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2015 Federal TrialtranscripttranscriptRaisat Suleimanova — Direct/Cross (Part 1) - Day 57 - 2015 Federal TrialRaisat Suleimanova described Jahar’s childhood and family life. Cross-examination emphasized her lack of contact since he left at age eight, while the court limited proposed family-opinion testimony and barred questions comparing childhood behavior with bombing victims’ suffering.
William D. WeinrebDavid I. BruckWilliam W. FickGeorge A. O'Toole Jr.Raisat SuleimanovaTHE COURTJurorMR. FICKCourt ClerkRaisat SuleimanovaMR. WEINREBMR. BRUCKInterpreterproceduraldirectsidebarcross
11 pages·7 witnesses·1,759 lines
Relatives and friends offered childhood and social recollections of Dzhokhar Tsarnaev. The court limited personal-reaction and family-history questioning, denied a mistrial motion, and excluded a Facebook post while admitting photographs and a recording identified as Tamerlan’s voice.
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ProceduralProc.Morning Jury Compliance Check and Witness Order

P R O C E E D I N G S

THE COURT: Good morning, jurors.

JUROR: Good morning, your Honor.

THE COURT: Let me ask again. Have you all been able to follow my instructions and avoid any news reports about the case?

JUROR: Yes.

THE COURT: Yes.

And any discussion among yourselves, you've avoided that?

JUROR: Yes.

THE COURT: Anything anybody wants to talk to me about?

All right. We'll resume the evidence. Mr. Fick.

MR. FICK: Good morning, your Honor. The defense calls Raisat Suleimanova.

THE COURT: Let me just note for the record that, when we last broke, there was a witness on the stand. We will resume the examination of that witness eventually, but we're going to take some witnesses in a different order.

MR. FICK: Your Honor, I have some chalks and exhibits as to which I believe there's no objection. So if I can get the screen access, I would appreciate it. Thank you.

(Interpreter sworn.)

DirectDirectRaisat Suleimanova — Direct Raisat Suleimanova William W. Fick

RAISAT SULEIMANOVA, Sworn

COURT CLERK: Be seated. State your name. Spell your first and last name slowly.

RAISAT SULEIMANOVA: (Name spelled by the witness.)

THE COURT: It's on the list, Paul. You can use the list.

MR. FICK: If I could ask you both to move the microphone a little closer so we can all hear you better.

DIRECT EXAMINATION BY MR. FICK:

MR. FICK: Good morning, Miss Suleimanova.

RAISAT SULEIMANOVA: Good morning.

MR. FICK: What year were you born?

MR. FICK: Where were you born?

RAISAT SULEIMANOVA: In Russia, the Republic of Dagestan, the village of Chokh.

MR. FICK: I'm going to put up on the screen as a chalk a map which has been identified as 3503. Is Dagestan in the area that I've just highlighted on the map?

RAISAT SULEIMANOVA: Yes, that's correct.

MR. FICK: I'm going to also put up another map, which is a little bit closer in scale, of Dagestan, which has been marked as 3506. The area that I'm circling here in the mountains of Dagestan, is that where Chokh is located?

RAISAT SULEIMANOVA: Yes, correct.

MR. FICK: Besides Chokh, where else did you live in your childhood and youth?

RAISAT SULEIMANOVA: In the town of Kaspiysk.

MR. FICK: Is that this town here on the coast of the Caspian Sea that I've circled?

RAISAT SULEIMANOVA: Yes, correct.

MR. FICK: Is it next to Makhachkala, the capital of Dagestan?

RAISAT SULEIMANOVA: Yes, all is correct.

MR. FICK: Where do you live now, Miss Suleimanova?

RAISAT SULEIMANOVA: In the town of Podolsk, Moscow Region.

MR. FICK: So this is a city just outside Moscow, is that right?

RAISAT SULEIMANOVA: That's correct.

MR. FICK: Are you employed?

RAISAT SULEIMANOVA: Yes, I am. I'm a nurse in an ICU unit in a hospital.

MR. FICK: Do you have any children?

RAISAT SULEIMANOVA: Yes, I have one child. It's a girl. She's three years old.

MR. FICK: I'm going to put up now on the screen another chalk that's a -- has been identified as 3507-118, a family tree of the Suleimanov family. And on the witness stand in front of you on paper is the same document in Russian if it helps you for reference. Can you just briefly tell me, what is your family connection to Jahar?

RAISAT SULEIMANOVA: Yes, of course. Zubeidat is a younger sister of my mother.

MR. FICK: So Zubeidat is your aunt, is that right?

MR. FICK: And Jahar is then your cousin?

MR. FICK: So just to sort of make clear on the chart here, is this you here that I've circled?

RAISAT SULEIMANOVA: Yes, that's me.

MR. FICK: And your mother is one of Zubeidat's sisters, named Shakhruzat, that I've circled?

MR. FICK: Is there a shorter name that your mother is sometimes called by?

MR. FICK: It's -- you have a number of aunts and -- aunts who are named Patimat, is that right? I'm circling them here.

RAISAT SULEIMANOVA: Yes. I have Patimat who is an older sister of my mother. There is another Patimat who is the wife of my Uncle Mukhammad Haji. And there is also another Patimat related to another brother of my mother's younger brother. And the wife of the youngest brother's name is also Patimat.

MR. FICK: So is that a -- is Patimat a common name in Dagestan?

RAISAT SULEIMANOVA: The most common name, female name, is Patimat; and the male name is Magomed.

MR. FICK: Now, Miss Suleimanova, have you ever traveled outside the territory of the former Soviet Union before?

RAISAT SULEIMANOVA: No. This is the first time.

MR. FICK: Why have you traveled so far to be here today?

RAISAT SULEIMANOVA: I came for the sake of my brother, whom I love very much. He's part of my family. I had no right not to come here. I categorically reject what he did. It's a great tragedy, of course.

MR. WEINREB: Your Honor, this is getting beyond --

THE COURT: Yes. Let's be sure there's a question-and-answer format, please.

MR. FICK: You referred to Jahar as your brother instead of your cousin. Can you explain why that is? Is there something about the Russian word for cousin and brother that we should take into account here?

RAISAT SULEIMANOVA: I usually call my cousins brothers. I don't have brothers per se. They're very close to me so I call my cousins my brothers.

MR. FICK: In the Russian language, is the word for cousin essentially brother second removed?

RAISAT SULEIMANOVA: Yes. Brother is related to me in the same family, and the cousin is twice removed.

MR. FICK: I'm going to move into evidence and publish a photograph that I'm going to ask you about, 3507-109.

(Defendant's Exhibit No. 3507-109 received into evidence.)

THE COURT: I take it from what Mr. Fick said earlier, there is no objection to these photographs, is that correct?

MR. WEINREB: That's correct, your Honor.

MR. FICK: Miss Suleimanova, do you recognize the people who are in this photograph?

RAISAT SULEIMANOVA: Yes, of course. These are my sisters and my cousins, male and female cousins.

MR. FICK: Where was this picture taken?

RAISAT SULEIMANOVA: In the town of Kaspiysk, at the square named after Lenin.

MR. FICK: If you touch the screen with your fingers, you can draw circles. Can you just go from right to left and circle the faces and tell us who they are?

RAISAT SULEIMANOVA: This is my older sister Nabisat. This is Dzhokhar. This is also my older sister Naida. This is myself. This is my cousin Tamerlan; my cousin Ailina; my cousin Bella; and my younger sister Rabiyat.

MR. FICK: Thank you. Did your family and the Tsarnaevs frequently visit each other during your childhood and youth?

RAISAT SULEIMANOVA: Yes, fairly often. Every summer they would come and stay with us.

MR. FICK: Did you sometimes visit them in the various places they were living?

RAISAT SULEIMANOVA: I only stayed with them once, in 1991, with my family. We went to visit them in Kirgizia.

MR. FICK: Did -- well, when was the last time you saw Jahar actually in person?

RAISAT SULEIMANOVA: When they were leaving for the United States.

MR. FICK: I'm sorry. When they left for the United States?

MR. FICK: How would you describe the Jahar you knew back then?

RAISAT SULEIMANOVA: I can only say good things about Dzhokhar, and that's not because he's my cousin. He was a very liked child. He was a very kind, very warm child. And I think that his kindness made everybody around him kind. I don't think there is anybody in our family who didn't like him or didn't love him. He was a sunny child. If you looked at him, you would want to smile even if you didn't feel good that time. And regarding what I said about his kindness causing others to be kind, so one time when Zubeidat and Anzor were leaving for Kyrgyzstan, he stayed with Aunt Patimat and Mukhammad Haji. Patimat is very strict. She is the kind of person who have -- one second.

MR. WEINREB: Can we have another question?

THE COURT: Yeah. I think --

MR. FICK: I was actually going to ask you, is there a particular memory or story about Jahar as a child that you would like to share with us?

MR. WEINREB: Your Honor, I object.

THE COURT: I think it has to be a little more guided than that.

MR. FICK: Well, when you talked about how Jahar had an affect on other members of your family, can you give us an example of what you mean -- what you meant?

RAISAT SULEIMANOVA: Yes. That's what I was trying to say. Aunt Patimat was a very strict person. She had her own ways, and even her nieces and nephews couldn't -- one second. So she was very strict with the children, and we couldn't go out of bounds with her. But when Dzhokhar was staying with her, with his kindness, he changed her. He could do whatever he wanted, and she would allow him to do whatever he wanted. She even said herself, This child has changed me. They would watch together a cartoon called king and the lion -- the cartoon, Lion King. And when Simba dies, Dzhokhar was crying. He was very sorry that the lion died. And she would say, I can't even understand how such a small child -- he was about four or five -- could sympathize so much, could understand tragedy. So my aunt changed after that very much. She started really loving everybody, including the children.

MR. FICK: Thank you. Can you tell me a little bit about your Aunt Zubeidat? Describe from your memories what kind of character or personality she had.

RAISAT SULEIMANOVA: First of all, she's a very strong person. She's a very determined person. She has a bright personality. She always wanted everything to be excellent, to be ideal in her life, to be beautiful. And she was trying to achieve it always. She loved fashion, with a big "F." She always loved bright clothing. She liked to wear bright clothing. How should I put that? She had a great taste. She had great taste in clothes and in furnishings. Her house was always the most beautiful. Her children were always the best dressed. She's a very hospitable person. She always had lots of people in her house.

MR. FICK: That's fine. Thank you. I'm going to show you a couple of pictures now and ask if you can tell us who it is and if that matches your memory of Zubeidat. The first one is 3501-16.

MR. FICK: I'd move it into evidence as I publish.

THE COURT: All right.

(Defendant's Exhibit No. 3501-16 received into evidence.)

MR. FICK: Who is this in the photograph, Miss Suleimanova?

RAISAT SULEIMANOVA: My Aunt Zubeidat.

MR. FICK: Is this representative of the kind of way she used to dress?

RAISAT SULEIMANOVA: Yes. I always remember her like this, beautiful, wearing bright clothes.

MR. FICK: Another photograph, moving into evidence 3501-120.

(Defendant's Exhibit No. 3501-120 received into evidence.)

MR. FICK: Is that also your Aunt Zubeidat?

RAISAT SULEIMANOVA: Yes. This is also my Aunt Zubeidat.

MR. WEINREB: Your Honor, I'd just like to say none of us have ever seen some of these pictures before, so our -- any objection to them is conditioned on raising it for those that we're seeing now for the first time.

THE COURT: Maybe we should go through the standard procedure and have you look at it before it's admitted.

MR. WEINREB: I don't want to slow things down unnecessarily. But if we see one that we do object to, then maybe we will need to go through that process. We're willing to assume --

MR. FICK: All of these were previously provided to the government, your Honor, so I'm not sure where the confusion lies. There may have been some miscommunication perhaps, but these are all in a series that were provided.

MR. WEINREB: We would dispute that, your Honor.

THE COURT: Just so -- we'll proceed, I guess, as we have been, admitting them. If there's an issue, we'll deal with it.

MR. FICK: Thank you. 3501-120 is moved in?

MR. FICK: Thank you.

MR. FICK: 3501-121, is this also your Aunt Zubeidat?

RAISAT SULEIMANOVA: Yes. That's how she always was, beautiful, tastefully dressed.

MR. FICK: What kind of personality did she have? Was she shy or outgoing or somewhere between?

RAISAT SULEIMANOVA: No. She wasn't shy at all. That's not something that was characteristic of her. She had a very bright personality. She was outgoing. She was very social. She was loud.

MR. FICK: Would you describe her as emotional or reserved or something between?

RAISAT SULEIMANOVA: Very, very emotional.

MR. FICK: What were her aspirations or goals in life?

RAISAT SULEIMANOVA: As all normal people, she wanted all the best for her and her family and her children. She was always learning. She was always trying to get more and more knowledge. I even heard it here she was studying to be a aesthetician. She was the kind of person -- how shall I put that?

MR. FICK: Okay. Thank you. Tell me a little bit now about your Uncle Anzor. What were your impressions of him growing up?

RAISAT SULEIMANOVA: He was the total opposite of Aunt Zubeidat. She was outgoing. She had this bright personality. Anzor was always very quiet, very even-keeled. He was kind person. He was always willing to help people.

MR. FICK: Did he provide well for his family, at least as you knew them in Russia?

RAISAT SULEIMANOVA: He always worked. He was always trying to provide as well as he could for his family, sometimes working two or three jobs. He didn't want his family to miss anything, to be wanting for anything. He was a very hardworking person, always trying to provide for his family.

MR. FICK: Did he live up to Zubeidat's expectations?

RAISAT SULEIMANOVA: He did his best. He did all he could to fulfill Zubeidat's and the children's expectations.

MR. FICK: Can you tell me a little bit about your observations of the relationship between Anzor and Zubeidat? What kind of relationship did they have?

RAISAT SULEIMANOVA: Anzor was crazy in love with Zubeidat, crazy, crazy in love. He was worshipping her. He wouldn't go anywhere without her. I mean, part is, were to visit somebody, and he didn't want Zubeidat to go anywhere without him, and he was very jealous of her.

MR. FICK: Did you have a favorite memory or story about a role you once played in that jealousy?

RAISAT SULEIMANOVA: Yes. Unfortunately, I was instrumental in stirring this jealousy up, although I'm very ashamed of it. I'll tell you one such story. There was a time when Zubeidat was supposed to attend her classmates' reunion. Anzor knew about this event, but he was away in a different town that time, and so he told Zubeidat not to go anywhere without him. She didn't wait for him, and she went to this event. And she warned everybody, my mother, myself, my sisters, not to tell Anzor about it. So she went. And when Anzor came, the first question was: Where is Zubeidat? My mother said that she went to visit a friend, and my sisters said the same thing. But he came to me and he told me, Raisat, tell me where Zubeidat is. And I told him everything. I told him where she was and with whom. That's how I was involved.

MR. FICK: Did the Tsarnaevs move around to a lot of different places when you were a young person?

RAISAT SULEIMANOVA: Unfortunately, they moved around a lot, and the children had to switch schools a lot. So the children didn't even have time to get adapted to the new school when it was time to move again. So they always lived out of suitcases, so to speak. We would even say, You're like gypsies. You always move around. You never stay in one place for a long time.

MR. FICK: Can you remember or just list off some of the places where you knew the Tsarnaevs to live before they came to America?

RAISAT SULEIMANOVA: Yes, of course. The first place is Novosibirsk. That's where they met.

MR. FICK: I'm sorry. Novosibirsk is not on this map. Can you just point out roughly where it is in Russia?

RAISAT SULEIMANOVA: This is in English though.

MR. FICK: I'm sorry. But you understand that this that I've circled here is Russia, is that right? Is Novosibirsk somewhere in Siberia?

RAISAT SULEIMANOVA: Yes, in Siberia.

MR. FICK: I'm sorry. I interrupted you. Where else did the Tsarnaevs live during your experience with them before they moved to America?

RAISAT SULEIMANOVA: Novosibirsk. Then they lived in Kyrgyzstan, the town of Tokmok. Then they moved to Chechnya, Makhachkala, and then they left. But when they lived in Tokmok, I know that it wasn't all the time that they stayed there. They moved around there as well.

MR. FICK: Is it fair to say they moved back and forth between Dagestan and Central Asia multiple times?

RAISAT SULEIMANOVA: Yes, yes, multiple times.

MR. FICK: When they were in Central Asia, even when they were living in Central Asia, did they sometimes come to visit the family in Dagestan?

RAISAT SULEIMANOVA: They would come to visit us often, especially in summers, with the children. Since we live on the Caspian Sea, all our cousins would come and visit us, including Zubeidat and her children, and not only in summer but many times in other seasons as well.

MR. FICK: When they would visit just for temporary visits to Dagestan, how long would they typically stay?

RAISAT SULEIMANOVA: Minimum of three months and sometimes up to six, seven months.

MR. FICK: How did all this moving around, in your experience, in your observation -- how did that affect Anzor's ability to make a living?

RAISAT SULEIMANOVA: You know, he's the kind of person that can find ways to support his family anywhere. He can find work anywhere. And he was never afraid of not being able to find work. He was an auto mechanic, and he did this all his life.

MR. FICK: How did all of the moving around affect, the children, your cousins, Jahar and his siblings?

RAISAT SULEIMANOVA: I don't think that moving around, changing school, changing friends, not being able to get adapted to one place, I don't think --

MR. WEINREB: Your Honor, I object and move to strike this on the grounds that it's speculative and not based on her personal knowledge.

THE COURT: I'll allow it to stand.

MR. FICK: Thank you. I'll move on.

MR. FICK: Where did the Tsarnaev family live immediately before they left for America?

RAISAT SULEIMANOVA: The town of Makhachkala.

MR. FICK: Did the children attend school?

RAISAT SULEIMANOVA: The children attended School No. 1, close to their house.

MR. FICK: I'm going to move into evidence and publish Exhibit 3507-25.

(Defendant's Exhibit No. 3507-25 received into evidence.)

MR. FICK: Miss Suleimanova, do you recognize what this photograph depicts?

RAISAT SULEIMANOVA: Yes, of course. This is my cousin Dzhokhar in the first grade.

MR. FICK: Can you use your finger and circle him on the screen?

MR. FICK: Thank you. So I'm going to now publish one additional photograph and ask you about it, 3507-111.

(Defendant's Exhibit No. 3507-111 received into evidence.)

MR. FICK: Do you recognize what this photograph depicts?

RAISAT SULEIMANOVA: Yes. These are my cousins and my sisters and my male cousin.

MR. FICK: Where was the picture taken?

RAISAT SULEIMANOVA: This picture was taken in Makhachkala where Zubeidat and her family lived.

MR. FICK: I'm going to circle the faces myself and ask you to identify who each person is. The first one, the man on the left?

RAISAT SULEIMANOVA: This is my cousin Bashir.

MR. FICK: And this young woman?

RAISAT SULEIMANOVA: This is my younger sister, Rabiyat.

MR. FICK: And here, this person?

RAISAT SULEIMANOVA: My cousins Bella and Ailina.

MR. FICK: These two faces are Bella and Ailina?

MR. FICK: And they're Jahar's sisters?

MR. FICK: And this woman in the back?

RAISAT SULEIMANOVA: This is older sister, Naida.

MR. FICK: I'm sorry. This one?

MR. FICK: And who is this?

RAISAT SULEIMANOVA: And this is myself.

MR. FICK: What -- when was this photograph taken? What was the occasion?

RAISAT SULEIMANOVA: This is where we are celebrating the new year, year 2000.

MR. FICK: How is it that you know this is a new-year photograph?

RAISAT SULEIMANOVA: First of all, you can see the Christmas tree on the right or the new-year tree. And you have table set for the celebration. That's a tradition. We always celebrate new year with a Christmas tree.

MR. FICK: What role did religion play in the life of you and your family as you were growing up?

RAISAT SULEIMANOVA: Well, religion is first because I'm a Muslim. We celebrate all our Muslim holidays. If you want me, I can name them. And we observed all the traditions of Islam.

MR. FICK: Were Zubeidat and Anzor religiously observant before they moved to America?

RAISAT SULEIMANOVA: To be honest, I think they were kind of removed from it. What I mean is they would celebrate the major holidays, Kurban Bayram, Uraza Bayram, but they wouldn't pray five times a day.

MR. FICK: After the family, the Tsarnaev family, moved to America, did a time come when Zubeidat became more religious?

MR. FICK: Can you describe what your family in Dagestan observed about that?

RAISAT SULEIMANOVA: Since I live in Moscow, I don't visit Dagestan very often. So what I know --

MR. WEINREB: Your Honor, I object. She's going to testify about what other people know.

THE COURT: I think we need a basis of knowledge.

MR. FICK: Well, I --

MR. FICK: Well, did you personally observe at some point Zubeidat dressed in more religious clothing?

RAISAT SULEIMANOVA: Yes. In 2010, I went back home, and that was the first time I saw her wearing a hijab for the first time.

MR. FICK: What was your reaction to that?

MR. WEINREB: Objection.

RAISAT SULEIMANOVA: I was in shock.

THE COURT: Overruled. I'll allow it.

RAISAT SULEIMANOVA: It was a shock for me. Knowing what kind of person Zubeidat used to be, it was very strange to see that. She used to be such a fashionable person. She loved to wear bright clothing; and now to see her wearing a hijab, it was a shock and not just for me but for my mother and everybody else.

MR. FICK: I'm going to move into evidence and publish Exhibit 3507-58.

(Defendant's Exhibit No. 3507-58 received into evidence.)

MR. FICK: Who is the woman in this photograph?

RAISAT SULEIMANOVA: This is my Aunt Zubeidat.

MR. FICK: Does that reflect how she began to dress at some time after the family moved to America?

MR. WEINREB: Your Honor, I'm going to object on the grounds of a lack of foundation. She said she saw her once in 2010. So how she began to dress back in America is not something she knows about.

THE COURT: Why don't you rephrase the question, refocus it.

MR. FICK: Is this consistent with the way you observed Zubeidat to be dressed when you saw her in 2010?

RAISAT SULEIMANOVA: Yes, that's how she was dressed.

MR. FICK: What, if any, concerns did you and your family have about the change in Zubeidat?

MR. WEINREB: Objection. That's calling for speculation.

THE COURT: Yes. Sustained to that.

MR. FICK: What, if any, concerns did you have about Zubeidat's change in appearance?

MR. WEINREB: Objection.

THE COURT: Same ruling. Sustained.

MR. FICK: What effect have the crimes committed by Tamerlan and Jahar had on you and your family?

MR. WEINREB: Objection.

THE COURT: Sustained.

MR. FICK: May we approach?

THE COURT: All right.

sidebarsidebarFamily Witnesses' Reactions to the Crimes

(SIDEBAR CONFERENCE AS FOLLOWS:

MR. FICK: It seems to me that a witness' potential biases, things that may influence their testimony, things that are on their mind, are always a subject of -- always a subject that's admissible. Here I think it's important to establish, especially given the kind of -- sort of, shall I say, reputation that precedes the family here. For the jury to be able to understand that these folks, while they love Jahar and they came here to support him, they do not support or endorse or in any way the crimes that were committed.

MR. BRUCK: If they are not able to say anything about their feelings and their reaction to this, the jury will simply discount everything they have to say. They will assume that they only care about Jahar and had no feelings whatsoever about this crime. They simply -- it's just essential to position them on the spectrum of human feeling and give them some -- the jury some basis for evaluating what sort of people they are. It's so fundamental.

MR. WEINREB: Your Honor, the only thing relevant here is the evidence that bears on Jahar Tsarnaev's moral culpability for the crime. Questions that essentially have nothing to do with that but that are necessarily going to elicit from the witnesses testimony about how they feel about what is happening to him is bound to have a disproportionate impact on the jury without contributing any probative -- anything probative in the case. Simply something that is going to elicit very prejudicial testimony, potentially going to mislead the jury and confuse the issues, which are not what effect his actions have had on them, let alone what effect his potential death sentence will have on them, but simply whether he is a -- has the kind of character, which is all they can talk about, that would make him somebody not deserving of the death penalty. This is just getting too far afield of that. Its probative value is low, and its prejudicial value is high.

MR. FICK: I certainly don't intend to go into the question about what impact the death penalty would have on his family. Again, witness credibility and witness bias and witness predisposition is always an issue. I'm simply trying to sort of level the field here so that these people are taken seriously.

The questions of what effect did Mr. Tsarnaev's character in the course of his life and the life of his parents are sort of broad ones. We need to sort of lay small bricks one piece at a time. The sort of way the witnesses are heard and interpreted, I think, it's just important for that human piece to be able to be in the picture.

THE COURT: All right. Well, you will have leeway about these witnesses. There's a lot of evidence that would not have been admissible under the Rules of Evidence that you've had. I think this goes too far and asks for personal opinions about things.

DirectDirectRaisat Suleimanova — Direct Raisat Suleimanova William W. Fick

. . . END OF SIDEBAR CONFERENCE.)

MR. FICK: So -- well, Miss Suleimanova, is there anything else you'd like to tell the jury about Jahar or your family?

MR. WEINREB: Objection.

THE COURT: Sustained.

MR. FICK: I have nothing further then. Thank you.

CrossCrossRaisat Suleimanova — Cross Raisat Suleimanova William D. Weinreb

CROSS-EXAMINATION BY MR. WEINREB:

MR. WEINREB: Good morning.

MR. WEINREB: My name is Bill Weinreb. I'm an attorney for the United States. I'd like to ask you a few questions.

MR. WEINREB: You talked about the defendant's family moving around before they came to the United States.

MR. WEINREB: Most of those moves took place before he was born, correct?

RAISAT SULEIMANOVA: Some before and some after.

MR. WEINREB: He spent -- he moved here when he was about eight years old?

MR. WEINREB: And for almost five years before that, he had lived in one place?

RAISAT SULEIMANOVA: As far as I know, they lived in Kyrgyzstan, and they moved to Grozny and then they moved to Makhachkala.

MR. WEINREB: The defendant was never in Grozny, was he?

RAISAT SULEIMANOVA: They didn't stay there for a long time. They moved there. They bought a house, but then the war began and they moved away.

MR. WEINREB: Yes. But, in fact, the defendant himself has never set foot in Chechnya, has he?

RAISAT SULEIMANOVA: I cannot give you the exact dates. I was a child myself. But I know for a fact that they moved to Chechnya and then the war began and they moved away from Chechnya.

MR. WEINREB: Because you were a child, you weren't keeping track of the exact dates of where they were when the defendant was alive?

RAISAT SULEIMANOVA: I was 14 years old when the war broke out in Chechnya.

MR. WEINREB: So it's possible the defendant spent about four or five years in one place in Kyrgyzstan before the family moved to the United States?

MR. FICK: Objection. I think the foundation is lacking based on the answers.

THE COURT: Go ahead. You can have it.

INTERPRETER: Can the question be read out, please?

MR. WEINREB: So it's possible that the defendant spent about four or five years in Kyrgyzstan before moving to the United States?

MR. FICK: Objection.

THE COURT: Overruled.

RAISAT SULEIMANOVA: I cannot tell you for a fact.

MR. WEINREB: No matter where he lived, he managed to -- and the whole family managed to -- summer on the Caspian Sea?

RAISAT SULEIMANOVA: Yes. They would always come for vacation no matter where they would live. They would come for -- to spend the summer.

MR. WEINREB: And spend time with family?

RAISAT SULEIMANOVA: Yes, with us, of course.

MR. WEINREB: You haven't seen the defendant since he was eight years old, correct?

RAISAT SULEIMANOVA: Yes. I haven't seen him since he left.

MR. WEINREB: Okay. But growing up, he was very loved?

RAISAT SULEIMANOVA: Yes, yes, madly, everybody.

MR. WEINREB: He grew up surrounded by loving family members?

RAISAT SULEIMANOVA: Yes. He was such a sweet child. One couldn't help but love him.

MR. WEINREB: Family members who doted on him?

RAISAT SULEIMANOVA: Yes, of course. He was the little one.

MR. WEINREB: And they supported him?

MR. WEINREB: If he had needs, they were met?

RAISAT SULEIMANOVA: What does a child need? I don't think a small child needs much.

MR. WEINREB: He needed food.

MR. WEINREB: And he was always well-fed?

MR. WEINREB: He always had clothing?

RAISAT SULEIMANOVA: Yes. Zubeidat really took care of the clothes and of her children. She made sure that her children are well-dressed.

MR. WEINREB: If he was sad, someone comforted him?

RAISAT SULEIMANOVA: Yes. When a child cries, yes, especially since there are sisters around.

MR. WEINREB: He was a very lucky boy in that way?

RAISAT SULEIMANOVA: He has a lot of cousins.

MR. WEINREB: And all these cousins and family members who surrounded him with love and with support, they helped him become a confident young boy?

RAISAT SULEIMANOVA: Yes, at least until he turned eight years old. But I've already said that I haven't seen him since he was eight.

MR. WEINREB: Okay. But when you did see him, they had raised him to be a confident young boy?

RAISAT SULEIMANOVA: Yes, of course.

MR. WEINREB: So confident that he wasn't intimidated by his strict aunt?

MR. WEINREB: You told a story about he had a strict aunt.

RAISAT SULEIMANOVA: She was strict towards us, but for a child who is four or five years old, it's hard to be very strict with a child like that.

MR. WEINREB: Well -- but you said that Jahar was the one who managed to make her less strict.

RAISAT SULEIMANOVA: Yes. He lived with her, and she changed because of him. Her biological children actually lived with their grandmother.

MR. WEINREB: So when he faced someone in the family, someone older who was strict, he managed to change them?

RAISAT SULEIMANOVA: You know, when he was a boy, he had such a smile that, know matter how strict you were, you couldn't help but have this huge smile on your face.

MR. WEINREB: And because of that, you said he could do whatever he wanted?

RAISAT SULEIMANOVA: Well, I don't mean it literally.

MR. WEINREB: But you mean that -- I'm sorry.

RAISAT SULEIMANOVA: In the bounds of the reasonable.

MR. WEINREB: But he did have a mind of his own even at age eight?

RAISAT SULEIMANOVA: I didn't understand the question.

MR. WEINREB: Let me ask a different question. You talked about Jahar's kindness.

MR. WEINREB: Okay. But you would agree that the bombing of innocent people is not an act of kindness?

MR. FICK: Objection.

THE COURT: Sustained. Same objection we dealt with at the side.

MR. WEINREB: Well, you said he felt sad watching the Lion King?

MR. WEINREB: He cried when Mustafa died?

RAISAT SULEIMANOVA: Yes, the character. What was his name? Yeah, when the -- when Simba's father died.

MR. WEINREB: But you would agree that a person who cries at the death of a cartoon character but is indifferent to the death and suffering of hundreds of people --

MR. FICK: Objection.

THE COURT: Sustained, Mr. Weinreb.

MR. FICK: We need to be seen at sidebar, your Honor.

THE COURT: No. I think it's clear. Sustained.

MR. WEINREB: I have no further questions.

MR. FICK: May we be seen?

THE COURT: All right.

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