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).
<CB_RESPONSE_TO_MOTION_TO_ADMIT_DRAFT_1.doc>
Carolynn Beck
(202) 316-1367