UNITED STATES DISTRICT COURTDISTRICT OF MASSACHUSETTSUNITED STATES OF AMERICA)))v.) Criminal No. 09-10017-GAO))TAREK MEHANNA)
GOVERNMENT’S OPPOSITION TO DEFENDANT’S MOTION TO DISMISS PORTIONSOF COUNTS ONE THROUGH THREE OF THE SECOND SUPERCEDING INDICTMENT
The United States of America, by and through United StatesAttorney Carmen M. Ortiz, and Assistant United States Attorneys(“AUSA”) Jeffrey Auerhahn and Aloke S. Chakravarty, for theDistrict of Massachusetts, and Jeffrey D. Groharing, TrialAttorney, Counterterrorism Section, National Security Division,United States Department of Justice, hereby responds to theDefendants’ motion to dismiss dated July 15, 2011. For the reasonsstated herein and supported by the allegations in the record
, theGovernment respectfully requests that the Defendants’ Motion bedenied.
Information expected to be tendered at trial and previewedto the court previously through the Indictment, Complaint
See Second Superseding Indictment ("Indictment"), ComplaintAffidavit of Agent Nambu and Detention Proffer for a non-exhaustive summary of evidence which, along with supplementalevidence is likely to be elicited at trial as relates to theinstant motion.
Case 1:09-cr-10017-GAO Document 200 Filed 07/29/11 Page 1 of 25