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Draft 1 of response



Hi Haytham,

Here's a draft of my response so far. I still need to add some citations for some of the arguments I make based on my discussions with Ibrahim. Please let me know if you know of any sources or have any suggestions. There was some anecdotal knowledge he mentioned that I added to my argument, but he didn't necessarily know of any documents he could point me to. You'll also notice I put brackets in some places where I need to add additional information (like where we need info about Sargon's unreliability). Let me know if you have any criticisms or would like me to add/remove anything.

Another thing - I had a hard time matching up some of the Government's exhibits I was comparing with your matrix and our discovery disk from before (mostly everything matched up, but I seem to be missing some of the FBI documents), so please tell me if I need to add more exhibit numbers or take any out that you see where I refer to them directly. (Or, is there a way to just generally refer to all the exhibits to make sure we are covering everything? I referred directly to certain exhibits to give the judge something to refer to, but I'm assuming you will also be referring to the specific exhibits in your oral argument).

Attachment: CB_RESPONSE_TO_MOTION_TO_ADMIT_DRAFT_1.doc
Description: MS-Word document






Carolynn Beck
(202) 316-1367