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2015 Federal TrialtranscripttranscriptMatthew Levitt — Direct (Part 2) - Day 37 - 2015 Federal TrialMatthew Levitt’s resumed direct examination addressed online radicalization, extremist propaganda, and the boat writing, with qualifications on his analysis and objections concerning testimony and exhibit displays.
Aloke ChakravartySteven D. MellinDavid I. BruckMiriam ConradGeorge A. O'Toole Jr.Matthew LevittMR. CHAKRAVARTYTHE COURTMatthew LevittCourt ClerkMR. BRUCKMS. CONRADMR. MELLINdirectsidebarprocedural
2015 Federal Trial/Day 37/March 23, 2015
6 pages·2 witnesses·2,144 lines
Kevin Swindon testified about digital exhibits and limits on file selection, timestamps, and user identification. Matthew Levitt began expert testimony on extremist propaganda and the boat writing, with defense objections addressing scope, methodology, and exhibit displays.
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Matthew Levitt - Direct Examination Resumed
DirectDirectMatthew Levitt - Direct Examination Resumed Matthew Levitt Aloke Chakravarty

(In open court:)

MR. CHAKRAVARTY: May I proceed, your Honor?

THE COURT: Yes, please.

BY MR. CHAKRAVARTY:

MR. CHAKRAVARTY: Dr. Levitt, thank you for your patience again. We weren't talking about you. Not the whole time.

MATTHEW LEVITT: That's a shame.

(Laughter.)

MR. CHAKRAVARTY: Did you examine some evidence in this case before you drafted your expert report?

MR. CHAKRAVARTY: And before you prepared for your testimony today?

MR. CHAKRAVARTY: And did we go through some of the scope of what I would be asking you today?

MR. CHAKRAVARTY: And just to be clear as to what your qualifications are, do you read or write Arabic?

MR. CHAKRAVARTY: And the materials that you reviewed, what language were they in?

MATTHEW LEVITT: Most of the materials that I reviewed were in English. There were a small number of materials that I reviewed for the report that were in Arabic which I had to go through with someone who could help me understand the Arabic. But the vast majority of the materials were in English. There were some materials in -- I think there was at least one other language which I communicated back to you I couldn't review because I didn't speak the language. It wasn't Arabic.

MR. CHAKRAVARTY: And you haven't reviewed all of the evidence in this case. Is that fair to say?

MATTHEW LEVITT: No, I have not.

MR. CHAKRAVARTY: So specifically, did I provide you with evidence that I told you was from the defendant's computer?

MR. CHAKRAVARTY: Now, Dr. Levitt, can you explain to the jury what the global jihad movement is?

MATTHEW LEVITT: The global jihad movement is an idea. It's not a movement, per se. It's not a group that has an office. It's not led by a committee or an individual. It's the idea of like-minded people who are pursuing in their mind this idea of a global jihad, and it will include people from different parts of the world who even disagree with one another on certain precepts, theological ideas, tactical ideas. It will include people who say that their implementation, their operationalization of these ideas should be local, in their home countries, and others will say, no, it should be done more globally. But the idea behind it that there is a need for a global effort on behalf of Muslims to unite as a nation among the Arabic, to defend itself, to do that through acts of violence, this is something that has a continuum going back several decades now through to today. And there are things that have been constant in terms of some of the core precepts, some of the key pieces of ideology, some of the key ways that it manifests itself, and there are things that have changed over time in terms of geographic focus, in terms of emphasizing this ideological precept more than that ideological precept. So it is accurate to say that there is, especially in the minds of its adherence, a global jihadi movement. You have people who, whether they're talking to other human beings or they're reading or hearing or watching this on various types of media on their computer screens, feel that they are part of a large, singular following, like-minded followers. But that doesn't mean we're talking about an organization incorporated or an office or anything like that.

MR. CHAKRAVARTY: So do you have to be in a terrorist group to be part of the global jihadi movement?

MATTHEW LEVITT: No, by definition you don't. It can and certainly does include terrorist groups, and it can include individuals, what we describe today as home-grown violent extremists or lone offenders who will feel that they are part of something bigger and will be acting in concert with and on behalf of something bigger but don't have to sign up, don't carry a membership card. Once upon a time you really had to travel to meet with one of these groups, to get trained by one of these groups, to meet people. Nowadays the world is flat through social media. You can get your indoctrination, you can get your motivation, you can get your schooling and skill set just online and you don't have to have traveled, or even necessarily communicated with anybody, in order to be able to carry out an action that in your own mind would be in concert with those other people.

MR. CHAKRAVARTY: So what ties adherence to the global jihadi movement together?

MATTHEW LEVITT: Ideas. Ideology both in terms of the things that motivate them, the ideas that motivate them, the things in which -- for which they think they're acting on behalf of, and then also frequently the how; the what they do. So you don't have to have met with an individual or belonged or signed up or pledged an oath, a pledge of loyalty or allegiance, in order to believe that there is a requirement to engage in militant jihad; that the primary type of jihad is not what is usually called the more important jihad, which is self-improvement, but rather, the lesser jihad of militancy; that this is to be done on behalf of this larger Muslim nation, the ummah; that one's affiliation really is to that ummah and not to any -- this Muslim nation, not to any local ethnicity, nationality community; that there are rewards for engaging in this behavior, rewards of a national level, this kind of altruistic doing on behalf of others who can't, coming to the defense of the people who can't defend themselves. And also, a more selfish deliverance: Forgiveness of past sins, getting into heaven. Not just heaven but the highest levels of heaven. And so these types of ideas also remove disincentives. So for most people the idea of killing innocents is forbidden, but what if through this ideology it's no longer forbidden; in fact, it's permitted. And what if it's no longer just permitted but it's also praiseworthy. And what if it's not only praiseworthy, but it's also a personal obligation upon you if you want to be a good member of this community, this ummah, if you want to be a good Muslim. So you've now gone the spectrum, from killing innocents is not okay all the way to this is something that's not only okay, it's not only praiseworthy, this is something that is incumbent upon you. And so these types of ideas have motivated a whole host of different types of characters, from people who operate as groups to people who coalesce together as networks that may have some tangential connection to a group or may not, to individuals, to lone offenders.

MR. CHAKRAVARTY: So there are some concepts there that I just wanted to have you explain a little bit to the jury. I think you started to explain what jihad was. Are you a religious scholar?

MR. CHAKRAVARTY: Okay. So what is the basis of your understanding of these concepts?

MATTHEW LEVITT: Well, one of the things that I've developed expertise in in the course of my studying terrorism studies is the concepts in the process of radicalization. Arguably, one of the most important issues we're dealing with today: How is it that people are being radicalized around the world to want to go out and carry out acts of terrorism in whatever venue that may be: at home, today in Syria, whatever it is. And within that area of study I've had to learn a lot of different things, from things that relate to social work and psychology, because one aspect that drives people is either local grievances, particular circumstances to an individual, anger over international grievances, foreign conflicts; but then the other half of the equation is ideology. And the fact is that Islam is not terrorism full stop, and the fact is that all religions have the capability for extremism, but the fact is that today the radicalization that we are seeing kind of as almost a global insurgency is happening in the name of Islam; not in the name of the Islam practice by the vast majority of Muslims, but it's happening in the name of Islam, and the twisting of certain Islamic concepts. And so I've spent a tremendous amount of time studying these to have a better understanding, not as a Muslim scholar to be sure, but as a scholar of terrorism studies, how are these being used and implemented to radicalize, motivate and then operationalize, dispatch and send people to engage in these types of acts of terrorism.

MR. CHAKRAVARTY: So you explained that there was a kind of a greater jihad and a lesser jihad. How do adherence to the global jihad movement refer to jihad?

MATTHEW LEVITT: So the greater jihad is traditionally the jihad of one's self, and that is self-improvement, becoming a better person, and that can be as behaviorally, just being a better person, being kind to one's neighbor and family, and also becoming a more pious person, you know, giving more charity, making the pilgrimage, et cetera. And these are praiseworthy. The lesser jihad traditionally was militant, was a violent jihad. And it can be done in a defensive manner and it can be done in an offensive manner. The radicalizers within this global jihadi movement over a period of decades -- and different individuals have done it can differently, but one of the common themes is their argument that, in fact, it is this lesser jihad, the jihad of militancy, which is actually the more important, the more religiously obligatory, the more impactful; that if you do this, and you do this violent jihad faithfully and with proper intent, not to enrich yourself or not to become a famous person but for the right reasons, then it can be even more powerful than someone who, say, was a pious person all their life and prayed five times a day or what-have-you, trying to promote this idea that violent jihad is something primary, violent jihad is something core to the practice of a good Muslim and that it is a personal obligation. There's this idea within Islam of something that is the obligation of a community, which means not every single individual has to do it, and something that is a personal obligation, that is the obligation of each individual. And the jihadi idiologs go to great lengths to say that this militant jihad, this is an obligation on the individual. So if you, individual, want to be a good practicing Muslim, this is something you need to do, and you can't shirk that responsibility.

MR. CHAKRAVARTY: You mentioned something called the ummah, U-M-M-A-H. What is that?

MATTHEW LEVITT: The nation. The Muslim nation.

MR. CHAKRAVARTY: Now, is there a relationship between the global jihad movement and the United States of America?

MATTHEW LEVITT: Not a friendly one. So the United States has for many years now been at the receiving end of much of the anger of a global jihad movement and for a variety of reasons. Idiologs within this milieu have described the United States as the force backing regimes, in the Middle East in particular, that were seen to be totalitarian, bad to their citizens, and insufficiently Islamic. And that the way, for example, to defeat Mubarak in Egypt back in the day, or others in other Arab countries or Muslim countries, Muslim-majority countries, would be not necessarily to try and take the fight to those governments which were very heavy-handed, but to take the fight to the United States, their backer. And if the United States were to withdraw its backing for these countries, they would fall like dominoes. There's anger over the United States and its perceived interventions against Muslims around the world in conflicts around the world. So there will be anger about the United States in Iraq, the United States in Bosnia, the United States support for Israel in the context of Israeli-Palestinian conflict, et cetera, and it comes down to a foundational idea that there's a war between the Muslim ummah and the West with the United States kind of leading the West.

THE COURT: Mr. Chakravarty, we're just about at one o'clock. I think perhaps we'll take the lunch recess at this point.

COURT CLERK: All rise for the Court and the jury. The Court will take the lunch recess.

(The Court and jury exit the courtroom and there is a recess in the proceedings at 1:00 p.m.)

COURT CLERK: All rise for the Court and the jury.

(The Court and jury enter the courtroom at 2:09 p.m.)

COURT CLERK: Be seated.

THE COURT: Go ahead, Mr. Chakravarty.

BY MR. CHAKRAVARTY:

MR. CHAKRAVARTY: Good afternoon, Dr. Levitt.

MATTHEW LEVITT: Good afternoon.

MR. CHAKRAVARTY: Can you explain how the global jihad movement has evolved over the last decade?

MATTHEW LEVITT: The global jihad movement has evolved over several decades, but over the past decade in particular we've seen really tectonic changes, that is to say, you know, about ten years ago the biggest threat on the horizon was an organized al-Qaeda. But with several years of international counterterrorism efforts, al-Qaeda itself began to almost break apart, and with the rise of social media and kind of the flattening of the earth and the ability to communicate via social media around the world you had two phenomena: The first is the rise of al-Qaeda affiliates, both formal affiliates, that is to say, recognized by al-Qaeda, and others, kind of al-Qaeda want-to-be affiliates, groups that saw themselves like al-Qaeda, aspired perhaps to maybe officially be part of al-Qaeda, but whether they were officially or not were of that same ilk in different regions. The ones that were truly al-Qaeda franchises would have their focus in a region. So, for example, al-Qaeda in the Arabian Peninsula, in Saudi Arabia and Yemen; al-Qaeda in Islamic Maghreb in North Africa; the Shabaab group in Somalia. And they would certainly do things locally, but they would also have interests in things international. Other groups that were more aspired to be part of al-Qaeda, some of which had asked to join but hadn't received a response, others that hadn't even asked, they might be more local in their activities than, say, the Sinai desert or other places. With time, again, more crackdowns from -- counterterrorism crackdowns by the international community and the rise of social media, what we found is a new phenomenon that in some ways is more difficult to contend with. I won't necessarily say more dangerous, because it's not quite as capable to carry out kind of spectacular attacks, but much harder to identify and stop, and that is the home-grown violent extremists, HVE, or the lone wolf or lone offender, as I prefer to call it. And this can be a lone individual or it can be a lone small group of individuals. These are much harder to stop -- identify and stop because they don't necessarily engage in the types of activities that set off the trip wires that security intelligence, counterterrorism entities have placed to try and figure out who's doing what; in particular, three: travel, communication and moving and receiving money. So if they're not setting off these trip wires, if they're not going to bring themselves to the attention of law enforcement by virtue of traveling to a place that terrorists are known to go to, or communicating with people who are known or suspected of engaging in terrorist activity, or sending funds to or receiving funds from people who are known or suspected of being involved in terrorist activity, they stay under the radar and they're much harder to identify. And many officials, both here in the United States and abroad, have articulated this concern, of just how hard it is to deal with these types of home-grown violent extremists. They won't necessarily have the capabilities to do a spectacular attack, but the expectation is -- and the President himself said this -- that over time they're going to be more frequent. And since terrorism at the end of the day is not necessarily about killing the maximum amount of people, wounding the maximum amount of people alone, it's also about getting media attention, it's also about literally terrorizing society, making people afraid, this can be a very, very effective means of accomplishing that goal.

MR. CHAKRAVARTY: And so in the last ten years, has this decentralized way become the strategic choice of the global jihad movement?

MATTHEW LEVITT: So this decentralization is a fact of life, and it means that it's not like the old school terrorism has gone away. Al-Qaeda in the Arabian Peninsula, for example, has attempted to carry out multiple attacks targeting the West over the past few years. There are other al-Qaeda elements, one based out of Syria today that we're very concerned, is plotting out of Syria -- not attacks in Syria but attacks in the United States and in Europe. That kind of organized al-Qaeda or al-Qaeda franchise model still does exist. But on top of that, the much more immediate threat and phenomenon that we're seeing more frequently is this phenomenon of the home-grown violent extremist, the individual or the small group.

MR. CHAKRAVARTY: So is there a command and control relationship between the individual, the small group and one of these terrorist organizations?

MATTHEW LEVITT: There need not be, and in most of the cases we're seeing today there isn't. Again, that doesn't mean that there can't be. And over the past few years there have been some instances, although at this point they're really more of the exception, where there is I wouldn't say full command and control, but interaction between senior, say, al-Qaeda or other terrorist group leaders and operatives trying to do things abroad. Most of the plots we're seeing nowadays are not like that. They do not have command and control. And in some cases there is some communication, in many cases there is no communication, and the -- as if command and control authority, say al-Qaeda, will simply log the attack after it happens, this was people following on our call to go do what has to be done. You don't have to come to a foreign battlefield to do it. You're welcome to if you want to, but you can also do it at home, especially in the West. And that's become a major theme of radical propaganda: Do it at home.

MR. CHAKRAVARTY: And are the terrorist organizations that are part of the global jihad movement, are they monolithic in the sense of their encouragement of this type of activity?

MATTHEW LEVITT: They're not monolithic. They encourage this type of activity. They also encourage people to travel to other places. A common refrain is: Come here. But if you don't come here, do something at home. We discussed earlier this personal obligation, right? You can't shirk this responsibility. If you still are intent on living amongst unbelievers, then at least you've got to do what you've got to do: terrorist attacks at home. They welcome you to come and fight somewhere else too. And this is not only al-Qaeda; now the so-called Islamic state or ISIS --

MR. BRUCK: I'd object to bringing in organizations that have nothing to do with --

THE COURT: As a general background I think it's all right. Go ahead.

BY MR. CHAKRAVARTY:

MR. CHAKRAVARTY: You were talking about ISIS. That we've all heard of, ISIS. How does that relate to the global jihad movement?

MATTHEW LEVITT: ISIS is the latest incarnation of this global jihad movement, a group that in the region in the Middle East is fighting with al-Qaeda and yet it won't be uncommon to see people who have a primary affiliation with al-Qaeda and people who have a primary affiliation with ISIS somewhere in diaspora doing something together as we've seen in just the past few weeks, in one instance. ISIS, like al-Qaeda, has glossy magazines, and even better than al-Qaeda very impressive online radical and radicalization literature. And it too explicitly says: Come. But if you don't come -- you don't have to come -- just do something back home.

MR. CHAKRAVARTY: So is there a common narrative to these global jihadi groups?

MATTHEW LEVITT: Well, as we discussed before, there's plenty of things that divide them on theological points, on points of strategy. What should you do first? Should you target the near enemy; say, for example, the government of Egypt first, or should you target the far enemy, say the government of United States first, or could they be done concurrently? Where there is this commonality is in the motivational ideology, the idea that there is a personal obligation upon every good Muslim, every member of this ummah to this Muslim nation to do their part for which they can be rewarded both altruistically, that is to say, giving of themselves on behalf of this ummah, defending those who are defenseless. And you can do that -- you know, you can defend people in, you know, some foreign conflict at home if you're in the United States by targeting the United States, which is this head of the snake as it were, but you also get this personal, if you will, selfish individualized benefit which is absolution, deliverance, entry into the highest levels of paradise.

MR. CHAKRAVARTY: So is there a particular demographic or particular traits of people that this narrative attempts to appeal to?

MATTHEW LEVITT: Well, as I said earlier, you know, Islam does not equal terrorism full stop. I can't stress that enough. But this particular set of radicalized ideologies is an extremist variation of Islamic concepts. And so it is targeted towards Muslim youth -- youth in particular. Not only Muslim but particularly Muslim youth. Beyond that, you know, there is no single profile. We have people who have been radicalized who were experiencing poverty and lack of opportunity, and we've had people who were very successful professionals, engineers, doctors, you know, people who had money, people from the West, people from the Middle East, people who seem to be quite well integrated into their societies, people who are not at all well integrated into their societies. The bottom line is, the way I describe it is there are two general baskets into which the issue sets fall, and it's like a salad bar of options. If you go to the salad bar and I go to the salad bar, we're going to, odds are, pick slightly different salads. What makes you laugh and me laugh and you cry and me cry is going to be slightly or very different. We're all individuals. It's the same for radicalization. There tends to be something that provides a cognitive opening. Some combination of local grievances can be -- I just had a case last week -- my girlfriend dumped me; to feeling discrimination; to feeling pulled by different types of identity crisis: Am I primarily, saying this country, American? Am I primarily Muslim? Is my primary national ethnic identity or national identity being an American? Is it being part of the Muslim ummah? Do I belong? Those types of local grievances. I'd also include in that first box the international grievances: concern about foreign conflicts, Palestine, Iraq, Chechnya, this type of thing. Those types of issues create in an individual a cognitive opening into which dangerous ideas can then fill the gap. So there's going to be some component of grievance, there's going to be some component of ideology, and for every single person the division of how much grievance and how much of which grievance and how much ideology and what type of ideology -- not only how much ideology, but how much exposure to ideology, over how much time, over how many medium, by individuals, not by individuals, online only, will be different, and we've seen cases that can fit anywhere across that spectrum.

MR. CHAKRAVARTY: So are you talking about the process of radicalization?

MR. CHAKRAVARTY: What is radicalization?

MATTHEW LEVITT: Radicalization is the process by which an individual adopts extremist or radical ideas and then possibly is mobilized to operationalize, to do something about them. You can, of course, have someone who adopts radical ideas and doesn't act on them, right? And ideas, even radical ideas, are protected in this country. So our concern is ultimately about action. Within the -- within the study of radicalization there are two schools of thought, however. One says: Yes, ideas are protected, but we have to be concerned or at least start being concerned when people start digesting really radical ideas which are about violence, whether or not they actually then have or have yet acted on it, prefer that they might potentially very quickly. And others say: No, dangerous ideas are protected in this country and we're quite proud of that, and so the only thing we're concerned about is action. What's absolutely clear is that for an individual who has gone through a process of radicalization and mobilization and operationalize those and has carried out an act of violence, that is, by definition, full-fledged radicalization. This is not someone who maybe is contemplating radical ideas like you might contemplate, you know, you might study fascist ideology in college; this is someone who has then acted on them. And so by then any definition of either of those two schools of thought, this would obviously be a case of concern.

MR. CHAKRAVARTY: And how does radicalization take place?

(Laughter.)

MATTHEW LEVITT: There is no one model for how radicalization takes place. Every single one of us is an individual. Our experiences are different. What makes us happy and makes us angry is different and, therefore, every single case of radicalization is going to be at least a little bit different. And you'll be able to find cases that are similar to one another, and that may be interesting to look at, but at the end of the day it's the combination of these two baskets: grievances, local and international; and some type of ideology. Now, mind you, of course, it doesn't have to be a deviation of Islam. It doesn't have to be radical Islamist ideology, right? We've seen a rise of white supremacist activity in this country since we elected an African-American president, right? But that combination of grievance and ideology. Some thing, either someone or some -- now in the age of social media and digital media, someone doesn't have to be in person, but someone has to be able to kind of hold your hand and pull you across that dividing line to the point where you mobilize and actually do, operationalize, these ideas.

MR. CHAKRAVARTY: When you say "someone," what do you mean?

MATTHEW LEVITT: There is a radicalizer in every case that we'll see. It won't necessarily be someone with a clear-cut name. The radicalizer can be the totality of things that someone has heard and read and watched online; it could be exposure to individuals; it could be long treatises; it could be 140-character tweets. In all likelihood, it will be some combination of that and everything in between it. Our concern is that, you know, unlike, say, ten years ago or so when much of the material that was put out there online were these mostly theological treatises written in language -- if it was written in English at all, and it wasn't particularly accessible. Nowadays you have glossy magazines; Twitter accounts; Facebook accounts; treatises; videos; chants, nasheeds, which are like devotionals -- which can be devotional in a purely, you know, religious way, but many radical Islamist groups use them to -- in singing a song to some type of percussion music promoting dangerous radical, explicitly violent ideas -- all these types of media are accessible today and it's removed barriers to entry. You don't have to be able to become an Islamic jurisprudent, you don't have to wade through really complicated writings of people who are a whole lot older than you and whose English maybe isn't so great. You can hear, you can read, you can watch people who speak your language -- not just English but American English; not just American English but colloquial English -- and put things in terms that you use every day and that removes barriers to entry.

MR. CHAKRAVARTY: Is there a way to measure how radicalized somebody is?

MATTHEW LEVITT: Lots of people have tried. The simple answer is: Until someone actually acts, there's complete room for debate, all right? There's no quantifiable, this is a 3.2 radicalization.

MR. BRUCK: Your Honor, if you'd please, I'm going to object to any further testimony along this line without a showing of any scientific basis for measuring how radical someone is whether they have acted or not. This is a Daubert issue. We did not have notice of this.

MR. CHAKRAVARTY: I can move on, your Honor, but it's a simple, you know, general question.

THE COURT: All right.

BY MR. CHAKRAVARTY:

MR. CHAKRAVARTY: Does the length of time that someone consumes radical material indicate how radicalized somebody is?

MATTHEW LEVITT: No. Again, we're all individuals. For some people, to get radicalized you'd need to be exposed to material for a long period of time; for other people it's very, very quick. The problem that we have nowadays -- and this is something I studied closely, especially over the past few months -- is that the pace of radicalization is much, much faster, the time period is much, much shorter over the past few years than we have seen in the past.

MR. CHAKRAVARTY: How about the nature and the volume of propaganda or other materials that somebody amasses. Is that dispositive as to how radical somebody might be?

MATTHEW LEVITT: Not necessarily, no. Again, it depends on the individual. Some people would need to have a lot of material and be reviewing it all the time and really, you know, immersing themselves in it, some people, short-term immersion of just a few particularly inspiring pieces of radicalization written, audio, video will be enough.

MR. CHAKRAVARTY: In the course of your study, have you found a way to predict whether somebody was going to be a terrorist or not?

MATTHEW LEVITT: No, and I don't know anybody else who has.

MR. CHAKRAVARTY: What are the channels through which this global jihadi movement actually recruits people to engage in the activities that you're talking about?

MATTHEW LEVITT: So there's a spectrum again. You know, back in the day it was primarily by drawing people to terrorist training camps around the world, and there are still people who will travel either for training camps or for opportunity to fight in foreign conflicts, but that is increasingly the exception. Increasingly, it is reaching out to people, and not necessarily to a particular individual, in kind of a direct communication, through online social media communication: putting out there these audio files, these video files, these documents manifestos that people can access, you know, in their mama's basement without having had to travel. And that is our greatest concern right now.

MR. CHAKRAVARTY: And how do they use the Internet to communicate this information?

MATTHEW LEVITT: Well, they post things online. It can be radicalization material; it can be, you know, if you want to contribute to the cause in other ways, such as giving money, they can communicate ways of giving money; they communicate if you want to -- if you decide that you'd rather travel someplace, there's now instructions on here's places you could go. Here's types of things you should bring. Here's what you'll need to know if you're going to go someplace. If you decide not to go, here's what you could do. So it's not just the question anymore about radicalizing and mobilizing, inspiring someone with these radical ideas, now it's also operationalizing them. Again, removing another level of barrier to entry. This time not barrier to radicalization but barrier to operationalization. And this has, therefore, been described as "terrorism on the go," right? So you want to know how to put together a bomb? You can see that online. You want to know how to communicate securely? There's stuff about that online. You want to know, on the other hand, how to go and travel someplace and what to expect when you get there and what types of things you should bring? That's available too.

MR. CHAKRAVARTY: Are there particular websites that these extremist groups use?

MATTHEW LEVITT: There are a whole host of them. And some of them got knocked down and they pop up elsewhere. The most common theme about them is there are certain types of common radicalization propaganda that they tend to put up on there; in particular Inspire magazine which was published by al-Qaeda in the Arabian Peninsula.

MR. CHAKRAVARTY: Okay. We'll talk about that in a moment. I'm just going to ask you about a few websites and ask if you're familiar with these. Tibyan Publications?

MATTHEW LEVITT: Tibyan Publications, if I recall correctly, actually isn't up anymore. But it was -- and its publications are still available on other websites, mirror sites. But it was a prominent jihadi kind of online publication house, if you will, for a whole host of different types of al-Qaeda and other publications.

MR. CHAKRAVARTY: Kavkaz Center?

MATTHEW LEVITT: Kavkaz Center is a website that was affiliated with the Chechen jihadi movement.

MR. CHAKRAVARTY: Hunafa.info?

MATTHEW LEVITT: Also a website with jihadi information. And if I recall, also about -- related to Chechnya.

MR. CHAKRAVARTY: Ghuraba.info?

MATTHEW LEVITT: Ghuraba, the stranger. Again, another one of these websites where you could access this type of material.

MR. CHAKRAVARTY: And then there are -- a website, one called Memri, M-E-M-R-I. Are you familiar with that?

MR. CHAKRAVARTY: And also Jihad Watch. Are you familiar with that?

MR. CHAKRAVARTY: What are those?

MATTHEW LEVITT: They're a host of websites that are maintained by people who track radicalization and track extremism and terrorism. There's a spectrum, thereto, from the left to the right, and those are both examples of kind of anti-jihadi, anti-terrorism websites that maintain a collection of this material for scholars and counterterrorism people to be able to access without accessing the jihadi websites themselves.

MR. CHAKRAVARTY: Now, does this movement specifically message to people in the United States?

MR. CHAKRAVARTY: How does it do that?

MR. CHAKRAVARTY: And what is that message?

MATTHEW LEVITT: The message is, again, as we've said, you can come here, wherever the "here" may be in that particular case, but if you don't, you should do what has to be done at home. And you can do things at home. Take the fight to the enemy, the United States, at home. In some cases it will be alternative messages: If for some reason you think you absolutely can't, then you should at least -- you know, be a fighter, you should at least fund a fighter. The general theme is: This is a personal obligation; you have to do at least what you can do.

MR. CHAKRAVARTY: And what's the value proposition offered by their narrative?

MATTHEW LEVITT: The value proposition, as we've discussed, is twofold: On the one hand, it's selfless, right? Do on behalf of the greater ummah, the greater nation. There are people who are being oppressed by the United States and others; there are people who can't -- who are defenseless, who can't defend themselves. We need to defend them. You need to defend them. You need to be one of these elite. This is a personal obligation. And then you'll be rewarded for that. There's also something that is a benefit to the individual, you might describe it as the selfish or at least the personal benefit, which is this absolution, this cleansing of past deeds, and the ability, even if you weren't such a great believer before -- which includes, by the way, being a Muslim, just not a jihadi Muslim -- in these people's world view, this can give you absolution. So this is so much greater a service. This type of violence is so much greater a religious service that it can absolve even if you haven't been a good person at prayer or going on the Hajj, the pilgrimage, or giving of charity, a zakat, et cetera.

MR. CHAKRAVARTY: You mentioned a moment ago Inspire magazine. What is that?

MATTHEW LEVITT: Inspire magazine is a glossy English language magazine produced by al-Qaeda in the Arabian Peninsula out of Yemen. Its publication was a watershed, as I said earlier, because it was written in American colloquial English. So it's so accessible and understandable to Western, in particular American, youth. Some of the authors were people who were born or lived in the United States and could speak to their American experiences to be able to make a connection with the reader. It's a glossy magazine like a Newsweek or, you know, a typical American magazine only it's not about, you know, the current news around the world; it's about jihad, the need to do jihad, to radicalize and mobilize people to jihad, and then removing the last barrier, giving how-to instructions. So you don't know how to build a bomb? Here's how you build a bomb. Step-by-step instructions with pictures, very, very clear, not unlike the kind of step-by-step instructions with pictures that my kids use when they put together a Lego that I bought them.

MR. CHAKRAVARTY: Who started this magazine?

MATTHEW LEVITT: So the key person behind it was Anwar al-Awlaki. Anwar al-Awlaki was an American-born Islam imam, preacher, lived in the southwest, lived at one point in Virginia, came up at one point in the 9/11 investigation, and ultimately left the United States and moved to Yemen. By virtue of having lived here much of his life, he was able to draw on those experiences, speaking American colloquial English combined with his knowledge of radical Islamist propaganda. And he was a gifted speaker, very calm, very professorial, and was an extraordinarily effective radicalizer.

MR. CHAKRAVARTY: What happened to him?

MATTHEW LEVITT: He was killed in a U.S. drone strike.

MR. CHAKRAVARTY: Aside from Inspire magazine, what other types of media information did Anwar Awlaki produce?

MATTHEW LEVITT: Aside from the video, the most famous are the audio. Some are him over-speaking some of these nasheeds, these chants, these devotionals, in this case not devotionals about kind of mainstream religious ideas but violent ones, and also a whole series of -- a lecture series. He has two different types of lecture series: some that are about the history of Islam, kind of Islam 101; the history of the life of the prophet. It's called "The Life of the Prophet Series," or another one is the "Hereafter Series." And some of these earlier series are not jihadi at all; they are introductions to Islam. And they were very, very popular among people who were either Muslim but weren't particularly practicing or among converts and potential converts. Again, a gifted orator, a very kind of calm and steady tone. But then he developed these explicitly violent jihadi sermons. And authorities and fellow Muslim preachers both have cited their concern about the continuum between these two sets of lectures, that many people get hooked on the Awlaki lectures that are just about the history of Islam and that don't call on people to engage in violence, but they get hooked on them, this guy's now effectively their kind of online teacher, and then they follow him into his expressly violent, there's an obligation upon you to engage in terrorism, violence lectures. And there's tremendous concern, therefore, today even about those earlier lecture series.

MR. CHAKRAVARTY: So if I may call up for the jury, your Honor, 1143-71, which is in evidence. Page 1.

MR. CHAKRAVARTY: Does this is appear to be a translation of one of his lectures?

MR. CHAKRAVARTY: Go to page 2, please. I'm sorry. Page 3, and page 4.

MR. CHAKRAVARTY: And is this a picture of Mr. Awlaki?

MR. CHAKRAVARTY: And it has a little biographic of him as well?

MR. CHAKRAVARTY: If you would go to page 8 quickly?

MR. CHAKRAVARTY: Can you read the portion of this lecture that I just highlighted?

MATTHEW LEVITT: "So let them spend their money as that's how they will be defeated as Allah 'Azza wa Jall says they need to spend their money first and then they will be defeated. So we should be happy that they are spending their money to fight Islam as that means that victory for Islam is soon; victory is on its way."

MR. CHAKRAVARTY: What's the significance of that passage?

MATTHEW LEVITT: He's arguing that it's not just that the effective attacks are in the actual explosions; let them spend their money on trying to prevent us from carrying these out, and that too is a means of being effective. They're spending their money to fight Islam. In these radical interpretations of Islam, there's supposed to be this penultimate battle where the West tries to defeat Islam. That means that this ultimate victory for Islam is coming, this process has begun, victory is on its way.

MR. CHAKRAVARTY: Mr. Bruemmer, can I call up Exhibit 1280, which is also in evidence.

MR. CHAKRAVARTY: Do you recognize this quote?

MR. CHAKRAVARTY: And what is that?

MATTHEW LEVITT: "They will spend their money and they will regret it and then they will be defeated."

MR. CHAKRAVARTY: And is that a paraphrase of what we just read?

MR. CHAKRAVARTY: Aside from Anwar Awlaki, are there other major figures in the contemporary global jihad movement?

MR. CHAKRAVARTY: Are there various al-Qaeda figures?

MR. CHAKRAVARTY: Are you familiar with somebody named Abdullah Azzam?

MATTHEW LEVITT: Abdullah Azzam is often referred to as the grandfather of the modern-day jihad. He was a Palestinian who went to Afghanistan and became one of the leaders of the jihad against the Soviets in the 1980s. And one of his key partners there was a guy who would later become very famous named Osama Bin Laden. Azzam wrote a treatise, the most significant of which was "Join the Caravan," that is to say, join the caravan of the mujahidin, the jihad fighters. He later wrote that he had no idea it would become as popular and influential as it did, but it did, and it is often found among the radicalizing literature of people radicalized to violence today and in the period since then, in the 1980s. It's been often referred to as the key manifesto, the go-to thing that people need to read to understand the kind of history. That was written, of course, in the context of come fight the jihad against the Soviets here in Afghanistan, but what he argues there is that there are many reasons why jihad is obligatory and you need to do it, and it's something that's incumbent upon you to do it. And those are critical concepts for moving someone beyond traditional Islam to this radical Islamist ideology that says that there is an obligation to engage in jihad against the enemy.

MR. CHAKRAVARTY: Now, people like Awlaki and some of the al-Qaeda figures, did they refer back to these Azzam works?

MR. CHAKRAVARTY: And did Azzam himself refer back to others who preceded him?

MR. CHAKRAVARTY: Are you familiar with someone named Sayyid Qutb?

MATTHEW LEVITT: Sayyid Qutb is a major figure in the Muslim brotherhood, and his major contribution to the concept of jihad that we're talking about was the idea that it's not sufficient to try and work to bring Muslims back to the proper -- the proper carrying out of their faith, the proper observance of their faith, and only then to engage in jihad against the enemy; he felt that the jihad against the enemy had to be uploaded, front-loaded, and that by virtue of people participating in that jihad, they would also become better Muslims. Now, as we discussed earlier, there's many disagreements within the kind of global jihadi movement ideological waterfront. And many people in al-Qaeda would then say Qutb didn't go far enough. There are many people who were Muslim brotherhood who didn't subscribe all the way to al-Qaeda. But those ideas of his were picked, maybe even cherry-picked, and became key pillars of the writings of still more radical people like Abdullah Azzam.

MR. CHAKRAVARTY: Now moving from individuals to places, you talk a little bit about what the geopolitical situation was in the Caucasus, particularly in Chechnya, as it relates to this global jihad movement in the last 20, 30 years?

MATTHEW LEVITT: When the Soviet Union fell, the Republic of Chechnya rebelled. And there were two distinct wars in the 1990s. Within these, there also grew a jihadi element. And Chechnya became a prominent rallying cry for the jihadists. Not all of this war was jihadi; there were Chechens who were rebelling against the new Russia and they weren't jihadis. But the jihadists used this as a platform. And many key jihadists tried to go to Chechnya. Many did. Some current al-Qaeda leaders tried to go and made it close but didn't get all the way there, but the fact that they were trying to get there shows how prominent it was at the time in the jihadi landscape. And it has continued to be ever since one of many foreign conflicts that jihadis have taken for themselves, whether it was originally theirs or not, to use to radicalize people. Look what the infidels, in this case the Russians, are doing to Muslims, in this case in Chechnya.

MR. CHAKRAVARTY: Are you familiar with Commander Ibn al-Khattab?

MR. CHAKRAVARTY: And who is he?

MATTHEW LEVITT: Commander Khattab was a Jordanian -- some say Saudis, but most likely Jordanian -- who became a very senior jihadi commander in Chechnya. After he was killed, battalions were named for him. There are Chechen battalions fighting in the Syrian conflict now. I believe one is named for him. He became a very prominent personality in the Chechen context, in the Chechen jihadi context.

MR. CHAKRAVARTY: Moving on to Syria, what's the role of the Syrian conflict in this global jihadi movement?

MATTHEW LEVITT: Can't be overstated. We just marked four years since the beginning of what, when it started, was a rebellion against the rule of Bashar al-Assad. But as has been the case in Chechnya and other place, jihadis use this opportunity to take a rebellion and make it a jihad of their own, and it has become a rallying cry around the world. We talked earlier about the different types of radicalization.

MR. BRUCK: I'm going to object to the whole discussion of Syria that goes beyond the date of any of the events alleged in the indictment.

THE COURT: Overruled.

MATTHEW LEVITT: Sticking even to the first two years of the Syrian conflict two years ago, there's a whole host of different things that drew jihadis to this conflict. Some were drawn by jihadi ideology and wanted to go fight with the next incarnation of al-Qaeda, and some were drawn to defend Muslims, Sunni Muslims who were being butchered by the Assad regime. Some of those people didn't go farther and stayed with what you might call moderate, or non-Islamist, non-jihadi battalions. Many did move to still more radical battalions.

Within the radical literature circulating in the home of any person who has a computer, online Syria has become the most powerful magnet drawing people to fight jihad. And not just to fight in Syria, or now more recently in Iraq as well, but again, as al-Qaeda in the Arabian Peninsula said even earlier through its Inspire magazine, today groups like this Islamic state which has a magazine called Dabiq, glossy, English, very much like Inspire magazine, echoes Inspire's message saying: Come here if you want, but you don't have to. And if you don't come here, take it to the infidels at home and hit them at home.

BY MR. CHAKRAVARTY:

MR. CHAKRAVARTY: Pakistan and Afghanistan: How do they relate to the contemporary global jihad movement as of 2013?

MATTHEW LEVITT: After the war in Afghanistan -- well, first, the war in Afghanistan after 9/11, and after years of fighting in Afghanistan what was left of the al-Qaeda core and some al-Qaeda affiliates was in that border area of Afghanistan/Pakistan, and in some cases individuals or cells elsewhere in large cities in Pakistan. And this was something of the everyday news, of coalition forces continuing to fight the remnants of al-Qaeda and the Taliban in Afghanistan and in Pakistan, increasingly through the use of drones which has become a very controversial tactic, which in and of itself according to many scholars has attributed to radicalization. Some drone strikes, I think it's hard to argue, have not been effective; have been able to reach places you'd never be able to reach on foot and removed some very dangerous people, and some the exact opposite end of the spectrum, were complete misses and killed innocents, which as you can imagine, radicalizes people.

MR. CHAKRAVARTY: Let's turn now to Inspire magazine in greater detail, Dr. Levitt, if you will. Can you tell us the significance of the first issue of Inspire magazine?

MR. CHAKRAVARTY: And I'll call up what's in evidence as 1142-091.

MATTHEW LEVITT: So the release of the first issue of Inspire magazine, as I said, was a watershed event. You'd be able to access this through your computer. It's not for sale; it's for free. It's popping up in mirror sites. It is in accessible American colloquial English. It's glossy. It's got a table of contents. It bulletizes in the front some of the key things to look forward to in the edition, what page you can flip right to. And it's extraordinarily accessible, and really for the first time in this type of American English, doesn't stop at you really should do stuff. It's incumbent upon you to do stuff. It takes it to the next step: Here are ideas for what you might want to do, and here's how you might go about doing them, removing barriers and disincentives to entry. So it's inspiration on the go, it's know-how on the go. And what they're hoping for and unfortunately ultimately succeeding, enabling terrorism on the go.

MR. CHAKRAVARTY: If we could go to page 2, please.

MR. CHAKRAVARTY: Is this a letter to the editor?

MR. CHAKRAVARTY: And does this spell out what the purpose is of Inspire magazine?

MATTHEW LEVITT: Yes, it explains the derivation of the name, why they use the name "Inspire" and what they're trying to do.

MR. CHAKRAVARTY: Go to page 17, please.

MR. CHAKRAVARTY: I'd ask you to read this and explain its significance. It actually goes on to the next column.

MATTHEW LEVITT: So this is a series of questions. We're starting here with Question 9. If memory serves, this is from an interview with one of the leaders of al-Qaeda in the Arabian Peninsula, and the editors of the magazine are asking this individual the ninth question, Question 9: "In the end, what is your advice to the Muslims in the West?" And the answer is: "My advice to my Muslim brothers in the West is to acquire weapons and learn methods of war. They are living in a place where they can cause great harm to the enemy and where they can support the messenger of Allah."

MR. CHAKRAVARTY: And does it continue up here?

MATTHEW LEVITT: It does. "There is no meaning in life if the messenger of Allah is cursed while they listen to and see such crimes being committed in front of their eyes. It is not enough to defend him, may my father and mother be sacrificed for him, to participate in demonstrations and protests because these methods would not stop the West, which is already used to them. The successful means are through explosive devices and sacrificing souls."

MR. CHAKRAVARTY: And what is the speaker communicating here?

MATTHEW LEVITT: It's not enough to protest, it's not enough to write letters to the editor. The West is used to this type of thing. The way to truly defend the name of God and the name of the Prophet Muhammad is through violence.

MR. CHAKRAVARTY: Page 31 and 32, if you could call these up side by side.

MR. CHAKRAVARTY: What is "Open Source Jihad"?

MATTHEW LEVITT: So "Open Source Jihad" is a section of the magazine that appears in multiple editions. This is obviously the first time; this is the first edition. It's a play on the idea of open source intelligence, which is something that has been widely reported in the media, about trying to leverage not just classified information but information that is what -- when I was in the intelligence community -- we would call the open source, online or elsewhere. A play on that is "Open Source Jihad." So the idea is instead of having to go to some classified place, some closed members-only chat room, instead of having to go to some training camp where someone has to vouch for you and you need to get there and pay for your travel and whatnot, here is "Open Source Jihad" available to you, easily accessible on the Internet. And in this first inaugural edition, it says in this section: "Make a bomb in the Kitchen of Your Mom"; and the second point, "How to use Asrar al-Mujahideen," which was an al-Qaeda secure communication -- online communication network.

MR. CHAKRAVARTY: If you would go to a single screen, next page, 33.

MR. CHAKRAVARTY: Are you familiar with this page?

MR. CHAKRAVARTY: And is this the first page of that article on "Make a Bomb in the Kitchen of Your Mom"?

MATTHEW LEVITT: It is. By what they describe as the al-Qaeda chef.

MR. CHAKRAVARTY: So let me first start with the first paragraph. Would you just read the white portion of that?

MATTHEW LEVITT: "Can I make an effective bomb that causes damage to the enemy from ingredients available in any kitchen in the world? The answer is yes. But before how, we ask why? It is because Allah says." And then there's a quote.

MR. CHAKRAVARTY: And is that a quote from a religious scripture?

MR. CHAKRAVARTY: Can you read the next section?

MATTHEW LEVITT: "And it is also because every Muslim is required to defend his religion and nation. The Jews and Christians have dishonored the Muslims, desecrated our holy places and cursed the beloved prophet. Today they are holding contests for the best blasphemy of Muhammad. "The western governments today are waging a relentless war against Islam. They brought together a coalition and have the support of their population in invading and destroying Muslim land. "But there is a small band of sincere Muslims who are striking back at the enemy. The efforts of this small group of mujahidin have had a great effect in hindering the plans of the enemy. So now we have a balance of forces. As they kill Muslims, Muslims respond by killing among them. This is the effect of a small group of sincere mujahidin, so what would the effect be if the Muslim ummah wakes up?"

MR. CHAKRAVARTY: Pause there for a moment. What is mujahidin?

MATTHEW LEVITT: Jihad fighters.

MR. CHAKRAVARTY: And the "ummah" is the same word you mentioned earlier for Muslim nation?

MATTHEW LEVITT: So if a small number of fighters have had this much success, imagine how much more success there would be if a much larger grouping -- if the whole nation were to rise and engage in this activity.

MR. CHAKRAVARTY: Please continue.

MATTHEW LEVITT: "There are many Muslims who have the zeal to defend the ummah, but their vision is unclear. They believe that in order to defend the ummah, they need to travel and join the mujahidin elsewhere and they must train in their camps. But we tell the Muslims in America and Europe there is a better choice, an easier one to give support to your ummah. That is individual work inside the West such as the operations of Nidal Hassan and Faisal Shahzad with a few 'failed' operations - as they claim. "The Director of National Intelligence was forced to resign. With a few more 'failed operations' we may have the resignation of the President of the United States."

MR. CHAKRAVARTY: Dr. Levitt, it sounds like there's a political dimension to this exhortation. Is there?

MATTHEW LEVITT: Yes. In part, that's what makes it terrorism and not just murder. Terrorism has to be by -- there are many definitions of terrorism, but the basic commonality is targeting civilians to achieve some type of political goal.

MR. CHAKRAVARTY: At the bottom of this -- start here after this passage. First it recites to another part of scripture, and then can you read from where it says "the results"?

MATTHEW LEVITT: "The results of these trials would be the highest levels of paradise, the pleasure of Allah, heaven in the hearts in this world and eternal pleasure in the afterlife. My Muslim brother, we are conveying to you our military training right into your kitchen to relieve you of the difficulty of traveling to us. If you are sincere in your intentions to serve the religion of Allah, then all what you have to do is enter your kitchen and make an explosive device that would damage the enemy if you put your trust in Allah and then use this explosive device properly. Here are the main qualities of this bomb." The following are four bullet points. The first bullet: "Its ingredients are readily available"; second bullet: "Buying these ingredients does not raise suspicion"; third bullet: "It is easily disposed of if the enemy searches your home. Sniffing dogs are not trained to recognize them as bomb-making ingredients"; fourth bullet: "In one or two days the bomb could be ready to kill at least ten people. In a month, you may make a bigger and more lethal bomb that could kill tens of people."

MR. CHAKRAVARTY: Does the magazine then go on to explain how to build these bombs?

MR. CHAKRAVARTY: Can we go to page 45 and 46 side by side, please?

MR. CHAKRAVARTY: What is this?

MR. CHAKRAVARTY: What is this?

MATTHEW LEVITT: This is another section of this first edition of Inspire called "What to Expect in Jihad - Part One."

MR. CHAKRAVARTY: And does this explain the process of traveling overseas to join a terrorist organization or a group that's fighting?

MATTHEW LEVITT: It describes the things that one needs to know in advance to overcome potential barriers to entry. In fact, one of the titles given in one of these is "cut out piece of paper" -- you can see even here the kind of fine-tuned graphics, there's language barrier. It's telling people you have to be prepared to overcome the language barrier. If you can, bring a companion. There will be downtime; it would be much better to have someone with you. There's a cultural issue of blending into the culture if you go fight in some foreign land. Don't expect it to be America or the United Kingdom or wherever you're from. What to bring, what not to bring, all sorts of advice what to do and what not to do to make it easier for you to make the decision to go and to then make it easier for you to actually do it once you decide to go.

MR. CHAKRAVARTY: Can we have page 56, please? Can we have 58 on the other screen? Thank you.

MR. CHAKRAVARTY: What is this portion?

MATTHEW LEVITT: This is a message from Anwar Al-Awlaki, Sheikh Anwar, to the American people and Muslims in the West.

MR. CHAKRAVARTY: And is it an extensive speech explaining what he thinks is the appropriate actions by Muslims in America?

MATTHEW LEVITT: In America in particular, but also more generally in the West. In some points in here he speaks specifically to the Muslims in the United States, and other times more generally to Muslims wherever they may be in the West.

MR. CHAKRAVARTY: Page 58, I'm highlighting just the last portion. Can you read that?

MATTHEW LEVITT: "Hence, my advice to you is this: You have two choices: Either hijra," which is immigration, "or jihad. You either leave or you fight. You leave and live among Muslims or you stay behind and fight with your hand, your wealth and your word. I specifically invite the youth to either fight in the West or join their brothers in the fronts of jihad: Afghanistan, Iraq and Somalia. I invite them to join the new front, Yemen, the base from which the great jihad of the Arabian Peninsula will begin, the base from which the greatest army of Islam will march forth."

MR. CHAKRAVARTY: Is this concept of choosing either hijra or jihad one that you've seen before?

MATTHEW LEVITT: Many times.

MR. CHAKRAVARTY: Can you explain what hijra is?

MATTHEW LEVITT: It's migration, and it's following in the footsteps of the Prophet Muhammad who in his day also made a migration. This idea is to make a migration to places where there's a Muslim majority; where you can live with fellow Muslims as opposed to living in a place where you are a minority as a Muslim. At least if you live among Muslims, it will be easier for you to live as a Muslim, is the idea, plus on top of that, the overlay from the radical jihadi perspective of being able to fight in jihadi conflicts. And if you don't do that and if you do decide to stay wherever you are in the diaspora, then as he says, you either join us or you fight.

MR. CHAKRAVARTY: Were there other copies of Inspire magazine that we sent to you that were similar in terms of the types of exhortations that the editors of the magazine were making?

MATTHEW LEVITT: Quite a few.

MR. CHAKRAVARTY: I'm going to draw your attention now to Exhibit 1142-89. Is this one of those issues? Excuse me. Yeah, 1142-89.

MR. CHAKRAVARTY: And this is the spring of 2011 issue. Is that right?

MATTHEW LEVITT: Yes, the fifth issue.

MR. CHAKRAVARTY: And was this a significant issue?

MATTHEW LEVITT: They're all significant. Yes, it was.

MR. CHAKRAVARTY: Can we go to page 8, please?

MR. CHAKRAVARTY: Is there a portion that discusses the various reactions to Inspire magazine?

MR. CHAKRAVARTY: And this one, can you read that?

MATTHEW LEVITT: "They're not looking to outdo the readership of the Economist or Time Magazine, they only need to inspire one or two people to blow something up in the right place and they'll make back their start-up costs."

MR. CHAKRAVARTY: Now, the highlighted passages were "inspire one or two people" and "in the right place." Is that correct?

MR. CHAKRAVARTY: Can we go to page 62 and 63 side by side, please?

MR. CHAKRAVARTY: And is this an interview of Anwar Awlaki as to "Why did I choose al-Qaeda"?

MR. CHAKRAVARTY: And does he say in Section 4 -- would you read that passage except for the scripture?

MATTHEW LEVITT: "Because they are the strangers (al Ghuraba)" and then he quotes scripture. After the scripture he continues, "Thereupon, regarding this prophetic description for the people of the truth about their status of estrangement, there is no doubt that the one who lives in a state of fear about his soul being taken for death as a result of this 'aqidah and jihad is the one who lives in the status of being strange. He lives in the state of estrangement because he is accused of having deficiency in his 'aqidah," in his creed, in other words. "This is not the case; rather, it is because he is steadfast upon the truth in a time where the supporters have become less in number. Indeed he is a stranger."

MR. CHAKRAVARTY: And what does that mean?

MATTHEW LEVITT: Being a stranger is not just living in the diaspora, being a stranger is living in a state of fear about whether or not you're going to live or die, because there is something greater in the afterlife.

MR. CHAKRAVARTY: Are you familiar with a person named Abu Muhammad al-Maqdisi?

MR. CHAKRAVARTY: And who is he?

MATTHEW LEVITT: Al-Maqdisi is one of the most prominent Jordanian radical Islamist preachers, been in and out of jail many, many times. His materials are frequently included among the jihadi materials on these various websites, and is a very well-known and prominent jihadi ideologue.

MR. CHAKRAVARTY: And did you read documents authored by him as part of the materials that we sent?

MR. CHAKRAVARTY: Can we call up 1142-16, page 2?

MR. CHAKRAVARTY: Is this one of those documents?

MR. CHAKRAVARTY: And is this published by a Tibyan Publications, the publication you mentioned earlier?

MR. CHAKRAVARTY: Can you read the title?

MATTHEW LEVITT: "Precaution, Secrecy and Concealment: Balancing Between Negligence and Paranoia."

MR. CHAKRAVARTY: And what is the topic of this document?

MATTHEW LEVITT: Well, as the title suggests, it's about the need for operational security and how this is not only permissible but required for the Islamist fighter, the jihadi, and how on the one hand you can go overboard; on the flip side, you can be negligent, and either of those is dangerous. So he describes in talking about something innocent with one of your compatriots, you insist on talking in code thereto, you could make the authorities think you're up to something dangerous and bring law enforcement scrutiny to yourself that was unnecessary. So you shouldn't be engaging in, you know, covert code all the time. And yet, if you think that no one's ever listening to you and you don't take security precautions, you also open yourself up to potential law enforcement scrutiny. And many of our operatives, he explains, have been thwarted that way as well. He, as an ideologue -- this is not just kind of as an operator's incentive, he explains the ideological, theological basis for this. This becomes now a matter of religion as well.

MR. CHAKRAVARTY: Now, has this message of operational security been simplified for easier consumption?

MATTHEW LEVITT: Absolutely.

MR. CHAKRAVARTY: If we could go to 1142-89, page 11.

MR. CHAKRAVARTY: Would you read that? Should I open that up a little bit more? Can you read that?

MATTHEW LEVITT: "We have noticed that the year 2010 alone saw the most arrests in the West for home-grown jihadi operations. Most of those arrested were arrested in groups, one connected to another. Sometimes the enemy would even set up the brother in a sting operation, fooling him into believing that he was working with the mujahidin. Keeping that in mind, we have witnessed that operations done by lone individuals has proven to be much more successful. "So what can we learn from this?" I think the last two cutoff words are "group operations have a greater tendency of failing than lone operations due to the idea (of the operation) escaping the mind and tongue to other individuals. Even if those individuals are trustworthy in your eyes, there is still that 1 percent chance that someone from the intelligence agencies are listening in and paying attention to your groups' actions or that the person you are talking to might be working for the enemy or that he might be pressured..."

MR. CHAKRAVARTY: Next page, please.

MR. CHAKRAVARTY: Just to finish that thought.

MATTHEW LEVITT: "...at a later period to give information to them. With lone operations, however, as long as you keep it to yourself, nobody in the world would know what you're thinking and planning."

MR. CHAKRAVARTY: Call up Exhibit 1142-15.

MR. CHAKRAVARTY: Are you familiar with this document?

MR. CHAKRAVARTY: And is this another Tibyan Publications document?

MR. CHAKRAVARTY: And what was the substance of this document?

MATTHEW LEVITT: This, again, is another document putting the idea of jihad in a religious context.

MR. CHAKRAVARTY: "The effects of intention upon it." Did it say anything about the type of intentions that bring the greatest rewards?

MATTHEW LEVITT: Well, this is the whole point, right, that to get rewards, whether it's that selfless, what you're doing on behalf of the ummah, or the benefits for one's self of entry into the highest levels of paradise, these only come if they're done for true intentions, right? So if you do it for monetary gain, you don't get that reward. If you do it for personal glory, you don't get that reward. You have to do what you do for the right reasons, which makes it in the eyes of these extremists not an act of terrorism, not an act of killing civilians that is forbidden, but an act -- a religious act of violence that is not only permissible but praiseworthy, and not just praiseworthy, but a personal obligation, but only if you do it for the right reasons and the right intention.

MR. CHAKRAVARTY: And what are the right reasons?

MATTHEW LEVITT: Service of God, defense of the ummah.

MR. CHAKRAVARTY: Would you go to 1142-36.

MR. CHAKRAVARTY: Are you familiar with this document?

MATTHEW LEVITT: This is the Abdullah Azzam document, "Join the Caravan," that we mentioned earlier.

MR. CHAKRAVARTY: Since we talked about it earlier, I won't go through it in detail at this moment. In addition to some of these documents, did you review some of these audio files that you had discussed?

MR. CHAKRAVARTY: Were there a few short ones that you were able to both listen to as well as see a transcript of?

MR. CHAKRAVARTY: Just for the witness, your Honor, Exhibit 1405A. Just the transcript.

MR. CHAKRAVARTY: And is this three pages of transcript excerpts of three of the audio files that we're going to listen to?

MATTHEW LEVITT: I have here in front of me one paragraph of one of them, yes; and a second, yes; and a third.

MR. CHAKRAVARTY: And do these transcripts fairly track the words of the audio files that you listened to?

MR. CHAKRAVARTY: Your Honor, I would ask to publish 1405A as a chalk while we play three short audio clips.

MR. BRUCK: I'd like to note our previously made objection.

THE COURT: All right. Subject to that, they'll be played.

BY MR. CHAKRAVARTY:

MR. CHAKRAVARTY: So if we could first play 1142-24 -- 124. Excuse me.

(Audio recording played.)

MR. CHAKRAVARTY: Dr. Levitt, do you recognize the voice of the speaker in that?

MATTHEW LEVITT: That was Sheikh Awlaki, Anwar al-Awlaki.

MR. CHAKRAVARTY: And what's the significance of that passage that he recited?

MATTHEW LEVITT: So this Battle of Uhud is one that he talks about a lot, he has a lecture series on it, among other battles, the Battle of Badr, for example. In this one, it's a theme we talked about earlier, he's saying: Look, if you do this act of jihad with true intention -- the individual is asked, "Did you come to fight here for the sake of your people or for the sake of God?" And he answers, "For the sake of God." And then later on his deathbed he says the Shahadah, the statement of faith, and dies and is given entry into the highest levels of paradise even though he had not been a good Muslim until then. He had not prayed, he had not fasted, et cetera. And so there is this idea that engaging in an act of jihadi violence for the right reasons and intentions is a religious act, and not just a religious act. One that can be more spiritually fulfilling than any other type of religious observance.

MR. CHAKRAVARTY: Go to 1142-110 and page 2.

(Audio recording played.)

MR. CHAKRAVARTY: Dr. Levitt, first, there's some references, again, is this Mr. Awlaki?

MATTHEW LEVITT: This is Awlaki again, yes.

MR. CHAKRAVARTY: And what's the significance of this?

MATTHEW LEVITT: Well, I think there are three things that are significant here: The first is you can see how he's trying to convince people that to be a good Muslim, you have to break with Western ideas. I mean, the idea of a birthday. This is a bad thing, whereas, of course, many, many, many Muslims celebrate birthdays and there's absolutely nothing wrong with that. This idea of breaking, having to be different and apart. But more importantly it's two things: One, there's a clock ticking. Don't waste a moment. Act now. It's: Don't push off to tomorrow what you can do today, right? Death could come tomorrow. You don't know what's going to be. We should be not wasting a moment of our life, to try and do what has to get done, whatever that may be, including this violent activity that he talks about elsewhere. Second is this idea of predestined time of death. And that is to say, you know, this is not something to fear. This is not something to be afraid of, as we read in an earlier quote; this is something that's going to happen. The date, the time, the how, this is all predetermined. It's not like if you are more careful or less careful -- it is going to happen, so you therefore have to take this time while you're here to do the right thing. And you don't have to be afraid of death because it's going to happen, it's preordained when, how, what. And this again removes the disincentive. For many people the idea of carrying out an operation in which they're not going to survive is something that's difficult for them to wrap their head around. This is one way that the radical individuals -- again, let's not associate this with traditional Islam -- try and overcome that dissidence.

MR. CHAKRAVARTY: There are a couple of words that I don't think we talked about yet here. Is "dunya" basically this mortal life that we're talking about?

MATTHEW LEVITT: Yes, this world.

MR. CHAKRAVARTY: And kuffar, or "kufar"?

MATTHEW LEVITT: The infidel, or non-believer.

MR. CHAKRAVARTY: Now, in the background there's some chanting or singing. Is that the nasheed that you described earlier?

MATTHEW LEVITT: It is. So here you have a kind of overlay of an al-Awlaki sermon on top of the chanting of a nasheed.

MR. CHAKRAVARTY: And in the earlier clip, which was entitled "The Man who went to Jannah Without Praying," what is Jannah?

MR. CHAKRAVARTY: I'll play one more short clip. I'm not going to go through the whole thing but a portion of it, which is 1142-32 and page 3.

(Audio recording played.)

MR. CHAKRAVARTY: Dr. Levitt, this was a considerably different tenor. Was this Anwar Awlaki?

MATTHEW LEVITT: No, this is not Awlaki. This -- you can completely hear the difference between the measured kind of professorial tone of Awlaki and this shrill, very, very excited speaker here. And this is obviously much more graphic in terms of trying to portray Islam in this violent context.

MR. CHAKRAVARTY: And audio files like these which are short clips of the various different types, how are they used by the global jihadi movement with regards to their messaging?

MATTHEW LEVITT: Short or longer, they're very, very popular because they're relatively small files. They're meant to be downloaded to players, and they are inspiration on the go. So you don't need to be tethered to your home computer, you don't even need to be carrying your laptop around. You can, you know, download them to your MP3 player or to your car and you can listen to them any time, as many times as you want.

MR. CHAKRAVARTY: Dr. Levitt, I want to now turn to the final series of questions that I'm going to have for you, and they relate to Exhibits 826 through 828.

MR. CHAKRAVARTY: If you'd call that up on the left side?

MR. CHAKRAVARTY: Dr. Levitt, did you recognize those photos as being photos of a writing that's of significance in this case?

MR. CHAKRAVARTY: And this transcript, is this a transcript of the writing?

MR. CHAKRAVARTY: And have you had a chance to study that writing?

MR. CHAKRAVARTY: Were you able to glean from just the four corners of the writing itself who the audience is for this writing?

MATTHEW LEVITT: I think it's clear from the grammar that the audience is kind of the American public. This is clearly not written for fellow travelers, fellow jihadis; this is an attempt to explain what's been done, and I think the grammar is quite clear there.

MR. CHAKRAVARTY: As we read through, if you can point those out -- point out those clues that give you that conclusion. We'll do that. But before we start reading, have you seen the concepts in this document before?

MATTHEW LEVITT: We've seen them in Awlaki's statements and writings and other writings from the radicalizers that was among the material that was provided to me to review in this case.

MR. CHAKRAVARTY: The themes that weave throughout this writing, are they common themes in the global jihad movement?

MR. CHAKRAVARTY: Let's first start with the first sentence. Would you read that, please?

MATTHEW LEVITT: "I'm jealous of my brother who ha..." and there's a bullet hole. Presumably it's "...has received the reward of Jannutul Firdaus, Insha'Allah..." which means the highest level of paradise, God willing "...before me."

MR. CHAKRAVARTY: To stop you there. Just some of the grammar. "Insha'Allah" means "God willing"?

MR. CHAKRAVARTY: And "Jannutul Firdaus," that's the highest level of paradise?

MR. CHAKRAVARTY: And is this a concept we've seen in some of the other documents that you've reviewed?

MR. CHAKRAVARTY: Can we call up on the second page 1142-36, which is "Join the Caravan"? Can we go to page 17, please?

MR. CHAKRAVARTY: And can you read Section 8?

MATTHEW LEVITT: Section 8 the title is "Hoping for Martyrdom and the High Station in Paradise." "It has been reported in the authentic hadith narrated by Imam Ahmad and Tirmidhi on the authority of Miqdam Ibn Ma that: 'The martyr has seven special favours from Allah: He is forgiven with the first spurt of his blood, he sees his place in Paradise, he is clothed with the garment of Faith, he is wed with seventy-two wives from the beautiful Houris of Paradise, he is saved from the punishment of the grave, and he is protected from the Great Terror onQiyamah, on his head is placed a crown of dignity, the jewel of which is better than the world and all in it.'"

MR. CHAKRAVARTY: Please continue.

MATTHEW LEVITT: Starting with the first full sentence: "He is granted intercession for 70 people of his household."

MR. CHAKRAVARTY: And then there is another reporting by a scholar and then another piece of scripture?

MR. CHAKRAVARTY: And is this a common theme in some of the global jihadi movement?

MR. CHAKRAVARTY: And were there numerous other references to Jannutul Firdaus throughout the materials that you reviewed in this case?

MR. CHAKRAVARTY: Read the next sentence of the writing in the boat.

MATTHEW LEVITT: "I do not mourn because his soul is very much alive. God has a plan for each person. Mine was to hide in his boat and shed some light on our actions. I ask Allah to make me a shahied (IA)..." presumably Insha'Allah, God willing "...to allow me to return to him and be among all the righteous people in the highest levels of heaven."

MR. CHAKRAVARTY: And, Dr. Levitt, you had pointed out that there's a line where it says "God has a plan for each person. Mine was to hide in the boat and shed some light on our actions." Have the actions that are relevant in this case been suggested throughout the media that you reviewed?

MATTHEW LEVITT: They have, and this is also one of those references that I think makes clear that this note is intended to explain to a broad public what was just going on, about what these actions were about, "shed some light on our actions."

MR. CHAKRAVARTY: This word "shahid," I don't know that you've explained what that means. Would you mind?

MATTHEW LEVITT: Martyr. In this case, a martyr for God. To be killed in the process of doing an act of jihad. It's not the only definition of martyr, but in the radical jihadi context, that's what it's referring to.

MR. CHAKRAVARTY: And I asked you whether you saw these references in the media that I sent you. What did I send you?

MATTHEW LEVITT: I'm sorry. Ask that again?

MR. CHAKRAVARTY: Media. I didn't mean media as in news media. What did I send to you that you reviewed, these materials?

MATTHEW LEVITT: In totality?

MR. CHAKRAVARTY: The types of materials that I sent you.

MATTHEW LEVITT: The nasheeds, the -- some videos, the Inspire magazines. The publications that we went through and a whole host of others.

MR. CHAKRAVARTY: I wanted to clarify it wasn't newspapers I sent to you.

MATTHEW LEVITT: No, this was jihadi media.

MR. CHAKRAVARTY: Can you read the bottom of -- if you can make out on page 56 of this issue of Inspire magazine, can you read what I've highlighted there?

MATTHEW LEVITT: "Another option for the individual jihad is the idea we proposed in 'Make a Bomb in the Kitchen of Your Mom.' The pressurized cooker should be placed in crowded areas and left to blow up. More than one of these could be planted to explode at the same time. However, keep in mind that the range of the shrapnel in this operation is short range, so the pressurized cooker or pipe should be packed close to the intended targets and should not be concealed from them by barriers such as walls."

MR. CHAKRAVARTY: Were there other references to operational planning for the types of actions in this case?

MR. CHAKRAVARTY: The next portion of this note, the writing, says -- asks Allah to make the author a shahid and to return him to the righteous people in the highest levels of heaven. What do the "highest levels of heaven" mean?

MATTHEW LEVITT: This is the Jannutul Firdaus that we talked about. By tradition, there are many levels of heaven and the differences between them are significant. And this is the highest level of heaven reserved for the prophets, the most pious and the martyrs.

MR. CHAKRAVARTY: Would you read the next line, please?

MATTHEW LEVITT: "He who Allah guides, no one can misguide."

MR. CHAKRAVARTY: What does that mean?

MATTHEW LEVITT: That if you were doing something in the name of and in defense of and for Allah, for God, you cannot be misguided.

MR. CHAKRAVARTY: And the last phrase?

MATTHEW LEVITT: The letter A, then a bullet hole, bar exclamation point which in all likelihood read "Allahu Akbar," praise to God, praised is God -- God is great.

MR. CHAKRAVARTY: And is that a common phrase in the materials that you reviewed over the course of your experience as a terrorism expert?

MR. CHAKRAVARTY: And what does that mean?

MATTHEW LEVITT: God is great. Again, it need not be jihadi; it can be said in other contexts too. But in this context, this has a jihadi connotation.

MR. CHAKRAVARTY: The next page, please.

MR. CHAKRAVARTY: Please continue.

MATTHEW LEVITT: "I bear witness that there is no God but Allah and that Muhammad is his messenger." There's a hole and then an R which likely read "our actions came with a..." there's a bullet hole and then the letter A, bullet hole, "ssage," "...came with a message, and that is..." hole -- bullet hole, "...ha," Illallah.

MR. CHAKRAVARTY: The last phrase, is that an Arabic phrase?

MR. CHAKRAVARTY: And is that frequently known as the "Shahadah"?

MR. CHAKRAVARTY: What is that?

MATTHEW LEVITT: It is a statement of faith. And again, nothing radical about this, per se. This is the statement of faith of all believing Muslims. But it is also traditional to state it at a time of death on the deathbed. Again, harking back to the Maqdisi document about intention, it's important before and after an act in particular to state and restate one's true intentions to be able to get that reward.

MR. CHAKRAVARTY: The first portion of this sentence, "I bear witness that there's no God but Allah and that Muhammad is his messenger," is that essentially the English translation of the first portion of the Shahadah?

MR. CHAKRAVARTY: Let me show you Exhibit 1341. And this flag back here. Do you recognize that?

MATTHEW LEVITT: I recognize it. As I stated earlier, I don't speak Arabic, but I've seen this many times, and this is the Arabic of the Shahadah; again, nothing inherently radical though many jihadi groups have taken to putting the Shahadah in white against the black backdrop as a symbol for them.

MR. BRUCK: I think that image is not currently in evidence.

THE COURT: I thought it was. This was the one that was talked about being redacted, at the bottom.

MS. CONRAD: It was redacted, your Honor.

MR. MELLIN: No, your Honor. The writing below it was redacted; that image was entered.

THE COURT: Right. The picture was in.

MS. CONRAD: The whole thing was displayed, your Honor, for the jury.

THE COURT: Yeah, but I don't think anyone could read it. The document should be redacted, though. It didn't affect anything that was shown to the witness.

BY MR. CHAKRAVARTY:

MR. CHAKRAVARTY: We'll move on to the next sentence, Dr. Levitt.

MATTHEW LEVITT: "The U.S. government is killing our innocent civilians but most of you already know that."

MR. CHAKRAVARTY: And here it says "most of you already know that." What significance do you attribute to that?

MATTHEW LEVITT: Again, the grammar, this is speaking to an American audience, this is speaking to a Western audience. The author is not associating himself with this audience, but it's "our," "your," us versus them, but I think this makes clear that this is, again, as stated earlier in the message, in the statement, trying to explain what just happened.

MR. CHAKRAVARTY: Now, did you find references amongst the materials in the Inspire magazine particularly that make reference to the same concept?

MR. CHAKRAVARTY: Go to 1142-89, page 57.

MR. BRUCK: I don't think that's the way it's supposed to be displayed.

THE COURT: If you can take down the unredacted...

BY MR. CHAKRAVARTY:

MR. CHAKRAVARTY: Can you read that, please?

MATTHEW LEVITT: "America is a terrorist state and Americans are complacent in some of the worst forms of terrorism our Muslim nation has been subjected to. Millions of Muslim lives has been lost to American brutality. It is about time Muslims wake up and pay back America what is due to it." "In this section, the OSJ" -- so that's Open Source Jihad -- "we give our readers suggestions often how to wage their individual jihad. Here is one idea of how an individual Muslim may do so. It is a simple idea and there is not much involved in its preparation. All what is needed is the willingness to give one's life for Allah."

MR. CHAKRAVARTY: There are several other passages like this throughout the Inspire magazines particularly that demonstrate enmity towards America?

MR. CHAKRAVARTY: Go back to the note, please.

And, Mr. Bruemmer, you can take that down.

MR. CHAKRAVARTY: Can you please keep reading?

MATTHEW LEVITT: "As a M..." and then a bullet hole, presumably Muslim. "As a Muslim I can't stand to see such evil go unpunished. We Muslims are one body. You hurt one, you hurt us all. Well, at least that's how Muhammad, peace be upon him, wanted it to be..." bullet hole "...ever," presumably "however, the ummah is beginning to rise..." presumably "awaken." There's a bullet hole.

MR. CHAKRAVARTY: And before we move on to the next page to finish that clause, this notion of "we Muslims are one body," is that that concept of ummah?

MATTHEW LEVITT: That and more, yes.

MR. CHAKRAVARTY: When you say "more," what do you mean?

MATTHEW LEVITT: It's not just the idea of a single ummah, a single Muslim nation, it's the idea that it is if you hurt one Muslim in any part of the world, it's incumbent upon a Muslim -- it's a personal obligation upon a practicing Muslim elsewhere in the world to do something about it. It's not like if Muslims in Chechnya or Palestine or Iraq are being hurt but you're being treated well here in the United States, you're okay here. You still need to do something because we are all one body. You hurt one of us, you hurt all of us.

MR. CHAKRAVARTY: And just before it says "I can't stand to see such evil go unpunished," is punishing a theme throughout these materials?

MR. CHAKRAVARTY: Can we go to 1142-79? Page 33, please.

MR. CHAKRAVARTY: And is this a statement by Anwar al-Awlaki?

MR. CHAKRAVARTY: Page 34, please.

MR. CHAKRAVARTY: Can you read that?

MATTHEW LEVITT: "The declaration goes on to claim that we may not terrorize those who enjoy safety and security. To throw out such a blanket statement that we are not allowed to terrorize those who enjoy safety and security in light of the present state of the world is another reckless statement. According to these scholars, we the Muslims are not allowed to terrorize the Israelis or the Americans or the British who are living in safety and security while millions of Muslims are being terrorized by them. We are told to never mind the insecurity of the Palestinian or the Chechen or the Kashmiri. Never mind them. We are simply not allowed to terrorize..."

MR. CHAKRAVARTY: Next page, please.

MATTHEW LEVITT: "...period. No. We do not agree with that. We do not agree with that because Allah says" -- and then there's a quote from the scripture. Would you like me to read it or not?

MR. CHAKRAVARTY: No, thank you.

MATTHEW LEVITT: After the quote from the scripture it says, "We say that whoever terrorizes us, we will terrorize them and we will do what we can to strip them of their safety and security as long as they do us the same."

MR. CHAKRAVARTY: Were there other passages like this throughout the Inspire magazine particularly?

MR. CHAKRAVARTY: The idea of Muslims are one body, you hurt one, you hurt us all, was that evident in "Join the Caravan" as well?

MR. CHAKRAVARTY: Go to 1142-36 at page 23.

MR. CHAKRAVARTY: Can you read that?

MATTHEW LEVITT: Yeah, with difficulty. I'm not as young as I once was.

(Laughter.)

MR. CHAKRAVARTY: How about if I read it and you tell me?

MATTHEW LEVITT: I'm not willing to give in quite yet. "The jurists have documented that the lands of the Muslims are like a single land, so that whichever region of the Muslims' territory is exposed to danger, it is necessary that the whole body of the Islamic ummah rally together to protect this organ which is exposed to the onslaught of the microbe. What is the matter with the scholars, that they do not arouse the youths for jihad, especially since arousal is compulsory."

MR. CHAKRAVARTY: And is this that notion that if you hurt one, you hurt us all?

MATTHEW LEVITT: That and the compulsory nature of this standing up and defending the ummah.

MR. CHAKRAVARTY: We'd finished this page, with "The ummah is beginning to rise/awake."

MR. CHAKRAVARTY: Can we go to the next page?

MR. CHAKRAVARTY: Please keep reading from the new portion.

MATTHEW LEVITT: "How Muhammad, peace be upon him, wanted it to be..." bullet hole "...ever," presumably "however, the ummah is beginning to rise awa..." bullet hole, presumably "awake, has awoken the mujahidin. Know you are fighting men who look into the barrel of your gun and see heaven. Now how can you compete with that? We are promised victory and we will surely get it."

MR. CHAKRAVARTY: And just before we move on, this idea of awakening the mujahidin, is that a theme that you saw throughout the materials?

MR. CHAKRAVARTY: Go to 1142-89, page 35.

MR. CHAKRAVARTY: And read this portion. I'm sorry. Can you read this portion?

MATTHEW LEVITT: "We must also awaken in the hearts of the ummah the spirit of resistance and jihad; confrontation of aggression, oppression and tyranny; firmness on the truth; and rejection of the culture of concession and methodology of backtracking, which has led some to abandon the government of the Sharia and concede four-fifths of Palestine.

MR. CHAKRAVARTY: Now going back to the note, the writing in the boat -- sorry.

MR. CHAKRAVARTY: Mr. Bruemmer, can you go back to page 3?

MR. CHAKRAVARTY: The next phrase is, "Know you are fighting men who can look into the barrel of your gun and see heaven." Are you familiar with that concept?

MATTHEW LEVITT: Again, this is the idea of not fearing death, looking into the barrel of the gun and seeing heaven, seeing the opportunity. Again, presumably if having done for the right reasons, being able to go to heaven, maybe even the highest levels of heaven. It's articulating to this Western audience that how can you compete with that? How can you fight people who aren't afraid to die for their cause?

MR. CHAKRAVARTY: Read the next line, please?

MATTHEW LEVITT: "We are promised victory and we will surely get it."

MR. CHAKRAVARTY: Now, this concept of victory, an assured victory, is that a theme throughout these materials?

MR. CHAKRAVARTY: Go to 1142-91, page 57.

MR. CHAKRAVARTY: This is that first issue of Inspire magazine?

MR. CHAKRAVARTY: Can you read that?

MATTHEW LEVITT: "It is true that we are facing the arsenal of the greatest army on earth with our simple modest means, but victory is on our side. Victory is on our side because there is a difference between us and you. We are fighting for a noble cause. We are fighting for God and you are..."

MR. CHAKRAVARTY: Next page, please.

MATTHEW LEVITT: "...fighting for worldly gain. We are fighting for justice because we are defending ourselves and our families and you are fighting for imperialistic goals. We are fighting for truth and justice and you are fighting for oppression. You have your B-52's, your Apaches, your Abrams and your cruise missiles, and we have small arms and simple improvised explosive devices, but we have men who are dedicated and sincere, with hearts of lions."

MR. CHAKRAVARTY: Your Honor, I still have a little bit more to go and it's four o'clock.

THE COURT: Let me see you at the side first.

sidebarsidebarTime Needed for Remaining Expert Testimony

(Discussion at sidebar and out of the hearing of the jury:)

THE COURT: Is he staying?

MR. CHAKRAVARTY: Once we got to lunch we realized he's not going to make it.

THE COURT: Okay. How much more?

MR. CHAKRAVARTY: Ten, 15 minutes.

THE COURT: How much time do you have?

MR. BRUCK: 10, 15 minutes. No more than a half hour. I would hate to be overtime with an expert with a jury.

THE COURT: Fair enough.

ProceduralProc.Jury Admonition and Adjournment

(In open court:)

THE COURT: Okay. We will pause here. There is more to go but we have reached the four o'clock hour. We'll adjourn. Remember my instructions, obey them, and we will see you tomorrow and finish with the testimony.

Enjoy the evening.

COURT CLERK: All rise for the Court and the jury. The Court will be in recess.

(The Court and jury exit the courtroom and the proceedings adjourned at 4:00 p.m.)

Continue to Day 381.Matthew Levitt — Direct/Cross/Redirect (Part 3)