Case 1:10-cr-00019-RJD Document 449 Filed 10/14/15 Page 1 of 3 PageID #: 6873 U.S. Department of Justice United States Attorney Eastern District of New York ZA/CAC/MPC 271 Cadman Plaza East F. #2010R00057 Brooklyn, New York 11201 September 28, 2015 By E-mail The Honorable Raymond J. Dearie United States District Court Eastern District of New York 225 Cadman Plaza East Brooklyn, New York 11201 Re: United States v. Abid Naseer Criminal Docket No. 10-19 (S-4) (RJD) Dear Judge Dearie: Pursuant to Federal Rule of Criminal Procedure 32(f), the government respectfully submits the following objections to the Presentence Report issued by the Probation Department on August 27, 2015 in reference to the defendant, Abid Naseer (the “PSR”). In paragraph 15, the PSR correctly states that the defendant’s al-Qaeda point of contact when he returned to the United Kingdom was an individual who used the alias “Sohaib,” and that Sohaib used the email account
[email protected] to communicate with both the defendant and a member of the New York City subway plot, Najibullah Zazi. The government objects, however, to the last statement in that paragraph that incorrectly indicates that Sohaib was actually Abdul Hafeez, al-Qaeda’s head of external operations at the time. According to testimony of Zazi, the individual who used the
[email protected] email account to communicate with him was not Abdul Hafeez but rather one of Abdul Hafeez’s communications conduits, who used the aliases “Zahid” and “Ahmad,” and who reported back to Abdul Hafeez.