mohammad shibin filings

IN THE UNITED STATES DISTRICT COURT FOR THE

EASTERN DISTRICT OF VIRGINIA

Norfolk Division

UNITED STATES OF AMERICA ))

v. ) CRIMINAL NO. 2:11cr33)

MOHAMMAD SAAILI SHIBIN, ))

Defendant. )

GOVERNMENT’S RESPONSE TO DEFENDANT’S MOTION TO SUPPRESS WITH MEMORANDUM OF LAW

The United States of America, by it attorneys, Neil H. MacBride, United States Attorney

for the Eastern District of Virginia, and Benjamin L. Hatch, Joseph E. DePadilla, and Brian J.

Samuels, Assistant United States Attorneys, respectfully submits this response to Defendant’s

Motion to Suppress with Memorandum of Law. For the reasons stated in detail herein, the

government respectfully submits that the defendant’s motion should be denied.

SUMMARY OF ARGUMENT

As Shibin concedes, the FBI’s interview of him on April 7 was appropriate and

admissible if he initiated the further discussion and knowingly waived his rights. The evidence

will show that Shibin was the one who engaged the further discussion on April 7. Shibin is a

multilingual 50 year old man and had already been interviewed three times by the FBI prior to

April 7. On each occasion, the FBI reviewed his Miranda rights with him and Shibin voluntarily

waived those rights. When, on April 7, Shibin indicated he wanted to speak with someone

knowledgeable about the law, the FBI promptly ceased questioning. The FBI only re-engaged

with Shibin after Shibin repeatedly indicated that he wanted to speak with the agents about his

Case 2:11-cr-00033-RGD -DEM Document 32 Filed 08/08/11 of 16 PageID# 118

case. In fact, on several occasions the FBI advised Shibin that they could not speak with him

because he had requested a lawyer. It was only after Shibin affirmatively stated that he wished to

speak without an attorney present, and once again reviewed and executed the FBI’s advice of

rights form, that Shibin gave the additional incriminating statements on April 7. At that point,

Shibin was very knowledgeable about his Miranda rights, having gone over them several times

before with the FBI and it was at his behest that the FBI engaged in further discussion with him

on April 7. The FBI studiously followed the law of interrogation, and Shibin, a man who in

December of 2010 had successfully negotiated and extracted a ransom of several million dollars

for the release of a German vessel, the M/V Marida Marguerite, was fully capable of

understanding his rights and making an informed and voluntary decision regarding whether to

speak to the agents without an attorney present.

BACKGROUND

I. April 4 Interview

On or about April 4, 2011, Shibin was taken into foreign custody by elements of Somali

defense forces in Bosasso, Puntland. On April 4, two FBI agents – Supervisory Special Agent

Robert C. D’Amico and Special Agent Brian J. Maliszewski – interviewed Shibin. As part of

this interview, the agents provided Shibin with the FBI’s advice of rights form, which reflects the

standard Miranda warnings. They initially provided Shibin with an English advice of rights

form, which Shibin read out loud in English. Shibin was also offered an advice of rights form

translated into Somali, but Shibin indicated he did not need that version as he understood the

English version. Shibin was asked if he understood the rights and if he wished to continue

speaking with the agents. Shibin stated that he understood the document, signed it as requested,

-2-


and agreed to speak with the agents. A copy of this executed form is attached hereto as

Attachment A.

During this interview, among other things, Shibin stated that he had been treated well1

while being detained and he expressed no complaints or issues relating to his detention. Shibin

was given a physical examination, which confirmed that he had no medical conditions that would

preclude him from being interviewed, and he was offered food.

Shibin stated that he was born in December of 1960 in Mogadishu, Somalia. He had

arrived in Bosasso on April 4th. On March 27, Shibin had been in Zambia and had traveled via

airlines and ground transportation from Lusaka, Zambia to Addis Ababa, Ethiopia and then

Djibouti, which was his last stop prior to arriving in Somalia. Prior to this trip, Shibin stated that

he had left Galcaio, Puntland on or about March 1, 2011 and traveled to Lusaka, Zambia. 2

Regarding prior employment, Shibin stated that he used to work for African Oil

Corporation (AOC). He claimed he was laid off about 18 months ago. Shibin served as a

dispatcher and translator for AOC. He would receive arrivals from the airport, transport them

around to where they needed to go and make all the logistical arrangements for them. Shibin

stated that he was good at this job because he could translate for them and he speaks good

English, some Italian, and good Arabic.

II. April 5 Interview

On April 5, Shibin was still in the custody of foreign forces and he was again interviewed

The government does not summarize all statements Shibin made during these interviews1

but does note statements or facts that are pertinent to his Motion to Suppress.

Puntland is a region in north-central Somalia.2

-3-


by the FBI agents. Prior to this interview, Shibin was provided with a full night’s rest, water, and

the opportunity to conduct self-hygiene. The agents reviewed the same advice of rights form

executed by Shibin during the April 4 interview. Shibin stated that he understood the document,

signed it again, and agreed to continue to speak with the agents.

Shibin again indicated that he had been treated well during his period of detention. He

expressed no complaints or issues related to his detention. During this interview, Shibin gave

consent to search for his luggage and other personal effects at the location where he had been

staying. Shibin also discussed two cell phones that he had previously possessed and the phone

numbers associated with those cell phones.

III. April 6 Interview

On April 6, Shibin was still in the custody of foreign forces and he was again interviewed

by the FBI agents. As with the April 4 and 5 interviews, the agents reviewed Shibin’s rights3

with him and he executed the waiver of his rights and agreed to speak. As in the prior

interviews, Shibin indicated that he had been treated well and had no complaints. Prior to the

interview, he was provided with a meal, water, and an opportunity to conduct self-hygiene.

During this interview, Shibin stated that at some point he had begun translating for the

pirates. Shibin stated that he was initially approached by a nameless friend who proposed that

Shibin participate in crimes of piracy. Shibin indicated that he researched this possibility by

speaking to several of his friends and associates. Shibin stated that his friends explained that you

could make money by negotiating and not be considered a criminal. Shibin stated that he

There were substantial breaks between the interviews on April 4, 5, and 6, and in3

between each interview Shibin had a night’s sleep.

-4-


believed he would not be considered a criminal if he did not actually hijack the vessel.

Shibin stated that he operated as a pirate negotiator one time, during the hijacking of the

German vessel named the M/V Marida Marguerite. Shibin stated that he earned $30,000 for his

participation in that hijacking. Shibin stated that another person, named Leon, took his place on

the Marida Marguerite at some point and that was one of the reasons that negotiation took longer.

Shibin was shown a photograph of himself on the Marida Marguerite and he stated that the

photograph was him on the Marida Marguerite. Shibin stated that he went to the Marida

Marguerite because the pirates called him directly. The pirates had requested that he serve as a

translator for the pirate crew. Shibin described the scene on the Marida Marguerite as horrible.

He stated that all of the hostages were kept in a small area in the wheelhouse. Shibin stated that

he left the Marida Marguerite in December of 2010.

With regard to the hijacking of the S/V Quest, Shibin was shown a picture of a cell phone

he previously possessed. Shibin affirmed that the phone looked like his phone. Shibin claimed4

that he lost the phone in a taxi while in Zambia, sometime within the past several weeks.

Shibin was next shown a collection of screen shots from his cell phone. These screen3

shots included internet searches conducted via the cell phone on February 19 and 20, 2011 – the

Quest was hijacked on February 18. The screen shots showed several internet searches

conducted through the phone in that time period, including the following: “Hijacked S/V Quest

This cell phone previously possessed by Shibin had the phone number that the pirates4

who had seized the S/V Quest gave to the military, along with Shibin’s name, as the contactnumber for their negotiator.

A “screen shot” is a photograph of the display screen of the cell phone. The cell phone3

can display various things in its display screen, including prior incoming and outgoing phonecalls and internet searches conducted via the phone.

-5-


by somali pirates,” “Jean and Scott Adams telephone number,” “address of hijacked S/V Quest

owner,” “jean and scott adams profile,” and “Hijacked S/V Quest value.” After reviewing these

screen shots, Shibin stated that the pictures were from his phone. Shibin stated that he had

searched the topics noted above using the phone.

Shibin also noted that the had an “auto-alert” feature that sent messages about

highjackings in and around Somalia directly to his phone. Shibin stated that you have to know

the number of people and the value of the boat. Shibin claimed that he had researched the Quest

solely out of curiosity. Shibin stated that he did not agree to help them with the Quest. He

further stated that he knew about the hijacking of the Quest, but he was never interested in

negotiating for its return or release.

IV. April 7 Interviews

Between the April 6 interview summarized above and the April 7 interviews summarized

below, Shibin was taken into the custody of the FBI pursuant to an arrest warrant issued in the

Eastern District of Virginia. Shibin was transported out of Somalia and ultimately placed on a

Gulfstream V (G-V) airplane owned by the Department of Justice and transported back to the

United States.

When Shibin and the arresting agents were awaiting the arrival of the G-V to transport

Shibin back to the United States, Shibin expressed to Special Agent Maliszewski that he wanted

to speak further to explain things. When Supervisory Special Agent D’Amico arrived to conduct

the interview, the agents reviewed with Shibin the offenses with which he was charged. At that

point, Shibin apparently had a change of mind and stated that he did not want to talk anymore

and he thought he needed professional help with this. When asked to clarify what he meant,

-6-


Shibin stated that he needed someone who knows the law. Erring on the side of caution, the

agents treated this statement as an invocation of the right to counsel and therefore ceased further

discussion with Shibin. When the G-V arrived with additional agents, Special Agent4

Maliszewski notified the agents who had arrived on the G-V that Shibin had invoked his right to

counsel. As a result, the agents initially did not seek to interview Shibin further on the return

flight. The agents aboard the G-V were Special Agents Kevin P. Coughlin and Edward Deck.

Detective Frederick A. Galloway of the New York City Police Department was also present.

Supervisory Special Agent D’Amico joined this group for the flight back to the United States.

The G-V is a small jet, and the seating arrangement is such that two rows of seats face

each other, rather than each row facing the back of the row in front, as is usual in larger

passenger aircraft. For the return flight Shibin sat in one seat looking forward with an agent

immediately to his right (also facing forward). Two agents sat in seats in front of Shibin facing

toward him (toward the rear of the aircraft). As a result, Shibin and the agents were generally

within speaking range for the duration of the return flight.

After some time passed on the return flight, Shibin started indicating that he wanted to5

speak to the agents and detective. Specifically, Shibin started asking questions about the case.

Shibin’s Motion to Suppress understandably references a section of a report by Special4

Agent Coughlin which states that, with regard to the April 7 interviews, “SHIBIIN initiallyindicated that he did not want to speak and that he wanted to speak to an attorney.” Motion toSuppress at 4-5. This reference in Special Agent Coughlin’s report actually reflects thesubstance of what Special Agent Maliszewski told Coughlin when Coughlin arrived on the G-V. That is, Maliszewski summarized for Coughlin what Shibin had earlier stated to Maliszewski andD’Amico. Maliszewski did this because the agents were treating Shibin’s earlier statement as aninvocation of the right to counsel, and therefore Maliszewski was advising Coughlin in essenceto avoid further interrogation.

The G-V’s return flight from Africa to the United States took a number of hours.5

-7-


Special Agent Coughlin told Shibin that he (Coughlin) would like to speak with him but that he

was not allowed to engage in conversation with Shibin because Shibin had requested an

attorney. 4

After some more time went by, Shibin again started talking to the agents and asking

questions about his case. Special Agent Coughlin again admonished Shibin that they could not

talk to him because Shibin had requested an attorney. Special Agent Coughlin recalls this same

back-and-forth pattern – i.e., Shibin attempting to engage in further conversation about his case

and the agents admonishing that they could not speak to him further – occurring approximately

three to six times.

Eventually, as Shibin persisted in his efforts to talk, Special Agent Coughlin told Shibin

that it was up to him (Shibin) if he wanted to talk to the agents. Special Agent Coughlin told

Shibin that Shibin had to be the one to engage them in the conversation because Shibin was the

one who asked for an attorney. Special Agent Coughlin advised Shibin that the agents could not

initiate discussions with him, but if Shibin changed his mind about wanting an attorney, he could

initiate further conversation with them. Shibin then said he wanted to talk. Special Agent

Coughlin asked him if that meant he was fine with answering questions without an attorney

present. Shibin said yes. At this point, Special Agent Coughlin presented Shibin with the FBI

advice of rights form. Shibin reviewed it, stated that he understood his rights, and signed the

form. A copy of the form, and the form that was used at the later interview that same day, is

Special Agent Coughlin is an attorney. He previously served as a Judge Advocate4

General (JAG) officer in the United States Marine Corp, and continues to serve in the MarineCorp reserves. While on active duty, he served as a military prosecutor for about one year and amilitary defense counsel for about a year and a half. In that capacity, he dealt with issuespertinent to rights advisements in the military process.

-8-


attached as Attachment B.

During the ensuing interview, Shibin stated, among other things, that an individual,

whose name he gave, had contacted him and told him that the hijacking of the Quest had

occurred. This person asked Shibin if he would be the negotiator and translator for the pirates.

Shibin claimed that he told this person that he would think about it. Shibin stated this is when he

began conducting the internet searches about the hostages on the Quest and the value of the boat.

Shibin stated that he looked into it in case he wanted to get involved in it. Shibin claimed that

two days after being contacted by the individual, he called the person back and told him that he

would not be the negotiator for the Quest.

With regard to the Marida Marguerite, Shibin stated again that he was paid $30,000 for

assisting with the hijacking of the ship. Shibin stated that after the ship was hijacked the people

who hijacked the ship could not talk to the owners of the ship due to the language barrier. As a

result, they asked Shibin to conduct the negotiations and Shibin claimed that he thought he was

helping by being a “go between.” Shibin claimed that after the Marida Marguerite hijacking, he

“had enough.”

Later in the day on April 7, the agents went back to Shibin to show him some pictures and

clarify some matters. Prior to this discussion, Shibin was again given the Miranda warnings and

again agreed to speak. In this interview, Shibin discussed a pirate investor that he knew.

ARGUMENT

As Shibin states, the issue is whether, after indicating that he wanted to speak to an

attorney, he initiated further conversation with the FBI. If he did, then his ensuing statements,

provided after a voluntary waiver of Miranda rights, are admissible.

-9-


At the outset, the government notes that it does not concede that Shibin unambiguously

invoked his right to counsel under the standard set forth in Davis v. United States, 512 U.S. 452

(1994). In Davis v. United States, the Supreme Court held that ambiguous or equivocal

assertions of the need for counsel do not invoke the right and require law enforcement to cease

questioning. Id. at 459 (“We decline petitioner’s invitation to extend Edwards and require law

enforcement officers to cease questioning immediately upon the making of an ambiguous or

equivocal reference to an attorney.”). In Davis, the Supreme Court found the statement “Maybe I

should talk to a lawyer” to be ambiguous. Id. at 458-60. Applying Davis, the Fourth Circuit

concluded that the statement “I think I need a lawyer” was equivocal. Burket v. Angelone, 208

F.3d 172, 197-98 (4th Cir. 2000). See also Diaz v. Senkowski, 76 F.3d 61, 63-65 (2d Cir. 1996)

(statements “I think I want a lawyer” and “Do you think I need a lawyer?” were equivocal).

Although the government does not concede the point, it is unnecessary for the court to

resolve whether Shibin’s statement was sufficiently unambiguous under Davis because the agents

erred on the side of caution and treated his statement as an invocation of the right to counsel.

Because, for the reasons stated herein, the agents complied with the law even if Shibin invoked

the right to counsel, it is not necessary for the Court to determine whether Shibin’s statement was

unambiguous under Davis.

Once the right to counsel is asserted, a subject in custody may not be interrogated outside

counsel’s presence “unless the accused himself initiates further communication, exchanges, or

conversations with the police.” Edwards v. Arizona, 451 U.S. 477, 484-85 (1981) (emphasis

added). See also McNeil v. Wisconsin, 501 U.S. 171, 177 (1991); Minnick v. Mississippi, 498

U.S. 146, 156 (1990) (“Edwards does not foreclose finding a waiver of Fifth Amendment

-10-


protections after counsel has been requested, provided the accused has initiated the conversation

or discussions with the authorities”). The Edwards framework applies regardless of whether the

counsel-right at issue arises under the Fifth or Sixth Amendments. See Montejo v. Louisiana,

129 S.Ct. 2079, 2091-92 (2009). If the defendant initiates the further discussion, then his

statements are admissible so long as there is a knowing, intelligent, and voluntary waiver of

counsel. Correll v. Thompson, 63 F.3d 1279, 1285 (4th Cir. 1995) (post-invocation statements

are admissible “if the defendant initiated the further discussions with the police and the defendant

knowingly and intelligently waived his right to counsel.”).

Here, it was Shibin who initiated the further discussion with the agents. On the return

flight, Shibin repeatedly attempted to engage the agents in discussions about his case and to ask

questions about his case. After stating several times that they could not talk to him, the agents,

after making sure that Shibin wanted to proceed without an attorney and advising Shibin of his

Miranda rights, engaged in further communication with Shibin at his behest.

This case is remarkably similar to the facts of Oregon v. Bradshaw, 462 U.S. 1039

(1983), where a plurality of the Supreme Court concluded that a defendant’s post-invocation

statement “Well, what is going to happen to me now?” constituted initiation of further

communication under Edwards. Id. at 1045-46 (plurality opinion). Similar to law5

enforcement’s response here, the officer in Bradshaw initially responded to the defendant that

due to the defendant’s request of a lawyer, any further discussion had to be of the defendant’s

Justice Powell, whose concurrence in the judgment was necessary for the result, rejected5

the idea that the courts should engage in an initial determination regarding whether the defendant“initiated” conversation, and instead voted to reverse because the defendant’s waiver of his rightto counsel was voluntary under all the circumstances. Id. at 1050-51 (Powell, J., concurring inthe judgment).

-11-


own free will. Id. at 1042. And just as here, law enforcement in Bradshaw subsequently

provided Miranda warnings to the defendant and obtained further statements.

After initiating further conversation, Shibin knowingly, intelligently, and voluntarily

waived his rights to remain silent and to counsel. In general, a waiver of the Miranda rights6

must be “made with a full awareness of both the nature of the right being abandoned and the

consequences of the decision to abandon it.” Moran v. Burbine, 475 U.S. 412, 421 (1986). But

“[t]he Constitution does not require that a criminal suspect know and understand every possible

consequence of a waiver of the Fifth Amendment privilege.” Colorado v. Spring, 479 U.S. 564,

574 (1987). In Harris v. Riddle, 551 F.2d 936 (4th Cir. 1977), for example, Harris, of low

intelligence, waived his Miranda rights and gave an inculpatory statement, wrongly believing

In this response, the government assumes that the basic Miranda advisement-waiver6

framework applies to an extraterritorial interrogation of an alien. See In re Terrorist Bombings,552 F.3d 177, 205 n.20 (2d Cir. 2008) (assuming, without deciding, that the Miranda framework“governs the admissibility of statements obtained by U.S. agents in the course of custodialinterrogations conducted overseas” because Miranda was satisfied in that case). However,precedent confirms that in the context of extraterritorial interrogations, particularly those ofaliens, the Miranda prophylactic rules can be modified to conform to the local conditions, even ifthose local conditions do not allow for access to counsel. See Cranford v. Rodriguez, 512 F.2d860, 862-64 (10th Cir. 1975) (approving FBI’s Miranda admonition before interrogation inMexico that omitted right to counsel but stated that suspect could consult American Consulateand noting that “we recognize that it was not possible to get an attorney and yet this should notmean that while the defendant is in detention investigation must stop”); United States v. Dopf,434 F.2d 205, 206-207 (5th Cir. 1970) (upholding Miranda warning in Mexico in which FBIagent stated that he could not furnish suspects with lawyer in Mexico but offered to contactAmerican Consul). “As these decisions [Cranford and Dopf] demonstrate, where Miranda hasbeen applied to overseas interrogations by U.S. agents, it has been so applied in a flexible fashionto accommodate the exigencies of local conditions.” In re Terrorist Bombings, 552 F.3d 177,205 (2d Cir. 2008). Here, for example, there was no defense counsel available on the G-V. Because the agents complied with heightened standards applicable to domestic interrogations,however, it is unnecessary for the court to consider whether lesser standards in fact applied giventhe extraterritorial circumstances of the interrogation.

-12-


among other things that oral confessions were not admissible in court. After his conviction

Harris challenged the waiver, arguing that the police were obligated to go beyond the prescribed

warnings to ensure that he understood not only his right to remain silent “but also the

consequences of his failure to exercise it.” Id. at 938. But the Fourth Circuit rejected Harris’s

claim, holding that “Miranda does not put upon the police the burden of explaining the rules of

evidence and the substantive criminal law.” Id. The Court explained:

When the police have fully and fairly given a suspect the Miranda warnings theirduty is discharged, and we hold that they are under no further and additional dutywhether or not the suspect acts wisely or foolishly or misapprehends either thefacts or the law. . . . Harris chose to speak with the knowledge that he could keepsilent or have counsel present when he talked. That is the meaning of intelligentwaiver; that and no more.

Id. at 939.

As the Fourth Circuit recently noted in United States v. Clenney, 631 F.3d 658, 668 (4th

Cir. 2011): “There is a value to keeping things simple and certain. The officers complied with

Miranda, and that ends the matter. Clenney received valid Miranda warnings, understood them,

and waived them.”

Just so here. Special Agent Coughlin asked Shibin specifically if Shibin wanted to

engage in further discussion without an attorney present, and Shibin stated that he did. The

agents then provided Shibin with the standard Miranda warnings – warnings that Shibin had

already reviewed with agents on three prior occasions – and Shibin elected to waive those rights7

and speak. Shibin is a 50 year old male capable of making informed decisions. He is educated

Shibin makes no claim that he failed to understand those same Miranda rights when he7

was interviewed on April 4, 5, and 6, and neither does he claim that his waiver of those rights onany of those occasions was unknowing or involuntary.

-13-


and speaks English, Italian, Arabic, and Somali. He has previously worked in jobs in which he

facilitated travel and transport by others, and recently before his interviews he had traveled

himself from Zambia to Somalia. And, just a few months prior to these events, Shibin had

successfully negotiated the ransom of a hijacked German vessel. Those ransom negotiations

involved international phone calls and months of back-and-forth negotiations with

representatives of the company. At the time of Shibin’s April 7 interview, he was not in a police

station house or in jail; rather, he was riding on a small jet. Further evidence of the voluntary

nature of Shibin’s April 7 statement comes from the content of the statement itself. The April 7

statement reflects Shibin’s effort to put his own spin on his involvement in the Marida

Marguerite hijacking and his claims of non-involvement in the Quest hijacking. Seeing that he

was now in the custody of the United States, Shibin was making a calculated decision to speak to

the agents and to try and tell the best possible story to the agents.

Although his statements on April 7 reflect Shibin’s spin efforts, they are, as Shibin

recognizes in his motion, highly incriminating. See Motion to Suppress at 2. In addition to

reiterating his involvement in piracy and the Marida Marguerite hijacking, Shibin’s April 7

statements contain important discrepancies from his earlier statements, demonstrating that he is

lying in important respects, and also contain other statements regarding his knowledge of the

pirates involved in the Quest that the government will be able to prove are false by other

evidence.

Shibin at times argues that he also invoked his right to remain silent, but the standards

applicable to further interrogation after a defendant asserts his right to remain silent are lower

than the standards applicable to a defendant who has asserted the right to counsel. See Michigan

-14-


v. Mosley, 423 U.S. 96, 104 (1975) (“We therefore conclude that the admissibility of statements

obtained after the person in custody has decided to remain silent depends under Miranda on

whether his ‘right to cut off questioning’ was ‘scrupulously honored.’”); id. at 104 n.10 (rejecting

claim that Miranda requires no further questioning after invocation of right to remain silent). In

essence, even if Shibin invoked his right to remain silent, the agents had to honor that request but

would have been able to enquire whether Shibin wished to speak further. Shibin’s assertion of a

desire to speak and his waiver of his rights enabled the agents to engage in further

communication with him.

CONCLUSION

For the foregoing reasons, the United States respectfully submits that the defendant’s

motion to suppress should be denied.

Respectfully submitted,

Neil H. MacBrideUnited States Attorney

By: /s/ Benjamin L. HatchJoseph E. DePadillaBrian J. SamuelsAssistant United States AttorneysAttorney for the United StatesUnited States Attorney’s Office101 West Main Street, Suite 8000Norfolk, VA 23510Office Number: 757-441-6331Facsimile Number: 757-441-6689E-Mail Address: [email protected]

[email protected] [email protected]

-15-


Certificate of Service

I hereby certify that on the 8th day of August, 2011, I electronically filed the foregoing

with the Clerk of Court using the CM/ECF system, which will send a notification to the

following:

James Broccoletti

Zoby & Broccoletti, P.C.

6663 Stoney Point S.

Norfolk, VA 23502

Counsel for defendant MOHAMMAD SAAILI SHIBIN

/s/ Benjamin L. Hatch

Assistant United States Attorney

United States Attorney’s Office

101 West Main Street, Suite 8000

Norfolk, VA 23510

Office Number: 757-441-6331

Facsimile Number: 757-441-6689

Email: [email protected]

-16-


mailto:[email protected]

Case 2:11-cr-00033-RGD -DEM Document 32-1 Filed 08/08/11 Page 1 of 5 PageID# 134

mohammad shibin filings

Documents