Case 1:03-md-01570-GBD-FM Document 2927-5 Filed 02/03/15 Page 1 of 38

Exhibit “5”
to the Affirmation of Sean P. Carter Transmitting Evidence in Support of Plaintiffs’
Memorandum of Law in Opposition to the Motion to Dismiss of the Kingdom of Saudi Arabia
and Saudi High Commission for Relief of Bosnia & Herzegovina

 Case 1:03-md-01570-GBD-FM Document 2927-5 Filed 02/03/15 Page 2 of 38

Page 1
STATEMENT UNDER OATH
OF
ZACARIAS MOUSSAOUI

The following statement was taken at 2:06 p.m.
before Priscilla Naff Medina, Registered Professional
Reporter and Notary Public in and for the State of
Colorado:
ADMAX USP
5880 Highway 67
Florence, Colorado 81226
October 20, 2014
PRESENT:
For the Federal
Insurance Plaintiffs
and Plaintiffs'
Executive Committees:

SEAN P. CARTER, ESQ.
J. SCOTT TARBUTTON, ESQ.
Cozen O'Connor
1900 Market Street
Philadelphia, Pennsylvania 19103

For the Ashton
Plaintiffs, 9/11
victims, and
Plaintiffs' Executive
Committees:

ANDREW J. MALONEY, III, ESQ.
Plaintiffs' Liason Counsel and
Kreindler & Kreindler, LLP
750 Third Avenue
New York, New York 10017

For the Burnett
Plaintiffs and
Plaintiffs' Executive
Committees:

ROBERT T. HAEFELE, ESQ.
Motley Rice LLC
28 Bridgeside Boulevard
Mt. Pleasant, South Carolina 29464

For the O'Neill
Plaintiffs and
Plaintiffs' Executive
Committees:

JERRY S. GOLDMAN, ESQ.
Anderson Kill, P.C.
1251 Avenue of the Americas
New York, New York 10020

Also Present:

John Fawcett
Evan Kohlmann

Javernick & Stenstrom, LLC
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FAX (720) 449-0334

 Case 1:03-md-01570-GBD-FM Document 2927-5 Filed 02/03/15 Page 3 of 38

Page 2
1

I N D E X

2
3

Page Number
Examination by Mr. Carter

4
5
6

4

E X H I B I T S
Exhibit Number

Initial Reference

(No exhibits were marked for identification.)

7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

Javernick & Stenstrom, LLC
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 Case 1:03-md-01570-GBD-FM Document 2927-5 Filed 02/03/15 Page 4 of 38

Page 3
1

P R O C E E D I N G S

2

MR. CARTER:

Afternoon, Mr. Moussaoui.

As --

3

as you know, we'd like to take down some of your testimony

4

con -- concerning your experiences in Osama bin Laden's

5

organization for purposes of the 9/11 families' and

6

victims' civil lawsuit which is pending in the Federal

7

Court in the Southern District of New York.

8
9

Before we begin today can you please just
simply tell us your name for the record?

10

THE WITNESS:

11

MR. CARTER:

My name is Zacarias Moussaoui.
And -- and, Mr. Moussaoui, because

12

our hope is that we will be able to present this testimony

13

in court, are you willing to present an oath that the

14

testimony that you're giving will be truthful?

15

THE WITNESS:

Yes, I take an oath.

I swear by

16

Allah that everything that I will say from now on and to

17

the end of this testimony will be true.

18

that everything I say until the end of this testimony will

19

be true.

20

the end of this testimony will be true.

21

Allah that everything I say until the end of this

22

testimony will be true.

23

And I swear by Allah that everything I say until

MR. CARTER:

24

/

25

/

I swear by Allah

And I swear by

May Allah curse the liar.
Thank you, Mr. Moussaoui.

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 Case 1:03-md-01570-GBD-FM Document 2927-5 Filed 02/03/15 Page 5 of 38

Page 4
1
2

EXAMINATION
BY MR. CARTER:

3

Q

We would like to begin in or around the period

4

of 1998.

5

Embassies in East Africa occurred, where were you?

6
7

A

In 1998, at the time the bombings of the U.S.

In the time of the East African bomb being in

1998 I was in the camp of Khalden, Afghanistan.

8

Q

And who ran that camp?

9

A

The camp was the -- the -- under the -- the

10

leadership of Abu Zubaydah, and it was run also by Ibn

11

Shaykh al Liby, and it was a -- it was a -- an Libyan

12

brother who used to be the pri -- the -- the on-the-spot

13

Imam.

14

Q

How much time did you spend at that camp?

15

A

I be -- I believe something around seven or

16

eight months.

17

Q

18
19

Did you at some point leave that camp to go to

a -- a separate camp in Derunta?
A

Yes, I -- I -- at the end of the camp I went to

20

Derunta, which next to Jalalabad, okay, to the ca -- to

21

the camp of Abu Khabab.

22

handmade explosives, meaning explosives made with ammonium

23

nitrate and -- and everything you find in the kitchen.

24
25

Q

Ab Khabab was specialize in

This camp in Derunta, was it affiliated with

Osama bin Laden?

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Page 5
1

A

It was affiliated religiously, yes, of course,

2

'cause it was a jihad camp, okay, but it was not directly,

3

strict -- strictly speaking, under the authority, but they

4

had financial support from Osama bin Laden, I'm sure

5

because Khabab told me so, and because Osama bin Laden

6

used to give handout, financial support to almost every

7

camp in -- of jihad in Afghanistan.

8
9

Q

At the time you initially went to the Derunta

camp, were you at that time a member of Osama bin Laden's

10

organization?

11

A

12
13
14
15

No, the first time I was not a member of Osama

bin Laden the first time I went to the -- to the camp, no.
Q

Did you at some point seek an opportunity to

join bin Laden's organization?
A

Yes, I met -- I went to Kabul and met with Saif

16

al-Adel, okay, and asked him to read about myself, and he

17

basically flatly rejected me, then I went back to

18

Jalalabad and I met somebody who told me that I just spoke

19

to the wrong person, so I went back to -- to Kabul and I

20

give this time my resume to Abdelhadi al-Iraqi, and -- he

21

used to be the Emir of the front line at the time -- and

22

my resume was intended to be sent to -- to Osama bin

23

Laden, and it was because I knew later.

24
25

Q

Do you remember what particular background you

identified on that resume?

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 Case 1:03-md-01570-GBD-FM Document 2927-5 Filed 02/03/15 Page 7 of 38

Page 6
1

A

Yes, I do, 'cause -- I do remember.

I re -- I

2

talk to him about the fact that I had a -- a Master degree

3

in international business, I have a Di -- Diploma of the

4

Institute of Export, and also I have been to Chechnya and

5

I was a -- a part of the -- initially I a part of the

6

group of Tooting of Babar Ahmad, okay; and I -- I had the

7

contact to meet Abdul -- Abdulwahid -- Abdulwahid

8

al-Yemani, and, also, Shaykh Umar al Saif -- Shaykh Umar

9

al Saif, because he's in Chechnya in the south, the south.

10
11
12

Q

Why was it important for you to identify your

relationships with all of those people in your resume?
A

Because trust is extremely important into this

13

environment, in this community, and I had to prove my

14

credential.

15

And I didn't know at the time, but Sadaf and

16

Abu al-Amoudi had saw me, I met with them in Chechnya, but

17

I didn't know at the time, and they were close attendant

18

of Osama bin Laden.

19

Q

You mentioned a moment ago that it's your

20

understanding that your resume eventually did reach Osama

21

bin Laden, how -- how do you know that?

22
23

A

Because Abu Hafs told me because -- and when I

meet him he had my resume in his hand.

24

Q

And when did that occur?

25

A

He -- it occur -- it was -- I can't be

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 Case 1:03-md-01570-GBD-FM Document 2927-5 Filed 02/03/15 Page 8 of 38

Page 7
1

precise -- exact precision of the -- of the -- but it was

2

the end of '90 -- '98.

3
4
5

Q

And were you thereafter accepted into bin

Laden's organization?
A

I was definitely accepted.

I mean, the -- I

6

will even say that I was angry because a -- a lot of

7

people who -- didn't understand that somebody like me, who

8

had the -- was not Saudi, from a French-Morrocan

9

background, so quickly could be on a daily basis contact

10

with Abu Hafs and Shaykh Saeed, and also -- also had

11

absolutely no problem to meet with Shaykh Osama, so that

12

was very surprising for a lot of people, okay.

13

And also at the time, okay, it was a very small

14

organization, so -- and it was just after the -- the --

15

the Eastern -- the East Africa bombing, so security was

16

much ti -- was very tight, so to see me be able to -- to

17

go and to do what I was doing it was surprising for some

18

people.

19

Q

20
21

What was the first assignment you were given

after you were accepted into bin Laden's organization?
A

Abu Hafs ask me to -- to create -- to

22

computerize everything, to create a database of the -- the

23

financial record of Osama bin Laden, because Group bin

24

Laden -- at the time we used to use this terminology, but

25

now you talk al-Qaeda, that's what you -- you Americans

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 Case 1:03-md-01570-GBD-FM Document 2927-5 Filed 02/03/15 Page 9 of 38

Page 8
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say al-Qaeda -- so Abu Hafs asked me to -- to put into a

2

computer all the record for al-Qaeda, because after the

3

cruise missile attack ordered by Bill Clinton, okay, he

4

was afraid that the Shaykh Saeed will be killed because a

5

few people have been killed in the camp, and it was a

6

possibility that there would be further attack.

7

asked me to make it into a computer, create a database --

8

database -- data ba -- bank, and that's what I did.

9

Q

So he

All right, just to provide some context, what

10

was Abu Hafs' role within bin Laden's organization at that

11

time?

12

A

He was the second in command and he was a

13

military commander, Shaykh Osama told me himself, okay,

14

because the structure was -- Shaykh Osama bin Laden was

15

the -- the head, the second in command was Abu Hafs, and

16

the -- the -- the -- the right hand of Abu Hafs was

17

Mohammed Masa.

18

Q

And what was Shaykh Saeed's role?

19

A

Shaykh Saeed was the finance -- the CFO,

20
21
22

financial officer.
Q

Did you thereafter begin the work of trying to

computerize the al-Qaeda organization's finances?

23

A

Can you repeat?

24

Q

Did you at some point thereafter actually begin

25

Sorry.

building a computer database of al-Qaeda's finances?

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 Case 1:03-md-01570-GBD-FM Document 2927-5 Filed 02/03/15 Page 10 of 38

Page 9
1

A

Yes, we -- at the time we went to the house was

2

not very far from the house of the Chief of the Taliban,

3

okay, and many time -- maybe the morning, maybe an

4

afternoon, during the day -- he will come out either with

5

Abu Hafs or either with Shaykh Saeed, and we -- we -- we

6

make -- enter thing into Toshiba computer.

7

Q

Where was this house located?

8

A

It was in Kandahar, okay.

9
10

the hospital of Kandahar.

It was not far from

The Chinese hospital in

Kandahar.

11

Q

During your criminal trial there were numerous

12

references to a -- a guest house where you had provided

13

security, are you talking about a different house?

14

A

Yes, definitely.

At this time this guest house

15

in -- in Hadibad(sic) -- Hadiba -- Habash was not open, at

16

this there was no camp in Kandahar, okay, it was -- the

17

camp was in Kabul, okay, and, in fact, the camp was

18

basically the front line, okay, and only restrict number

19

of people will go to Kandahar, okay, the top people, okay,

20

okay.

21

And, so, the house was -- was very secret, and

22

it was run by Saadov, okay, and that's where I will sit

23

down, okay, and I will -- I will sit down with Abu Hafs,

24

the commander, and sometime Abu -- Shaykh Saeed, okay, and

25

I would do this work to enter, and they will tell me and

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 Case 1:03-md-01570-GBD-FM Document 2927-5 Filed 02/03/15 Page 11 of 38

Page 10
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they would provide document to me, okay.

2

document were in Arabic, so I would ask them to -- to tell

3

me what does that mean exactly.

4

financial document, okay.

5

Saudi bank, okay, and a Pakistani bank.

6
7
8
9

Q

And some of the

It -- it was a -- a

A lot of them were between

How long did the work that you were involved in

building the database take?
A

I think so -- something along two months,

something like that, okay, because at some point some --

10

somebody was injure, so it -- it become more so a

11

responsibility with me, because somebody from the front

12

came severely injure and he was placed in the Chinese

13

hospital, so I -- I think the two or three months, but

14

I -- I remember in the beginning I was only dedicated to

15

this stuff.

16
17
18
19

Q

All right.

Do you recall how many years the

database covered?
A

I definitely re -- recall that it was 1998, but

I don't know 1997 or 1996, I don't know, okay.

20

But when I was there it was re -- the date of

21

the document was the -- the -- the time period I was there

22

was 1998, '99.

23

Q

And did the database you were creating include

24

a list of the people and organizations that were donors to

25

bin Laden's organization?

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 Case 1:03-md-01570-GBD-FM Document 2927-5 Filed 02/03/15 Page 12 of 38

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A

That's -- that's -- that's exactly the purpose

2

of me, was to create a database of donation to see how

3

much money was being given to al-Qaeda, because I was not

4

creating a database of al-Qaeda expense, if it came or for

5

their mission or whatnot, it was only for donation, okay,

6

because he wanted to have -- Shaykh Osama wanted to keep a

7

record who give money because -- who give money, who --

8

who is to be listened to or who contribute to -- to the

9

jihad.

10
11
12

Q

Okay.

Did it also indicate how the transfers

were carried out?
A

Through the financial document I -- I could

13

see, you know, some -- some money was being transferred

14

from an account to a relief so -- organization who

15

ultimately will give or pay people ticket to come to the

16

camp, or they will pay for them for material, okay,

17

building material, or -- I mean, when it's building, like

18

electrical material, when -- 'cause building you buy

19

on-site, but everything from electrical usually come

20

from -- from Pakistan.

21
22
23

Q

Do you remember any of the individuals who were

identified within that database as donors?
A

I remember -- I -- I would rather have a --

24

I -- I remember many of them, because some of them that

25

are -- were known within the circle of the mujahideen,

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 Case 1:03-md-01570-GBD-FM Document 2927-5 Filed 02/03/15 Page 13 of 38

Page 12
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some of them extremely famous, like Waleed -- Waleed bin

2

Talal, Prince -- Prince Turki Al Faisal Al Saud, Prince --

3

Prince Bandar bin Sultan Al Saud, Prince Mohammed Al

4

Faisal Al Saud, and Haifa Al Faisal Al Saud, I know there

5

was another -- a woman.

6

It will come back to me.

But Yassin Adbullah al Kadi, Sharif Sedky,

7

Mohammed Al Hussein al Almoudi, Ibrahim bin Mahfouz,

8

Khalid bin Mahfouz.

9
10

That's all that come to mind on the top of my
head now.

11

Organization like the Saudi American Bank,

12

that's -- was a lot -- oh, so the -- the -- Abdulla --

13

Abdulla bin Laden, the brother of bin Laden, who used to

14

be in America, because -- I know because I send him e-mail

15

so he send us a laser for the copy and printing machine

16

laser, okay, okay, because we wanted -- al-Qaeda wanted to

17

do some count -- American dollar counterfeit, okay.

18
19
20
21

Q

Did you send that e-mail to Abdulla bin Laden

from Afghanistan?
A

No, from -- from Karachi.

I used to go either

Karachi or Quetta, but I think Karachi.

Karachi.

22

Q

Do you recall approximately when that happened?

23

A

Between 1999 -- I don't recall precisely.

I

24

remember that the -- when I went to Karachi I went to --

25

for -- to -- one of the main purpose, you know, okay,

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Page 13
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because Shaykh Abu Hafs gave me the e-mail and the

2

telephone number, okay, and, so, that's why on my way

3

to -- I think to go to London.

4
5
6

Q

Do you recall whether there were any members of

the Saudi ulema on your donor list?
A

I -- I recall that the -- I wonder if it was

7

not -- I want to say there were -- all of them were there,

8

in the Majlis ash-Shura ulema.

9

THE COURT REPORTER:

10

MR. CARTER:

11

THE WITNESS:

Are what?

In the -In the -- in the great concert of

12

the -- of the -- the great -- what we -- the great scholar

13

ash-Shura.

14

Uthaimeen, Shehri; and -- and for Commission, Shaykh

15

Jibreen and -- and Shaykh -- there was also some people

16

who -- who -- who were not -- Shaykh Hammoud al Uqlaa,

17

Hammoud al-Uqlaa, it was Shaykh -- many -- many -- you --

18

I mean, for -- it was all the -- the people of important

19

used to -- donate money to bin Laden, that's my

20

understanding.

21
22
23

Q

It's -- there was definitely Bin Baz,

(By Mr. Carter)

What -- what was bin Laden's

attitude towards the Saudi ulema?
A

It was of complete reverence and obedience,

24

meaning that the -- that he told the Majlis ash-Shura --

25

you could see somebody will have Catholic -- I don't want

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Page 14
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2

to offend anybody -- toward the Pope.
Q

Did bin Laden believe that what he was doing

3

with his organization was consistent with the teachings of

4

the ulema?

5

A

He was doing it with the express advice and

6

consent and directive of the ulema.

7

single persons coming from Saudi Arabia if the ulema and

8

Baz or Uthaimeen state this man is wrong, just to say he's

9

wrong.

He will not have a

Not to say he's an apostate, not just he's wrong,

10

there would -- everybody will have left, except the North

11

African maybe.

12

Q

There were not many.

You -- you mentioned earlier in your testimony,

13

or you made reference to some charities, you recall

14

whether there were any charitable organizations identified

15

on your donor list?

16

A

I definitely recall that -- the International

17

Islamic Relief Organization and the Muslim World -- World

18

League, and the Al-Haramain Islamic Foundation and the

19

Rabita Trust and the World Family of Muslim Youth and the

20

Third World Relief Agency, and I believe the Saudi Joint

21

Relief Committee, and I'm definitely certain about Saudi

22

High Commission and the Saudi Crescent -- Red Crescent.

23
24
25

Q

Do you have any recollection of seeing the name

Muwafaq Foundation on that list?
A

I'm not confident to say.

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Q

You -- you said just a second ago that you're

2

absolutely certain about the Saudi High Commission, did

3

you have any interactions yourself with the Saudi High

4

Commission?

5

A

Through my -- my interaction with them was

6

before even Afghanistan, it was in Chechnya, because when

7

I was in Chechnya, towards the -- we went the house, it

8

was being basically rented or organized by the

9

Al-Haramain, but towards the Saudi Commission who used to

10

provide us exit permit to -- to go out of the country,

11

'cause in this country when you want to go airport you

12

have to give them an exit permit that you have no business

13

with the police and blah, blah, blah, so you can leave the

14

country.

15

Q

When the Saudi High Commission would give you

16

those exit papers in Chechnya was it aware that you were a

17

fighter?

18

A

They used to call my -- the -- the -- the -- he

19

used to eat every day with us, he used to be with us, one

20

of -- one of them was Tuwaijri, okay, he used to work for

21

the Islamic, the Al-Haramain and the Saudi Commission of

22

Tuwaijri -- Abdullah al Tuwaijri, okay, so he used to work

23

with them, and it was no different, okay, it was just one

24

guy with two hat.

25

THE COURT REPORTER:

And two what?

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MR. KOHLMANN:

2

MR. CARTER:

3

THE WITNESS:

4

THE COURT REPORTER:

5

Q

Two hats.

Hats.
Two hat.

(By Mr. Carter)

Oh, thank you.

Do you -- do you recall from

6

your experiences in bin Laden's organization whether any

7

of the charities provided support other than financial?

8

For instance, documentation or support of that nature.

9

A

Yes, they used to give support for them for

10

help people to get visa to go to Pakistan, okay.

11

they're from Yemeni, or even Saudi, because -- especially

12

Yemeni, if they have a problem to getting a visa from

13

Pakistan to go they will get some -- a relief organization

14

to say they are a relief worker going to Pakistan, okay,

15

and they will get the money to travel to get to.

16

Yemeni people were not financially well off, okay.

17

So if

The

In Saudi Arabia they will send us, for example,

18

food -- food, let's say like container, not the -- okay,

19

of -- of food; and also if we want to buy computer

20

equipment or this, okay, it will go through any of the

21

relief organization because it was more discreet.

22
23
24
25

Q

And which of the relief organizations provided

that kind of assistance?
A

The Saudi High Commission in Pakistan heavy,

okay, and -- and the -- and the Al-Haramain, that's --

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Page 17
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2

that's the -- the thing that I vividly remember.
Q

Turning back to the donor list that you created

3

on the Toshiba computer, do you recall any references to

4

any individuals named Al-Rajhi?

5

A

Yes, I do recall Al-Rajhi, I re -- the -- the

6

Arab Bank, I do re -- recall Yassid -- Yassin al Kadi with

7

Sharif Asafi; and I recall Mahfouz -- Ibrahim and -- and

8

Khalid Mahfouz, father and son; and that's what I recall.

9

Oh, yeah, Mohammed Hussein al Amoudi.

10
11

Q

With regard to the Al-Rajhis, were you aware at

the time that the Al-Rajhi family owned a bank?

12

A

Yes, I believe.

13

Q

Do you recall there being any discussion within

14
15
16
17
18
19

Yes.

Yes.

al-Qaeda about that bank?
A

I don't know al-Qaeda in general, but Shaykh

Osama bin Laden, yes.
Q

What did Shaykh Osama bin Laden say about

Al-Rajhi bank?
A

I know that the discussion we have they were

20

like a good brother, I mean, they were -- they were

21

one -- one of the main support with the Haramain and the

22

High Commission, and -- and the -- the -- the -- and

23

national commission of the financial support and moving --

24

moving money around, I know this for a fact.

25

Q

You had mentioned earlier as well having

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contact with Abdulla bin Laden, were the names of any

2

other bin Laden family members included on your list of

3

donors?

4

A

As far as I am aware they were altogether,

5

they -- all of them, okay, they never meet -- met any bin

6

Laden, I believe that all of the -- Saad, Mohammed, all

7

the bin Ladens that were in Afghanistan with them, they

8

were all in there with -- and I think that the -- I can

9

truly say that even his mother came to visit him in -- in

10

Afghanistan, and the -- the -- the visitation was arranged

11

by General Gul, the Chief of the ISI, the -- the Pakistani

12

Secret Service Intelligence.

13
14
15

Q

Was the visit by Osama bin Laden's mother a

significant event?
A

It was, yes, it was organized as a very

16

significant exit event, it was a festivity.

17

they -- they organized by shooting RPG and shooting a PKM,

18

and it was a -- there was a banquet, you know.

19

They --

She was not there, that's the way -- way --

20

she have -- we have to thank them for her, a woman, okay,

21

so -- but it was -- it was a well -- because she didn't

22

come alo -- alone, it was the -- some other family mem --

23

member, okay, she was not the only one.

24

Q

The other family member was a man or a woman?

25

A

It was a -- I think two brother.

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brother of Shaykh Osama, okay, I -- and I don't know if

2

it -- if it was brother-in-law, but I -- I think there was

3

two brother of Shaykh Osama, okay, they came with -- the

4

mother.

5

Q

How long did they stay?

6

A

Not very long.

7

of -- I don't believe it -- if they stay a week or 10 day.

8
9

I think that it was a matter

Q

It -- it's been suggested in our litigation by

the bin Ladens that the family severed all ties with Osama

10

in 1994, from your experience do you believe that to be

11

true?

12

A

A complete lie.

An -- an absolute lie.

I

13

have -- Shaykh Osama give me the name and the e-mail and

14

the telephone number of his brother in the United State,

15

okay, I went -- I went to -- to -- to what's Jeddah, I had

16

contact with the -- one of the brother of Shaykh

17

Osama -- and his brother I know, okay, and his brother I

18

know was -- the first time I went he was sitting in the --

19

in the compound, okay, and he receive his -- his mother,

20

okay, with two I think the brother -- it was one brother

21

or a brother-in-law, two -- two brother, okay, but family

22

member, okay.

23

And I saw all the -- the children of Osama bin

24

Laden, even the one who wrote the book about Osama bin

25

Laden, I knew exactly the -- that he was in Afghanistan,

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1

okay.

2

the son -- the -- the -- the oldest son of Osama Laden was

3

in the hospital -- hospital -- Chinese hospital with me

4

when I had malaria, and I remember because we were on the

5

floor and I was receiving an IV, and I didn't know that he

6

was the son of Osama bin Laden because he was dressed like

7

an Afghan, okay.

8
9

Abdulla bin -- bin -- oh, Abdulla bin -- bin Laden,

And, then, I -- Richard Reid also witness it.
And, then, after that him -- you couldn't differentiate

10

him between an Afghan.

11

bin Laden, he was dressing 100 percent with the -- like an

12

Afghan, and, then, after that it's more -- Abu Bakr

13

al-Suri, he told me this is Abdulla bin Laden, and, then,

14

we talk, and that's how I -- and -- I met bin Laden, I met

15

him in -- be -- well before when -- the first time I was

16

on the front line, okay, I met bin Laden, okay.

17

You couldn't know that he was a

And I also didn't know initially that he was

18

bin Laden until I went to Kandahar and discovered that the

19

guy I used to be with was the son of bin Laden.

20

So I know that his family was never cut, and he

21

become -- I will say this because I heard on televi -- on

22

the radio, okay, and I was taught that -- that just the

23

Saudi tell him either you fit in publicly or we take your

24

money away.

25

never been a shred of truth.

So it was pure cosmetic, he -- there was --

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And he go against every Arabic way, especially

2

tribe, the mother cutting the tie with the -- the -- a son

3

doesn't exist.

4

Q

Did you receive any information indicating that

5

the family in general was continuing -- continuing to send

6

money to Osama bin Laden?

7

A

Yes, I receive -- I used to -- to enter into

8

database a financial document of money of -- of account of

9

the bin Laden group within Saudi Arabia; al -- also when

10

we wanted to buy spare part of -- okay, the -- the spare

11

part were bought by the Saudi bin Laden group, and was

12

sending to -- to Jeddah, and, then, after to Karachi.

13

Q

14

(Reviewed documents.)
You -- you told us a little bit ago that

15

members of the Saudi royal family were contributing to bin

16

Laden's organization during this time, the royal family

17

and government of the Kingdom have said that that's an

18

illogical idea because bin Laden was the enemy of the --

19

of Saudi Arabia, how would you respond to that?

20

A

This is a complete misleading explanation for

21

assumption of people who are not familiar with the way the

22

Saudi government is established, because the Saudi

23

government is -- they have two heads of the snake, they

24

have the Saudi, like Al Saud, and the Wahhabi were in

25

charge of the Islamic Code of the Islam -- or Islamic

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 Case 1:03-md-01570-GBD-FM Document 2927-5 Filed 02/03/15 Page 23 of 38

Page 22
1

power in Saudi Arabia, okay, and that's why they have the

2

name "Wahhabi," okay, okay.

3

So the Saudi cannot keep power in Saudi Arabia

4

without having the agreement, okay, of the Wahhab, the

5

Wahhabi, the scholar, okay.

6

So Shaykh Osama bin Laden had been sent

7

initially 100 percent -- it's a matter of public record,

8

there are books about this I believe, okay -- that he was

9

saying that -- with Abdullah Azzam, okay -- as being the

10

one who organize the jihad against the communists, okay.

11

So he was his -- father of Osama bin Laden was

12

best friend, he was known, okay, of -- of -- of -- of Fahd

13

Al Saud, the ruler, the King of Saudi Arabia, and he's the

14

one -- Al Saud -- okay, who give to bin Laden to rebuild

15

the Holy Mosque in Mecca and to rebuild the Holy Mosque in

16

Medina and also to rebuild the Holy Mosque in Jerusalem,

17

okay.

18

sites in Islam was built by the father of Osama bin Laden,

19

okay.

20

So the three mosques -- the hol -- the three holy

So bin Laden was pure -- a pure Wahhabi and

21

will obey the Wahhabi scholar to the letter, and, in fact,

22

even in schween(phonetic), in his testament he say that --

23

he refer that vase guda(phonetic) ulema Saudi Arabia, and

24

he didn't want to give them by name, okay.

25

So Osama bin Laden went against Al Saud, but

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not all of Al Saud, he went against Fahd, but he didn't

2

want to go against -- for many year against Abdullah Saud

3

and Turki and the people who have been classified by -- as

4

the ulema, the scholar -- Bin Baz, Uthaimeen and Shehri --

5

as fath(phonetic) criminal, but not apostate, so that's

6

where there is a difference, okay.

7

If you were being branded an apostate Osama bin

8

Laden most likely 100 percent will not have any business

9

with you and wage war, but at the fath he will not be --

10

will not be allowed to wage war unless he was guaranteed

11

success, and, so, the ulema told him not to wage war

12

against Al Saud because Fahd was going to die and,

13

therefore, that Al -- Abdullah Al Saud will take power and

14

he will reestablish a true power, okay.

15

You have to see that on -- after the seizure of

16

Mecca, okay, you -- after the seizure of Mecca by

17

Juhaiman, okay, the -- the Saudi Kingdom reverted to a

18

more autotic(phonetic) or more drastic Draconion Islam 100

19

percent in the hand of the ulema, the scholar of Saudi

20

Arabia, so Bin Baz, Uthaimeen, who used to be the mentor,

21

the scholar of Juhaiman, the person who make the city of

22

Mecca, okay.

23

So bin Laden was the child of Wahhabi, the

24

child of the -- of the -- of the scholar, and he -- he --

25

he obeyed them and will -- did it with jihad in Saudi

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1

Arabia in 2003 I believe, okay, because the Saudi

2

gov -- Saudi scholar, the Wahhabi, told him not to do it,

3

that's why he went to -- to East Africa where I -- he had

4

much more capability to do it in Saudi Arabia at the time

5

where the American troop were, had boots on the ground.

6

Q

What would be the specific benefit to the Saudi

7

royal family in this 1998, '99 period to giving money to

8

bin Laden's organization?

9

A

There is -- there -- there is many benefit.

10

First of all it was a -- a matter of survival for them,

11

okay, because all of the mujahideen, okay -- I believe --

12

I believe all of them, okay, the hard core believe that

13

Za -- Al Fahd was an apostate, so they would have wanted

14

jihad against Saudi Arabia, so it was the policy for the

15

Saudi government to finance jihad in the first Af --

16

Afghanistan -- the first jihad in Afghanistan, then in

17

Bosnia, then before that in Tajikistan, and Saudi used to

18

send people, and you could travel and you could -- as long

19

as you don't do stuff in your back -- back -- backyard.

20

Q

Okay, in your view was the ule -- ulema

21

demanding that the royal family support bin Laden's

22

organization?

23

A

24
25

If -- it was a -- it was a credential to the

proof that they were emphatic in an apostate.
Q

It was a proof for whom?

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A

For -- for -- for -- to give to -- money to bin

2

Laden could be used by the Saudi to say to the ulema,

3

"Look, see, we are not against Islam or the jihad, we

4

finance bin Laden."

5
6
7

Q

And that would assist them in their

relationship with the ulema?
A

It -- it will guarantee that the ulema will not

8

raise their -- their voice and their concern about many

9

thing wrong with Saudi Arabia, like, you know, widespread

10

homosexuality, it's endemic, okay; usury, you know,

11

interest rate in bank; American troop on the ground,

12

you -- I think -- I don't remember exactly the date, but

13

you stay long time in Saudi Arabia after the Gulf War,

14

okay, and Shaykh Hudhaify even make a speech and say that

15

you -- you are to -- you are to leave, and he's -- he's

16

a -- he was a -- Hudhaify was the -- the Imam of the

17

second holy site in Islam, Medina.

18

So he -- bin Laden was also -- was proof

19

that -- because when -- bin Laden, al-Qaeda and the people

20

that come to him was the proof that these people were not

21

apostate, 'cause they say, "You don't finance jihad if you

22

don't believe in Allah."

23

Q

The money that was coming from the Saudi

24

donors, how important was it to bin Laden's ability to

25

maintain the organization?

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1

A

It was crucial.

I mean, without the money of

2

the -- of the Saudi you will have nothing, I mean, that

3

you would have like a kalashnikov, it was absolutely

4

fundamental, because at the time -- at the end there was

5

hundred of people coming, you have to feed them, you have

6

to pay for -- for kalashnikov, or all the military

7

equipment, as -- after that it become more important

8

because some come from tank, some bulldozer, and -- and

9

that's -- and they were paying the house of everything the

10

member for the -- for the housing, the family, and they

11

will give you -- I -- I used to receive -- being pay by

12

bin Laden, it was very small, but I didn't have children;

13

but if you had children every child had a certain amount,

14

okay, and every -- the rent will be paid by al-Qaeda, and

15

for every child you have a -- a certain amount, every wife

16

you have a certain -- certain amount, it was a -- I --

17

then it might be military not very organized, but

18

financially they were the people being -- taking all of

19

the money.

20

Q

When the donations came in were they

21

essentially just placed into a central pool to be used as

22

the organization deemed fit?

23

A

You had too broad -- too broad way of spending

24

the money, okay.

25

okay, that's what I know, okay, maybe -- probably

You have Kandahar and -- and Kabul,

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Page 27
1

Jalalabad, because they also have a guest house where I

2

was in Jalalabad, I went there, okay.

3

I went there, okay.

But I know certain with Jalalabad and Kabul

4

because the money used to be given, a lot of money -- lot

5

of money . . .

6

(A discussion was held off the record.)

7

MR. MALONEY:

8

I think we're almost out of time.

We've still got about five minutes probably.

9

THE WITNESS:

A lot of money were -- were sent

10

to -- to the front line because they will be paying

11

everything, okay, everything will be paid by bin Laden,

12

okay, and -- and he -- we go to Al Belajari, and in Kan --

13

in Kandahar it was just Saeed, okay.

14

take my money from just Saeed.

15

Q

(By Mr. Carter)

Me, I -- I used to

Do you recall any of the

16

transfers that you worked on involving National Commercial

17

Bank?

18

A

Definitely I recall very -- from -- from Jeddah

19

to Karachi opening amount, line of credit, send money, and

20

never send good, okay, then after we receive the money it

21

will buy material that we send to -- to -- to Quetta and

22

to Kandahar.

23
24
25

Q

And do you recall whose account at National

Commercial Bank was used to make those transfers?
A

The name I don't recall.

I don't recall, you

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know.

2

don't recall the name.

3
4
5

It was a different name, a different company, I

Q

And the company receiving the funds in Pakistan

was essentially a front of some sort?
A

If it was created.

And I even almost

6

considered I give the idea and I initiated it to -- to

7

tell to the brother Khal -- Khal it was a good, effective

8

thing to -- to do, you know, with this fake account, fake

9

letter of credit and all this, rather than to send Khallad

10

to have a bunch of money, padding himself, and come back

11

to -- to Karachi and take the plane, and it was don't go

12

do it, you know, I -- this is more effective and you

13

can -- you can do much more money, okay (indicating).

14

I -- I'm not sure that I was the first one to -- to say it

15

to them.

16

Q

But

Mr. Moussaoui, I think we're at the end of our

17

time for today, but we want to thank you, and we expect to

18

see you again tomorrow morning.

19
20
21

A

I definitely will be here tomorrow morning for

a time for sure this testimony.
Q

Thank you.

22

MR. MALONEY:

23

MR. KOHLMANN:

24

MR. CARTER:

25

Thank you.
Thank you very much.

Oh, I am sorry, did you want to

take an oath at the conclusion of today's testimony?

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Page 29
1

THE WITNESS:

2

my testimony, what I say was true.

3

all I say was true.

4

I swear by Allah that all I say was true.

5

the liar.

6

Yes.

I swear by Allah that all
I swear by Allah that

I swear by Allah all I say was true.
Cursed be on

(The statement under oath was concluded at 2:55

7

p.m., on Monday, October 20, 2014.)

8

/

9

/

10

/

11

/

12

/

13

/

14

/

15

/

16

/

17

/

18

/

19

/

20

/

21

/

22

/

23

/

24

/

25

/

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Page 30
1
2

REPORTER'S CERTIFICATE
I, Priscilla Naff Medina, Registered

3

Professional Reporter and Notary Public in and for the

4

State of Colorado, do hereby certify that prior to the

5

commencement of the examination the Witness first duly

6

swore to testify the truth; that said statement under oath

7

was taken in shorthand by me at the time and place

8

hereinabove set forth and was thereafter reduced to

9

typewritten form by me, as per the foregoing transcript;

10

that the same is a full, true, and correct transcription

11

of my shorthand notes then and there taken.

12

I further certify that I am not related to,

13

employed by, nor of counsel for any of the parties or

14

attorneys herein, nor otherwise interested in the event of

15

the within action.

16
17

My commission expires July 2, 2015, and I have
hereunto set my hand this October 24, 2014.

18
19
20
21

________________________________
Registered Professional Reporter
and
Notary Public

22
23
24
25

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Page 1
A
Ab 4:21
Abdelhadi 5:20
Abdul 6:7
Abdulla 12:12
12:13,18 18:1
20:1,1,13
Abdullah 15:22
22:9 23:2,13
Abdulwahid 6:7
6:7
ability 25:24
able 3:12 7:16
absolute 19:12
absolutely 7:11
15:2 26:3
Abu 4:10,21
6:16,22 7:10
7:21 8:1,10,15
8:16 9:5,23,24
13:1 20:12
accepted 7:3,5
7:20
account 11:14
21:8 27:23
28:8
action 30:15
Adbullah 12:6
ADMAX 1:9
advice 14:5
Af 24:15
affiliated 4:24
5:1
Afghan 20:7,10
20:12
Afghanistan 4:7
5:7 12:19 15:6
18:7,10 19:25
24:16,16
afraid 8:4
Africa 4:5 7:15
24:3
African 4:6
14:11
afternoon 3:2
9:4
Agency 14:20
ago 6:19 15:1

21:14
agreement 22:4
Ahmad 6:6
airport 15:11
al 4:11 6:8,9
12:2,2,3,3,4,4
12:4,6,7,7
13:16 15:22
17:6,9 21:9,24
22:13,14,25
23:1,12,13,13
24:13 27:12
al-Adel 5:16
al-Amoudi 6:16
Al-Haramain
14:18 15:9,21
16:25
al-Iraqi 5:20
al-Qaeda 7:25
8:1,2,22 11:3,4
12:16 17:14,15
25:19 26:14
al-Qaeda's 8:25
Al-Rajhi 17:4,5
17:11,18
Al-Rajhis 17:10
al-Suri 20:13
al-Uqlaa 13:17
al-Yemani 6:8
Allah 3:16,17,19
3:21,22 25:22
29:1,2,3,4
allowed 23:10
Almoudi 12:7
alo 18:22
altogether 18:4
America 12:14
American 12:11
12:17 24:5
25:11
Americans 7:25
Americas 1:22
ammonium 4:22
Amoudi 17:9
amount 26:13
26:15,16 27:19
Anderson 1:21
ANDREW 1:15

Bakr 20:12
Bandar 12:3
bank 8:8 10:5,5
12:11 17:6,11
17:14,18 25:11
27:17,24
banquet 18:18
basically 5:17
9:18 15:8
basis 7:9
Baz 13:13 14:8
23:4,20
beginning 10:14
Belajari 27:12
believe 4:15
14:2,20 17:12
18:6 19:7,10
22:8 24:1,11
24:12,12 25:22
benefit 24:6,9
best 22:12
Bill 8:3
bin 3:4 4:25 5:4
5:5,9,12,14,22
6:18,21 7:3,20
7:23,23 8:10
8:14 10:25
12:1,3,7,8,13
12:13,18 13:13
13:19,21 14:2
16:6 17:16,17
18:1,2,5,7,13
19:9,23,24
20:1,1,1,1,6,11
20:13,14,16,18
20:19 21:6,9
21:11,15,18
22:6,11,14,18
B
22:20,25 23:4
B 2:4
23:7,20,23
ba 8:8
24:8,21 25:1,4
Babar 6:6
25:18,19,24
back 5:17,19
26:12 27:11
12:5 17:2
bit 21:14
24:19,19 28:10 blah 15:13,13,13
background
bomb 4:6
5:24 7:9
bombing 7:15
backyard 24:19 bombings 4:4
angry 7:6
anybody 14:1
apostate 14:9
23:5,7 24:13
24:24 25:21
approximately
12:22
Arab 17:6
Arabia 14:7
16:17 21:9,19
22:1,3,13,23
23:20 24:1,4
24:14 25:9,13
Arabic 10:2
21:1
arranged 18:10
Asafi 17:7
ash-Shura 13:8
13:13,24
Ashton 1:15
asked 5:16 8:1,7
assignment 7:19
assist 25:5
assistance 16:23
assumption
21:21
attack 8:3,6
attendant 6:17
attitude 13:22
attorneys 30:14
authority 5:3
autotic(phone...
23:18
Avenue 1:17,22
aware 15:16
17:10 18:4
Azzam 22:9

Javernick & Stenstrom, LLC
3131 South Vaughn Way, Suite 224, Aurora, Colorado 80014 (720) 449-0329

book 19:24
books 22:8
boots 24:5
Bosnia 24:17
bought 21:11
Boulevard 1:19
branded 23:7
Bridgeside 1:19
broad 26:23,23
brother 4:12
12:13 17:20
18:25 19:1,3
19:14,16,17,17
19:20,20,21
28:7
brother-in-law
19:2,21
building 8:25
10:7 11:17,17
11:18
built 22:18
bulldozer 26:8
bunch 28:10
Burnett 1:18
business 6:3
15:12 23:8
buy 11:18 16:19
21:10 27:21
C
C 3:1
ca 4:20
call 15:18
camp 4:7,8,9,14
4:17,18,19,21
4:24 5:2,7,9,12
8:5 9:16,17,17
11:16
capability 24:4
Carolina 1:20
carried 11:11
Carter 1:12 2:3
3:2,11,23 4:2
13:10,21 16:2
16:5 27:15
28:24
Catholic 13:25
cause 5:2 6:1

FAX (720) 449-0334

 Case 1:03-md-01570-GBD-FM Document 2927-5 Filed 02/03/15 Page 33 of 38

Page 2
11:18 15:11
25:21
central 26:21
certain 14:21
15:2 26:13,15
26:16,16 27:3
CERTIFICA...
30:1
certify 30:4,12
CFO 8:19
charge 21:25
charitable 14:14
charities 14:13
16:7
Chechnya 6:4,9
6:16 15:6,7,16
Chief 9:2 18:11
child 23:23,24
26:13,15
children 19:23
26:12,13
Chinese 9:9
10:12 20:3
circle 11:25
city 23:21
civil 3:6
classified 23:3
Clinton 8:3
close 6:17
Code 21:25
Colorado 1:8,10
30:4
come 9:4 11:15
11:19 12:5,9
18:22 25:20
26:8 28:10
coming 14:7
25:23 26:5
command 8:12
8:15
commander
8:13 9:24
commencement
30:5
Commercial
27:16,24
commission
13:14 14:22

15:2,4,9,15,21
16:24 17:22,23
30:16
Committee
14:21
Committees
1:14,17,20,22
communists
22:10
community 6:13
company 28:1,3
complete 13:23
19:12 21:20
compound
19:19
computer 8:2,7
8:25 9:6 16:19
17:3
computerize
7:22 8:22
con 3:4
concern 25:8
concerning 3:4
concert 13:11
concluded 29:6
conclusion
28:25
confident 14:25
consent 14:6
considered 28:6
consistent 14:3
contact 6:7 7:9
18:1 19:16
container 16:18
context 8:9
continuing 21:5
21:5
contribute 11:8
contributing
21:15
copy 12:15
core 24:12
correct 30:10
cosmetic 20:24
counsel 1:16
30:13
count 12:17
counterfeit

demanding
24:21
Derunta 4:18,20
4:24 5:8
Di 6:3
die 23:12
difference 23:6
different 9:13
15:23 28:1,1
differentiate
20:9
Diploma 6:3
directive 14:6
directly 5:2
discovered
20:18
discreet 16:21
discussion 17:13
17:19 27:6
District 3:7
document 10:1
10:2,4,21
11:12 21:8
documentation
16:8
documents
21:13
doing 7:17 14:2
14:5
dollar 12:17
D
donate 13:19
D 2:1 3:1
donation 11:2,5
daily 7:9
donations 26:20
data 8:8
donor 13:5
database 7:22
14:15 17:2
8:7,8,25 10:7
donors 10:24
10:17,23 11:2
11:22 18:3
11:4,22 21:8
25:24
date 10:20 25:12 Draconion
day 9:4 15:19
23:18
19:7
drastic 23:18
dedicated 10:14 dressed 20:6
deemed 26:22
dressing 20:11
definitely 7:5
duly 30:5
9:14 10:18
E
13:13 14:16,21
E 2:1,4 3:1,1
27:18 28:19
degree 6:2
e-mail 12:14,18
12:17
country 15:10
15:11,14
course 5:1
court 3:7,13
13:9 15:25
16:4
covered 10:17
Cozen 1:13
create 7:21,22
8:7 11:2
created 17:2
28:5
creating 10:23
11:4
credential 6:14
24:23
credit 27:19
28:9
Crescent 14:22
14:22
criminal 9:11
23:5
crucial 26:1
cruise 8:3
curse 3:22
Cursed 29:4
cut 20:20
cutting 21:2

Javernick & Stenstrom, LLC
3131 South Vaughn Way, Suite 224, Aurora, Colorado 80014 (720) 449-0329

13:1 19:13
earlier 14:12
17:25
East 4:5,6 7:15
24:3
Eastern 7:15
eat 15:19
effective 28:7,12
eight 4:16
either 9:4,5
12:20 20:23
electrical 11:18
11:19
Embassies 4:5
Emir 5:21
emphatic 24:24
employed 30:13
endemic 25:10
enemy 21:18
enter 9:6,25
21:7
environment
6:13
equipment
16:20 26:7
especially 16:11
21:1
ESQ 1:12,13,15
1:18,21
essentially 26:21
28:4
established
21:22
Evan 1:24
event 18:14,16
30:14
eventually 6:20
everybody
14:10
exact 7:1
exactly 10:3
11:1 19:25
25:12
examination 2:3
4:1 30:5
example 16:17
Executive 1:14
1:17,19,22

FAX (720) 449-0334

 Case 1:03-md-01570-GBD-FM Document 2927-5 Filed 02/03/15 Page 34 of 38

Page 3
Exhibit 2:5
exhibits 2:6
exist 21:3
exit 15:10,12,16
18:16
expect 28:17
expense 11:4
experience
19:10
experiences 3:4
16:6
expires 30:16
explanation
21:20
explosives 4:22
4:22
Export 6:4
express 14:5
extremely 6:12
12:1
F
fact 6:2 9:17
17:24 22:21
Fahd 22:12 23:1
23:12 24:13
Faisal 12:2,4,4
fake 28:8,8
familiar 21:21
families' 3:5
family 14:19
17:11 18:2,22
18:24 19:9,21
20:20 21:5,15
21:16 24:7,21
26:10
famous 12:1
far 9:2,8 18:4
fath 23:9
fath(phonetic)
23:5
father 17:8
22:11,18
Fawcett 1:23
Federal 1:12 3:6
feed 26:5
festivity 18:16
fighter 15:17

finance 8:19
24:15 25:4,21
finances 8:22,25
financial 5:4,6
7:23 8:20 10:4
11:12 16:7
17:23 21:8
financially
16:16 26:18
find 4:23
first 5:11,12
7:19 19:18
20:15 24:10,15
24:16 28:14
30:5
fit 20:23 26:22
five 27:8
flatly 5:17
floor 20:5
Florence 1:10
following 1:5
food 16:18,18,19
foregoing 30:9
form 30:9
forth 30:8
Foundation
14:18,24
French-Morr...
7:8
friend 22:12
front 5:21 9:18
10:11 20:16
27:10 28:4
full 30:10
fundamental
26:4
funds 28:3
further 8:6
30:12
G
G 3:1
general 17:15
18:11 21:5
getting 16:12
give 5:6,20 11:7
11:7,15 15:12
15:15 16:9

19:13 22:14,24
25:1 26:11
28:6
given 7:19 11:3
27:4
giving 3:14 24:7
go 4:17 7:17
9:19 12:20
13:3 15:10,11
16:10,13,20
21:1 23:2
27:12 28:11
going 16:14
23:12
GOLDMAN
1:21
good 17:20
27:20 28:7
gov 24:2
government
21:17,22,23
24:15
great 13:11,12
13:12
ground 24:5
25:11
group 6:6 7:23
21:9,11
guarantee 25:7
guaranteed
23:10
guda(phonetic)
22:23
guest 9:12,14
27:1
Gul 18:11
Gulf 25:13
guy 15:24 20:19
H

9:5,23 13:1
Hafs' 8:10
Haifa 12:4
Hammoud
13:16,17
hand 6:23 8:16
23:19 30:17
handmade 4:22
handout 5:6
happened 12:22
Haramain 17:21
hard 24:12
hat 15:24 16:3
hats 16:1,2
head 8:15 12:10
heads 21:23
heard 20:21
heavy 16:24
held 27:6
help 16:10
hereinabove
30:8
hereunto 30:17
High 14:22 15:2
15:3,15 16:24
17:22
Highway 1:9
hol 22:17
holy 22:15,15,16
22:17 25:17
homosexuality
25:10
hope 3:12
hospital 9:9,9
10:13 20:3,3,3
house 9:1,2,7,12
9:13,14,21
15:7 26:9 27:1
housing 26:10
Hudhaify 25:14
25:16
hundred 26:5
Hussein 12:7
17:9

H 2:4
Habash 9:15
Hadiba 9:15
Hadibad(sic)
9:15
I
HAEFELE 1:18
Ibn 4:10
Hafs 6:22 7:10
7:21 8:1,15,16 Ibrahim 12:7

Javernick & Stenstrom, LLC
3131 South Vaughn Way, Suite 224, Aurora, Colorado 80014 (720) 449-0329

17:7
idea 21:18 28:6
identification
2:6
identified 5:25
11:22 14:14
identify 6:10
III 1:15
illogical 21:18
Imam 4:13
25:16
important 6:10
6:12 13:18
25:24 26:7
include 10:23
included 18:2
indicate 11:10
indicating 21:4
28:13
individuals
11:21 17:4
information
21:4
Initial 2:5
initially 5:8 6:5
20:17 22:7
initiated 28:6
injure 10:10,12
instance 16:8
Institute 6:4
Insurance 1:13
Intelligence
18:12
intended 5:22
interaction 15:5
interactions
15:3
interest 25:11
interested 30:14
international
6:3 14:16
involved 10:6
involving 27:16
ISI 18:11
Islam 21:25
22:18 23:18
25:3,17
Islamic 14:17,18

FAX (720) 449-0334

 Case 1:03-md-01570-GBD-FM Document 2927-5 Filed 02/03/15 Page 35 of 38

Page 4
15:21 21:25,25 killed 8:4,5
IV 20:5
kind 16:23
King 22:13
J
Kingdom 21:17
J 1:13,15
23:17
Jalalabad 4:20
kitchen 4:23
5:18 27:1,2,3
knew 5:23 19:25
Jeddah 19:15
know 3:3 6:15
21:12 27:18
6:17,21 10:19
JERRY 1:21
10:19 11:13
Jerusalem 22:16
12:4,14,25
Jibreen 13:15
17:15,19,24
jihad 5:2,7 11:9
18:18 19:1,17
22:10 23:25
19:18 20:5,10
24:14,15,16
20:17,20 25:9
25:3,21
25:10 26:25
John 1:23
27:3 28:1,8,12
join 5:14
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22:12
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1:16
K
Kabul 5:15,19
L
9:17 26:24
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27:3
5:5,12,23 6:18
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8:14 12:13,13
26:3,6
12:18 13:19
Kan 27:12
14:2 17:16,17
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18:1,2,6 19:24
9:10,16,19
19:25 20:1,2,6
20:18 26:24
20:11,13,14,16
27:13,22
20:18,19 21:6
Karachi 12:20
21:9,11,18
12:21,21,21,24
22:6,11,14,18
21:12 27:19
22:20,25 23:8
28:11
23:23 25:2,4
keep 11:6 22:3
25:18,19 26:12
Khabab 4:21,21
27:11
5:5
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5:14 7:4,20
Khalden 4:7
8:10 10:25
Khalid 12:8
13:21 16:6
17:8
18:13 21:16
Khallad 28:9
24:8,21 25:24
Kill 1:21
Ladens 18:7

19:9
laser 12:15,16
lawsuit 3:6
leadership 4:10
League 14:18
leave 4:17 15:13
25:15
left 14:10
let's 16:18
letter 22:21 28:9
liar 3:22 29:5
Liason 1:16
Liby 4:11
Libyan 4:11
lie 19:12,12
line 5:21 9:18
20:16 27:10,19
list 10:24 13:5
14:15,24 17:2
18:2
listened 11:8
litigation 19:8
little 21:14
LLC 1:19
LLP 1:16
located 9:7
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long 10:6 19:5,6
24:18 25:13
Look 25:3
lot 7:6,12 10:4
12:12 27:4,4,9
M
machine 12:15
Mahfouz 12:7,8
17:7,8
main 12:25
17:21
maintain 25:25
Majlis 13:8,24
malaria 20:4
MALONEY
1:15 27:7
28:22
man 14:8 18:24
marked 2:6
Market 1:14

Masa 8:17
Master 6:2
material 11:16
11:17,18 27:21
matter 19:6 22:7
24:10
mean 7:5 10:3
11:17 13:18
17:20 26:1,2
meaning 4:22
13:24
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23:16,16,22
Medina 1:6
22:16 25:17
30:2
meet 6:7,23 7:11
18:5
mem 18:22
member 5:9,11
18:23,24 19:22
26:10
members 13:4
18:2 21:15
mentioned 6:19
14:12 17:25
mentor 23:20
met 5:15,15,18
6:16 18:5
20:14,14,16
military 8:13
26:6,17
mind 12:9
minutes 27:8
misleading
21:20
missile 8:3
mission 11:5
Mohammed
8:17 12:3,7
17:9 18:6
moment 6:19
Monday 29:7
money 11:3,7,7
11:13 13:19
16:15 17:24
20:24 21:6,8
24:7 25:1,23

Javernick & Stenstrom, LLC
3131 South Vaughn Way, Suite 224, Aurora, Colorado 80014 (720) 449-0329

26:1,19,24
27:4,4,5,9,14
27:19,20 28:10
28:13
months 4:16
10:8,13
morning 9:3
28:18,19
Mosque 22:15
22:15,16
mosques 22:17
mother 18:9,13
19:4,19 21:2
Motley 1:19
Moussaoui 1:3
3:2,10,11,23
28:16
moving 17:23,24
Mt 1:20
mujahideen
11:25 24:11
Muslim 14:17
14:19
Muwafaq 14:24
N
N 2:1 3:1
Naff 1:6 30:2
name 3:9,10
14:23 19:13
22:2,24 27:25
28:1,2
named 17:4
names 18:1
national 17:23
27:16,23
nature 16:8
never 18:5 20:20
20:25 27:20
New 1:17,17,22
1:22 3:7
nitrate 4:23
North 14:10
Notary 1:7 30:3
30:21
notes 30:11
number 2:2,5
9:18 13:2

FAX (720) 449-0334

 Case 1:03-md-01570-GBD-FM Document 2927-5 Filed 02/03/15 Page 36 of 38

Page 5
papers 15:16
part 6:5,5 21:10
21:11
O
particular 5:24
O 3:1
parties 30:13
O'Connor 1:13
pay 11:15,16
O'Neill 1:21
26:6,11
oath 1:1 3:13,15
paying 26:9
28:25 29:6
27:10
30:6
pending 3:6
obedience 13:23
Pennsylvania
obey 22:21
1:14
obeyed 23:25
people 6:11 7:7
occur 6:24,25
7:12,18 8:5
occurred 4:5
9:19,19 10:24
October 1:10
11:15 13:15,18
29:7 30:17
16:10,16 21:21
offend 14:1
23:3 24:18
officer 8:20
25:19,20 26:5
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26:18
17:9 20:1
percent 20:11
28:24
22:7 23:8,19
okay 4:20 5:2,16
period 4:3 10:21
6:6 7:12,13 8:3
24:7
8:13 9:3,8,16
permit 15:10,12
9:17,18,19,19
person 5:19
9:20,22,23,24
23:21
10:1,4,5,9,19
persons 14:7
11:5,10,16
Philadelphia
12:16,16,17,25
1:14
13:2 15:20,22
PKM 18:17
15:23 16:10,14
place 30:7
16:16,18,20,25
placed 10:12
18:5,20,23
26:21
19:1,3,15,17
Plaintiffs 1:13
19:19,20,21,22
1:16,19,21
P
20:1,7,16,16
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P 1:12 3:1
20:22 21:10
1:16,17,19,22
22:1,2,2,4,5,8 P.C 1:21
plane 28:11
22:9,10,12,14 p.m 1:5 29:7
Pleasant 1:20
padding 28:10
22:17,19,24
please 3:8
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point 4:17 5:13
23:22 24:1,11 paid 26:14 27:11
8:24 10:9
Pakistan 11:20
24:11,12,20
police 15:13
16:10,13,14,24 policy 24:14
25:10,14 26:14
28:3
26:24,25,25
pool 26:21
Pakistani 10:5
27:2,2,11,12
Pope 14:1
18:11
27:13,20 28:13
possibility 8:6
19:14
numerous 9:11

oldest 20:2
on-site 11:19
on-the-spot 4:12
open 9:15
opening 27:19
opportunity
5:13
ordered 8:3
organization 3:5
5:10,14 7:4,14
7:20 8:10
10:25 11:14
12:11 14:3,17
16:6,13,21
21:16 24:8,22
25:25 26:22
organization's
8:22
organizations
10:24 14:14
16:22
organize 22:10
organized 15:8
18:15,17 26:17
Osama 3:4 4:25
5:4,5,9,11,22
6:18,20 7:11
7:23 8:13,14
11:6 17:16,17
18:13 19:1,3,9
19:13,17,23,24
20:2,6 21:6
22:6,11,18,25
23:7
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power 22:1,3
23:13,14
precise 7:1
precisely 12:23
precision 7:1
present 1:11,23
3:12,13
pri 4:12
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12:3,3
printing 12:15
prior 30:4
Priscilla 1:6
30:2
probably 26:25
27:8
problem 7:11
16:12
Professional 1:6
30:3,20
proof 24:24,25
25:18,20
prove 6:13
provide 8:9 10:1
15:10
provided 9:12
16:7,22
public 1:7 22:7
30:3,21
publicly 20:23
pure 20:24
22:20,20
purpose 11:1
12:25
purposes 3:5
put 8:1
Q
Quetta 12:21
27:21
quickly 7:9
R
R 3:1
Rabita 14:19
radio 20:22
raise 25:8
ran 4:8

Javernick & Stenstrom, LLC
3131 South Vaughn Way, Suite 224, Aurora, Colorado 80014 (720) 449-0329

rate 25:11
reach 6:20
read 5:16
rebuild 22:14,15
22:16
recall 10:16,18
12:22,23 13:4
13:6 14:13,16
16:5 17:3,5,6,7
17:8,13 27:15
27:18,23,25,25
28:2
receive 19:19
21:4,7 26:11
27:20
receiving 20:5
28:3
recollection
14:23
record 3:9 7:23
8:2 11:7 22:7
27:6
Red 14:22
reduced 30:8
reestablish
23:14
refer 22:23
reference 2:5
14:13
references 9:12
17:3
regard 17:10
Registered 1:6
30:2,20
Reid 20:8
rejected 5:17
related 30:12
relationship
25:6
relationships
6:11
relief 11:14
14:17,20,21
16:13,14,21,22
religiously 5:1
remember 5:24
6:1 10:14
11:21,23,24

FAX (720) 449-0334

 Case 1:03-md-01570-GBD-FM Document 2927-5 Filed 02/03/15 Page 37 of 38

Page 6
12:24 17:1
20:4 25:12
rent 26:14
rented 15:8
repeat 8:23
Reporter 1:7
13:9 15:25
16:4 30:3,20
REPORTER'S
30:1
respond 21:19
responsibility
10:11
restrict 9:18
resume 5:20,22
5:25 6:11,20
6:23
reverence 13:23
reverted 23:17
Reviewed 21:13
Rice 1:19
Richard 20:8
right 8:9,16
10:16
ROBERT 1:18
role 8:10,18
royal 21:15,16
24:7,21
RPG 18:17
ruler 22:13
run 4:10 9:22

14:7,20,21,22
15:2,3,9,15,21
16:11,17,24
20:23 21:9,11
21:15,19,22,22
21:24 22:1,3,3
22:13,23 23:17
23:19,25 24:1
24:2,4,6,14,15
24:17 25:2,9
25:13,23 26:2
saw 6:16 19:23
saying 22:9
scholar 13:12
22:5,21 23:4
23:19,21,24
24:2
schween(phon...
22:22
SCOTT 1:13
SEAN 1:12
second 8:12,15
15:1 25:17
secret 9:21
18:12
security 7:15
9:13
Sedky 12:6
see 7:16 11:2,13
13:25 23:15
25:3 28:18
seeing 14:23
S
seek 5:13
S 1:21 2:4 3:1
seizure 23:15,16
Saad 18:6
send 12:14,15
Saadov 9:22
12:18 16:17
Sadaf 6:15
21:5 24:18
Saeed 7:10 8:4
27:19,20,21
8:19 9:5,24
28:9
27:13,14
sending 21:12
Saeed's 8:18
sent 5:22 22:6
Saif 5:15 6:8,9
27:9
Saud 12:2,3,4,4 separate 4:18
21:24 22:13,14 Service 18:12
22:25 23:1,2
set 30:8,17
23:12,13
seven 4:15
Saudi 7:8 10:5
severed 19:9
12:11 13:5,22 severely 10:12

Sharif 12:6 17:7
Shaykh 4:11 6:8
6:8 7:10,11 8:4
8:13,14,18,19
9:5,24 11:6
13:1,14,15,16
13:17 17:15,17
19:1,3,13,16
22:6 25:14
Shehri 13:14
23:4
shooting 18:17
18:17
shorthand 30:7
30:11
shred 20:25
significant
18:14,16
simply 3:9
single 14:7
sit 9:22,23
site 25:17
sites 22:18
sitting 19:18
small 7:13 26:12
snake 21:23
somebody 5:18
7:7 10:10,11
13:25
son 17:8 20:2,2
20:6,19 21:2
sorry 8:23 28:24
sort 28:4
south 1:20 6:9,9
Southern 3:7
spare 21:10,10
speaking 5:3
specialize 4:21
specific 24:6
speech 25:14
spend 4:14
spending 26:23
spoke 5:18
state 1:7 14:8
19:14 30:4
statement 1:1,5
29:6 30:6
stay 19:5,7

testament 22:22
testify 30:6
testimony 3:3,12
3:14,17,18,20
3:22 14:12
28:20,25 29:2
thank 3:23 16:4
18:20 28:17,21
28:22,23
thing 9:6 17:1
25:9 28:8
think 10:8,13
12:21 13:3
18:8,25,25
19:2,6,20
25:12 27:7
28:16
Third 1:17
14:20
three 10:13
22:17,17
ti 7:16
ticket 11:15
T
tie 21:2
T 1:18 2:4
ties 19:9
Tajikistan 24:17 tight 7:16
take 3:3,15 10:7 time 4:4,6,14 5:8
20:23 23:13
5:9,11,12,20
27:14 28:11,25
5:21 6:15,17
taken 1:5 30:7
7:13,24 8:11
30:11
9:1,3,14 10:21
Talal 12:2
17:11 19:18
Taliban 9:2
20:15 21:16
talk 6:2 7:25
24:4 25:13
20:14
26:4 27:7
talking 9:13
28:17,20 30:7
tank 26:8
today 3:8 28:17
TARBUTTON today's 28:25
1:13
told 5:5,18 6:22
taught 20:22
8:13 13:24
teachings 14:3
20:13 21:14
telephone 13:2
23:11 24:2
19:14
tomorrow 28:18
televi 20:21
28:19
tell 3:9 9:25 10:2 Tooting 6:6
20:23 28:7
top 9:19 12:9
terminology
Toshiba 9:6
7:24
17:3
25:13
Street 1:14
strict 5:3
strictly 5:3
structure 8:14
stuff 10:15
24:19
success 23:11
suggested 19:8
Sultan 12:3
support 5:4,6
16:7,8,9 17:21
17:23 24:21
sure 5:4 28:14
28:20
surprising 7:12
7:17
survival 24:10
swear 3:15,17
3:19,20 29:1,2
29:3,4
swore 30:6

Javernick & Stenstrom, LLC
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 Case 1:03-md-01570-GBD-FM Document 2927-5 Filed 02/03/15 Page 38 of 38

Page 7
transcript 30:9
transcription
30:10
transferred
11:13
transfers 11:10
27:16,24
travel 16:15
24:18
trial 9:11
tribe 21:2
troop 24:5 25:11
true 3:17,19,20
3:22 19:11
23:14 29:2,3,3
29:4 30:10
truly 18:9
trust 6:12 14:19
truth 20:25 30:6
truthful 3:14
trying 8:21
Turki 12:2 23:3
Turning 17:2
Tuwaijri 15:20
15:22,22
two 10:8,13
15:24,25 16:1
16:3 18:25,25
19:3,20,21,21
21:23
typewritten
30:9

USP 1:9
usually 11:19
usury 25:10
Uthaimeen
13:14 14:8
23:4,20
V
vase 22:23
victims 1:16
victims' 3:6
view 24:20
visa 16:10,12
visit 18:9,13
visitation 18:10
vividly 17:1
voice 25:8

W
wage 23:9,10,11
Wahhab 22:4
Wahhabi 21:24
22:2,5,20,21
23:23 24:2
Waleed 12:1,1
want 13:7,25
15:11 16:19
22:24 23:2
28:17,24
wanted 11:6,6
12:16,16 21:10
24:13
war 23:9,10,11
25:13
U
way 13:2 18:19
U.S 4:4
18:19 21:1,21
ule 24:20
26:23
ulema 13:5,8,22
14:4,6,7 22:23 we're 27:7 28:16
We've 27:8
23:4,11,19
24:20 25:2,6,7 week 19:7
ultimately 11:15 went 4:19 5:8,12
5:15,17,19 9:1
Umar 6:8,8
12:24,24 15:7
understand 7:7
19:15,15,18
understanding
20:18 22:25
6:20 13:20
23:1 24:3 27:2
United 19:14
27:2
Uqlaa 13:16
whatnot 11:5
use 7:24

widespread 25:9
wife 26:15
willing 3:13
witness 3:10,15
13:11 16:3
20:8 27:9 29:1
30:5
woman 12:5
18:20,24
wonder 13:6
work 8:21 9:25
10:6 15:20,22
worked 27:16
worker 16:14
World 14:17,17
14:19,20
wrong 5:19 14:8
14:9,9 25:9
wrote 19:24
X
X 2:1,4

1251 1:22
1900 1:14
19103 1:14
1994 19:10
1996 10:19
1997 10:19
1998 4:4,4,7
10:18,22 24:7
1999 12:23
2
2 30:16
2:06 1:5
2:55 29:6
20 1:10 29:7
2003 24:1
2014 1:10 29:7
30:17
2015 30:16
24 30:17
28 1:19
29464 1:20

Y
3
Yassid 17:6
4
Yassin 12:6 17:6
4 2:3
yeah 17:9
year 23:2
5
years 10:16
5880 1:9
Yemeni 16:11
16:12,16
6
York 1:17,17,22
67 1:9
1:22 3:7
Youth 14:19
7
750 1:17
Z
Za 24:13
Zacarias 1:3
3:10
Zubaydah 4:10
0
1
10 19:7
100 20:11 22:7
23:8,18
10017 1:17
10020 1:22

8
81226 1:10
9
9/11 1:16 3:5
90 7:2
98 7:2
99 10:22 24:7

Javernick & Stenstrom, LLC
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FAX (720) 449-0334