Case 1:07-cr-00543-DLI Document 214-2 Filed 05/07/10 Page 1 of 2 PageID #: 1537

U.S. Department of Justice

United States Attorney

Eastern District of New York
MLM:BWB:ZA

271 Cadman Plaza East

Brooklyn, New York 11201

April 19, 2010

Via ECF
Millie Whalen, Esq.
Federal Defenders of New York
147 Pierrepont Street
Brooklyn, New York 11201

Michael Hueston, Esq.

Cardinale, Hueston & Marinelli
350 Fifth Avenue, Suite 4810
New York, NY 10118

Daniel Nobel, Esq.

401 Broadway, 25th Floor
New York, NY 10013

Kafahni Nkrumah, Esq.

116 W. 111th Street
New York, NY 10026

Re:

United States v. Russell Defreitas, et al.

Criminal Docket No. 07-543 (DLI)

Dear Counsel:
Pursuant to Rule 16(a)(1)(G) of the Federal Rules of
Criminal Procedure and Rules 701 et seq. of the Federal Rules of
Evidence, the government hereby discloses that it intends to call
Matthew A. Levitt and Calvin Bennett as expert witnesses at trial.
The government will forward copies of Mr. Levitts and Mr.
Bennetts curricula vitae under separate cover this week.
Mr. Levitt 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. In particular, he will be asked about the nature,
structure, methods and means of organizations including Hezbollah
and Al Qaeda, and about the role that individuals such as Adnan
Shukrijumah and Mohsen Rabbani, and countries such as Iran, play
in those organizations. During his testimony, Mr. Levitt will
also be asked about the history of those individuals and
organizations in the Caribbean and South America. Mr. Levitt will
further testify about the meaning of certain jargon used by the
defendants, including the term jihad. Finally, Mr. Levitt may
be asked about certain physical evidence the government will
introduce at trial, including notebooks, documents, magazines,
books and other items seized from the home of defendant Abdul
Kadir.
Mr. Bennett is a retired officer of the Special Branch

Case 1:07-cr-00543-DLI Document 214-2 Filed 05/07/10 Page 2 of 2 PageID #: 1538

of the Trinidad and Tobago Police Service, who spent a

substantial portion of his career investigating the Trinidadian
organization known as Jamaat Al-Muslimeen (JAM). Mr. Bennett
will be called to testify about JAMs nature, structure, history,
methods and means. In particular, Mr. Bennett will explain to
the jury how the organization first started and what its
strategic goals are, and also describe the history of its
terrorist, violent and other criminal activities, including the
coup attempt it staged in 1990. Mr. Bennett will also testify
about the role that Yasin Abu Bakr, an individual from whom the
defendants attempted to solicit aid for the charged conspiracies,
plays within JAM. In addition, Mr. Bennett will testify as a
fact witness regarding his participation in the execution of a
search warrant at the residence of an individual named Khalid
Hassan who had taken custody of defendant Abdul Kadirs luggage.
Mr. Bennett will testify regarding the items recovered during
that search.
If you have any questions, please do not hesitate to
contact us.
Very truly yours,
BENTON J. CAMPBELL
UNITED STATES ATTORNEY
By:

cc:

/s/
Marshall L. Miller
Jason A. Jones
Berit W. Berger
Zainab Ahmad
Assistant U.S. Attorneys
(718) 254-6421/7553/6134/6522

Clerk of the Court (DLI)(via ECF)