7 March 2001
Source: Digital file from the Court Reporters Office, Southern District of New York; (212) 805-0300.

This is the transcript of Day 14 of the trial, 7 March 2001

See other transcripts: http://cryptome.org/usa-v-ubl-dt.htm


                                                                1884



   1   UNITED STATES DISTRICT COURT
       SOUTHERN DISTRICT OF NEW YORK
   2   ------------------------------x

   3   UNITED STATES OF AMERICA

   4              v.                           S(7) 98 Cr. 1023

   5   USAMA BIN LADEN, et al.,

   6                  Defendants.

   7   ------------------------------x

   8
                                               New York, N.Y.
   9                                           January 8, 2001
                                               9:55 a.m.
  10

  11

  12   Before:

  13                       HON. LEONARD B. SAND,

  14                                           District Judge

  15

  16

  17

  18

  19

  20

  21

  22

  23

  24

  25



                                                                1885



   1                            APPEARANCES

   2   MARY JO WHITE
            United States Attorney for the
   3        Southern District of New York
       BY:  PATRICK FITZGERALD
   4        KENNETH KARAS
            PAUL BUTLER
   5        Assistant United States Attorneys

   6
       SAM A. SCHMIDT
   7   JOSHUA DRATEL
       KRISTIAN K. LARSEN
   8        Attorneys for defendant Wadih El Hage

   9   ANTHONY L. RICCO
       EDWARD D. WILFORD
  10   CARL J. HERMAN
       SANDRA A. BABCOCK
  11        Attorneys for defendant Mohamed Sadeek Odeh

  12   FREDRICK H. COHN
       DAVID P. BAUGH
  13        Attorneys for defendant Mohamed Rashed Daoud Al-'Owhali

  14   JEREMY SCHNEIDER
       DAVID STERN
  15   DAVID RUHNKE
            Attorneys for defendant Khalfan Khamis Mohamed
  16

  17

  18

  19

  20

  21

  22

  23

  24

  25



                                                                1886



   1            (Trial resumes)

   2            THE COURT:  The record will indicate that the Court

   3   didn't sit on Monday and Tuesday, March 5th and 6th, because

   4   of the weather conditions.

   5            On March 6th I entered an order with respect to the

   6   cross-examination of victim witnesses consistent with my

   7   ruling the previous Thursday that crossed with a motion in 

   8   limine by the government dated March 5.  In my March 6

   9   memorandum I said, "If any defense counsel believes that the

  10   vulnerability of the embassy or the failure to issue warning

  11   or take other precautions is a valid defense issue as to

  12   guilt, the Court should promptly be so advised, preferrably in

  13   writing, and we will deal with this issue forth with."

  14            I subsequently received a letter from Frederick Cohn,

  15   which, I've been advised, is also to be sealed, and I have so

  16   marked my copy, in which he makes certain observations but

  17   does not contest that the vulnerability of the embassy or the

  18   failure to advise Kenyans of any threats was relevant.

  19            Does anybody have a contrary view?  Silence is

  20   acquiescence.  I assume, therefore, that questions such as

  21   that posed to Ambassador Bushnell at page 1876, line 16, "As

  22   United States ambassador, did you ever warn the Kenyans about

  23   threats made against U.S. embassies or U.S. facilities?" will

  24   not be asked of any of the victim witnesses and that the

  25   matter need not be addressed before the jury.



                                                                1887



   1            At some point today, not now and not in open court, I

   2   would like to resume a dialogue which was begun last week with

   3   respect to future timing of this case and what, if anything,

   4   should be said to the jurors.

   5            Any other matter which we should address before we

   6   bring in the jury?

   7            MR. KARAS:  Your Honor, with respect to your Honor's

   8   ruling regarding the in limine motion and Ambassador Bushnell,

   9   we assume that that same ruling would apply to the witnesses

  10   that would testify regarding the Dar es Salaam Embassy and the

  11   Dar es Salaam bombing and any issues regarding vulnerability

  12   and so forth.

  13            MR. RUHNKE:  No problem, Judge.

  14            THE COURT:  I think that's correct, yes.

  15            Mr. Cohn.

  16            MR. COHN:  There will be some matters which should be

  17   taken up before Agent Gaudin takes the stand, which I gather

  18   will be right after the victims.  I can do it now or I can

  19   wait until the recess.

  20            THE COURT:  Let's do it during the recess and let's

  21   bring in the jury and the next witness.

  22            MR. BUTLER:  Your Honor, one quick matter.  We would

  23   request that the victim witnesses not be sketched.

  24            THE COURT:  Not be sketched.

  25            Is there a sketch artist in the courtroom?  No.  All



                                                                1888



   1   right.

   2            MR. RUHNKE:  Just walked in, I think.

   3            THE COURT:  Ma'am, are you a sketch artist?

   4            SPECTATOR:  No.

   5            MR. SCHMIDT:  Your Honor, just so you're aware, we

   6   have issues concerning the cross-examination of Officer Gaudin

   7   that we would like to take up also.

   8            THE COURT:  Very well.

   9            All right, so let's bring in the jury and the next

  10   witness.

  11            I just advise the marshals, then, if a sketch artist

  12   comes and starts to sketch, that he or she been advised not to

  13   sketch the faces of any of the witnesses this morning.

  14            (Jury present)

  15            THE COURT:  Welcome back.  Welcome back.

  16            THE JURY:  Good morning.

  17            THE COURT:  Before we begin, may I inquire whether

  18   any jurors have seen or read any media reports over the trial

  19   over the weekend or before trial today?

  20            THE JURY:  No.

  21            THE COURT:  Very well.  The government may call its

  22   next witness.

  23            MR. BUTLER:  Government calls Frank Pressley, your

  24   Honor.

  25



                                                                1889



   1    FRANK PRESSLEY,

   2        called as a witness by the government,

   3        having been duly sworn, testified as follows:

   4            DEPUTY CLERK:  Please be seated, sir.  Please state

   5   your full name.

   6            THE WITNESS:  Frank Pressley.

   7            DEPUTY CLERK:  Please spell your last name.

   8            THE WITNESS:  P-R-E-S-S-L-E-Y.

   9            MR. BUTLER:  May I proceed, your Honor?

  10            THE COURT:  Yes, please.

  11   DIRECT EXAMINATION

  12   BY MR. BUTLER:

  13   Q.  Mr. Pressley, how old are you, sir?

  14   A.  I'm 48.

  15   Q.  How are you presently employed?

  16   A.  I work with the U.S. Department of State.

  17   Q.  How long have you worked for the State Department?

  18   A.  21 years.

  19   Q.  Where are you working for the State Department right now?

  20   A.  I'm presently assigned to our regional office in Florida.

  21   Q.  And where were you assigned before you were sent to the

  22   regional office in Florida?

  23   A.  Frankfurt, Germany, and before that, Nairobi, Kenya.

  24   Q.  And when were you in Nairobi, Kenya?

  25   A.  I arrived in Nairobi in February of 1997.



                                                                1890



   1   Q.  When did you leave Nairobi, Kenya?

   2   A.  August the 10th, 1998.

   3   Q.  Directing your attention to August 7th, 1998, do you

   4   recall that day?

   5   A.  Very well.

   6   Q.  Where were you on August 7th, 1998?

   7   A.  The morning, Friday morning, I -- I'm the information

   8   management officer.  I handle all the communication activities

   9   in the embassy -- computers, radios, televisions, telephones.

  10   I was called with a problem in the mail facility.

  11            I went to the mail facility, and the problem actually

  12   had happened or originated in the GSO section.  I left the

  13   mail room facility and went upstairs to the second -- first

  14   floor, I'm sorry, first floor, to the General Services Office.

  15            MR. BUTLER:  I would like to publish what has been

  16   previously entered into evidence as Government Exhibit 801D,

  17   as in dog.

  18            THE COURT:  801D, as in dog.

  19   Q.  Mr. Pressley, where was the General Services Office

  20   located within the embassy?

  21   A.  The GSO office is on the first floor.

  22   Q.  Is this the correct floor?

  23   A.  I don't have my glasses.

  24   Q.  Why don't you just ignore that.

  25            Why don't you just describe for the jury where it was



                                                                1891



   1   located, what side of the building it was located on.

   2   A.  Well, the GSO office is a large office.  The office I went

   3   to was the main GSO office, the supervisor GSO office, in the

   4   corner of the building, facing Moi Avenue.

   5   Q.  And where was it located in relationship to where the rear

   6   parking lot and co-op house was located?

   7   A.  Okay.  The GSO section, like I say, it swung all the way

   8   around from Moi all the way to the back.  The actual GSO

   9   office is in the back of the building in the corner, right

  10   beside procurement and across from Customs and shipping.

  11   Q.  And do you recall exactly where you were around 10:30 in

  12   the morning?

  13   A.  I went to the senior GSO office and the person,

  14   supervisor, was not there.  I was standing in front of the GSO

  15   secretary's office and I initiated a conversation with

  16   Michelle O'Connor, then GSO.

  17   Q.  Who is Michelle O'Connor?

  18   A.  Michelle O'Connor was the general services officer in that

  19   office and also a good friend of mine.  She was also my

  20   neighbor.

  21   Q.  And do you recall what you were discussing at the time?

  22   A.  Well, we had a problem with the fax system and I was

  23   discussing her procedures, her staff that were having

  24   problems, continuous problems with those procedures.

  25   Q.  What happened while you were having this conversation?



                                                                1892



   1   A.  Well, I completed the conversation and I was about to

   2   leave her general office and then she started discussing, you

   3   know, personal things like "see ya later" and "see ya

   4   tonight."  We often went out together because her children,

   5   her three girls, and mine played together.  So we were kind of

   6   talking about personal stuff.

   7            I went to the secretary's desk and I said goodbye and

   8   made a note to the senior GSO that I came by to discuss the

   9   problem, and then Lydia Sparks and Jay Bartley entered the

  10   office.

  11   Q.  Let me go back a second.  Who else was in the office when

  12   you were having this conversation with Michelle O'Connor,

  13   about how many people?

  14   A.  I believe there was five, Rookia Ali, Michelle O'Connor,

  15   Lydia Sparks entered and Jay Bartley entered, and there

  16   were -- some of them were going in and out at the same time so

  17   I don't know who those other people were at the time.

  18   Q.  Who was Jay Bartley?

  19   A.  Jay Bartley was one of the -- I think he was a college

  20   student, actually was a college student there, was the son of

  21   Jay Bartley, Sr., the consul general's son.

  22   Q.  What happened after you began to leave the procurement

  23   office -- the GSO office?  I'm sorry.

  24   A.  Well, it was interesting.  It was a Friday morning and I

  25   was surprised that Jay and Lydia were there.



                                                                1893



   1            THE COURT:  What happened, sir?

   2            THE WITNESS:  Oh, what happened?

   3            THE COURT:  What happened?

   4            THE WITNESS:  What happened was I started to leave

   5   the office and Rookia was talking to me, and I could see out

   6   the windows from where I was standing.  Where I was standing,

   7   I could see out both sides of the building, two sides of the

   8   building.  There was a glass on that side and I saw people

   9   running away.  You know, I wasn't sure why.

  10            And as I faced toward Michelle O'Connor's office, we

  11   saw the same thing -- people running away, screaming and

  12   making noise.  I really didn't know what was going on and I

  13   wasn't going to pay much attention until I heard some noise,

  14   and the noise was like firecrackers or small explosions, small

  15   fire -- you know, noises.

  16   Q.  What happened after you heard these small firecracker

  17   noises?

  18   A.  Then the screaming got louder and people were really

  19   scattering across the streets.  But I didn't think much about

  20   it.  I wanted to go down the hall and go back to my office.

  21   So I turned to go down the hall and I heard a larger

  22   explosion.  It was large like a tire exploding, a backfire on

  23   a truck or something, and that caught my attention, of course.

  24   Q.  And what happened after you heard this louder explosion?

  25   A.  Almost everyone that I saw ran to the window in the



                                                                1894



   1   procurement section, looking out the window, and I turned to

   2   Ms. O'Connor and Jay Bartley and Jay Bartley started walking

   3   down the hallway.  I said, I got to go, I don't know what this

   4   is.  I turned to my right to go down the hall, and then all of

   5   a sudden I was flying.  A loud explosion, huge impact.  It

   6   just kind of picked me up and I just went through, flying

   7   through the air.

   8   Q.  What happened after you went flying through the air?  Were

   9   you knocked unconscious?

  10   A.  I think for a few seconds I just kind of lost things.  I

  11   wasn't -- I hit the wall.  I landed on the wall and I looked

  12   up at the ceiling and I didn't really know what had hit me.  I

  13   was surprised, I mean, shocked, basically.  And then I looked

  14   up and I saw the -- I thought it was smoke.  It seemed like

  15   black burling smoke through the hallway, and I noticed that

  16   basically the ceiling was gone.

  17            And I tried to stand up.  It was difficult.  I stood

  18   up, and from that point I just couldn't believe what I saw.  I

  19   looked around.  I saw like chunks of blood or red, kind of

  20   meat on the walls.  Some of the walls were actually missing,

  21   too.  It was pretty shocking.  I mean --

  22   Q.  Did you sustain any injuries as a result of the blast?

  23   A.  Oh, yeah.  I lost part of my jaw.  I lost a large section

  24   of my shoulder.  When I stood up, I actually, after I kind of

  25   figured out where I was, I looked down and saw my bone



                                                                1895



   1   sticking up out of my shirt.

   2   Q.  And did you see Michelle O'Connor on your way out of the

   3   embassy?

   4   A.  Well, I saw, I -- first of all, I heard a lot of noise,

   5   people crying, screaming.  And I did see, I thought, Michelle

   6   O'Connor's body.  But more than that, I saw some legs, a pair

   7   of just man's legs with the pants on.  But I still didn't

   8   realize what was going on.  You know, I thought maybe that the

   9   boiler had blown up or -- I wasn't sure what had happened at

  10   that point.

  11   Q.  And were you able to get out of the embassy?

  12   A.  I started walking to the hallway and trying to focus on

  13   what had happened, not really sure what had happened.  I tried

  14   to go down the stairwell.  One of the stairwells was

  15   completely blocked, concrete door had blown off.  So I went to

  16   the other stairwell, and I started walking down the stairwell

  17   and then someone came up behind me about halfway down and

  18   started helping me down the stairwell.

  19   Q.  Did you eventually get out of the embassy?

  20   A.  I got out of the embassy.  I stood in front of the embassy

  21   after that and just watched.  I couldn't believe my eyes.

  22   Q.  Was there anyone else inside the embassy that you were

  23   looking for?

  24   A.  Well, as I stood there, I, in front of the embassy, facing

  25   towards the embassy and people were all around me, I saw my



                                                                1896



   1   wife's boss walk in front of me, Mr. Cavalier.  I asked him if

   2   he had seen my wife because my wife worked for him.  He didn't

   3   seem to know anything.  He was very nervous and crying and

   4   worried about his wife, as I was.

   5   Q.  And did your wife make it out of the embassy?

   6   A.  Yes.  She came down the steps eventually and she came over

   7   to me from behind.  I heard her voice.  People were trying to

   8   take care of me because I didn't realize that I was hurt as

   9   bad as I was.  As she came close to me, she was -- her eyes

  10   got bigger and she started crying.

  11   Q.  Do you know what happened to Michelle O'Connor and Jay

  12   Bartley?

  13   A.  Well, I know now.  At that time I knew they were hurt, but

  14   I didn't know how bad.  I know now they were killed.

  15            MR. BUTLER:  No further questions, your Honor.

  16            THE COURT:  Any cross-examination?

  17            MR. COHN:  No.

  18            MR. SCHMIDT:  No, your Honor.

  19            THE COURT:  Thank you.  You may step down.

  20            (Witness excused)

  21            THE COURT:  Government may call it's next witness.

  22            MR. BUTLER:  Government calls George Mimba, your

  23   Honor, M-I-M-B-A.

  24    GEORGE MIMBA,

  25        called as a witness by the government,



                                                                1897



   1        having been duly sworn, testified as follows:

   2            DEPUTY CLERK:  Please be seated, sir.  Please state

   3   your full name.

   4            THE WITNESS:  My name is George Mygit Mimba.

   5            DEPUTY CLERK:  Please spell your last name.

   6            THE WITNESS:  My last name is M-I-M-B-A.

   7   DIRECT EXAMINATION

   8   BY MR. BUTLER:

   9   Q.  Good morning, Mr. Mimba.

  10   A.  Good morning.

  11   Q.  How old are you, sir?

  12   A.  I'm 35 years old.

  13   Q.  Where were you born?

  14   A.  I was born there Yaza Gzmet.  Yaza is a province in

  15   Nairobi, Kenya.

  16   Q.  Have you lived in Kenya your entire life?

  17   A.  Yes, your Honor.

  18   Q.  And how are you presently employed?

  19   A.  Say again?

  20   Q.  How are you presently employed?  What is your job?

  21   A.  My job is information systems manager.

  22   Q.  And where is that?

  23   A.  That is in Nairobi.  I'm in charge of American embassies

  24   in Eastern and Central Africa, Nairobi's regional office.

  25   That covers about five embassies.



                                                                1898



   1   Q.  So you work for the American Embassy?

   2   A.  Yes, sir.

   3   Q.  And how long have you worked for the American Embassy?

   4   A.  I've worked for the embassy for a total of 11 years.  The

   5   first four years with U.S. Aid, which is also an agency of the

   6   United States.

   7   Q.  And were you working at the American Embassy on the

   8   morning of August 7th, 1998?

   9   A.  Yes, sir.

  10   Q.  Where was your office in the embassy located?

  11   A.  My office was on -- I don't know how to explain it, but

  12   when you come into the embassy it was on the first floor,

  13   first floor when you arrived when you get into the building.

  14   Q.  And how many people worked in your office?

  15   A.  We -- right now or then?

  16   Q.  Back then, on August 7?

  17   A.  Back then we had one American who was the information

  18   systems officer and three FSNs.  Including me, we were four

  19   Kenyans working on the embassy.  So we were a total of five

  20   people.

  21   Q.  What time did you arrive at the embassy, approximately, on

  22   August 7th, 1998?

  23   A.  That day I was picked up early because I was supposed to

  24   travel to attend an information systems managers conference in

  25   Nakra.  So they picked me up at around 6:30.  We arrived at



                                                                1899



   1   the embassy some minutes to 7 -- some minutes after 7, about

   2   7:15.

   3   Q.  And what did you do at the embassy that morning?

   4   A.  When I got into the embassy, I started preparing to leave,

   5   taking my money, having meetings with my staff, telling them

   6   what I need done in my absence, and stuff like that.

   7   Q.  When you say you went to get your money, where did you go

   8   to get your money?

   9   A.  The cashier was on the first floor.  In between my office

  10   and the cashier we had a telephone strong room and then the

  11   lifts.  So behind the lifts we had the cashier's office.  So

  12   that is where I went to get my money.  The first thing in the

  13   morning, immediately after the cashier had opened I took about

  14   15 minutes before I went there.  And so when I went there, I

  15   found a queue of other people in the queue, the people who

  16   wanted to cash their money for the weekend, some Americans who

  17   wanted to go on a safari, like a tour or something, and also

  18   the consular lady, the cashier who takes the money from Visa

  19   applicants also was there.

  20            So the queue was long when I went in the first time.

  21   I decided to come back to the office and finish up sending

  22   e-mails to my staff.  When I went back the second time, the

  23   queue was still long.  That's when the lady spotted me, the

  24   cashier, and shouted.  Because back in Nairobi I was the

  25   president of foreign service national, the non-Americans who



                                                                1900



   1   work at the American Embassy, so I was the president.  So when

   2   I was leaving, they knew that I will be out.  And so she saw

   3   me and just welcomed me, please come, come, come and join the

   4   queue.  You don't need to sit in the queue, come and be at the

   5   front.  I want you to be served first because your flight is

   6   at 11.  And so I did not have to wait in the queue, I just

   7   went to the front to be served first by the cashier.

   8   Q.  Do you recall about what time that was?

   9   A.  That was about 10:15, 16, 25, there, because I did not --

  10   it did not take -- it was about 10:25 because it did not take

  11   me about five or so minutes before everything went.

  12            MR. BUTLER:  Can we publish Government Exhibit 801D

  13   again, please.

  14   Q.  Mr. Mimba, could you point out for the jury where the

  15   embassy cashier's office is located on Government Exhibit

  16   801D.

  17   A.  Where is the gate to the embassy here?  I can't tell.

  18   Q.  If you look to the bottom left-hand corner of the screen

  19   and move upward, do you see where the embassy cashier's office

  20   is?

  21   A.  Now, which -- I don't know how this is --

  22   Q.  Let's ignore this.  We're having some difficulty with

  23   this.

  24            Where did the embassy cashier's office face?  Do you

  25   know?  Did it face on --



                                                                1901



   1   A.  It was facing the cooperative building side.

   2   Q.  So it was on the first floor.  Was it in the rear of the

   3   embassy?

   4   A.  Yes, in the rear of the embassy, yes.

   5   Q.  What happened after you left the embassy cashier's office?

   6   A.  After I left the embassy, I know the lady haggled me

   7   because she was really nice.  So I just said bye to the people

   8   who were in the queue.  I told them I was sorry the lady made

   9   me jump the queue.  So they were all students, they were all

  10   laughing because the lady was still joking and funny.

  11            So after leaving the queue, I was heading back to my

  12   office.  I went back to my office, put the per diem, the money

  13   I had in my briefcase, then I came out.  As I came out of my

  14   office, I met another lady.  She used to work at the personnel

  15   office, the lady Lucy Onono, and she stopped me.  Then she

  16   called me chairman.  President there is like the same as

  17   chairman.  She called me chairman.  I understand you are going

  18   to Nakra.  I said yes.  What are you going to bring me?

  19   That's what everybody was asking for, because if I go out

  20   there, it's like I'm a father, I'm supposed to bring everybody

  21   gifts and stuff like that.

  22   Q.  After you had this conversation with her, what did you do?

  23   A.  That is right in front of my office, facing the cashier,

  24   because when you are slightly in front of my office, you

  25   could -- there was a path through to the cashier's office.  So



                                                                1902



   1   you could see the people, like you go straight on and then you

   2   turn right to get to the queue.  And so I had just come from

   3   my office when I met Lucy.

   4   Q.  After you met Lucy, what did you do next?

   5   A.  After I met Lucy, I promised her, yes, I'll bring -- then

   6   she told me to bring her an African dress and I told her I

   7   would do so.

   8   Q.  Where did you go after your conversation with Lucy?  What

   9   did you do after that?

  10   A.  I went to my office then.  I received a call from the late

  11   Julian Bartley and Julian insisted that he wanted to see me

  12   off.  The previous night we had stayed with Julien until

  13   around 10:30 at night.  He was a good friend of mine.  He

  14   liked me and he used to tell me all about his background, how

  15   he was raised up, how he admires the way I work hard, and they

  16   encouraged me that I should keep on working hard, even told me

  17   how he was raised up, how he went to school.  The first day he

  18   went to high school, I think the president asked him --

  19   Q.  Mr. Mimba, let's move on to --

  20            MR. COHN:  Your Honor --

  21            Thank you.

  22   Q.  Where were you around 10:30 that morning?

  23   A.  Around 10:30 I was right in front of my office.  After

  24   talking to this lady, then I was -- I went back to my office,

  25   was trying to send an E-mail, and then I heard the first



                                                                1903



   1   explosion.  It came like a tremor.  And I don't know, somehow

   2   I thought it was something outside the embassy.  So I --

   3   somebody asked, what was that?  Then I said, I think it's a

   4   bomb, but I think it's somewhere.  There's a place called

   5   Lamaru, which is many miles from Nairobi, some miles from

   6   Nairobi.

   7   Q.  So after you heard the first explosion, what happened

   8   next?

   9   A.  Then people were rushing to the window.  Then I thought

  10   about locking my office before I could also join them.  So I

  11   was heading towards the open area, which was on the Budget

  12   section, to see what people were going to see.  And on my way

  13   there, there was a computer room, which was a sealed room.  On

  14   my way there, just reaching the corner, that's when the second

  15   deadly explosion came and --

  16   Q.  And what happened after the explosion came?

  17   A.  I didn't know where I was.  I lost -- I didn't know.  I --

  18   the house came on me because the ceiling came on me.  I was

  19   thrown down.  The house was dark.  It was dusty.  It was

  20   smoky.  Choking because the duct smoke somehow choked me, and

  21   I could not open my eyes.  I cannot see nothing.

  22            Then I went down.  I was thrown down.  Then the

  23   bodies were burying me.  Then I heard people cry and some of

  24   them were -- I could hear, I could get their voices and could

  25   know, that's so and so's voice, but I could not open my eyes.



                                                                1904



   1   I could not breathe.  I could not do nothing.  Though I

   2   prayed.  I said a prayer, about three seconds, that, Lord,

   3   just take my soul.

   4            Then I remembered, I fumbled for my I.D. because I

   5   remembered my dad and my brothers loved me so much that I

   6   would want them to see my body.  And so I was looking for a

   7   form of identification where if I'm found, they would get an

   8   I.D.  It didn't occur to me that an I.D. would burn if the

   9   house burns.

  10   Q.  Were you eventually able to get outside the embassy?

  11   A.  Yes.  I started crawling after that when I could feel like

  12   I was alive, I started crawling because I was choking.  I

  13   started moving torwards a place I could get fresh air.

  14            Then all of a sudden I felt a breeze come from a

  15   direction.  I didn't want to open my eyes.  I didn't want to

  16   breathe.  I started crawling towards that place.  I didn't

  17   know where it was.  Then after reaching that place, I realized

  18   there was a cold breeze coming from outside.  So I started

  19   moving towards that side.  It was the window that had been

  20   blown.

  21            So as I moved, and I wanted to like keep moving, I

  22   realized that I was at the edge.  Then I slept there for some

  23   time.  I was shaking.  When I opened my eyes, I saw the

  24   garden, a green garden.  I said, where am I?  As I was moving

  25   toward the window, I could feel people's -- could feel bodies



                                                                1905



   1   of the dead people.

   2   Q.  Were you able to get outside the embassy to the garden?

   3   A.  Yes.  After that, then I realized that I was looking for

   4   an I.D., I could not get it, I would like my dad to see my

   5   body, so I have to jump, to die outside.  So I looked at where

   6   I was going to jump.  It was far, and I closed my eyes because

   7   I didn't know where I was going to die.  I wanted my body to

   8   be found by my dad.  So I just closed my eyes and then jumped

   9   through the window.

  10            Then I landed on, on something, a sharp object.  I

  11   think it's the stand that was making the flowers stand upright

  12   there.  They were metallic, kind of.  So I had something cut

  13   me, my back and my knee and here.  Then I went down.  I was

  14   not conscious for some time.  When I raised my head, I

  15   realized that I did not die.

  16   Q.  What did you see when you were outside the embassy?

  17   A.  When I came down, I saw like it was not the embassy that

  18   has been bombed.  Somehow I saw so many things, like the

  19   houses.  Then I realized that I thought the world was coming

  20   to an end.  I didn't know, I didn't know where I was.

  21            Then I realized that if I sleep down there, I was

  22   going to be buried because somehow I had the feeling that this

  23   building is going to burn down.  So I jumped.  I climbed the

  24   fence again.  Then I jumped over to the pavement and I landed

  25   out at the pavement next to the parking lot.



                                                                1906



   1   Q.  What did you see in the roadway on the roundabout outside

   2   the parking lot?

   3   A.  Outside the parking lot I saw so many people.  Then as I

   4   was lying down there I could see people run, running towards

   5   my direction.  Some were coming from the other direction.

   6            Then there was this man who was running and he didn't

   7   know that his intestine was out.  His belly's been chopped off

   8   so he's trying to hold onto his intestine at the same time

   9   he's running.

  10            Then when I came down, I saw an American lady and two

  11   kids, two daughters.  She's within the fence, crying for help.

  12   Then she's crying, please help me, please help, help my kids,

  13   help.  Then I, after lying down, another object almost came on

  14   me somehow, some object was flying down.  I thought it was a

  15   helicopter that's been sent to help people.  I didn't know, it

  16   was like something that was going to bang.  I just missed me

  17   and I rolled under it.

  18   Q.  What, if anything, happened to the lady and the two

  19   children?

  20   A.  When I heard these kids cry, then I decided to run back

  21   towards the embassy.  Then I tried to pass my hand to reach

  22   the kids.  They were crying.  They didn't know me.  Their

  23   mother is also crying.  Then the mother convinced them,

  24   please, honey, go, go, go, get out of here, go.

  25            Then I, together with an American called Bob Gaudy,



                                                                1907



   1   we moved next to the fence and we were able to lift the kid.

   2   I passed my hand inside the fence.  Then we were able to lift

   3   the kid up to the sharp end and took the two daughters out.

   4            I don't know whether the lady survived.  I don't know

   5   who she was.  What I know is we were able to get the two girls

   6   out to an ambulance that was somewhere.

   7   Q.  Did you go back into the embassy after this?

   8   A.  Yes.  After this I tried to run away towards the railway

   9   station to, like go out.  As I was running, I realized there

  10   was a Kenyan bus and another school bus that was shut down

  11   where I could see everybody was dead, the driver.  Then I said

  12   wherever I go, I don't think I'm going to survive.  Let me go

  13   and save my colleagues in there who were still trapped.

  14            So I headed back to the embassy and I saw a Marine by

  15   the stair.  He had a gun and he's crying also.  He had -- I

  16   think he was in pain.  And then I tried to go and he told me,

  17   please don't come in this house, it's weak.  But I insisted.

  18   When I went back in -- then I sneaked and went back in.  Then

  19   I sneaked to the first floor.  That was where my office was,

  20   and I, I --

  21   Q.  Why don't we publish what has been previously marked as

  22   Government Exhibit 806A.

  23            Mr. Mimba, is that you in that photograph in

  24   Government Exhibit 806A?

  25   A.  Yeah.



                                                                1908



   1   Q.  And what's depicted in Government Exhibit 806A?

   2   A.  Your Honor, when I went to the first floor, the whole

   3   place was squared.  I could not open my eyes because I was

   4   still choking, but I was fumbling for any, any, something,

   5   anybody I could get.  I was moving, kneeling, I'd been

   6   crawling down and feeling the bodies.  They're all dead.

   7            Then another lady, I think -- I started calling out,

   8   is anybody out there?  Please, can you hear me?  Can anybody

   9   hear me?  Then as I was heading back, another lady called me:

  10   George, George, please help me.  I did not want to open my

  11   eyes.  I did not want to -- so I started moving towards in the

  12   direction where the sound had come from.

  13            And as I was moving, feeling the bodies, I held to

  14   something that made a move and I yelled, I said, this is the

  15   lady who called me.  I did not look at what I had held, I just

  16   held the object tightly and started pulling the body, heading

  17   back to where I had come from.  When I came down and people

  18   came down to help me, then I realized that the person I had

  19   helped was a man.  And the lady's voice kept coming back to

  20   me.

  21   Q.  Do you know who this person was that you assisted out of

  22   the building?

  23   A.  I don't know.  I don't know, sir.  It's been haunting me.

  24   I really wanted to know if he survived.

  25            MR. BUTLER:  No further questions, your Honor.



                                                                1909



   1            THE COURT:  Any cross-examination?

   2            MR. COHN:  No.

   3            THE COURT:  Thank you.  You may step down.

   4            (Witness excused)

   5            THE COURT:  Government may call its next witness.

   6            MR. BUTLER:  Government calls Samuel, NGANGA, your

   7   Honor.

   8    SAMMY NGANGA,

   9        called as a witness by the government,

  10        having been duly sworn, testified as follows:

  11            DEPUTY CLERK:  Please be seated.  Please state your

  12   full name.

  13            THE WITNESS:  Sammy Nganga.

  14            DEPUTY CLERK:  Please spell your last name.

  15            THE WITNESS:  N-G-A-N-G-A.

  16   BY THE COURT:

  17   Q.  Sir, if I could ask you to please try to keep your voice

  18   up and speak, if you could, into the microphone, okay?

  19   A.  Yes.

  20   Q.  How old are you, sir?

  21   A.  I'm about 53 years.

  22   Q.  And where were you born?

  23   A.  Born in Kenya.

  24   Q.  Have you lived in Kenya your whole life?

  25   A.  I have lived in Kenya my whole life.



                                                                1910



   1   Q.  Going back to August of 1998, how were you employed?

   2   A.  In August of 1998 I was office at Ufundi Cooperative

   3   House.

   4   Q.  If you could just maybe lean forward a little bit into the

   5   microphone and try to keep your voice up, sir.

   6            So you were in your office in Ufundi Cooperative

   7   House?

   8   A.  Yes.

   9   Q.  And what type of business were you in?

  10   A.  When I was there around 10:30, I had --

  11   Q.  Mr. Nganga, what type of business were you in?

  12   A.  About 10:30.

  13   Q.  What business?  What was your business in the Ufundi

  14   House?

  15   A.  I was doing business of governmental.  I was a

  16   governmental dealer.

  17   Q.  And where was your office located?

  18   A.  The office was located Ufundi Cooperative House.

  19   Q.  Where in the Ufundi House?

  20   A.  First floor.

  21   Q.  And where in relationship to the American Embassy was it?

  22   A.  It was just adjacent to the American Embassy.

  23   Q.  Do you recall where you were about 10:30 in the morning on

  24   August 7?

  25   A.  Yes.



                                                                1911



   1   Q.  Where were you?

   2   A.  I was in my office.

   3   Q.  And what do you recall happening around 10:30 on August

   4   7th?

   5   A.  When I was in the office I heard a loud explosion, and we

   6   were four of us in the office.  I rushed out to the balcony to

   7   see what it was, and before I could reach the balcony, another

   8   powerful explosion occurred and I found myself down in the

   9   rubble of the house.

  10   Q.  Let's go back just a moment.  You say you heard an

  11   explosion, correct?

  12   A.  Yes.

  13   Q.  And then you went out to the balcony of the Ufundi House?

  14   A.  Ufundi House.

  15   Q.  Where was that balcony located?

  16   A.  It was located on the first floor of the Ufundi House.

  17   Q.  And what did it look out onto?

  18   A.  I didn't reach the balcony which was overlooking the

  19   American Embassy, I didn't reach it.  Then another explosion

  20   occurred, powerful explosion occurred, and I was buried.

  21   Q.  And then there was the second explosion?

  22   A.  Yes.

  23   Q.  And what happened after the second explosion?

  24   A.  After the second explosion, everything became dark.  I was

  25   buried in the rubble.



                                                                1912



   1   Q.  And what happened after you were buried in the rubble?

   2   A.  After I was buried in the rubble, I heard a quick -- I

   3   went to my down to my pocket.  I had matchbooks and I wanted

   4   to see my position.  And I found myself, I had spared about

   5   four feet, four feet high and four feet wide.

   6            So I then, so I was very hot and I started doing my

   7   first aid.  I tied my legs, the bones which were already

   8   protruding from the skin.  I tied the legs and then I tied my

   9   leg, broken leg, to my right leg, which I hung up, and so I

  10   started digging for the other foot.  I was really tired and I

  11   slept.

  12            When I woke up, I, after sleeping, I dreamt having

  13   been rescued.  But when I woke up, I found myself in the same

  14   position I was in the same in the rubble.  So I just then,

  15   before I could think about anything, I started -- I heard

  16   another lady who was trapped inside.  And we started

  17   communicating with the lady who was trapped in the other

  18   building where I was.

  19            So after conversing with the lady for some time, then

  20   the rescuers, I started communicating with the rescuers who

  21   were on top.  And they kept updating the movement, how they

  22   were trying to rescue us and so that we could not worry, so

  23   they were about to rescue us.  I stayed there until I was, I

  24   stayed there until I was rescued on the 9th, on the 9th of

  25   August.



                                                                1913



   1   Q.  What day of the week was the 9th of August?

   2   A.  Saturday.

   3            (Continued on next page)

   4

   5

   6

   7

   8

   9

  10

  11

  12

  13

  14

  15

  16

  17

  18

  19

  20

  21

  22

  23

  24

  25



                                                                1914



   1   Q.  So you were under the rubble from Friday August 7 till

   2   Sunday August 9?

   3   A.  Up to the 9th.

   4   Q.  Will you publish what has been marked and admitted into

   5   evidence as Government Exhibit 806-I.

   6            Do you recognize Government Exhibit 806-I?

   7   A.  Yes.

   8   Q.  What is Government Exhibit 806-I?

   9   A.  That's rubble of the Ufundi house.

  10   Q.  Again, could you please sir, just lean forward a little

  11   bit into the microphone so everybody can hear you?

  12   A.  This is the collapse of the Ufundi cooperative house.

  13   Q.  And how were you rescued sir?

  14   A.  What?

  15   Q.  Could you please just describe for the jury how you were

  16   rescued?

  17   A.  The rescue part was a difficult one, and I had to keep on

  18   banging the walls so that the rescuers could know where I was

  19   located, and so sometimes they tell me to bang the wall, I had

  20   to bang the wall.  They tell me when they had to come around

  21   they had to cut holes and he had torch and ask me where I

  22   could see the light.  So I could not see the light.  They kept

  23   on changing positions.  Here I could see the light.  So when

  24   they asked me how long the light was I told them because about

  25   four foot from where I was, but they asked me, could I hold



                                                                1915



   1   them, I could not because my leg was already was broken.

   2            I could not walk and I was badly off.  And so they

   3   came here and then they cut another hole, this where I could

   4   see them on the top.  So though I was talking they thought

   5   where I was near and they followed me to where I was.  So they

   6   followed where I was talking.  I was very badly off, and they

   7   told me to give them my hand.

   8            So I lifted my hand and they took my hand.  Then I

   9   forgot that I already tied my leg with a, my leg was broken so

  10   I had to snatch it, and then I hit myself because I had a lot

  11   of pain, and so then they find a way of coming down to where I

  12   was.  But it was difficult because there was no space, so they

  13   had to leave so they could come and then they were cutting

  14   some holes, cutting holes through.  One of them was able to

  15   come down to where I was.

  16   Q.  Now, were you communicating with this woman that you had

  17   spoken about during this time?

  18   A.  The woman I was I came to know her as Lois, but

  19   unfortunately she was not saved.  She wanted to come out

  20   before I was rescued, but I told her I was, it was a lock on

  21   my side, so I told her I could just, they were nearer her and

  22   they could rescue her.  So I left her with a promise that they

  23   had to rescue her within two hours, maybe because I thought

  24   they could pass the same hole, but, unfortunately, they

  25   couldn't, so it was not.



                                                                1916



   1   Q.  What was her name?

   2   A.  Lois Gadignu.

   3            MR. BUTLER:  No further questions, your Honor.

   4            THE COURT:  Thank you, sir.  You may step down.

   5            (Witness excused)

   6            MR. BUTLER:  The government calls Father John Kiongo.

   7    JOHN KIONGO KARIUKI,

   8        called as a witness by the government,

   9        having been duly sworn, testified as follows:

  10   DIRECT EXAMINATION

  11   BY MR. BUTLER:

  12   Q.  Father Kiongo, if I could ask you to just keep your voice

  13   up and try to speak directly into the microphone.  You're a

  14   Catholic priest, sir?

  15   A.  Yes, sir.

  16   Q.  And where are you a priest?

  17   A.  In Nairobi diocese Kenya.

  18   Q.  Have you lived in Kenya your entire life?

  19   A.  Yes.

  20   Q.  And do you recall where you were on the morning of August

  21   7, 1998?

  22   A.  Yes.

  23   Q.  And where was that?

  24   A.  I was in the Ruta parish where I am based in Nairobi.

  25   Q.  Where did you go that morning?



                                                                1917



   1   A.  That morning I went to the American embassy in town.

   2   Q.  And why did you go to the American embassy?

   3   A.  I went to the embassy because my brother was working at

   4   the embassy and my niece wanted to go to America the following

   5   week for studies.

   6   Q.  What did your brother do at the embassy?

   7   A.  He was working at the embassy, shipping department.

   8   Q.  In the shipping department?

   9   A.  Yes.

  10   Q.  About how old was your niece at the time?

  11   A.  Beg your pardon?

  12   Q.  About how old was your niece at the time?

  13   A.  She was 23 or so.

  14   Q.  What happened when you got to the embassy?

  15   A.  When we got, when I got the embassy, my brother came for

  16   me downstairs, so we went to his office and before that we had

  17   made a collection, and I was carrying the money so I was going

  18   to take him to give him the money, so that he can be able to

  19   buy the thing necessary for paying school fees when my niece

  20   came to America.

  21   Q.  And where was your brother's office located, if you

  22   recall?

  23   A.  I think it was first floor.

  24   Q.  And do you know which side of the building it was on?

  25   A.  That was, that was on the, it was not the left side of the



                                                                1918



   1   main road.  It was on the other side behind.

   2   Q.  Do you know what you saw when you looked out from your

   3   brother's office?

   4   A.  Yes, when I looked out I saw the parking lot.

   5   Q.  The rear parking lot?

   6   A.  Yes.

   7   Q.  How many people were in your brother's office that

   8   morning?

   9   A.  My brother had a big office, but on the corner was his

  10   compartment, a small one, and so I was with him and my niece

  11   we are three, but the other bigger office there are about six

  12   people.

  13   Q.  And what happened while you were visiting with your

  14   brother and your niece that morning?

  15   A.  When we, we counted the money, it was about 400,000 Kenya

  16   shilling, and then my niece came later on because she came

  17   after me, and then we were trying to see how the bank draft,

  18   how many we are going to buy for her to come to pay for school

  19   fees.

  20            And then when we had done that, then my brother told

  21   me, I think now, Father, you can go because Theresa can do the

  22   rest.  She will take this money.  She will take this forms

  23   downstairs to the bank and then she will get the necessary

  24   things, and so that was that.

  25            I did rise up when we heard a loud bang and then we



                                                                1919



   1   stood up to look to see what happened downstairs.  So we

   2   looked, and for me it was an ordinary parking, but my brother

   3   was saying that man is shooting that, that man is shooting.

   4   What is going on there?  So I was very worried.  I wasn't

   5   happy.  I was worried.

   6            And I sat down, and I held my face like this, and I

   7   said a prayer because I knew this was the embassy, it was like

   8   the foreign country, and might be things, if things go wrong,

   9   then we don't know where we are going to end.

  10   Q.  Then what happened after that?

  11   A.  After that, there was now big thing that came, and then we

  12   all shuddered to almost to death.

  13   Q.  You say you shouted.  What happened after this explosion?

  14   A.  After the explosion everything fell down and when

  15   everything fell on me, the desk, I don't know whether the

  16   doors and I felt I was somewhere very far away, somewhere very

  17   far away, nobody could hear me even when I was shouting.

  18   Q.  And did you hear anything at the time?  Did you hear

  19   anybody speaking to you?

  20   A.  Now, it's only after sometime then I heard people come,

  21   and people saying, this one is not dead, this one is not dead,

  22   get this one, and leave those who are dead alone.

  23            So I knew from there my brother must have died, and

  24   my niece is dead.  And they took me out, and my right hand was

  25   almost off, and so it was very painful, I had to cry out,



                                                                1920



   1   because my, when my left hand was badly damaged, I could not

   2   see.  Also, I had lost sight, but I could hear a lot of

   3   crying, a lot of noise, people praying, and people crying, and

   4   so forth.

   5   Q.  And what happened to your brother and your niece?

   6   A.  They died.

   7            MR. BUTLER:  No further questions your Honor.

   8            THE COURT:  Is there cross-examination?

   9            Thank you, Father.  You may step down.

  10            MR. BUTLER:  The government calls Tobias Otieno.

  11    TOBIAS OTIENO,

  12        called as a witness by the government,

  13        having been duly sworn, testified as follows:

  14   DIRECT EXAMINATION

  15   BY MR. BUTLER:

  16   Q.  Mr. Otieno, if I could ask you to lean forward just a

  17   little bit, keep your voice up and speak directly into the

  18   microphone.

  19            How old are you, sir?

  20   A.  I am 51 years old.

  21   Q.  Where were you born?

  22   A.  When was I born?

  23   Q.  Where were you born?

  24   A.  I was born in Kenya.

  25   Q.  Have you lived in Kenya your whole life?



                                                                1921



   1   A.  Yes, sir.

   2   Q.  How are you employed?

   3   A.  I'm employed by the US embassy in the Department of

   4   Commerce as a commercial specialist.

   5   Q.  And how long have you been employed by the American

   6   embassy?

   7   A.  This is my 30th.

   8   Q.  And were you at the embassy on August 7, 1998?

   9   A.  Yes, sir, I was at the embassy on August 7, 1998.

  10   Q.  Where is your office located?

  11   A.  My office was located behind the entrance, the ground

  12   floor, that be directly behind the entrance front of the

  13   embassy.

  14   Q.  And how many people work in your office?

  15   A.  At the time of August we are about, we are eight people.

  16   Q.  Do you recall what happened on the morning of August 7,

  17   1998?

  18   A.  Yes, I can recall.  It was a Friday, and around -- I was

  19   in the office you know as usual on that day.  And at around

  20   10:30 a.m. I was on my desk together with my colleague who was

  21   also sharing the office with me, and also another friend who

  22   also was working at the embassy.  So we were about three

  23   people in the office at that time.  And about 10:30 as I was

  24   saying, we heard an explosion from behind the office and all

  25   of us were curious about the explosion.



                                                                1922



   1            We all asked what was the noise about or what was the

   2   explosion, because we wanted to know.  And it was what we

   3   thought was a tire bus, you know, some huge tire bus behind

   4   the office.  And just within seconds after that initial

   5   explosion, another big explosion erupted in the building and

   6   we, within seconds the whole lights, the whole building shook,

   7   and terrible outbreak.

   8            I thought it was the end of the world.  Really I

   9   thought it was the end of the world, and in the Christian

  10   sense I thought you know God has come to take his people,

  11   because I didn't know what it was, and --

  12   Q.  What happened to you, Mr. Otieno?

  13   A.  I was thrown back on my chair, and I landed somewhere

  14   which I didn't know, but I came to realize I came to learn

  15   later that, you know, I was still sitting on the chair, but

  16   what happened to me was that I lost my eyesight, the whole

  17   thing went dark, my head was hot, my stomach I felt was bust,

  18   and I lost, I lost all sense of relation at that time.

  19   Q.  How did you get out of the embassy?

  20   A.  After one minute or two minutes I heard the people crying

  21   within the building, and I said, here I am.  There are also

  22   people crying for help, so my only salvation is also to cry

  23   for help.  So I join the others in the cry for help.  And

  24   somebody from behind me came and said, I will help you.  So

  25   the person came and they held my right hand, because my left



                                                                1923



   1   hand was already gone, and led me towards climbing the debris.

   2            And we went, we reach a wall which he asked me to

   3   climb, and I tried to climb it with all my effort, and we were

   4   on the wall until we reached a point where he asked me to jump

   5   on the ground, and from there when I jump on the ground some

   6   people who I later learned to be military or Marines helped me

   7   into a waiting ambulance when I was taken to hospital.

   8   Q.  What injuries did you sustain as a result of the bombing?

   9   A.  I, my eyes, all my eyes were shattered by the exploding

  10   glasses, I shattered my eyes, I lost my vision, and then I

  11   lost my left hand on the wrist was severed off.  It was

  12   hanging by a thread, and I my four upper teeth, and several

  13   wounds on my face and body.

  14   Q.  And what happened to your colleagues in the commercial

  15   office?

  16   A.  Two of my colleagues died right there in the building, and

  17   one colleague who was with me also within the building at the

  18   time also suffered serious eye injuries similar to my

  19   injuries, and, you know, body wound as well.

  20            MR. BUTLER:  No further questions, your Honor.

  21            THE COURT:  Thank you.  You may step down.

  22            (Witness excused)

  23            MR. BUTLER:  The government calls Staff Sgt. Daniel

  24   Briehl.

  25    DANIEL M. BRIEHL,



                                                                1924



   1        called as a witness by the government,

   2        having been duly sworn, testified as follows:

   3   DIRECT EXAMINATION

   4   BY MR. BUTLER:

   5   Q.  Staff Sgt. Briehl, if I could just ask you to keep your

   6   voice up and lean toward the microphone when you answer so

   7   everybody can hear you.  Thank you.

   8            What branch of the service are you with, sir?

   9   A.  United States Marine Corp.

  10   Q.  How long have you been a Marine?

  11   A.  I've been in the Marine Corp for a little over six years.

  12   Q.  How old are you now?

  13   A.  I'm 30 years old.

  14   Q.  Where are you presently stationed?

  15   A.  I'm stationed in California at this time.

  16   Q.  And where were you stationed before California?

  17   A.  I was stationed as a Marine security guard in Nairobi

  18   Kenya.

  19   Q.  And how long were you in Nairobi Kenya as a Marine

  20   security guard?

  21   A.  I was there for 15 months.

  22   Q.  And what time period is that?

  23   A.  I reported there about three months before the bombing.

  24   Q.  Where were you on August 7, 1998?

  25   A.  I was in front of the embassy waiting on a Marine who just



                                                                1925



   1   entered the building.

   2   Q.  To be clear, were you on duty that day?

   3   A.  No, I was off.

   4   Q.  And who were you with?

   5   A.  I was with the Marine driver, Sgt. Aaron Russell, myself,

   6   and Jesse Alanga.

   7   Q.  What were you doing at the embassy that morning?

   8   A.  Sgt. Alanga had to cash a check at the bank and they were

   9   going to go shopping that day.

  10   Q.  And where were you situated around 10:30 in the morning?

  11   A.  We were parked in front of the embassy in the front

  12   parking lot facing the street.

  13   Q.  And what happened around 10:30 in the morning?

  14   A.  Sgt. Alanga was in the building longer then I expected him

  15   to be, and I exited the vehicle and was going to walk in the

  16   embassy and see what was taking him so long, when I heard some

  17   gun fire, went back to the vehicle, and got Sgt. Russell out

  18   of the vehicle.

  19            I thought something was happening, maybe a carjacking

  20   or a bank robbery.  But just to be safe we were going to go

  21   inside the building.  And then we heard an explosion kind of

  22   like a back fire, but a little bit louder, and then the

  23   explosion happened.

  24   Q.  After the explosion happened, what did you do?

  25   A.  We ended up diving under a vehicle in the front parking



                                                                1926



   1   lot for cover from falling debris, concrete, windows and such,

   2   and then we got up off the ground, and ran into the front

   3   steps of the building.

   4   Q.  And what did you do when you went into the building?

   5   A.  When I entered the building I could not see the Marine on

   6   post one at all.  Post one there was a lot of, it was

   7   completely dark, a lot of soot.  And I started calling his

   8   name through the drop box, which is a small box where you can

   9   slide IDs back and forth.  I was getting no response.  I look

  10   to my left and saw some people trying to get out of the

  11   counsulate section who were getting visas that day and they

  12   were trying to exit the entrance door, which is a one-way door

  13   only.

  14            Sgt. Russell then began to guide them to the correct

  15   door for them to leave the building.  None of them seemed to

  16   be badly banged up, and they got out of the building.  My next

  17   concern was seeing inside the embassy itself.

  18   Q.  Did you eventually get inside the embassy itself?

  19   A.  Yes.  We entered the embassy and did not get inside post

  20   one, as it's being locked and could not still see the Marine

  21   on post one.  I next tried to go to our reaction room where we

  22   keep our gear at and to set off a perimeter around the

  23   building.

  24            There was rubble from the floor to the ceiling behind

  25   post one in my way.  I tried climbing over this, and the pile



                                                                1927



   1   giving way, I slid down and expected to hit the floor, which I

   2   didn't.  I fell through open elevator shaft that had the door

   3   blown off of it and proceeded to fall two stories down on to

   4   my back.

   5   Q.  And what happened to you after you fell down this elevator

   6   shaft two stories?

   7   A.  At that point I told myself I needed to get up.  I didn't

   8   land on the elevator, therefore, it was probably above me.  I

   9   worried about that or secondary explosion.  I could see some

  10   light coming in from the hallway.  The doors were still closed

  11   but partly open.  I pulled myself up and pushed the doors

  12   opened, and found some people in the hallway.  Told them what

  13   had happened, and that we needed to get them out of the

  14   building and to a secure location and get them medical

  15   treatment as they needed it.

  16   Q.  And what did you do next?

  17   A.  I then climbed the steps and found Sgt. Russell again

  18   upstairs.  And I was bleeding from my arm and my hand, and I

  19   also had a pain in my back from the fall.  He told me that

  20   they were evaccing people to the hospitals and that they it

  21   under control and he thought I should go get medical

  22   attention.

  23   Q.  And did you go get medical attention at that time?

  24   A.  I went outside to where some of the doctors were, and I

  25   saw some people running that way.  I'll never forget a face of



                                                                1928



   1   a gentleman who was wearing a white shirt was totally covered

   2   in blood.  And I told myself that I could still stand, I could

   3   still do my job, and I went back up on the steps then and put

   4   a set of gear on and took post on the front steps for a while.

   5   Q.  What happened to Sgt. Alanga?

   6   A.  Sgt. Alanga was found the next day, approximately 10 in

   7   the morning, in an area of about four feet of rubble.

   8   Q.  Did he survive the bombing?

   9   A.  No, he did not.

  10            MR. BUTLER:  No further questions, your Honor.

  11            MR. COHN:  Briefly, your Honor.

  12            THE COURT:  Yes. Mr. Cohn on behalf of defendant

  13   Al-'Owhali.

  14   CROSS-EXAMINATION

  15   BY MR. COHN:

  16   Q.  Thank you your Honor.

  17            Sgt. Briehl, when you approached the embassy that day

  18   did you notice, is there something called a swing bar at the

  19   entrance?

  20   A.  Yes, there is.

  21   Q.  And did you notice something particular about the swing

  22   bar that morning as you came in?

  23   A.  It was nothing wrong with the swing bar in the front

  24   entrance.

  25   Q.  Excuse me?



                                                                1929



   1   A.  There was nothing to notice about the swing bar.

   2   Q.  Well, was the -- the swing bar is normally in a position

   3   where it has to be unlocked, is that right?

   4   A.  It's in a down position.  It has to be opened for a

   5   vehicle to enter.

   6   Q.  That's right.  And on that morning did you, do you recall

   7   that the swing bar had been removed that morning?

   8   A.  The swing bar in front of the embassy was opened for us

   9   when we drove up.  It was intact.

  10   Q.  Well, let me show you, if I may, a report 3518-2.

  11            May I approach the witness, your Honor?

  12            THE COURT:  Yes.

  13   Q.  If you'll take a look, Sgt. Briehl, at the third

  14   paragraph.  Read it to yourself.  Don't worry about the

  15   handwriting on the side.  Just read it to yourself.

  16            (Pause)

  17            After reading that, do you, does that change your

  18   recollection about what you saw that day?

  19   A.  No, it does not.  The embassy was in charge of two swing

  20   bars.  There was one in the front and one in the rear.  This

  21   swing bar that I'm mentioning in the statement belonged to the

  22   cooperative bank as it says, and so there was three swing bars

  23   in the immediate area of the embassy.  This one was towards

  24   the rear of the building.

  25            MR. COHN:  All right.  Thank you.  I have nothing



                                                                1930



   1   further.

   2            THE COURT:  Thank you.  You may step down.

   3            (Witness excused)

   4            MR. BUTLER:  Your Honor, I believe the next witness

   5   needs a Swahili interpreter.  I would ask the interpreter to

   6   come forward.  The government calls Pinanah Muhoho.

   7    PININAH MUHOHO,

   8        called as a witness by the government,

   9        having been duly sworn, testified through

  10        the interpreter as follows:.

  11   DIRECT EXAMINATION

  12   BY MR. BUTLER:

  13   Q.  Ma'am, where were you born?

  14   A.  West side.

  15   Q.  Is that in Kenya?

  16   A.  Yes.

  17   Q.  Have you lived in Kenya your entire life?

  18   A.  Yes.

  19   Q.  Do you recall where you were on the morning of August 7,

  20   1998?

  21   A.  Yes.

  22   Q.  Where were you?

  23   A.  Ugi.

  24   Q.  Do you recall where you were about 10:30 in the morning on

  25   August 7, 1998?



                                                                1931



   1   A.  Yes.

   2   Q.  Where was that?

   3   A.  I was coming from Ugi and I was coming through, from Ugi

   4   went to the road call Haile Selassie.  And we, I reached this

   5   the bus station and the bus stopped there.  We stopped there

   6   at the bus station and there is a truck came by, there is a

   7   car came passing out, stopped near to us.

   8   Q.  What type of vehicle were you in?

   9   A.  It was a bus.

  10   Q.  And you were located on Haile Selassie Avenue?

  11   A.  Yes.

  12   Q.  And where were you in relationship to the American

  13   embassy?

  14   A.  I was in the bus stop near to the American embassy.

  15   Q.  And what did you see at that time?

  16   A.  It was a jam of so many cars and behind us was a pickup.

  17   Q.  And what did the pickup do?

  18   A.  The pickup came and it came up to the stairs, one stairs

  19   where they were standing near the embassy of the American

  20   embassy.  When it went up to the stairs, the pickup went up

  21   one of the stairs and we are there standing, was which at the

  22   bus station and they heard this paw.

  23            And I some people start running and some people start

  24   laying down on the floor.  And the person I was sitting near

  25   to me asked me, do you know what is that?  Is a bomb.  And the



                                                                1932



   1   person who was in the car came out from the pickup, came out

   2   and stand on top of the, at the door.  He open the door and he

   3   stand on top there.  And they took out something long like

   4   this size (indicating).  And he was targeting like the upper,

   5   the upper floor of the house.

   6   Q.  And then did you hear a second explosion?

   7   A.  After he stood up over there and he did with two hands and

   8   a lot of noise came out, pop pop.  And then he walk up to the

   9   main door again to the stairs and again he did paw paw, and it

  10   came out like a thunder storm.

  11   Q.  What happened to you after this thunder storm that you

  12   heard?

  13   A.  And after that we was coming, we was running out of the

  14   bus, and all of us was fall down.  And after that I heard one

  15   of the kids crying, help me, help me.  And the other woman was

  16   saying, help me.

  17            And then I touch my mouth and I found that I don't

  18   have no teeth in my mouth.  And I asked for help and pray.

  19   And one person came and pulled her by hand, and then I heard

  20   other people crying.  And they tried, they pull us to the end

  21   of the car and there was another person.

  22   Q.  And Ms. Muhoho, did you lose your eyesight as a result of

  23   the injuries that you suffered in the blast?

  24   A.  In the time they was taking us and another woman to the

  25   hospital that I realize I lost even my eyes.



                                                                1933



   1            MR. BUTLER:  No further questions, your Honor.

   2            THE COURT:  Thank you.  You may step down.

   3            (Witness excused)

   4            MR. BUTLER:  The government calls Elijah Mutie Mue.

   5    ELIJAH MUTIE MUE,

   6        called as a witness by the government,

   7        having been duly sworn, testified as follows:

   8   Q.  How old are you, sir?

   9   A.  I'm now 37 years.

  10   Q.  Where were you born?

  11   A.  I was born in the Katri district, that's in Kenya.

  12   Q.  Have you lived in Kenya your entire life?

  13   A.  Yeah, I have been there my whole life.

  14   Q.  And where are you presently employed?

  15   A.  I'm presently employed by Kenya secretarial consultants.

  16   Q.  And how long have you had that job?

  17   A.  What?

  18   Q.  How long have you been employed at the present position?

  19   A.  It should be now around from 1994, around, about eight

  20   years now.

  21   Q.  If I could just ask you to keep your voice up and try to

  22   lean forward a little into the microphone.  Thank you.

  23            In August, 1998 where was your office located?

  24   A.  Our office was located in a building call the NHC,

  25   National Housing Corporation on the first floor.



                                                                1934



   1   Q.  Where was that in relation to the American embassy?

   2   A.  It was about a hundred meters from there, from their

   3   building.

   4   Q.  If we could publish what's been previously admitted into

   5   evidence as Government Exhibit 805-A.

   6            Look at Government Exhibit 805-A.  Do you see your

   7   office building there?

   8   A.  Yes.

   9   Q.  Where is it located?

  10   A.  There (pointing).

  11   Q.  If you could just describe it for the jury?  Is it looking

  12   to the bottom of the exhibit there you see a row of buildings

  13   with a sort of bluish roof?

  14   A.  Yes.

  15   Q.  Is it located in that row of buildings there at the bottom

  16   of the screen?

  17   A.  Yes, cooperative is a tall building next to it.

  18   Q.  So it's the tall building directly behind the cooperative

  19   house?

  20   A.  Yes, yes.

  21   Q.  Where were you on the morning of August 7, 1998, Mr. Mue?

  22   A.  That morning at around 10 I was in my office which is in

  23   the first floor of that building.

  24   Q.  And what happened on the morning of August 7, 1998?

  25   A.  As I was sitting there I heard some, my office is next to



                                                                1935



   1   a window, is facing the embassy, so I heard something like gun

   2   shots, and I stood from my chair, I looked out the window,

   3   because I just sitting in the window:

   4            Then all of a sudden, you know, I heard a very big

   5   blast, I mean blast, which, you know, after that was really

   6   very difficult to say what happened.

   7   Q.  And what happened after you heard this blast?

   8   A.  Well, the blast was so big that, you know, I was standing

   9   behind the window, has a window pane that's metal dividing the

  10   window, and, in fact, that is the one that saved me, because

  11   the glass which came from the window, after the blast that

  12   window fell, hit me in my chest, and the glass and cut me, you

  13   know, to pieces in my face.  I fell down and I lost

  14   consciousness for about ten, 15 minutes.

  15   Q.  And what injuries did you receive as a result of the

  16   bombing?

  17   A.  I had several lacerations on my face here (indicating).  I

  18   almost lost this eye.  A big one here (indicating).  And I

  19   also had three ribs broken, because of being hit by that

  20   window pane.

  21   Q.  And could you describe briefly the damage that your office

  22   in this building sustained?

  23   A.  It was completely damaged because the partitions in the

  24   office they all came down.  The walls which were of course

  25   wood partitions in the office, they came down.



                                                                1936



   1   Q.  And what kinds of businesses were located in your

   2   building?

   3   A.  Recruitment bureau, but are also training computer, so you

   4   had some computer its there.

   5            MR. BUTLER:  No further questions, your Honor.

   6            THE COURT:  Thank you.  You may step down.

   7            (Witness excused)

   8            THE COURT:  The government may call the next witness.

   9            MR. BUTLER:  The government calls Moses Kinyua.

  10    MOSES KINYUA,

  11        called as a witness by the government,

  12        having been duly sworn, testified as follows:

  13   DIRECT EXAMINATION

  14   BY MR. BUTLER:

  15   Q.  Good morning, sir.  I ask you to please do what you're

  16   doing, which is to try to keep your voice up and speak

  17   directly into the microphone.  Thank you.  How old are you,

  18   sir?

  19   A.  I'm 40.

  20   Q.  Where were you born?

  21   A.  Used to work with the US embassy.

  22   Q.  I'm sorry.  Where were you born?  What country were you

  23   born in?

  24   A.  I'm a Kenyan.

  25   Q.  And have you lived in Kenya your whole life?



                                                                1937



   1   A.  Sure.

   2   Q.  And you mentioned you are presently employed at the

   3   American embassy?

   4   A.  Yeah.

   5   Q.  How long have you been working at the American embassy in

   6   Nairobi?

   7   A.  For the last eight years.

   8   Q.  And on August 7, 1998 what job did you hold at the

   9   American embassy?

  10   A.  I was holding a driver clerk job.

  11   Q.  Why don't you explain briefly to the jury what you did for

  12   the embassy?

  13   A.  I was working with the Department of Agriculture, and we

  14   used to go out for reports for trade and so on.

  15   Q.  Do you recall where you were on the morning of August 7,

  16   1998?

  17   A.  I was at the embassy building.

  18   Q.  And what were you doing at the embassy building?

  19   A.  I was preparing for a trip to out of the town, up country

  20   where we were going for a report.

  21   Q.  What happened on the morning of August 7, 1998?

  22   A.  During the preparation I was working in the second floor,

  23   where the office was, and the vehicle was parked at the rear

  24   gate of the embassy, so I was packing the vehicle and wrap ups

  25   in the vehicle for the travel, and I was traveling down up and



                                                                1938



   1   down from the office and to the vehicle.

   2            On my way to the vehicle on my way back to the office

   3   that's when the, this bombing happened, so I was on the

   4   stairs.  So I can't say much about whatever happened beyond

   5   that because I lost consciousness.

   6   Q.  You said you didn't see anything at around the time of the

   7   bombing?  You were in the interior stairwell, correct?

   8   A.  Yes.

   9   Q.  And what happened to you after the bomb went off?

  10   A.  From the vehicle where I was the rear gate there is a

  11   barrier, and another gate, and now the vehicle, my vehicle was

  12   on the inner side, so --

  13   Q.  Let me just see if I can get you focused on the question.

  14            You were at the interior stairwell.  What happened to

  15   you, sir, as a result of the bombing?  What happened after the

  16   bomb went off?

  17   A.  After the bombing I was hit and the head was blown open.

  18   Half of it was got lost, the forehead and the ear, the eye,

  19   and the rest of the part was crushed.  So I lost consciousness

  20   after that.  So the construction was done later with the

  21   plastic.  So I can't say much about anything more, because I

  22   lost consciousness.

  23            MR. BUTLER:  No further questions, your Honor.

  24            THE COURT:  Thank you.  You may step down.  We'll

  25   take a recess.



                                                                1939



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                                                                1940



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                                                                1948



   1            (In open court)

   2            THE COURT:  Let's bring in the jury and the next

   3   witness.

   4            (Pause)

   5            THE COURT:  While we're waiting, with respect to the

   6   sketching of the faces of witnesses, the government is, in

   7   advance of each day, going to give the marshals a list of

   8   witnesses whose facial features are not to be sketched, and

   9   the marshals will enforce that.  Obviously that is a list that

  10   somebody from CNN can also look at.

  11            (Jury present)

  12            THE COURT:  Government may call its next witness.

  13            MR. BUTLER:  Your Honor, the government calls

  14   Caroline Gicharu.

  15    CAROLINE  GICHURU,

  16        called as a witness by the government,

  17        having been duly sworn, testified as follows:

  18            DEPUTY CLERK:  Please be seated.  Please state your

  19   full name.

  20            THE WITNESS:  Caroline Gichuru,

  21            DEPUTY CLERK:  Please spell your last name.

  22            THE WITNESS:  G-I-C-H-U-R-U.

  23            DEPUTY CLERK:  U-R-U?

  24            THE WITNESS:  Yes.

  25            DEPUTY CLERK:  Thank you.



                                                                1949



   1   DIRECT EXAMINATION

   2   BY MR. BUTLER:

   3   Q.  Ms. Gichuru, where are you from?

   4   A.  I'm from Kenya.

   5   Q.  Have you lived in Kenya your whole life?

   6   A.  I was born and raised in Kenya, but I have been in the

   7   U.S. on several occasions for treatment and training.

   8   Q.  How are you presently employed?

   9   A.  I'm employed at the American Embassy in Nairobi as a human

  10   resources clerk.

  11   Q.  How long have you been employed with the American Embassy?

  12   A.  It will be five years May of this year.

  13   Q.  What was your position on August 7th, 1998, what was your

  14   job?

  15   A.  I was a secretary to the personnel office at that time.

  16   Q.  Where was the personnel office located?

  17   A.  It was on the second floor of the embassy, which faced the

  18   cooperative building.

  19   Q.  And how many people worked in the personnel office?

  20   A.  We were seven, but at that particular time, day, we were

  21   six because the personnel officer was not in.

  22   Q.  Were you in the office on the morning of August 7th, 1998?

  23   A.  Yes.  That time I was at my desk.

  24   Q.  Could you please tell us what you remember about that

  25   morning.



                                                                1950



   1   A.  Yes.  I had a friend who had a birthday on that Saturday,

   2   and also my colleague, her name is Lucy Onono, they had a

   3   wedding anniversary that weekend.  So we had agreed that that

   4   day we would go out and buy some cards, and at that time I was

   5   on the phone calling her to find out what time she wanted us

   6   to go to the bookstore and get the card.

   7            My other colleagues were behind me.  They were

   8   working on the Xerox machine, which was not working.  There

   9   were three of them.  And while I was on the phone, I heard a

  10   loud noise outside, but I didn't wake up to go and find out

  11   what was happening because at that particular time there were

  12   teacher strikes and the offices were housed at the cooperative

  13   building.  So I didn't stand to go.  And after a while, I

  14   don't know how long, I just felt like I was lifted and thrown

  15   somewhere.  And everything went dead.

  16            I was out, but I don't know for how long, and when I

  17   woke up I could hear a lot of voices.  I could hear sirens

  18   from outside and I could smell dust and I could feel blood all

  19   over me.  And I remember that we were many in my office, so I

  20   was looking around to see where my colleagues were.  And at

  21   that time I saw one of my colleague's legs hanging up in the

  22   air and that time I started feeling myself, I could feel blood

  23   on my face.  I looked at my hand and I could see right through

  24   to the bone and that's when I started screaming for help.

  25            I tried standing, but I can't.  There was something




                                                                1951



   1   heavy lying on my feet so I could not stand.  But after I

   2   shouted, the regional security officer by that time came and

   3   he helped me out of the building.

   4   Q.  What happened to your colleagues in the personnel office?

   5   A.  They all died in the bombing that day.

   6            MR. BUTLER:  No further questions, your Honor.

   7            MR. COHN:  No questions, your Honor.

   8            THE COURT:  Thank you, ma'am.  You may step down.

   9            (Witness excused)

  10            MR. BUTLER:  Government calls Caroline Ngugi,

  11   N-G-U-G-I.

  12    CAROLINE NGUGI,

  13        called as a witness by the government,

  14        having been duly sworn, testified as follows:

  15            DEPUTY CLERK:  Please be seated.  Please state your

  16   full name.

  17            THE WITNESS:  Caroline Gnugi.

  18            DEPUTY CLERK:  Please spell your last name.

  19            THE WITNESS:  N-G-U-G-I.

  20   DIRECT EXAMINATION

  21   BY MR. BUTLER:

  22   Q.  Where were you born, Ms. Ngugi?  Where were you born?

  23   A.  I was born in Nairobi.

  24   Q.  Have you lived in Kenya, have you lived there in Nairobi

  25   your whole life?



                                                                1952



   1   A.  Yes.

   2   Q.  Where are you presently employed?

   3   A.  I'm employed in U.S. embassy, the U.S. Department of

   4   Agriculture.

   5   A.  In the foreign office, that's the residency of the United

   6   States Department of Agriculture.

   7   Q.  How long have you been employed at the embassy?

   8   A.  This is my third year.

   9   Q.  And were you employed at the embassy on August 7th, 1998?

  10   A.  Yes.  By that time I was only five months old in

  11   employment.

  12   Q.  And were you working for the Department of Agriculture

  13   office at that time?

  14   A.  Yes.

  15   Q.  Where was your office located?

  16   A.  It was on the second floor, second floor, at the corner.

  17   The end of the corridor office, second floor.

  18   Q.  Where did it look out to?

  19   A.  It faced the cooperative and the Ufundi Building.

  20   Q.  How many people worked in the agricultural office with

  21   you?

  22   A.  It's was an office of five people.  The agricultural

  23   attache, the driver, the secretary and two agricultural

  24   specialists.

  25   Q.  Were you in your office on the morning of August 7th,



                                                                1953



   1   1998?

   2   A.  Yes.

   3   Q.  Could you please tell us what happened on the morning of

   4   August 7, 1998?

   5   A.  Okay.  Like any other office, they were all there and

   6   ready to start off our day.  I used to go to college in the

   7   Ufundi House, but that morning for a strange reason I decided

   8   not to go.

   9            My other colleague we used to share the office with,

  10   my colleague, Evans Onsongo, was killed in the blast, and

  11   during that morning he came in around 9.  He came in late for

  12   work.  We normally report at 7, 7:30.  He used to report at

  13   7:30 at that time but he came in at 9.  The agricultural

  14   attache was not there.  He was on home leave.  He was in the

  15   U.S.  And it was only me in the office and the secretary and

  16   now our driver had also called in late.

  17            And around just before 10:30, we heard a loud bang.

  18   Evans was there, I was sharing the office with him, he was

  19   seated cross to the window.  I was, I used to sit cross to the

  20   door and the window was next to the, or near the cooperative

  21   building.  So we heard a loud bang and he shrugged his

  22   shoulders and asked me, Carol, what's that?  And I was like,

  23   in Kenya the teachers were on strike and I told him, oh, those

  24   must be teachers bombing the co-op house.

  25            I stood up from my seat, he stood up and faced the



                                                                1954



   1   building, and I went and leaned on him like a small baby, I

   2   don't know why I did that, and from there I was -- I think we

   3   were just knocked off.  And I was unconscious for quite some

   4   time.  Then after some time I woke up and I couldn't see.

   5   Part of my head was all shattered with glass and I was hot on

   6   my left arm and my face was all shattered by glass.  And I was

   7   just breathing and the whole place was just open, it was like

   8   an open.

   9            I started walking towards the square.  I could see

  10   light and I could see his legs standing on top of the desk.

  11   Me, I was under the desk, and I was desparate to, oh, God,

  12   just save my soul.  I woke up, and as I got towards the right

  13   I grabbed on the window sill, the window from which you could

  14   see outside, and just by God's luck that I didn't fall.  And

  15   it attracted a lot of attention from the crowd, and everybody

  16   was like, don't jump, don't jump, because I could have fallen,

  17   I could have just gotten down and died there.

  18            And as I attracted a lot of attention, Marines from

  19   somewhere stated, and just two guys came over, I remember it

  20   was an American, and he carried -- he told me just come over.

  21   And they carried me.  There were two guys, they carried me

  22   down and I was taken to the hospital.

  23   Q.  And the man who stood in front of you at the window, do

  24   you know what happened to him?

  25   A.  Yeah.  He was killed in the blast.



                                                                1955



   1            MR. BUTLER:  No further questions, your Honor.

   2            MR. COHN:  No questions, your Honor.

   3            THE COURT:  Thank you.  You may step down.

   4            (Witness excused)

   5            MR. BUTLER:  Government calls Dr. Gretchen McCoy,

   6   your Honor.

   7    DR. GRETCHEN McCOY,

   8        called as a witness by the government,

   9        having been duly sworn, testified as follows:

  10            DEPUTY CLERK:  Please be seated.  Please state and

  11   spell your last name.

  12            THE WITNESS:  Gretchen Anne McCoy, M-c-C-O-Y.

  13   DIRECT EXAMINATION

  14   BY MR. BUTLER:

  15   Q.  You're a medical doctor?

  16   A.  Yes.

  17   Q.  When did you graduate from medical school?

  18   A.  I graduated from medical school in 1973.  Sorry, 1976.

  19   Q.  How are you presently employed?

  20   A.  I'm employed as a regional medical officer for the

  21   Department of State.

  22   Q.  How long have you worked for the State Department?

  23   A.  Eight years.

  24   Q.  Where did you work in August of 1998?

  25   A.  I was working at the American Embassy in Nairobi, Kenya.



                                                                1956



   1   Q.  How long had you been at the American Embassy in Nairobi?

   2   A.  One year.

   3   Q.  What was your position with the embassy in Nairobi?

   4   A.  I was the regional medical officer there.

   5   Q.  What were your duties and responsibilities as the regional

   6   medical officer?

   7   A.  About 40 percent of the time I was at the mission in

   8   Nairobi and I provided care to the staff, the American staff

   9   there, and also provided assistance for any injuries of

  10   Kenyans related to their work.  The other 60 percent of the

  11   time I did administrative work, and that included traveling to

  12   eight other countries and providing medical care and

  13   supervising medical care for those areas.

  14   Q.  Where was your office located?

  15   A.  My office was located on, in the first sub-basement, the

  16   level of the parking lot.  Our offices were located on the

  17   side of the building adjacent to the Aga Khan walkway.  My

  18   office was on the back side of the building, and the medical

  19   offices extended forward toward the front of the building.

  20   Q.  Were you in your office on the morning of August 7, 1998?

  21   A.  Yes, I was.

  22   Q.  Who else was in the office with you at that time?

  23   A.  We had two other RNs that were in the office at the time

  24   and a nurse practitioner that we were all co-located there.

  25   We also had two small children and their mother who were in



                                                                1957



   1   the office at the time.

   2   Q.  They were there for a visit?

   3   A.  Right.

   4   Q.  Could you tell the jury what you recall that happened on

   5   the morning of August 7, 1998?

   6   A.  I was in my office on the telephone at the time and heard

   7   just a very small, what turned out to be an explosion, a pop,

   8   and about ten seconds later there was a huge explosion.  The

   9   whole building just vibrated.  The lights immediately went out

  10   and it was very quiet.

  11            We, the staff, the nursing staff that was there, we

  12   all yelled to make sure everybody was okay.  Fortunately,

  13   everybody was.  We had one emergency light in one of the exam

  14   rooms, otherwise the entire area was pitch dark.  We sort of

  15   gathered ourselves together.  One of the nurses grabbed our

  16   emergency treatment bag and we went out into the waiting area,

  17   and the furniture there was all disheveled.  We basically

  18   crawled over that furniture.

  19            The nurses went first.  I grabbed the hand of Joanne

  20   Husky, who was the mother that was there, and she had her two

  21   children, and we attempted to exit.  The nurses went up the

  22   front stairway and I took the Huskys on out through a door

  23   that was approximately 15 feet farther on down that exited

  24   into the parking lot area.

  25            The door was ajar.  We managed to get that open and I



                                                                1958



   1   could see that there was a pathway, a clear pathway that they

   2   could get up the ramp area.  They walked on up the ramp and I

   3   went back in to make sure that everybody else was out of that

   4   section of the building.

   5   Q.  What did you do after that?

   6   A.  Well, I went back in.  There were some offices adjacent to

   7   our offices and that were responsible for repairing

   8   telephones, and there was one person in there.  He was fine.

   9   Got him out.  And as I was exiting through the parking lot

  10   door again, there was a person on the floor or on the ground

  11   that we had missed when we walked out.  When we first exited

  12   building, there was a lot of smoke and it was very difficult

  13   to see and it was very difficult to breathe, and as I said, we

  14   totally missed this one person, we literally tripped over.

  15            At any rate, I found her on the way out the second

  16   time and basically picked her up and sort of half dragged her

  17   out.  I was afraid -- there was still a lot of smoke, I was

  18   afraid that there was going to be a fire, and drug her out up

  19   the ramp area.  And the chief security officer, Paul Peterson,

  20   met me and he took Carol and carried her on out to the front

  21   of the building.

  22            I went around to the front where the nurses were.  We

  23   had sort of planned to set up what's called a triage area in

  24   the front parking lot.  Basically that's an area that you hope

  25   to have all the injured kind of go through that area, where we



                                                                1959



   1   kind of collect them and get them transported to the hospital

   2   and basic first aid applied.

   3            Unfortunately, it quickly became evident that people

   4   weren't coming that way.  I mean, the back of the embassy was

   5   basically wide open.  People were being taken out, put into

   6   vehicles from the back side of the mission, so we were

   7   basically losing a lot of patients that way.

   8            At the same time, there were some additional medical

   9   staff from some of the other embassies that had arrived, so

  10   the nurse practitioner and I went back into the building and

  11   our two nurses stayed there.  One of them subsequently took

  12   patients to the hospital, Barbara Mooley.

  13   Q.  What did you do when you went back inside the building?

  14   A.  I basically tried to just start going through the areas

  15   that I could get to.  I went back to the back side of the

  16   building, went into the basement, and there were three Kenyans

  17   that were unconscious in the garage area.  There were some

  18   bystanders there.  We managed to find some pieces of metal

  19   roofing that we put these people on and got them out and

  20   transported to the hospital.

  21            Also, there was an American there by the name of Gary

  22   Spears who had fractured his upper arm and had some shrapnel

  23   injuries to the abdominal wall.  We got them taken care of,

  24   and then I went back into the building and went to the first

  25   floor and there were two Americans that were in the GSO area,



                                                                1960



   1   O'Connor, Michelle O'Connor and Jay Bartley, and Michelle was

   2   basically decapitated from the jaw up and Jay Bartley was in

   3   the doorway and his legs were basically thrown over his

   4   shoulders.  They were clearly dead.  There was nothing more

   5   that could be done for them.  And continued through the

   6   building.

   7            A lot of areas I couldn't get into because it was

   8   very dark and there was debris many feet deep, so just started

   9   going through the floors.  I think it was on the third or

  10   fourth floor that Carolyn Reilly, we found her.  She was an

  11   American that was complaining of a lot of shortness of breath

  12   and chest pain.  We managed to find a piece of the door to get

  13   her on and get her transported downstairs.

  14            It was very, very difficult to get her down the

  15   stairs.  There were a lot of people that were on that, there

  16   was a lot of debris, a lot of people that didn't belong in the

  17   embassy that were coming in.  So there was a lot of

  18   competition for the stairs.

  19   Q.  Did you eventually get out of the embassy?

  20   A.  Yes.  After I kind of went through it again, it was clear

  21   that, you know, we weren't coming across anybody else that we

  22   could help there that was immediately evident, so I went on to

  23   Nairobi Hospital to try and locate people that were injured

  24   there and make sure that they were getting proper attention.

  25   Q.  Could you just briefly describe what you encountered at



                                                                1961



   1   Nairobi Hospital?

   2   A.  Well, as you can imagine, with the number of people that

   3   were injured and killed, it was utter chaos.  There were a lot

   4   of people milling around in the front of the hospital.  When I

   5   entered into the hospital, again, the waiting area was just

   6   jammed.  There were people on the floor, a few people on

   7   stretchers for the stretchers that they had, and basically

   8   just started going through these mobs of people looking for

   9   injured that we could recognize.

  10            MR. BUTLER:  No further questions, your Honor.

  11            MR. COHN:  No questions, your Honor.

  12            THE COURT:  Thank you, Doctor.  You may step down.

  13            (Witness excused)

  14            MR. BUTLER:  Your Honor, at this time the government

  15   would like to read a stipulation.

  16            THE COURT:  Stipulation, yes.

  17            MR. BUTLER:  "It is hereby stipulated and agreed by

  18   and between the United States of America, by Mary Jo White,

  19   the United States Attorney for the Southern District of New

  20   York, Patrick J. Fitzgerald, Kenneth M. Karas and Paul W.

  21   Butler, of counsel, and defendants, by and with the consent of

  22   their attorneys, as follows:

  23            "1.  If called as a witness, A.O. Kirase Olombe would

  24   testify as follows:

  25            A.  He is a medical doctor who graduated from the



                                                                1962



   1   University of Nairobi with a Bachelor of Medicine and Surgery

   2   degree in 1998 and a Postgraduate Master of Medical Pathology

   3   and Microbiology in 1993.  In 1993, Dr. Olumbe joined the

   4   staff of the nairobi City Mortuary.  In 1995, Dr. Olumbe was

   5   sponsored by the World Health Organization to attend the

   6   Victoria Institute of Forensic Medicine at Monash University

   7   in Melbourne, Australia.  Since 1996, Dr. Olumbe has been the

   8   Chief Government Pathologist at the Kenyan Ministry of Health.

   9   Dr. Olumbe performs autopsies on corpses to determine the

  10   cause of death.  In his experience as a medical examiner,

  11   Dr. Olumbe has examined persons who are killed by explosive

  12   devices.

  13            "B.  Between August 7 and August 14, 1998, Dr. Olumbe

  14   was asked to perform or supervise autopsies on 200 individuals

  15   at the Nairobi City Mortuary.  In summary, all of the persons

  16   listed below were determined to have been killed by injures

  17   resulting from a bombing.

  18            "C.  The bodies examined by Dr. Olumbe were

  19   identified by family members as the following individuals:

  20            Bonita Achola, age 22, female; Samson Oduor Ahomo,

  21   age 31; male; Margaret Akinyi, age 33, female; Emma Adhiambo

  22   Anulo, age 18, female; Elizabeth Anyango, age unavailable,

  23   gender, female; Monicah Apondi, age 39, female; Rosetta Ivayo

  24   Barasa, age 54, female; Chrispine Bonyo, age 42, male; Daniel

  25   Kiprono Cheruiyot, age 28, male; Jean Rose Dalizu, age 60,



                                                                1963



   1   male; Eva Nyanjau Gacheru, age 22, female; Alice Nduta

   2   Gachiri, age 46, female; Jane Wangui Gakuru, age 31, female;

   3   Ralph Johnstone Gathumbi, age 53, male; Justus Njeru Geoffrey,

   4   age 34, male; Agnes Wanjiku Gitau, age unavailable, female;

   5   Lawrence Amrose Gitau, age 48, male; Bernard Mugambi Gitunga,

   6   age 25, male; Susan Wairimu Gitu, age 36, female; Rosemary

   7   Njeri Gituma, age unavailable, female; Hassan Hukay Guracha,

   8   age 37, male; Burhan Aden Hanshi, age 21, male; Hindu Omar

   9   Iddi, age unavailable, female; Tony Kihato Irungu, age 35,

  10   male; George Irungu, age 62, male; Jane Wangari Itutia, age

  11   unavailable, female; Dorine Aluoch Jow, age 30, female;

  12   Gilbert Mugo Kahindi, age 41, male; John Karoki Kahuthu, age

  13   59, Female; Geoffrey Mulu Kalio, age unavailable, male; Joel

  14   Gitumbo Kamau, age 60, male; Franci Kihara Kamiti, age 27,

  15   male; Lawrence Gitau Kamuti, age 31, male; Margaret Wanjiru

  16   Kangi, age 21, female; Rachel Wambui Karaba, age 25, female;

  17   Charles Mugo Karanja, age 30, male; Lucy Nyamira Karigi, age

  18   53, female; Beatrice Nyambura Kariuki, age 35, female; Moses

  19   Kariuki, age 35, male; Kristine Anne Wairimu Karumba, age 43,

  20   female; Thomas Mudanyi Khahenzi, age 44, male; Francis Kiiru

  21   Kibathi, age 38, male; Jackline Nyawira Kibera, age 18,

  22   female; Rael Biiri Kimami, age 33, female; Felistas Njeri

  23   Kimani, age unavailable, female; Stephen Manina Kimani, age

  24   33, male; Joseph Kamau Kiongo, age 55, male; Teresa Wairimu

  25   Kiongo, age 20, female; David Ndura Koimburi, age 38, male;



                                                                1964



   1   Naftali Mwangi Kuria, age 32, male; Juliana Mbuli Kwali, age

   2   40, female; Peter Mbithi Kyalo, age unavailable, male; Moses

   3   Muli Kyule, age 40, male; Tirus Muraguri Macharia, age

   4   unavailable, male; Dennis Evans Radcliffe Madegwa, age 47,

   5   male; Francis Watoro Maina, age 34, male; Linda Ndindi Jackson

   6   Maingi, age unavailable, female; Fred Yafes Maloba, age

   7   unavailable, male; Cecelia Mamboleo, age 36, female; James

   8   Otieno Masea, age 33, male; Anne Nyambura Mathenge, age

   9   unavailable, female; James Migwi Mathenge, age 53, male; Pity

  10   Mwihaki Mathenge, age 35, female; Simon Peter Ngumo Matu, age

  11   30, male; Daniel Mutinda Maundu, age 44, male; June Mary

  12   Maweu, age 58, female; Lydia Mukiri Mayaka, age 41, female;

  13   Allan Sabato Mbandu, age 20, male; Doreen N. Mbayaki, age 22,

  14   female; Pamela Mboya, age 29, female; Rachael Kebendi Mboya,

  15   age 30, female; Francis Ndungu Mbugua, age 51, male; Lucy

  16   Waruthi Mbunja, age unavailable, female; Stephen Waweru Mburu,

  17   age 29, male; Catherine Mukeithi Mibere, age 38, female;

  18   Elizabeth Anyango Mito, age 37, female; Ahmed Warku Mohammed,

  19   age 27, male; Edward Mokaya, age 35, male; Lucian Mugambi, age

  20   unavailable, male; Sharon Wangechi Mugo, age 19, female;

  21   Josephat Mutua Muia, age 22, female; Emmanuel Mujyambere, age

  22   40, male; Samuel Vondo Mulalya, age 28, male; Francis Mukenye

  23   Mulehi, age 25, male; Edward Mwea Mungai, age 26, male; John

  24   Amos Mungai, age 48, male; Domi Munzala, age 24, male; Tommy

  25   Nkurume Munzala, age 25, male; Caroline Mumbi Muraguri, age



                                                                1965



   1   unavailable, female; Fiddes Wambui Muritu, age 33, female;

   2   Alice Waruguru Muriuki, age 20, female; Mary Wanjiku Muriuki,

   3   age unavailable, female; Robert Mwigwi Muriuki, age

   4   unavailable, male; Dominic Kithuva Musyoka, age 52, male;

   5   Wilson Kipkorir Mutahi, age 33, female; Florence Mwende

   6   Muthama, age 32, female; Josephine Nzilani Mutinda, age 28,

   7   female; Emmanuel Nyagah Mutiira, age unavailable, male;

   8   Catherine Ndoome Mutua, age 24, female; Patrick Kariuki Mutui,

   9   age unavailable, male; Caroline Karumba Mutuiri, age 17,

  10   female; Gloria Nkatha Mutuiri, age 16, female; Gabriel

  11   Mwadime, age 26, male; Harrison Njuguna Mwangi, age 56, male;

  12   Roselyn Wanjiku Mwangi, age 36, female; Samuel Githua Mwangi,

  13   age 33, male; Moses Aston Mwani, age 50, male; Anna Mwaniki,

  14   age 48, female; Isaac Mukera Mwaria, age 66, male; Abdalla

  15   Musyoka Mwili Mwilu, age 38, male; Elizabeth Nyarosto Nakhale,

  16   age 50, female; Geoffrey Moses Namai, age 42, male; Moses

  17   Andika Namayi, age 29, male; Mary Nyaguthi Ndirangu, age 28,

  18   female; Simon Kinuthia Ndirangu, age 38, male; Caroline Atieno

  19   Ndolo, age unavailable, female; Martin Kivathe Nduati, age 28,

  20   male; Julius Ndulu, age 28, male; Edwin Paul Ndumbi, age 24,

  21   male; Peter Njoroge Ndungu, age 44, male; Ephraim Kingori

  22   Ndunu, age 27, male; Joyce Njeri Ng'Ang'a, age 19, female;

  23   Loice Njeri Nganga, 23, female; John Mwangi Ngaragari, age 35,

  24   male; Peter Kabau Macharia Ngugi, age 31, male; Jacinta Njoki

  25   Njau, age 29, female; Simon Mwangi Njiima, age unavailable,



                                                                1966



   1   male; Abel Mutegi Njiru, age 37, male; Agatha Ann Njoki, age

   2   27, female; Catherine Wambara Njoroge, age 41, female; Francis

   3   Ndungu Njoroge, age 48, male; Grace Nyambura Njoroge, age 53,

   4   male; William Waithaka Njoroge, age 29, male; Francis Kibe

   5   Njuguna, age 51, male; Godfrey Muchori Njuguna, 31, male;

   6   Patrick Mbiyu Njuguna, age 29, male; Francis Mbogo Njuige, age

   7   49, male; Michael Oduor Nyademba, age 34, male; Vincent Kamau

   8   Nyoike, age 53, male; Janet Ndumi Nzioka, age 24, female;

   9   Johnson Kimeu Nzioka, age 35, male; Magdaline Mbithe Nzoka,

  10   age 22, female; Joseph Ngove Nzwili, age unavailable, male;

  11   Aineah Joshua Obonyo, age 32, male; Frederick Ezra Ochieng,

  12   age 27, male; Francis Olewe Ochito, age 35, male; Lawrence

  13   Olum Ochola, age 29, male; Duncan Odhiambo, age unavailable,

  14   male; John Oduor Odhiambo, age 33, male; Patricia Atieno Ogol,

  15   age 38, female; Maurice Okatch Ogola, age 50, male; Michael

  16   Ochieng Okeyo, age 30, male; Simon Otieno Olang, age 35, male;

  17   Dominic Otieno Olango, age 32, male; Lepeine Kitatian Olotono,

  18   age 54, female; Hanson Nyabera Omar, age 31, male; Margaret

  19   Atieno Ombunya, age unavailable, female; Edwin Opiyo Omori,

  20   age 47, male; Enoch Omweno, age 42, male; Lucy Grace Onono,

  21   age 48, female; Evans Kibiro Onsongo, age 35, male; Eric Abuor

  22   Onyango, age 32, male; John Ouko Onyango, age 31, male;

  23   Caroline Sella Opati, age 47, female; Sylvia Oriedo, age 35,

  24   female; Godfrey Okuro Orono, age 33, male; Elizabeth Achieng

  25   Orwa, age 30, female; Joseph Ondari Osamba, age 50, male;



                                                                1967



   1   Elias Otieno Osir, age 32, male; Julius Ochieng Otieno, age

   2   35, male; Mathews Walunya Otieno, age 54, male; Rogers Otolo,

   3   age unavailable, male; Elijah Ngito Owino, age 40, male;

   4   Josiah Odero Owuor, age 35, male; Rachel Magasia Pussy, age

   5   unavailable, female; Margaret Okello Rading, age 31, female;

   6   Peter Evans Mugo Rungu, age 44, male; Ruth Mukami Rungu, age

   7   20, female; Timothy Odhiambo Sande, age 31, male; Fahat

   8   Sheikh, age 40, male; Hassan Jarso Soka, age 36, male;

   9   Shadrack Nyagah Thitu, age 35, male; Samuel Mbugua Thuo, age

  10   36, male; Phaedra Vrontamis, age 51, female; Gloria Wangechi

  11   Wachira, age 27, female; Shadrack Mwangi Wagaiyu, age 54,

  12   male; James Mwangi Wainaina, age 47, male; Adams Titus Wamai,

  13   age 53, male; Anne Mumbi Wambugu, age 44, female; John Gitau

  14   Wamutwe, age 40, male; David Soita Wanabacha, age 30, male;

  15   Margaret Wambui Wangethi, age 42, female; Gladys Wangui, age

  16   33, female; Mercy Wanjiku, age 29, female; John Mwangi

  17   Wanyoike, age 28, male; Margaret Wasike, age unavailable,

  18   female; Sabina Wateri, age 46, female; Benson Wathigo, age 56,

  19   male; Margaret Njeri Waweru, age unavailable, female; Ann Mumo

  20   Zakayo, age 28, female.

  21            "D.  Between August 7 and August 14, 1998, Dr. Olumbe

  22   also prepared death certificates for two individuals.  These

  23   persons were also determined to have been killed by injuries

  24   resulting from a bombing.  The bodies of these two individuals

  25   were identified by family members to be the following persons:



                                                                1968



   1            "Philip Munyao Kioko, age 52, male; Ruth Mukami

   2   Musyoka, age unavailable, female.

   3            "2.  If equalled as a witness, Joyce Lapa would

   4   testify as follows:

   5            "A.  She is a medical doctor who graduated from the

   6   University of Florida with a Bachelor of Science in Nursing in

   7   1976 and from the Duke University with a medical degree in

   8   1982.  Dr. Lapa was a Pathology Resident at the National Naval

   9   Medical Center in Bethesda, Maryland from 1998 to 1992 and a

  10   Forensic Pathology Resident at the Armed Forces Unit of

  11   Pathology from 1992 to 1993.  Dr. Lapa is a Diplomat in the

  12   National Board of Medical Examiners and is certified by the

  13   American Board of Pathology.  Since 1995, Dr. Lapa has been

  14   the Chief Deputy Medical Examiner at the Armed Forces Unit of

  15   Pathology in Rockville, Maryland.  Dr. Lapa performs autopsies

  16   to determine the cause of death.  In her experience as a

  17   medical examiner, Dr. Lapa has examined persons who were

  18   killed by explosive devices.

  19            "B.  Between August 12 and August 14, 1998, Dr. Lapa

  20   was asked to perform or supervise autopsies on 11 individuals

  21   at the Dover Port Mortuary, Dover, Delaware.  In summary, all

  22   of the persons listed below were determined to have been

  23   killed by injuries resulting from a bombing.

  24            "C.  The bodies examined by Dr. Lapa were identified

  25   by family members as the following individuals:



                                                                1969



   1            "Jesse Nathaniel Aliganga, age 21, male; Julian

   2   Leotis Bartley, Jr., age 27, male; Julian Leotis Bartley, Sr.,

   3   age 54, male; Molly H. Hardy, age 51, female; Kenneth Ray

   4   Hobson, age 27, male; Prabhi Gutpara Kavaler, age 45, female;

   5   Arlene Bradley Kirk, age 50, female; Mary Louise Martin, age

   6   45, female; Ann Michelle O'Connor, age 37, female; Sherry Lynn

   7   Olds, age 40, female; Uttamlal Thomas Shah, age 37, male.

   8            "23.  All 213 individuals listed in paragraphs 1 and

   9   2 above were found within, or in the vicinity of, the United

  10   States Embassy, located at Moi Avenue and Haile Selassie

  11   Avenue, Nairobi, Kenya, and the neighboring buildings and

  12   grounds during the late morning of August 7, 1998 or during

  13   later rescue and recovery operations at the scene.

  14            "4.  If called to testify as a witness, other doctors

  15   from Nairobi, Kenya would testify that approximately 4,000

  16   persons who were in the vicinity of the American Embassy in

  17   Nairobi, Kenya, during the morning of August 7, 1998 were

  18   injured as a result of a large explosion.

  19            "It is further stipulated and agreed that this

  20   stipulation may be received in evidence as a government

  21   exhibit at trial."

  22            And the government at this point would offer the

  23   stipulation as Government Exhibit 39.

  24            THE COURT:  Received.

  25            (Government Exhibit 39 received in evidence)



                                                                1970



   1            MR. BUTLER:  Agent Gaudin is the next witness.

   2            THE COURT:  We'll take our lunch break at this point

   3   and we are adjourned until 2:15.

   4            (Luncheon recess)

   5

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   7

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   9

  10

  11

  12

  13

  14

  15

  16

  17

  18

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  21

  22

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  24

  25



                                                                1971



   1                 A F T E R N O O N    S E S S I O N

   2                             2:15 p.m.

   3            (In open court; jury not present)

   4            THE COURT:  All right.  Let's be seated.  All right.

   5   The witness may come in and the jury may come in.

   6            (Jury present)

   7            THE COURT:  The government may call its next witness.

   8            MR. BUTLER:  Government calls Stephen Gaudin, your

   9   Honor.

  10    STEPHEN GAUDIN,

  11        called as a witness by the government,

  12        having been duly sworn, testified as follows:

  13   DIRECT EXAMINATION

  14   BY MR. BUTLER:

  15   Q.  How are you employed?

  16   A.  I'm employed by the FBI.

  17   Q.  And how long have you been an agent with the FBI?

  18   A.  I've been with the FBI a little over nine years.

  19   Q.  And where are you currently assigned?

  20   A.  I'm currently assigned to the New York office of the FBI.

  21   Q.  How long have you been with the New York office of the

  22   FBI?

  23   A.  I've been with the New York office of the FBI for a little

  24   over three years.

  25   Q.  Where were you assigned before the New York office?



                                                                1972



   1   A.  Prior to coming to New York I was assigned with the FBI in

   2   upstate New York in Albany, New York.

   3   Q.  In any unit or section while you were in Albany?

   4   A.  While in Albany I worked on general crimes.

   5   Q.  Concerning your time in Albany, did you conduct facility

   6   interviews of suspects in criminal investigations?

   7   A.  Yes, I did.

   8   Q.  And about how many times?

   9   A.  Dozens of times.

  10   Q.  Now, were you one of the FBI agents sent to Nairobi Kenya

  11   after the bombing of the American embassy on August 7, 1998?

  12   A.  Yes, I was.

  13   Q.  When did you arrive in Nairobi?

  14   A.  I arrived in Nairobi on early Sunday morning, August 9,

  15   1998.

  16   Q.  Prior to your arrival what was your understanding of your

  17   assignment while you were in Kenya?

  18   A.  Prior to arriving in Kenya I wasn't given a specific

  19   assignment but just general instructions that we were going to

  20   Kenya to help out with the investigation of the bombing in any

  21   way we could.

  22   Q.  I'm talking specifically about what you did after arriving

  23   in Kenya.  Did you receive an assignment on August 12, 1998?

  24   A.  Yes, I did.

  25   Q.  And what was that assignment?



                                                                1973



   1   A.  On August 12th I was instructed to go with my Kenyan law

   2   enforcement counterpart there is the CID, the investigators

   3   from their Criminal Investigation Division.  I was to go with

   4   them to a hotel.

   5   Q.  And were you working with the Kenyan CID in this

   6   investigation?

   7   A.  Yes, I was.

   8   Q.  Where was this hotel you were going to located?

   9   A.  It was in Eastleigh Nairobi.

  10   Q.  And where is Eastleigh located?

  11   A.  It was about a twenty or thirty minute drive outside of

  12   Nairobi.

  13   Q.  And who was with you?

  14   A.  I was with another FBI agent and a New York City Police

  15   detective who was working with us, also.

  16   Q.  And who else was with you?

  17   A.  There were two Kenyan CID officers and their driver.

  18   Q.  And how did you get to Eastleigh that day?

  19   A.  We drove.  We were in the back of a truck.

  20   Q.  And who drove the truck?

  21   A.  The Kenyan CID driver drove the truck.

  22   Q.  Where were you located?

  23   A.  I was in the back of the truck.  It was a covered truck

  24   sort of like a pickup truck with a big cab on the back.

  25   Q.  Did there come a time when you arrived at the Iftin Lodge



                                                                1974



   1   in Eastleigh?

   2   A.  Yes, there was.

   3   Q.  About what time was that?

   4   A.  It was around 10 o'clock in the morning that day.

   5   Q.  And what happened when you arrived at the Iftin Lodge?

   6   A.  The CID investigators went into the hotel and they came

   7   out with a man.

   8   Q.  And at the time that you were in the truck could you see

   9   the man that the CID officers were with?

  10   A.  Yes, I could.  I was in the back of the truck, but it was

  11   pretty hot, so we had the door open and I could see the CID

  12   officers talking to this man.  I was very close.

  13   Q.  At the time could you see if this person had any documents

  14   on him?

  15   A.  Yes.  This man was, had presented a white slip of paper of

  16   some kind to the Kenyan CID officers.

  17   Q.  And did you see that white slip of paper?

  18   A.  Yes, I did.

  19   Q.  What was it?

  20   A.  It was a hospital, what appeared to me to be a hospital

  21   admissions card showing that someone was treated at the MP Sha

  22   Hospital on August 7, 1998.  It had a patient number written

  23   on the top, printed on the top and a person's name Khalid

  24   Saleh written in the handwritten form.

  25            MR. BUTLER:  Your Honor, may I approach?



                                                                1975



   1            THE COURT:  Yes.

   2   Q.  I'd like to show you what has been marked as Government

   3   Exhibit 550 for identification.  If we could just show that

   4   just for identification purposes.  Agent Gaudin, is this the

   5   document that the individual who you saw in Eastleigh that day

   6   had on him?

   7   A.  This is it right here in my hand.

   8            MR. BUTLER:  I move Government Exhibit 50350 into

   9   evidence your Honor.

  10            THE COURT:  Received.

  11            (Government's Exhibit 550 received in evidence)

  12   Q.  Now, was this person taken into custody?

  13   A.  Yes, he was.

  14   Q.  What was your understanding as to why this person was

  15   arrested?

  16   A.  He was arrested by the Kenyan CID officers for not having

  17   any official identification on him.

  18   Q.  And to be clear, who made that arrest?

  19   A.  The Kenyan CID officers made that arrest.

  20   Q.  And after the arrest where was he placed?

  21   A.  He was put into the back of the truck with me.

  22   Q.  And once inside the truck did this person confirm that he

  23   was Khalid Saleh?

  24   A.  Yes, he did.

  25   Q.  And did he tell you where he was from?



                                                                1976



   1   A.  He said he was Yemen.

   2   Q.  Looking around the courtroom do you recognize the

   3   individual who identified himself as Khalid Saleh from Yemen

   4   that day?

   5   A.  Yes, I can.

   6   Q.  Could you tell us where he is?

   7   A.  He's sitting right there in between the two ladies in the

   8   corner.  I can get up and point whatever is easier.

   9            MR. COHN:  We concede the identification.

  10            THE COURT:  The witness identifies the defendant

  11   Al-'Owhali.

  12   Q.  Did you observe whether he had any injuries that day?

  13   A.  Yes, I could see that he did have injuries.

  14   Q.  What type of injuries did he have?

  15   A.  He had stitches on his forehead.  They weren't covered

  16   with a bandage or bandaid.  I could see the stitches and both

  17   of his hands had bandages on them.

  18   Q.  And did you take any pictures of him after his arrest?

  19   A.  Yes, we did.

  20            MR. BUTLER:  May I approach, your Honor?

  21            THE COURT:  Yes.

  22   Q.  Agent Gaudin, I just handed you what has been marked as

  23   Government Exhibits 551 A through I for identification.

  24            If we could just show those for identification

  25   purposes.  Are those copies of the photographs that you took



                                                                1977



   1   that day?

   2   A.  Yes, these are.

   3            MR. BUTLER:  Your Honor, I would move Government

   4   Exhibits 551 A through I into evidence.

   5            MR. COHN:  No objection.

   6            THE COURT:  Received.

   7            (Government's Exhibits 551-A through I received in

   8   evidence)

   9   Q.  If we could publish 551-A through I to the jury.

  10            Agent Gaudin, do these photographs accurately depict

  11   the injuries that you saw that day on Mr. Al-'Owhali?

  12   A.  Yes.  Except in the fact that on his hand he doesn't have

  13   the bandages on his hand, but at the time of arrest he did

  14   have like a gauze with some bandaid or tape or something

  15   covering those stitches on his hands.  That's the only

  16   difference.

  17   Q.  Now, Mr. Al-'Owhali obviously doesn't have a shirt on, but

  18   did you notice whether the clothes that he was wearing were

  19   the same clothes that he was wearing at the time of his

  20   arrest?

  21   A.  Yes.  In the first picture it does have his shirt on and,

  22   yes, these were the clothes he was wearing on August 12th.

  23   Q.  Did there come a time when you took custody of those

  24   clothes?

  25   A.  Yes, I did.



                                                                1978



   1   Q.  When did you take custody of those clothes?

   2   A.  On August 13th.

   3   Q.  Did the FBI maintain custody of those clothes?

   4   A.  Yes, they did.

   5            MR. BUTLER:  May I approach, your Honor?

   6            THE COURT:  Yes.

   7   Q.  Agent Gaudin, I've just handed you a bag that's been

   8   marked Government Exhibits 552 through 556 for identification.

   9   I would ask you just to open those bags and just take a look

  10   at those clothes.

  11   A.  These are two paper bags I had put his clothes into.  The

  12   first bag, the belt --

  13   Q.  Don't show them to the jury yet.  Look at those clothes to

  14   yourself, Agent Gaudin, and tell us whether those