Chicago: Citing the need to be better
prepared for trial, Pakistani-Canadian terror suspect Tahawwur
Rana has asked the US government to provide him "specific"
details of the kind of "material support" he provided to
terror acts, saying so far the prosecution`s allegations in
the superseding indictment have been "vague".
In a 10-page motion filed in a court here, Rana`s
lawyer Patrick Blegen said given the "complexity of the case",
his client should be entitled to know "with specificity what
material support he is alleged to have provided" to terrorism.
"The superseding indictment is not a clear apprisal of
the allegations against the Defendant. Rather, by simply
reciting the language of the statute, the superseding
indictment keeps the allegations vague and prevents Defendant
from properly preparing a defence," Blegen said in the motion.
He said the government need not identify all of the
evidence it will produce, but should point out what the
allegations are, rather than hide behind the "vague and
amorphous language of the statute".
Each count in the indictment against Rana lists that
he provided material support to terrorism in the form of
"personnel", "tangible property", "money", "currency" and
"false documentation, and identification".
Neither the superseding indictment, nor the discovery
provided by the government so far reveal what these things
are, Blegen said. "There is no inkling of what these things
might be," he added.
The superseding indictment alleges that Rana provided
approval for the use of an immigration office, sent emails,
printed business cards and provided co-accused David Headley
assistance with obtaining a Visa.
While these items represent the alleged "false
documentation and identification" charge, nothing in the
indictment or in the government?s response identifies the
personnel, tangible property, money or currency in detail.
"If the charges are limited to what is described in
the Government`s response, then each of the allegations aside
from `false identification and documentation` should be
stricken. Otherwise, the government should be required to
identify the `personnel`, `tangible property`, `money` and
`currency` that it has alleged.
"Should the defence be required to sift through all of
the discovery to find anything that possibly fits under the
absurdly wide umbrella of `tangible property`," Blegen added.
Rana, who has pleaded not guilty to providing support
to the Mumbai terror attacks, had in February asked the
government to provide "a bill of particulars" - specific
details about the "material support and resources" he
allegedly provided to terrorist plots.
The government argued that such a bill is not
necessary because the superseding indictment provides more
detail than required, and because it is providing extensive