Another is "God curse Zerkin and MacMahon, " a reference to Gerald Zerkin and Edward MacMahon, his lead defense attorneys.

NPR: Moussaoui Courts Death, and the Media, at Trial

"Jurors might have found that something was true, but found that it was not mitigating, so you have to factor that in as well, " Zerkin told reporters.

CNN: Moussaoui jury split on mitigating factors

Gerald Zerkin, a defense attorney for Moussaoui, said after the verdict that apparent inconsistencies in the jurors' decisions "are always going to be found" in such capital cases.

CNN: Moussaoui jury split on mitigating factors