Chicago, May 5: Tahawwur Hussain Rana, Pakistani-Canadian arrested with LeT operative David Coleman Headley for plotting terror attacks on India and Denmark, has sought 'specific' details of the kind of 'material support' he had provided to terror outfits, stating that the prosecution's allegations in the superseding indictment so far have been 'vague'.
Rana's lawyer Patrick Blegen in the 10-page motion filed in a Chicago court, said that the keeping in mind the 'complexity of the case', his client should be informed 'with specificity what material support he is alleged to have provided' to terrorism.
"The superseding indictment is not a clear apprisal of the allegations against the Defendant. Rather, by simply reciting the language of the statute, the superseding indictment keeps the allegations vague and prevents Defendant from properly preparing a defence," Blegen said in the motion.
He said that the government can keep somethings secret but it should be upfront about the allegations instead of hiding behind vague and amorphous language of the statute.
Rana has been charged of providing material help in the form of 'personnel', 'tangible property', 'money', 'currency' and 'false documentation, and identification'.
Apart from such vague description of the material support given by Rana, neither the superseding indictment, nor the discovery provided by the government reveal in detail what these things are, Blegen said.
"There is no inkling of what these things might be," he added.
The superseding indictment accuses Rana of giving his consent to using of an immigration office, sending emails, printing business cards and helping co-accused David Headley in obtaining visa.
Though these actions represent the alleged "false documentation and identification" charge, the indictment including the government's response fail to identify the 'personnel', 'tangible property', 'money', 'currency' and 'false documentation, and identification'.
"If the charges are limited to what is described in the Government's response, then each of the allegations aside from 'false identification and documentation' should be stricken. Otherwise, the government should be required to identify the 'personnel', 'tangible property', 'money' and 'currency' that it has alleged.
"Should the defence be required to sift through all of the discovery to find anything that possibly fits under the absurdly wide umbrella of 'tangible property'," Blegen added.
Rana who had maintained that he had been duped by co-accused David Coleman Headley had pleaded not guilty to all counts of charges against him.
He had earlier sought 'a bill of particulars' - specific details about the 'material support and resources' that he had allegedly provided to terrorist plots.
In response the government said that such a bill is not required as the superseding indictment provides more detail than necessary and it is providing extensive discovery.