UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF NORTH CAROLINA

----------------------------------------------X
Ziyad Yaghi,
Petitioner,

Case No: 5:09-cr-00216-FL

v.
United States of America,
Respondent.
-----------------------------------------------X
EXPERT REPORT OF DAVID MILLER
Qualifications
I am a Professor of Sociology at the University of Bath, UK and earned my PhD in Sociology
in 1994. Sociology, generally, is the study of the organization, functioning, and classification
of human societies. Relevant to this case, I have spent a portion of my career studying the
sociology of expertise. My research in this area involves examining how expertise is created
and how it is used in society in relation to a variety of issues including scientific expertise
and specifically in relation to expertise in terrorism. I have studied the way in which terrorism
and political violence have been portrayed, going back to my doctoral thesis (in 1994), which
examined the conflict in Northern Ireland.1 I have also, since that time, been interested in the
way in which government and related institutions engage in public relations and propaganda
activities. More recently, I undertook a study on the way in which academia and the press
evaluated expertise in terrorism.2 This study used citation data to examine which experts
were most highly cited in scholarly journals and compared this with those most highly cited
in the global English language press. It found that the most highly cited academic experts
featured rarely in the press and conversely that those described as experts in the press were
not among the most highly cited in the scholarly literature. In some cases this appeared to be
because some of those cited in the press did not possess any real degree of expertise in the
topics on which they were quoted, but simply were members of intelligence, military or
policing agencies or were closely connected to them such as being involved in think tanks
with close links of that type. The approach taken to expertise in this work and in other similar
research is that of comparing and evaluating datasets against each other. This is important
because it allows the comparison of the way in which differing domains (the press, academia,
the courts, for example) treat expertise, while avoiding subjective judgements about
individual levels of expertise. In 2012 I was awarded a Global Uncertainties Leadership

1 Miller, David, Don't Mention the War: Northern Ireland, Propaganda and the Media London: Pluto, 1994.
2 Miller D. and Mills, T., 'The Terror Experts and the Mainstream Media: The Expert Nexus and its Dominance
in the News Media', Critical Studies on Terrorism, Volume 2, issue 3. December 2009, p. 414 437.

DECLARATION OF DAVID MILLER

Fellowship which runs from January 2013 to January 2016.3 This is a prestigious
competitive, peer reviewed, award from the Economic and Social Research Council, the main
public social science funding agency in the UK. It was awarded to further develop my
research on terrorism expertise, which I am currently completing.4 On issues of terrorism,
political violence and conflict I have published five books, four reports and more than thirty
articles and book chapters.
Introduction
Mr Kohlmann has no educational qualifications beyond an undergraduate degree in politics
and a Juris Doctor from the University of Pennsylvania Law School. He is not well respected
and is closely connected to individuals and organisations described as constituting a small,
tightly networked group of misinformation experts who have been instrumental in the rise
of Islamophobia1 He has been severely criticised by leading figures in his purported field of
expertise and moreover has been criticised by the High Court in England and Wales for
distorting evidence through selective quotations.2
Kohlmanns background and affiliations
Mr Kohlmann states in his report that he began researching terrorism in approximately
1997. At that stage he was an undergraduate at the Georgetown University. In February the
following year, he began an internship at the think tank, the Investigative Project on
Terrorism (IPT). There, he says, he was responsible for tracking North African militant
groups, and monitoring Islamist websites. He subsequently completed his graduate studies
and began studying law, but was encouraged by a former IPT colleague to return to IPT after
the September 11th attacks. He then worked at the IPT until 2004 whilst studying law, and
has referred to himself as having been basically the deputy head of the organisation at this
time.3
The IPT is a not-for-profit organisation founded and run by former journalist Steve Emerson.
Emerson claimed in 1995 that Islam sanctions genocide, planned genocide, as part of its
religious doctrine4 and that year famously attributed the Oklahoma City Bombing (carried
out by former US soldier Timothy McVeigh) to Middle Eastern Terrorists. In July 2011,
Kohlmann would similarly attribute the attacks in Norway to Muslims, claiming that,
Norway has had an increasing problem with these kind of asymmetric threats from al-Qaida
and its Central Asian allies.5 The actual perpetrator of the attack, the right-wing extremist
Anders Breivik, cited Kohlmanns former boss, Steve Emerson, twice in an Islamophobic
manifesto he wrote shortly before carrying out the attacks.6 In January 2015, Emerson
appeared on Fox News to discuss Europe's Muslim population and claimed that Birmingham,
England was an example of a 'totally Muslim [city] where non-Muslims just simply don't go
in'. After the claim attracted widespread publicity the British Prime Minister David Cameron
reportedly described Emerson as 'a complete idiot'.7
Steve Emerson and his former colleagues not only have a questionable record as analysts, but
Emerson himself has been accused of deliberately spreading misinformation. On one
occasion he presented Associated Press with a purported FBI dossier showing ties between
American Muslim organisations and radical Islamist groups.8 The Associated Press reporters
concluded [that] the dossier was created by Emerson and that [Emerson] had edited out all
phrases, taken out anything that made it look like his.9 The Center for American Progress
3 Global Uncertainties RCUK Global Uncertainties Leadership Fellows
http://www.globaluncertainties.org.uk/about/Leadership-Fellows.aspx
4 Global Uncertainties, Understanding and explaining terrorism: expertise in practise
http://www.globaluncertainties.org.uk/about/GU-fellows/Miller.aspx

DECLARATION OF DAVID MILLER

has identified Emerson and his IPT as part of a small, tightly networked group of
misinformation experts that peddle hate and fear of Muslims and Islam.10 Its research
discovered that the IPT shares its major donors with all of the other major Islamophobic
organisations it identified.11
In 2004, Kohlmann left the IPT, and law school, and set up his own terrorism research outfit,
Globalterroralert.com. Globalterroralert.com was a one man operation Kohlmann ran out of
his bedroom in a high rise apartment in New York. National Public Radio journalist Mary
Louise Kelly met Kohlmann in his bedroom-office, and described how he worked at a desk
two feet from his bed wearing what looks suspiciously like last nights pyjamas.12
Globalterroralert.com, operated until October 2007 when Kohlmann closed the site and
redirected traffic to www1.nefafoundation.org, which he said would be publishing all his
future work.13
The now defunct, NEFA Foundation, or Nine/Eleven Finding Answers Foundation, which
hosted Kohlmann for around five years, was a not-for-profit organisation based in Charleston,
South Carolina. It was set up in 2004 to [expose] those responsible for planning, funding,
and executing terrorist activities, with a particular emphasis on Islamic militant
organizations.14 Kohlmann was paid as an investigator by NEFA in 2006 and 200715 and
was listed as a Senior Investigator on its website in 2012.16 The NEFA Foundation was
neither well respected, nor especially prominent. In February 2008, Daniel Byman, a leading
terrorism expert, told the Charleston City Paper he had never heard of the organisation.17
The NEFA Foundation was reportedly privately funded18 and whilst little is publicly known
about its sources of income, IRS filings reveal that it has received grants from the Abstraction
Fund and the William Rosenwald Family Fund.19 Both these foundations are associated with
Nina Rosenwald, a major donor to neoconservative, pro-Israel and Islamophobic
organisations in the United States. A board member of the leading pro-Israel lobby group,
the American Israel Public Affairs Committee (AIPAC), Rosenwald, according to a profile in
The Nation magazine, is known for launching into anti-Arab anti-Palestinian tirades at
public forums.20 The Center for American Progress identified the William Rosenwald
Family Fund and the Anchorage Charitable Fund, which is run by Rosenwalds sister
Elizabeth Varet, as key financial backers of Islamophobic organisations in the United States:
Between 2001 and 2008, the Anchorage Charitable Fund and William Rosenwald
Family Fund contributed $2,818,229 to Islamophobic organizations. Among the
donations: $2,320,229.33 to the Middle East Forum; $437,000 to the Center for
Security Policy; $25,000 to the Clarion Fund; $15,000 to the Counterterrorism &
Security Education and Research Foundation; $11,000 to the David Horowitz
Freedom Center; and $10,000 to the Investigative Project on Terrorism.21
The Center for American Progress has identified these groups as part of Americas
Islamophobia network and claimed that its research frames Islam as an inherently violent
and antagonistic religion.22 The Abstraction Fund has donated to these same groups. In the
year it donated to NEFA, other grant recipients included the Center for Security Policy, the
David Horowitz Freedom Center and the Middle East Forum. It also donated to Committee
for Accuracy in Middle East Reporting in America (CAMERA), a pro-Israel media pressure
group, the Central Fund of Israel, a New York based tax-exempt charity registered in 197923
which distributes funds to settlers in the Occupied Territories,24 and the Zionist Organization
of America, an organisation on the far right of American Zionism.
Whilst working for the NEFA Foundation, Kohlmann was also a contributor to
Counterterrorism Blog, an outfit which ceased operations in March 2011, but described itself
DECLARATION OF DAVID MILLER

as a unique, multi-expert blog dedicated to providing a one-stop gateway to the

counterterrorism community.25 Counterterrorism Blog was founded by Andrew Cochran, a
US lobbyist whose clients included Steve Emerson and the IPT.26 The editor of the site was
the former journalist Douglas Farah, who headed a company, IBI Consultants, which
conducted paid investigative work for the NEFA Foundation and was also personally listed as
a NEFA investigator.
In his report Kohlmann refers to himself as now being a senior partner at Flashpoint Global
Partners, a New York-based security consulting firm. It has been registered with the New
York Department of State Division of Corporations since 1 February 2011 under the name
Flashpoint Global Partners LCC, but is incorporated in Delaware. It appears to be officially
registered there under the name Ej2 Communications Inc., which was incorporated on 12
February 2010. The registered address of the company is 111 East 14th Street in New York,
an address which was used by Kohlmann in 200627 and was the registered address for his
one-man consultancy, globalterroralert.com (indeed the domain globalterroralert.com
currently redirects to the website of Flashpoint Global Partners). On the leadership section
of the website Kohlmann is listed along with two partners: Josh Devon and Josh Lefkowitz.28
Lefkowitz is a former analyst at the Investigative Project and the NEFA Foundation. Josh
Devon is also a former IPT analyst who founded the SITE Intelligence Group (formerly the
SITE Institute) with another IPT alumni, the Israeli American Rita Katz.
Mr Kohlmanns expertise
Terrorism studies scholar Magnus Ranstorp cites Kohlmann as an example of charlatans
used as expert witnesses in legal proceedings, whose presence, he suggests, undermines
severely the credibility of the proceedings and makes a mockery of the principle of scientific
expertise.29 The former CIA analyst and terrorism expert, Philip Giraldi, has written:
Within the intelligence community and at the Pentagon, Kohlmann, like many of
his expert colleagues, is widely considered a phony who has somehow ingratiated
himself with those who want an affable young media resource who will say just
the right things when it comes to terrorism, keeping the public suitably alarmed
while exuding a facile expertise.30
Marc Sageman, a former Operations Officer for the CIA, who is perhaps the most respected
figure in the field of terrorism expertise, writes that Kohlmann and his work have very poor
standing in both the academic and intelligence communities, and describes him as a tireless
self-promoter, who has published very few peer reviewed articles or books.31 He is scathing
of Kohlmanns supposed expertise. He notes Kohlmanns lack of training in any of the
social sciences and the lack of integrity in his work,32 but also goes as far as accusing him
of the most egregious distortions of the evidence.33 A decade ago Sageman reviewed
Kohlmanns book, Al-Qaida's Jihad in Europe: the Afghan-Bosnian Network, for the
University of Pennsylvania Press. Al-Qaida's Jihad in Europe was published in 2004, and is
Kohlmanns only book. According to Sageman it is based on erroneous propaganda
set[ting] the tone to his lifes work.34 Sageman states, in an expert witness report, that he
recommended rejecting the book in 2004, warning the publisher that Kohlmann has
problems with reliability and one sided presentation of facts. He described the book as
sensationalistic, its claims as uncompelling, and described Kohlmanns handling of
evidence as cavalier, noting his practice of using data supporting his point, and, worse,
misinterpreting other, creating data to support his argument.35 Offering his opinion on an
expert report produced by Kohlmann in April 2014, Sageman concluded that:

DECLARATION OF DAVID MILLER

Kohlmann cherry picks evidence in a very biased way, often out of context;
intentionally ignores or deletes evidence contradictory to its claims; does not
demonstrate general background or much familiarity for the Bosnian and
Chechen Wars; conflates and misidentifies people; and occasionally fabricates
evidence by misquoting people. Mr. Kohlmanns disregard of social science
methodology compounds his lack of academic training and credentials.
Throughout his report, Mr. Kohlmann conflates jihad and terrorism and confuses
any sympathy for Muslim fighters defending Muslims against atrocities, like in
Bosnia and Chechnya, with material support for terrorism.36
Kohlmann has previously been accused of bias and misleading interpretation of evidence.
For example, Kohlmann submitted a report in the case of R v AV. The report, the High Court
noted in Secretary of State for the Home Department v AR and others, was significantly
undermined by its selective quotation from an interview with a valuable source, which was
sufficient to distort his views. This, combined with its reliance on detainee reporting and
the palpable hits secured by defence Counsel in the case, led the prosecution to abandon
reliance on any expression of opinion by Mr Kohlmann.37
Mr Kohlmanns expertise
Mr Kohlmann claims to have identified 'the principle relevant factors as to whether a person
or persons might fit the profile of a "homegrown" terrorist network'.38 These 'principle
relevant factors' are stated as follows:
The Formulation of Self-Selecting Schemes Aimed at Traveling Abroad to Join
Foreign Terrorist Organizations, and/or Achieving Imminent Acts of Physical
Violence;
The Acquisition of Automatic Weapons and Sniper Rifles (Including Requisite
Accessories Such As Sniper Scopes), Paramilitary Training Manuals, and the
Establishment of Makeshift Training Camps;
The Adoption of a Hardline Sectarian Religious Perspective, Often Identified With
the "Salafi-Jihadi" or "Takfiri" School (Evidenced by the Possession And/Or
Distribution of Extremist Ideological Materials);
The Use of Coded Language and Attempts at Logistical Subterfuge (i.e. Attempts to
Secret or Hide Ones Activities); and,
The Deliberative Collection and Redistribution of Large Quantities of Terrorist
Propaganda. 39
Mr Kohlmann does not provide an account of how these 'principle relevant factors' have been
identified and tested in his expert report. However, his methodology was discussed at length
in USA v. Osmakac. During Daubert proceedings in that case, Mr Kohlmann was questioned
by Judge Mary Scriven as to the scientific basis of his 'relevant factors' and as to whether his
theory had been subject to peer review. Peer review is the process whereby scholarly work is
reviewed anonymously by other scholars (peers) prior to publication and either rejected or
published (often after certain revisions). Though demonstrating a clear understanding of the
concept, Mr Kohlmann repeatedly implied in USA v. Osmakac that his work had been peer
reviewed, when in fact it has not, and attempted to distinguish between 'peer review' and
'formal peer review', the former seemingly denoting any discussion or dissemination of his
work. He claimed at one point that his 'peers would include a variety of individuals who are
both in academia as well as, in some cases, nongovernmental agencies, as well as some
independent individuals who I have worked and I do work with regularly'. Mr Kohlmann
also claimed that his honours thesis was peer reviewed, and referred to an article in the
Annals for the American Academy of Social Political Sciences as having been 'peer reviewed,
DECLARATION OF DAVID MILLER

but not formally peer reviewed'. The Annuls has confirmed that it has no peer review process
beyond review of issue proposals by the Editorial Advisory Board.40 Mr Kohlmann has made
similar misleading claims in previous cases. Under cross examination by Geoffrey Robertson
QC in 2007, Mr Kohlmann claimed that 'every paper that I write is extensively peer reviewed
by academics and by others around the world'.41 And in United States v. Paracha, Mr
Kohlmann testified that his 'written publications are submitted for comment and critique by
academics and peers in his field before publication'.42 In his expert report for the present
case, Mr Kohlmann cites several court judgements to the effect that his work is or has been
subject to peer review a 'considerable amount', according to one judgement.
In fact, Mr Kohlmann has never published a sole authored peer reviewed journal. The
bibliographic database Scopus presently contains three journal articles for Mr Kohlmann.
The first is a 2006 article in Foreign Affairs, which although well respected, it is arguably a
journalistic rather than academic publication. The second is the aforementioned article in the
Annals for the American Academy of Social Political Sciences. The third is a co-authored
article published in the quarterly African Security.
None of these publications include any discussion of his 'principle relevant factors'. In USA
v. Osmakac, Mr Kohlmann stated: 'These are certainly things that other experts and other
colleagues of mine that I've discussed with that have indicated that they also believe are
significant.' Mr Kohlmann, stated that the only place his 'factors' have published is his
Annals article. Under repeated questioning, he was therefore forced to concede that the
method he uses in this case has never been subject to peer review:
So I think the answer to your question is is that the paper in which I presented
these all together is the Annals. Now, I have certainly presented individual
factors in peer reviewed journals, but I have never presented all the factors
together in a formal peer reviewed journal.
In fact, even Mr Kohlmann's Annals article contains no reference to his 'principle relevant
factors'. Neither does it give any account of his methodology. Indeed, despite purporting to
examine 'theory and cases' of 'homegrown terrorists', the article has no theoretical content.43
His more recent co-authored Africa Security paper, , 'Bringing Global Jihad to the Horn of
Africa', makes no use of, or reference to Kohlmann's 'principle relevant factors', or indeed
any of Mr Kohlmann's work.44 In short, Mr Kohlmann's expertise has not been subject to any
peer review process. More than that though, he has not been able to give a coherent account
of his methods in cases in which he has testified. In the course of Daubert proceedings in
USA v. Osmakac, Mr Kohlmann referred to his analysis several times as 'Bayesian':
The way to do analysis in this -- these materials is a Bayesian analysis. It's taking
a sample set of cases and then doing a comparative analysis and looking for the
common threads that appear. It's not statistical...
...this is not a statistical study, it's not meant to be a statistical study. It's meant to
be looking at individual factors that appear in cases and assessing their
significance. But again, it's a Bayesian analysis, this is not a Fisherian analysis.
This shows Mr Kohlmann's basic ignorance of social scientific theory and methods. The
difference between Bayesian and Fisherian (or frequentists) statistics is epistemological and
is to do with different understandings of probability and different ways in which one might
draw inferences from data. Mr Kohlmann describes his own approach as Bayesian,
apparently believing that this justifies his inability to present any quantitative evidence in
support of his methodology. But far from not being statistical, the Bayesian approach is a

DECLARATION OF DAVID MILLER

school within statistics. It is an approach based around Bayes's theorem, a mathematical tool
describing the relationship between different probabilities.
Bayes's theorem is worth briefly considering, as ironically it illustrates a basic problem with
Kohlmann's methods. A social scientist might want to examine, for example, the relationship
between acts of terrorism and the 'Adoption of a Hardline Sectarian Religious Perspective' one of Mr Kohlmann's 'factors'. Bayes's theorem can help conceptualise the relationship
between these two factors. It is usually expressed as follows:
P(A|B) = P(B|A) P(A)/P(B)
Here A and B are particular outcomes and P is the probability of that outcome. In our
example, let's say that A is an American committing an act of terrorism, and B is an
American adopting a 'hardline sectarian religious perspective'. P(A|B) is what we are
interested in. It is the probability of an American who has adopted a 'hardline sectarian
religious perspective' committing an act of terrorism. P(B|A) is, inversely, the probability of
an American who has committed an act of terrorism having adopted a 'hardline sectarian
religious perspective'. P(A), meanwhile, is the overall probability of an American
committing an act of terrorism, and P(B) is the overall probability of an American adopting a
'hardline sectarian religious perspective'. Bayes's theorem points to the information which
must be known in order to draw certain inferences and shows that the relationship between
different probabilities is not as straightforward as is sometimes intuitively thought. In this
case, even if it were true that the overwhelming majority of Americans who had committed
an act of terrorism had previously adopted a 'hardline sectarian religious perspective', it does
not follow that someone who has adopted a 'hardline sectarian religious perspective' will
likely commit an act of terrorism. Not only that, Bayes's theorem proves that one cannot
make any such logical inference.
Mr Kohlmann's misguided invocation of 'Bayesian analysis' it likely due to a widely read and
discussed article on terrorism research authored by leading terrorism expert and former CIA
analyst, Marc Sageman. In 'The Stagnation of Research on Terrorism', Sageman wrote:
Aggressive FBI field offices identify many young men based on nonspecific
indicators, set them up in sting operations, and arrest them. According to
Bayesian probability models, the odds that these young men would ever have
turned to violence are low. But it is difficult to teach lawyers and juries Bayesian
probability...45
The relevant point here is that one cannot necessarily draw an inference on the likelihood of
an individual committing an act of terrorism on the basis of characteristics observed amongst
those who do. This is precisely what Mr Kohlmann seeks to do.
Mr Kohlmann in fact readily concedes that he cannot offer any 'statistical determination' to
support his 'seven factors' theory, and in addition to the claim that he uses Bayesian analysis,
refers to his method as 'comparative analysis'.46 He states that this 'basically involves taking
a variety of different sources, identifying whether or not these sources are reliable and
credible and then juxtaposing these sources against each other to pull out a common
narrative.' This explanation is more suggestive of an historical method. Comparative
analysis generally refers not to the assessment of multiple sources but multiple causal factors
observable in different cases. Qualitative comparative analysis, for example, is a social
scientific method developed to identify relevant causes associated with a particular event. Its
adherents claim that it allows for the examination of complex causality in a relatively small
number of cases not allowing for statistical inference. Such an approach would seem
amenable to the analysis of cases of terrorism. But Mr Kohlmann's approach shows no
DECLARATION OF DAVID MILLER

evidence of the sort of analytical rigour necessary as much for this sort of analysis as for a
statistical approach, whether 'Bayesian' or 'Fisherian'. An adequate application of such a
method would, for example, require a clear procedure for the selection of cases, including
cases where the particular event was not observed. Without this methodological rigour, it is
simply not possible to assess relevant causal factors without potentially confirming the
rationale (conscious or not) for the selection of cases.
Mr Kohlmann admits that his theory about factors has 'crystallized' through his consultancy
work for the Department of Justice and with the FBI, and states that his 'factors' are those
'that tend to surface in the evidence surrounding homegrown terrorism cases.'47 This means
not only that his theory has not been subject to peer review, but that it has been developed in
the small number of cases in which his unscientific claims are expected to be useful in
securing a prosecution. The evidential problem here is obvious. Mr Kohlmann is drawing
(unsound) conclusions based on the confluence of factors in cases in which he is called to
testify, the presence of which may as likely reflect the fact that Kohlmann being called as a
expert, as the probability of the person in that case in fact being a 'violent extremist' or part of
'a "homegrown" terrorist network'.
Mr Kohlmann does claim a wider evidential basis for his theory, referring to 'large data sets'
drawn especially from 'social networking forums related to terrorist organizations'.48
However, he has presented no evidence to suggest that this data has been collected in a
methodologically rigorous fashion or, assuming it has, that he is competent enough to draw
any sound evidential conclusions from it. Indeed, what little we know about Mr Kohlmann's
methods from his cross examination in terrorism cases suggests that his work is marred by
the most rudimentary fallacies. To give just one example, in the Daubert proceedings in USA
v. Osmakac, Mr Kohlmann states that 'almost everybody who's radicalized in this country is
downloading terrorist propaganda'. 49 Not only is this an unsound basis on which to draw
conclusions, for the reasons outlined above, but there is moreover no evidence that either
'radicalisation' or 'terrorist propaganda' have been clearly defined. Indeed elsewhere in the
same proceedings Mr Kohlmann states: 'By radicalizing, I mean digesting propaganda from
extremists'.50 Radicalisation, then, is defined with reference to 'The Deliberative Collection
and Redistribution of Large Quantities of Terrorist Propaganda', which is in turn used as
evidence of radicalisation. This type of fallacious and tautological reasoning is regrettably
endemic in Mr Kohlmann's work.
I, David Miller, declare under penalty of perjury under the laws of the state of North Carolina
that the foregoing is true and correct.

Signed this 19th day of January, 2016.

________________________
David Miller, Declarant
Strasbourg, France
DECLARATION OF DAVID MILLER

Wajahat Ali et al, Fear Inc.: The Roots of the Islamophobia Network in America, Center for American
Progress (August 2011), http://www.americanprogress.org/issues/2011/08/pdf/islamophobia.pdf

Secretary of State for the Home Department v AR and others [2008] EWHC 2789. Available at:
http://www.bailii.org/ew/cases/EWHC/Admin/2008/2789.html
3
R. v. F, Cross Examination of Kohlmann by Geoffrey Robertson QC, 23 January 2007.
http://powerbase.info/images/1/15/Kohlman_cross_robertson_qc.pdf
4
Cited in John F. Sugg, Steven Emerson's Crusade, Extra!, January/February 1999.
http://www.fair.org/index.php?page=1443
5
Spencer Ackerman, Were Oslos Terror Blasts Caused by Car Bombs?, Wired, 22 July 2011.
http://www.wired.com/dangerroom/2011/07/were-oslos-terror-blasts-caused-by-car-bombs/
6
Eli Clifton Anders Breivik Recommended Popular Anti-Muslim Documentary Obsession For
Further Study Think Progress Security, Jul 26, 2011 at 1:28 pm
7
Matthew Holehouse, and Raf Sanchez, 'David Cameron: US terror "expert" Steve Emerson is a
"complete idiot"', Telegraph, 12 Januarty 2015, http://www.telegraph.co.uk/news/uknews/terrorismin-the-uk/11340399/David-Cameron-US-terror-expert-Steve-Emerson-is-a-complete-idiot.html
8

Wajahat Ali et al, Fear Inc.: The Roots of the Islamophobia Network in America, Center for
American Progress (August 2011), http://cdn.americanprogress.org/wpcontent/uploads/issues/2011/08/pdf/islamophobia.pdf
9
Wajahat Ali et al, Fear Inc.: The Roots of the Islamophobia Network in America, Center for
American Progress (August 2011), http://cdn.americanprogress.org/wpcontent/uploads/issues/2011/08/pdf/islamophobia.pdf
10
Wajahat Ali et al (2001), Fear Inc: The Roots of the Islamophobia Network in America, Center for
American Progress, August 2011.
http://www.americanprogress.org/issues/2011/08/pdf/islamophobia.pdf
11
Wajahat Ali et al, Fear Inc.: The Roots of the Islamophobia Network in America, Center for
American Progress (August 2011), p.48. http://cdn.americanprogress.org/wpcontent/uploads/issues/2011/08/pdf/islamophobia.pdf
12
Mary Louise Kelly, All Things Considered, National Public Radio, 8 June 2006.
http://www.npr.org/templates/story/story.php?storyId=5472132
13
Globalterroralert.com, http://www.globalterroralert.com/ [Accessed 29 February 2008].
14
Nine Eleven Finding Answers Foundation Inc, Form 990s for the Year Ending 31 January 2011,
p.1.
15
Nine Eleven Finding Answers Foundation Inc, Form 990s for the Years Ending 2006 and 2007.
16
Internet Archive, NEFA Foundation > About Us,
https://web.archive.org/web/20120706143639/http://www.nefafoundation.org/index.cfm?pageID=26
17
Greg Hambrick, Charlestons Counter-Terrorism Unit, Charleston City Paper, 20 February 2008.
18
Susan Schmidt, 'Imam From Va. Mosque Now Thought to Have Aided Al-Qaeda', Washington
Post, 27 February 2008. Available at: http://www.washingtonpost.com/wpdyn/content/article/2008/02/26/AR2008022603267_2.html
19
Abstraction Fund, Form 990 for the calendar year 2009, Schedule A. William Rosenwald Family
Fund, Inc., Form 990 for the calendar year 2009, Schedule A.
20
Max Blumenthal, The Sugar Mama of Anti-Muslim Hate, The Nation, 13 June 2012.
http://www.thenation.com/article/168374/sugar-mama-anti-muslim-hate
21
Wajahat Ali et al, Fear Inc.: The Roots of the Islamophobia Network in America, Center for
American Progress (August 2011), p.21. http://cdn.americanprogress.org/wpcontent/uploads/issues/2011/08/pdf/islamophobia.pdf
22
Wajahat Ali et al, Fear Inc.: The Roots of the Islamophobia Network in America, Center for
American Progress (August 2011),
http://www.americanprogress.org/issues/2011/08/pdf/islamophobia.pdf
23
Central Fund of Israel Form 990 for the year ending 31 January 2012.24 Moshe Kohn, Caring,
Jerusalem Post, 27 September 1989.
25
Counterterrorism Blog, 'About'. http://counterterrorismblog.org/about/
DECLARATION OF DAVID MILLER

26

See for example Public Policy Partnership Lobbying Report for Steven Emerson 2004,
http://www.powerbase.info/images/a/ad/Steven_Emerson_Public_Policy_Partnership_Year_End_Rep
ort_2004.pdf
27
Nine Eleven Finding Answers Foundation Inc, Form 990 2006, Schedule A, p.1.
28
Flashpoint Global Partners, About Us > Leadership. http://flashpoint-intel.com/about-us/leadership/
29
Ranstorp, Magnus 2009. Mapping terrorism studies after 9/11: An academic field of old problems
and new prospects. In Richard Jackson, Marie Breen Smyth & Jeroen Gunning, eds. Critical
Terrorism Studies: A new research agenda. London: Routledge, p.28.
30
Philip Giraldi, Terrorism Experts On Parade, Antiwar.com, 28 July 2011.
http://original.antiwar.com/giraldi/2011/07/27/terrorism-experts-on-parade/
31
Redacted Expert Report of Marc Sageman in USA v. Babar Ahmad, 25 April 2014, p.22. Available
from: http://www.sacc.org.uk/sacc/docs/sageman-%20expert-report-fully-redacted-4.pdf
32
Redacted Expert Report of Marc Sageman in USA v. Babar Ahmad, 25 April 2014, p.22. Available
from: http://www.sacc.org.uk/sacc/docs/sageman-%20expert-report-fully-redacted-4.pdf
33
Redacted Expert Report of Marc Sageman in USA v. Babar Ahmad, 25 April 2014, p.74. Available
from: http://www.sacc.org.uk/sacc/docs/sageman-%20expert-report-fully-redacted-4.pdf
34
Redacted Expert Report of Marc Sageman in USA v. Babar Ahmad, 25 April 2014, p.24, ft.14.
Available from: http://www.sacc.org.uk/sacc/docs/sageman-%20expert-report-fully-redacted-4.pdf
35
Marc Sageman, email to Peter Agree, University of Pennsylvania Press, 10 June 2003, quoted in
Redacted Expert Report of Marc Sageman in USA v. Babar Ahmad, 25 April 2014, p.22. Available
from: http://www.sacc.org.uk/sacc/docs/sageman-%20expert-report-fully-redacted-4.pdf
36
Redacted Expert Report of Marc Sageman in USA v. Babar Ahmad, 25 April 2014, p.88. Available
from: http://www.sacc.org.uk/sacc/docs/sageman-%20expert-report-fully-redacted-4.pdf
37
Secretary of State for the Home Department v AR and others [2008] EWHC 2789. Available at:
http://www.bailii.org/ew/cases/EWHC/Admin/2008/2789.html
38
Evan F. Kohlmann, Expert Report I U.S. v. Daniel Patrick Boyd et al., April 2011.
39
Evan F. Kohlmann, Expert Report I U.S. v. Daniel Patrick Boyd et al., April 2011.
40

Email from Dr. Phyllis Kaniss, Executive Director of the American Academy of Political and Social Science
to David Miller, Tue, 19 Aug 2008 10:44:23 -0400.
41
Cross Examination of Kohlmann by Geoffrey Robertson QC. 23 January 2007.
http://powerbase.info/images/1/15/Kohlman_cross_robertson_qc.pdf
42
United States v. Paracha (Southern District of New York, 2005)
43
Evan F. Kohlmann, Homegrown' Terrorists: Theory and Cases in the War on Terror's Newest Front', The
ANNALS of the American Academy of Political and Social Science, Vol. 618, No. 1, 95-109 (2008).
44

Lorenzo Vidino, Raffaello Pantucci, and Evan Kohlmann. 'Bringing Global Jihad to the Horn of
Africa: Al Shabaab, western fighters, and the sacralization of the Somali Conflict.' African Security
3.4 (2010): 216-238.
45
Marc Sageman, 'The Stagnation of Research on Terrorism', The Chronicle of Higher Education, 30
April 2013.
46
USA v. Osmakac, transcript of Daubert proceedings.
47
USA v. Osmakac, transcript of Daubert proceedings.
48
USA v. Osmakac, transcript of Daubert proceedings.
49
USA v. Osmakac, transcript of Daubert proceedings.
50
USA v. Osmakac, transcript of Daubert proceedings.

DECLARATION OF DAVID MILLER