Mr. Abdel Rahman, who is blind, is named in the indictment as the "intellectual leader" of a "jihad organization" whose purpose was to punish the United States because it was an "infidel nation" that supported Israel as well as the Egyptian Government, which he bitterly opposes.

They discovered that the four men who carried out the attack, which killed 6 and wounded more than 1,000, had ties to Sheik Omar Abdel Rahman, whom they charged with leading a worldwide "jihad organization" that had begun plotting to kill Americans as early as 1989.

Among the elements in the case that the Government needs to prove is the existence of a "jihad organization" that plotted terrorist acts against the United States.

This would buttress the defense argument that in fact, there is no "jihad organization" planning "a war of urban terrorism against the United States," as the prosecution has said.

Mr. Salem is a crucial witness in the Government's attempt to prove that the 11 men were actually a "jihad organization" that plotted to destroy New York landmarks and assassinate local politicians.

More recently, after deadly terror attacks in Kashmir and New Delhi in October and December, which India said were the work of two Pakistani-based groups, he arrested the leaders of these jihad organizations and began shutting them down.

Mr. Salem is the linchpin in the Government's attempt to prove the 11 Muslim men on trial were a "jihad organization" bent on "waging a war of urban terrorism" against the United States.

The Government contends that the trade center bombing was part of a conspiracy by a "jihad organization" aimed at waging a "war of urban terrorism against the United States."

The effort, the papers say, was undertaken by a "jihad organization" that had "headquarters" in several American cities and ties to similar groups in other countries.

The document presented to Judge Mukasey says that a "jihad organization" came into existence in the late 1980's, well before the Kahane assassination.