Response To US Opposition To Motion 2255 (June 9, 2014)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION
UNITED STATES OF AMERICA
VS.
ABDULRAHMAN ODEH CIVIL NOS. 3:13-CV-04299-P

MUFID ABDULQADER 3:13-CV-04300-P
GHASSAN ELASHI 3:13-CV-04301-P
MOHAMMAD EL-MEZAIN 3:13-CV-04302-P
SHUKRI ABU BAKER 3:13-CV-04303-P
CRIM. NO. 3:04-CR-00240-P
MOVANTS CORRECTED RESPONSE TO UNITED STATES
OPPOSITION TO MOTIONS UNDER 28 U.S.C. 2255
TO VACATE, SET ASIDE, OR CORRECT SENTENCE
BY A PERSON IN FEDERAL CUSTODY
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES the Movants, ABDULRAHMAN ODEH, MUFID ABDULQADER,
GHASSAN ELASHI, MOHAMMAD EL-MEZAIN, and SHUKRI ABU BAKER, submits this
Corrected Response to United States Opposition to Motions to Vacate, Set Aside or Correct
Sentence Under 28 U.S.C. 2255 By A Person In Federal Custody and would show the
following:
I.
Scope Of This Response
This response covers issues that were raised by all of the Movants. Any issues that are
unique to a particular Movant are addressed in a separate response. This corrected response is to
correct typographical errors on page 2.
Movants Corrected Response to United States Opposition to Motion to Vacate, Set Aside or Correct Sentence
Under 28 U.S.C. 2255 - Page 1
II.
Introduction
The Movants were prosecuted and convicted of providing support - food, school supplies,
monthly stipends, and the like - to Palestinians in the West Bank through local Zakat (charity)
committees that, according to the government, Hamas controlled. There is no contention that the
Movants provided material support directly to Hamas. Rather, the governments theory was that
Hamas controlled the Zakat Committees, and that by providing support to the Zakat Committees,
the Movants provided support to Hamas.
The evidence at trial did not establish that Hamas controlled the Zakat Committees. To the
contrary, the evidence showed that the Zakat Committees were independent of political control and
operated as charitable organizations through the supervision of local committees comprised of
community leaders.
Moreover, additional evidence submitted in support of these 2255 motions further
demonstrates that Hamas did not control these Zakat Committees. At trial, no witness testified who
had any personal knowledge or involvement in the Zakat Committees. All of the evidence which
the government relied on to argue that the Zakat Committees were controlled by Hamas came from
persons who had no real factual knowledge of the operation of the Zakat Committees. Even then,
the government witnesses presented no evidence by which a rational juror would have found that the
crucial element of control was established. The court now has before it evidence from Zakat
Committee insiders that Hamas did not control these committees. These insiders are persons who
were members of the Zakat Committees and worked at the committees on a day to day basis. This
evidence establishes, beyond any question, the falsity of the governments charge. In fact, Hamas
did not control these Zakat committees.
These Movants are innocent. They did not provide material support to Hamas, either directly
or indirectly. Hamas did not control the Zakat committees and this fact, standing alone, shows that
each of these five men were unjustly imprisoned on a charge on which they are, without question,
totally innocent.
III.
Necessity of Evidentiary Hearing
As explained in more detail below, these 2255 motions cannot be fairly decided without an
evidentiary hearing. 28 U.S.C. 2255(b) states:
(b) Unless the motion and the files and records of the case conclusively show that
the prisoner is entitled to no relief, the court shall cause notice thereof to be served
upon the United States attorney, grant a prompt hearing thereon, determine the issues
and make findings of fact and conclusions of law with respect thereto.
Clearly, there are substantial and serious issues raised that require a hearing for a fair
resolution. See Owens v. United States, 551 F.2d 1053, 1054 (5th Cir.), cert. denied, 434 U.S. 848
(1977) (District Court in a federal habeas corpus case should not ordinarily attempt to resolve
contested issues of fact without holding an evidentiary hearing).
IV.
Issues Raised (Joint Issues)
The issues raised that are common to all Movants are:
GROUND ONE: All Movants received ineffective assistance of counsel at trial.
GROUND TWO: All Movants received ineffective assistance of counsel on appeal.
GROUND THREE: There is no evidence that Hamas controlled the Zakat Committees.
GROUND FOUR: The government suppressed exculpatory evidence.
GROUND FIVE: The Court of Appeals engaged in an improper harm analysis on appeal resulting
in a denial of due process.
GROUND SIX: The prosecution was brought against the Movants for improper purposes resulting
in a denial of due process and equal protection.
V.
Response to Governments Arguments
Ground One:
All Movants received ineffective assistance of counsel at trial.
Reply to Governments Response
Ineffective assistance at trial was rendered in the following ways:
a. Failure To Challenge The Basis Of the Expert Testimony Concerning Whether
Hamas Controlled The Zakat Committees
Defense counsel did challenge the testimony of the governments expert witnesses under
Rule 702 of the Rules of Evidence. However, a specific challenge to the witnesses basis of
knowledge as to whether Hamas controlled the Zakat Committees was not pursued. In particular,
government witnesses Levitt, Avi, and Shorbagi claimed that Hamas controlled the Zakat
Committees. However, they had no factual basis for this testimony.
The government contends that defense counsel did make the challenge that is complained of.
In order to make this contention, the government rewrites the question raised by Movants. The
specific testimony which defense counsel failed to challenge was the witnesses basis of knowledge
of whether Hamas controlled the Zakat Committees. Rather than address this question, the
government rewrote the question and treated it as whether defense counsel failed to challenge the
governments experts with respect to their knowledge of Zakat Committees. (Gov. Response, p.
17). In fact, while defense counsel did make a general challenge to the expert testimony with respect
to the knowledge of the Zakat Committees, no challenge was made concerning the experts basis of
knowledge as to whether Hamas controlled the committees. These are two different questions.
The court understood what was being challenged. In its Memorandum and Order addressing
this issue, the Court stated, as to Dr. Levitt,
E. Admissibility of Levitts Testimony
The defendants object to Levitts proposed expert testimony on three grounds.
First, they argue that Levitts methodology lacks the reliability necessary to qualify
his opinion under Daubert. Second, the defendants claim that Levitts testimony is
nothing more than hearsay in disguise. Finally, they aver that his expert testimony
runs afoul of the Confrontation Clause. Doc. 717.
Likewise, the challenge to Avis factual basis underlying his knowledge of the committees
is not the same thing as a challenge to his basis of knowledge as to whether Hamas controlled the
Zakat Committees. The same is true as to Shorbagi.
b. Evidence From Members of the Committees
Defense counsel rendered ineffective assistance at trial by failing to present evidence from
persons who were actually involved personally, as members or employees, at the Zakat Committees.
Witnesses with personal knowledge that Hamas did not control the Committees would certainly have
caused a different outcome in this trial.
Affidavits have been submitted with this 2255 motion from the following persons who were
available to provide this evidence:
- Muhammad Eed Muhammad Mesh
- Abd-El Azez Magames Abd-El Azez Saafen
- Hashen Sadek Abd El Fattah Alnatshen
- Hamzeh Theeb Mustafa Abu-Sbaiha
- Ammar Tawfik Ahmad-Badawi Khojiyyeh
- Ghayyat Raafat Hafez Khairy
- Walid Abdallatif Solayman Abu Libdeh
- Riyad Rashid Hamad Walwil
- Abd Al Rahin Mohammad-Radi Taha Hanbali
- Adil Rifaat Salih Yaeesh
- Yasin Ahmad Amin Al-Saadi
- Walid Ibrahim Khaled Jarror
- Bilal Khamis Yusef Abu-Sofirah
- Shaban Mohammad Salem Abu-Atten
- Hilwa Azmi Mohammad Hermas
- Gayath Rafat Hafez Khayre
- Adli Rifaat Salih Yaesh
- Ammar Towfiq Ahmad-Badawi Ayyoub
These affidavits all state the following:
1. That the affiant was a member of a particular West Bank Zakat Committee.
2. That this affiant was not associated with Hamas.
3. Hamas did not control the Zakat Committee.
4. That the Committees operated independently.
These witnesses were available to testify at the time of this trial. They are available to testify
now.
The government contends that these witnesses will not, and were not, able or willing to come
to the United States to provide testimony. However, the only way to determine if the witnesses will
1
provide this testimony is to set this case for a hearing and give the witnesses the opportunity to come
See affidavit from Adli Rifaat Salih Yaeesh expressing a willingness to provide testimony before a United States Court. Same
1
from Abd-Alrahim Mohammad-Radi Taha Hanbali, Ammar Tawfiq Ahmad-Badawi Ayyoub, Bilal Khamis Yousef Abu-Sofira,
Abd-El Azez Magames Abd-Azez Saafen, Walid Abd-Allatil Solayman Abu-Libdeh, Muhammed Eid Muhammed Mesk,
Hashem Sadek Abd-Elfattah Alnatsheh, Gayyath Rafat Hafez Khayre, Riyad Rashid Hamad Walwil, Shaban Mohammad Salem
Abu-Atten, Hilwa Azmi Mohammad Hermas, Hamzeh Theeb Mustafa Abu-Sabiha, Walid Khaled Ibrahim Jarrar, Yasin Ahmad
Amin Al-Saadi.
to the United States to testify. Speculation as to whether they will testify will be mooted by them
actually appearing and providing testimony.
The government additionally argues that the decision not to call these witnesses was a
reasonable strategy choice by counsel. However, affidavits have been submitted by defense counsel
Nancy Hollander, Teresa Duncan, John Cline, Linda Moreno, and Marlo Cadeddu admitting that this
was not a strategy decision. The question of whether the failure to call these witnesses constitutes
ineffective assistance requires a complete evidentiary hearing where defense counsel, as well as the
witnesses, are allowed to testify.
c. Decision Not To Call Nathan Brown At The Second Trial
At the first trial, which resulted in a mistrial, the defense called expert Nathan Brown.
Professor Brown was a very effective witness who had an expertise concerning the Zakat
Committees. Unlike the government experts, he had actually visited some Zakat Committees. He
had also done extensive investigation and research into the Zakat Committees. His testimony refuted
the governments argument that Hamas controlled the Zakat Committees. However, the defense
attorneys did not call Professor Brown in the second trial, even though he was the best, most
effective witness from the first trial.
Professor Brown was willing and able to testify in the second trial. An affidavit from him
to this effect has been filed.
Moreover, it was not reasonable trial strategy to not call him to testify in the second trial.
Defense counsel Nancy Hollander has provided an affidavit which states the following:
3. The Motion alleges that the defense should have called Professor Nathan
Brown to testify in the second trial and the failure to do so was ineffective.
Professor Nathan Brown did testify in the first trial. We did not call him to
testify in the second trial, which I believe was error. His testimony was important
and material and could have brought about a different result in the second trial.
This is an issue that should be further addressed in an evidentiary hearing.
d. Motion to Suppress
Defense counsel failed to pursue a motion to suppress the evidence obtained from HLFs
offices without a warrant by challenging the blocking order. The Court of Appeals upheld the
District Courts denial of the defendants motion to suppress this evidence and noted that the defense
had not challenged the blocking order. The Court of Appeals referred to a Ninth Circuit case that
had found constitutional problems with a blocking order and implied that a challenge to the blocking
order in this case would have been well founded. The failure to make this challenge constitutes
ineffective assistance.
Defense counsel Nancy Hollander also addressed this issue in her affidavit, stating:
4. The Motion alleges that the defense lawyers were ineffective in failing to
pursue a motion to suppress the evidence the government obtained from the Holy
Land Foundations offices without a warrant by challenging the blocking order.
The Fifth Circuit Court of Appeals noted the failure to make this challenge
in its opinion upholding the convictions. Our failure to make this challenge was not
the result of any trial strategy on our part. According to the appellate court, we
should have made this challenge and I agree that it was an error not to do so.
See also affidavit of Theresa Duncan.
This is another issue that must be addressed in an evidentiary hearing.
e. Selective Prosecution
Defense counsel were ineffective for not raising a selective prosecution argument. The
government selectively prosecutes Muslims and Muslim groups under the statutes used in this case
and under similar statutes. Non-Muslims are rarely, if ever, prosecuted for this alleged conduct. A
prima facie case of selective prosecution could have been made that would have allowed the defense
to engage in the necessary discovery to prove that this prosecution was pursued based on the
defendants Muslim religion and was in violation of due process.
Contrary to the governments argument, a prima facie case can be made that the government
engaged in selective prosecution against Muslims. This is an issue that must be addressed in an
evidentiary hearing.
f. Exculpatory Evidence
Defense counsel were ineffective for not requesting that the Court order the prosecutors to
review items in their possession for exculpatory evidence. These items include taped conversations
that the government had of various defendants and the material seized by the Israeli defense forces
from the Zakat Committees and kept in Israel. While the defense made efforts to review this
evidence themselves, they did not ask for an order to the prosecutors for them to fulfill their
obligation to review this material for exculpatory evidence. Had the prosecutors been ordered to
review this material for exculpatory evidence, evidence would have been discovered that showed that
the defendants were attempting to comply with the law and that Hamas did not control the Zakat
Committees. This evidence would have included conversations involving the defendants that
showed efforts to be in compliance with the law and a belief that they were in compliance.
Moreover, the evidence taken from the Zakat Committees by the Israeli military certainly included
pro Fatah material that would indicate that Hamas did not control the Zakat Committees.
The governments response is that counsel made substantial arguments in an attempt to
obtain exculpatory evidence. Movants do not contend otherwise. This argument is that counsel
should have made this specific argument as part of their effort to obtain exculpatory evidence.
Additionally, the government argues that the phone calls were turned over to cleared defense
counsel, and other material was in the possession of the Israeli military, not the United States
government. This argument ignores the fact that it was impossible for defense counsel to listen to
all of the calls since they do not speak or understand Arabic and there were not enough security-
cleared Arabic speakers to assist the defense in listening to the calls. On the other hand, the
government had more than adequate resources to review these calls for exculpatory evidence.
Moreover, while the other evidence was in the control of the Israeli military, the record shows
that the U. S. Justice Department had access to this material, and the prosecutors and agents had
looked at it. They could certainly have done a complete review for exculpatory evidence.
Lastly, the government again argues that the defense cannot show prejudice from the denial
of exculpatory evidence because they cannot identify what exculpatory evidence they did not receive.
This circular argument is designed to deny the defense access to exculpatory evidence that certainly
exists and undermines the legal requirement that the government provide to the defense all
exculpatory evidence.
g. Defense Counsel Were Deficient In Not Raising An Entrapment Defense
In the 2255 Motion and Memorandum in Support, Applicants set out, in detail, the facts and
law supporting an entrapment defense. The government responds that counsel had sound tactical
reasons for not raising an entrapment defense. However, defense counsel Nancy Hollander
addressed this issue in her affidavit, stating:
7. The Motion alleges that the defense lawyers were ineffective by not
requesting an entrapment defense instruction or otherwise pursuing an entrapment
defense.
I agree that we should have done this. There was evidence that the defendants
were led into committing this offense by actions taken by government officials.
There was also evidence that the defendants were attempting to comply with the law.
These facts created a basis to pursue an entrapment defense. Our failure to do so was
not the result of any trial strategy.
See also affidavit of Theresa Duncan.
Moreover, the contention that the government did not induce Movants crimes is refuted by
the facts of this case. By not listing the Zakat Committees, and specifically rebuffing Movants
attempts to ensure they were complying with the law, the government directly induced the alleged
violation of the law.
Likewise, the governments argument that Movants were predisposed to violate the law is
without merit. In fact, the Movants made significant efforts to be in compliance with the law and,
had the government not engaged in misleading and deceptive tactics, there would never have even
been a claim of a violation.
h. Mistake of Law
Defense counsel were ineffective for not pursuing a mistake of law defense. This was a
legitimate defense based on the meeting with the officials where the defendants were led to believe
that contributions to the Zakat Committees were not prohibited.
In United States v. Davis, 690 F.3d 330 (5th Cir. 2012), the court stated:
In general, under both federal and Texas state law, ignorance of the law is not a
defense. See, e.g., Ratzlaf v. United States, 510 U.S. 135, 149, 114 S.Ct. 655, 126
L.Ed.2d 615 (1994); Tex. Penal Code Ann. 8.03(a) (It is no defense to prosecution
that the actor was ignorant of the provisions of any law after the law has taken
effect.). Under federal law, a mistake-of-law defense may be allowed only where
the crime charged is a specific intent crime. Cf. United States v. Whaley, 577 F.3d
254, 262 n. 6 (5th Cir. 2009); see also United States v. Schultz, 333 F.3d 393, 410-11
(2d Cir. 2003).
The offense charged in the indictment in the case at bar were specific intent crimes. For this
reason, the defendants received ineffective assistance based on the failure to raise this defense.
I. Vagueness of Statute
Movants withdraw this portion of their ineffective assistance argument.
Ground Two:
All Applicants received ineffective assistance of counsel on appeal.
Reply to Governments Response:
a. Failure To Challenge Sufficiency of Evidence
In order for Applicants to be guilty of any count in the indictment, the government was
required to prove that Hamas directed or controlled the Zakat Committees listed in the indictment.
Since there was insufficient evidence to prove this, defense counsel were ineffective on appeal in
not raising this issue.
The following is what the evidence, in the light most favorable to the verdict, shows:
1. No HLF funds were sent to Hamas.
2. Whether Hamas controlled the committees was the key question in the trial.
3. No witnesses testified that had any personal knowledge as to whether Hamas
controlled the Zakat Committees.
4. There was no evidence at all as to how the Zakat Committees operated, how decisions
were made, how they received and distributed aid or who actually controlled or directed the activities
of the committees.
5. The government presented evidence that some of the defendants were sympathetic
with some of the activities and philosophy of Hamas, and some had connections to Hamas leaders.
The government also presented evidence that some Hamas members and sympathizers were on the
Zakat Committees. However, there was no evidence showing how these facts established control
of the Zakat Committees by Hamas.
6. There were conclusory statements by some witnesses that Hamas controlled the Zakat
Committees. However, there was no evidence presented that supported the conclusory statements.
In response, the government cites language from the Court of Appeals opinion concerning
the formidable evidence of guilt. However, in order to understand the opinion of the Court of
Appeals, it is necessary to understand what they were analyzing. Since defense counsel did not
challenge the sufficiency of the evidence and did not argue that there was insufficient evidence on
the particular question of control of the committees by Hamas, the Court of Appeals did not analyze
that argument. By failing to raise this issue and focus the Court of Appeals on the question of
control, defense counsel allowed the Court of Appeals to believe the evidence was formidable
based on the evidence of sympathy between some committee members and Hamas, and some
defendants and Hamas. However, the case was not about sympathy; it was about control, and the
Court of Appeals was not asked to decide if control was proven.
The government further argues that HLF functioned as a fund-raising entity for Hamas.
(p. 49). While the evidence proved no such thing, even if it did, this is a completely different
question from whether Hamas controlled the Zakat Committees.
Additionally, the government contends that Hamas made efforts to obtain control of
charitable committees and other institutions by installing a critical mass of Hamas members in the
controlling positions of these institutions. p. 49. However, the governments own statement shows
that there was no control of the committees by Hamas. They say Hamas made efforts to obtain
control. However, making efforts is not the same as obtaining control. They say Hamas efforts
included installing a critical mass of Hamas members in the controlling positions. However, the
government does not show that Hamas did this or how, even if this was true, it resulted in control
of the committees. Most importantly, the government fails to make the crucial connection and
demonstrate how having Hamas members or sympathizers on the Zakat Committees resulted in
Hamas control of the committees.
Likewise, the statements made by some persons that certain committees are ours, referring
to Hamas, does not prove control. What is meant by ours is unclear, but it does not equate with
control. Rather, it is likely nothing more than a reflection of sympathy for Hamas within some
committees. The use of the word ours cannot substitute for actual evidence proving control.
b. Failure to Raise Vagueness of Statute
Applicants have withdrawn their argument that counsel was ineffective at trial in not raising
an argument concerning the constitutional vagueness of the statute at trial. In fact, trial counsel did
raise this argument. However, on appeal, counsel failed to raise the issue. The failure to raise the
vagueness issue constitutes ineffective assistance on appeal.
18 U.S.C. 2339B and 50 U.S.C. 1701-06 prohibits giving aid to designated terrorist
organizations. However, in this case, the Zakat Committees that received the aid were not
designated. This raises an issue of constitutional vagueness as applied.
Vagueness may invalidate a criminal law for either of two independent reasons. See City of
Chicago v. Morales, 527 U.S. 41, 56 (1999). First, it may fail to provide the kind of notice that will
enable ordinary people to understand what conduct it prohibits; second, it may authorize and even
encourage arbitrary and discriminatory enforcement. See id., Kolender v. Lawson, 461 U.S., at 357;
Smith v. Goguen, 415 U.S. 566, 572-73 (1974) (The doctrine incorporates notions of fair notice or
warning. Moreover, it requires legislatures to set reasonably clear guidelines for law enforcement
officials and triers of fact in order to prevent arbitrary and discriminatory enforcement.). This
second ground mandates that laws contain minimal guidelines to govern law enforcement.
Kolender v. Lawson, 461 U.S. 352, 358, 103 S.Ct. 1855, 75 L.Ed.2d 903 (1983). Indeed, statutes
must provide explicit standards for those who apply them to avoid resolution on an ad hoc and
subjective basis, with the attendant dangers of arbitrary and discriminatory application. Grayned,
408 U.S. at 108-09, 92 S.Ct. 2294.
Accordingly, the first issue is whether the statutory scheme prohibiting material support to
a designated terrorist organization provides fair notice to the citizen. See Morales, 527 U.S. at 56.
It is established that a law fails to meet the requirements of the Due Process Clause if it is so vague
and standardless that it leaves the public uncertain as to the conduct it prohibits. . . . Giaccio v.
Pennsylvania, 382 U.S. 399, 402-03, 86 S.Ct. 518, 15 L.Ed.2d 447 (1966).
The vagueness that dooms this statute is not the product of uncertainty about the normal
meaning of designated, but rather about what activity is covered by the statute when the organization
is not designated. The purpose of the fair notice requirement is to enable the ordinary citizen to
conform his or her conduct to the law. Here, the defendants made significant efforts to comply with
the law. Yet, according to the government, their conduct did not comply. If they were not in
compliance, it is only because of the uncertainty and vagueness inherent in the application of these
statutes to their conduct.
c. Failure to Raise The Court of Appeals Erroneous Harm Analysis on Petition
for Writ of Certiorari
Applicants contend that appellate counsel was ineffective for not raising this strong issue on
a Petition for Writ of Certiorari to the U. S. Supreme Court. There is no question that the Court of
Appeals engaged in an erroneous harm analysis and there is a good chance that the Supreme Court
would have agreed to review this question.
Ground Three
There is no evidence that Hamas controlled the Zakat Committees. Thus, the defendants are
actually innocent.
Applicants argue that the Courts should recognize a free-standing claim of actual innocence
on an application for writ of habeas corpus. Once such a claim is recognized, based on the facts and
circumstances of this case, it is established that all Applicants are actually innocent of these charges.
Ground Four
The government suppressed exculpatory evidence.
As argued previously, there is no question that the government had within its possession and
control exculpatory evidence that was not turned over to the defense. This exculpatory evidence
consists of intercepted phone calls and items in an Israeli military warehouse.
When the government is in exclusive control of a large amount of potential evidence that the
defense does not have access to, there is a constitutional imperative that this evidence be reviewed
and examined and that all exculpatory evidence located be turned over to the defense. This requires
the government to actually listen to all of the phone conversations in order to identify exculpatory
evidence. And it requires the government to review all of the material in the warehouse in Israel to
identify exculpatory evidence.
The suppression of this exculpatory evidence constituted a violation of due process.
Ground Five
The Court of Appeals engaged in an improper harm analysis on appeal resulting in a denial
of due process.
Applicants contend that the Court of Appeals improper harm analysis was so egregious as
to violate due process. This constitutional violation should be corrected through this 2255 motion.
Ground Six
The prosecution was brought against the Applicants for improper purposes resulting in a
denial of due process and equal protection.
The defendants in the Holy Land Foundation case were prosecuted for one reason, and one
reason only: they are Muslim. This selective prosecution is in violation of their right to due process
and equal protection of the law under U. S. Constitution, amends. V and XIV. This egregious
injustice should be corrected on this 2255 motion.
CONCLUSION
For all of the reasons argued previously, as well as those in this submission, the Court should
set this matter for an evidentiary hearing and then grant the prayed for relief.
Respectfully submitted,
/s/ Gary A. Udashen
GARY A. UDASHEN
Texas State Bar No. 20369590
SORRELS, UDASHEN & ANTON
2311 Cedar Springs Road
Suite 250
Dallas, Texas 75201
214-468-8100
214-468-8104 fax
Attorney for Movants
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the foregoing Movants
Corrected Response to United States Opposition to Motions Under 28 U.S.C. 2255 to Vacate, Set
Aside, or Correct Sentence By A Person In Federal Custody was electronically delivered to
all counsel, on this the 9th day of June, 2014.
/s/ Gary A. Udashen
GARY A. UDASHEN

Response To US Opposition To Motion 2255 (June 9, 2014)

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Response To US Opposition To Motion 2255 (June 9, 2014)

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IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

ABDULRAHMAN ODEH CIVIL NOS. 3:13-CV-04299-P

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