Page:Substitution for the Testimony of Khalid Sheikh Mohammed.pdf/2

 available to testify in this courtroom under oath and subject to perjury he would have said what is contained in these statements.

Although you do not have the ability to see the witness's demeanor as he testifies, you must approach these statements with the understanding that they were made under circumstances designed to elicit truthful statements from the witness. In evaluating the truthfulness of these statements, you should consider all other evidence in this case, including all exhibits, regardless of which side may have produced the exhibit, and all other witness testimony including summarized statements of other enemy combatant witnesses, that tends to either corroborate or contradict the accuracy of this witness's statements. It is solely up to the jury to decide how much, if any, of any witness's testimony to credit.

1. Sheikh Mohammed described his role in the al Qaeda leadership. He said he was never a member of al Qaeda's Shura council. The highest position that he attained while in al Qaeda was Chief of External Operations, which was decreed in writing by Bin Laden four months before Sheikh Mohammed's arrest in March 2003.

2. In October 2000, Bin Laden appointed Sheikh Mohammed as head of all media operations for al-Qaeda. He was also in charge of the 9/11 operation. Page 2 of 58