-cites many killings by enforcers

The prosecution in the Shaheed Roger Khan drug trial yesterday released a memorandum of law submitted in support of its motion for a pretrial ruling to admit evidence regarding uncharged criminal activity by Khan.

According to the memorandum, Khan, indicted for trafficking of cocaine in the US, not only ordered the murder of Devendra Persaud, but also that of boxing coach Donald Allison.

The document, which was filed in the New York Eastern District Court on Monday, seeks to have the court admit at trial evidence of Khan’s retaliation against Persaud, who was once part of his organisation, which included threats to Persaud and his family, seizing Persaud’s car, and ultimately, ordering Persaud’s murder; as well as the murder of Allison.
According to the document, though this conduct was not charged in the indictment, it constituted direct proof of the accused’s continuing criminal enterprise and narcotics conspiracy and the evidence was admissible under Rule 404(b).

Further, the prosecution gave notice that it would seek to offer evidence of Khan’s criminal conduct in Vermont and subsequent bail jumping if necessary to rebut defences advanced by Khan, including lack of knowledge of drug trafficking, pursuant to Rule 404(b).

The prosecution said it would establish at trial that Khan was the leader of a violent drug trafficking organisation (the “Khan Organisation”) that was based in George-town, Guyana, from at least 2001 until his arrest in June 2006.

“Khan and his co-conspirators obtained large quantities of cocaine, and then imported the cocaine into the Eastern District of New York, among other places, where it was further distributed,” the memorandum said. “Khan was ultimately able to control the cocaine industry in Guyana, in large part because he was backed by a para-military squad that would murder, threaten, and intimidate others at Khan’s direction. While Khan’s enforcers killed many people as part of a battle among political factions in Guyana, they also committed violent acts and murders on Khan’s orders that were directly in furtherance of Khan’s drug trafficking conspiracy.”

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