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Re:
Dear Counsel:
Pursuant to Rule 16(a)(1)(G) of the Federal Rules of
Criminal Procedure and Rules 701 et seq. of the Federal Rules of
Evidence, the government hereby discloses that it intends to call
Matthew A. Levitt and Calvin Bennett as expert witnesses at trial.
The government will forward copies of Mr. Levitts and Mr.
Bennetts curricula vitae under separate cover this week.
Mr. Levitt will be called to testify as an expert in
certain terrorist organizations and individuals referenced and/or
solicited by the defendants over the course of the charged
conspiracies. In particular, he will be asked about the nature,
structure, methods and means of organizations including Hezbollah
and Al Qaeda, and about the role that individuals such as Adnan
Shukrijumah and Mohsen Rabbani, and countries such as Iran, play
in those organizations. During his testimony, Mr. Levitt will
also be asked about the history of those individuals and
organizations in the Caribbean and South America. Mr. Levitt will
further testify about the meaning of certain jargon used by the
defendants, including the term jihad. Finally, Mr. Levitt may
be asked about certain physical evidence the government will
introduce at trial, including notebooks, documents, magazines,
books and other items seized from the home of defendant Abdul
Kadir.
Mr. Bennett is a retired officer of the Special Branch
cc:
/s/
Marshall L. Miller
Jason A. Jones
Berit W. Berger
Zainab Ahmad
Assistant U.S. Attorneys
(718) 254-6421/7553/6134/6522