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UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION

CRIMINAL NO. 13-20772

UNITED STATES OF AMERICA

Plaintiff,

HON. GERSHWIN DRAIN

RASMIEH ODEH
Defendant.

AFFIDAVIT OF DEFENSE COUNSEL

I, Michael E. Deutsch, first duly sworn, declare and state the following:
1. This affidavit is submitted as an Offer of Proof, outlining evidence that
could have been presented and is presented now, in support of the
Defendant's (re-)application for bond pending her sentencing, now
scheduled for March 10, 2014.
2. Your affiant is prepared to submit the following evidence in support of
reconsideration of the Court's order denying Ms. Odeh bond pending her
sentencing date:
a. The testimony of Attorney James Fennerty who has known Ms. Odeh
since meeting her in Amman, Jordan in 1984, and developed a close
1

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friendship with her after she moved to Chicago. If released Ms. Odeh
can stay at the Fennerty home, and he would assume custodial
responsibility for her and guarantee her appearance for sentencing.
b. Ms. Lisa Kosowski is an attorney living in Chicago---and the daughter
of a Holocaust survivor---and has known Ms. Odeh since 2004. Sh is
a member of Jewish Voices for Peace, and on the Board of Arab and
Jewish Partnership for Peace and Justice in the Middle East. She
would testify that Ms. Odeh, to her observation and knowledge, is
deeply committed to her community and her work in Chicago that she,
Ms. Kosowski, believes without question that Ms. Odeh would not
flee and would obey the orders of the Court and appear for sentencing.
c. Similarly, Rev. Don Wagner of Chicago is a member of the clergy of
the Presbyterian Church of the United States, and has known Ms.
Odeh through her work since 2008. Rev. Wagner is also the National
Program Director of the Palestinian Liberation Center, a church
project working to help victims of torture, particularly children,.
Previously he was a Professor at North Park University in Chicago,
and he and his students have met with Rasmea to learn of her work
with Palestinian youth. He maintains that, in his experience, Ms. Odeh

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is a most honorable woman, and if released, would certainly appear

for all her required court dates and otherwise as the Court directs.
d. In addition, attached as Exhibit #1 are letters from the staff of 8'h Day
Center for Justice, an organization of the Catholic Church in Chicago;
the National Network of Arab-American Communities: and Rev.
Daniel Dale, Senior Minister at the Wellington Avenue United Church
of Christ; all affirming that that Ms. Odeh is not a flight risk and
calling on the Court to exercise compassion. (Ex. # 1)
3. Also attached is a letter from Dr. Mary Fabri, who is known to the Court
from the October hearing, who raises serious concerns about her sudden
imprisonment, and how that is likely to trigger serious PTSD episodes.
(Attached as Exhibit #2)
4. The defense also submits that there are several homes here in Chicago,
whose owners are willing to post their deeds as surety for Ms. Odeh. The
total value of the involved properties exceeds $500.000.
5. Also attached is a petition signed by members Ms. Odeh's Chicago
community whom she has mentored and assisted, who join in urging the
Court to allow her release. (Exhibit 3)

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Signed and sworn to at Chicago, Illinois

this 13th day of November, 2014.

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Michael E. Deutsch
Attorney for Rasmieh Odeh

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