The government should "identify the material support and resources" that defendant Rana and co-conspirators allegedly provided regarding the terrorism in India, the motion said.
Pakistani-Canadian LeT operative Tahawwur Rana has sought from prosecutors specific details about the "material support and resources" that the indictment alleged he provided to terror plots in India and Denmark, saying that he wanted to be "adequately prepared" for trial.
In a six-page motion filed in the US district court, Northern District of Illinois his lawyer Patrick Blegen sought "particulars" regarding the charge in the indictment that says Rana, a Chicago-based businessman, conspired to provide material support to terrorism in India and Denmark.
The government should "identify the material support and resources" that defendant Rana and co-conspirators allegedly provided regarding the terrorism in India, the motion said.
"The charge lists 'personnel', 'tangible property', 'money and false documentation and identification'" and the government should be required to "identify, with particularity," information regarding all these, it said.
The motion further said the prosecution must also identify the material support and resources that Rana and co-defendant David Headley allegedly provided to LeT.
"The government should be required to identify, with particularity, terrorist activity which Lashkar-e-Tayyiba had engaged in or was engaging in," as alleged in the indictment, it said.
Blegen said he is seeking the information so that Rana, 49, is "sufficiently apprised" of the scope of the government's allegations and is "adequately prepared" for trial.
The information will also help "minimise or avoid undue surprise at trial and permit the defendant to successfully plead double jeopardy as a bar to later prosecution for the same offence," the lawyer said.
Rana is charged in three counts of a twelve count superseding indictment that alleged he provided some form of "material support and resources" to terrorists.
Count 12 of the indictment lists "personnel, currency, tangible property, and false documentation and identification".
"Aside from generally listing broad categories of material support/resources such as personnel or false documentation, the superseding indictment fails to identify what was actually provided," Blegen said in the motion.
"For example, is the 'personnel' alleged to be defendant himself? Is the 'false documentation' a false passport? Without such particulars, trial preparation will be extremely difficult and pleading any of the counts of the indictment as a bar against double jeopardy would be impossible."
Rana's lawyer has filed five separate motions in district court that ask government to disclose all allegedly similar crimes, wrongs or acts allegedly committed by the Pakistani-Canadian on which the prosecution intends to rely at trial.
They also seek details about criminal identification and history sheet of each potential government witness and general nature of evidence authorities intend to introduce at trial.
Blegen said such information is necessary to effectively represent Rana, who has pleaded not guilty to the charges.
Rana has also sought an extension of time to file additional pre-trial motions, which were initially scheduled to be filed by February 16.
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