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linked - Investigating the Terror

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We have reached several conclusions regarding Williams' testimony.<br />

First, Williams lacked <strong>the</strong> requisite scientific knowledge to testify<br />

competently in this area. When Jourdan initially discussed <strong>the</strong> calculation<br />

of potential urea nitrate, Williams appeared to Jourdan not to understand<br />

<strong>the</strong> concept of a limiting reagent. His testimony makes clear that he<br />

never learned <strong>the</strong> concept. Urea is not always <strong>the</strong> limiting reagent and<br />

was apparently not <strong>the</strong> limiting reagent here. Moreover, in his<br />

memorandum Jourdan explicitly defines limiting reagent as<br />

stoichiometrically you run out of it first and finds nitric acid to be <strong>the</strong><br />

limiting reagent based on <strong>the</strong> information he was given. Accordingly,<br />

Williams' testimony was inconsistent with <strong>the</strong> Jourdan memorandum.<br />

Moreover, assuming that urea was <strong>the</strong> limiting reagent in this case,<br />

Williams' numbers do not add up. Because, as earlier noted, 60 pounds<br />

of fully reacted urea will produce 123 pounds of urea nitrate, 1200 pounds<br />

of urea will produce a <strong>the</strong>oretical (100% yield) of 2460 pounds of urea<br />

nitrate. A 90% yield would produce 2214 pounds (not 2100 pounds), and<br />

a 60% to 70% yield would produce 1476 to 1722 pounds (not 1200 to 1800<br />

pounds). The errors in Williams' calculations conveniently produced a<br />

range that included <strong>the</strong> exact amount of urea nitrate--1200 pounds--that<br />

he later testified was used in <strong>the</strong> Trade Center bombing.<br />

Second, Williams' discussion of laboratory yield was problematic.<br />

Williams testified that in a laboratory type environment <strong>the</strong> [b]est case<br />

scenario would be a yield in <strong>the</strong> neighborhood of 90 percent. In his OIG<br />

interview Williams said he got <strong>the</strong> 90% figure from Whitehurst or<br />

Burmeister, although <strong>the</strong>y do not confirm this. Assuming <strong>the</strong>y said it, we<br />

never<strong>the</strong>less question Williams' choice of words, which implied that his<br />

testimony about laboratory yield was based on his own expertise. A<br />

laboratory yield for a chemical reaction is obviously outside Williams'<br />

area of expertise. He told us in his OIG interview that he had no way of<br />

knowing, independent of <strong>the</strong> chemists, <strong>the</strong> accuracy of <strong>the</strong> 90% number,<br />

but believed he could rely on <strong>the</strong> opinion of o<strong>the</strong>r experts in his<br />

testimony. An expert may rely on opinions of o<strong>the</strong>r experts if this is <strong>the</strong><br />

normal practice in <strong>the</strong> field. See Fed. R. Evid. 703. Accordingly, Williams<br />

would have been fully justified, in rendering his own opinions, in relying<br />

on <strong>the</strong> chemist's statement about yield. For example, he could have<br />

testified, My opinion is based in part on <strong>the</strong> statement of Chemist W, who<br />

told me 90% is <strong>the</strong> best yield. But if he had so testified (with an<br />

attribution for <strong>the</strong> yield statement), <strong>the</strong> court would have known on whose

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