In a 10-page motion filed in a court here, Rana's lawyer Patrick Blegen said given the "complexity of the case", his client should be entitled to know "with specificity what material support he is alleged to have provided" to terrorism.
"The superseding indictment is not a clear apprisal of the allegations against the Defendant. Rather, by simply reciting the language of the statute, the superseding indictment keeps the allegations vague and prevents Defendant from properly preparing a defence," Blegen said in the motion.
He said the government need not identify all of the evidence it will produce, but should point out what the allegations are, rather than hide behind the "vague and amorphous language of the statute".
Each count in the indictment against Rana lists that he provided material support to terrorism in the form of "personnel", "tangible property", "money", "currency" and "false documentation, and identification".
Neither the superseding indictment, nor the discovery provided by the government so far reveal what these things are, Blegen said. "There is no inkling of what these things might be," he added.
The superseding indictment alleges that Rana provided approval for the use of an immigration office, sent emails, printed business cards and provided co-accused David Headley assistance with obtaining a Visa.
While these items represent the alleged "false documentation and identification" charge, nothing in the indictment or in the government’s response identifies the personnel, tangible property, money or currency in detail.
"If the charges are limited to what is described in the Government's response, then each of the allegations aside from 'false identification and documentation' should be stricken. Otherwise, the government should be required to identify the 'personnel', 'tangible property', 'money' and 'currency' that it has alleged.
"Should the defence be required to sift through all of the discovery to find anything that possibly fits under the absurdly wide umbrella of 'tangible property'," Blegen added.
Rana, who has pleaded not guilty to providing support to the Mumbai terror attacks, had in February asked the government to provide "a bill of particulars" - specific details about the "material support and resources" he allegedly provided to terrorist plots.
The government argued that such a bill is not necessary because the superseding indictment provides more detail than required, and because it is providing extensive discovery.
