DRAFT TRIP REPORT

Event: Initial information-gathering trip to Motley Rice LLC

Date: Wednesday, August 13, 2003 and Thursday, August 14, 2003

Location: Offices of Motley Rice in Mount Pleasant (Charleston), SC

Special Access Issues: None

Prepared by: Serena Wille

Team Number: Team 4

Attendees - Commission: Doug Greenburg, Serena Wille

Attendees - Non-Commission: Mike Eisner (POC), Jodi Flowers, Jeff Thompson, Lisa
Saunders, Richard Cashin (sp?), Janice Campbell, Patrick lost, Ron Motley

Since the inception of the Commission Motley Rice (MR) has offered to be of assistance
to the Commission in its investigation. MR is bringing a lawsuit on behalf of 9/11
victims against named individuals and organizations that MR claims financed the terror
attacks (directly or indirectly). As part of its investigation, MR has gathered and is
continuing to gather documents. After making it clear that the Commission could not and
would not offer anything in return for access to MR's information, it was agreed that
Team 4 would send two representatives to MR's main offices in Charleston, South
Carolina.

Late Wednesday morning Doug and Serena arrived at the Mount Pleasant offices of
Motley Rice and were escorted to a conference room by Mike Eisner. We were greeted
by the non-Commission attendees listed above who gave us a quick update on the status
of their case and an overview of their database (and the kind of linkage analysis they
hope to be able to perform in the coming months). They asked if we had any questions,
which we did not. Doug expressed our desire to keep our visit confidential. We also
made clear again that we could not divulge the status of our investigation or provide them
with any information. After this brief introduction we were left alone in the conference
room with the documents and reviewed them for the remainder of the day.

A majority of the documents in the conference room were untranslated versions of the
German and Spanish collections of the MR's documents. The German collection contains
documents from the trial of Motassadeq and the German government's investigation of
German Al-Qaeda cell. The translated German documents include witness interrogation
reports and the opening and closing arguments in the Motassadeq trial. The Spanish
collection contains documents from the Spanish government's investigation of the
Spanish Al-Qaeda cell. The translated Spanish documents include court documents,
intelligence reports, wiretap transcripts, account statements, and the like. The conference
room also contained small sets of translated documents from Bosnia, France, Italy,
Thailand, and the Philippines. In addition there were reports from MR's consultants and
several MR memos. We were able to review all the documents in the room and
indicated those documents we wished MR to copy for us. The only documents that we
cannot receive copies of are the MR memos and the consultant reports, although Mike
Eisner thought we could "work something out" with respect to the latter.

On Thursday, August 14, we arrived shortly after 9 a.m. to finish our review of the
documents and at 10 a.m. Mike Eisner and Patrick Jost, a consultant on the case and a
former Treasury official, met with us. Again they offered to answer any questions we
had. Serena had some specific questions about the documents she had been reviewing
(e.g., sources, organization, etc.). Doug asked if there were documents missing from the
room that had been source material for a recent MR power point presentation or that
directly linked the defendants to the 9/11 plotters. The response was no. Mike Eisner
stated (rightly or wrongly) that for purposes of proving a conspiracy under US law they
had only to show that money was donated to the terrorism network generally rather than
for a specific act. Hence, he claimed that they did not need direct links between funders
and the 9/11 attacks. With respect to the complaint against NGOs, MR's backup currently
consists of their consultants' reports. The MR contacts in Germany have had no success
in getting information or documents from Saudi Arabia or the UAE. Mike noted that
discovery will begin shortly and more information of interest may come to light.

Patrick Jost then provided us with an overview of the connections between NGOs and
financial institutions and an overview of hawala. The specifics of this information have
been input into our database. When asked what he would do about regulating hawala in
the United States, Patrick made several points. First, he isn't sure what purpose will be
served by requiring hawaladers to file. What will be done with the information? Second,
hawaladers define "suspicious transactions", "remittance", etc. differently. Finally, in
many countries the police are corrupt which will deter hawaladers from registering and
filing as required or understanding that the enforcement of registration and filing
requirements is a legitimate action rather than mere harassment. Patrick suggests that
the US should pressure foreign countries to minimize the prevalence of hawala by
changing their remittance policies, bank regulations, and foreign exchange policies.
However, the hawala system may be too culturally ingrained to be affected simply by
changing these laws. Ultimately Patrick believes there are more pressing issues than the
regulation of hawala, since only about 1% of the transactions are problematic. When
pressed on how he would regulate hawalas if given a mandate to do so, Patrick ultimately
said it was a very challenging task and he had no real answers. He said he would have to
think about it. We chose not to discuss Patrick's experiences at Treasury at this time but
told him we might be touch with him in the coming weeks.

Jodi Flowers then joined Patrick and Mike and the three of them brainstormed their
document "wish list". Following our admonition that they would get nothing from us,
they made clear that they were not hoping to receive these documents from us; rather
they thought it might be good for us to know where they thought useful information
 might lie because it would benefit us as well. We refused to be drawn into revealing
whether we had access to various categories of information.

We left open the possibility that our colleagues on other teams might like to review the
materials themselves and that we might seek to review additional material as it comes in
during discovery.

Finally Ron Motley stopped by the conference room just prior to our departure to greet us
and reiterate the firm's offer to assist us in any way.