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André Birotte Jr Case 5:12-cr-00092-VAP Document 267 Filed 04/21/14 Page 1 of 37 Page ID #:1962 1 ANDRÉ BIROTTE JR. United States Attorney 2 ROBERT E. DUGDALE Assistant United States Attorney 3 Chief, Criminal Division SUSAN J. DE WITT (Cal. Bar No. 132462) 4 Acting Executive Assistant United States Attorney CHRISTOPHER D. GRIGG (Cal. Bar No. 220243) 5 Acting Deputy Chief, National Security Section ALLEN W. CHIU (Cal. Bar No. 240516) 6 Assistant United States Attorney National Security Section 7 1300 United States Courthouse 312 North Spring Street 8 Los Angeles, California 90012 Telephone: (213) 894-4496/5429 9 Facsimile: (213) 894-6436 E-mail: [email protected] 10 [email protected] [email protected] 11 Attorneys for Plaintiff 12 UNITED STATES OF AMERICA 13 UNITED STATES DISTRICT COURT 14 FOR THE CENTRAL DISTRICT OF CALIFORNIA 15 EASTERN DIVISION 16 17 ED No. CR 12-00092(B)-VAP UNITED STATES OF AMERICA, 18 GOVERNMENT’S PRELIMINARY EXHIBIT Plaintiff, LIST 19 v. 20 SOHIEL OMAR KABIR, et al., 21 Defendants. 22 23 24 Plaintiff United States of America, by and through its 25 counsel of record, the United States Attorney for the Central 26 District of California, hereby submits its preliminary list of 27 exhibits the government intends to introduce into evidence at 28 trial. This list includes only those exhibits that the Case 5:12-cr-00092-VAP Document 267 Filed 04/21/14 Page 2 of 37 Page ID #:1963 1 government currently believes are necessary for its case-in- 2 chief. The government specifically reserves its right to 3 supplement this list at a later time and to introduce additional 4 evidence, both in its case-in-chief and as the need arises 5 during trial. 6 Dated: April 21, 2014 Respectfully submitted, 7 ANDRÉ BIROTTE JR. 8 United States Attorney 9 ROBERT E. DUGDALE Assistant United States Attorney 10 Chief, Criminal Division 11 ___/s/_________________________ 12 SUSAN J. DE WITT CHRISTOPHER D. GRIGG 13 ALLEN W. CHIU 14 Assistant United States Attorneys 15 Attorneys for Plaintiff UNITED STATES OF AMERICA 16 17 18 19 20 21 22 23 24 25 26 27 28 2 Case 5:12-cr-00092-VAP Document 267 Filed 04/21/14 Page 3 of 37 Page ID #:1964 1 GOVERNMENT’S PRELIMINARY EXHIBIT LIST 2 United States v. Sohiel Omar Kabir, et al. 3 ED CR No. 12-00092(B)-VAP 4 NO. EXHIBIT IDENTIFIED ADMITTED 5 1 California Department of Motor Vehicles (“DMV”) Identification 6 for Sohiel Omar Kabir 7 2 California DMV Identification for Ralph Kenneth Deleon 8 3 California DMV Identification for Miguel Alejandro Santana Vidriales 9 4 California DMV Identification for 10 Arifeen David Gojali 5 Tan Backpack with Seal of Sierra 11 Club and Contents Seized from Honda Civic on November 16, 2012 12 6 Black Adidas Duffle Bag and 13 Contents Seized from Honda Civic on November 16, 2012 14 7 White Laundry Basket and Contents Seized from Honda Civic on 15 November 16, 2012 (Including 16 Passports, Sony Laptop, and Handwritten Letters) 17 8 White Plastic Bag and Contents Seized from Honda Civic on 18 November 16, 2012 19 9 Green Jansport Backpack and Contents (Including Toshiba Laptop 20 and Passport) Seized from Honda Civic on November 16, 2012 21 10 Books and Prayer Items Seized from 22 Honda Civic on November 16, 2012 11 Blue American Tourister Suitcase 23 and Contents Seized from Honda 24 Civic on November 16, 2012 12 Items Seized from Person of Ralph 25 Deleon at Time of Arrest on November 16, 2012, Including Items 26 from Wallet, Bank Receipts, Card 27 from LAX Firing Range, Various Cards, and Post-It Notes (“Dubai 28 to Afghanistan”), Consulate 3 Case 5:12-cr-00092-VAP Document 267 Filed 04/21/14 Page 4 of 37 Page ID #:1965 Receipt 1 13 Spiral Notebook with Handwritten 2 Notes Seized at 1300 Primrose St., #2, Upland California 3 14 California Driver’s License Seized from the Person of Miguel Santana 4 on November 16, 2012 5 15 U.S. Department of Homeland Security Permanent Residence Card 6 Seized from Person of Miguel Santana on November 16, 2012 7 16 Mexican Passport Seized from 8 Person of Miguel Santana on November 16, 2012 9 17 U.S. Passport Seized from Person 10 of Arifeen Gojali on November 16, 2012 11 18 Green Sea Bag Containing Military- Style Uniforms Seized from 28 12 Rancho Jurupa Place, Pomona, 13 California 19 Green Military Jacket Seized from 14 28 Rancho Jurupa Place, Pomona, California 15 20 Miscellaneous Documents Re: Jihad 16 Found in Orange Nike Shoebox Seized from 28 Rancho Jurupa 17 Place, Pomona, California 21 Excerpt of Transcripts from 18 Audio/Video Recording – 2/15/12 19 22 CD Containing Consensually- Recorded Conversation (Video and 20 Audio) on 5/25/12 Sessions 1-16 22A Excerpt of Transcripts from 21 Consensually-Recorded Conversation 22 on 5/25/12 Sessions 1-16 23 CD Containing Consensually- 23 Recorded Conversation (Video and Audio) on 5/25/12 Sessions 1-6 24 23A Excerpt of Transcripts from 25 Consensually-Recorded Conversation on 5/25/12 Sessions 1-6 26 24 CD Containing Consensually- Recorded Conversation (Video and 27 Audio) on 5/25/12 Sessions 7-9 28 24A Excerpt of Transcripts from 4 Case 5:12-cr-00092-VAP Document 267 Filed 04/21/14 Page 5 of 37 Page ID #:1966 Consensually-Recorded Conversation 1 on 5/25/12 Sessions 7-9 2 25 CD Containing Consensually- Recorded Conversation (Video and 3 Audio) on 5/25/12 Sessions 10-12 25A Excerpt of Transcripts from 4 Consensually-Recorded Conversation 5 on 5/25/12 Sessions 10-12 26 CD Containing Consensually- 6 Recorded Conversation (Video and Audio) on 5/25/12 Sessions 13-14 7 26A Excerpt of Transcripts from 8 Consensually-Recorded Conversation on 5/25/12 Sessions 13-14 9 27 CD Containing Consensually- 10 Recorded Conversation (Video and Audio) on 5/25/12 & 5/26/12 11 27A Excerpt of Transcripts from Consensually-Recorded Conversation 12 on 5/25/12 & 5/26/12 13 27B Excerpt of Transcripts from Audio/Video Recording – 5/26/12 14 28 CD Containing Consensually- Recorded Conversation (Video and 15 Audio) on 5/26/12 through 5/27/12 16 Sessions 15-25 28A Excerpt of Transcripts from 17 Consensually-Recorded Conversation on 5/26/12 through 5/27/12 18 Sessions 15-25 19 29 CD Containing Consensually- Recorded Conversation (Video and 20 Audio) on 5/27/12 Sessions 26-30 29A Excerpt of Transcripts from 21 Consensually-Recorded Conversation 22 on 5/27/12 Sessions 26-30 30 CD Containing Consensually- 23 Recorded Conversation (Video and Audio) on 5/27/12 Sessions 31-33 24 30A Excerpt of Transcripts from 25 Consensually-Recorded Conversation on 5/27/12 Sessions 31-33 26 31 CD Containing Consensually- Recorded Conversation (Video and 27 Audio) on 6/16/12 28 31A Excerpt of Transcripts from 5 Case 5:12-cr-00092-VAP Document 267 Filed 04/21/14 Page 6 of 37 Page ID #:1967 Consensually-Recorded Conversation 1 on 6/16/12 2 32 CD Containing Consensually- Recorded Conversation (Video and 3 Audio) on 6/21/12 & 6/22/12 32A Excerpt of Transcripts from 4 Consensually-Recorded Conversation 5 on 6/21/12 & 6/22/12 33 Excerpt of Transcripts from 6 Audio/Video Recording – 7/6/12 34 CD Containing Consensually- 7 Recorded Conversation (Video and 8 Audio) on 7/11/12 & 7/12/12 34A Excerpt of Transcripts from 9 Consensually-Recorded Conversation 10 on 7/11/12 & 7/12/12 35 CD Containing Consensually- 11 Recorded Conversation (Video and Audio) on 7/16/12 12 35A Excerpt of Transcripts from 13 Consensually-Recorded Conversation on 7/16/12 14 36 CD Containing Consensually- Recorded Conversation (Video and 15 Audio) on 7/18/12 16 36A Excerpt of Transcripts from Consensually-Recorded Conversation 17 on 7/18/12 37 CD Containing Consensually- 18 Recorded Conversation (Video and 19 Audio) on 7/18/12 37A Excerpt of Transcripts from 20 Consensually-Recorded Conversation on 7/18/12 21 38 CD Containing Consensually- 22 Recorded Conversation (Video and Audio) on 7/19/12 23 38A Excerpt of Transcripts from Consensually-Recorded Conversation 24 on 7/19/12 25 39 CD Containing Consensually- Recorded Conversation (Video and 26 Audio) on 7/26/12 39A Excerpt of Transcripts from 27 Consensually-Recorded Conversation 28 on 7/26/12 6 Case 5:12-cr-00092-VAP Document 267 Filed 04/21/14 Page 7 of 37 Page ID #:1968 40 CD Containing Consensually- 1 Recorded Conversation (Video and 2 Audio) on 8/15/12, 8/17/12, 8/21/12, 8/29/12, 8/30/12, and 3 8/31/12 40A Excerpt of Transcripts from 4 Consensually-Recorded Conversation 5 on 8/15/12, 8/17/12, 8/21/12, 8/29/12, 8/30/12, and 8/31/12 6 41 CD Containing Consensually- Recorded Conversation (Video and 7 Audio) on 8/29/12 8 41A Excerpt of Transcripts from Consensually-Recorded Conversation 9 on 8/29/12 42 CD Containing Audio/Video 10 Recording - 8/31/12 (Skype Call) 11 43 CD Containing Consensually- Recorded Conversation (Video and 12 Audio) on 8/31/12 13 43A Excerpt of Transcripts from Audio/Video Recording – 8/31/12 14 43B Excerpt of Transcripts from Consensually-Recorded Conversation 15 on 8/31/12 16 44 CD Containing Consensually- Recorded Conversation (Video and 17 Audio) on 9/4/12 to 9/11/12 44A Excerpt of Transcripts from 18 Consensually-Recorded Conversation 19 on 9/4/12 to 9/11/12 45 CD Containing Consensually- 20 Recorded Conversation (Video and Audio) on 9/5/12 21 45A Excerpt of Transcripts from 22 Consensually-Recorded Conversation on 9/5/12 23 46 CD Containing Consensually- Recorded Conversation (Video and 24 Audio) on 9/7/12 & 9/9/12 25 46A Excerpt of Transcripts from Consensually-Recorded Conversation 26 on 9/7/12 & 9/9/12 47 CD Containing Consensually- 27 Recorded Conversation (Video and 28 Audio) on 9/9/12 & 9/10/12 7 Case 5:12-cr-00092-VAP Document 267 Filed 04/21/14 Page 8 of 37 Page ID #:1969 47A Excerpt of
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