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May 6, 2010
Via ECF
Mildred Whalen, Esq.
Federal Defenders of New York
147 Pierrepont Street
Brooklyn, New York 11201
Re:
Dear Counsel:
The government hereby provides additional information
concerning the scope of the testimony of its proposed expert
witnesses in response to letter of defendant Kareem Ibrahim dated
April 26, 2010. This letter supplements the governments previous
disclosure dated April 19, 2010.
Matthew A. Levitt, currently the Director of the Stein
Program on Counterterrorism and Intelligence at The Washington
Institute for Near East Policy, 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. Mr. Levitts experience in this field
and his academic writings on these subjects, as extensively
detailed in his curriculum vitae provided to you on April 19th,
will serve as the bases for his opinions.
With regard to Hezbollah, Mr. Levitt will testify about
that organizations relationship to the government of Iran and the
Iranian Revolutionary Guard, its longstanding presence in South
America and its efforts to secure financing, recruit operatives
and conduct terrorist attacks inside and outside of Lebanon and
Israel. Relatedly, Mr. Levitt will describe for the jury Irans
role as the vanguard of Shia Islam in the world, its revolutionary
ideology and its efforts to spread and propagate Shia Islam and
the Iranian revolution globally through its embassies and cultural
cc:
/s/
Marshall L. Miller
Jason A. Jones
Berit W. Berger
Zainab Ahmad
Assistant U.S. Attorneys
(718) 254-6421/7553/6134/6522