, 145:17, 153:4

reading 25:9, 80:17

reads 143:1

real 8:5, 8:9, 8:10, 8:11, 

104:8, 104:13, 104:14, 

104:14, 110:15, 115:17, 

118:4

reality 101:18, 101:23, 

105:14, 126:25, 134:16, 

150:12

realized 21:22

really 6:25, 73:23, 101:2, 

106:1, 108:18, 110:21, 

110:23, 110:25, 113:12, 

119:20, 119:23, 119:25, 

122:4, 132:3, 147:7, 147:18, 

148:16, 156:2, 156:4

reason 10:18, 14:25, 15:19, 

15:21, 123:23, 132:15, 134:6, 

134:22, 139:14, 140:21, 

141:11, 143:25, 147:22, 

151:23

Reasonable 134:7, 134:21, 

134:24, 135:7, 135:9, 145:11, 

145:17, 152:5, 152:24, 

152:25, 153:12, 153:16, 

153:17, 153:17, 153:18, 

153:23, 154:11, 155:1, 155:8, 

155:10, 156:19

reasons 15:7, 79:13, 79:13, 

97:15, 143:24

recall 22:18, 26:16, 39:18, 

79:18, 105:4, 114:24, 151:13

receipt 116:19

received 44:22, 45:15, 46:8, 

139:19, 141:20

receiving 45:5, 132:10, 

134:12, 134:17

recently 137:9

Recess 6:12, 6:12, 46:1, 

46:3, 46:4, 75:24, 76:3, 

77:21, 77:22, 102:5, 102:6, 

103:5, 103:9, 157:21, 157:25

recesses 6:11, 102:3

recipients 104:11, 104:12

recognition 5:20

recognized 29:2

reconciliation 61:23

record 31:10, 60:8, 158:10, 

158:16

records 8:4, 31:4, 41:24, 

41:25, 43:7, 67:13, 104:10, 

111:14, 116:16, 116:18, 

116:25, 132:10

Red 8:7, 119:7

reduced 4:20

Reeves 62:17, 101:5

refer 4:21, 30:21, 86:21, 

147:2, 147:16

referred 11:7

referring 33:15

refers 82:17

reflected 129:19

reform 11:5

refrigerator 107:6

refrigerators 107:7, 127:11

refugee 127:13

refugees 127:12

regard 8:19, 36:10, 77:7, 

89:24

regarding 97:4, 157:24

regular 8:6, 35:10, 40:16, 

53:8, 65:17, 71:17, 71:24

regularly 44:21, 121:10, 

140:3

reject 5:14

rejects 43:23, 43:25

related 25:24, 70:7

Relations 39:9

relationship 29:17, 29:19, 

29:22, 29:22, 41:16, 71:5, 

72:10, 79:11, 82:4, 110:6, 

110:7, 126:24, 127:1, 146:4, 

151:25

release 15:2, 137:12, 

137:13, 142:10

relevant 109:24, 113:16, 

114:2, 117:18

reliable 151:15

relied 156:3, 156:3

Relief 67:23, 74:9, 74:9, 

74:14, 74:15, 74:16, 74:19, 

74:23, 74:25

religion 69:1, 108:11, 121:1, 

125:19

religions. 69:2

religious 9:16, 34:1, 108:6

reluctantly 132:9

rely 115:9, 135:1, 135:4, 

135:5, 150:13, 150:17, 

151:25, 153:20, 155:14

relying 83:14, 88:21

remain 36:24

remains 12:1, 86:8, 155:19, 

155:20, 155:22, 155:22

Remarks. 26:5

Remember 7:9, 7:10, 7:16, 

7:21, 7:23, 8:1, 9:9, 11:19, 

16:13, 27:10, 42:14, 46:22, 

55:15, 80:18, 82:10, 85:2, 

88:14, 109:20, 110:19, 

111:14, 115:24, 117:18, 

117:25, 122:25, 124:6, 

125:23, 128:13, 130:3, 

CASSIDI L. CASEY, CSR, 214-354-3139

UNITED STATES DISTRICT COURT

185
132:25, 136:2, 137:6, 137:8, 

138:17, 142:6, 143:11, 

147:14, 149:10, 153:3

remembering 7:13, 7:20

remind 78:17

reminded 138:19

removed 156:19

rendition 117:23

rep 99:20

Report 44:24, 44:25, 44:25, 

45:6, 45:12, 45:14, 104:23, 

104:23, 115:13, 116:6, 

116:23, 116:25, 117:1, 117:2, 

117:3, 117:5, 117:8, 131:3, 

149:13

report. 72:21

reported 44:22, 45:21, 46:8

REPORTER 3:13, 55:16, 

62:17, 62:25, 63:7, 100:18, 

114:25, 161:5, 161:19

reporting 45:3, 72:22, 98:24

reports 30:4, 37:16, 45:6, 

116:11, 145:23

represent 141:13

representative 43:9, 43:10, 

56:6, 56:12, 110:5, 120:11, 

141:8, 150:14

representatives 18:1, 32:5, 

140:9

represented 25:13, 33:25, 

103:15, 105:5, 133:7, 133:8, 

144:14

Representing 36:19, 73:1

represents 60:13, 60:14, 

79:7

reputation 142:2, 143:4

request 73:8

requesting 139:8

requests 139:9

require 104:12, 153:24

requirements 154:12

requires 21:19, 21:24, 108:6, 

156:24

rescuers 14:17

Research 20:14, 20:15, 

55:17

Resistance 11:6, 22:21, 

22:24, 24:6, 25:15, 26:7

resisting 22:25

resolution 23:15

resolutions 23:14, 24:8

resolve 79:21

resources 140:12

respect 119:21, 121:9

respond 73:8

responded 106:18

rest 15:9, 49:14, 118:21, 

124:22

restaurant 14:12, 45:16

restful 4:3

restored 23:6

retaliation 10:17

retire 5:2

retired 133:8

return 98:25, 125:6, 150:22

returns 18:23, 99:1

review 100:22, 120:18, 

120:19

Reviewing 37:16

Richardson 58:5, 68:6

rid 48:3, 123:10

right-hand 27:21

Rights 37:10, 99:12, 99:12, 

99:16

rival 121:18

River 48:5, 48:6, 122:20, 

122:22

Rm 3:14

roads 133:17

rocket 90:16

rocks 11:12

role 20:10, 20:15, 20:16, 

20:17, 25:11, 26:7, 49:1, 

49:2, 52:20, 68:19, 78:11, 

93:6, 120:16, 120:23

roll 115:25

room 124:1

roots 10:20

RPG 90:16

run 9:15, 10:6, 21:11, 42:1, 

42:13, 67:19, 74:3, 85:15, 

92:13, 93:18

running 14:17, 42:14, 45:18, 

62:13, 80:19, 86:20, 91:17, 

92:11, 92:16

runs 17:13, 65:7, 76:23

< S >

sabotaging 68:24

sacrifices 23:1

safehouse 15:25

sake 66:12

Salaam 67:20

salaries 30:6

Saleh 137:10, 137:15, 

137:16, 137:18, 138:6, 

138:14, 148:5, 149:4, 154:21

SAMAH 32:19, 33:11, 33:12, 

33:15, 35:9, 52:25, 52:25, 

55:9, 124:25, 125:7, 128:13, 

129:5, 129:10

SAMAH. 33:9, 35:14, 35:18, 

128:10

sampling 21:4

San 2:33

Sanabil 138:14, 148:3

sang 48:20, 111:17, 111:21

satisfied 135:9

satisfy 107:10

Saudi 54:22, 113:7

saw 48:18, 52:23, 59:23, 

59:25, 60:3, 63:24, 65:21, 

67:6, 67:17, 69:4, 80:12, 

87:8, 91:8, 106:8, 106:11, 

109:17, 151:5, 151:8

saying 12:19, 19:12, 19:13, 

25:2, 32:18, 34:3, 36:19, 

40:2, 45:23, 49:9, 52:4, 52:5, 

65:13, 67:9, 70:21, 79:16, 

94:11, 99:4, 106:2, 107:12, 

111:16, 111:21, 112:12, 

113:8, 117:25, 124:23, 127:3, 

145:24

scare 106:1, 106:7

scared 15:10

schedule 4:12, 5:9, 40:23, 

41:3, 74:18, 78:14, 91:2, 

98:19, 158:5

scheduled 81:19, 85:20

schedules 5:4, 40:23, 98:22

scholars 142:25

school 56:11, 90:13, 92:11, 

105:18, 127:10

Schools 15:16, 73:18, 93:18

Science 85:14, 85:21, 86:6, 

86:9, 86:13

screen 26:11, 53:23, 80:4

SDFO 95:5

SDT 95:6

CASSIDI L. CASEY, CSR, 214-354-3139

UNITED STATES DISTRICT COURT

186
Sea 48:5, 48:6, 122:20, 

122:22

searched 14:23, 16:22, 17:1

Second 8:2, 10:23, 14:18, 

21:17, 44:12, 46:22, 49:17, 

57:14, 57:15, 57:17, 70:25, 

87:10, 132:2, 146:14, 148:18

seconds 46:18

secret 122:2

Secretary 34:10, 148:18, 

148:19

secretive 53:6, 53:11, 110:2

Section 22:2, 22:8, 22:9, 

28:10, 42:4, 67:14

sections 13:10

secular 34:1, 121:2, 121:19

Security 8:10, 52:24, 53:3, 

53:4, 53:25, 54:1, 54:1, 54:2, 

54:10, 54:12, 54:15, 54:18, 

54:24, 55:3, 55:8, 56:17, 

104:24, 113:7, 133:21, 

152:10

seeing 28:13

seeking 120:22, 150:22, 

150:22

seem 153:9

seems 147:9, 150:18

seen 4:23, 23:22, 28:10, 

28:16, 29:17, 30:2, 30:15, 

30:25, 41:24, 46:19, 48:12, 

48:13, 48:14, 54:2, 55:12, 

62:19, 69:13, 69:13, 75:16, 

80:22, 81:12, 100:16, 100:17, 

100:18, 132:10, 143:12

segment 47:22, 57:15, 58:7, 

71:15, 71:16, 78:3, 81:4

segments 56:22, 57:1

seized 21:10, 49:4, 49:5, 

49:12, 49:22, 50:5, 53:14, 

56:24, 61:20, 69:17, 75:16, 

79:23, 89:9, 93:25

select 131:1

selected 117:16

selective 122:9, 123:20, 

123:25, 130:8, 133:24, 

134:18, 151:18, 156:12

selectively 114:1

self-rule 127:1

selves 100:2

semi-brother 92:15

senate 60:25

Senator 18:6, 18:9, 61:1

Send 39:1, 49:21, 50:3, 

65:11, 65:16, 66:14, 67:2, 

67:4, 67:5, 67:8, 68:7, 71:23, 

73:13, 74:4, 93:8

sending 49:11, 66:17, 67:9, 

69:5, 74:13, 79:9, 93:10, 

98:12, 98:14, 98:17, 98:24

sends 140:9

senior 120:10, 141:8

sense 14:9, 93:5, 93:9, 

93:11, 93:12, 120:21, 134:22, 

143:25

sent 18:9, 42:18, 61:1, 68:6, 

68:11, 70:14, 70:16, 71:7, 

71:18, 72:12, 74:4, 74:8, 

74:12, 78:9, 83:7, 119:1, 

119:11, 142:18, 158:16, 

158:19

separate 31:25, 40:13, 

46:13, 98:18, 126:8

separately 13:18, 98:1, 

103:15, 147:24, 148:8, 

148:10

September 33:20

series 28:5, 46:11, 46:12, 

80:22, 83:22

serious 152:9

serve 24:20

Service 7:1, 136:4

services 99:1, 141:20

session 5:5, 32:20

session. 32:19

set 10:10, 20:20, 30:11, 

30:22, 31:2, 40:12, 42:15, 

54:18, 63:16, 70:14, 70:15, 

72:6, 72:17, 72:20, 73:19, 

74:10, 141:25

Sets 32:10, 156:25

settle 80:15

settlement 68:20

settlements 133:18, 145:25

settlers 123:11

Seven 83:11, 85:9, 89:5, 

117:6, 131:15

Seventies 22:5, 42:13, 87:5

seventy 129:16

Several 7:4, 10:7, 10:13, 

14:25, 15:22, 17:3, 18:3, 

20:20, 30:16, 34:6, 37:22, 

41:7, 43:12, 44:9, 56:20, 

57:1, 60:21, 61:6, 79:2, 

79:13, 80:7, 82:6, 84:1, 

85:16, 86:2, 87:7, 88:24, 

96:8, 100:16, 114:5, 135:14, 

136:22, 154:20

sewer 134:15

SFDO 95:5

shake 57:12

shakes 66:5

Shamm 22:5, 22:6, 22:8

SHAPIRO 1:27

Sheikh 10:6, 11:1, 11:10, 

17:17, 42:13, 42:19, 49:11, 

49:21, 50:16, 56:4, 56:9, 

56:10, 57:8, 64:5, 81:1, 

81:15, 87:4, 88:13, 91:18, 

100:17, 136:1, 154:19

shekels 87:2, 132:6, 132:11, 

132:13

Shield 151:1

shoes 105:18

shoot 51:4

shootings 13:24

short 45:20, 48:19, 81:4, 

88:2

shortly 11:16

shot 59:12

shouldn't 31:8, 42:7, 110:1

show 9:21, 26:19, 50:9, 54:3, 

79:6, 79:9, 91:3, 92:21, 

93:13, 93:25, 94:1, 100:1, 

114:2, 114:17, 116:19, 

116:22, 116:23, 117:1, 117:7, 

119:6, 119:9, 120:3, 124:2, 

129:13, 130:18, 132:15, 

132:24, 134:8, 134:11, 136:3, 

155:24

showed 9:22, 31:14, 71:21, 

91:20, 110:9, 111:7, 114:7, 

115:12, 115:22, 115:23, 

116:7, 116:8, 116:19, 119:4, 

130:4, 130:23, 132:19, 

132:20, 132:21, 151:3

showing 15:5, 81:12, 85:12, 

92:20, 101:13, 130:16, 

152:13

shown 4:9, 4:10, 89:14, 

161:6

CASSIDI L. CASEY, CSR, 214-354-3139

UNITED STATES DISTRICT COURT

187
shows 13:13, 26:20, 28:15, 

40:7, 81:21, 84:11, 85:11, 

109:7, 109:10, 145:18

Shura 24:9, 25:13

shut 68:4

sick 19:11, 19:13, 31:19

side 4:11, 12:2, 12:2, 27:21, 

77:12, 109:16, 145:6

signature 31:9

signed 33:21, 122:5

significant 87:7, 117:23, 

124:5, 124:6

similar 68:2, 69:3, 72:5

Simple 9:4, 95:17

simply 114:22, 125:21, 

129:21, 152:24

sing 49:8, 49:10, 49:21, 

50:3, 57:19

singing 48:18, 49:3, 49:20, 

58:9, 62:22, 88:16, 94:3, 

94:6, 94:19

single 7:13, 7:20, 27:9, 

85:10, 97:15, 97:16, 106:21, 

136:24, 138:2, 141:25, 142:2, 

154:5, 156:19

sir 6:20, 76:11, 102:16

sister 60:17

site 121:6

sits 13:14, 17:12

sitting 56:1, 59:15, 79:25, 

87:9, 87:15, 93:22, 99:19, 

116:13

situation 38:24, 99:6, 111:20

situations 134:5

six 4:10, 5:22, 83:11, 89:5, 

91:11, 91:16, 103:16, 106:6, 

107:21

sixteen 133:19

sixty-two 45:14

ski 51:1

skit 51:16, 52:7, 58:24, 59:4, 

59:5

skits 50:4, 50:5

skulls 94:18

small 45:17, 73:22, 133:12

social 13:11, 13:14, 15:14, 

15:15, 16:5, 16:6, 16:9, 

16:18, 17:2, 17:5, 17:12, 

73:16, 75:4, 78:10, 82:10, 

83:3, 97:4

societies 136:25, 138:3, 

138:9, 140:14, 140:24, 143:7, 

143:18

Society 71:15, 74:6, 74:6, 

78:3, 84:16, 84:17, 84:18, 

84:21, 84:24, 85:2, 85:8, 

85:12, 86:9, 86:25, 87:1, 

87:4, 87:23, 87:25, 88:2, 

88:7, 88:8, 88:10, 88:22, 

88:23, 89:1, 89:4, 89:25, 

90:4, 90:6, 90:8, 90:21, 

90:25, 137:16, 137:16, 

142:23, 154:21

soldier 45:7, 45:8

soldiers 11:15, 13:24, 61:24, 

62:11

soliciting 68:9

solution 11:24, 11:25, 12:22, 

50:22

solutions 12:17

Somalia 61:25

somebody 16:3, 52:7

somehow 132:18, 139:4

Someone 15:24, 16:3, 16:25, 

35:16, 36:23, 37:3, 38:14, 

45:4, 58:25, 59:24, 67:7, 

67:9, 67:14, 69:24, 70:3, 

73:23, 91:22, 97:22, 107:16, 

107:24, 108:9, 121:10, 

123:14, 124:15, 124:23, 

129:9, 137:24, 146:20, 

152:24

someplace 70:13

sometime 4:17

sometimes 11:7, 14:15, 

133:17, 146:16, 146:18

song 57:19, 57:20, 88:14

Songs 48:18, 48:19, 58:13, 

62:22, 88:15, 111:17

Sooner 77:20

sorry 25:7, 49:13, 88:1, 

102:7, 113:20

sort 20:11, 20:24, 67:3, 

74:11, 74:14

sought 106:20

souls 69:21

sound 15:18, 43:25, 45:3

sounds 45:4, 103:8

source 28:10, 84:12, 139:24

sources 40:8, 83:14, 84:13, 

84:13, 84:14, 91:12, 92:19, 

92:21, 156:4

south 10:1

speaker 7:21, 38:1, 60:12, 

62:2, 63:18, 63:19, 63:22, 

64:7, 86:1

speakers 7:18, 7:21, 38:6, 

59:19, 59:25, 60:1, 60:3, 

60:6, 60:12, 61:7, 61:8, 

61:16, 61:17, 63:4, 63:12, 

64:1, 64:12, 66:20, 66:21, 

72:10, 93:2, 93:3, 93:7, 

112:17, 120:20

speakers. 101:6

speaking 106:2, 111:11

speaks 140:5, 143:1

Special 21:22, 21:23, 22:2, 

44:25, 71:15, 71:15, 78:2, 

108:10, 108:14

Specially 95:3, 95:4, 95:11, 

95:23, 97:19, 98:15, 136:15, 

136:16, 143:18, 147:3, 

147:17, 153:5

specific 98:14, 127:6, 

145:12

specifically 23:12, 25:20, 

34:21, 36:11, 70:19, 71:10, 

71:14, 86:6, 91:10, 116:4

speech 52:1, 52:2, 52:9, 

52:14, 52:16, 52:17, 63:20, 

65:3, 65:9, 65:12, 125:19, 

128:16

speeches 64:19, 64:19

spend 119:14

spent 104:13, 105:24, 106:6, 

109:21, 109:22, 112:18, 

119:15, 125:16

spiritual 50:16, 56:5, 64:6

spoke 115:7

spoken 98:10, 141:18, 142:1

spokesman 61:4

sponsored 63:7

sponsoring 63:4, 71:4

spools 46:25, 57:1

spy 139:20, 139:20

St 2:31

stage 35:2, 50:25, 58:13, 

58:17, 59:8, 59:18

stamp 64:20

stamped 36:22

CASSIDI L. CASEY, CSR, 214-354-3139

UNITED STATES DISTRICT COURT

188
stand 39:19, 125:2

standard 152:23, 152:25, 

153:22, 154:10, 155:8, 

155:10

standing 58:16, 81:8

stands 156:8

start 6:23, 18:17, 21:9, 

21:10, 21:14, 21:16, 26:2, 

49:21, 78:11, 78:12, 109:16, 

115:10

started 19:22, 24:6, 81:22, 

83:4, 84:17, 117:24, 152:14

starting 42:17, 78:23, 86:17

starts 18:19, 78:23, 84:20

State 12:4, 22:20, 29:2, 

34:10, 101:20, 123:1, 136:6, 

140:17, 140:18, 144:13, 

148:20

statement 11:13, 19:9, 99:3, 

101:5, 118:15, 124:15

statements 29:24, 51:25, 

83:16, 89:13

station 15:2, 149:11, 149:13

stayed 145:6, 158:4

staying 117:6

stenotypy 161:5

step 98:11, 98:13, 99:11

steps 34:6, 106:25, 108:3

Steve 55:15, 55:20, 56:4, 

100:18, 114:24, 114:24

stipulated 156:6

stipulation 154:1

stood 153:4

stop 38:16, 104:16, 146:11, 

146:13

store 107:6

stories 107:12, 107:13

story 55:18, 62:25, 110:16, 

141:17

stoves 127:11

straight 78:18

strategy 26:1

Street 1:33, 2:6, 3:14, 21:12

streets 61:25

stretch 6:22

strikes 25:17

striking 25:14, 25:16

stringing 114:1

Strip 9:20, 9:23, 9:23

strong 25:14

stronger 147:15

strongest 17:9

structure 13:10, 13:14

struggle 21:20

Studies 20:14, 139:25

study 73:3, 105:18

studying 120:10, 142:23

stuff 99:13, 99:16

style 14:7

subject 46:14, 136:13

subjected 10:13

subjects 107:22

subpoenas 116:18

substantial 73:4, 79:11

successful 17:9

Sudan 18:1

sued 29:14, 110:6

suffering 67:21, 99:7, 

109:17

sufficient 135:10

suggest 5:6, 116:5

suggested 77:14

suggesting 77:13

suggestion 37:3, 116:7, 

124:11

suggestions 13:24, 37:17

Suicide 13:25, 14:21, 15:5, 

15:6, 15:9, 16:12, 34:7, 

44:18, 44:19, 44:24, 45:13, 

46:9, 46:16, 48:15, 82:9, 

88:12, 89:22, 93:19, 111:19, 

152:14

Suite 1:45, 2:16, 3:7

Sultan 67:24

summarizes 40:23

summary 114:8, 114:12, 

114:19, 130:5, 130:5, 130:12, 

131:13

summer 93:15

Summit 3:7

supervising 24:19

supervision 24:18

supplies 67:23, 71:22, 

105:12, 105:18, 107:4, 

127:10, 142:12

supported 44:21, 49:9, 64:1, 

70:12, 70:19, 70:21, 71:12, 

86:17, 87:18, 101:6, 151:3

supporter 44:14

supporters 44:2, 44:4, 

62:23, 67:4, 69:5, 84:10

supporting 28:18, 35:23, 

35:24, 36:3, 36:6, 36:7, 36:8, 

37:12, 40:20, 45:4, 71:11, 

71:25, 72:2, 83:4, 84:19, 

101:23, 108:21, 130:22

supportive 67:16

supports 17:2, 101:14

supposed 31:18, 53:1, 59:1, 

89:18, 127:21, 148:23

surgery 135:5

surprise 143:17, 153:6

surrounded 9:25

surrounding 22:7

survey 105:1

survive 105:19, 105:21, 

134:17, 134:18, 150:23

suspension 45:9

suspicious 14:22

swear 100:4

sweep 55:3, 55:5

Switzerland 41:22, 41:23, 

42:7

sword 48:1

sworn 32:11, 43:22, 101:8

Syam 39:11, 62:3, 63:24, 

80:16

symbol 80:3

Syria 10:1, 22:7

system 21:7, 21:15, 46:10, 

46:11, 156:25, 157:5, 157:14

system. 137:19, 148:12

< T >

table 155:20

tainted 36:17

Tamimi 132:20

Tampa 2:26

tangible 158:9

tank 20:15, 28:20, 40:14

taped 30:17, 144:25

tapes 46:21, 47:1, 47:3, 

47:4, 47:7, 47:8, 58:10, 62:7, 

66:22, 88:17

tapped 112:5, 139:2

tapping 146:10

taps 46:12, 138:23, 138:24, 

138:24

targeted 70:19

CASSIDI L. CASEY, CSR, 214-354-3139

UNITED STATES DISTRICT COURT

189
tasked 24:19

taught 13:9

tax 18:23, 98:23, 98:25, 

104:11, 155:13

teaches 16:10

team 97:25

tedious 130:15, 130:17

telephone 61:4, 129:6, 

145:18

television 139:24, 149:11

tells 41:25, 93:9, 137:2, 

137:4, 137:24, 148:12

Ten 112:7, 119:15, 128:20, 

139:12, 142:9

tens 41:14, 150:25

tent 87:9, 87:15, 134:12

TERESA 1:42

term 13:5, 33:5, 33:7, 33:11, 

35:14, 35:17, 71:16

terms 36:20, 151:16

terrible 105:23

Territories 9:25, 22:10

terror 14:8, 15:8

terrorism 106:14, 106:15, 

137:3, 141:13, 143:6, 149:17, 

152:11

terroristic 35:23

terrorists 95:3, 95:4, 107:15, 

133:2, 133:14, 133:25, 

136:16, 136:17, 146:24, 

149:14

Terrorists. 29:4

terrorize 14:14

testified 26:17, 55:17, 55:18, 

114:25, 118:16, 135:17, 

150:14, 151:15

testify 133:10, 143:5

testimonies 106:9

testimony 8:16, 17:25, 

70:10, 73:15, 78:6, 88:5, 

130:5, 135:13, 135:21, 

139:17, 141:22

TEXAS 1:2, 1:31, 1:34, 2:17, 

3:8, 3:15, 96:15, 107:14, 

132:13, 161:20

thanked 119:10

thanking 6:24, 59:15

thanks 63:21, 157:10

theirs 90:7, 91:10

theme 93:8

themselves 11:5, 33:10, 

35:20, 36:2, 56:21, 59:18, 

78:2, 79:15, 79:25, 87:16, 

87:17, 96:14, 97:11, 97:21, 

103:18, 128:3

theory 117:12, 119:17, 

155:15

thereabouts 85:19

thinking 145:8, 151:16

thinks 151:14

Third 8:15, 17:11, 20:16, 

46:22, 65:25, 147:22

thirteen 101:15

thirty 120:12, 133:9

though 28:22, 68:9, 102:4, 

108:1, 109:21, 112:11, 

112:12, 112:15, 118:4, 119:9, 

138:13, 148:5, 149:15, 

152:23

thoughts 52:12

thousand 41:7, 90:5, 118:10, 

118:12, 118:17, 119:1, 119:3, 

119:3, 119:4, 119:5, 119:15, 

119:16, 128:20, 129:16, 

133:19

thousand. 118:10, 118:12

thousands 41:14, 144:4, 

150:25, 154:8, 154:9

threat 152:9

threatened 112:4

three 13:10, 20:5, 37:19, 

44:8, 80:18, 86:13, 86:19, 

100:20, 103:7, 109:23, 141:5

three-month 41:18

threw 124:23

thrive 105:20

throughout 5:17, 19:16, 

29:11, 31:24, 33:16, 37:7, 

55:10, 66:18, 73:21, 110:15, 

113:14, 113:25

throwing 11:12, 27:8

Thursday 5:7

tide 36:9

tiny 89:17, 123:5, 137:13, 

144:4

title 65:24

titles 18:22

to. 144:22

Today 6:8, 10:22, 25:11, 

47:22, 76:17, 108:17, 114:20, 

123:24, 130:3, 135:23, 

137:14, 137:17, 158:23

together 4:7, 30:16, 38:21, 

39:7, 47:6, 98:8, 98:19, 

114:1, 126:13, 158:11

tomorrow 103:5, 103:7, 

105:22, 154:14, 158:1

took 30:18, 31:21, 34:6, 

51:21, 57:9, 64:18, 64:25, 

106:25, 108:3, 117:19, 128:5, 

161:5

tool 25:14

tools 63:15

top 13:17, 23:11, 26:23, 

37:13, 43:4

total 83:7, 109:23

toured 136:7

towards 62:23

Tower 3:6

Trading 41:21, 41:22, 42:1, 

42:6, 42:8

tragic 119:8

trail 132:12

tramples 112:24

transaction 136:19

transactions 98:21, 114:8, 

114:13

transcribed 161:6

TRANSCRIPT 1:17, 31:20, 

33:13, 145:18, 149:25, 161:8, 

161:10

transcripts 31:24, 33:16, 

101:12, 120:18

transfer 132:19, 139:8, 

146:8

transfers 130:25

translation 25:9, 117:24, 

118:14, 118:19, 118:21, 

119:21

translations 115:17

translator 118:7, 120:1

translators 118:2

travel 54:21, 55:7, 60:1

traveled 34:10, 113:6, 113:9, 

140:6

traveling 113:12

travelling 54:25

Treasurer 18:25, 19:3

Treasury 136:15, 137:8, 

137:9, 137:15, 137:20, 

CASSIDI L. CASEY, CSR, 214-354-3139

UNITED STATES DISTRICT COURT

190
137:23, 138:7, 146:25, 148:1, 

148:7, 148:19, 148:23, 149:3, 

150:8, 153:11, 154:7, 154:9, 

154:17, 154:20, 154:24, 

154:25, 155:6

treaty 33:23

TRIAL 1:17, 4:4, 4:12, 4:14, 

5:12, 7:11, 16:8, 52:5, 52:16, 

109:20, 113:3, 113:20, 

113:21, 118:8, 141:13, 147:1, 

153:24, 154:4, 156:11, 

158:10

triangle 13:13

tried 21:7, 47:1, 47:4, 47:8, 

52:24, 100:16, 105:15, 106:6, 

107:16, 121:13, 129:11, 

135:18, 155:24, 156:14

Tries 32:15, 32:15, 121:3, 

146:19, 147:5

trifecta 64:3

trip 56:8, 115:11, 115:14, 

117:4

trouble 56:3, 145:24, 146:2, 

146:3

truck 10:15

true 5:17, 19:12, 32:7, 33:1, 

55:13, 55:15, 63:2, 63:10, 

63:10, 100:2, 101:1, 101:7, 

104:2, 109:6, 114:22, 120:8, 

126:3, 129:18, 137:18, 

141:17, 146:3, 148:11, 149:2, 

154:17, 161:8

Trust 69:24, 70:3, 70:4, 70:9, 

110:20, 110:20, 111:1, 

119:20, 136:11

truth 32:13, 130:8, 130:9, 

151:24

try 6:9, 33:3, 34:6, 47:9, 

101:20, 102:2, 113:15, 

130:13, 145:15, 146:23, 

156:21

trying 55:14, 94:8, 97:7, 

100:1, 106:1, 106:7, 111:14, 

121:24, 125:11, 126:1, 146:1, 

151:16

Tulkarem 83:4, 83:5, 83:8, 

83:10, 83:12, 83:19, 84:7, 

84:9, 123:5, 138:20, 140:11, 

142:16

Turkey 43:5, 43:7

Turn 5:24, 9:14, 18:12, 

23:11, 26:5, 26:22, 43:16, 

65:20, 65:24, 69:11, 72:1, 

136:13

turned 134:3

turning 122:2

TV 15:2, 88:7

twelve 111:12

twenty 105:7, 131:15

twenty-five 105:7, 119:7

twice 132:20

Two 9:1, 12:2, 12:10, 13:15, 

14:16, 15:7, 17:19, 21:18, 

29:23, 31:21, 43:4, 44:8, 

44:11, 65:3, 76:1, 80:25, 

87:20, 95:2, 103:7, 105:25, 

114:12, 118:25, 119:22, 

126:17, 129:4, 136:10, 

136:17, 136:19, 142:24, 

148:1

two-month 41:20

two-state 11:24, 11:24

two. 85:13

type 62:1, 72:9

typed 115:17, 117:2

types 64:11, 67:15, 95:3

< U >

UASR 20:14, 25:6, 26:16, 

28:20, 36:17, 37:11, 37:18, 

40:14, 44:10

uncovered 46:25, 131:21

undated 115:12

undercover 113:13

underneath 61:3

understand 68:22, 123:22

understandable 7:8, 123:6

Understanding 68:19, 

158:15

understood 98:10, 139:4, 

158:10

unfair 126:1, 147:9

unique 21:19, 21:19, 53:9

University 123:20, 125:2, 

142:22, 149:24

unknown 124:6

unless 28:4, 32:25, 38:18, 

42:7, 47:9, 49:8, 55:7, 56:13, 

67:16, 68:1, 135:8

Unlike 140:5, 141:9, 141:17

unlikely 5:8

unnecessary 154:16

unrealistic 5:8

unsalvageable 47:7

unsigned 115:12

untainted 36:16

until 4:17, 10:5, 12:7, 19:8, 

41:19, 46:3, 64:23, 68:4, 

75:24, 77:21, 81:23, 85:19, 

87:1, 102:6, 118:7, 122:13, 

157:25

updates 158:12

upholds 157:14

uprising 10:19, 10:20, 10:21

us. 65:17, 125:6

USAID 142:7, 142:11, 

142:17, 149:23, 149:23, 

150:2

using 4:12, 6:7, 13:8, 26:13, 

33:5, 52:25, 64:11, 72:9, 

121:25

< V >

value 151:19, 152:4, 156:1

vastly 111:20

vendor 130:19

verdict 5:7, 156:24

version 129:24

versions 136:17

VERSUS 1:8, 78:17

vetted 142:15

victims 14:17, 119:1

victorious 66:11, 69:2

video 45:25, 46:18, 46:21, 

47:7, 47:8, 48:18, 49:4, 

49:22, 56:22, 56:24, 62:7, 

62:19, 63:24, 64:24, 79:22, 

79:23, 81:3, 81:4, 81:11, 

81:16, 87:8, 87:10, 88:3, 

88:3, 89:9, 90:10, 91:9, 93:1, 

93:13, 93:25, 106:11

videos 75:15, 88:22, 106:8

viewpoint 112:24

violating 96:4

violation 99:2

violence 12:10, 12:14, 

12:15, 12:21, 23:10, 25:17, 

36:7, 75:1, 105:25, 106:3, 

CASSIDI L. CASEY, CSR, 214-354-3139

UNITED STATES DISTRICT COURT

191
106:4, 106:10

violent 11:14, 12:12, 16:17, 

29:1, 99:9, 101:21

Virginia 20:23

visa 54:21, 113:10

visit 36:20, 56:4, 73:1, 116:3, 

116:9, 116:24

visited 39:10, 65:3, 140:9, 

140:10, 141:23, 142:24, 

151:6, 151:8

VOLUME 1:16

voluntarily 145:12

volunteers 119:11

voted 39:3

< W >

Wade 97:20

waiting 146:6

walk 105:18

walked 132:11

walking 31:15, 89:14, 100:8

walks 91:22

Wall 2:6, 25:12

walls 151:6, 151:8

wanted 5:3, 5:9, 73:23, 76:4, 

76:5, 76:11, 77:6, 77:17, 

80:9, 101:18, 105:16, 105:17, 

105:19, 107:11, 108:18, 

116:5, 116:5, 122:18, 123:2, 

125:8, 128:4, 133:11, 133:21, 

141:16, 143:3, 144:19, 145:4, 

145:5, 145:19, 146:11, 

147:10, 157:18, 158:7

wants 12:3, 12:3, 112:9, 

112:13, 122:19, 133:17, 

140:8, 157:7

War 100:4, 100:5, 100:6, 

100:13, 100:15, 101:15, 

109:9, 126:3

war. 100:13

warning 6:16

warnings 6:14, 76:4, 103:20

Washington 20:23, 46:24, 

142:22, 146:22

waste 12:24, 34:4, 40:20

watch 15:10, 103:22, 115:16

watching 135:14

water 62:12

ways 14:25, 16:10, 16:19, 

20:20, 35:19, 43:12, 43:24, 

53:5, 56:20, 56:20, 60:20, 

61:11, 66:19, 73:7, 73:16, 

73:25

weak 146:15

weapons 65:6, 65:15, 67:23, 

75:2

wear 50:20

Wearing 50:19, 51:1

web 121:6

Wednesday 4:17, 5:1, 84:15, 

103:7, 154:14

week 4:8, 5:6, 5:10, 141:2, 

141:3, 158:11

weekend 4:3

weeks 106:6, 136:19

weigh 157:11

weight 90:3

welfare 109:8

West 9:24, 11:25, 13:4, 

17:16, 17:18, 38:2, 39:2, 

57:9, 57:10, 70:15, 71:19, 

72:5, 73:14, 73:21, 86:2, 

93:23, 99:6, 123:11, 123:13, 

128:18, 131:21, 135:16, 

140:6, 141:4, 141:5, 146:2

Western 14:6, 23:21, 67:21, 

68:24

Westfall 3:4, 3:5, 68:9, 

102:20, 129:10, 129:18

Whatever 10:18, 43:17, 

140:2, 143:14

whatever. 36:22

whatsoever 106:5

wheel 131:15

wheelchair 131:21, 131:22

Wheelchairs 131:16, 131:16, 

131:17, 131:18

wherever 78:20

whether 9:2, 9:4, 40:25, 

44:14, 44:15, 44:20, 52:9, 

52:14, 75:8, 76:13, 96:24, 

97:4, 97:6, 145:16

whimsical 33:11, 55:10

whimsically 33:14

White 33:21, 88:14, 121:6

whole 52:22, 75:13, 110:16, 

141:17, 148:2, 152:7

whom 82:7, 87:8, 87:17, 

89:7, 116:1, 130:19

widows 101:23, 101:24

wife 121:5

Willfully 9:3, 145:11, 145:11, 

145:17

willfully. 145:10

willing 135:1, 135:4, 135:5, 

149:10, 149:15, 152:3

willing. 45:23

win 15:14, 15:19

wings 13:15

winning 92:2

wire 41:1, 46:12, 132:19, 

138:23, 138:23, 138:24

wired 41:21

wiretapping 152:8

wiring 42:6, 42:10, 42:12

within 68:24, 76:9, 158:4

Without 38:7, 73:24, 113:15, 

124:18, 124:18, 127:2, 

133:10, 150:16, 150:19, 

153:20, 153:21

witness 9:10, 22:6, 46:22, 

74:16, 104:6, 127:19, 127:19, 

141:7, 151:23, 151:23

witnesses 8:17, 8:18, 70:11, 

97:4, 120:5, 121:20, 122:13, 

135:15, 136:23

woman 14:21, 67:8, 90:23, 

131:19, 131:21

women 14:5, 14:20

won 16:5, 123:9

wonderful 52:2, 66:4

word 12:11, 12:13, 14:9, 

18:5, 52:25, 68:21, 108:8, 

128:10, 145:9

words 16:24, 33:11, 33:14, 

55:9, 56:17, 128:25, 129:1, 

148:10, 156:22

Work 24:5, 30:3, 37:17, 54:7, 

60:10, 68:22, 72:24, 73:4, 

77:3, 77:14, 118:23, 125:9, 

132:1, 137:21, 142:16, 

149:23, 150:2, 150:5

worked 34:11, 54:23, 89:11, 

102:9, 113:8, 118:2, 140:19, 

140:21, 140:25, 142:17

workers 90:7

working 35:5, 37:16, 128:18, 

134:16, 146:13

works 150:18

CASSIDI L. CASEY, CSR, 214-354-3139

UNITED STATES DISTRICT COURT

192
workshop 32:20

world 9:14, 9:14, 9:17, 9:19, 

15:9, 19:16, 104:6, 104:15, 

112:14, 112:14, 132:5, 137:3, 

137:18, 137:23, 138:8, 

148:11, 149:2, 150:9

Worldwide 19:19, 19:24

worried 38:9, 56:8, 127:9, 

145:3, 150:3

worry 7:12, 7:20, 14:11, 

23:19, 27:8, 80:17, 110:18

Worth 3:8

wounded 23:1, 71:9

wrap 156:8, 156:10

write 67:15, 67:25, 68:13

writes 43:20, 67:7, 67:14, 

143:1

writing 4:20, 62:25, 89:18, 

98:10, 137:13

written 43:17, 44:1, 67:6, 

69:4, 89:17

wrote 38:15, 111:8, 111:23, 

111:25, 112:3, 113:11

< Y >

Yaish 39:19, 64:2, 64:4, 

71:12, 81:2, 83:24

Yasser 33:25, 121:17, 140:5, 

151:7

Yassin 10:7, 10:8, 11:1, 

11:10, 17:17, 42:13, 42:14, 

42:19, 49:11, 49:22, 50:16, 

56:5, 56:9, 56:10, 64:2, 64:6, 

81:1, 87:5, 88:13, 91:18, 

100:17, 154:19

Year 10:23, 16:11, 29:3, 

38:7, 41:5, 45:11, 53:17, 

65:25

years 9:18, 12:24, 19:6, 

25:1, 28:22, 34:2, 40:19, 

42:17, 49:6, 64:24, 65:3, 

68:4, 69:10, 70:14, 82:1, 

83:6, 85:19, 86:17, 91:4, 

101:15, 105:6, 111:12, 112:7, 

116:16, 118:25, 120:12, 

126:17, 127:13, 128:17, 

130:10, 131:7, 133:9, 136:10, 

139:12, 142:9, 150:19

Yehya 27:12

Yemen 18:1

York 2:7, 17:22, 18:8, 50:2, 

117:5

young 14:4

younger 47:21

yourself 29:5, 47:9, 53:7, 

53:21, 96:1, 116:18

yourselves 156:10

< Z >

Zahar 55:19, 55:20, 55:23, 

55:25, 56:2, 56:2, 57:6, 

59:15, 114:22, 115:1, 115:2, 

115:3, 115:7

Zant 61:18, 61:19

Zeid 80:10, 91:8, 91:10, 

123:18

Zionist 22:16, 22:25

< Dates >

august 26, 2002 142:11, 

142:11

july 30, 1994. 37:14, 37:14, 

37:15

june 29, 2001 136:18, 

136:18, 136:18

october 1993 31:21, 31:21

september 17, 2007 1:11, 

1:11, 1:11

september 1988 41:19, 

41:19

CASSIDI L. CASEY, CSR, 214-354-3139

UNITED STATES DISTRICT COURT

193